Last updated: 29.07.2026

Through this Policy, we inform you about how we collect, use, transfer, and protect your personal data. We process this data in accordance with the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 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 (the “General Data Protection Regulation,” hereinafter “GDPR”), as well as the relevant national legislation on personal data protection.

1. Who are we?

Ghencea Residential Project S.R.L., hereinafter the Company or We.

Our contact details are:

• Registered office: Piața Nucetului no. 12, Building A3, Ground Floor, SP COM 2, Office 14, Oradea Municipality, Bihor County, Romania
• E-mail address: dpo@primadevelopment.ro
• Phone no.: 0371.783.004

2. How do we process your personal data?

As Data Controller, the Company processes the personal data of candidates applying for available positions, employees, individual clients, representatives of corporate clients, contractual partners and collaborators, and the data of other individuals who interact with the Company and/or are engaged in contractual relationships with it.

Personal data is:

• processed lawfully, fairly, and transparently in relation to the data subject;
• collected for specified, explicit, and legitimate purposes and not further processed in a manner incompatible with those purposes;
• adequate, relevant, and limited to what is necessary in relation to the purposes for which it is processed;
• accurate and kept up to date;
• kept in a form that permits identification of data subjects for no longer than necessary for the purposes for which the data is processed;
• processed in a manner that ensures appropriate security of personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction, or damage, using appropriate technical or organizational measures.

3. What types of personal data do we process and for what purpose?

In the context of personnel recruitment, we process the following types of personal data: first name, last name, address, date of birth, nationality, gender, phone number, e-mail address, data regarding professional and/or social experience, education and professional training, skills, and other personal data derived from the information contained in the CV and cover letter submitted, and, where applicable, from discussions during the job interview.

For the conclusion and performance of service and partnership/collaboration agreements, we primarily process the following types of personal data: first name, last name, ID card/passport series and number, gender, home/residence address, bank account number, e-mail address, phone number.

For the purpose of completing and submitting the Contact form on the Company’s website — www.prima-astera.ro (hereinafter “the website”) — we process the following types of personal data: first name, last name, e-mail, phone number, and, where applicable, any other data provided at the data subject’s own initiative in the “Message” section.

For website visitors, we may collect data through cookies or similar technologies, such as: IP address, internet browser, location, web pages accessed on our website, time spent on the website, internet network, device used. For more details, please see our Cookie Policy.

We do not use your personal data to send you marketing communications, such as newsletters, unless you give your explicit consent to such communications by checking a consent box. In this case, we only process your e-mail address and ensure that you have a simple option to unsubscribe at any time, or to withdraw your consent regarding receipt of these types of communications.

4. What legal grounds does the processing of personal data rely on?

Your personal data is processed for the purpose of:

• concluding and performing various contracts;
• fulfilling our legal obligations;
• processing based on consent requested and/or given in advance (in the context of personnel recruitment, for sending marketing communications, etc.);
• pursuing the Company’s legitimate interests (e.g., adopting protection and security measures for our employees, exercising the Company’s legitimate rights and interests in contentious or non-contentious proceedings, etc.).

Specifically, in the case of the exchange of contact data in the phase preceding the conclusion of a contract (for example, submitting a request or offer through the Contact form or directly to the Company), the processing is based on Article 6(1) of the GDPR, as follows:

• point (b) — processing is necessary to take steps at the request of the data subject prior to entering into a contract (in the case of a request or offer);
• point (f) — the Company’s legitimate interest in responding to commercial requests, particularly relevant in a B2B context (relations between professionals).

5. For how long do we process your personal data?

Personal data is stored for processing for the period necessary to achieve the processing purposes mentioned in this Policy, or for the period required by law (e.g., for archiving, accounting purposes, etc.).

6. To whom do we disclose personal data?

We will not disclose or transfer any of the personal data collected from you or about you to any third party, except for:

• Public authorities and institutions — where there is a legal obligation to do so or for the purpose of a legitimate interest (defending the Company’s rights in contentious or non-contentious proceedings, etc.);
• The Company’s contractual partners or collaborators who provide us with web hosting, website development and maintenance, online marketing services, etc.;
• Any third party — if you have given your explicit and specific consent for that particular situation and data.

We also disclose personal data when required by law or by a court order, or at the request of a competent authority, to the extent permitted by legal provisions, including for the purpose of a public safety investigation.

Additionally, in the event that the Company (or its business or website) is taken over, sold, or involved in a merger or acquisition, personal data may be disclosed to consultants and potential buyers and may be transferred to the new owners, in compliance with the GDPR.

Where personal data processed by the Company is transferred, directly or through its contractual partners/collaborators, outside the European Economic Area, we ensure that such transfers take place in compliance with the GDPR (in particular Article 46 of the GDPR) and applicable legal provisions, based on appropriate safeguards (standard data protection clauses adopted by the Commission), and subject to the existence of enforceable rights and effective remedies for data subjects.

7. What protection measures and safeguards do we take?

The Company implements appropriate technical and organizational measures to ensure a high level of security and protection of personal data. We use security methods and technologies, together with internal work policies and procedures, including control and audit measures, to protect the personal data collected in accordance with applicable legal provisions relevant to personal data protection.

Third-party sites. This Policy does not apply to third-party sites accessible through links present on our website. We cannot guarantee that these third parties process your personal data correctly and securely, which is why we recommend that you review the privacy policies of these sites before using them.

Changes to this Policy. We reserve the right to modify this Policy. We recommend that you review it periodically to stay informed of any changes; whenever possible, we will actively inform you of such changes.

8. What are your rights as a data subject?

Any data subject may exercise the following rights, as provided by the General Data Protection Regulation:

• Right of access
• Right to rectification
• Right to erasure
• Right to restriction of processing
• Right to data portability
• Right to object to processing
• Right not to be subject to a decision based solely on automated processing, including profiling
• Right to lodge a complaint with the National Supervisory Authority for Personal Data Processing (www.dataprotection.ro) and with the courts

To exercise these rights, or for any questions regarding the processing of your personal data, please contact us at the e-mail address dpo@primadevelopment.ro or by phone at 0365.401.269, contact person: Ionel Orza. Data Protection Officer (DPO) services are outsourced and provided by GDPRComplet.

For the most common requests (access, erasure, portability), you may also use the dedicated data request form available on the website.