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Our Commitment to Your Privacy

M.S.WRANGHEL SRL is committed to protecting the privacy of our potential and existing customers. The  M.S.WRANGHEL SRL privacy policy (the “Privacy Policy”) applies to all Personal Data (as defined  below) processed by us, including Personal Data collected or submitted through our websites, mobile  applications or through our official social media pages or through other channels online and offline as  further described below. 

If you cannot, or will not, provide us with the personal information we reasonably require, we may be  unable to provide you with the information, goods or services you have requested. M.S.WRANGHEL SRL  will never use your personal data for purposes other than providing you with the information, goods, or  services you have requested. And we will never, ever, share your data with third party companies  unassociated with. “M.S.WRANGHEL “ Your data will be in safe hands

Notification of Privacy and protection of data

The “M.S.WRANGHEL” company that is the controller for the processing of your Personal Data (as set  out in this Privacy Policy) can be found here and will depend on which M.S.WRANGHEL Product(s) you  are interested in or have engaged with. Being the controller means that this company is responsible for  ensuring that your Personal Data is processed in compliance with applicable privacy and data protection  legislation.

 

1.Data controller: 

“M.S.WRANGHEL “ LTD is a “data controller”. „M.S.WRANGHEL” LTD with the registered office: str  E.Gojdu nr 3 ap 19 Timișoara.România, company registration number. J35 / 2504/1994, VAT no.  6240746, are registered with the Information Commissioners office as required under the Data Protection  Act 2018

This means that we are responsible for deciding how we hold and use personal information about you.

“M.S.WRANGHEL” collects stores and processes personal data relating to its employees in order  to manage the employment relationship. This privacy notice sets down how the Company collects  and uses personal information about you during and after your working relationship with us.

This privacy notice applies to current and former employees, workers, clients, partners, and  contractors. This notice does not form part of a contract of employment or any contract to provide  services and may be updated at any time.

The Company is committed to protecting the privacy and security of your personal information.  The Company is committed to being clear and transparent about how it collects and uses that  data and to meeting its data protection obligations.

 

2. Data Protection Principles

The Company will comply with data protection law. This means that the personal information we hold  about you must be: 

• Used lawfully, fairly and in a transparent way;

• Collected only for valid purposes that we have explained to you clearly and not used in  any way that is incompatible with these purposes;

• Relevant to the purposes we have told you about and limited to those purposes only;  • Accurate and kept up to date;

• Kept only for such time as is necessary for the purposes we have told you about; and • Kept securely. 

• Must not be transferred to other countries without adequate protection

• Must be processed in line with the data subjects rights

 

3. What Information Does the Company Collect and Process?

The Company collects and processes a range of personal information (personal data) about you.  Personal data means any information about an individual from which the person can be identified.  This includes :

• Personal contact details, such as your name, title, address and contact details, including  email address and telephone number.

• date of birth;

• gender; country of residence

• the terms and conditions of your employment.

• details of your qualifications, skills, experience and employment history, including start  and end dates, with previous employers and with the Company;

• information about your remuneration, including entitlement to benefits such as pensions; • details of your bank account, tax status and national insurance number;

• information about your marital status, next of kin, dependants and emergency contacts; • information about your nationality and entitlement to work in the EU,UK,USA; • copy of driving licence;

• details of periods of leave taken by you, including holiday, sickness absence, family leave  and the reasons for the leave;

• details of any disciplinary or grievance procedures in which you have been involved,  including any warnings issued to you and related correspondence;

• assessments of your performance, including appraisals, training you have participated in,  performance improvement plans and related correspondence;

• Preferences (e.g. preferred cultural exchange programs, preferred educational courses) • Medical condition (e.g. allergies or illness);

• National Insurance Number;

• Start date, leave date;

• Recruitment information including copies of right to work documentation, references and  other information included in a CV or as part of the application process;

• Records from the Disclosure and Barring Service;

• Information about your use of our information and communications systems • Photographs;

• A log of our communications with you by email, telephone ,fax, Viber, skype and  WhatsApp.

 

SENSITIVE DATA

• We do not generally seek to collect any sensitive Personal Data. Sensitive Personal Data is data  related to racial or ethnic origin, political opinions, religious or philosophical beliefs, health or  medical condition, criminal background or trade union membership. In certain situations, this 

might however be necessary (for example in order to provide you with the services and products you have ordered and in relation to your insurance). We will make sure that we receive your  explicit consent to such processing and treat this information securely.

IF YOU ARE UNDER THE AGE OF 16

• If you are under the age of 16, you should review this text together with your parent or guardian to  make sure you both understand them. We are not responsible for checking your age but  sometimes we still do verification checks. If we learn that you are under the age of 16 and that we  have collected information about you without consent from your parent or guardian, we will delete  the information as soon as possible and you will not be able to use M.S.WRANGHEL Products.

 

4.How do we collect Personal Data?

We collect Personal Data in a variety of ways:

• Directly from you: Information is collected directly from you, either by you providing the  information directly to us or you acting in a manner that provides us with the information, for  example:

▪ Offline: We collect Personal Data from you offline, for example when you 

contact customer service, enroll in a product or service or provide information to  us in writing.

▪ Online: We collect your Personal Data through the M.S.WRANGHEL Products,  for example when you sign up for a newsletter or a brochure, enroll in a product  or service. We also collect Personal Data:

- through the application and recruitment process and during work-related 

activities throughout the period of working for us.

- In some cases, the Company collects personal data about you from third 

parties, such as references supplied by former employers and information from 

criminal records checks permitted by law.

- Through cookies. Cookies allow a web server to transfer data to a computer or  device for recordkeeping and other purposes.

From M.S.WRANGHEL corporate affiliates, business partners, assistance providers or claim handlers.

The outcome of criminal record checks and security clearance checks, where relevant, will be supplied by  the Disclosure and Barring Service or other external company applicable to the placement

From other sources. We may receive your Personal Data from other sources, such as public databases;  joint marketing partners such as marketing agencies or providers of software and services for digital  marketing automation and analytics; social media platforms, as well as from other third parties.

Data is stored in a range of different places, including in your personnel file, in the Company's scheduling  systems and in other IT systems (including the Company's email system).

 

5.How do we use Personal Data?

Service delivery and Information

• We need to process your personal data when we provide you with information and services that  you have requested from us. We do so because it is necessary for our legitimate interests and/or  because it is necessary for the performance of a contract to which you are a party or in order to  take steps at your request before entering into a contract. 

• If you request information via our website at www.mswranghel.ro you can see the website also  has a Privacy Statement detailing how information is obtained, used, stored, secured and  destroyed; you can see this information here: https://www.mswranghel.ro/privacy-policy

Marketing

• When we send marketing communications to you we do so because it is necessary for our  legitimate interests. Our legitimate interests include highlighting relevant services in order to fulfil  our vision to improve and deliver health and social care. You can request that we stop sending  you marketing communications at any time (see 'your rights' below).

• In respect of personal email addresses, we will only send you marketing with your explicit consent  and you can opt out at any time.

Partnership

• We may need to process your personal data when we partner with an organisation to deliver  services (such as within extra care schemes). This is necessary for the performance of a contract  to which you are a party or in order to take steps to deliver a new contract, provide information or  following a request before entering into a contract. We also work in partnership with other health  and social care providers. (See also Sharing Information section below)

Situations in which we will process your personal information are listed below: In order to:

• make decisions about recruitment and promotion processes;

• maintain accurate and up-to-date employment records and contact details (including  details of whom to contact in the event of an emergency), and records of employee  contractual and statutory rights;

• check you are legally entitled to work;

• gather evidence for, and keep a record of, disciplinary and grievance processes, to  ensure acceptable conduct within the workplace;

• pay you and, in the case of employees, make deductions for tax and National Insurance;  • make decisions about salary reviews and compensation;

• operate and keep a record of employee performance and related processes;

• keep records of training and development requirements;

• operate and keep a record of absence and absence management procedures, to allow  effective workforce management and ensure that employees are receiving the pay or  other benefits to which they are entitled;

• ascertain your fitness to work;

• operate and keep a record of other types of leave (such as maternity, paternity, adoption,  parental and shared parental leave), to allow effective workforce management, to ensure  that the organisation complies with duties in relation to leave entitlement, and to ensure  that employees are receiving the pay or other benefits to which they are entitled; • ensure effective general HR and business administration;

• provide references on request for current or former employees;

• deal with legal disputes involving you or other employees, workers and contractors; and • Facilitate equal opportunities monitoring in the workplace.

• To prevent fraud

• To monitor your use of our information and communication systems to ensure compliance  with IT policies.

• To ensure network and information security, including preventing unauthorised access to  our computer and electronic communications systems and preventing malicious software  distribution

• To conduct data analytics studies to review an better understand workers retention and  attrition rates

• Equal opportunities monitoring

• To allow you to participate on message boards, chat, profile pages and blogs and use  other services enabling you to post information and materials.

 

6. If You Fail to Provide Personal Information 

If you do not prove certain information when requested, the Company may not be able to perform  the contract we have entered into with you, such as paying you or providing a benefit. You may  also have to provide the Company with data in order to exercise statutory rights, for example in  relation to statutory leave entitlements. 

 

7.Change of Purpose

The Company will only use your personal information for the purpose for which it was collected  unless we reasonably consider that we need to use it for another reason and that reason is

compatible with the original purpose. If we need to use your personal information for an unrelated  purpose, we will advise you of this and explain the legal basis which allows us to do so. 

You should be aware that we may process your personal information without your knowledge or  consent where this is required or permitted by law.

 

8.How do we share Personal Data?

• We share your Personal Data with M.S.WRANGHEL’s corporate affiliates, business partners  and service providers both within and outside the EEA/UE:

▪ Our corporate affiliates are for example a local M.S.WRANGHEL company that  promotes the sales of our services and offers customer service in your country 

of residence, or the school in your destination country that provides some of the  services that you have ordered, or one of the principal companies that is 

offering another of M.S.WRANGHEL’s program.

▪ Business partners are for example local sales agents that promote the sales of  our services in your country of residence; transportation or accommodation 

providers in your destination country; or course leaders, activity leaders or other  contractors for management of any of our programs; or a travel insurance 

company that prepares the travel insurance for you.

▪ Service providers, such as providers of IT systems.

• We have put appropriate safeguards in place for transfers of your Personal Data outside the  UE/EEA, including the standard data protection clauses adopted by the European Commission,  available at http://eur-lex.europa.eu/legal

content/EN/TXT/?uri=CELEX%3A32004D0915 and http://eur-lex.europa.eu/legal content/en/TXT/?uri=CELEX%3A32010D0087. For more information on standard data protection  clauses in place, please see the contact section below.

• We also share Personal Data as we believe to be necessary: (a) under applicable law; (b) to  comply with legal process; (c) to respond to requests from public and government authorities  including public and government authorities outside your country of residence; (d) to enforce our  terms and conditions or a contract; (e) to protect our operations or those of any of our affiliates; (f)  to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g)  to allow us to pursue available remedies or limit the damages that we may sustain.

For the purposes referred to in this privacy notice and relying on the bases for processing as set out  above, we may share your personal data with certain third parties. We may disclose limited personal data  to a variety of recipients including:

• Other health and social care professionals where you require attention of those other  professionals. In all cases, your information is only accessed and used by authorised staff who  are involved in providing or supporting your direct care. Your permission will be asked before the  information is accessed, other than in exceptional circumstances (e.g. emergencies) if the  healthcare professional is unable to ask you and this is deemed to be in your best interests  (which will then be logged).

• Your information will be shared internally, including with Line Managers, Payroll and HR. • Our employees, agents and contractors where there is a legitimate reason for their receiving the  information

• Internal and external auditors and our legal advisers

• When M.S.WRANGHEL is legally required to do so (eg, by a court, government body, law  enforcement agency or other authority of competent jurisdiction), for example, by HM Revenue  and Customs.

We often work with third parties to help us provide our services and products to you. For example, if you  wanted to attend one of our events we may use a third party to manage the booking on our behalf.

We have contracts in place with all our third parties to make sure they protect and respect your  information with the same commitment as we do. For further information please contact us at  info.client@mswranghel.ro

 

9.On what do we base our right to collect and use Personal Data?

We base our right to collect and use your Personal Data on the need to do so in order to provide you with  the services or products that you have ordered from us, or when there is a legitimate interest for us (i.e.  the service provider) to use your Personal Data, such as for the marketing of products or services similar  to the one(s) you have already purchased from that same legal entity.

To the extent we use sensitive Personal Data, we base this on your explicit consent. Sensitive data can  for example be information about health, ethnicity, or religious beliefs, read more under “Sensitive data”.  To the extent that we use your Personal Data to send you offers beyond what is considered to be within 

our legitimate interest, such as marketing of products and services provided by a M.S.WRANGHEL  affiliate, we base this on your specific consent.

 

10.Security/How Does The Company Protect Data?

The Company takes the security of your data seriously. The Company has internal policies and controls  in place to prevent your data being lost, accidentally destroyed, misused or disclosed, and is not  accessed except by its employees in the performance of their duties. Details of these measures are  available on request.

When the Company engages third parties to process personal data on its behalf, they do so on the basis  of written instructions, are under a duty of confidentiality and are obliged to implement appropriate  technical and organisational measures to ensure the security of data.

 

11.HOW LONG DO WE STORE PERSONAL DATA?

We will only keep your Personal Data for as long as it is necessary for the purposes for which it has been  collected or in accordance with time limits stipulated by law and market practice, unless further retention  is necessary for compliance with a legal obligation or for the establishment, exercise or defence of legal  claims or unless a specific time period has been communicated.

We will keep limited parts of your Personal Data which are necessary for marketing purposes until you  withdraw your consent, but in no event for longer than 10 years after your last completed service or  delivery of product.

Your Duty to Inform Us of Changes 

It is important that the personal information we hold about you is accurate and current. Please be  sure to keep us informed if your personal information changes during your time working with us.

 

12.Your Rights

As a data subject, you have a number of rights. You can:

• access and obtain a copy of your data on request (known as a “data subject access  request”);

• require the Company to change incorrect or incomplete data;

• Request erasure of your personal information. This enables you to ask the Company to  delete or stop processing your data, for example where the data is no longer necessary  for the purposes of processing;

• Request the transfer of your personal information to another party.

• object to the processing of your data where the Company is relying on its legitimate  interests as the legal ground for processing; and

• Ask the Company to suspend the processing of your personal data for a period of time if  data is inaccurate or there is a dispute about its accuracy or the reason for processing it. 

If you would like to exercise any of these rights, or you have any questions about the privacy  notice, please contact Head Office. (info.client@mswranghel.ro)

If you believe that the Company has not complied with your data protection rights, you have the  right to make a complaint to the Information Commissioner’s Office.

The above rights are not absolute, and we may be entitled to refuse requests where exceptions  apply: for example, if we have reason to believe the personal data we hold is accurate or we can  show our processing is necessary for a lawful purpose set out in this notice.

Where our processing of your personal data relies on your consent, and where you then withdraw  that consent, we may not be able to provide all or some aspects of our services to you and/or it  may affect the provision of those services. If you have given your consent and you wish to  withdraw it, please contact us at:info.client@mswranghel.ro 

You can find out more about your rights under data protection legislation at:

https://www.dataprotection.ro/ If you are not satisfied with how we are processing your persona 12.Survey’s, Compliments and Complaints

If you participate in our satisfaction surveys, make a complaint or offer a written compliment, we will only  collect and process your personal information if it is provided, many of our surveys give the opportunity  for anonymity. We do so because it is necessary for our legitimate interests in pursuing feedback into the  health and care sector. However, we follow ethical guidelines when conducting surveys and will always  keep you informed of your rights. Should you feel the need to make a complaint you may do so  anonymously although without your personal details we will be unable to directly address any concerns  you have raised with you.

 

13. H O W D O I M A N A G E C O O K I E S ?

Although most internet browsers are initially set up to automatically accept cookies, most internet  browsers allow you to change the settings to block cookies or to alert you when cookies are being sent to  your device. In addition to the options provided above, you may refuse, accept or remove cookies from  the Site at any time by activating or accessing the setting on your browser. Information about the

procedure to follow in order to enable, disable or remove cookies can be found on your Internet browser  provider’s website via your help screen. Please be aware that if cookies are disabled or removed, not all  features of the Site may operate as intended, for example you may not be able to visit certain areas of our  Site or you may not receive personalised information when you visit the Site. If you use different devices  to view and access the sites (e.g. your computer, smartphone, tablet etc) you will need to ensure that  each browser on each device is adjusted to suit your cookie preferences. If you want to clean out all  cookies left behind by the websites you have visite.

 

14.UPDATES TO THIS PRIVACY POLICY

Our Privacy Policy may change from time to time. We will not significantly reduce your rights under this  Privacy Policy without informing you. We will post any Privacy Policy changes on this page and, prior to  implementing such changes, we will provide a more prominent notice. Where required by law, we will  seek your prior consent to any change.

 

15.REVIEW OF THIS STATEMENT

Review of this document is recorded on the controlled index and reviewed annually as part of the  management review process.

Policy Review Group Issue no:2 Date: August 2021

 

Notificare: confidențialitate și politica de protecție a datelo

M.S.WRANGHEL is committed to protecting and preserving the privacy of our visitors when visiting our website or communicating electronically with us. 

Please also see:

• Details of visits to our website and the pages and resources that are accessed, including, but not limited to, traffic data, location data and other communication data that may assist us in understanding how visitors use this website.

• Information that visitors provide to us as a result of filling in forms on our website, such as when a visitor registers for information or makes a purchase.

• Information provided to us when our visitors communicate with us electronically for any reason.

This Privacy Policy contains an explanation of what happens to personal data that you choose to provide to us, or that we collect from you whilst you visit this site. Our Privacy Policy should be read in conjunction with our terms of website use. We do occasionally update this Policy so please do return and review this Policy from time to time.

We collect in running and operating this website we may collect and process certain data and information relating to you and your use of this site. This data and information is detailed below:

 

Use of cookies

Cookies are sometimes used to improve the website experience of a visitor to a website. We may sometimes use cookies on this website to record aggregate statistical information about the visitors to our site and the use that our visitors make of the website. When collected this information is used by us to improve our website and further enhance the visitor experience and, may be shared with advertisers.

Please note that no personally identifiable information is recorded. We may also use the cookies to gather information about your general internet use to further assist us in developing or website. Where used, these cookies are downloaded to your computer automatically. This cookie file is stored on the hard drive of your computer. Cookies contain information that is transferred to your computer’s hard drive and then stored there and transferred to us where appropriate to help us to improve our website and the service that we provide to you.

All computers have the ability to decline cookies. You can easily decline or remove cookies from your computer using the settings within your browser. Our advertisers may also use cookies on their website. We have no control over this and you should review the privacy policy of any advertiser that you visit as a result of an advert or link on this website.

 

Use of your information

The information we collect is used for our own use in developing our website and also occasionally by advertisers on this site. In addition, we may use the information for the following purposes:

• To provide you with information relating to our website, products or our services that you request from us.

• To provide you with information on other products that we feel may be of interest to you.

• To meet our contractual obligations to you.

• To notify you about any changes to our website, including improvements, and service or product changes that may affect our website.

If you are an existing customer, we may contact you with information about goods and services similar to those that you have expressed an interest in previously via our website. Finally, we may use your data, or allow carefully selected third parties to use your data, so that you can be provided with information about unrelated goods and services which we consider are likely to be of interest to you. We or they may contact you about these goods and services by any of the methods that you consented to at the time your information was collected.

If you are a new customer, we will only contact you or allow third parties to contact you only when you have provided consent and, only by those means you provided consent for. If you do not want us to use your data for our or third parties use then you wil always have the option to object to such use.

 

Storing your personal data

Information that we collect will be securely stored within the European Union for the purpose of supplying our goods or services to you. By submitting your personal data, you agree to this transfer, storing or processing. We will always take all reasonable precautions to make sure that your data remains secure and is handled in accordance with this Privacy Policy. Data that is provided to us is stored on our secure servers. Details relating to any transactions entered into on our site will be encrypted to ensure its safety.

The transmission of information via the internet is not completely secure and therefore we cannot guarantee the security of data sent to us electronically and transmission of such data is therefore entirely at your own risk. Where we have given you (or where you have chosen) a password so that you can access certain parts of our site, you are responsible for keeping this password confidential.

 

Disclosing your information

Where applicable, we may disclose your personal information to any member of our group. This includes, where applicable, our subsidiaries, our holding company and its other subsidiaries (if any).

 

Third party links

You mind find links to third party websites on our website. These websites should have their own privacy policies which you should check. We do not accept any responsibility or liability for their policies whatsoever as we have no control over them.

 

Access to information

The Data Protection Act 2018 gives all individuals the right to access personal information that is held about them. You can request a copy of any information that we hold about you. Please note that any request for this information may be subject to payment of £10 which covers our administrative costs. Please contact us if you wish to make such a request.

 

Contact us

If you have any questions or queries relating to this Privacy Policy then please contact us.