Privacy Policy

As of 25.05.2018, Regulation 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data becomes applicable, also known by the acronym GDPR (General Data Protection Regulation).

1. General Information
   1.1. Data Controller

The operator that processes personal data is:

S.C. HORIZON X S.R.L.
Bucharest, Sector 1, Dacia Boulevard, no. 15, floor 2, room 15
C.U.I. RO 53151268
J2025099086005
hello@horizonx.eu

1.2. Data Protection Officer (DPO)

What is Personal Data?
“Personal data” means any information relating to an identified or identifiable natural person (“data subject”), in particular by reference to an element of identification, such as a name, an identification number, location data, an online identifier, or to one or more elements specific to the physical, physiological, genetic, mental, economic, cultural or social identity thereof.

What Does Processing of Personal Data Mean and What Data Does S.C. HORIZON X S.R.L. Process?
“Processing” means any operation or set of operations performed on personal data or sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or modification, extraction, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

S.C. HORIZON X S.R.L. collects the following data:

• identification data: surname, first name, series and number of identity document, correspondence address, email, telephone (fixed, mobile, fax), online identifier;
• employee signature;
• client signature;

other information derived as a result of processing carried out by S.C. HORIZON X S.R.L., such as:

• unique identifier generated at the level of S.C. HORIZON X S.R.L. for each client individually, contractual history, financial history, specific information about products and services contracted from S.C. HORIZON X S.R.L. and the manner in which the client has used them;
  session cookies used to improve website performance;

What are cookies and how are they used?

Cookies are small files, generally consisting of a string of characters, or parts of a file, which are saved in the browser used by the computer, phone, tablet or any other device through which the website is accessed online. Each subsequent time the website is accessed, the browser used sends this file to the server of that website, for the purpose of allowing identification of a visitor who has returned to the website.

In general, websites use cookies to facilitate providing visitors with functionalities that cannot be provided without them by the http protocol, a text protocol most commonly used for accessing information online from web servers (www). These functionalities consist of managing user sessions, maintaining an authenticated session, maintaining preferences on a visited page (for example, aspects related to the functionality or graphic display of pages), keeping products in a shopping cart and others.

When a person accesses the website as a visitor, a cookie is sent to their internet browser and saved on the hard disk of their computer, but they can block the saving of cookies by changing their browser settings.

Cookies may store information that is personal in nature (for example, a visitor’s identification code, personalized preferences or a history of visited pages). This information is not generated by cookies, but by the visitor, when they complete online forms, register on the website, use electronic payment systems, etc. Although cookies are stored in the memory of the computer, phone, tablet or any other device used to access a website, cookies cannot access or read other information stored on that device.

Cookies are not viruses, are not compiled as code and cannot be executed. Consequently, they cannot self-copy, cannot spread to other networks to generate certain actions and cannot be used to spread viruses.

Depending on duration, cookies can be session cookies or persistent cookies.
Session cookies have a temporary storage duration, limited only to the duration of the session in which a particular visitor accesses the website. At the moment the session or browser is closed, all stored information is deleted.

Persistent cookies are stored in the device used by the visitor and are not deleted at the moment the session or browser is closed.

Web browsers provide functionality for setting the security level of information, allowing visitors to choose that their preferences not be recorded, thus blocking the use of any cookie by changing the browser settings. To use the functionality of setting the level of acceptance of cookies, in most cases the “Settings” / “Internet options” section is accessed, the “Privacy and Security” / “Privacy” sub-section from the browser menu (depending on the browser used).

Disabling the option to accept cookies may result in the inability to access some of the most important sections of the website. For this reason, it is recommended to accept cookies from websites you consider trustworthy. At any time you wish, you have the possibility to delete the cookies stored in the device you use, by accessing the “Settings” / “Safety” section, the “Privacy and Security” / “Delete browsing history” sub-section from the browser menu (depending on the browser used).

4. Where Does S.C. HORIZON X S.R.L. Obtain the Personal Data It Processes?

S.C. HORIZON X S.R.L. processes personal data relating to the Client, to the Client’s representatives, legal or conventional, as well as to persons whose data are provided by the Client to S.C. HORIZON X S.R.L., in order to obtain a product or to perform an operation/provide a service. The natural persons whose personal data are processed are referred to as “Data Subjects”.

S.C. HORIZON X S.R.L. addresses the following data subjects: its own employees, clients (even after the contractual relationship has ended), potential clients, candidates who wish to be employed within S.C. HORIZON X S.R.L., visitors to the website of S.C. HORIZON X S.R.L., clients who take courses offered by S.C. HORIZON X S.R.L.

The data are obtained directly from the Client and/or from a representative of the Client (at the moment when forms or documents of S.C. HORIZON X S.R.L. are completed, a webpage is accessed, or through other means of communication). In addition, S.C. HORIZON X S.R.L. may obtain the above data by consulting external sources (public institutions and authorities, public registers, electronic databases, information available online or third parties authorized).

5. For What Purposes Does S.C. HORIZON X S.R.L. Process Personal Data?

The purposes for which S.C. HORIZON X S.R.L. processes personal data are:

• provision of services through all available channels for this purpose (physical locations, internet, telephone, etc.);
• performing economic, financial and/or administrative management activities within S.C. HORIZON X S.R.L.;
• centralizing operations and maintaining an internal database in which to store information regarding data subjects, in order to be used by the departments and structures of S.C. HORIZON X S.R.L. in their activities;
• contacting the Client/other data subject through means of communication for the purpose of informing/notifying them of information about contracted products (eg expiration date, non-performance of obligations, modification/completion of characteristics, costs, functionalities, benefits);
• provision of support services for requests from the Client/data subject (eg additional information about products, updating some identification data, resolving requests, complaints and petitions filed), both at the physical locations of S.C. HORIZON X S.R.L. and through means of communication (phone/email/mail);
• creating or analyzing profiles to improve products/services, for personalized/general promotion, for carrying out direct marketing activities through any means of communication (phone/email/mail/fax/sms or advertisements addressed directly and specifically to a certain person) if the Client has accepted this;
• analyzing the behavior of the Client/anyone accessing the website, through the use of cookies, both those of S.C. HORIZON X S.R.L. and those of third parties, for the purpose of providing general or particularized content, offers adapted to the interests of users;
• conducting internal analysis (including statistical analysis), both regarding products/services and regarding the client portfolio;
• archiving both in physical and electronic format of documents;
• resolving disputes, investigations or any other petitions/complaints/requests to which S.C. HORIZON X S.R.L. is a party;
• for fulfilling legal obligations (drawing up salary documents, reporting to entitled public institutions).

6. On What Grounds Does S.C. HORIZON X S.R.L. Process Personal Data?

S.C. HORIZON X S.R.L. processes personal data for the purposes mentioned above, based on the following grounds:

based on the Client’s explicit consent;
for the performance of a contract to which the Client/data subject is party (provision of services/products), to take pre-contractual steps at the Client’s request or to provide the Client with information about products and services offered by S.C. HORIZON X S.R.L.;
based on a legal obligation incumbent on S.C. HORIZON X S.R.L. (eg fraud identification and prevention);
based on the legitimate interest of S.C. HORIZON X S.R.L. (eg centralization of operations, operation of an internal database, fulfillment of current operations for carrying out activities, development and improvement of services, ensuring a high level of security both at the level of computer systems and at the level of physical locations, in particular regarding the discovery and minimization of risks that may affect S.C. HORIZON X S.R.L.).

7. What Are the Consequences of Refusing to Provide Personal Data?

The processing of personal data requested by S.C. HORIZON X S.R.L. through forms/other communication channels is mandatory, except where processing is based solely on the Client’s consent. In this case, the Client will be informed that the provision of data or consent is optional. In other cases, refusal will make it impossible for S.C. HORIZON X S.R.L. to provide services or products.

7. Who Are the Recipients of Personal Data Processed by S.C. HORIZON X S.R.L.?

Recipients of the data may be:

• service providers: IT services (maintenance, software development), archiving in physical/electronic format, courier services, marketing service providers, traffic and user behavior monitoring providers;
• accounting service providers;
• central and/or local public authorities.

8. How Long Are Personal Data Processed and Stored?

For the purpose of fulfilling the aforementioned purposes, personal data will be processed by S.C. HORIZON X S.R.L. throughout the contractual relationship and after its completion, for compliance with applicable law in the field, including but not limited to archiving provisions.
Information collected by cookies is stored for 26 months in order to conduct analysis and reports related to website performance. They will be deleted after this period.

9. What Are the Rights of Data Subjects and How Can They Be Exercised?

The data subject has the following rights:

• Right to Information – the right to receive detailed information regarding data processing activities carried out by S.C. HORIZON X S.R.L., as provided in this document;
• Right of Access – you can request and obtain confirmation of whether your personal data is processed or not by S.C. HORIZON X S.R.L., and if so you can request access to it, as well as certain information. Upon request, S.C. HORIZON X S.R.L. will also provide a copy of the personal data processed, additional copies being charged based on the actual costs of S.C. HORIZON X S.R.L.;
• Right to Rectification – the right to obtain rectification of inaccurate personal data and completion of incomplete data;
• Right to Erasure of Data (“Right to be Forgotten”) – in situations expressly regulated by law (in particular in case of withdrawal of consent or where it is found that the processing of personal data was not legal), the data subject can obtain erasure of that data. Following such a request, S.C. HORIZON X S.R.L. may anonymize the data, depriving it of its personal character and thus continue processing for statistical purposes;
• Right to Restrict Processing – in situations expressly regulated by law (in particular where the accuracy of the data is contested during the period necessary to determine this inaccuracy or where processing is unlawful and erasure of the data is not desired, only restriction);
• Right to Object – you may object at any time, on grounds relating to your particular situation, to processing based on the legitimate interest of S.C. HORIZON X S.R.L. (including profile creation) or carried out in the exercise of a public interest or an authorization with which S.C. HORIZON X S.R.L. is invested;
• Right to Data Portability – you can receive personal data in a structured format that can be automatically read, or you can request that such data be transmitted to another controller. This right applies only to: (i) personal data provided by the Client to S.C. HORIZON X S.R.L., (ii) if processing of personal data is carried out by automated means and (iii) if processing is based on either the performance of a contract or the consent of the data subject;
• Right to Lodge a Complaint – you can lodge a complaint regarding the manner in which S.C. HORIZON X S.R.L. processes personal data with the National Supervisory Authority for Personal Data Processing;
• Right to Withdraw Consent – in cases where processing is based on consent, it can be withdrawn at any time. Withdrawal of consent shall have effect only for the future, processing carried out prior to withdrawal remaining valid;
• Additional Rights Related to Automated Decisions Used in the Process of Providing Services and Products of S.C. HORIZON X S.R.L. – in the event that S.C. HORIZON X S.R.L. makes automated decisions relating to personal data, the data subject may (i) request and obtain human intervention regarding such processing, (ii) express their view regarding such processing and (iii) contest the decision.

The Client may exercise these rights either individually or cumulatively, by sending a written, dated and signed request to the registered office of S.C. HORIZON X S.R.L., Bucharest, Sector 1, Dacia Boulevard, no. 15, floor 2, room 15, or by Email: hello@horizonx.eu.