Policy protection of personal data

 I. The Purpose of Data Protection Policy

 As part of its responsibility S.C. KERRAKS UMG SRL is committed to complying with national and international data protection laws. This data protection policy applies at society level and is based on principles accepted at European level on data protection. Ensuring data protection is the foundation of trusted business relationships and the reputation of our society.

The data protection policy provides the framework conditions necessary to ensure the adequate level of data protection provided by Regulation no. 679 of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data.

 II. Scope and policy change

This privacy policy applies to KERRAKS UMG and its employees.

The data protection policy extends beyond all personal data processing.

Anonymized data, where available, used e.g. for statistical evaluations or other studies, are not subject to this data protection policy.

The policy is reviewed annually and the latest version approved by the Chief Executive Officer will be immediately available to both employees and customers and business partners.

 III. Principles for the processing of personal data

 Article 1. Compliance and legality

When processing personal data, the individual rights of the data subjects must be protected. Personal data must be collected and processed legally and correctly.

 Article 2. Restriction to a particular purpose

Personal data may be processed only for the purpose defined before collecting the data and communicated to the data subject. Subsequent changes to the scope are possible only to a limited extent and require a solid foundation.

Art. 3. Transparency

The data subject should be informed of how his data is dealt with. In general, personal data must be collected directly from the person concerned. When the data is collected, the data subject must already know or be informed about:

• Data controller identity (data collection company)

• Purpose of data processing

• Third parties or categories of third parties to whom data may be transmitted

Article 4. Reducing data and minimizing data

Before processing personal data, you need to determine whether and to what extent processing of personal data is necessary to achieve the purpose for which it is performed.

Where the goal permits and where the costs involved are proportionate to the objective, anonymous data should be used. Personal data can not be collected in advance and stored for future potential purposes, unless this is required or permitted by national law.

 Art. 5. Deletion

Personal data that is no longer required after the legal or business process expires must be deleted. There may be situations in which legal interests oblige them to keep these data on pre-defined terms. In this case, the data must remain in the files until the legal obligations expire.

Art. 6. The accuracy and timeliness of the data

Personal data collected must be accurate, complete and, if necessary, updated. Permanent measures must be taken to ensure that inaccurate or incomplete data is deleted, corrected, supplemented or updated.

 Article 7. Privacy and data security

Within our company, personal data is considered to be confidential information and is protected by appropriate organizational and technical measures to prevent unauthorized access to, processing, or unlawful distribution as well as accidental loss, alteration or destruction.

The privacy policy is found in the PG 10.

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