GDPR Compliance

Account, Billing, and Usage Data

• Name, job title, email address, phone number
• Company name, tax identification number, registered address, billing data
• Authentication data: encrypted password, kiosk PIN codes
• IP address, access and system logs, device and browser type

Employee Data (processed by e-HR as processor)

• Identification data: name, national ID number (CNP), identity document details, address, contact details
• Employment contract details, job title, department, and organizational structure
• Attendance and time-tracking data, including records made via the kiosk terminal with PIN code and IP address
• Leave data (annual, medical, and other leave types) and related requests
• Payroll data: salary calculation elements, contributions, deductions, payslips
• HR documents: contracts, addenda, certificates, medical leave certificates

Special Categories of Data and National Identifiers

• National ID number (CNP) — a national identifier subject to additional safeguards under Law No. 190/2018
• Health data contained in medical leave certificates, processed by the Client Company for payroll and legal reporting purposes, and by e-HR strictly as processor

We process personal data for the following purposes, based on the corresponding legal grounds under Article 6 GDPR:

• Creating and managing the account and providing the Service — performance of a contract [Art. 6(1)(b)];
• Providing time-tracking, leave, payroll, and document features to the Client Company, as processor — based on the Company's instructions and the service agreement [Art. 6(1)(b), Art. 28];
• Processing payments, issuing invoices, and maintaining accounting records — performance of a contract and legal tax/accounting obligations [Art. 6(1)(b) and (c)];
• Transactional and security communications — performance of a contract and the legitimate interest of ensuring the Platform functions properly [Art. 6(1)(b) and (f)];
• Marketing communications — consent, which may be withdrawn at any time [Art. 6(1)(a)];
• Improving the Platform and statistical analysis — e-HR's legitimate interest, assessed so as not to override data subjects' rights [Art. 6(1)(f)];
• Ensuring Platform security and preventing fraud — the legitimate interest of e-HR and its Clients [Art. 6(1)(f)];
• Complying with legal obligations (labor registry reporting, tax obligations, archiving, requests from authorities) — legal obligation [Art. 6(1)(c)];
• Resolving disputes and defending rights — e-HR's legitimate interest [Art. 6(1)(f)].

Right of Access (Art. 15)

The right to obtain confirmation that we process your data and a copy of it, together with information about the purposes, categories of data, recipients, and retention period.

Right to Rectification (Art. 16)

The right to request correction of inaccurate data or completion of incomplete data.

Right to Erasure (Art. 17)

The right to request deletion of your data, for example when it is no longer necessary for the purposes for which it was collected or you withdraw consent, subject to applicable legal retention obligations.

Right to Restriction of Processing (Art. 18)

The right to request that we limit the processing of your data in certain situations, for example while the accuracy of the data is being verified.

Right to Data Portability (Art. 20)

The right to receive the data you provided in a structured, commonly used, machine-readable format, and to transmit it to another controller.

Right to Object (Art. 21)

The right to object to processing based on e-HR's legitimate interest, as well as to processing for direct marketing purposes, at any time.

Right to Withdraw Consent (Art. 7)

Where processing is based on consent, you have the right to withdraw it at any time, without affecting the lawfulness of processing carried out before the withdrawal.

Right Not to Be Subject to Automated Decision-Making (Art. 22)

e-HR does not use automated decision-making processes or profiling that produce legal effects concerning you or similarly significantly affect you, without human intervention.

Right to Lodge a Complaint

The right to lodge a complaint with the National Supervisory Authority for Personal Data Processing (ANSPDCP) or with the competent courts, as described in Section 20.

We work with the following categories of sub-processors/recipients, contractually bound to security and confidentiality safeguards:

• Stripe — payment processing and subscription billing;
• Cloud infrastructure providers (for example Amazon Web Services/S3) — hosting and storage of data and documents;
• Email and notification service providers — transactional communications;
• Platform monitoring, maintenance, and technical support providers.

Certain categories of data are subject to minimum retention periods required by Romanian law, regardless of account status, including:

• Accounting records and payslips — under Accounting Law No. 82/1991 and the Fiscal Code;
• The general employee registry (REVISAL) and related employment documents — under the Labor Code and Government Decision No. 905/2017;
• Documents related to medical leave and related indemnities — under health and social security legislation;
• Data necessary to defend legal rights, for the duration of applicable limitation periods.

Technical Measures

• Encryption of data in transit (TLS/HTTPS) and, where applicable, at rest
• Role-based access control and the principle of least privilege
• Logical isolation of each Client Company's data (multi-tenant architecture)
• Periodic backups and disaster recovery procedures
• Continuous monitoring of activity and security incidents
• Hosting through recognized cloud infrastructure providers with their own security certifications

Organizational Measures

• Internal data protection and security policies and procedures
• Access to Employee Data limited on a need-to-know and role basis
• Confidentiality agreements with staff and sub-processors
• Periodic risk assessments and, where applicable, data protection impact assessments
• Documented security incident response procedures