Starting May 25, 2018 Regulation 679/27-April-2016 regarding the protection of natural persons in what concerns the processing of personal data and regarding the free movement of such data and repeal of Directive 95/46 / EC (General Data Protection Regulation) (hereinafter referred to as "GDPR") it is applied in all the states of the European Union. This Information regarding the processing of personal data is intended to inform you about how we understand to regulate and integrate at our company level the GDPR policy and is an integral part of the Contract for the provision of qualified reliable services concluded with Digisign.
The operator (the one who processes your data) | DIGISIGN S.A. Office: 74B Nicolae G. Caranfil St., 1st District, 014146, Bucharest, Romania Trade Registry No: J2005008069408 VAT No: RO17544945 The data protection officer declared at ANSPDCP is DPO DATA PROTECTION SRL, d p o @ digisign.ro In its relations with its customers, DigiSign is the Controller of personal data. DigiSign has implemented an information security management system, ISO 27001 certified. DigiSign has also obtained the status of a qualified trusted service provider in accordance with EU Regulation no. 910/2014 eIDAS. Obtaining and maintaining ISO 27001 certification and Qualified Trusted Service Provider status requires annual external audits, which assess the security of information systems and information. DigiSign SA employees who have access to personal data are regularly trained on respecting the confidentiality, integrity and security of the data and have become aware of the applicable internal procedures. |
Purposes of processing | The processing of your personal data as a data subject is carried out for the following purposes: • Provision of services ordered or purchased from DigiSign: issuing qualified digital certificates, delivery of the eToken device, use of the certificate for electronic signing of documents, as well as management of related payments. (Legal basis: art. 6 para. (1) lit. b) GDPR – execution of the contract). • Identification of the data subject for issuing certificates - Identification of the holder of the digital certificate by verifying the identity document, including the photograph, or by means of electronic identification. (Legal basis: art. 6 para. (1) lit. c) GDPR and art. 24 para. (1) of the eIDAS Regulation). • Remote video identification and processing of captured images - Capturing video/photo images, photocopying the identity document, when identification takes place remotely, by video means (DigiSign video identification platform) (Legal basis: art. 6 para. (1) let. a) GDPR and art. 24 of the eIDAS Regulation, in conjunction with ADR Norm no. 564/2021). • Recording the remote identification video-audio session - storing the video-audio session in order to validate the identification process and its compliance. (Legal basis: art. 6 para. (1) let. a) GDPR and your consent). • Publishing data in the public certificate register - publishing certain data from the certificate in the Electronic Certificate Register. (Legal basis: art. 6 para. (1) let. b) and c) GDPR and art. 14 of Law 214/2024). • Renewal of digital certificates - processing of data necessary for the renewal of the certificate at the request of the user. (Legal basis: art. 6 para. (1) lit. b) GDPR). • Validation of the certificate upon request or within the framework of a legal procedure - Confirmation of the validity of the certificate at the request of the holder, a third party or an authority. (Legal basis: art. 6 para. (1) lit. b) and c) GDPR, in conjunction with art. 24 of the eIDAS Regulation). • Suspension/revocation of the certificate - processing of data in order to suspend or revoke the certificate, at the request of the data subject or on legal basis. (Legal basis: art. 6 para. (1) lit. b) and c) GDPR). • Prevention and/or identification of fraud - the data are used to prevent fraud attempts or the misuse of digital certificates. (Legal basis: art. 6 para. (1) lit. c) GDPR, art. 24 para. (2) lit. g) of the eIDAS Regulation.). • Compliance with other legal obligations of the Operator - we process data to respond to requests from competent authorities and to update the electronic register of certificates. (Legal basis: art. 6 para. (1) lit. c) GDPR, art. 24 para. (2) lit. k) of the eIDAS Regulation, Law 214/2024). • Storage of data and copy of identity document - In the case of non-electronic identification, we keep the data, including the copy of the identity document, for a period of 10 years from the expiry of the certificate, for the purpose of continuity of services and their use in legal proceedings, if applicable. (Legal basis: art. 6 para. (1) lit. c) GDPR, art. 24 para. (2) lit. h) of the eIDAS Regulation, Law 214/2024, art. 16 para. (2) and art. 22 of ADR Norm no. 564/2021) • Pursuing our legitimate interests, such as: managing contracts and accounting documents; sending information about the expiration period of the purchased certificate; resolving requests or disputes, including debt recovery, to be contacted and respond to you regarding the services you use or intend to use from DigiSign; to keep in touch with you and provide you with necessary information through our website: www.digisign.ro but also on our social media pages. https://www.facebook.com/SemnaturaElectronicaDIGISIGN (Legal basis: art. 6 par. (1) letter f) GDPR.) • For marketing communications. We will only make these communications if we have the consent of the data subject. |
Who are the data subjects and what personal data do we process | • Customers or potential customers whose data we will use to prepare offers, conclude and execute the contract and to provide the services requested by them. |
Data transfer | DigiSign does not transfer your personal data outside the European Union. |
Data retention periods | The deadlines expected for the retention and deletion of the various categories of data will be those established by the legislation in force, including that regarding archiving, respectively until the purpose for which they were collected is achieved, for the entire duration necessary for their use as established by the legislation in force (including fiscal legislation) or by the competent authorities. Thus: After the issuance of the qualified digital certificate, the personal data related to the identification process of the holder and those related to the issued certificate will be retained for a period of 10 years from the date of expiry of the certificate's validity, in accordance with: art. 6 para. (1) let. c) GDPR - legal obligation and art. 24 para. (2) let. h) of the eIDAS Regulation;. After the expiration of the archiving period, the data will be irreversibly deleted. Unfinished certificate acquisition/renewal requests are kept in the database for 30 days, after which they are irreversibly deleted. If the video identification process is rejected, the video recording made will be kept for a period of 7 days from the date of recording, for the following purposes: justification of the reasons for rejection; internal records and external audits (e.g. the Romanian Digital Authority); possibility of use in a possible dispute. This storage is in accordance with the Norms of the Romanian Digital Authority no. 564/2021 and the applicable regulations in the field of trust services. Biometric data, generated within the video identification process (e.g. facial image for automatic verification), are not stored. They are temporarily processed and automatically deleted immediately after the comparison operation is completed. |
To whom we will disclose your data | As a rule, DigiSign SA does not disclose the data it holds and processes, about all categories of data subjects, to other natural or legal persons. The cases in which DigiSign SA customer data may be disclosed to other companies or natural persons are those in which other companies, natural or legal persons act as authorized persons in relation to DigiSign SA. In these cases, we will disclose the data for legitimate reasons related to the performance of a contract, the preparation of documentation necessary for the performance of the contract, the establishment, defense and exercise of our rights or interests. The categories of recipients to whom we may disclose your data are: • employees and collaborators of the Operator located on the territory of Romania; • third-party companies or contractual partners, such as: courier service providers, for the delivery of eToken devices and documents; authorized providers of video identification services, • Supervisory bodies and competent authorities, including: the Romanian Digital Authority (ADR), the Ministry of Research, Innovation and Digitalization (MCID), ANAF, and other criminal investigation bodies. In all these cases DigiSign SA will make all reasonable efforts to ensure that the recipients of the data process them in conditions of security and confidentiality, in accordance with the purpose for which they were transmitted and with respect for the rights of the data subjects. |
Your rights | You have the following rights as a data subject: |
Use of personal data and consequences of failure to provide it | The personal data collected by DigiSign are used exclusively for legitimate purposes, in accordance with applicable law (Regulation (EU) 2016/679 – GDPR, eIDAS Regulation, Law no. 214/2024). They are necessary for: • Identifying the data subject for the purpose of issuing the qualified digital certificate (including by video means); • Providing and managing qualified trust services, including electronic signature, electronic seal and time stamping; • Validating identity and issuing certificates, as well as maintaining their records in official registers; • Complying with legal obligations imposed by regulatory authorities and bodies; • Ensuring security and preventing fraud in IT and identification processes; • Maintaining a fair contractual relationship with users, including through technical support, billing, managing requests, renewing certificates, etc.; • Exercise and defense of the Operator's legal rights before authorities, courts or other third parties. The provision of certain personal data is mandatory (processing is required by law or regulation, identification according to eIDAS, data storage according to ADR rules) and necessary for the conclusion or execution of a contract (e.g. issuance of a qualified certificate); Refusal to provide the contractually mandatory or necessary data has the following consequences: • Impossibility of identifying the person and, implicitly, of issuing the digital certificate; • Impossibility of providing electronic signature services or access to signing/validation platforms; • Impossibility of complying with legal requirements on the part of DigiSign (which may lead to refusal to provide the service); • Termination of the contract or impossibility of concluding it. |
Where can you go for exercise rights and the response time. | The exercise of the aforementioned rights will be done on the basis of a written request addressed to the DigiSign office or by email to d p o @ digisign.ro. The deadline for any application for your rights is 30 days. except in cases where the request is complex or there is a large number of requests, when the deadline can be extended by another 60 days. If you are not satisfied with the solution received, you can contact the National Supervisory Authority for Data Processing with Personal Character - contact details can be found at www.dataprotection.ro |
Updates | This Information may be subject to changes in content over time. Any new version will be announced and displayed on the DigiSign website https://www.digisign.ro |
Date of entry into force: | This Information is valid starting with 10.04.2025 |