“DEMA ENERGY”, “we”, “us”, “ours” mean DEMA ENERGY S.R.L., as well as its subsidiaries and affiliates (collectively, “DEMA ENERGY”) is committed to protecting the privacy of the individuals we encounter in conducting our business.

Your privacy is one of our fundamental commitments at DEMA ENERGY. Therefore, we take outmost care to process your personal data in accordance with the principles set forth in the data protection legislation applicable in Romania, including (EU) Regulation 2016/679 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 (“GDPR”).

“Personal Data” is information that identifies and relates to you or other individuals (such as your dependents). Our aim is responsible handling of Personal Data, balancing the benefits of activities like research and data analytics with our other commitments, including transparency and non-discrimination.

This Privacy Policy regards the Personal Data of our clients, business partners, other persons contacting and visiting us and of the representatives thereof, potential employees, interns, associates or persons attending events organized by or with the involvement of DEMA ENERGY and it applies to data collected through:

• this website (the “Website”), the software applications made available by us for use on or through computers, mobile devices or other Internet-connected devices (the “Apps”), our social media pages set forth in the links in the footer on www.demaenergy.ro (our “Social Media Pages”) (collectively, including the Website, the Apps and our Social Media Pages, referred to as the “DEMA ENERGY On-line Services”); and
• other means (for example, from telephone calls, e-mails and other communications with us, as well as from other third parties involved in our business dealings with you).

By using the DEMA ENERGY On-line Services, you signify your acceptance of this Privacy Policy.

This Privacy Policy describes how we handle Personal Data that we collect as well as:

• How to contact DEMA ENERGY about your Personal Data;
• The categories of Personal Data we collect from you and how we use Personal Data;
• The purposes for which we collect and use your Personal Data;
• International transfer of Personal Data;
• Sharing of Personal Data (to whom we may disclose your Personal Data);
• The duration of processing of such Personal Data;
• Security;
• Personal Data of other individuals;
• Marketing preferences;
• Questions and concerns;
• Third party privacy practices;
• Use of services by minors;
• Your rights and the manner in which you may exercise them;
• Changes to this Privacy Policy.

WHO TO CONTACT DEMA ENERGY ABOUT YOUR PERSONAL DATA

If you have any questions about our use of your Personal Data you can e-mail contact@demaenergy.ro.

PERSONAL DATA THAT WE COLLECT

Depending on your relationship with us (for example, as a client/customer; or other person relating to our business), Personal Data collected about you and your dependents may include:

• General identification and contact information: Your name; address; e-mail and telephone details; gender; marital status; family status; date of birth; educational background;
• Identification numbers issued by government bodies or agencies: Passport number; tax identification number or other license number;
• Financial information and account details: Payment card number; bank account or other financial account number and account details; credit history and credit score; assets; income; and other financial information;
• Other sensitive information: In certain cases, we may obtain information about your criminal record or civil litigation history. We may also obtain sensitive information if you voluntarily provide it to us;
• Telephone recordings: Recordings of telephone calls to our representatives and call centers;
• Photographs and video recordings: Photographs or video recordings created in connection with our business activities, or for other relevant purposes as permitted by law;
• Marketing preferences, customer feedback and survey responses: You may let us know your marketing preferences, enter a contest or prize draw or other sales promotion, or respond to a voluntary survey;
• Social media account and information from Apps: We may receive certain Personal Data about you when you use our Apps or Social Media Pages, including your social media account ID and profile picture. If you elect to connect any of your other social media accounts to your account(s) on the DEMA ENERGY On-line Services, Personal Data from your other social media account(s) will be shared with us, which may include Personal Data that is part of you profile relating to those accounts or your friends’ profiles;
• Information from Other Sources: We and our service providers may supplement the Personal Data we collect with information from other sources, such as publicly available information from social media services, commercially available sources and information from our affiliates or business partners.

HOW WE USE PERSONAL DATA

We use this Personal Data to:

• Communicate with you and others as part of our business;
• Respond to your requests;
• Send you important information regarding changes to our policies, other terms and conditions, our DEMA ENERGY Services and other administrative information;
• Make decisions about whether to provide products and services which we offer, and provide such products and services;
• Provide improved quality, training and security (for example, with respect to recorded or monitored phone calls to our contact numbers);
• Prevent, detect, analyze and manage commercial risks;
• Carry out research and analysis, including analysis of our customer base and other individuals whose Personal Data we collect as explained in this Privacy Policy;
• Provide marketing information to you (including information about other products and services offered by selected third-party partners) in accordance with preferences you have expressed;
• Personalize your experience when using our DEMA ENERGY Services or visiting third-party websites by presenting information and advertisements tailored to you;
• Identify you to anyone to whom you send messages through any of the DEMA ENERGY On-line Services;
• Allow you to participate in contests and similar promotions, and to administer these activities. Some of these activities have additional terms and conditions, which could contain additional information about how we use and disclose your Personal Data, so we suggest that you read these carefully;
• Facilitate social sharing functionality;
• Manage our infrastructure and business operations, and comply with internal policies and procedures, including those relating to auditing; finance and accounting; billing and collections; IT systems; data and website hosting; data analytics; business continuity; and records, document and print management;
• Resolve complaints, and handle requests for data access or correction;
• Comply with applicable laws and regulatory obligations (including laws outside your country of residence), such as those relating to anti-money laundering, sanctions and anti-terrorism; comply with legal process; and respond to requests from public and governmental authorities (including those outside your country of residence);
• Establish and defend legal rights; protect our operations or those of any of our group companies or business partners, our rights, privacy, safety or property, and/or that of our group companies, you or others; and pursue available remedies or limit our damages.

INTERNATIONAL TRANSFER OF PERSONAL DATA

Due to the global nature of our business, for the purposes set out above we may transfer Personal Data to parties located in other countries. We may transfer information internationally to our group companies, service providers, business partners and governmental or public authorities. By providing Personal Data and other information to DEMA ENERGY, including through the DEMA ENERGY On-line Services, and/or by sending a communication to an “DEMAEnergy.ro” e-mail address, you understand and consent to the collection, use, processing disclosure and transfer of such information in the Romania and other countries or territories, which may not offer the same level of data protection as the country where you reside, in accordance with the terms of this Privacy Policy. Further, please note that any communication you send to an “DEMAEnergy.ro” e-mail address will be routed through Romania.

SHARING OF PERSONAL DATA

DEMA ENERGY may make Personal Data available to:

• Our group companies: Other DEMA ENERGY group companies may have access to and use of Personal Data in connection with the conduct of our business where appropriate;
• Other parties: In the course of marketing and business, DEMA ENERGY may make Personal Data available to third parties such as appointed representatives; distributors; affinity marketing partners; and financial institutions and other business partners;
• Our service providers: External third-party service providers, such as accountants, auditors, experts, lawyers and other outside professional advisors; call center service providers; IT systems, support and hosting service providers; printing, advertising, marketing and market research and analysis service providers; banks and financial institutions that service our accounts; translators; and similar third-party vendors and outsourced service providers that assist us in carrying out business activities;
• Recipients of your social sharing activity: Your friends associated with your social media account(s), other website users and your social media account provider(s), in connection with your social sharing activity, such as if you connect another social media account to your DEMA ENERGY On-line Services account or log into your DEMA ENERGY On-line Services account from another social media account. By connecting your DEMA ENERGY On-line Services account and your other social media account you authorize us to share information with your social media account provider and you understand that the use of the information we share will be governed by that other social media website’s privacy policy. If you do not want your Personal Data shared with other users or with your other social media account provider(s), please do not connect other social media accounts with your DEMA ENERGY On-line Services account and do not participate in social sharing using our DEMA ENERGY On-line Services;
• Providers of Internet-connected devices and associated software: DEMA ENERGY may make the Personal Data you provide to us via our Apps available to providers of Internet-connected devices and/or associated operating systems and/or software as set forth in the terms of use and/or privacy policies you agree to with those providers;
• Governmental authorities and third parties involved in court action: DEMA ENERGY may also share Personal Data with governmental or other public authorities (including, but not limited to, courts, tax authorities); and third-party civil legal process participants and their accountants, auditors, lawyers and other advisors and representatives as we believe to be necessary or appropriate: (a) to comply with applicable law, including laws outside your country of residence; (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; (e) to protect our operations or those of any of our group companies; (f) to protect our rights, privacy, safety or property, and/or that of our group companies, you or others; and (g) to allow us to pursue available remedies or limit our damages;
• Other Third Parties: We may share Personal Data with purchasers and prospective purchasers or other parties in any actual or proposed reorganization, merger, sale, joint venture, assignment, transfer or other transaction relating to all or any portion of our business, assets or stock.
• Should you prefer, we will not disclose confidential Personal Data about you to non-affiliated third parties. You may opt out of those disclosures; that is, you may direct us not to make those disclosures (other than disclosures required or permitted by law). Should you wish to opt out of disclosures to non-affiliated third parties you may contact us by e-mail at contact@DEMAEnergy.ro.

Personal Data may also be shared by you, on message boards, chat, profile pages and blogs, and other services to which you are able to post information and materials (including, without limitation, our Social Media Pages and Apps). Please note that any information you post or disclose through these services will become public information, and may be available to visitors who access the DEMA ENERGY On-line Services and to the general public. We urge you to be very careful when deciding to disclose your Personal Data, or any other information, on the DEMA ENERGY On-line Services.

DURATION OF PROCESSING

How long DEMA ENERGY holds Personal Data will vary. The retention period will be determined by various criteria including:

• the purpose for which DEMA ENERGY is using it – DEMA ENERGY will need to keep the Personal Data for as long as is necessary for that purpose; and
• legal obligations – laws or regulation may set a minimum period for which DEMA ENERGY has to retain Personal Data.

SECURITY

DEMA ENERGY will take appropriate technical, physical, legal and organizational measures, which are consistent with applicable privacy and data security laws. Unfortunately, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any Personal Data you might have with us has been compromised), or if you have other data security questions or concerns related to DEMA ENERGY, please immediately notify us (Please see the “How to Contact DEMA ENERGY About Your Personal Data” section above).

When DEMA ENERGY provides Personal Data to a service provider, the service provider will be selected carefully and required to use appropriate measures reasonably designed to protect the confidentiality and security of the Personal Data.

If we believe the security of your Personal Data in our possession or control may have been compromised, we may seek to notify you of that development. If a notification is appropriate, we would endeavor to do so as promptly as possible under the circumstances, and, to the extent we have your e-mail address, we may notify you by e-mail.

PERSONAL DATA OF OTHER INDIVIDUALS

If you provide Personal Data to DEMA ENERGY regarding other individuals, you agree: (a) to inform the individual about the content of this Privacy Policy, and any other applicable DEMA ENERGY Privacy Notice provided to you; and (b) to obtain any legally-required consent of Personal Data about the individual in accordance with this Privacy Policy.

MARKETING PREFERENCES

We will provide you with regular opportunities to tell us your marketing preferences, including in our communications to you. You can also contact us by e-mail at contact@DEMA Energy.ro to tell us your marketing preferences and to opt out.

If you no longer want to receive marketing-related e-mails from DEMA ENERGY on a going-forward basis, you may opt out of receiving these marketing-related emails by clicking on the link to “unsubscribe” provided in each e-mail or by contacting us at the above addresses. We will endeavor to comply with your opt-out request(s) within a reasonable time period. Please note that if you opt out as described above, we will not be able to remove your Personal Data from the databases of third parties with whom we have already shared your Personal Data (i.e., to those to whom we have already provided your Personal Data as of the date on which we respond to your opt-out request). Please also note that if you do opt out of receiving marketing communications from us, we may still send you other important administrative communications from which you cannot opt out.

QUESTIONS AND CONCERNS

Please contact us as set out in the “How to Contact DEMA ENERGY About Your Personal Data ” section above with any such requests or if you have any questions or concerns about how we process Personal Data.

OTHER INFORMATION WE COLLECT THROUGH OUR DEMA ENERGY ONLINE SERVICES

“Other Information” is any information that does not reveal your specific identity, such as:

• Browser and device information;
• App usage data;
• Information collected through cookies, pixel tags and other technologies;
• Demographic information and other information provided by you; and
• Aggregated information.

We and our third-party service providers may collect Other Information in a variety of ways, including:

• Through your browser or device: Certain information is collected by most websites or automatically through your device, such as your IP address (i.e., your computer’s address on the internet), screen resolution, operating system type (Windows or Mac) and version, device manufacturer and model, language, internet browser type and version, time of the visit, page(s) visited and the name and version of the DEMA ENERGY On-line Services (such as the App) you are using. We use this information to ensure that the DEMA ENERGY On-line Services function properly;
• Using cookies; online tracking: Cookies are pieces of information stored directly on the device you are using. Cookies allow us to recognize your device and to collect information such as internet browser type, time spent on the DEMA ENERGY On-line Services, pages visited, language preferences, country website preference. We may use the information for security purposes, to facilitate navigation, to display information more effectively, or to personalize your experience while using the DEMA ENERGY On-line Services. In addition, we may use the information to gather statistical information about the usage of the DEMA ENERGY On-line Services in order to understand how they are used, continually improve their design and functionality, and assist us with resolving questions about them. Cookies further allow us to present to you the advertisements or offers that are most likely to appeal to you. We may also use cookies to track your responses to our advertisements and we may use cookies or other files to track your use of other websites. We do not respond to browser do-not-track signals at this time. The Website doesn’t follow to the DNT setting. Third parties may collect information about your use of the DEMA ENERGY On-line Services and your use of other websites or online services.
• The details on the cookies we may use on the Website, what they do, what data about you they collect and what we may use them for are available in our Cookies Policy.
• Using pixel tags, web beacons, clear GIFs or other similar technologies: These may be used in connection with some DEMA ENERGY On-line Services and HTML-formatted e-mail messages to, among other things, track the actions of users of the DEMA ENERGY On-line Services and e-mail recipients across the devices they use, measure the success of our marketing campaigns and compile statistics about usage of the DEMA ENERGY On-line Services and response rates. In some instances, we may combine information collected through these technologies with your Personal Data.
• We use the Google analytics service, which uses cookies and web beacons to help us understand more about how our Website is used by consumers so we can continue to improve it. Google does not have the right to use the information we provide to them beyond what is necessary to assist us.
• For more information on the Google service, including how to opt out, go to https://support.google.com/analytics/.
• We may use interest-based advertising service providers to customize, target, serve and report on DEMA ENERGY advertisements served across the web and mobile applications, based on information relating to our offline interactions with you, our online interactions with you (on any of your devices) and information received from third parties. To do this, these service providers may use cookies, pixel tags and other technologies to collect information about your and other users’ use of the DEMA ENERGY On-line Services and third-party sites and mobile applications. They may also use these technologies, along with information they collect about your online use, to recognize you across the devices you use, such as a mobile phone and a laptop. Our service providers may also match Personal Data we provide to them with your IP address and serve DEMA ENERGY advertisements to you across the web, based on your IP address. If you would like to opt out of having your information used for these purposes, visit the self-regulatory program opt-out pages at www.aboutads.info/choices/ or www.networkadvertising.org/managing/opt_out.asp to opt out in desktop and mobile web browsers on the particular device from which you access the opt-out options.
• Using your Physical Location: We may collect the physical location of your device by, for example, using satellite, cell phone tower or WiFi signals. We may use your device’s physical location to provide you with personalized location-based services and content. We may also share your device’s physical location, combined with information about what advertisements you viewed and other information we collect, with our marketing partners to enable them to provide you with more personalized content and to study the effectiveness of advertising campaigns. In some instances, you may be permitted to allow or deny such uses and/or sharing of your device’s location, but if you choose to deny such uses and/or sharing, we and/or our marketing partners may not be able to provide you with the applicable personalized services and content. You may opt-out of our collection and sharing of precise geolocation information by deleting the mobile application from your device, by disallowing the mobile application to access location services through the permission system used by your device’s operating system, or by following any additional opt-out instructions provided in the privacy notice available within the mobile application.
• Using information provided by you: Some information (for example, your location or preferred means of communication) is collected when you voluntarily provide it. Unless combined with Personal Data, this information does not personally identify you.
• By aggregating information: We may aggregate and use certain information (for example, we may aggregate information to calculate the percentage of our users who have a particular telephone area code).

Please note that we may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. If we are required to treat Other Information as Personal Data under applicable law, or if we combine Other Information with Personal Data, then, in addition to the uses listed in the “Other Information We Collect” section above, we may use and disclose Other Information for all the purposes for which we use and disclose Personal Data.

THIRD PARTY PRIVACY PRACTICES

This Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including any third party operating any site or service to which the DEMA ENERGY On-line Services link. The inclusion of a link on the DEMA ENERGY On-line Services does not imply endorsement of the linked site or service by us or by our group companies.

Please note that we are not responsible for the collection, usage and disclosure policies and practices (including the data security practices) of other organizations, such as Facebook, Apple, Google, Microsoft, RIM or any other software application developer or provider, social media platform, operating system or wireless service provider, or device manufacturer, including any Personal Data you disclose to other organizations through or in connection with the Apps or our Social Media Pages.

USE OF SERVICES BY MINORS

The DEMA ENERGY On-line Services are not directed to individuals under the age of eighteen (18), and we request that these individuals do not provide Personal Data through the DEMA ENERGY On-line Services.

YOUR RIGHTS

In your capacity as data subjects, the GDPR provides you with a series of rights including:

• Right of access: Allows you to obtain confirmation that your Personal Data are being processed by us and, if affirmative, the relevant details of such processing activities;
• Right to rectification: Allows you to rectify your Personal Data if inaccurate;
• Right to erasure: Allows you to obtain the erasure of your Personal Data in certain cases (e.g., if the data are no longer necessary in relation to the purposes for which it was collected).
• Important! We will not be able to act on such requests in all cases, such as where the law compels us to keep data for a certain period, or where the Personal Data are necessary for a legitimate interest such as the defense of a right in court;
• Right to restriction: Allows you to request us not to use your Personal Data in any way except to store it until another request from you is resolved, namely: (i) you have requested the rectification of the Personal Data; (ii) you have opposed the erasure of the Personal Data in the case of unlawful processing; (iii) you have required us to provide you with certain Personal Data for the defense of a right; (iv) you have objected to the Personal Data processing;
• Right to object: Allows you to object to further processing of your Personal Data within the conditions and limits set forth by law.
• Important! The law compels us to act on such requests only for direct marketing processing (for example, if you receive emails with our informative notes, you can unsubscribe). In the other cases, we will balance our interests and your particular situation in order to make a final decision. Therefore, please explain why you object to the processing when making such a request;
• Right to portability: Allows you to receive the Personal Data concerning you that you have provided to us, in a structured, commonly used and machine-readable format or to transmit this Personal Data to another data controller.
• Important! The law compels us to act on such requests only for the Personal Data previously processed based on your consent or on the performance of the contract concluded with us and only if the processing is carried out by automated means.

We are happy to ensure your exercise of these rights.

You may exercise your aforementioned rights and find out more about such rights by filing with us, as data controller, by e-mailing us at contact@DEMA Energy.ro.

You also have the right to file a complaint with the data protection authority, having its headquarters at 28-30 G-ral Gheorghe Magheru Bld. District 1, Bucharest, 010336, Romania. We are committed to always treat your requests with the utmost attention and address any queries you may have in the shortest time possible.

CHANGES TO THIS PRIVACY POLICY

This Privacy Policy is in force as of [March, 25, 2022]. We review this Privacy Policy regularly and reserve the right to make changes at any time to take account of changes in our business and legal requirements. We will place updates on our Website. Any changes shall become effective as of the date they are posted on the Website.

Please take a look at the “Last Updated” date at the top of this Privacy Policy to see when it was last revised.