PRIVACY POLICY

This privacy policy determines how SC BAT Medias SA (“we”) collects, stores, and uses information about you, when you use or interact with its website batmedias.ro, apps, and services.

By accessing or using this website and/or any products, services, information, tools and documentation contained or described therein, you declare that you have understood and acknowledge the privacy policy in the version cur-rent at any time.  If you do not consent to this, you may not access and use our website.

1. About us

You can contact us by sending an e-mail to office@batmedias.ro. If you have any questions about this Privacy Policy, please contact using the mentioned e-mail.

2. Information that we collect when you visit our website

We collect and use information from website visitors in accordance with this Section as well as Section 9 below.

2.1 Web server log information.  We use a third party server to host our website called batmedias.ro. Our website server automatically logs the IP address you use to access our website as well as other information about your visit such as the pages accessed, information requested, the date and time of the request, the source of your access to our website (e.g., the website or URL (link) which referred you to our website), and your browser version and operating system.

2.2 Use of website server log information for IT security purposes.  We and our third party hosting provider collect and store server logs to ensure network and IT security and so that the server and website remain uncompromised.  This includes analyzing log files to help identify and prevent unauthorized access to our network, the distribution of malicious code, denial of services attacks and other cyber-attacks, by detecting unusual or suspicious activity.

(i) Legal basis for processing: compliance with a legal obligation to which we are subject (Article 6(1)(c) of the General Data Protection Regulation).

Legal obligation: we have the legal obligation to implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk of our processing of information about individuals.  Recording access to our website using server log files is such a measure.

(ii) Legal basis for processing: our and a third party’s legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interests: we and our third party hosting provider have a legitimate interest in using your information for the purposes of ensuring network and information security.

2.3 Use of website server log information to analyze website use and improve the website.  We use the information collected by our website server logs to analyze how our website users interact with our website and its features.  For example, we analyze the number of visits and unique visitors we receive, the time and date of the visit, the location of the visit and the operating system and browser used.  We use the information gathered from the analysis of this information to improve our website.  For example, we use the information gathered to change the information, content and structure of our website and individual pages based according to what users are engaging most with and the duration of time spent on particular pages on our website.

Legal basis for processing: our legitimate interests (Article 6(1) (f) of the General Data Protection Regulation).

Legitimate interests: improving our website for our website users and getting to know our website users’ preferences so that our website can better meet their needs and desires.

2.4 Use of cookies and similar technologies. Cookies are data files which are sent from a website to a browser to record information about users for various purposes.  We use cookies and similar technologies on our website, including essential, functional, analytical and targeting cookies and web beacons.  For further information on how we use cookies, please see our cookies policy.

You can reject some or all of the cookies we use on or via our website by changing your browser settings but doing so can impair your ability to use our website or some or all of its features.  For further information about cookies, including how to change browser settings, please visit www.allaboutcookies.org or see our cookies policy.

3. Information that we collect when you interact with our website

We collect and use information from individuals who interact with particular features of our website in accordance with this Section as well as Section 9 below.

4. Information that we collect when you contact us

We collect and use information from individuals who contact us in accordance with this Section and Section 9 below.

4.1 Contact by Email.  When you send an email to the email address displayed on our website we collect your mail address and any other information you provide in that email (such as your name, telephone number and the information contained in any signature block in your email).

(i) Legal basis for processing: our legitimate interests (Article 6(1) (f) of the General Data Protection Regulation).

Legitimate interests: responding to enquiries and messages that we receive, and keeping records of correspondence.

(ii) Legal basis for processing: necessary to perform a contract or to take steps at your request prior to entering into a contract (Article 6(1)(b) of the General Data Protection Regulation).

Reason why it’s necessary to perform a contract: where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so.

Transfer and storage of your information.  We use a third party email provider to store the emails that you send to us.  Emails you send us will be stored within or outside the European Economic Area .For further information please see Section of this privacy policy entitled Transfers of your information outside the European Economic Area.

4.2 Contact by website contact form.  When you contact us using the contact form on our website, we collect your name, email address, and IP address.  We also collect any other information you provide to us when you complete the contact form.  If you do not provide the mandatory information required by our contact form, you will not be able to submit the contact form and we will not receive your enquiry.  If you do not supply the optional information required by our contact form, we may not be able to respond or process your enquiry.

(i) Legal basis for processing: our legitimate interests (Article 6(1) (f) of the General Data Protection Regulation).

Legitimate interests: responding to enquiries and messages that we receive, and keeping records of correspondence.

(ii) Legal basis for processing: necessary to perform a contract or to take steps at your request prior to entering into a contract (Article 6(1)(b) of the General Data Protection Regulation).

Reason why it’s necessary to perform a contract: where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so.

Transfer and storage of your information.  Messages that you send us via our contact form will be stored on our third party hosting. Messages you send to us via our contact form will also be stored in email servers hosted by Yahoo.

4.3 Contact by Post.  If you contact us by post, we will collect any information you provide to us in any postal communications you send us.

(i) Legal basis for processing: our legitimate interests (Article 6(1) (f) of the General Data Protection Regulation).

Legitimate interests: responding to enquiries and messages that we receive, and keeping records of correspondence.

(ii) Legal basis for processing: necessary to perform a contract or to take steps at your request prior to entering into a contract (Article 6(1)(b) of the General Data Protection Regulation).

Reason why it’s necessary to perform a contract: where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so.

5. Information collected or obtained from third parties

5.1 Information received from third parties.  In general, we do not receive information about you from third parties.  The third parties from which we receive information about you will generally include group companies.  It is also possible that third parties with whom we have had no prior contact may provide us with information about you.  Information we obtain from third parties will generally be your name and contact details, but will include any additional information about you which they provide to us.

(i) Legal basis for processing: necessary to perform a contract or to take steps at your request prior to entering into a contract (Article 6(1) (b) of the General Data Protection Regulation).

Reason why it’s necessary to perform a contract: where a third party has passed on information about you to us (such as your name and email address) in order for us to provide services to you, we will process your information in order to take steps at your request to enter into a contract with you and perform a contract with you (as the case may be).

(ii) Legal basis for processing: your consent (Article 6(1) (a) of the General Data Protection Regulation).

Your Consent: where you have asked a third party to share information about you with us and the purpose of sharing that information is not related to the performance of a contract or services by us to you, we will process your information on the basis of your consent, which you give by asking the third party in question to pass on your information to us.

(iii) Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interests: where a third party has shared information about you with us, and you have not consented to the sharing of that information, we will have a legitimate interest in processing that information in certain circumstances.  For example, we would have a legitimate interest in processing your information to perform our obligations under a subcontract with the third party, where the third party has the main contract with you.  Our legitimate interest is the performance of our obligations under our subcontract.  Similarly, third parties may pass on information about you to us, if you have infringed or potentially infringed any of our legal rights.  In this case, we will have a legitimate interest in processing that information to investigate and pursue any such potential infringement.

5.2 Information received in error.  If we receive any information about you from a third party in error and/or we do not have a legal basis for processing that information, we will delete your information.

6. How we use your information

Profiling.  Please note that we use profiling on our website.  We do not consider this to have any legal effect on you or similarly significantly affects you.  You have the right to object to our use of automated decision-making and profiling described in this Section.  You can do that by opting-out of cookies and similar technologies in accordance with the method described in the relevant section below.  Your IP address isn’t paired with any other information of yours, since it’s used just for traffic/connection logs – therefore we can’t identify you based on your IP. You can find out more about our use of cookies and similar technologies (including the legal basis on which we use them) and how to opt out from them in our cookies policy: /en/cookie-policy/

Profiling is any form of automated processing of your information to evaluate personal aspects about you, in particular to analyze or predict things like your performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements.

6.1 Use of profiling for web analytics.  Our web analytics service, Google Analytics uses and collects information such as your location (based on your IP address) and your behavior (based on cookies) when you access our website (such as the pages you visit and what you click on).  We will only process information from cookies, if you have consented to us setting cookies on your computer in accordance with our cookies policy.

Logic involved: by automatically analyzing and categorizing information such as the location (based on IP address) as well as the behavior and devices of visitors to our website (using cookies), we are able to gain a better understanding of what our website visitors want (in terms of the content of our website and our products), how to improve our website and how to advertise and market our services to them.

Significance and envisaged consequences: cookies will be used to track and store information about your behavior and device on our website (unless you have opted out from receiving such cookies by the site pop-up or by emailing your IP address with subject “Cookies Opt Out” to office@batmedias.ro) and your location will be analyzed based on your IP address.

Legal basis for processing: legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest: delivering of the best experience to our visitors based on their region, language, and interests.

7. How long we retain your information

This Section sets out how long we will retain your information.  Where possible, we have provided specific retention periods.  Where that has not been possible, we have set out the criteria that we use to determine the retention period.

7.1 Retention periods.

  • Server log information: we retain information on our server logs according to legal requirements in our country. For logs that aren’t under special statute, we retain the information for a period of maximum three years.
  • Correspondence and enquiries: if you make an enquiry or correspond with us for any reason, whether by email, via our contact form, by post, or by phone, we will retain your information for as long as it takes to respond to and resolve your enquiry, and for 12 further months, after which point we will delete your information.

7.2 Criteria for determining retention periods.  In any other circumstances, we will retain your information for no longer than necessary, taking into account the following:

  • the purpose(s) and use of your information both now and in the future (such as whether it is necessary to continue to store that information in order to continue to perform our obligations under a contract with you or to contact you in the future);
  • whether we have any legal obligation to continue to process your information (such as any recordkeeping obligations imposed by relevant law or regulation);
  • whether we have any legal basis to continue to process your information (such as your consent);
  • how valuable your information is (both now and in the future);
  • any relevant agreed industry practices on how long information should be retained;
  • the levels of risk, cost and liability involved with us continuing to hold the information;
  • how hard it is to ensure that the information can be kept up to date and accurate; and
  • any relevant surrounding circumstances (such as the nature and status of our relationship with you).

8. How we secure your information

We take the appropriate technical as well as organizational measures to secure your information, and to protect it against unauthorized or unlawful use and accidental loss or destruction, including:

  • information is stored encrypted and access to it is limited to internal staff with vested interest using login credentials and in accordance to the rules defined by the internal policies regarding usage of personal data as defined in the company’s registry.
  • using secure servers to store your information;
  • verifying the identity of any individual who requests access to information prior to granting them access to information;
  • using Secure Sockets Layer (SSL) and Transport Layer Security (TLS) software to encrypt any information you submit to us via any forms on our website;

The improper means of sending the information via internet (no or weak encryption) by the user absolves us from any liabilities incumbent from it.

9. Transfer of your information

Your information will be transferred and stored outside the European Economic Area (EEA) in the circumstances set out below. We will also transfer your information outside the EEA or to an international organization in order to comply with legal obligations to which we are subject (compliance with a court order, for example).  Where we are required to do so, we will ensure appropriate safeguards and protections are in place.

9.1 Contact form.  The information that you submit to us via our contact form is transferred outside the EEA and stored on our third party hosting and email providers’ servers.

Data is sent to: United States, Romania, Singapore, France

9.2 Email.  The Information that you submit to us by email is transferred outside the EEA and stored on our third party email provider’s servers.

9.3 Google Analytics.  The Information collected by Google Analytics (your IP address and actions you take in relation to our website) is transferred outside the EEA and stored on Google’s servers.  You can access Google’s privacy policy here: https://www.google.com/policies/privacy/

Country of storage: United States of America.  This country is not subject to an adequacy decision by the European Commission.

Safeguard(s) used: Google has self-certified its compliance with the EU-US Privacy Shield, which is available here: https://www.privacyshield.gov/welcome. The EU-US Privacy Shield is an approved certification mechanism under Article 42 of the General Data Protection Regulation, which is permitted under Article 46(2)(f) of the General Data Protection Regulation.  You can access the European Commission decision on the adequacy of the EU-US Privacy Shield here: http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm

10. Disclosure of your information

10.1 Disclosure to service providers.  We use a number of third parties to provide us with services that are necessary to run our business or to assist us with running our business, and who process your information on our behalf.  These include:

  • Hosting provider(s), including , located in Romania. Their privacy policy is available here:

Your information will be shared with these service providers where necessary to provide you with the service that you have requested, whether that is accessing our website or ordering goods and services from us.  We do not display the identities of all of our service providers publicly by name for security and competitive reasons.  If you would like further information about the identities of our service providers, however, please contact us directly via our contact form or by email and we will provide you with such information, where you have a legitimate reason for requesting it (where we have shared your information with such service providers, for example).

(i) Legal basis for processing: legitimate interests (Article 6(1) (f) of the General Data Protection Regulation).

Legitimate interest relied on: where we share your information with these third parties in a context other than where is necessary to perform a contract (or take steps at your request to do so), we will share your information with such third parties in order to allow us to run and manage our business efficiently.

(ii) Legal basis for processing: necessary to perform a contract and/or to take steps at your request prior to entering into a contract (Article 6(1) (b) of the General Data Protection Regulation).

Reason why it’s necessary to perform a contract: we may need to share information with our service providers to enable us to perform our obligations under that contract or to take the steps you have requested before we enter into a contract with you.

10.2 Disclosure to other third parties.  We also disclose your information to other third parties in specific circumstances, as set forth below.

10.2.1    Providing information to third parties such as Google Inc.  Google collects information through our use of Google Analytics on our website.  Google uses this information, including IP addresses and information from cookies, for a number of purposes, such as improving its Google Analytics service.  Information is shared with Google on an aggregated and anonym basis.  To find out more about what information Google collects, how it uses this information and how to control the information sent to Google, please see the following page: https://www.google.com/policies/privacy/partners/ .

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest(s): meeting our contractual obligations to Google under the Google Analytics Terms of Service (https://www.google.com/analytics/terms/us.html ).  You can opt out of Google Analytics by installing the browser plugin here: https://tools.google.com/dlpage/gaoptout.

Transfer and storage of your information.  Information collected by Google Analytics is stored on Google’s servers in the United States of America.  For further information about the safeguards used when your in-formation is transferred outside the European Economic Area, see Section 9 above.

10.2.2 Sharing your information with third parties, which are either related to or associated with our business operations, where it is necessary for us to do so. The information is stored encrypted and can only be de-crypted by used the login credentials assigned to specific users with vested interests, in accordance to our GDPR policies.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest: running and managing our business efficiently.

  • Accountants. We share information with our accountants for tax purposes. For example, we share invoices that we issue and receive with our accountants for completing tax returns and our end of year accounts.
  • Advisors. Occasionally, we obtain advice from advisors, such as accountants, financial advisors, lawyers, public relations professionals and security specialists. We will share your information with these third parties only where it is necessary to put them in a position to be able to provide us with the relevant advice.
  • Business partners. Business partners are businesses we work with, which provide goods and services complementary to our own, or which allow us to provide goods or services that we could not provide on our own. We share information with our business partners where you have requested services which they provide whether independently from, or in connection with, or own services.
  • Independent contractors. We use independent contractors in our business. Your information will be shared with independent contractors only where it is necessary for them to perform the function that we have hired them to perform in relation to our business.
  • Insurers. We will share your information with our insurers where it is necessary to do so, for example in relation to a claim or potential claim that we receive or make, or under our general disclosure obligations under our insurance contract with them.

10.2.3 Sharing your information within our company for internal administrative purposes, including client, customer and employee information.

(i) Legal basis for processing: our legitimate interests (Article 6(1) (f) of the General Data Protection Regulation).

Legitimate interest: running and managing our business effectively.

(ii) Legal basis for processing: necessary to perform a contract or to take steps at your request prior to entering into a contract (Article 6(1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract: we need to share your information within the company to be able to meet our contractual obligations to you, or to take steps at your request prior to entering into a contract, for example because of the services or information that you have requested.

10.2.4 We do not display the identities of all third parties that we may share information with by name, for security and competitive reasons.  If you would like further information about the identities of such third parties, however, please contact us directly via our contact form or by email and we will provide you with such information where you have a legitimate reason for requesting it (where we have shared your information with such third parties, for example).

10.2.5 Sharing your information with a prospective or actual purchaser or seller in the context of a business or asset sale or acquisition by us, a merger or similar business combination event, whether actual or potential.

Legal basis for processing: legitimate interests (Article 6(1) (f) of the General Data Protection Regulation).

Legitimate interest(s): sharing your information with the prospective purchaser, seller or similar person in order to allow such a transaction to take place.

10.3 Disclosure for legal reasons.

10.3.1    Reporting of crimes or threats to public security.  If we suspect a criminal or potential criminal conduct has occurred, we will in certain circumstances need to contact an appropriate authority, such as the police.  This could be the case, for instance, if we suspect that a fraud or a cybercrime has been committed, or if we receive threats or malicious communications.  We will generally only need to process your information for this purpose, if you were involved or affected by such an incident in some way.

Legal basis for processing: our legitimate interests (Article 6(1) (f) of the General Data Protection Regulation).

Legitimate interests: preventing crime or suspected criminal activity (such as fraud).

10.3.2 Enforcement or potential enforcement of legal rights.  We will use your information in connection with the enforcement or potential enforcement of our legal rights, including, for example, sharing information with debt collection agencies, if you do not pay amounts owed to us when you are contractually obliged to do so.  Our legal rights may be contractual (where we have entered into a contract with you) or non-contractual (such as legal rights that we have under copyright law or tort law).

Legal basis for processing: our legitimate interests (Article 6(1) (f) of the General Data Protection Regulation).

Legitimate interest: enforcing our legal rights and taking steps to enforce our legal rights.

10.3.3 In connection with legal or potential legal disputes or proceedings.  We may need to use your information if we are involved in a dispute with you or a third party for example, either to resolve the dispute or as part of any mediation, arbitration or court resolution or similar process.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interests: resolving disputes and potential disputes.

10.3.4 Compliance with laws, regulations and other legal requirements.  We will use and process your information in order to comply with legal obligations to which we are subject.  For example, we may need to disclose your information pursuant to a court order or subpoena, if we receive one.

(i) Legal basis for processing: compliance with a legal obligation (Article 6(1) (c) of the General Data Protection Regulation).

Legal obligation(s): legal obligations to disclose information which are part of the UK law or which are binding on UK legal entities, for example on the basis of an international agreement which the UK has signed.

(ii) Legal basis for processing: our legitimate interests (Article 6(1) (f) of the General Data Protection Regulation).

Legitimate interest: where the legal obligations are part of the laws of another country and have not been integrated into Romania’s legal framework, we have a legitimate interest in complying with these obligations.

11. Your rights in relation to your information

11.1 Subject to certain limitations on certain rights, you have the rights listed below with regard to your information.  You may exercise these rights likewise, by sending an email to office@batmedias.ro.

  • The right to request access to your information and information related to our use and processing of your information;
  • The right to request the correction or deletion of your information;
  • The right to request that we restrict our use of your information;
  • The right to receive information which you have provided to us in a structured, commonly used and machine-readable format (e.g., a CSV file) and the right to have that information transferred to another data controller (including a third party data controller);
  • The right to object to the processing of your information for certain purposes (for further information, see Section 12 below); and
  • The right to withdraw your consent to our use of your information at any time, where we rely on your consent to use or process that information. Please note that if you withdraw your consent, this will not affect the lawfulness of our use and processing of your information on the basis of your consent before the point in time when you withdraw your consent.

In accordance with Article 77 of the General Data Protection Regulation, you also have the right to lodge a complaint with a supervisory authority, in particular in the State of your habitual residence, place of work or of an alleged infringement of the General Data Protection Regulation.

11.2 The above rights are provided in summary form only and certain limitations apply to many of these rights.  You can find further information about your rights, as well as information on any limitations that apply to those rights, by reading the underlying legislation contained in Articles 12 to 22 and 34 of the General Data Protection Regulation, which is available here: http://ec.europa.eu/justice/data-protection/reform/files/regulation_oj_en.pdf.

11.3 Where you request access to your information, we are required by law to use all reasonable measures to verify your identity before doing so.  These measures are designed to protect your information and to re-duce the risk of identity fraud, identity theft or general unauthorized access to your information.

How we verify your identity.  Where we possess appropriate information about you on file, we will attempt to verify your identity using that information.  If it is not possible to identity you from such information, or if we have insufficient information about you, we may require original or certified copies of certain documentation in order to be able to verify your identity before we are able to provide you with access to your information.  We will be able to confirm the precise information that we require to verify your identity in your specific circumstances, if and when you make such a request.

  1. Your right to object to processing of your information for certain purposes.

With regard to using or processing your information, you have the rights to object listed below.  You may exercise these rights likewise, by sending an email to office@batmedias.ro.

  • The right to object to us using or processing your information, where we use or process it in order to carry out a task in the public interest or for our legitimate interests, including “profiling” (i.e. analyzing or predicting your behavior based on your information) based on any of these purposes; and
  • The right to object to us using or processing your information for direct marketing purposes, including any profiling we engage in, that is related to such direct marketing.

You may also exercise your right to object to us using or processing your information for direct marketing purposes by:

  • sending an email to office@batmedias.ro asking that we stop sending you marketing communications or by including the words “OPT OUT”.

For more information on how to object to our use of information collected from cookies and similar technologies, please see our cookies policy.

13. Sensitive personal information; children’s privacy

13.1 ‘Sensitive personal information’ is information about an individual that reveals their racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic information, biometric information for the purpose of uniquely identifying an individual, information concerning health or information concerning a natural person’s sex life or sexual orientation.

We do not knowingly or intentionally collect any sensitive personal information from individuals, and you must not submit sensitive personal information to us.  If, however, you inadvertently or intentionally transmit sensitive personal information to us, you will be considered to have explicitly consented to us processing that sensitive personal information under Article 9(2) (a) of the General Data Protection Regulation.  We will use and process your sensitive personal information for the purposes of deleting it.

13.2 We do not knowingly contact or collect information from persons under the age of 18.  Our website is not intended to solicit information of any kind from persons under the age of 18.  It is possible that we could receive information pertaining to persons under the age of 18 by the fraud or deception of a third party.  If we are notified of this, as soon as we verify the information, we will, where required by law to do so, immediately obtain the appropriate parental consent to use that information or, if we are unable to obtain such parental consent, we will delete the information from our servers.  If you would like to notify us of our receipt of information about persons under the age of 18, please do so by sending an email to office@batmedias.ro.

14. Changes to our privacy policy

We may update and amend our privacy policy from time to time.

14.1 Minor changes.  Where we make any minor changes to our privacy policy, we will update our privacy policy with a new effective date stated at the beginning of it.  Our processing of your information will be governed by the practices set out in that new version of the privacy policy from its effective date onwards.

14.2 Major changes.  Where we make any major changes to our privacy policy or intend to use your information for a new purpose or a different purpose than the purposes for which we originally collected it, then we will notify you by email (where possible) or by posting a notice on our website.  We will provide you with the information about the change in question and the purpose and any other relevant information before we use your information for that new purpose.  Wherever required, we will obtain your prior consent before using your information for a purpose that is different from the purposes for which we originally collected it.

15. Additional Information

From time to time, our website might contain links to third party websites.  The privacy policies or practices of third parties are beyond our control.  Hence, please read the privacy policies of these websites before using them.