Privacy Notice

SCA BOHALTEANU & ASOCIATII, headquartered at1-3 Magheru Blvd, 5^thfloor, District 1, Bucharest, Romania (“BSMP” or the “Company”),hereby informs you that, in the course of its day to day activities (including those arising out ofthe use of our website, the management of your unsolicited request for information or the engagement of our legal services),it may process, respectively collect, register, store, consult, disclose and/or use (the “Processing”):

personal data of our individual clients and/or potential clients;
personal data of the representatives, contact persons, employees and/or collaborators of our clients/potential clients;
personal data of our suppliers or potential suppliers of goods and services that approach us, and/or personal data of therepresentatives, contact persons, employees and/or collaborators of our suppliers or potential suppliers of goods and services;
personal datafollowing the submission of yourunsolicited application for a job/position in the Company;
data regarding the visitors of our website;
personal data regarding third party individuals, as such are provided by the BSMP’s clients/potential clients;
personal data arising out of any other request for information and/or any other unsolicited correspondence to be provided by any individual.

BSMP intends to process, with the observance of the Romanian and EU data protection legal provisions, for the purpose and under the terms and conditions described under this Notice, personal data detailed hereinbelow about:

BSMP’s individual clients and/or potential clients;
representatives, contact persons, employees and/or collaborators of BSMP’s clients/potential clients;
representatives, contact persons, employees and/or collaborators of suppliers or potential suppliers of goods and services;
job/internship applicants;
users of our website;
data subjects whose personal data are provided by BSMP’s clients/potential clients;
any individuals requesting information by means of e-mail, fax, telephone and/or other means of communication and/or sending any other unsolicited correspondence.

If you have any questions about BSMP’s use of your personal data, please use the following contact details:

Phone: (+40) 311 027 961
Fax: (+40) 311 000 140
E-mail: office@bsmp.ro
Address: Magheru One, 1-3 Gh. Magheru Blvd., 5th floor, District 1, 010321.

1. PURPOSE OF THE PROCESSING; CATEGORIES OF THE PROCESSED PERSONAL DATA; LAWFUL BASIS FOR PROCESSING

In the context of your interaction with BSMP, you may be subject to the data processing activities that we perform.

Minors under the age of 18 should not transfer any personal data to the Company without approval of their parents or a legal guardian.

In the course of our day to day activities, we may use your personal data,as follows:

1.1. Individual clients and/or potential clients

1.1.1. Purpose of the Processing

The Company intends to Process your Personal Data (as detailed below) for:

providing legal services;
communicating with you with respect to any request and/or any other relevant business/caserelated matters;
complying with the obligations imposed upon BSMP by law or by the Statute governing the lawyer profession, such as:
- the obligation set forth by the Statute governing the lawyer profession to verify the exact identity of the client;
- the obligation set forth by the Statute governing the lawyer profession to make the best efforts in carrying out the professional services;
- the obligations related to Anti-Money Laundering regulated under the Law no. 129/2019 on preventing and combating money laundering and terrorism financing.

1.1.2. Categories of the processed personal data

The Company may Process the following categories of personal data which belong to you:

identification data: name, surname, gender, title, signature, ID card details if necessary and legally required;
personal data relevant for your case and necessary for the provision of the requested services;
contact details: e-mail, phone number, address;
any other personal data you may provide directly to us, as needed to fulfill the purposes mentioned under item 1.1.1. above.

The provision of your personal data is necessary in the context of the conclusion and/or performance of the agreement for the provision of legal services and for the fulfilmentby BSMP of itslegal obligations arising from the applicable legislation, as provided under item 1.1.1. (iii) above.

In case you do not provide us the necessary personal data,we will not be able to fulfill our legal obligations (including those related to the identification of clients, as these are detailed under item 1.1.1. (iii) above) and, as a consequence, we will not be in the position to execute with you an agreement for the provision of legal services.

1.1.3. Lawful basis for processing

The Company process your Personal Data based on the following legal basis, as follows:

6 (1) b of GDPR, namely processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract;
6 (1) c, namely processing is necessary for compliance with a legal obligation to which the controller is subject.

1.2. Representatives, contact persons, employees and/or collaborators of our clients/potential clients

1.2.1. Purpose of the Processing

The Company intends to Process your Personal Data (as detailed below) for:

providing legal services;
communicating with you with respect to any request and/or any other relevant business/professional/caserelated matters;
complying with the obligations imposed upon BSMP by law or by the Statute governing the lawyer profession, such as:
the obligation set forth by the Statute governing the lawyer profession to verify the exact identity of the client;
the obligation set forth by the Statute governing the lawyer profession to make the best efforts in carrying out the professional services;
the obligations related to Anti-Money Laundering regulated under the Law no. 129/2019 on preventing and combating money laundering and terrorism financing.

1.2.2. Categories of the Processed personal data

The Company may Process the following categories of personal data which belong to you:

identification data: name, surname, gender, title, signature, ID card details if necessary and legally required;
personal data relevant for your case and necessary for the provision of the requested services;
contact details: e-mail, phone number, address;
any other personal data you may provide directly to us, as needed to fulfill the purposesmentioned under item 1.2.1. above.

The provision of your personal data is necessary in the context of the fulfilmentby BSMP of the legal obligations arising from the applicable legislation, as provided under item 1.2.1. above.In case you do not provide us the necessary personal data, we will not be able to fulfill our legal obligations (as these are detailed under item 1.2.1. (iii) above) and, as a consequence, we will not be able to carry out the operations related to the provision of the legal services and the management of the relationship with the client.

The provision of your personal data is also necessary for the legitimate interests pursued by BSMP, as provided under item 1.2.3. (ii) below. Although you do not have a legal obligation to provide personal data to be processed by the Company so as to fulfill the legitimate interests of BSMP, in case you do not provide the relevant data, BSMP will not be able to carry out the operations related to the provision of the legal services and the management of the relationship with the client.

1.2.3. Lawful basis for processing

The Company process your Personal Data based on the following legal basis, as follows:

6 (1) c, namely processing is necessary for compliance with a legal obligation to which the controller is subject;
6 (1) f, namely processing is necessary for the purposes of the legitimate interests pursed by BSMP in providing the legal services and managing the relationship with our clients.

1.3. Representatives, contact persons, employees and/or collaborators of our suppliers or potential suppliers of goods and services

1.3.1. Purpose of the Processing

The Company intends to Process your Personal Data (as detailed below) for:

assessment of and/or discussions/negotiation on the products and/or services related offers provided by you;
initiating and/or maintaining our contractual relationship with your company/employer/business partner;
communicating with you with respect to any request and/or any other relevant business/professional related matters;

1.3.2. Categories of the Processed personal data

The Company may Process the following categories of personal data which belong to you:

identification data: name, surname, signature, ID card details if necessary and legally required;
contact details: e-mail, phone number, address;
any other personal data you may provide directly to us, as needed to fulfill the purposesmentioned under item 1.3.1. above.

The provision of your personal data may also be necessary for the legitimate interests pursued by BSMP, as provided under item 1.3.3. below. Although you do not have a legal obligation to provide personal data to be processed by the Company so as to fulfill the legitimate interests of BSMP, in case you do not provide the relevant data, BSMP will not be able to carry out the operations related to the provision of the goods and services and the management of the contractual relationship with the legal entities that you represent.

1.3.3. Lawful basis for processing

The Company process your Personal Data based on Art. 6 (1) f, namely processing is necessary for the purposes of the legitimate interests pursed by BSMP of ensuring that the contractual relationship is managed properly and adequately carried out.

1.4. Job/internship applicants

1.4.1. Purpose of the Processing

The Company intends to Process your Personal Data (as detailed below) for the management of your unsolicited application for a job/position within the Company.

1.4.2. Categories of the Processed personal data

The Company may Process the following categories of personal data which belong to you:

identification data: name, surname, gender, date and place of birth, citizenship;
contact details: e-mail, phone number, address (domicile/residence);
professional training – diplomas – studies, previous places of work;
image;
any other personal data you may provide directly to us, as needed to fulfill the purposesmentioned under item 1.4.1. above.

1.4.3. Lawful basis for processing

The Company process your Personal Data based on Art. 6 (1) b of GDPR, namely processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.

The provision of your personal data is necessary in the context of the conclusion and/or performance of your employment/collaboration/services agreement. In case you do not provide such personal data, we will not be able to initiate the relevant procedures in order to enter into an employment/collaboration/services agreement.

1.5. Users of our website

1.5.1. Purpose of the Processing

The Company intends to Process your Personal Data (as detailed below) so as to monitor the traffic and improve the content of the website. For these purposes, we use cookies, as detailed in the Cookies Policy.

1.5.2. Categories of the Processed personal data

The Company may Process the following categories of personal data which belong to you:

IP address (abbreviated);
hour and date of accessing the website.

1.5.3. Lawful basis for processing

The Company process your Personal Data based on the following legal basis:

6 (1) a, namely your consent, on what concerns the personal data processed by means of non-necessary cookies;
6 (1) f, namely processing is necessary for the purposes of the legitimate interests in ensuring the proper functioning of our website, as well as its improvement.

For more information, please refer to our Cookies Policy.

1.6. Data subjects whose personal data are provided by BSMP’s clients

1.6.1. Purpose of the Processing

The Company intends to Process your Personal Data (as detailed below) for:

providing the legal services requested from us by clients;
complying with the obligations imposed upon BSMP by law or by the Statute governing the lawyer profession, such as the obligation to make the best efforts in carrying out the professional services.

1.6.2. Categories of the Processed personal data

The Company may Process the following categories of personal data which belong to you:

identification data: name, surname;
personal data relevant for your case and necessary for the provision of the requested services;
any other personal data provided by the client/potential client or accessed from public sources, as required by the client, as the case may be.

The provision of your personal data is necessary in the context of the fulfilment by BSMP of the legal obligations arising from the applicable legislation, as provided under item 1.6.1. (ii) above.In case the necessary personal data we will not be provided us by our clients, we will not be able to comply with our legal obligations.

The provision of your personal data may also be necessary for the legitimate interests pursued by BSMP, as provided under item 1.6.3. (ii) below. Although there is no legal obligation to be provided with your personal data to be processed by the Company so as to fulfill the legitimate interests of BSMP, in case these data are not provided, BSMP will not be able to carry out the operations related to the provision of the legal services.

1.6.3. Lawful basis for processing

The Company process your Personal Data based on the following legal basis, as follows:

6 (1) c, namely processing is necessary for compliance with a legal obligation to which the controller is subject;
6 (1) f, namely processing is necessary for the purposes of the legitimate interests pursed by BSMP in providing the legal services and managing the relationship with our clients.

1.7. Individuals requesting any information and/or sending any other unsolicited correspondence

1.7.1. Purpose of the Processing

The Company intends to Process your Personal Data (as detailed below) for the management of your request for information and/or your unsolicited correspondence.

1.7.2. Categories of the Processed personal data

The Company may Process the following categories of personal data which belong to you:

name and surname;
e-mail address;
any other information comprised in the correspondence.

The provision of your personal data may be necessary for the legitimate interests pursued by BSMP, namely in order to address and/or solve your requests and/or unsolicited communications transmitted via e-mail or phone and/or in any other similar means of communication, as well as to respond to such requests/communications.

1.7.3. Lawful basis for processing

The Company process your Personal Data based on Art. 6 (1) f, namely processing is necessary for the purposes of the legitimate interests pursed by BSMP in addressing and/or resolving and/or responding to your requests/communications.

2. Recipients of your personal data

To the extent that it is necessary for fulfilling the above-mentioned purposes and within the limits set forth by the applicable legislation, your personal datamay be accessed exclusively by authorized persons with explicit competencesin connection to the purposes referred to hereinabove.

3. Transfer of the Personal Data

BSMP will not transfer your personal data to third parties, unless:(i)this is legally requested in relation to any public institution/authority and/or court of law or (ii) the Company is obliged to do so based on a legal provision or (iii) this is necessary in consideration of a decision of a public authority/institution, including but not limited to a court ruling/decision.

4. Accurate information and deletion

BSMP is committed to keeping your personal data accurate and up to date. Therefore, please informBSMP of any relevant changes to your details. In this respect, you may contact the Companyto the e-mail address office@bsmp.ro.

BSMPprocesses and stores your personal data with the observance of the data minimization and storage limitations principles.

Thus, we will process Personal Data which:

are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
will be kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed.

Therefore, BSMP will erase any personal data as soon as such is no longer necessary for the Purposes detailed under item 1 hereinabove.

5. Rights related to the Processing of the personal data

As per the applicable Romanian and EU data protection legal provisions, you have the following rights related to the Processing of your personal data:

the right to access your personal data;
the right to request the rectification, erasure or restriction of processing of your personal data;
the right to your personal data portability;
the right to object the Processing of your personal data;
the right not to be subject to a decision based solely on automated processing, including profiling;
the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal; and also
the right to lodge a complaint with the supervisory authority.

The Company does not use any kind of automated decision – making system, including profiling.

In order to exercise these rights and/or to request any amendment or update of your Personal Dataand/or in order to obtain clarifications related to the Processing operations of your Personal Data, please submit a request in this respect to the following contact details:

Phone: (+40) 311 027 961
Fax: (+40) 311 000 140
E-mail: office@bsmp.ro
Address: Magheru One, 1-3 Gh. Magheru Blvd., 5th floor, District 1, 010321.