Oregon Park 1 S.R.L respects the privacy of its clients and other persons in contact and guarantees the maximum level of protection of their personal data.  

The current Policy for privacy and protection of personal data (as referred to below "Privacy Policy" or “the Policy”) aims to inform you about the personal data we collect for you, why and how we process it and what are your rights in this regard.  This Policy is prepared and is based on the current Romanian and European legislation in the field of personal data protection, including without limitation the Regulation 2016/679 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (the “Regulation”) the Law no. 190/2018 regarding measures for application of EU Regulation 2016/679 of the European Parliament and of the Council dated 27 April  2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC, as well as any other secondary laws, regulations or decisions issued at European Union level or national level with respect personal data protection matters.

This Privacy Policy does not affect, limit or invalidate your rights under the [Romanian legislation, the Regulation or other relevant legislation. 

Please read this Policy carefully before using the Site, as well as before entering into commercial, civil or other relations with us. If you do not want us to process your personal information in the manner described in this Privacy Policy, please do not provide it to us. If your personal data has been provided to us by a third party, your employer or assigner, you may also refer to the latter for more information.   

If you have any questions or comments regarding this Privacy Policy, please contact us at: regulatorycompliance@lhinv.eu. 

 

I. Who processes and takes responsibility for your personal data? 

Oregon Park 1 S.R.L (“Oregon”, “we”) is a company, registered in the Commercial Registry under Company Number J40/15645/2013, sole identification code 32606200, with seat and registered address at 46D-46E-48 Pipera Road, Oregon Park, Building B, Ground floor, Units B 032 and B042, Office No.1, District 2, Bucharest, Romania, which collects, processes and stores your personal data under the terms of this Privacy Policy. Oregon Park 1 S.R.L is a controller of personal data within the meaning of the Regulation. You can contact us at any of the following coordinates: 

Seat and registered address: 46D-46E-48 Pipera Road, Oregon Park, Building B, Ground floor, Units B032 and B042, Office No.1, District 2, Bucharest, Romania e-mail: regulatorycompliance@lhinv.eu. 

Oregon is a company owner of Class A office buildings, with commercial name Oregon Park (“Buildings”), located at 46D-46E-48 Pipera Road, Oregon Park and the adjacent land plots (together referred to as “the Site”). Oregon processes personal data with regard to and to the extent necessary for the management of the leasing process of the Site, maintenance, and management of the Site.

 

II. Sources for collection of personal data: 

2.1. We may be provided with your personal data directly from You, when: 

• You initiate contact with us for the purpose of entering into commercial or other civil relations with us, either in your capacity of an individual or when acting on behalf of legal entities – clients or other contracting parties of Oregon;
• You visit the Site 

In these cases, the scope of personal data we process is restricted to the one you provide us and which is required so that we may legally execute our commercial activity. 

2.2.  If you are an employee of our client (including lessee of an unit in the Building) or of our supplier/subcontractor/contracting party or of a subcontractor of a lessee in the Building, your personal data me be submitted to us by your employer or by an assigner of your employer. 

2.3.  We may process data collected or generated by us when executing our commercial activity:

• Video shooting when visiting the Site
• It is possible that when visiting our website statistic data as IP address, visited webpages, other identificatory stored in Cookies locally by the website user are collected (most of them are not qualified as personal data). 

2.4. In order to ensure the proper performance of the services and the obligations arising from client contracts, Oregon may process information that is available in public registers (including public database and data disclosed on the Internet) as well as information obtained from third parties regarding the implementation of legal provisions regarding customers.

Oregon has the right and the duty to verify the correctness of the personal data stored in such databases and for this purpose requires you to verify the data and, if necessary, correct or validate your data.

 

III. Purposes and legal grounds for the processing of personal data

3.1. Processing of personal data that is necessary for the conclusion or performance of contracts with us or with regard to preparation for concluding contracts with us.

Oregon processes your personal data for the following purposes: 

• (i)Client identification upon: signing a new or changing an existing contract with us; 
• (ii)Negotiation on contracts; management of pre-contractual relations;
• (iii)Managing and administration of contracts concluded with you, execution of obligations and exercising of rights. 

3.2. In fulfillment of its legal obligations, Oregon processes your data for the following purposes:

• (i)To perform its accounting and tax obligations provided for in the relevant legislation in relation to proper and legal accounting; invoice issuing; upon execution of tax - insurance control by the respective competent authorities; control under the Anti-money Laundering (if applicable) and other;
• (ii)Providing information to the National Supervisory Authority For Personal Data Processing in relation to obligations provided by the regulatory of personal data protection – the Regulation, other national laws or decisions, etc.;
• (iii)To ensure the protection of objectives, assets, values and protection of persons.

3.3. Processing based on protection of the legitimate interests of Oregon

• (i)Upon video surveillance of the Site – for the purpose of protecting the security of the individuals in the Site, as well as for protection of the property and other assets, located on the Site;
• (ii)Upon managing the access control to the Site – for the purpose of protecting the security of the individuals in the Site, as well as for protection of the property and other assets, located on the site; providing of high quality service as Class A office buildings;
• (iii)Upon managing the contracts between Oregon and contractors – legal entities – the personal data on this base are processed for the purpose of execution of contracts concluded between Oregon and a third party-legal entity, which has employment of other civil contractual relations with the data subject. This covers mainly personal data of legal representatives and authorised representatives of contracting parties, contact persons, persons authorized and obliged to execute certain activities under the concluded contract. 

IV. Categories of personal data we process  

4.1. Personal data processed with regard to the functioning of the access control system and the access control on Reception of the Buildings:

• (i)for employees of lessees in the Buildings and employees of other contracting parties employer, access card number, date and hour of entry/exit, car registration number (if applicable);
• (ii)for visitors in the Site – name, surname, as well as number and series of ID card,  and the company each visitor intends to visit

4.2. Personal data processed upon video surveillance 

A video image of the persons staying on or passing through the territory of the Site.

4.3. Personal Data processed with regard to entering into and execution of contracts, where Oregon is a party, regardless of whether concluded with you personally or with a company You are working for or you represent.

• (i)Personal identification data – names, Personal identification number, data as per the personal ID card (these are processed as an exception only – for example when You are legal representative of a company or a proxy of such company – our contracting party and the agreement between us is notary certified);
• (ii)Contact details – as post and electronic mails, phone and fax number;
• (iii)Financial information – bank account, when a payment is made by or to You;
• (iv)Professional information – employer, position;

Different types of personal data can be processed on their own or in combination.

 

V. For what period is your personal data stored? 

The period of time that your personal data is stored depends on the processing purposes for which it was collected:

• 1.Personal data processed for the purpose of concluding / amending and executing contracts between Oregon and you or between Oregon and a contracting party (legal entity) - for the term of the agreement and for the period necessary for protection of the Company’s rights in view of the applicable law, including the prescription term and/or the terms set out by the fiscal and accounting regulations. 
• 2.Personal data processed for the purpose of issuing accounting / financial documents and for exercising of tax control, audit and consecutive financial inspections – 10 years, as of 1 January of the period following the period under review. 
• 3.Video data from security cameras - 30 days from the video recording
• 4.Data connected to the functioning of the access control system and processed with regard to the access control rules:
  • (i) 1 month for data registered with respect to access cards;
  • (ii) license plates are kept until notice from tenant requiring elimination thereof or termination of lease contract;
  • (iii) for visitors’ registry - 60 days calculated as of the date when the full register is completed.

The personal data may be processed for a longer term in the case of a legal dispute that has already arisen or an administrative investigation until its final settlement with a court / arbitration ruling or until completion for the examination, as well as in other cases provided for in the law; 

 

VI. Where we store your personal data?   

The data we process about you are stored within the European Union and the European Economic Area.

At present based on the available information we, (as data controller) don’t transfer and don’t intend to transfer your personal data outside the European Union. 

Any change of the above information will be reflected as an amendment in this Policy.

 

VII. Third-party categories that may access and process your personal data. 

Your personal data, which are accessed by third persons, will be processed for the purposes described in this Policy. It is possible that in the process of delivering our services and managing of our relations with You or with the company you are employed in, we might need to use third parties, such as:

• (i)Transportation / courier companies, postal operators in order to fulfill our contractual obligations, sending correspondence and communications, in connection with the contract between us;
• (ii)People who, under the responsibility of the data controller, maintain the equipment and software used to process your personal data; 
• (iii)Banks, servicing payments made by and to you or an entity represented by you;
• (iv) Individuals to whom Oregon has provided the implementation of part of the service or servicespecific obligations we owe to you or to your employer; 
• (v)People/legal entity processing personal data who, on the basis of a contract with Oregon, process your personal data on behalf of Oregon, such as asset managers or providers ensuring security of the sites;  
• (vi)People performing consulting services in different spheres - lawyers, accountants, notary publics etc.;
• (vii)People, institutions and persons to whom we are required to provide personal data under current legislation; 

Please be informed that some of these companies have their own legal right or obligation to process your personal data, in their own capacity of data processor. 

 

VIII. Your Rights in relation to the processing of your Personal Data 

• 1.General rights

  At any time while we store or process your personal data you have the following rights:

  • To request a copy of Your personal data and right to access your personal data at any time, as well as to demand information why we process your personal data; 
  • To request that we correct, without undue delay, your inaccurate personal data as well as
  • data that is not up to date;
  • Upon certain circumstances to request from us your personal data in a form convenient to be transfered to another data controller, or request us to do so (the right of portability);
  • To request the deletion of your personal data without undue delay in the presence of any of the legal grounds for doing so;
  • To request that we restrict the processing of your personal data, in which case your data will only be stored but not processed. Our refusal (if such) to restrict the processing of your personal data will be explicit and only in writing, and we are obliged to ground it with legitimate reason;
  • to withdraw your consent to the processing of your personal data at any time with a separate request addressed to us upon consent-based processing;
  • to object to the processing of your personal data in case your personal data is processed based on our legitimate interest. If your objection is well-grounded, we will cease processing your personal data;

   

• 2.You have the right to appeal to the supervisory authority

  You have the right to submit a complaint directly to the supervisory authority. The competent authority is the National Supervisory Authority For Personal Data Processing, address: 28-30 G-ral Gheorghe Magheru Bld. District 1, post code 010336,  Bucharest, Romania; email:anspdcp@dataprotection.ro ,   website: www.dataprotection.ro .

• 3.Automated processing and profiling

  We don’t use your personal data for automated decision making, including profiling, which to result in any legal consequences for you or affect you in significant amount.

• 4.Can you refuse to provide your personal data and what are the consequences of that?

  We need certain data identifying the contracting party, its proxy, contact details, payment details.  Not providing such data prevents us from signing a contract with you or with a company you are employed at or you represent. 

  Data processed for other than the above purpose may not be provided to us, by not visiting our Site.

 

IX. Amendments to the Privacy Policy 

We may periodically update our Privacy Policy. In the event of a change in the current policy, a notice will be published on our website as well as the updated Privacy Policy. All amendments and additions to the Privacy Policy will be applied only after publishing its current content available through our Site. In case of major amendments of the Privacy Policy we may choose to send personal e-mail message to each one of you linking to the new Privacy Policy, so that we can be sure you will take time to read it.

 

This Policy enters into force on 23/02/2018

Last updated: 23/04/2021