Personal data is information, or any combination of separate information, that could be used to identify you. We may collect information about you from a variety of sources. This includes information we collect directly from you, information we collect when you visit our website, view our online content, and information we collect about you from other third-party sources.
Information we collect directly from you
We collect information directly from you when you participate in our offers and programs or participate in phone calls and email correspondence with us or otherwise provide information directly to us.
The following information we may collect using these technologies is:
We also collect your personal data from the following third-party sources: publicly available sources, third-party referral agencies, social media platforms, legitimate marketing lists or authorized referral agents.
The following information we may collect from third-party sources is:
The legislation treats some types of personal data about you differently as ‘special’, as this data requires more protection due to its sensitive nature. This includes information about race, religion, health, sex life, public opinion or sexual orientation. This also applies to crimes. We will only collect or use this type of personal data (i) with your explicit consent or (ii) if we are required to do so by law.
We use your personal data to provide you with products, offers and services, to deliver advertisements, offers or other content tailored to your interests, to answer your questions and to carry out other business operations. We will only use your personal data where we have a valid legal basis to do so.
The personal data provided with your consent will be collected and processed by us exclusively for the purpose of sending you information and offers for marketing purposes (e.g. information about Millstone’s activity, projects and products, offers, other information as well as to contact you to request more details necessary to solve your requests. The processing of personal data is carried out based on your consent in this regard (art. 6 para. (1) letter (a) of the General Data Protection Regulation ).
We rely on your consent for this purpose.
Your data collected through this form is not subject to an automated decision-making process including the creation of profiles.
Contract: We may process personal data to fulfill our contractual obligations, as well as in the steps leading to the conclusion of a contract, when you ask us to send you an offer.
Consent: We rely on your consent when we send you marketing messages.
Legitimate interest: We may process personal data on the basis of legitimate interest, when, according to our assessment, we believe that the processing is fair, reasonable and proportionate to the purpose of the processing.
Legal obligation and public interest: We may process personal data in order to fulfill legal obligations owed to Millstone.
We process personal data transparently for the following purposes:
Sending the requested offers through the contact form both by e-mail and/or phone;
Processing any other requests received online or by email, including formulating responses to your requests;
Promotion of products offered by Millstone through marketing messages communicated by e-mail and/or telephone;
For the organization and management of promotional campaigns, as well as for analyzing their effectiveness, we may share your personal data with advertising and marketing agencies or digital media agencies;
For direct marketing communications, we may pass on personal data to advertising and marketing agencies that carry out the communication on our behalf;
Administration and maintenance of the website;
Fulfilling the obligations that Millstone has assumed by entering into contracts;
Fulfilling legal and/or contractual obligations.
We will only use your personal data for the reasons we have outlined above. If we need to use your personal data for any other reason, we will let you know and tell you the reason together with the relevant legal basis, unless the law prevents us from doing so.
We share your personal data within the Millstone Group and with other organizations so that we can provide you with our services and comply with our legal obligations. We have set out below who these organizations are and why we share your personal data with such organisations.
We may collect personal and other information for a co-promotion or as part of a joint initiative with a business partner and share your information with that business partner. For these initiatives, we will make it clear at the point of collection that the information will be shared with Millstone Developments and the participating business partner and we will seek your consent in accordance with applicable laws.
We engage third party service providers to perform a variety of business operations on our behalf. In this regard, we may share your personal data with them. We only provide our service providers with the personal data they need to perform the services we request, and we contractually require that they protect this information appropriately and not use it for any other purpose.
In providing our services and products, we may disclose your personal data to third parties and third party service or solution providers, specifically:
We may transfer or otherwise process your personal data:
Millstone Developments does not transfer personal data outside the European Economic Area (EEA).
When you provide us with your personal data, we will process it using our systems, which means that your details will be entered into our databases. We have appropriate security measures in place to ensure that your data is not lost, stolen, accessed by unauthorized third parties or altered in any way. Internally, your personal data will only be accessible to those members of our staff who need to see your data (depending on the nature of the services provided). However, we cannot guarantee that your personal data will not benefit from any security risks that may be possible when your information is sent to and from the website.
As a data subject you have the following rights:
All personal data processing activities presented in this policy refer exclusively to persons who are at least 16 years old. The use of the systems, as well as the results of the processing, is prohibited with regard to children who have not reached this age without the consent of their parents/legal representatives. If, despite our reasonable efforts to prevent, such processing still takes place, we will stop it once we notice that the users have not reached the age mentioned above.
If you do not provide us with the personal data provided in the contact form, you will not be able to send us your request.
If you do not opt-in to receive direct marketing communications, we will not be able to inform you about Millstone offers.
You can modify the data provided by accessing the ‘update your preferences’ section available in the footer of each newsletter sent.
You can unsubscribe from the newsletter by selecting the ‘unsubscribe from this list’ option or by accessing the ‘update your preferences’ section, followed by the unsubscribe option, in the footer of any newsletter sent.
Millstone will provide the information in electronic format when possible, unless you request a different format.
The information provided and any communications and actions taken by you in exercising the above rights are provided by Millstone free of charge. However, if the requests made by you are unfounded or excessive, in particular due to their repetitive nature, Millstone may: (i) either charge a fee taking into account the administrative costs of providing the information or communication or taking the requested measures; (ii) either refuse to comply with the request.
Also, regarding the processing of your personal data, you have the right to file a complaint with the National Supervisory Authority for Personal Data Processing (www.dataprotection.ro).