I. General information :
The content of the website www.bestoptic.ro (hereinafter referred to as the Site) is the exclusive property of the legal entity B.G. VISION S.R.L (hereinafter referred to as the Owner or BEST OPTIC) with registered office in Mun. Brasov, str. Barbu Stefanescu Delavrancea nr. 10, cam. 3, Jud. Brasov, registered at the Trade Register Office under no. J8/927/2012, with fiscal code RO 30338144.
As a data controller, the Data Controller shall constantly monitor and ensure that the processing of personal data strictly complies with the principles and legislation on the protection of personal data, in particular the provisions of Regulation (EU) 2016/679 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (hereinafter “GDPR”).
This Privacy Policy is effective as of 25 May 2018 and is intended to inform you of:
- The personal data processing activities, of you, as a visitor to the Site or as a user of the functions within the website;
- the processing of personal data carried out by the Controller in order to carry out its activities as described below.
BEST OPTIC may update this Privacy Policy at a later date, in which case it will inform data subjects via the Site of any changes before they become applicable.
II. Definitions :
„“Personal data” means any information relating to an identified or identifiable natural person (“data subject”); an identifiable person is a person who can be identified, directly or indirectly, in particular by reference to an identifier, such as a name, an identification number, location data, an online identifier, or to one or more factors specific to his or her physical, physiological, genetic, mental, economic, cultural or social identity.
“Processing” (and its derivatives, including without limitation “to process”) means any operation or set of operations performed upon Personal Data, including without limitation collecting, recording, storing, modifying, using, disclosing, accessing, transferring or destroying them.
“Visitor” means any person who accesses or uses the website.
III. Categories of Personal Data Processed:
The categories of Personal Data processed depend on the context of your interactions and relationships with the Data Controller, i.e. in relation to your interactions with the Site. Thus, the Controller may process the following Categories of Personal Data:
3.1. In the case of visitors to the Site the following categories of Data – depending on your interaction with the Site, could be processed as Personal Data:
- in the case of Suggestion Forms, request for further information, contact and/or complaints: name, surname, e-mail address, age, telephone, street, gender.
3.2. In the case of candidates for employment: name, surname, e-mail address, telephone number, position/function, city, CV (which may include, among other things, the following data in addition to those mentioned above, i.e.: image, professional training, information on current job).
3.3. In the case of Newsletter subscribers, name, surname, e-mail address.
3.4. In the case of persons contacting BEST OPTIC through the Call Center, other telephone numbers displayed on the Site or other means of distance communication belonging to the Registrant, in the context:
– Appointments for optometric consultation, the following Personal Data of the patients may be processed: name, surname, date of birth, telephone number, e-mail;
– – Requests, complaints and suggestions made by telephone, as well as those transmitted by other means of distance communication, may be processed the following Personal Data: name, surname, home address, telephone number, e-mail address. To the extent that through such requests, including through the contact form on the Site, you directly provide other data not expressly requested by the Data Controller, BEST OPTIC will process only the data necessary for the purpose of handling your request.
IV. Purposes and grounds for processing Personal Data:
Performance of medical services, registration of medical services rendered, communication with the patient, appointments, identification of the patient and the services rendered, informing the patient about the results of the services rendered.
Direct marketing communications. Communicating with the patient by any means: email, mobile or landline phone, telephone messages (including SMS), postal correspondence, messages sent via social media platforms, news about specific medical services available at BEST OPTIC, subscribing to newsletters or providing other information that may be of interest to the patient, including offering promotional services or information about our promotions.
Fulfillment of legal obligations regarding archiving, financial management, health, physical and information security, control of our service providers to ensure the protection of the data we process, record keeping and other obligations that Romanian and European legislation in force requires.
4.1. If you are a visitor to the Site, we may process your data as follows:
– For more details on the use of cookies please see the Cookie Policy available on the BEST OPTIC website (www.bestoptic.ro).
Basis of processing: consent, performance of contract or legitimate interest, as provided for by Law 506/2004.
– For the purpose of Registration/validation of your appointments on the Site: name, surname, age, date of birth, address, telephone, e-mail. Depending on the specifics of your requests, the categories of data collected may be different;
Basis of processing: legitimate interest.
– For the purpose of handling requests submitted via the Site’s suggestion, request for further information, contact and/or complaint forms.
Basis of processing: legitimate interest.
4.2. In order to fulfil the legitimate interests of the Data Subject for the following purposes:
– Establishing, exercising or defending rights of BEST OPTIC in court and in any other legal proceedings;
– handling any other requests, complaints, suggestions.
4.3. If you are a candidate for employment we may process your data:
4.3.1 In order to comply with legal obligations for the following purposes:
– Dealing with requests/complaints regarding the exercise of your rights in the context of data processing, indicated below in section XI;
– archiving documents in accordance with the legal provisions within the legal deadlines;
– managing relations with public authorities or other entities providing a public service.
4.3.2 In order to take the necessary steps to conclude a contract for the following purposes:
– carrying out specific recruitment activities for certain vacancies within BEST OPTIC;
– handling any other requests, complaints, suggestions.
Basis of processing: contract.
4.3.3 In order to meet the legitimate interests of the Data Subject for the following purposes:
– Conducting subsequent recruitment activities for other vacancies within BEST OPTIC than those for which you initially applied;
– handling any other requests, complaints, suggestions.
Basis of processing: legitimate interest.
4.4. If you are a Newsletter subscriber we may process your data:
4.4.1 For marketing purposes, to send, via remote communication means (e.g. e-mail, telephone) and other digital communication platforms, newsletters or other commercial messages about BEST OPTIC products and services to affiliates and companies cooperating with BEST OPTIC.
Basis for processing: consent.
Note 1: Your consent for direct marketing activities can be withdrawn at any time. Withdrawal of your consent will take effect for the future without affecting the lawfulness of the processing carried out prior to the withdrawal.
Note 2: For certain processing activities, the legal basis may be a legal obligation (among those mentioned below in point IV.5.1.).
5.0. If you are a third party and you contact us via the Call Center or other telephone numbers or other means of communication we may process your data:
5.1 In order to comply with legal obligations for the following purposes:
– Settlement of requests/complaints regarding the exercise of your rights in the context of data processing, indicated below in section XI;
– archiving documents in accordance with the legal provisions within the legal deadlines;
– managing relations with public authorities or other entities providing a public service.
Basis of processing: legal obligation
5.2. In order to meet the legitimate interests of the Data Subject for the following purposes:
– managing any other requests, complaints, suggestions.
Basis for processing: legitimate interest.
V. Cookie files :
The website uses cookie files. For more information on how these files are used, please see the Cookie Policy available on the BEST OPTIC website (www.bestoptic.ro).
VI. Recipients of Personal Data :
For the fulfilment of processing purposes, the Data Controller may disclose certain categories of Personal Data to the following categories of recipients:
– the data subject and/or his/her legal representatives;
– representatives of BEST OPTIC, entities of the Group to which the Data Subject belongs,
– contractual partners, namely: payment processors, medical optician clinics, other corporate partners (in the case of corporate partners who are the patient’s employer, the latter’s data may be disclosed to the employer in the context of the assessment of the patient’s capacity to work, within the limits of the legal provisions and for occupational health purposes);
– BEST OPTIC’s representatives in various fields (such as security services, archiving services, marketing agencies);
– other suppliers of services and goods involved in BEST OPTIC’s activities (such as external consultants in various fields such as accounting, legal, tax), professional organisations, market research organisations;
– judicial or other public authorities of any kind, international organisations.
VII. Duration of processing of Personal Data :
The Data Controller will process your Personal Data for the time necessary to achieve the processing purposes and thereafter in accordance with internal policies and in order to comply with applicable legal obligations, including, but not limited to, the provisions relating to archiving obligations. Data will also be stored in accordance with BEST OPTIC’s internal policies which set data retention periods.
It is possible that, following the fulfilment of the legal archiving periods, the Data Controller may order the anonymisation of the data, thus depriving them of their personal nature, and continue processing the anonymised data for statistical purposes.
In the case of newsletter subscribers and data processing for marketing purposes, BEST OPTIC will process the data until such time as the data subject withdraws his/her consent or exercises his/her right to object according to the law.
VIII. Transfer of Personal Data:
Personal data provided to BEST OPTIC may be transferred outside Romania, to countries in the European Economic Area.
Outside the European Economic Area, Personal Data may also be transferred to countries outside the European Economic Area. It is possible that in the course of its activities, the aforementioned transfer states may change.
IX. Security of Personal Data:
The Data Controller attaches great importance to the confidentiality and security of your Personal Data and understands to ensure its security during the processing activities in this Privacy Policy. To this end, the Data Controller implements appropriate technical and organisational measures to ensure a level of security appropriate to the risks associated with the types of data processed and the processing operations.
X. Provision of Personal Data :
The provision of Personal Data may be a contractual obligation or an obligation necessary for the conclusion/performance of a contract, it may be necessary in order to benefit from the services made available by BEST OPTIC, to navigate on the Site and to benefit from the facilities offered on this space. In some cases, the refusal to provide Personal Data may result in the impossibility of benefiting from the services made available to you through the Site (for example, the impossibility of registering your appointment/request). For direct marketing activities, providing your data is voluntary.
Although BEST OPTIC requires your consent for the processing of certain Personal Data, such consent may not always be required by law. In such situations, the Data Controller may use other grounds for processing the data, such as the provision of medical optician services, performance of contract or legitimate interest.
XI. Rights of the Data Subject :
Right of access to data. You have the right to obtain access to your data or copies thereof; you also have the right to obtain information about the nature, processing and disclosure of such data.
Right to rectification of data. You have the right to have inaccuracies in your data rectified.
Right to erasure of data (“right to be forgotten”). You have the right to have your data erased.
The right to restrict data processing. You have the right to restrict the processing of your data.
The right to object. You have the right to object to the processing of your data by us or on our behalf.
Right to data portability. You have the right to transfer your data to another controller.
Right to withdraw consent. Where we process your data on the basis of your consent, you have the right to withdraw your consent; you may do so at any time, at least as easily as you originally gave us your consent; withdrawal of consent will not affect the lawfulness of the processing of your data that we carried out prior to withdrawal.
Right to lodge a complaint with the Supervisory Authority. You have the right to lodge a complaint with the Data Protection Supervisory Authority about the processing of your data by us or on our behalf.
All these rights can be exercised by a written request sent to the email address: dpo@bestoptic.ro.
You are under no obligation to provide us with your personal data referred to in the BEST OPTIC Privacy Policy. However, in the absence of this and/or your consent to the processing of personal data, it will not be possible for us to provide the full medical optician services requested in your interest.
Please note that in case of withdrawal of consent according to the applicable legal provisions, where such consent was previously expressed for direct marketing activities, BEST OPTIC, after having taken note of this fact, will no longer send you direct marketing messages. Although you will no longer receive direct marketing messages, BEST OPTIC may still process your Personal Data lawfully, on other grounds and for other purposes such as the fulfilment of certain legal obligations incumbent upon it, the performance of the contract or the legitimate interest of BEST OPTIC (e.g. for the improvement of services, the resolution of complaints received, the defence of rights and interests).
Also, in the case of data transfers outside the EEA (“European Economic Area”), data subjects whose Personal Data are the subject of the transfer may request the data controller for information on the transfer guarantees.
In order to exercise the above mentioned rights, you may address a request to the following contact details :
B.G. VISION S.R.L. – Personal Data Protection Department
Address: 10 Barbu Stefanescu Delavrancea Street, room 3, Mun. Brasov, Jud. Brasov
E-mail: dpo@bestoptic.ro
Also, for any further information on how Personal Data are processed, please contact the Data Protection Officer at the e-mail address: dpo@bestoptic.ro.