Retention Policy

 1.Personal data operator

The operator of the personal data obtained from or granted by the company's clients is:

RAINBOW MARKETING & CONSULTING S.R.L. Commercial Company

Registered office address: Bucharest, 2nd Piața Alba-Iulia Street, building I1 entrance 1 ap. 11, 3rd District, Romania;

You can contact us through:

E-mail:

By phone: (+4) 0748 281 484 (normal rate call)  

By mail: 29th Tudor Vianu Street, Apt. 1, 1st District, post code 011636, Bucharest, Romania.

2.Requests regarding the Personal Data Storage (Retention) Policy

This Policy is applicable to both our contractual partners as Personal Data Operators under the General Data Protection Regulation and individuals with whom we directly contact for events, contests, or promotional campaigns on behalf of and for our client.

We only store and process your personal data in cases where you have voluntarily provided these data by sending a message using the predefined contact form on the website, telephone, e-mail or in direct contact with you or through our subcontractors (promoters).

To the extent that you have requests or questions about the periods of storage of your personal data within RAINBOW IDEA, please contact us using the above-mentioned email address or phone number.

3.Storage Policy

The RAINBOW IDEA storage policy is a tool that ensures requirements regarding the principle of accuracy and limitation of the storage of personal data under the General Data Protection (GDPR), relevant laws and regulations in the field of personal data protection are respected strictly. This policy encompasses the principle of limiting timed retention of processed personal data, which requires storage only for the time required for purposes for which such data is processed. The personal data retention (storage) policy is primarily intended as a favourable resource to the company’s activity that will allocate relevant retention periods in important business areas and company departments where the law does not impose precise storage deadlines, allowing the personal data removal/ deletion activities to take place in a consistent and controlled manner.

4.Retention (storage) periods

The personal data storage periods are specified in the table below and apply to all formats of entries, i.e. both paper and electronic format, unless otherwise specified in this Policy.

DEPARTMENT

PROCESSING ACTIVITIES

RETENTION PERIOD

NOTIFICATIONS SENT BY RAINBOW IDEA

Notifications SENT by RAINBOW IDEA directly or through its contractual partners (invoices, notice of non-payment, etc.)

3 years from the date of transmission of each notification

RELATIONS WITH SUPPLIERS

Contracts concluded by the company with suppliers

10 years from the date of contract’s termination

RELATIONS WITH CONTRACTUAL PARTNERS

Service Contracts (undertaking)

10 years from the date of contract’s termination

RELATIONS WITH THE REPRESENTATIVES OF THE CONTRACTUAL PARTNERS

Phone calls

We do not record / store phone calls

RELATIONS WITH THE REPRESENTATIVES OF THE CONTRACTUAL PARTNERS

Business cards collected at organized events

1 year from the date of receipt of the business card, if the contract is no longer valid

BUSINESS RELATIONS (B2B)

Personal data such as: name, position, and contact details of the representatives of the companies we collaborate with

Until the date requested for the deletion of the data or the date, we have learned that the data became inactive

We also note that, given the activity carried out by RAINBOW IDEA acting as the representative of its contractual partner, which is always a legal person (another company), personal data obtained from individuals on behalf and for our contractual partner (as part of promotional events organized by RAINBOW IDEA where individuals participate) will be processed according to the instructions provided by our partner and within the limits set forth herein. As a result, we process data for well-defined purposes by forwarding such data as well as any information about or in connection with these data to our partner for whom this data has been obtained.

For information on the storage periods of personal data processing activities within the company that are not covered by this Policy, please send your requests to the above-mentioned email address or by accessing other means of communication made available under art. 1 and having regard to the conditions stipulated in art. 2.

  1. 5.Retention plan

The storage period is applied by default to all entries in that category and will be respected whenever possible, although we admit that there may be exceptional circumstances requiring the retention of documents for either shorter or longer periods. If entries or individual documents require a different retention period, RAINBOW IDEA should be contacted to discuss specific storage requirements.

6. Data deletion

You may request the deletion of personal data to the extent that we hold these data at the time of submitting the request by sending an email toin which you need to specify the following:

- Your contact details for sending the company's response / opinion;

- Your name;

- Processing activities through which data was collected or processed (in promotional campaigns such as events, prize competitions or other types of campaigns for marketing and advertising purposes, the conclusion of a contract, the transmission of a written request by post or e-mail or by phone call, etc.);

- The type of collected or processed data that you want to delete;

- Total number of entries to be deleted.

If we no longer have personal data obtained in your direct contact with you at the time of your request, we will let you know our partner's data to address your request.

The deadline for replying to the request is one month after the request was submitted.

We respond to deletion requests received from representatives of our contractual partners, legal entities, namely Personal Data Operators or Persons empowered by the Operators, with whom we have entered into collaborations (such as for the purpose of doing the activities related to collecting information for carrying out the promotional activities of the products or services of our partner) to which we are liable as Personal Data Operators.

To the extent that your request will be solved after its assessment under RAINBOW IDEA with the deletion of your data, we will prepare a standardized document that will be sent to your attention through the agreed means of communication. The document shall include at least the following information:

- Purpose (s) on which the data were obtained (processed);

- Data that was transferred/deleted/removed/destroyed, and the processing activity performed within RAINBOW IDEA;

- Number of entries removed.

The hardcopy transmitted is signed by a representative of RAINBOW IDEA and is stored and scanned in physical format for a period of 3 years from the date of transmission of the notification, after which the original document will be destroyed and recycled. If the opinion will be sent by email, it will be stored on the company's servers for a period of 3 years from the date of submission to the applicant at the email address provided, and then deleted.

If you submit a request to RAINBOW IDEA for access to the processing of your personal data in our company, please be aware that due to the processing of your personal data and taking into account the routine established in our systems for deleting processed information in the terms of the Data Storing Policy, or if in the case of individuals, the obligation to send these data to our contractual partner, we try to keep you data up-to-date and accurate at all times.Thus, this routine processing may involve modifying or deleting the personal information we process after you have submitted a request to us. In this case, RAINBOW IDEA will provide the information held at the time we send you the response, even if they differ from the information we stored at the date of submission of the request. Please note that deleting or transmitting your personal data is a procedure that RAINBOW IDEA would have performed even if you had not submitted the request.

7. Continuous development

The storage (retention) periods will be maintained by RAINBOW IDEA, which will make modifications, additions and updates, whenever the legislation, the guidelines of the National Supervisory Authority for Personal Data Processing or the organizational or structural modifications of RAINBOW IDEA impose these changes.

8. Updates

Our data storage (retention) policy may be changed from time to time (generally to comply with data protection and processing laws and practices). Updated versions will be published on our website.

©- RAINBOW IDEA: May 2019