POLICY OF PRIVACY
Personal data processing with MyEdenred mobile application
VERSION OF: JANUARY 2020
1. WHO ARE WE?
2. WHAT IS THE INFORMATION WE COLLECT ABOUT YOU?
2.1. In order to create your account, we will process your personal data represented by your name, surname, e-mail address and access password (the access password will be processed in an encrypted form), the identification data of your Edenred card (series consisting of 10 digits displayed on the back of the card and the last digits of the number displayed on the face of the card), the city and county of residence. The city and county of residence are collected on the basis of the legal provisions on combating money laundering and terrorist financing.
2.2. Optionally, when creating the account in the application, you can also provide us with your mobile phone number.
2.3. For a better quality of services offered, within the Application we will process the history of the transactions made, which we will show you for a better management of your expenses, the balance of the card, the validity of the vouchers charged on the card, as well as the PIN code, which we can remind you after following a security procedure.
2.4. In order to ensure the functionality of the Application, we will process data relating to the device used (hardware) and the operating system, log information, such as the IP address, date and time when the Application was used, including your preferences data related to marketing notifications.
2.5. Through our websites, we will not collect or disclose data on racial or ethnic origin, political beliefs, religious, philosophical or other of similar nature, union membership or personal data on your health or sexual life.
3. WHAT IS YOUR PERSONAL DATA USED FOR AND WHAT ARE THE GROUNDS FOR PROCESSING?
3.1. We will process your personal data with the following purposes::
- a) to carry out services related to the operation of the Edenred cards (activate account, activate card, view transaction history, charges, balance, expiring amounts, PIN reminder, card lock in case of theft or loss, suggestions and notices) and to process your requests related to accessing/using our products.
Grounds The processing of your data for this purpose is based on the agreement between your employer and Edenred and the compliance with the legal requirements provided by the Law on granting of securities, which states that we must provide you access to the available balance or to lock the card, and the provision of your personal data is necessary in order to use the services within the Application.
- b) analyses and statistics on the use of our products
Grounds: : We strive to constantly improve the quality of our products and services. Based on our legitimate interest, we use the data collected from you or other data we generate/deduce from the data received from you or resulted from using our products for various statistics, analyses and surveys. When we conduct statistical analyses on the use of our products and services, the analysed data is strictly protected and the aggregated results are used internally or may be communicated to our trade partners on the basis of an existing contractual relationship in this regard, without allowing the identification of the data subjects and observing the applicable legal requirements.
- c) advertisement, marketing and advertising, activities to promote the products and services of Edenred Romania S.R.L. and of its partners, conducting promotional campaigns, sending newsletters (newsletters)
Grounds: The processing of your data for this purpose is based on your consent. When you create your account, you may choose to receive various commercial notifications from us to improve your shopping experience and to help you benefit from advantageous offers from our partners. You can choose to receive news and offers through various ways (email, SMS, or push notifications on your mobile phone screen), indicating that you can change your option at any time within the "Settings" section.
- d) creating profiles in order to customize the promotional offers
Grounds: : Edenred may divide its own customers according to several criteria in order to classify them in various categories for marketing and/or analysis purposes. The processing of your data for this purpose is based on a legitimate interest. These profiles do not entail exclusive automatic decision making. We want to offer you the most relevant products and services, in agreement with your profile and area of interest and for that purpose you may receive different customized commercial notifications from us, to improve your shopping experience and to help you benefit from the most advantageous offers from our partners. The promotional offers of our partners displayed in the Application may be general or customized. The general promotional offers displayed within the Application do not imply the processing of personal data, therefore they will be displayed to all those who use the Application. The customization of the offers will be made according to one or several of the following criteria: county/city of residence, gender, age, purchasing habits resulting from your transactions with the Edenred cards, displayed in the Application.
- e) fulfilment of legal obligations
Grounds: We have certain legal obligations involving the processing of personal data, such as specific obligations related to the prevention and combating of money laundering and terrorist financing, reporting to the relevant tax authorities and keeping accounting records.
- f) To find, exert or defend a legal right in proceedings before a court, in an administrative proceeding or in other official proceedings involving Edenred, as well as for the settlement of requests, complaints or claims.
Grounds: The processing of your data to this end is based on our legitimate interest to defend our rights and interests.
- g) to send messages aimed at improving our services (surveys of questionnaires)
Grounds: Because we want you to have the best interaction with our products and services, based on our legitimate interest, we will use your data (email and telephone) as user of our products or obtained in any other manner when you made this data available for the representatives of our company, to find out your opinion about the quality of our products. We will never ask for more than your feedback regarding the use of our products and we will use your answers to make our products and services simpler and more effective to use.
4. TO WHOM DO WE DISCLOSE YOUR DATA?
4.1. As the case may be, we can disclose your personal data, solely for the purposes of processing, to:
- a) companies within the Edenred Group;
- b) our service providers (acting either as controllers or as persons authorised by Us) and who We contract for administrative and transaction processing services, for marketing, other service providers (e.g. the payment service providers, IT service providers);
- c) agencies for market research which conduct market surveys for us;
- d) other companies with which we can develop common programmes to put our products and services on the market;
- e) public authorities, if such disclosure is necessary to comply with an obligation under the applicable law;
- e) your employer, Edenred’s trade partner, upon request.
4.2. The transmission of your personal data to the abovementioned recipients will only be made based on a commitment to privacy and to ensuring an adequate level of security on their part, guaranteeing that your personal data is kept safe and that its transmission is made in accordance with the legislation in force.
5. TRANSFER OF PERSONAL DATA
5.1. The personal data provided to Us may be transferred outside Romania, only to those states members of the European Union.
6. DURATION OF PROCESSING
6.1. Generally, we will process your personal data for as long as necessary to achieve the processing purposes mentioned above, except where the legal provisions state or oblige us otherwise. As follows:
- ● with regard to the issuance of securities, we will retain your data during the period of a contractual relationship with your employer, and the register of electronic ticket transactions will be kept for a minimum period of 5 years, in accordance with the legal provisions relating to securities, unless we are legally obliged to retain them for a longer period, or, where appropriate, for a reasonable additional period necessary to exert or to defend our rights related to the products/services offered and to the personal data processed;
- ● with regard to the issuance of electronic money cards, we will retain your data for the period of 5 years calculated from the termination of your contractual relationship with your employer or with the partner who offered you that card, unless we are legally obliged to retain such data for a longer period of time, or, where appropriate, for a reasonable additional period necessary to exert or defend our rights in relation to the products/services offered and with the personal data processed;
- ● with regard to the commercial notifications sent by Edenred or its partners, we will retain your e-mail address or phone number in our database as long as your subscription is active; from the moment we receive your request to unsubscribe, we will deactivate the sending of such notifications to your email address or phone number;
- ● with regard to the online accounts that you create in the Application, we will retain your personal data during the existence period of your account and subsequently for the period necessary to prove the operations made through the account; if you exert your option to disable the user account, Edenred will understand this action as your option to unsubscribe from receiving commercial notifications by which we keep you informed of the products and services we offer. In this respect, if you choose to deactivate your user account, we will cease to send you any notifications of this kind. However, we would like to inform you that disabling your account will not automatically erase your personal data. If you want to stop your personal data from being processed, or if you want to erase your data, you can exert your rights detailed at point 7 below.
- ● with regard to customer/trader recommendation programmes, we will retain your personal data for the period necessary to carry out these programmes and to prove your participation in these programmes;
6.2. Edenred may erase your personal data when it considers that it is no longer necessary for the purposes for which it was collected. We will not retain and we will not have no access to the following data, which is automatically deleted when you leave the appropriate section of the application: geolocation data from the "Map of Traders" section and the data on your physical characteristics (weight, height, age), completed in the section „Hai la 1 la masa” ("Come to lunch at 1" ).
6.3. In any case, if you withdraw your consent and there are no legal grounds for processing or you oppose the processing and there are no legitimate and compelling reasons for the processing to prevail, we shall cease such processing of your data.
7. WHAT ARE YOUR RIGHTS
7.1. Regarding this processing of your data, you have the right to request access to your personal data (you have the right to obtain from Edenred the confirmation that Edenred processes your personal data, as well as information on the specifics of the processing), its rectification (modification) or deletion or the restriction of the processing, the right to object to the processing within the limits and conditions provisioned by the law, as well as the right to data portability (they have the right to request us to provide your personal data in a structured, frequently used form which can be read in an automated manner, such as the Excel format). Also, if you choose to give your consent, you have the right to withdraw it at any time without affecting the processing carried out by Edenred on the basis of the consent expressed by you prior to this withdrawal. In addition, you have the right to submit complaints to the National Supervisory for Personal Data Processing.
7.2. For any further questions as to how your personal data is processed and to exert your rights as mentioned above, please go to: email@example.com. You can also submit a personalized request, signed and dated with your personal data that you wish us to update or delete, to our addresses, to the attention of the data processing officer:
Headquarters of Edenred Bucharest, Calea Şerban Vodă 133, 040205 - Sector 4, Bucharest.
7.3. The compliance with the legal requirements in this field is monitored and ensured inclusively by the person responsible to protect the data appointed within the Edenred Group, who has the following contact details: firstname.lastname@example.org.
8. USE OF THE APPLICATION
8.1. Edenred does not force anyone to provide all the data and information requested, but it reserves the right that, in the absence of the necessary information and data, not to allow the opening of the user account of the MyEdenred mobile application.
8.2. Please provide only real data and information and, in particular, do not provide any identification data that does not belong to you (for example, do not use a false email address or one belonging to another person). Consequently, Edenred reserves the right to verify the veracity of the data and information provided by you in the procedure to create a user account, as well as the right to refuse to create a user account if the information provided is not real or, where appropriate, to suspend or terminate such an account. Also, as a user you understand and accept that you are solely and fully responsible for the information provided in the user account creation procedure, both to Edenred and to any other third party that may be harmed.
8.3. The user account is personal and you have the obligation:
- ● not to transfer, (temporarily or permanently, free of charge or onerously) the right to use the Application or the user account to any third party.
- ● to keep the privacy of your Application access data and to notify about any unauthorized use and about any security breach you suspect or identify.
9. UPDATING THE INFORMATION INCLUDED IN THIS POLICY
9.1. Edenred may periodically update this Policy as the activity and services rendered by it extend or change, or if Edenred is obliged by law to make changes. Should Edenred do that, it will display on its websites the most up to date version. As such, please check regularly if there are any updates. Should Edenred bring major changes to the practices specified in this Policy, we will notify you using the available contact details.