Effective Date: May 25, 2018.

Who We Are

CLARIO Ophthalmology is a provider of high-quality medical services. “Clario”, “Clario Ophthalmology”, “we”, “our” or “us” refers to Clario Oftaclinic SRL / Clario Lens SRL, Romanian legal entities, registered with the following details:

Clario Oftaclinic SRL
Str. Zagazului 21-25, corp C, cam 25, etaj 1, sector 1, Bucharest
CUI: 34283564
J40/13385/2014

Clario Lens SRL
Str. Zagazului 21-25, corp C, cam 21, etaj 1, sector 1, Bucharest
CUI: RO33810917
J40/3659/2015

Through this privacy policy, CLARIO wishes to inform you about your personal data that we collect and use (in other words, that we process and use) during your visit to our websites. Personal data refers to any information relating to a specific or identifiable natural person, which you communicate to us or which we receive or collect, such as: name and contact details (e.g. address, phone number, email address), information about your requests and professional relationship with us, as well as any participation alongside us, information regarding the time, purpose and, if applicable, place where you use our websites and other electronic services. We collect and use personal data only to the extent permitted by law or if you have given us prior consent in this regard.

Processing of Personal Data

We process your personal data exclusively within the framework of legal provisions regarding the protection of personal data in Romania. These are the provisions of Law no. 677/2001 for the protection of persons regarding the processing of personal data and the free circulation of such data as well as the provisions of Law no. 506/2004 regarding the processing of personal data and the protection of private life in the electronic communications sector.
Our employees and representatives have the obligation to respect the provisions regarding data protection according to legal norms.

Regarding all requests related to your data, data protection within CLARIO company or any questions/complaints can be addressed to the email address: contact@clario.ro.

The purpose of data processing is:

  • own marketing
  • website operation

In the following, we inform you about the manner, volume and purposes of processing and use of personal data.

You can modify any information held about you at any time.

The process of modifying or deleting your data will be carried out online, from your account. We are in the process of implementation, until then, however, please contact us at the email address: contact@clario.ro and our company representative will solve your request as soon as possible.

What rights do you have and how can you exercise them?

According to law 677/2001 you benefit from the right of access, the right to intervene on data and the right not to be subject to an individual decision, as well as to address justice. At the same time, you have the right to oppose the processing of personal data concerning you and to request the deletion of personal data collected by us.

Right to Information

(1) In case personal data is obtained directly from the data subject, the operator is obliged to provide the data subject with at least the following information, except in the case where this person already possesses the respective information:
a) the identity of the operator and its representative, if applicable;
b) the purpose for which data processing is performed;
c) additional information, such as: recipients or categories of recipients of the data; whether providing all requested data is mandatory and the consequences of refusing to provide it; the existence of rights provided by this law for the data subject, especially the right of access, intervention on data and opposition, as well as the conditions under which they can be exercised;
d) any other information whose provision is required by provision of the supervisory authority, taking into account the specifics of the processing.
(2) In case data is not obtained directly from the data subject, the operator is obliged to, at the time of data collection or, if disclosure to third parties is intended, at the latest until the time of the first disclosure, provide the data subject with at least the following information, except in the case where the data subject already possesses the respective information:
a) the identity of the operator and its representative, if applicable;
b) the purpose for which data processing is performed;
c) additional information, such as: categories of data concerned, recipients or categories of recipients of the data, the existence of rights provided by this law for the data subject, especially the right of access, intervention on data and opposition, as well as the conditions under which they can be exercised;
d) any other information whose provision is required by provision of the supervisory authority, taking into account the specifics of the processing.
(3) The provisions of para. (2) do not apply when data processing is performed exclusively for journalistic, literary or artistic purposes, if their application would give indications about information sources.
(4) The provisions of para. (2) do not apply in case data processing is performed for statistical, historical or scientific research purposes, or in any other situations where providing such information proves impossible or would involve disproportionate effort compared to the legitimate interest that could be harmed, as well as in situations where data recording or disclosure is expressly provided by law.

Right of Access to Data

(1) Any data subject has the right to obtain from the operator, upon request and free of charge for one request per year, confirmation of the fact that data concerning them is or is not processed by the operator. The operator is obliged, in the situation where it processes personal data concerning the applicant, to communicate to them, together with the confirmation, at least the following:
a) information regarding the purposes of processing, categories of data considered and recipients or categories of recipients to whom the data is disclosed;
b) communication in an intelligible form of the data that is the subject of processing, as well as any available information regarding the origin of the data;
c) information about the operating principles of the mechanism through which any automatic processing of data concerning the respective person is performed;
d) information regarding the existence of the right to intervene on data and the right of opposition, as well as the conditions under which they can be exercised;
e) information about the possibility to consult the register of personal data processing records, provided in art. 24, to file a complaint with the supervisory authority, as well as to address the court to challenge the operator’s decisions, in accordance with the provisions of this law.
(2) The data subject may request from the operator the information provided in para. (1), through a request made in written form, dated and signed. In the request, the applicant may indicate whether they wish the information to be communicated to them at a certain address, which may also be an email address, or through a correspondence service that ensures delivery will be made only personally.
(3) The operator is obliged to communicate the requested information within 15 days from the date of receiving the request, respecting any option of the applicant expressed according to para. (2).
(4) In the case of personal data related to health status, the request provided in para. (2) may be submitted by the data subject either directly or through a medical professional who will indicate in the request the person on whose behalf it is submitted. At the request of the operator or the data subject, the communication provided in para. (3) may be made through a medical professional designated by the data subject.
(5) In case personal data related to health status is processed for scientific research purposes, if there is no apparent risk of harming the rights of the data subject and if the data is not used to make decisions or measures against a certain person, the communication provided in para. (3) may be made within a longer period than that provided in that paragraph, to the extent that this could affect the proper conduct or results of the research, and no later than when the research is concluded. In this case, the data subject must have given express and unequivocal consent for the data to be processed for scientific research purposes, as well as regarding the possible postponement of the communication provided in para. (3) for this reason.
(6) The provisions of para. (2) do not apply when data processing is performed exclusively for journalistic, literary or artistic purposes, if their application would give indications about information sources.

Right to Intervene on Data

(1) Any data subject has the right to obtain from the operator, upon request and free of charge:
a) as the case may be, rectification, updating, blocking or deletion of data whose processing does not comply with this law, especially incomplete or inaccurate data;
b) as the case may be, transformation into anonymous data of data whose processing does not comply with this law;
c) notification to third parties to whom the data has been disclosed of any operation performed according to lit. a) or b), if this notification does not prove impossible or does not involve disproportionate effort compared to the legitimate interest that could be harmed.
(2) For exercising the right provided in para. (1), the data subject will submit to the operator a request made in written form, dated and signed. In the request, the applicant may indicate whether they wish the information to be communicated to them at a certain address, which may also be an email address, or through a correspondence service that ensures delivery will be made only personally.
(3) The operator is obliged to communicate the measures taken under para. (1), as well as, if applicable, the name of the third party to whom personal data concerning the data subject has been disclosed, within 15 days from the date of receiving the request, respecting any option of the applicant expressed according to para. (2).

Right of Opposition

(1) The data subject has the right to oppose at any time, for well-founded and legitimate reasons related to their particular situation, that data concerning them be subject to processing, except in cases where there are contrary legal provisions. In case of justified opposition, processing may no longer concern the data in question.
(2) The data subject has the right to oppose at any time, free of charge and without any justification, that data concerning them be processed for direct marketing purposes, on behalf of the operator or a third party, or be disclosed to third parties for such a purpose.
(3) For exercising the rights provided in para. (1) and (2), the data subject will submit to the operator a request made in written form, dated and signed. In the request, the applicant may indicate whether they wish the information to be communicated to them at a certain address, which may also be an email address, or through a correspondence service that ensures delivery will be made only personally.
(4) The operator is obliged to communicate to the data subject the measures taken under para. (1) or (2), as well as, if applicable, the name of the third party to whom personal data concerning the data subject has been disclosed, within 15 days from the date of receiving the request, respecting any option of the applicant expressed according to para. (3).
Exceptions
(1) The provisions of art. 12, 13, of art. 14 para. (3) and of art. 15 do not apply in the case of activities provided in art. 2 para. (5), if their application prejudices the efficiency of the action or the objective pursued in fulfilling the legal attributions of the public authority.
(2) The provisions of para. (1) are applicable strictly for the period necessary to achieve the objective pursued through the conduct of activities mentioned in art. 2 para. (5).
(3) After cessation of the situation that justifies the application of para. (1) and (2), operators conducting activities provided in art. 2 para. (5) will take necessary measures to ensure respect for the rights of data subjects.
(4) Public authorities keep records of such cases and periodically inform the supervisory authority about their resolution.

Right Not to Be Subject to an Individual Decision

(1) Any person has the right to request and obtain:
a) withdrawal or cancellation of any decision that produces legal effects concerning them, adopted exclusively based on personal data processing, performed through automated means, intended to evaluate certain aspects of their personality, such as professional competence, credibility, behavior or other similar aspects;
b) re-evaluation of any other decision made concerning them, which significantly affects them, if the decision was adopted exclusively based on data processing that meets the conditions provided in lit. a).
(2) Respecting other guarantees provided by this law, a person may be subject to a decision of the nature referred to in para. (1), only in the following situations:
a) the decision is made within the framework of concluding or executing a contract, provided that the request for concluding or executing the contract, submitted by the data subject, has been satisfied or that adequate measures, such as the possibility to support their point of view, guarantee the defense of their own legitimate interest;
b) the decision is authorized by law that specifies measures guaranteeing the defense of the legitimate interest of the data subject.

Right to Address Justice

(1) Without prejudice to the possibility of addressing a complaint to the supervisory authority, data subjects have the right to address justice for the defense of any rights guaranteed by this law, which have been violated.
(2) Any person who has suffered damage as a result of illegal personal data processing may address the competent court for its repair.
(3) The competent court is the one in whose territorial jurisdiction the plaintiff resides. The summons is exempt from stamp duty.

Contact

For exercising the rights mentioned above for revocation, information, deletion or correction of your data, please address us through written request by email at contact@clario.ro.

What data is stored by CLARIO?

1.1 Storage and processing of non-personal (anonymous) data for internal system purposes and statistical purposes

When accessing our internet page, your internet browser automatically transmits data (e.g. date and time of access, URL address of the internet page that makes the reference, accessed file, amount of transmitted data, browser type and version, operating system, ) to our server, based on technical settings. This data is collected and used exclusively for statistical and analysis purposes, e.g. for improving the offer.
Certain traffic data (such as IP addresses or other identifiers of devices with which you access our site) may in certain circumstances be personal data and as such we will treat them as such.

1.2 Storage and processing of personal data

1.2.1 Data for newsletter service.
When registering for our newsletter service, your data is used by CLARIO for promotional and marketing purposes. Use ceases as soon as you give up the newsletter service. You can give up the newsletter service at any time.

1.2.2 Use of cookies
Cookies are small text files that are saved by your internet browser and serve to make our internet page overall easier to use, more efficient and safer. Cookies do not damage your computer and do not contain viruses. You can prevent cookie installation through an appropriate setting of your browser.
Our online page contains cookies. Cookies save especially the settings chosen by you. Cookies are also used by us for statistical purposes. We draw your attention to the fact that by preventing cookie installation it may happen that you cannot use all functions of our internet page.

We use cookies to personalize content and ads, to provide social media functions and to analyze traffic. We also provide social media, advertising and analytics partners with information about how you use our site. They may combine this with other information provided by you or collected as a result of using their services.

For information or requests based on the rights of data subjects according to GDPR, you can address the Data Protection Officer (Responsible) at the email address contact@clario.ro or you can access the page where you can express your consent regarding each cookie file separately.

1.2.2.1 Cookie files will be divided into categories:

Internal Cookies

A visit to this site may place cookies for purposes of:

  • Essential cookies. Necessary for site functionality. We may use essential cookie modules to authenticate users, to prevent fraudulent use of user accounts or to provide site-specific functions.
  • Traffic measurement cookies. Allows us to recognize and count the number of visitors and see how visitors move around the site when they use it. This helps us improve how the site works.
  • Functionality cookies. Used to recognize you when you return to the Site. This allows us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
  • Targeting cookies. Record your visit to the site, the pages you have visited and the links you have clicked. We will use this information to make the site even more relevant to your interests. There is also the possibility of sharing this information with third parties, also for the purpose of making the site more relevant to you.

To see a list of cookies used by our site, consult the Cookies table.

Third-party cookies

In addition to our own cookies, we may also use other third-party cookies to report site usage statistics and to improve marketing efforts.

  • Tracking cookies. Track behavior on the site and connect it to other values that allow a better understanding of usage habits.
  • Optimization cookies. Allow real-time tracking of user conversion from various marketing channels to evaluate their effectiveness.
  • Partner cookies. Provide our partners with conversion metrics so they can optimize their paid marketing efforts.

To see a list of third-party cookies used by our site, consult the Cookies table.

Updating or deleting your personal information

You have certain rights regarding your personal information. You may access your personal information and confirm that it remains correct and update it or choose whether or not you want to receive materials from us or from some of our partners.

If you want additional information about your rights or want to exercise any of the rights above, you can contact us also through contact@clario.ro. Exercising your rights mentioned above is free. If you live or are located in the EEA, you have the right to request:

  • that we provide you access to any information regarding personal identity that we hold;
  • to prevent processing of your personal information for direct marketing purposes;
  • to update any personally identifiable information that is outdated or incorrect;
  • delete all personally identifiable information we hold about you;
  • restrict the way we process your personally identifiable information;
  • provide your personally identifiable information to a third-party service provider; or
  • provide you with a copy of any Personal Identification Information we have about you.

We try to respond to each email promptly, where possible, and to provide our response within the timeframe established by current legislation. Please note, however, that there will be residual information that will remain in our databases, access logs and other records that may or may not contain personal information. Also note that certain personally identifiable information may be exempt from such requests in certain circumstances, which may include if we must continue processing your personal information for the purpose of complying with a legal obligation.

When you send us an email with a request, we may ask you to provide us with the information necessary to confirm your identity.

In what situations do third parties have access to your data?

1. Transmission to public institutions, e.g. in case of a court order
At the disposal of competent institutions in special cases we must provide information regarding personal data, to the extent that this is necessary for the purpose of criminal investigation, public safety, for fulfilling the legal tasks of intelligence services or military counterintelligence service or for the purpose of realizing intellectual property rights.

2. Social network plugins
Our internet page uses “plugins” from social network operators (e.g.: www.facebook.com). All social network plugins on our internet page are clearly marked. When accessing our internet pages that contain a social network plugin, your browser will make a direct connection to the social network operator’s server. The plugin content will be transmitted from the accessed server of the social network operator directly to your browser and will be integrated by it into the internet page. Through plugin integration, the social network operator receives information that you have accessed our page. In case a valid connection session to a social network is running during the visit to our internet page, the visit can be attributed to the respective user account. If you interact with the plugin, the respective information is transmitted to the social network operator and is saved there. If you want to prevent the collection of your data by the social network operator through our internet page, you must disconnect (i.e. log out) from the social network operator’s service before visiting our internet page.

You can also oppose from our site the transmission of data to each type of plugin, from the Cookie Usage Policy page

Information regarding the purpose and volume of data storage as well as regarding further processing, use and rights you benefit from, as well as setting possibilities can be found in the social network operator’s data protection specifications, which are not related to this data protection statement. Regarding the “facebook” operator you can find these guidelines at http://www.facebook.com/policy.php.

CLARIO does not assume responsibility for the data protection guidelines and procedures of partner internet pages.

3. Google Analytics web analysis service
Our internet page uses the web analysis service “Google Analytics” of Google Inc. for statistical purposes. This web analysis service uses so-called “cookies” (see above at Use of cookies). Through cookies, only anonymous information regarding the use of our internet page is generated. This information is transmitted to Google Inc.’s server in an EU member state or outside the EU (e.g. in the USA) and is saved there. Google Inc. provides an adequate data protection regime in the USA through participation in the Privacy Shield project – see details at https://www.privacyshield.gov/participant?id=a2zt0000000GnaNAAS

Google Inc. will possibly transmit the information to third parties, to the extent that this is provided by law or to the extent that third parties process this data on behalf of Google Inc. Neither we nor Google Inc. will connect your IP address with other data that is saved by Google Inc. or by us.

CLARIO does not assume responsibility for the data protection guidelines and procedures of partner internet pages.

Data Security

Our internet page and other computer systems are protected through technical and organizational measures against access, modification or dissemination of your data by unauthorized persons as well as against loss or destruction of your data.
It is necessary to permanently treat your access data confidentially and to close the browser window when you finish visiting our internet page.
For the transfer of personal data we use technical encryption procedures. You can identify encrypted data transmission (https) by displaying a lock symbol, e.g. displaying a key or lock symbol in your browser’s status bar.

Questions, Suggestions and Complaints?

Do you have questions regarding data protection, cookie usage policy or our internet page? No problem, we are happy to help you.
contact@clario.ro