Information notice regarding the processing of personal data
Please read this document carefully before accessing thecoopnetwork.io coopwallet.finance (hereinafter referred to as " our Websites") or accessing our Coop Wallet app (hereinafter referred to as " our App").
The processing of the User's personal data is carried out by the operator " GEOMA DAO COOP Cooperativa agricolă ", a legal entity with registered office in the village of Mândra, commune of Loamneş no. 17, Sibiu county, Romania, registered in the Trade Register under number C32/4/2020, having CUI 43109878 and EUID C32/4/2020 (hereinafter referred to as " The Coop Network Operator ").
The user can browse the Site without providing personal data. However, in some specific cases, in order to be able to offer the requested electronic services, the User is required to provide such data. In this sense, The Coop Network Operator undertakes all the necessary steps to process the User's personal data, in accordance with the principles established by the data protection legislation applicable in Romania and the GDPR Regulation. The safety of the User's data is the most important for The Coop Network Operator, therefore we treat with seriousness and involvement any aspect regarding the protection of this data.
Important: Our Websites, nor our App is not intended for persons under the age of 18 (eighteen). The operator of The Coop Network does not collect, and does not knowingly wish to collect, data relating to minors. In this regard, The Coop Network Operator makes all necessary due diligence to verify, reasonably, that the person providing data is not under 18 years of age. The responsibility for any kind of information provided to The Coop Network, with the circumvention of these provisions, rests entirely with the User who transmits this data or the guardian in question. If the situation so requires, The Coop Network Operator will process personal data of a person under 18 years of age only if and to the extent that the consent regarding the processing of personal data is granted or authorized by the parent or the holder of parental responsibility for this people.
Identification data of The Coop Network Operator
Our Websites and our App are operated by the Agricultural Cooperative " GEOMA DAO COOP", a legal entity with its registered office in the village of Mândra, commune of Loamneş no. 17, Sibiu county, Romania, registered in the Trade Register under number C32/4/2020, having CUI 43109878 and EUID C32/4/2020 (hereinafter referred to as "The Coop Network "), having the capacity of personal data operator.
The contact details of The Coop Network Operator are available here https://thecoopnetwork.io/contact.
1 The categories of personal data processed
2 Method of processing the User's personal data
3 The purpose of processing the User's personal data
4 Disclosure of the User's personal data
5 International transfers of the User's personal data
6 Links to external websites
7 Links to the Site provided by third parties
8 Provision by the User of other people's personal data
9 Duration of personal data processing
10 User Rights
11 Security of personal data
12 Questions, complaints, complaints
13 Legal basis
" Cookies "
means a small file, usually made up of letters and numbers; it is downloaded, with your consent, into the memory of an electronic device used for Internet browsing ( smartphone , tablet, etc.), when the user accesses a certain website.
" Personal data "
means any kind of information about a natural or legal person that can help, directly or indirectly, to identify that person.
" Operator of The Coop Network " or " The Coop Network "
means the operator responsible for data processing within the meaning of the GDPR Regulation, namely the agricultural cooperative " GEOMA DAO COOP ", a legal entity with its registered office in the village of Mândra, commune of Loamneş no. 17, Sibiu county, Romania, registered in the Trade Register under number C32/4/2020, having CUI 43109878 and EUID C32/4/2020.
" Data Subject " or "User"
means that natural person (including the agent of an entity) who accesses and uses our Websites (thecoopnetwork.io, coopwallet.finance) or our App (Coop Wallet) for any purpose ( eg viewing presentations of the services and/or products offered by The Coop Network , subscribing to the newsletter, becoming a member of The Coop Network) and who, from the perspective GDPR Regulation, can be an identified or identifiable natural person (directly or indirectly, in particular by reference to an identification element: name, identification number, location data, an online identifier, or to one/more specific elements, own his physical, physiological, genetic, psychological, economic, cultural or social identity). The person concerned can be the applicant for a service offered by The Coop Network Operator , as well as any other natural person whose personal data is transmitted to the Operator (for example a customer or potential customer, a candidate for a certain available position, a user of the Operator's website, etc.).
" Processing of personal data "
means any operation or set of operations performed on personal data or sets of personal data belonging to the Data Subject, with or without the use of automatic means, such as collection, recording, organization, structuring, storage, adaptation or modification, extract, consult, use, disclose by transmission, disseminate or otherwise make available, align or combine, restrict, delete or destroy.
" GDPR Regulation "
means Regulation (EU) 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (General Data Protection Regulation) known as GDPR ( General Data Protection Regulation ).
" Responsible for data protection "
the address to which requests for information regarding the processing of personal data by The Coop Network Operator can be sent : firstname.lastname@example.org
" our Websites "
" our App "
means the Coop Wallet mobile application
" Third Party "
means a person, entity or group of persons and/or entities that is not and has not been declared to be a member, employee, affiliate or subsidiary of The Coop Network .
1. The categories of personal data processed
In order to read the existing information on our Websites and our App, it is not necessary to provide personal data, providing them depends exclusively on the User's option. However, for the purpose of the technical exploitation of the Websites & App or for the use of some services (e.g. newsletter subscription, becoming a Coop Network member, investing in Coop Network projects), it is necessary to provide certain personal data in order to be able to provide access to the respective functionality or to be able to deliver the good and/or service . For details, please refer to the section corresponding to the operation used on the site.
In any case, The Coop Network Operator does not collect personal data about Users regarding details of racial or ethnic origin, political opinions and affiliations, religious confession, philosophical beliefs, Processing of genetic data, Processing of biometric data , Processing of health data or Processing of data regarding sex life or sexual orientation. Also, The Coop Network does not collect information regarding crimes and/or criminal convictions.
2. Method of processing the User's personal data
2.1. Use of the Websites
When the User intends to access our Websites to search for certain products, services and / or to view certain information that The Coop Network makes available, a number of cookies are used by us (first party cookies) and by third parties (third party cookies) to enable the operation of the Site and to provide the best possible experience in using the Site.
2.2 Use of the App
Whenever you use our App, we collect the following information:
✓ technical information, including the internet protocol (IP) address used to connect your computer/mobile device to the internet, your login information, the browser type and version, the time zone setting, the operating system and platform, the type of device you use, a unique device identifier (for example, your device's IMEI number, the MAC address of the device's wireless network interface, or the mobile phone number used by the device), mobile network information, your mobile operating system and the type of mobile browser you use
✓ information about your visit, including the links and pages you’ve clicked on, through and from our App (including date and time), services you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling and clicks), and methods used to browse away from the page
✓ information on transactions and your use of Coop Wallet products (for example, payments into and out of your account), including the date, time, amount, currencies, exchange rate, beneficiary details if is a Coop member, sender's and receiver's name and registration information if they are Coop members, details of device used to arrange the payment and the payment method used
2.3. Requests made by the User to benefit from a service
When the User intends to subscribe to the newsletter, he must enter his e-mail address on the Site, in the dedicated section. Thus, the e-mail address will be processed by The Coop Network Operator to be able to send to the interested User personalized information about our products and services.
When the User intends to register as a Coop Network member, he must enter his email, phone number, fullname, date of birth, nationality, born location, residence address, ID card / passport No. and ID card / passport scan on the Site, in the dedicated section. The user is able to become a member only if he successfully completes our Know Your Customer (KYC) process. The KYC standards are designed to protect financial institutions against fraud, corruption, money laundering and terrorist financing. KYC involves several steps to establish member identity, like the identity document scan & liveness detection. Persons who, according to the law, are incapable or who have been convicted of crimes against patrimony through breach of trust, crimes of corruption, embezzlement, crimes of forging documents or tax evasion cannot be members.
When the User intends to invest in Coop Network projects, he will provide data including date, time, amount, currencies, exchange rate, details of device used to arrange the payment and a choosed payment method. The user is able to invest in a Coop Network project only if he is an active Coop Network member and successfully completes our Know Your Customer (KYC) process.
3. The purpose of processing the User's personal data
Purpose : the personal data processing activity is carried out to ensure an optimal connection, to ensure a comfortable use of the Websites and App, to evaluate the safety and stability of the Websites and the App systems. Thus, the processing of personal data is carried out both in the interest of the User (in order to provide him with fully functional Websites & App), as well as in the interest of The Coop Network Operator (in order to continuously improve the Websites & App and to avoid potential losses generated by potential fraudulent actions).
Grounds: in order to achieve the stated purpose, we consider that The Coop Network Operator has a legitimate interest in processing certain personal data of the User to analyze the usability of the Websites & App, to ensure the general functionality of the Websites & App, to improve the experience To the User and provide a higher quality service or to avoid cyber attacks, as the case may be.
Purpose: we process the User's personal data to customize the products and / or services offered by The Coop Network Operator so that we can make recommendations to the User based on your interactions with us on the Site ;
Grounds: The Coop Network Operator's legitimate interest is to promote its products and/or services.
Purpose: the processing of personal data for marketing purposes is mainly carried out to transmit personalized information about the products and / or services provided by The Coop Network Operator (to the extent that the User has subscribed to the newsletter) via e-mail . Specifically, through direct marketing actions, The Coop Network Operator sends interested Users an e-mail message containing general and thematic information about similar or complementary customized products or services.
Basis: The operator of The Coop Network is permitted, from a legal point of view, to process the User's data for marketing purposes
Purpose: these communications will be made for a specific reason such as: ( i ) to respond to the User's requests, ( ii ) to inform the User about the way in which the complaints and/or incidents arising in the interaction with us were resolved.
Grounds: the legitimate interest of The Coop Network Operator to provide services at the desired standards by resolving possible requests and / or complaints and to assure the User of our full availability.
Purpose: In certain cases, The Coop Network Operator must process the information provided by the User (which may include personal data) to protect our rights and business activity. These situations may include:
Grounds : the reasons for the processing can be represented by the legal obligation (if we have the legal obligation to disclose certain personal data to the public authorities) or by our legitimate interest to resolve possible investigations, disputes and/or complaints.
Grounds: the legitimate interest to continuously provide improved services to the Users of the Websites.
Note: In the event that the Operator intends in the future to process the Users' personal data for a purpose other than those mentioned above, this will be brought to your attention, even before this further processing, information regarding the respective secondary purpose and any relevant information.
4. Disclosure of the User's personal data
In order to provide the expected level of professionalism and provide high-quality services, the User's personal data may be transmitted by The Coop Network Operator to third parties for the purposes mentioned in section 2 (" Purpose of processing the User's personal data " ), subject to applicable law, as detailed below:
The privacy of the User's data is important to The Coop Network Operator, which is why, where possible, the transmission of personal data in accordance with the above is only carried out on the basis of a confidentiality commitment from the recipients, by which they guarantee that this data are kept secure and that the provision of such information is made in accordance with applicable law and policies. In any case, each time the Operator of The Coop Network transmits to third parties only the information strictly necessary to achieve that purpose.
5. International transfers of the User's personal data
In the context of the operations described above, the User's personal data may be transferred by The Coop Network Operator abroad, including to countries in the European Union ("EU") or the European Economic Area ("EEA"), to other companies, organizations or persons from third countries or to international organizations. If it will be necessary for us to transfer the User's personal data to any of the above destinations, The Coop Netwrok Operator will send a new information notice about this in advance. The Coop Network Operator will ensure, within reasonable limits, that Users' data does not leave the EEA.
It is possible that some of the service providers of The Coop Network Operator are located outside the EEA, so their processing of the User's personal data will involve a transfer of data outside the EEA.
Thus, if The Coop Network Operator deems it necessary to transfer the User's personal data to a third country, outside the EEA, this will only be done if the country ensures an adequate level of protection and only to the extent that the transfers are legitimate (based on the explicit consent of the User or other legal basis).
We ask the User to contact us at the email address email@example.com if they want more information about the specific mechanism used by The Coop Network Operator when we transfer personal data outside the EEA.
6. Links to external websites
Therefore, The Coop Network Operator shall not be responsible for the availability of such external websites, nor for the content, advertising, goods, services, information or other materials available on or through such websites, for the functionality or performance of such of sites or for the infringement of any intellectual property rights or other rights that occurs through these sites. It is the responsibility of the Third Parties who administer the respective sites to ensure compliance with any legal regulations imposed on them.
7. Links to the Site provided by third parties
8. Provision by the User of other people's personal data
9. Duration of personal data processing
The operator of The Coop Network constantly reviews the need to keep the User's personal data, and to the extent that the processing is no longer necessary and there is no legal obligation to keep this data, we will delete / destroy the information as soon as possible and in a way in which they can no longer be recovered or reconstituted.
If the User's personal information is printed on paper, it will be destroyed in a way that ensures its complete elimination, and if it is saved on electronic media, it will be deleted by technical means to ensure that the information cannot be recovered or reconstituted later.
10. User Rights
The User, as the Data Subject, benefits from a series of rights provided by the GDPR Regulation, namely:
The operator of The Coop Network is not obliged to comply with this request if the processing of the User's data is necessary for
as well as in other circumstances, but these two are the most probable.
The rights listed above are not absolute, with certain exceptions. For any additional questions, please contact us at one of the available contact addresses.
Also, in order to exercise the mentioned rights, the User is asked to send a written, dated and signed request to the e-mail address: firstname.lastname@example.org or to the postal address Mândra village, Loamneş commune no. 17, Sibiu county, Romania, to the attention of the data protection officer . In order to exercise the rights mentioned, the User does not have to pay any fee.
However, each request received from the User will be analyzed by The Coop Network Operator in order to decide whether it is justified or not. To the extent that the request is justified , The Coop Network Operator will facilitate the exercise of the rights claimed by the User. If the User 's request is unfounded , The Coop Network Operator will reject it and inform the User both of the reasons for the refusal and of his right to file a complaint with the competent Supervisory Authority and/or of his right to go to court.
Thus, within no more than 30 (thirty) days, calculated from the date of receipt of the request, the User will be provided by The Coop Network with a response with information on the actions taken or, where applicable, on the reasons for that the requested measures can (not) be taken. Also, according to the GDPR Regulation, the said response period can be extended by no more than two months in the situation where it is necessary, taking into account the complexity and the large number of requests received or the impossibility of identifying the User in a timely manner, following that The operator of The Coop Network will inform you about this, if applicable.
Therefore, in order to be able to respond to the possible requests of the User (by which it is desired to exercise certain rights), The Coop Network Operator will be able to request additional information in order to be able to confirm the identity of the User. If the User does not respond to our requests, and following reasonable efforts made by The Coop Network Operator it is found that the User cannot be identified, then The Cook Network Operator has no obligation to comply with such a request.
Note: We ask the User to bear in mind that, in order to comply with a request for access to personal data, The Coop Network Operator will take all reasonable steps to verify the identity of the Data Subject/User.
11. Security of personal data
The operator of The Coop Network takes the necessary measures to process the User's personal data, in conditions of security, legitimacy and legality, while also implementing appropriate technical and organizational measures to ensure the integrity and confidentiality of the data, according to art. 25 and 32 of the GDPR Regulation.
In this regard, The Coop Network Operator treats the security of the User's personal data seriously, taking necessary measures to protect and prevent their unauthorized access, modification, disclosure or destruction. This involves internal reviews ( i ) of data collection, retention and processing practices, but also ( ii ) of cyber and physical security measures to protect and prevent unauthorized access to personal data storage systems used by The Coop Network Operator .
The operator of The Coop Network has implemented the following technical and organizational security measures for the User's personal data:
Although The Coop Network Operator makes constant efforts to ensure the security of the data that the User entrusts to us, there may be events / incidents / security breaches. In these cases, The Coop Network Operator will strictly follow the security incident reporting and notification procedure and will take all necessary measures to restore the situation to normal in the shortest possible time.
12. Questions, complaints, complaints
If the User wishes to address to The Coop Network Operator questions, claims, complaints or other aspects related to the processing of his personal data or if he wishes to exercise any of the rights mentioned in the " User Rights " section , the User will have to send a written request, dated and signed at the following e-mail address email@example.com .
To the extent that he does not have electronic means or does not wish to use them, the User can formulate a written request to send to the address of the registered office of The Coop Network , located in Loamneş commune no. 17, Mândra village, Sibiu county, postal code 557124, Romania .
Within no more than 30 (thirty) days, calculated from the date of receipt of the request, The Coop Network Operator will provide the User with a response with information on the actions taken or, where appropriate, on the reasons why they can (not) be taken the requested measures. Also, according to the GDPR Regulation, the mentioned response period can be extended by a maximum of two months in the situation where it is necessary, taking into account the complexity and number of requests, and the Operator of The Coop Network will inform you about this aspect , if applicable.
If the User is not satisfied with the manner in which his request was resolved by The Coop Network Operator , he may submit a complaint to
Note: The Coop Network Operator asks Users to bear in mind that in order to comply with a request for access to personal data, The Coop Network Operator will take all reasonable steps to verify the identity of the Data Subject/User.
13. Legal basis
For even more details, the User can consult the following legal basis: