Volt Evse Distribution SRL (hereinafter referred to as “Volt”), having its headquarters in 12 Paharnicul Turturea Entrance St., C2 Building, Room 5, District 1, Bucharest, Romania, responsible for the administration of the www.volt.com.ro platform and in accordance with Art. 4 par. (7) from the requirements of 2016/679 EU Regulation of the European Parliament and of the 27 April 2016 Council on the protection of people privacy rights with regard to the processing of personal data and on the free movement of such data (“GDRP”), we inform you through this Data Protection Statement, if and to what extent your personal data will be processed when you visit the website/ websites located under this domain on the Internet.

This notice is addressed to you as a customer or potential customer of Volt and explains how Volt uses and protects the personal data provided by you while using the website, including the online contracting portal on the website. We process your personal data in line with the relevant legal provisions, in particular by aligning with GDRP requirements, as detailed below.

 

Website interaction

We process your data when you interact with us through the website and through the contact form.

We process the following data:

1. Identification (such as your first and last name)
2. Contact details (such as home address, email address, telephone number)
3. Account details (any other information you request/ provide to us through the contact form)

 

Legal grounds:

1. Our legitimate interests to ensure optimal and easy communication with customers, to provide customers with an easy communication channel; to ensure effective customer management and improve Volt’s performance indicators;
2. Your consent expressed by the transmission of documents/ information to us.

If you do not provide the information requested through the contact form or our colleagues we may be unable to resolve your request or fully respond to it.

In addition to the previously mentioned aspects, so-called “cookies” are stored on your computer when you visit our website. Cookies are small text files that are stored on your hard drive by the browser you use and through which certain information is transmitted to the applicant who installed the cookie (in this case, us) . Cookies cannot run programs or transmit viruses to your computer. Their function is to make our website easier to use and more efficient in general.

You will be informed about the use of cookies the first time you visit our website or when a cookie is missing on your device. For the continued use of cookies we obtain your consent for the installation of the cookie/s or for processing personal data. When this initial cookie notice is issued we refer users to this privacy policy.

The data collected through the website can be used for any of the purposes indicated below, depending on their relevance (e.g.: the data provided for the request for offers can be used – in order to provide future offers and services, the data provided through other requests/ complaints – in order to handling your requests and informing you according to the law, the possibility to be contacted by us for the purposes of service promotion, studies, market surveys, energy consumption data to comply with industry performance standards, personalized communications, improving the relationship with the clients, etc. ).

Retention period: See details under purposes below. 

 

Social Media interaction

We process your data when you use your profile registered in a social media network, for example Facebook, Instagram or LinkedIn or other similar portals (referred to as “Social Media”) to interact with our professional pages available on these social networks.

We use these Social Media pages and the tools made available to us by the operators of these platforms for the following purposes: support and customer relations, measuring the performance of Social Media pages, promoting the image of our company and personalizing content and advertisements in Social Media, defending our rights and our interests.

 

Changing this informing note

This notice can be changed by Volt. In such cases, the changes will enter into force from the moment the new version of the notice is posted on our website www.volt.com.ro, in the section dedicated to the protection of personal data. 

 

Promoting our image and services. Improving the relationship with our customers

We want to keep you informed about our services as well as about the events we organize. In this context, we may send you offers, promotions, invitations to events or, as the case may be, information regarding Volt’s activity and services.

Depending on your choice we may contact you by e-mail or telephone, automated calls, online channels (including Social Media networks), and/ or traditional channels (correspondence or courier services), either directly or through our partners who help us in our promotional activity.

We process the following categories of data:

1. identification data: name, surname;

2. contact details: e-mail address, telephone number, postal address;

3. data regarding your work function;

4. data related to the services you are interested in (such as the type of services, monthly electricity consumption, etc.);

5. data related to your opinion regarding our services;

6. data regarding your marketing options.

Legal grounds:

Regardless of the type of contracted service, we use:

1. calls (human or automated), emails, online channels – based on your consent to receive such communications;

2. mailing address to promote our services and activity to you (post office/ courier, face-to-face interactions or door-to-door sales) – based on our legitimate interest in keeping you informed about services that you might be interested. If you no longer wish to receive such communications, please send us your refusal at the contact details you cand find at the end of this Policy.

3. your marketing opt-in and proof of acceptance of this privacy policy – based on our legitimate interest in keeping a record of compliance with our specific obligations in the matter and defending our rights and interests, if applicable.

You may unsubscribe from these communications at any time by:

1. activation of the “Unsubscribe” command – for e-mail communications;

2. by calling the phone number +40.752.145.491;

3. changing the permissions of the User Account, when this option will be available on the website;

4. contacting us at any other contact details available on the Volt website or at the end of this information.

If you withdraw your consent you will no longer receive commercial communications from us via email, telephone (including automated calls) or online channels.

 

Customed Marketing communications

We want to offer you the most relevant services, according to your profile and areas of interest. Therefore, we personalize commercial communications based on the services you have purchased from us or intended to purchase, as well as based on your interaction with our website or our Social Media pages or based on other information data derived from your contract with Volt or that we receive from other partners.

For example, we can consider: 1. data regarding the contract and the customer account (contract number, contract type, collection code, consumption code, customer type – household, commercial, prosumer ), 2. consumption data (such as consumption index, energy quantity), 3. general payment history (value of issued energy invoices, account balance, payment method), 4. demographic data, 5. expressed interest for certain offers, 6. your profile provided by other partners/ website result.

Legal grounds:

1. Volt’s legitimate interest in only sending you relevant communications and offers and

2. your consent, with a dual purpose: 1. to send you commercial communications of interest to you, and 2. to become more efficient in our marketing activity.

We can obtain the above data from:

(i) our partners, when you have given your consent in the relationship with our partners to receive commercial communications from other entities – minimum identification data, contact data, your profile;

(ii) acquaintances of yours who recommended you in the context of participating in promotions – Social Media profile, name, surname, contact details;

(iii) providers of social networks / technologies / cookies to track your behavior / preferences;

(iv) persons you authorize in relation to Volt.

Processing period:

We will process your data for the purpose of sending commercial communications and personalized marketing communications for the duration of our contractual relationship, as well as thereafter, unless you withdraw your express consent to receive commercial messages from us.

We will keep the proof of your consent for a period of 3 years from the date of withdrawal of consent. The generated profiles will be periodically deleted, as a result of the generation of updated profiles in relation to the new information.

 

Surveys, market research and other internal analysis

We are constantly concerned with improving the quality of our services. We conduct studies, surveys, market research activities and internal analyzes on how you use our services, including your satisfaction. In this context, we may use services of market research agencies.

We will ensure that we use personal data only if such use is necessary to achieve the proposed objective. As a rule, the result of internal analyzes and studies is in anonymized format.

We process the following categories of data: 1. identification data (name, surname, signature); 2. contact data (e-mail address, telephone number); 3. data related to the services you are interested in/benefit from (such as the type of services, utility, consumption needs, installed capacities); 4. data related to your opinion of our services and your expectations from a provider of such services; 5. your feedback on events, communication with you of other aspects related to the Volt relationship or other similar providers.

Grounds: 1. our legitimate interests to know the opinion and preferences of customers regarding our services or other providers, as well as to optimize our activity and identify new opportunities for the development and promotion of services and activity, in general; 2. your consent expressed in the context of the surveys/ market studies we run.

We may obtain the above data from: generally, we use data that we either 1. receive from you (directly or through our partners – such as marketing, promotion and market research agencies) or 2. we generate or infer them based on the information we hold about you.

Retention period: in the case of data that are the basis of studies, surveys, analyzes with anonymized results – for the duration necessary to transform them into anonymized statistics, but no more than 6 months from the conduct of the survey/ market study or the analysis/ internal study. If they are not anonymized, the results of studies, surveys, analyzes will be kept 1 year from the date of their generation and will not be made public.

If you do not wish to participate in our surveys or studies, we may not implement or take into account certain of your suggestions or other matters of interest to you. In any case, your refusal to participate will not affect your relationship with Volt in any way.

 

 

Defending the rights and interests of Volt and Volt customers. Our compliance with any legal obligations

Data: any of the categories of data mentioned above, appropriate to the type of proceeding/ investigation/ litigation/ official audit.

Grounds:

1. our legitimate interests to defend our rights and interests in the context of situations where Volt’s image and interests would be exposed or affected, respectively to preserve evidence of our rights and interests as well as our compliance with specific legal obligations (for example: resolving complaints within the term required by law in the energy or data protection sectors, the manner of resolution, suspension/ interruption of services only when the law allows this; keeping powers of attorney when the customer is represented by another person/ entity; identification and proof of identification of customers/ other applicants before making changes to contracts/ providing data on customer accounts, etc.);

2. our legal obligations, such as those to comply with the requests of public authorities/ courts/ other public institutions that have the power to impose certain processing operations on us; the obligation to archive certain documents/ information according to archiving rules, Romanian Energy Regulatory Authority or other applicable Volt regulations; the obligation to notify confidentiality/ security incidents to the competent authorities, etc.

We may obtain the above data from any of the sources mentioned for the above purposes, as well as from the authorities, institutions or courts involved.

Retention period: for the period imposed by the specific legal provisions; where there are no other rules, during the an audit/ investigation/ litigation and for a period of 3 years after its conclusion, respectively taking into account the limitation period applicable to the specific situation; for the duration imposed by the competent authority/ institution/ court, according to legal provisions; for the duration requested by you to defend your rights and interests or those of a third person who has a legitimate interest in this regard.

In certain situations, refusing to provide us with data may attract your contractual or civil liability in relation to Volt, other persons whose rights/ interests would be affected.

When we receive the data directly from you we will consider that it is real, correct, complete and that it relates to you. We will use reasonable efforts to ensure that the data is real, correct and that it belongs to you, and if we suspect that you are sending us incorrect, incomplete data or that you are using another person’s data without authorization, we will take steps to clarify and remedy the situation.

These measures could consist of: updating, completing or deleting data, limiting access to illegally used data – including deleting accounts associated with data that do not belong to you. We will also consider the data collected directly from you to be current as long as you have not requested to change it through the mentioned communication channels or you have not personally updated the data. At the same time, we inform you that we may carry out data update campaigns on a regular basis, by phone calls or at the time of re-signing a Volt contract.

Please notify any change in your data to the contact details indicated in the contract with you or on the Volt website, or in this information.

 

To whom do we transfer your data?

We may transfer your data to:

1. your potential service providers, at the time you decide to stop using our services – we may send them any data at your request, including – information on your previously billed consumption, if available;
2. other persons who may receive data at your request or when acting as your proxies in relation to Volt;
3. our IT, Software, security service providers, for the management of the Volt system and applications, ensuring the security and confidentiality of your data;
4. our marketing, PR, research service providers, for knowing the specifics of customers, organizing events and promoting Volt’s image and services;
5. partners involved in the delivery of services you order from us or use, such as courier companies or packing and delivery services;
6. invoicing, payment management and tax reporting service providers, debt recovery agencies;
7. economic operators contracted for verification/revision services, partners who provide technical services or other involved partners;
8. Volt providers in various fields, respectively: providers of database and document storage services, including in the cloud; archiving service providers; providers of web development services and website administration/ social media pages; email service providers; providers of legal and tax consultancy services; providers of accounting and financial audit services; providers of electronic communications services (eg: e-mailing, SMS, etc.); payment service providers involved in processing and/or making payments related to your purchases of our services; providers of new technologies used on our website; cookie providers (will have access only on an anonymized basis);
9. providers of notary services, translations, enforcement;
10. partners with whom we collaborate for the sale of our services. If you purchased our services through a partner entity, we may exchange your data with it for the proper management of the partnership relationship and your account – for example, to be able to identify your order and to make the commission payment to that partner;
11. in the event of a merger, acquisition or other type of reorganization. In the event that Volt undergoes a reorganization or sale process, we will provide your information to that organization;
12. institutions and public authorities or courts, such as:

• The National Energy Regulatory Authority (ANRE);
• National Fiscal Administration Authority (ANAF);
• Competition Council;
• Courts and other judicial entities (such as Police, the Prosecutor’s Office, the National Anticorruption Directorate – DNA, etc.);
• other authorities (for example, ANPC, ANAF, ANSPDCP), or information requested by them, within the limits of legal powers.

 

Your rights

1. Right of acces to data. You have the right to obtain access to your data that we process or control or to copies thereof; you also have the right to obtain from us information about the nature, processing and disclosure of this data.
2. The right to data rectification. The right to data rectification. You have the right to obtain the rectification of inaccuracies in your data that we process or control.
3. The right to data deletion (“the right to be forgotten”).You have the right to obtain from us the deletion of your data that we process or control, in the cases provided by law.
4. The right to restrict data processing. You have the right to restrict the processing of your data that we process or control, when necessary.
5. The right to object. You have the right to object to the processing of your data by us or on our behalf, under the conditions provided by law.
6. The right to withdraw consent. In situations where we process your data based on your consent, you have the right to withdraw your consent; you can do this at any time, at least as easily as you originally gave us consent; the withdrawal of consent will not affect the lawfulness of the processing of your data that we carried out before the withdrawal.
7. The right to lodge a complaint with the supervisory authority. You have the right to lodge a complaint with the supervisory authority for the processing of personal data regarding the processing of your data by us.

You can get more information about your rights by consulting annex no. 1 to this Information Note. You will observe that, according to the law, you can exercise these rights under certain conditions. In any case, we will take all the steps required by law to facilitate your rights expressing.

 

How you can exercise your rights

To exercise one or more of these rights (including the right to withdraw your consent, where we process your data based on it) or to ask any questions about any of these rights or any provision of this notice or any other aspects of the processing of your data, please use the contact details in the OUR CONTACT DETAILS section below at any time. We will try to respond as quickly and completely as possible to all your questions and concerns and facilitate the exercise of your rights.

 

Annex No. 1 YOUR RIGHTS IN DETAIL

You can find separate information about your right to object in the following appendix (Appendix No. 2).

The right to be informed

As an operator, we take appropriate measures to ensure that the information provided and all communications related to processing are in a concise, transparent, intelligible and easily accessible form, in clear and plain language. Information may be provided either in writing or by other means (including electronically, where appropriate).

You will be informed both when personal data is collected from you and when it has been obtained from a third party.

Right of access

In order to be informed about the processing and to verify its legality, you have the right of access to the personal data relating to you that we process.

You also have the right to obtain from us confirmation that your personal data is being processed or not. If we process your personal data, you have the right to access that data; also, in such a situation, you have the right of access to the following information:

• the purposes of the processing;
• the categories of personal data concerned;
• recipients/categories of recipients to whom the data was or will be disclosed, especially recipients from third countries or international organizations;
• the period for which data storage is expected or, if not possible, the criteria used to determine the storage period;
• the fact that you have the right to request from us the rectification, deletion of data or restriction of data processing and the right to object to processing;
• your right to lodge a complaint with the supervisory authority for the processing of personal data;
• if the data is not collected from you, any information about the source;
• the existence of automated decision-making (including profiling) and information regarding the algorithm used and the importance and expected consequences of the processing for you.

 

The right to rectification

If your personal data is inaccurate or incomplete, you have the right to have it rectified by us without undue delay. Depending on the purpose of processing personal data, you have the right to have the data we process completed (if applicable), including after providing additional statements by you.

 

Right to erasure (“right to be forgotten”)

You have the possibility to request that your personal data is deleted without undue delay if it is no longer necessary for us to process it. You have the right to delete your data in the following situations:

• your personal data are no longer necessary to achieve the purposes for which we collected (processed) them;
• you have withdrawn your consent on the basis of which the processing took place and there is no other basis on which we can rely to process your data;
• you object to the processing (under your right to object) and there are no legitimate reasons that would give us the right to continue processing your data;
• we have processed your data illegally;
• there is a legal obligation on our part that requires data deletion;
• data collection took place in connection with the provision of information to a minor.

In turn, we have the right to refuse your request to delete personal data if it is necessary to process it:

• for the exercise of the right to free expression and information;
• to comply with a legal processing obligation, to fulfill a task performed in the public interest or in the exercise of an official authority;
• for reasons of public interest in the field of public health;
• for archiving purposes in the public interest, for scientific or historical research purposes or for statistical purposes, in accordance with the legislation on the protection of personal data, to the extent that the right to delete data is likely to make impossible or seriously affect the realization the objectives of the respective processing;
• for establishing, exercising or defending a right in court.

 

The right to restrict data processing

You have the right to ask us to restrict the processing of your data if at least one of the following conditions is met:

• you dispute the accuracy of that data – in this case, we will stop processing until we verify the accuracy of that data;
• the processing is unlawful – in which case, although you have the right to have your data deleted (“the right to be forgotten”), you object to the deletion and instead ask us to restrict its use;
• we no longer need that data, but you request it for the purpose of ascertaining, exercising or defending a right in court;
• you objected to the processing necessary for the performance of a task of public interest or resulting from the exercise of the public authority with which we are vested or you objected to the processing necessary for the purpose of our legitimate interests or that of a third party – in all these cases, we will stop the processing of your data during the period in which we check whether the legitimate grounds for the processing of the data by us prevail over your rights. 

However, we will continue to process (not only by storing) data the processing of which has been restricted by you if and to the extent that:

• you agree to the processing;
• the processing is necessary for establishing, exercising or defending a right in court;
• the processing is necessary for the protection of the rights of another person/ juridical entity;
• the processing is necessary for reasons of important public interest of the European Union or a member state of the European Union.

We will inform you before lifting the processing restriction.

For example, depending on the specific way in which we process the data in question, in order to comply with the request for restriction of processing, we can temporarily move the data whose processing is restricted to another processing system, we can block users’ access to that data or adopt any measures with a similar effect.

 

The right to data portability

You can obtain from us your personal data that we process, to use it for the purposes you want and to be able to transfer it from one environment to another, in a safe and easy way. You have the right to portability only with respect to data that we process on the basis of your consent, for the performance of a contract to which you are a party or to take steps before the conclusion of a contract at your request.

 

The right not to be subject to a decision based solely on automated processing (including profiling)

At the present time, we do not automatically process your data.

If in the future if we will carry out automatic processing of your data:

• you have the right not to be subject to decisions based on such processing, which produce legal effects regarding you or otherwise significantly affect you;
• however, you will not benefit from the above right when the decision (i) is necessary for the conclusion or execution of a contract between you and Volt, (ii) is provided by law or (iii) is based on your explicit consent;
• if the decision is necessary for the conclusion or execution of a contract between you and Volt or is based on your explicit consent, you have the following rights: (i) the right to obtain human intervention in making the decision, (ii) the right to express your point of view and (iii) the right to appeal the decision;
• our decisions based on automated processing, when permitted, will not be based on your special categories of personal data, unless you have expressly consented or the processing of that data is necessary for reasons of overriding public interest, under laws.

 

The right to withdraw your consent

In situations where we process your data based on your consent, you have the right to withdraw your consent, at least as easily as giving it. You can do this at any time in the ways indicated in the section above on how you can exercise your rights – the sections YOUR RIGHTS and YOUR RIGHTS IN DEYTAIL. If you withdraw your consent, this will not affect the legality of the processing that we carried out on the basis of this prior to the withdrawal.

 

The right to file a complaint with the data processing supervisory authority

In addition to any other rights you have in relation to making claims before courts and other authorities, you have the right to lodge a complaint with a data processing supervisory authority, if you consider that the processing of your data by we are breaking the law. You can file a complaint in particular with the supervisory authority of the Member State of the European Union: (i) where you have your habitual residence; or (ii) where your workplace is located; or (ii) where the alleged breach of your data protection rights occurred. In Romania, the supervisory authority for the processing of personal data is the National Authority for the Supervision of Personal Data Processing (ANSPDCP). The contact details of ANSPDCP are as follows:

Address: 28-30 General Gheorghe Magheru Blvd., District 1, Bucharest, Romania, postal code 010336

Telephone number (landline): 031 805 92 11

Fax number: 031 805 96 02

Email address: anspdcp@dataprotection.ro 

Website: http://www.dataprotection.ro/

 

Appendix no. 2

Your right to object

You have the right to object to the processing of your personal data that is necessary for the performance of a task that serves a public interest, results from the exercise of public authority with which we are vested, or is necessary for our or a third party’s legitimate interests.

You also have the right to object to processing for direct marketing purposes.

You also have the right to object to processing for scientific or historical research purposes or for statistical purposes, unless such processing is necessary for the performance of a task carried out for reasons of public interest.

You can exercise this right in the ways indicated in the section above on how you can exercise your rights – the sections YOUR RIGHTS and YOUR RIGHTS IN DEYTAIL.

To exercise the rights mentioned above and any additional information, you can contact us by:

i. e-mail: contact@volt.com.ro;

ii. by post, to the address: 54A Aviator Popișteanu St., District 1, Bucharest;

iii. through the customer account, when this functionality will be available on our website.