PRIVACY POLICY OF E4M.PRO

APPROVED

CEO of

Modern IT Solutions S.R.L.

IDNO 1022600046085

1. General provisions

1.1. This Privacy Policy of Modern IT Solutions S.R.L. (hereinafter referred to as the "Operator") defines the principles and guidelines for the processing of personal data by the Operator in compliance with international privacy laws and regulations, including the General Data Protection Regulation (GDPR) of the European Union, the Privacy Shield Framework, and other applicable data protection laws and regulations.

1.2. This Policy has been developed in accordance with internationally recognized standards, including the GDPR, the Privacy Shield Framework, and other relevant data protection laws and regulations.

1.3. The terms used in this Policy shall have the meanings assigned to them under the applicable international data protection laws and standards, including those outlined in the GDPR and the relevant privacy regulations of the jurisdiction in which the company operates.

1.4. This Policy applies to all operations performed by the Operator with personal data, whether using automated systems or without them, in accordance with international standards.

1.5. Rights and Obligations of the Operator

1.5.1. The Operator has the right to:

• request accurate information and/or documents containing personal data from the data subject;
• require the data subject to promptly clarify or correct the provided personal data.

1.5.2. The Operator is obliged to:

• process personal data in compliance with the applicable data protection laws, including the GDPR and other relevant international privacy standards;
• respond to requests from the data subject (or their legal representative) regarding the processing of their personal data and provide substantiated answers;
• provide the data subject (or their legal representative) with free access to their personal data upon request, subject to applicable law;
• take necessary actions to clarify, delete, or correct the personal data of the data subject based on legitimate and substantiated requests from the subject or their legal representative;
• ensure the protection of personal data in accordance with the relevant international standards and legal frameworks, including technical and organizational measures to ensure security.

1.6. Rights and Obligations of Data Subjects

1.6.1. Data subjects have the following rights:

• The right to be informed about the processing of their personal data, including the purposes for which the data is processed, and the legal basis for processing (such as consent or contractual necessity);
• The right to access their personal data and to request a copy of any records containing their personal data;
• The right to rectification of inaccurate or incomplete personal data;
• The right to erasure ("right to be forgotten") of personal data when it is no longer necessary for the purposes for which it was collected, or if the data subject withdraws consent;
• The right to restrict processing of their personal data in certain circumstances (e.g., if the accuracy of the data is contested);
• The right to data portability, allowing the data subject to request that their personal data be transferred to another data controller in a structured, commonly used, and machine-readable format;
• The right to object to the processing of their personal data in specific cases (e.g., direct marketing purposes);
• The right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal;
• The right to lodge a complaint with a supervisory authority, should they feel their rights have been infringed.

1.6.2. Data subjects are obliged to:

• provide the Operator with only accurate information about themselves;
• provide documents containing personal data to the extent necessary for processing purposes;
• inform the Operator about any updates or changes to their personal data.

1.6.3. Individuals who provide the Operator with inaccurate information about themselves or another data subject without their consent shall be held responsible in accordance with the applicable data protection laws.

2. Scope and categories of processed personal data, categories of data subjects

2.1. The Operator may process the personal data of the following categories of data subjects:

• employees of the Operator, former employees, job candidates, as well as their relatives;
• clients and contractors of the Operator (individuals);
• representatives/employees of the Operator’s clients and contractors (legal entities);
• visitors to the Operator's website e4m.pro (hereinafter referred to as "the Website").

2.2. The personal data processed by the Operator may include:

• full name of the data subject;
• passport details of the data subject or equivalent personal identification information;
• birth certificate details;
• driver's license details;
• military ID details;
• social security card details, pensioner certificate, bank card details, etc.;
• phone number, email address;
• data related to the subject's interaction with the Website (e.g., browsing history);
• photographs and other personal identifiers.

2.3. The Operator ensures that the content and scope of the processed personal data corresponds to the declared processing purposes and takes steps to eliminate unnecessary or excessive data relative to the stated objectives.

2.4. The processing of special categories of personal data, such as race, ethnic origin, political opinions, religious or philosophical beliefs, and personal life data, is not carried out by the Operator unless explicit consent is obtained from the data subject, or other legal grounds for processing such data apply.

2.5. The Operator does not engage in the cross-border transfer of personal data, unless required by applicable law or international agreements. However, if cross-border transfers occur, the Operator will ensure that such transfers are conducted in accordance with applicable international data protection regulations, such as the GDPR, through mechanisms such as Standard Contractual Clauses (SCC) or Privacy Shield certification.

2.6. Disclosure of Personal Data to Third Parties. The Operator may transfer personal data, including but not limited to: full name, phone number, email, to third parties such as event organizers, if the data subject has registered for or purchased tickets for an event, for the purpose of sending informational messages about the event. Personal data may also be shared with third parties in accordance with the terms of service or legal requirements.

3. Purposes of personal data collection

3.1. Personal data is processed by the Operator for the following purposes:

• entering into and performing contracts with the data subjects;
• conducting surveys, questionnaires, and research on the Website;
• identifying and verifying the data subject within the context of the agreements with the Operator;
• providing services to data subjects and informing them about new products, including marketing communications;
• communication with data subjects, including the processing of their requests and inquiries, and providing information about the Website’s operation;
• quality control and improvement of services, including those offered on the Website;
• recruitment, employment, and workforce management;
• generating statistical reports;
• facilitating the Operator's business activities;
• collecting anonymous data for the purpose of improving the Website.

4. Legal basis of personal data processing

4.1. The legal bases for personal data processing by the Operator are:

• the General Data Protection Regulation (GDPR) of the European Union;
• the Privacy Shield Framework and other privacy frameworks for cross-border data transfers;
• applicable national laws relating to data protection, privacy, and personal data processing in the jurisdictions where the Operator operates;
• the legitimate interests pursued by the Operator, provided such interests are not overridden by the data subject's rights and freedoms;
• any other relevant international data protection laws and standards that may apply in the specific context of the data processing.

5. Processing methods and conditions

5.1. The Operator processes personal data using the following methods:

• Non-automated data processing;
• Automated data processing, including the transfer of the obtained information through information and telecommunication networks or without such transfer;
• Mixed data processing (a combination of manual and automated methods).

5.2. The actions performed by the Operator with personal data include collection, systematization, accumulation, storage, updating (including modifications), usage, dissemination (including transmission), anonymization, blocking, deletion, and any other actions permitted under applicable law.

5.3. Personal data is processed by the Operator only with the consent of the data subject (hereinafter referred to as "Consent"), except in cases where processing is allowed without consent under applicable law.

5.4. The data subject freely decides whether to provide their personal data and grants Consent voluntarily and in their own interests.

5.5. Consent is provided in any form that allows confirmation of its receipt, including actions performed on the Website.

By granting Consent to this Policy, the data subject agrees to the processing of their personal data in the manner and for the purposes described in this Policy.

5.6. Processing of personal data may cease if the purposes for processing have been achieved, the term of the Consent has expired, or the data subject withdraws their Consent. It may also cease if unlawful processing is detected.

5.7. Consent can be revoked at any time by sending a written notice to the Company or via email to: support@e4m.pro.

competent individual who agrees to the terms of this Agreement the opportunity to use the functionality of the web-based platform available at: https://e4m.pro/pages/policy/en/user-agreement, under the conditions set forth below.

5.8. Security Measures. The Operator shall implement appropriate technical and organizational measures to ensure the security of personal data during processing. This includes preventing unauthorized access, alteration, or disclosure, and ensuring the protection of data integrity. These measures will be regularly assessed to ensure compliance with international standards such as GDPR and other applicable regulations.

5.9. Data Retention. Personal data shall be retained for no longer than is necessary to fulfill the purposes for which it was collected. After the data is no longer necessary for those purposes, it will be securely deleted or anonymized. The retention period for personal data will be determined based on legal, contractual, or operational requirements.

5.10. Data Subject’s Right to Withdraw Consent. The data subject has the right to withdraw their consent to the processing of their personal data at any time. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal. The data subject can withdraw consent by sending a request to the Operator via the contact details provided in this Policy.

6. Modifications and deletion of personal data, data subject requests

6.1. Data Subject Access Request (DSAR). The data subject has the right to request access to their personal data being processed by the Operator. Upon receiving a Data Subject Access Request (DSAR), the Operator will provide the requested information within 30 days, unless otherwise specified by law. The data subject may also request a copy of their personal data, subject to applicable law.

6.2. Rectification of Data. The data subject may request the correction of inaccurate or incomplete personal data held by the Operator. The Operator will take reasonable steps to ensure that the data is accurate and up to date.

6.3. Erasure ("Right to be Forgotten"). The data subject has the right to request the deletion of their personal data when the data is no longer necessary for the purposes for which it was collected, or if the data subject withdraws consent. Requests for erasure will be assessed based on legal requirements, and data will be deleted unless retention is required for compliance with legal obligations.

6.4. Restriction of Processing. The data subject may request that their personal data be restricted from processing, including storage, when they believe the data is inaccurate or processing is unlawful. During the restriction period, the data will not be processed for any purpose other than storage.

6.5. Data Portability. Where technically feasible, the data subject has the right to receive their personal data in a structured, commonly used, and machine-readable format. The data subject may also request that their personal data be transferred to another data controller.

6.6. Complaint to Supervisory Authority. The data subject has the right to lodge a complaint with a supervisory authority if they believe their rights under applicable data protection laws (such as the GDPR) have been violated. The supervisory authority will investigate the complaint and take appropriate action.

7. Cookie policy

7.1. Use of Cookies. Cookies are used on the Website to enhance the user experience. Cookies help the Website remember visitors during their first visit and upon return visits. Some cookies are necessary for the functionality of the Website, while others help to personalize content based on the visitor's preferences.

7.2. Types of Cookies:

• First-party cookies: These cookies are set by the Website and can only be read by the Website.
• Third-party cookies: These cookies are set by external services used by the Operator, such as analytics providers or advertising partners. These third parties may set cookies to collect information about user behavior on the Website.

7.3. Managing Cookies. Visitors can control cookies through their browser settings. The visitor has the option to refuse or accept cookies by adjusting their browser settings. Instructions for managing cookies in different browsers are available in the browser’s help section. Visitors can also delete cookies already stored on their devices.

7.4. Cookie Consent. By continuing to use the Website, visitors consent to the use of cookies. However, they may withdraw this consent at any time by adjusting their cookie settings in their browser.

8. Final provisions

8.1. Changes to the Privacy Policy. The Operator reserves the right to make changes to this Privacy Policy. Any updates or changes will be indicated with the date of the last revision. The updated Privacy Policy will take effect from the moment it is posted on the Website, unless otherwise specified. The current version of the Privacy Policy is always available on the Website at: http://e4m.pro/pages/policy/en/privacy-policy .

8.2. Data Subject’s Rights and Obligations. The data subject is encouraged to review this Privacy Policy regularly to stay informed about how their personal data is being processed. The data subject may exercise their rights under this Policy by contacting the Operator using the contact information provided on the Website.

8.3. International Data Transfers. If personal data is transferred internationally, the Operator will ensure that such transfers are carried out in accordance with applicable data protection regulations, such as the GDPR, using mechanisms such as Standard Contractual Clauses (SCC) or other legally recognized safeguards to protect personal data.

8.4. Contact Information. For any questions or concerns about this Privacy Policy or how personal data is processed, or if the data subject wishes to exercise any of their rights under this Policy, they can contact the Operator at:

• Email: support@e4m.pro
• Website: https://e4m.pro