DATA PROTECTION POLICY

We are committed to respecting your privacy and complying with all applicable data protection laws and regulations, including the General Data Protection Regulation (EU) 2016/679 („GDPR”).

This policy (along with the Terms and Conditions of this website and any other documents referenced in this policy) aims to provide you with information regarding the personal data we collect from you or that you provide to us through this website and how we will process it. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

1. WHO WE ARE

The data controller is the Romanian Association for Audience Measurement, established under Government Ordinance 26/2000 on associations and foundations („ARMA” or „the Association”). For more information about the Association, please visit https://www.arma.org.ro/?lang=en.

ARMA carries out certain activities using shared contact points, operational resources, and staff together with ARMADATA S.R.L. („ARMADATA”), a commercial company owned by ARMA. In these situations, for certain data flows, ARMA and ARMADATA may act as joint controllers within the meaning of Article 26 of the GDPR.

For this joint processing, in addition to this policy, the Joint Information Notice on Personal Data for the contact points and joint activities of ARMA and ARMADATA applies, available on the ARMA website (https://www.arma.org.ro/joint-privacy-notice-regarding-personal-data/?lang=en) and/or communicated through the relevant channels. For ARMADATA’s own commercial activities, it may act as a separate controller, and its own privacy notices apply accordingly.

2. WHAT KIND OF PERSONAL DATA DO WE PROCESS, FOR WHAT PURPOSES, AND ON WHAT LEGAL BASES?

In the course of administering this website, the Association will collect certain information („personal data”) relating to identified natural persons or that may lead to the identification of natural persons, which is provided by users of this website directly (e.g., first name, last name, email address) or indirectly (e.g., IP address, type of web browser used to browse our website, operating system, domain name, or domain host through which the user browses the website).

We will process personal data for the following purposes, based on the legal grounds indicated for each of them:

2.1. Browsing the website. Use of cookies

Our website does not use cookies.

For more information about the use of cookies on this website, please see our Cookie Policy: https://www.arma.org.ro/politica-privind-cookie-urile/

2.2. Responding to your questions, requests, or complaints

We will process your personal data, such as your first and last name, email address, and any other information or details you may provide in your correspondence, to resolve and respond to your questions or requests, depending on the communication channel through which you contact us, as described below.

 PurposeLegal basis
1Providing answers to your questions or requests via email or telephoneThe processing is based on a legitimate interest, allowing us to provide answers to your questions or requests.

2.2.1. To the extent that your request is submitted through a joint ARMA/ARMADATA channel or if, based on its content, it is necessary to determine whether the relevant relationship is exclusively associative, commercial, or mixed, your data may be processed by ARMA together with ARMADATA, as joint controllers, in accordance with the joint privacy notice mentioned above.

2.3. Handling of formalities regarding the conclusion, performance, and termination of contracts entered into by the Association

We will process the personal data of the representatives of contractual partners, their contact persons, and their employees, such as first name, last name, job title, email address, phone number, signature, as well as any other information or details you may provide to us in correspondence, in order to conclude, execute, and terminate contracts to which the Association is a party, as described below:

 PurposeLegal Basis
1The conclusion, performance, and termination of contracts to which the Association is a partyThe processing is based on a legitimate interest, enabling the contractual partner to conduct business with the Association.

2.4. Completion of legal formalities regarding appointments to the Association’s management and supervisory bodies

We will process the personal data of members’ representatives appointed to the Association’s management and supervisory bodies, such as first name, last name, date and place of birth, citizenship, home/residence address, signature, personal identification number (CNP), and ID card series and number in order to complete the formalities required by law regarding appointment to the Association’s management and supervisory bodies, as described below:

 PurposeLegal basis
1To complete the formalities required by law regarding appointment to the Association’s management and supervisory bodiesThe processing is based on a legal obligation.

2.5 Resolving any legal disputes and/or out-of-court proceedings related to the conclusion and performance of contracts with contractual partners (customers, suppliers, members, other entities)

We will process the personal data of members’ representatives and representatives of contractual partners and/or any persons acting on behalf of an entity, such as first name, last name, profession, place of employment, signature, personal identification number, ID card number and series, and any other such information provided to the Association in order to resolve any legal and/or extrajudicial proceedings related to the conclusion and performance of contracts with contractual partners (customers, suppliers, members, other entities), as described below:

 PurposeLegal basis
1To resolve any legal and/or extrajudicial proceedings related to the conclusion and performance of contracts with contractual partners (customers, suppliers, members, other entities)The processing is based on a legitimate interest in protecting and exercising the Association’s rights.

2.6. Managing relationships with Association members (registration, conducting activities, meetings)

We will process the personal data of members’ representatives—first name, last name, position, place of employment, signature, email address, phone number, image, voice, and signature—in order to manage our relationship with Association members, as described below:

 PurposeLegal basis
1To manage the relationship with Association members (registration, conducting activities, meetings)The processing is based on a legitimate interest, namely the management of the rights and obligations of data subjects, which derive from their status as representatives of an Association member. For image and voice, the legal basis is the data subject’s consent.

2.7. Promotion, collaboration, and public relations

We will process the personal data of representatives of national, European Union, or international authorities and bodies, as well as members and representatives of other national associations within the European Union or international associations, such as first name, last name, position, email address, and phone number, for the purpose of promoting the Association’s activities, collaborating with these entities, and for public relations, as described below:

 PurposeLegal basis
1To promote the Association’s activities, to establish collaborative relationships, and for public relationsThe processing is based on a legitimate interest, namely the completion of formalities for initiating or conducting collaborative relationships.

2.7.1 To the extent that these activities are organized or carried out together with ARMADATA or involve common points of contact, data processing may be carried out jointly with ARMADATA, under the conditions described in the Joint Information Notice.

2.8. Organization of meetings, events, workshops, seminars, conferences, and courses

We will process the personal data of representatives of members and contractual partners, contact persons, employees, speakers/presenters, course participants, and representatives of media partners, such as first name, last name, job title, email address, phone number, signature, image, and voice for the purpose of organizing meetings, events, workshops, seminars, conferences, and courses, as described below:

 PurposeLegal basis
1To organize meetings, events, workshops, seminars, conferences, and courses, including, but not limited to sending invitations and information regarding these events, publishing names in related materials (guides, regulations, etc.) produced by the Association or in which the Association has actively participated, as well as photographing, filming, and publishing photos/videos on the Association’s websiteThe processing is based on a legitimate interest, namely the management of the rights and obligations arising from the status of representative of an Association member. The processing is based on a legitimate interest, allowing us to organize such meetings, events, workshops, seminars, conferences, and courses. For the processing of images and voices and their publication on the website, as well as in event-related materials, the basis is consent.

2.8.1. If the event or activity is organized jointly with ARMADATA, if it uses shared resources and staff, or if the resulting data is used by both entities, ARMA and ARMADATA may act as joint controllers for that data flow, and this policy is supplemented by the Joint Privacy Notice.

2.9. Certification of reports containing data from the National TV Audience Measurement Service (SNMATV)

We will process the personal data of the applicants’ representatives, such as last name, first name, position, workplace, email address, phone number, and signature, for the purpose of carrying out the procedures for certifying reports containing data from SNMATV, as described below:

 PurposeLegal basis
1To carry out the certification procedures for reports containing data from SNMATV.The processing is based on a legitimate interest, namely the performance of the procedures necessary for the execution of the service contract underlying the certifications carried out by the Association.

2.10. Preparation of annual financial statements, filing of tax returns, and other legal financial obligations

We will process the personal data of members’ representatives, such as first name, last name, email address, phone number, signature, personal identification number (CNP), and ID card series and number, for the purpose of preparing annual accounts, filing tax returns, and fulfilling other legal financial obligations, as described below:

 PurposeLegal basis
1To prepare and file annual financial statements, tax returns, and other statutory financial reports.The processing is based on a legal obligation.

2.11. Making payments due to suppliers, managing balance sheets and reconciling accounts, retaining payment supporting documents, monitoring collections, sending payment notifications, managing the risk of non-payment, and administering debt collection activities

We will process the personal data of members’ representatives and representatives of contractual partners and/or any persons acting on behalf of and for an entity, such as first name, last name, job title, workplace, email address, phone number, fax number, signature, personal identification number, and ID card series and number (to the extent necessary to complete invoices, delivery documents, and any other documents related to the relationship with business partners) for the purpose of making payments due to suppliers, managing balance sheets and reconciling accounts, retaining payment supporting documents, monitoring collections, sending payment-related notifications, managing the risk of non-payment, and administering debt collection activities, as described below:

 PurposeLegal Basis
1To make payments owed by the Association to suppliers/service providers and/or customers of the Association; to manage balance sheets and reconcile accounts; retaining supporting documents (e.g., contracts, delivery notes, invoices) entered into by the Association with contracting parties to substantiate payments (financial and accounting purposes). Monitoring payments owed by clients to the Association, sending notifications regarding overdue payment deadlines and amounts owed, managing insurance against the risk of non-payment by clients, and administering debt collection activities.The processing is based on the Association’s legitimate interest in conducting its business by entering into contracts and fulfilling legal obligations to submit documents to tax authorities.

2.12. Conducting voting procedures by members via the website www.vot.arma.org.ro

We will process the personal data of members’ representatives, such as first name, last name, position, workplace, and email address, in order to carry out the voting procedures provided for in the Association’s Bylaws and the voting procedures necessary for the Association’s activities, as described below:

 PurposeLegal basis
1To manage the relationship with the Association’s members (conducting activities, meetings, and exercising members’ voting rights) To link a member’s representative’s name to the choice made during a voting procedure (if the vote is open) To generate reports containing the names of members’ representatives and whether or not they exercised their right to voteThe processing is based on a legitimate interest, namely the management of the rights and obligations of data subjects arising from their status as representatives of a member of the Association.

2.13. Managing relationships with Association members (registration, ongoing activities, meetings, sessions) through the use of audio-video teleconferencing service providers and service providers that transcribe audio-video and/or audio files.

We will process the personal data of members’ representatives: last name, first name, title, workplace, signature, email address, phone number—provided directly—as well as any other information you provide indirectly when using the service in question (IP address, browser type, session start date, session end date, number of minutes of the session), image, voice, in order to manage the relationship with the Association’s members, as described below:

 PurposeLegal basis
1To manage the relationship with Association members (registration, conducting activities, meetings, drafting meeting minutes, preparing meeting attendance sheets, preparing other documents necessary for the Association’s operations).The processing is based on a legitimate interest, namely the management of the rights and obligations of data subjects arising from their status as representatives of an Association member. For images and voice recordings, the legal basis is the data subject’s consent.

2.14. Managing relationships with Association members (registration, conducting activities, meetings, sessions) through the use of service providers for the electronic signing of Association documents

We will process the personal data of members’ representatives: last name, first name, position, place of employment, signature, email address, phone number, as well as any other information you provide indirectly when using the service in question (IP address), in order to manage our relationship with Association members, as described below:

 PurposeLegal basis
1To manage the relationship with Association members (registration, conducting activities, meetings, sessions, drafting meeting minutes, preparing meeting attendance sheets, preparing other documents necessary for the Association’s operations)The processing is based on a legitimate interest, namely the management of the rights and obligations of data subjects, which arise from their status as representatives of an Association member.

2.15. Managing relationships with Association members (registration, conducting activities, meetings, sessions, transmission of Association documents) through the use of service providers for the secure electronic transmission of Association documents

We will process the personal data of members’ representatives: last name, first name, position, place of employment, signature, email address, phone number, as well as any other information you provide indirectly when using the service in question (IP address, geographic location, operating system, browser type, activities performed regarding the transmitted documents: for example, viewing, downloading, forwarding to others), in order to manage the relationship with the Association’s members, as described below:

 PurposeLegal basis
1To manage the relationship with Association members (registration, conducting activities, meetings, meetings, drafting meeting minutes, preparing meeting attendance sheets, preparing other documents necessary for the Association’s operations, transmitting confidential or non-confidential documents necessary for the proper conduct of the Association’s activities)The processing is based on a legitimate interest, namely the management of the rights and obligations of data subjects, which derive from their status as representatives of an Association member, and the protection of the Association’s documents.

2.16. Managing relationships with Association members (administrative activities regarding members’ identification data) through the use of service providers that employ generative artificial intelligence tools with minimal or limited risk (e.g., ChatGPT, Microsoft Copilot)

We will process the personal data of members’ representatives: first name, last name, title, workplace, email address, and phone number, in order to manage our relationship with Association members, as described below:

 PurposeLegal basis
1In order to manage the relationship with Association members (for basic data processing related to member registration and updating their information)The processing is based on a legitimate interest, namely the management of the rights and obligations of data subjects, which derive from their status as representatives of an Association member.

2.17. Promotion, collaboration, and public relations through the use of audio-video teleconferencing service providers and providers of transcription services for audio-video and/or audio files, providers of electronic document signing services, providers of secure electronic document transmission services for the Association, and providers of services involving generative artificial intelligence tools with minimal or limited risk (e.g., ChatGPT, Microsoft Copilot, or Deepl Pro).

We will process the personal data of representatives of national, European Union, or international authorities and bodies, or of representatives of any other third parties, as well as members and representatives of other national associations within the European Union or international associations, such as first name, last name, title, email address, phone number, as well as any other information you provide indirectly when using the service in question (IP address, browser type, session start date, session end date, session duration in minutes, operating system, activities performed regarding the transmitted documents: for example, viewing, downloading, forwarding to others), image, voice, for the purpose of promoting the Association’s activities, collaborating with these entities, and for public relations, as described below:

 PurposeLegal basis
1To promote the Association’s activities, to establish collaborative relationships, and for public relations, to translate documentsThe processing is based on a legitimate interest, namely the completion of formalities for initiating or conducting collaborative relationships. For images and voice recordings, the legal basis is the data subject’s consent.

2.18. Automated decision-making and automated profiling

The personal data referred to herein is not subject to automated decision-making processes, including profiling.

3. TO WHOM DO WE DISCLOSE YOUR PERSONAL DATA?

To achieve the purposes described above, the Association uses the services of several contractual partners. Some of them act as data processors, such as: the IT service provider, accounting and secretarial service providers, the SNMATV provider (Kantar Media Audiences S.R.L.), and the SNMATV service provider (Armadata S.R.L.), which conduct their business in Romania, and your personal data may be provided to them for use within the limits of the obligations they have assumed toward the Association. The personal data we disclose to our authorized third parties is limited to the minimum personal information necessary to provide those services, and we require them not to use the personal data for any other purpose. We make every effort to ensure that all entities we work with store your personal data safely and securely.


To the extent that there are joint data flows described in the Joint Privacy Notice, ARMADATA does not act solely as a processor for certain services provided to ARMA, but may also act jointly with ARMA as a joint controller for those data flows. Consequently, the disclosure of data to ARMADATA may, as the case may be, constitute either a disclosure to a processor or to a joint controller, depending on the specific data flow.


Some of these are designated as authorized entities, such as: the electronic signature service provider (Adobe Systems Software Ireland LTD), the audio-video teleconferencing service provider (Microsoft, Zoom Communications, Inc), the secure file transfer service provider (Dropbox International Unlimited Company Ireland), the provider of services involving generative artificial intelligence tools with minimal or limited risk (OpenAI Ireland Limited and Deepl SE Germany, Microsoft), the provider of audio-video and/or audio transcription services (Notta Inc.), which also conducts business outside of Romania. Your personal data may be provided to them for use within the limits of their obligations to the Association, in accordance with the standard contracts they enter into with end users and the public statements available at https://www.microsoft.com/en-gb/privacy/privacystatement, on https://www.adobe.com/ro/privacy/policies-business/esign.html, on https://www.docsend.com/privacy-policy/, on https://openai.com/en-GB/policies/privacy-policy/, and on https://www.deepl.com/en/privacy, on https://www.notta.ai/en/privacy, at https://www.zoom.com/en/trust/privacy/privacy-statement/.


Some of these are third parties that do not intend to process the data, but may have access to it in the course of their duties or interactions with the Association, such as companies providing technical maintenance, courier services, financial or legal auditors, and companies providing cloud backup services (which also operate outside Romania, such as Dropbox International Unlimited Company Ireland, https://www.dropbox.com/privacy).


The personal data indicated above may also be made available or transferred to third parties in the following situations: (i) public authorities, auditors, or institutions with the authority to conduct inspections and audits of the Association’s activities and assets, which request the Association to provide information pursuant to the Association’s legal obligations; (ii) to comply with a legal requirement or to protect the rights and assets of our Association or other entities or individuals, such as courts; (iii) third-party acquirers, to the extent that the Association’s activities would be transferred (in whole or in part), and the data of data subjects would be part of the assets subject to such a transaction.

4. TRANSFER OF PERSONAL DATA ABROAD

In the context of the operations described above, your personal data may be transferred abroad to countries within the European Union („EU”) or the European Economic Area („EEA”).

We hereby inform you that any transfer made by the Association to an EU or EEA member state will comply with the legal requirements set forth in the GDPR.

5. HOW LONG WE STORE YOUR PERSONAL DATA

We will store your personal data only for the period of time necessary to achieve the processing purposes set out above, in compliance with as well as with the applicable legal requirements. If the Association determines that it has a legitimate interest or a legal obligation to continue processing your personal data for other purposes, you will be duly informed accordingly.

We estimate that the processing activities detailed above will require the storage of personal data for the following periods:

 PurposeDuration
1Browsing the websiteFor the duration of the session
2Response to your questions or requestsFor the duration of the request resolution process, but no later than 3 years from the date of collection.
3Handling formalities related to the conclusion, performance, and termination of contracts entered into by the AssociationFor the duration of the contract, but no longer than the statutory period applicable in this situation. In the absence of such a period, the retention period will be 4 years from the date of termination of the contract.
4Completion of legal formalities regarding appointments to the Association’s management and supervisory bodiesFor the duration of the term of office and for the period necessary to protect the Association’s rights, including the statute of limitations and the time limits provided for by tax and accounting legislation
5Resolution of any legal disputes and/or out-of-court proceedings related to the conclusion and performance of contracts with contractual partners (clients, suppliers, members)Data is retained for the duration of the commercial contract and for the period necessary to protect the Association’s rights in accordance with the law applicable to the contract, including the statute of limitations and the time limits provided for by tax and accounting legislation/the retention period established by law
6Management of relations with Association members (registration, conduct of activities, meetings)For the duration of the member’s representative status, but no longer than 4 years from the date such status ceases. If the member’s representative is replaced during this period, the former representative’s data is retained for a period of 4 years from the date the change is noted. For processing based on consent, data is retained until consent is withdrawn, but no later than the dates indicated above.
7Marketing, Collaboration, and Public RelationsDuring the course of the collaboration
8Organization of meetings, events, workshops, seminars, conferences, and coursesFor the duration of the member’s representative status, but no longer than 4 years from the date such status ceases. If the member’s representative is replaced during this period, the former representative’s data is retained for a period of 4 years from the date the change is noted. For processing based on consent, data is retained until consent is withdrawn, but no later than the dates indicated above.
9Certification of reports containing data from the National TV Audience Measurement Service (SNMATV)For the duration of the contract, but no longer than the statutory period applicable in this situation. In the absence of such a period, the retention period will be 4 years from the date of termination of the contract.
10Preparation of annual financial statements, filing of tax returns, and other legal financial obligationsFor the period prescribed by law for the retention of financial and accounting documents.
11Making payments due to suppliers, managing balance sheets and reconciling accounts, retaining supporting documents for payments, monitoring collections, sending payment notifications, managing the risk of non-payment, and administering debt collection activitiesData is retained for the duration of the commercial contract and for the period necessary to protect the Association’s rights, taking into account the law applicable to the contract, including the statute of limitations and the time limits set forth in tax and accounting legislation/the retention period established by law
12Management of the relationship with Association members (conduct of business, meetings, and exercise of members’ voting rights)For the duration of the member’s representative’s tenure, but no longer than 4 years from the date of termination of that tenure. If the member’s representative is replaced during this period, the former representative’s data is retained for a period of 4 years from the date the change is noted.
13Management of relations with Association members (registration, conduct of activities, meetings, sessions) through the use of audio-video teleconferencing service providers and providers of transcription services for audio-video and/or video files.For the duration of the member’s representative’s tenure, but no longer than 4 years from the date of termination of that tenure. If the member’s representative is replaced during this period, the former representative’s data is retained for a period of 4 years from the date the change is noted. For processing based on consent, data is retained until consent is withdrawn, but no later than the dates indicated above.
14Management of relations with Association members (registration, conduct of activities, meetings, sessions) through the use of providers of electronic document signing services for the AssociationFor the duration of the member’s representative’s tenure, but no longer than 4 years from the date of termination of that tenure. If the member’s representative is replaced during this period, the former representative’s data is retained for a period of 4 years from the date the change is noted.
15Management of relations with Association members (registration, conduct of activities, meetings, sessions, transmission of Association documents) through the use of service providers for the secure electronic transmission of Association documentsFor the duration of the member’s representative’s tenure, but no longer than 4 years from the date of termination of that tenure. If the member’s representative is replaced during this period, the former representative’s data is retained for a period of 4 years from the date the change is noted.
16Management of relations with Association members (administrative activities regarding members’ identification data) through the use of service providers that employ generative artificial intelligence tools with minimal or limited risk (e.g., ChatGPT, Microsoft Copilot)For the duration of the member’s representative status, but no longer than 4 years from the date such status ceases. If the member’s representative is replaced during this period, the former representative’s data is retained for a period of 4 years from the date the change is noted.
17Promotion, collaboration, and public relations through the use of audio-video teleconferencing service providers and providers of transcription services for audio-video and/or video file transcription services, providers of electronic document signing services, providers of secure electronic document transmission services for the Association, and providers of services involving generative artificial intelligence tools with minimal or limited risk (e.g., ChatGPT, Microsoft Copilot, or Deepl Pro).For the duration of the collaboration. For processing based on consent, data is retained until consent is withdrawn, but no later than the date indicated above.

Once the processing period indicated above expires, and the Association no longer has legal or legitimate grounds to process your personal data, the data will be deleted in accordance with its procedures, which may involve archiving, anonymizing, or destroying it.

6. PROCESSING OF DATA OF CHILDREN UNDER THE AGE OF 16

All personal data processing activities described in this Policy apply exclusively to individuals who are at least 16 years of age. The use of the systems, as well as the results of the processing, is prohibited with respect to children who have not reached this age without the consent of their parents or legal guardians. If, despite our reasonable efforts to prevent it, such processing nevertheless occurs, we will cease it as soon as we become aware that the users have not reached the age mentioned above.

7. DATA PROCESSING SECURITY

The Association hereby informs you that it constantly evaluates and updates the security measures implemented to ensure the safe and secure processing of personal data.

8. RIGHTS OF DATA SUBJECTS

8.1. In the context of the processing of your personal data, you have the following rights:

The right of access to processed personal data: you have the right to obtain confirmation as to whether or not your personal data is being processed and, if so, to access the type of personal data and the conditions under which it is processed, by submitting a request to that effect to the data controller;

The right to request the correction or deletion of personal data: You have the right to request, by submitting a request to the data controller, the rectification of inaccurate personal data, the completion of incomplete data, or the erasure of your personal data if (i) the data is no longer necessary for the original purpose (and there is no new legal basis), (ii) the legal basis for processing is the data subject’s consent, the data subject withdraws consent, and there is no other legal basis, (iii) the data subject exercises their right to object, and the controller has no legitimate grounds to continue processing, (iv) the data has been processed unlawfully, (v) erasure is necessary to comply with EU or Romanian law, or (vi) the data was collected in connection with information society services offered to children (if applicable), where specific requirements regarding consent apply;

Right to request restriction of processing: you have the right to obtain restriction of processing in cases where: (i) you consider that the personal data being processed is inaccurate, for a period enabling the controller to verify the exactness of the personal data; (ii) the processing is unlawful, but you do not want us to delete your personal data, but rather to restrict the use of such data; (iii) where the data controller no longer needs your personal data for the purposes mentioned above, but you need the data to establish, exercise, or defend a legal claim or (iv) you have objected to the processing, for the period during which we verify whether the data controller’s legitimate grounds override the data subject’s rights;

The right to withdraw your consent to processing, when the processing is based on consent, without affecting the lawfulness of processing activities carried out up to that point;

The right to object to the processing of your data for reasons related to your particular situation, when the processing is based on a legitimate interest, as well as the right to object, at any time, to the processing of your data for direct marketing purposes, including profiling;

The right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning the data subject or similarly significantly affects the data subject;

The right to data portability, meaning the right to receive the personal data you have provided to the data controller in a structured, commonly used, and machine-readable format, as well as the right to transmit those data to another controller, where the processing is based on your consent or on the performance of a contract and is carried out by automated means;

The right to file a complaint with the Data Protection Authority (ANSPDCP) and the right to bring the matter before the competent courts.

The above rights may be exercised at any time. To exercise these rights, we encourage you to submit a written request, dated and signed, or in electronic format, to the following address: 3A Promoroacă St., 3rd floor, Sector 1, Bucharest, or via email to contact@arma.org.ro .

8.2. If your request concerns a joint ARMA/ARMADATA data flow, ARMA will coordinate the response internally with ARMADATA, without limiting your right to contact either of the two entities.

9. CHANGES TO THIS POLICY

This Data Protection Policy may be amended from time to time and updated by the Association as necessary. The Association will notify you of any material or substantial changes to this Data Protection Policy and will ensure that such notification is provided in a manner that ensures you are made aware of them, for example, by using the email address you provided to us or any other appropriate means that ensure effective communication.

10. CONTACT

You may direct any questions regarding this document using the following contact details: contact@arma.org.ro.

For matters concerning ARMA/ARMADATA contact points or joint activities, please also refer to the Joint Information Note available on the ARMA website or communicated through the relevant channels.

Rev. June 22, 2026