Privacy Policy

1. Introduction

Your data privacy matters to us. We take the responsibility of protecting the personal data you provide us very seriously. This privacy policy, which we update from time to time, explains what types of data we collect, for what purposes, how we use and protect this data, and your rights regarding the processing of personal data.

2. Your Data Controller

COMEDY BOX S.R.L (located at Sat Ștefăneștii de Jos, Comuna Ștefăneștii de Jos, Strada Libertății, Nr. 4, Tarla 44, Parcela 337, Bloc M5, Etaj 6, Ap. 602, Ilfov County, registered at the Ilfov Trade Register Office under no. J23/7106/26.10.2023, having the unique identification code 49011215) collects and processes various categories of personal data, which qualifies us as the controller of this personal data under data protection legislation.

3. Legal Context

In accordance with the requirements of 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 (known as “GDPR”), effective from May 25, 2018, we are obliged to manage your personal data safely and only for specified purposes, in compliance with the provisions of GDPR.

For more details on this legal norm, please visit the following link: GDPR Information

4. Data Protection Officer

We have appointed a Data Protection Officer whom you can contact regarding any matter related to the processing of your data, as well as to exercise your legal rights, especially if you have questions or concerns about how we process your personal data. You can contact the data protection officer at: support@comedybox.ro

5. Applicability

This privacy policy applies to all persons affected by the personal data processing activities carried out by COMEDY BOX S.R.L, which can include:

• Visitors and users of the COMEDY BOX S.R.L website: https://www.comedybox.ro/, Contractual partners such as suppliers, vendors, clients, collaborators, guests with whom copyright assignment contracts are concluded ("Commercial Partners");
• Users of COMEDY BOX S.R.L Mobile Applications ("App Users");
• Individuals interested in participating in our productions, including those who register to participate or actually participate in our productions;
• Participants in our programs and productions, including contests, promotions, etc.;
• Candidates for employment within COMEDY BOX S.R.L and/or its employees.

6. Principles of Personal Data Processing

The personal data collected will be:

• Processed in a lawful, fair, and transparent manner in relation to the data subject ("legality, fairness, and transparency");
• Collected for specified, explicit, and legitimate purposes and not further processed in a manner that is incompatible with those purposes ("purpose limitation");
• Adequate, relevant, and limited to what is necessary in relation to the purposes for which they are processed ("data minimization");
• Accurate and, where necessary, kept up to date ("accuracy");
• Kept in a form that permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed ("storage limitation");
• Processed in a way that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction, or damage, using appropriate technical or organizational measures ("integrity and confidentiality").

7. How We Collect and Process Your Personal Information

7.1 Personal information you provide to us:

We may collect, store, and use the following types of personal data:

A. Data collected on COMEDY BOX S.R.L. websites:

• Information about your computer and about your visits and use of this website (including your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views, and website navigation paths);
• Information that you provide to us for the purpose of registering with our website (including your contact information);
• Information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (including your name and email address);
• Information that you provide to us when using our services, or information that is generated in the course of the use of those services (including the timing, frequency, and pattern of service use);
• Information contained in or relating to any communication that you send to us or send through our website (including the communication content and metadata associated with the communication);
• Information that you provide when making a purchase from our website;
• Publications, blogs, interviews, opinions, comments, etc.

B. Data collected in the context of our programs/shows/competitions/promotions/events:

• Personal data that you provide to us when interacting with us, whether by filling out registration or participation forms or communicating with us orally or in writing (e.g., questionnaires filled out before filming or telephone interviews, when you register to use our services, participate in discussion forums, etc.), or disclosed through your voluntary presence in the show, or provided by a third party. The data we process may include: name and surname, address, identity card details, personal numerical code, phone number, email address, personal description, age, date of birth, gender, image, voice, voluntarily provided information about private life, other personal data related to preferences/behavior/personality/opinions, if these are disclosed or result from your performance in the program/competition/show, and other information as applicable.
• Special categories of personal data related to guests, participants, or competitors and/or other persons (e.g., information concerning racial or ethnic origin, political opinions, religious or philosophical beliefs, health, sex life, or sexual orientation), in cases where (i) they are relevant to your participation in the show/program/competition; (ii) we are required to do so by law; (iii) you have expressly consented to this; (iv) the Operator is carrying out a task in the public interest and/or (v) sensitive data have been manifestly made public by the data subject.

C. Professional contacts of legal representatives, contact persons, or employees of partners, clients, service providers, collected by COMEDY BOX S.R.L in the course of its business activity. Specifically, the professional data processed are: name, surname, job title, phone number, email address.

D. Personal data contained in Curriculum Vitae

Submitted by candidates in response to recruitment advertisements by COMEDY BOX S.R.L, as well as data of the Operator's employees, including data relating to name and surname, home/residence address, date and place of birth, marital status, personal numerical code, citizenship, nationality, educational and professional experience, occupational status, email address, phone number, and others, as required by Labor Legislation.

E. Other information

That you provide to us through correspondence with us by phone, email, or any other means, including, where applicable, questionnaires completed prior to filming or telephone interviews, as well as any other personal data you choose to send us.

7.2. What happens if you do not provide your data

Depending on the data and the purposes of collection, you may enjoy this site or part of the services offered by the Operator without providing us your personal data or your consent, or you may enter only the minimum amount of information. However, some personal information is necessary for our site to provide you with the services you have purchased or requested and to authenticate you so that we know it is you and not someone else. You can manage the data you communicate to us and withdraw your consent at any time for commercial communications.

8. Purposes of Your Personal Data

Personal data transmitted through this site and/or collected by other means as per article 7.1 or from public sources will be used for the purposes specified in this Privacy Policy. Depending on the relationships we have or wish to establish with you, we may use your personal data for the following purposes:

• Responding to Inquiries: If you have contacted us through this site or otherwise, we may process your name, contact details, location, and other information you provided to respond to your questions, organize meetings, phone calls, or other communications.
• Media Participation: When an individual registers, requests, or is invited to create video/audio/photo materials, for their appearance in and/or participation in pre-selections, selections, recordings, shows, or promotional campaigns, for broadcasting or publishing photos, video recordings, audio recordings, or audiovisual recordings, and generally for public communication of shows for journalistic, artistic, and/or literary purposes.
• Journalistic Purposes: When the right to free expression, as provided by applicable law, prevails over the right to image or privacy of the individual.
• Contracts and Transactions: When an individual (a) submits forms, documents, or information regarding their interactions and/or transactions with the company; or (b) uses or purchases the company's products; or (c) enters into, executes, and finalizes a contract (including employment or remote contracts) with the company.
• Business Interactions: When an individual interacts with company personnel, including customer relations representatives, guests, or other representatives, for example, by phone, letters, fax, face-to-face meetings, or email, to manage or administer the business relationship with the organization the individual belongs to.
• Requests for Contact: When an individual requests to be contacted by the company, to be included in an email or other mailing lists, or responds to the company’s request for additional personal data.
• Online Interactions: When an individual interacts with the company through online platforms.
• Fraud Prevention: When the company acts to prevent or investigate suspected fraud, illegal activities, omissions, or improper behavior related to the individual's relationship with the company or other persons.
• Advertising Purposes: For communicating with the individual through channels they have approved to keep them informed about the company's or Intact Group's activities by sending newsletters, announcements, and other information regarding the company's or any other Intact Group company's services, products, and technologies, as well as about company or Intact Group events and projects or for customer surveys, marketing campaigns, market analysis, raffles, contests, or other promotional activities or events.
• Compliance with Legal Obligations: When the company complies with or acts in accordance with a request from any competent public authority or institution or responds to information requests from them.
• Reporting and Management: When the company performs fiscal, financial, regulatory, management, risk management (including monitoring exposure to risk), and audit reporting.
• Submission of Personal Data: When an individual submits their personal data or third-party personal data (e.g., information about family members and/or employees) to the company for any reason.
• Legal Compliance and Rights Protection: For complying with court decisions and exercising and/or defending the company’s rights.
• Monitoring and Evaluating Compliance: For monitoring and evaluating compliance with the company's policies and standards.
• Market Research: For market and public opinion research to measure or understand preferred content related to programs and to offer relevant content to you; to allow you to participate in interactive service features when you choose to do so; to measure or understand the effectiveness of the advertising we provide to you and others and to offer relevant advertising.
• Statistical and Audience Profiling: For statistical purposes and audience profiling of Comedy Box S.R.L, as well as profiling information obtained by Comedy Box S.R.L under copyright transfer agreements.
• Ancillary Purposes: For any purpose related to and/or ancillary to the above.

Additionally, if you are a visitor to our site, we may process your IP address, geographic location, browser type and version, operating system, referral source, visit duration, log files, interactions with our website and online campaigns, automatically collected data about you or your device, in accordance with this Privacy Policy, and information you provided via the site form or services purchased (value, date, data sources, notes, and remarks) for conducting marketing research and analyzing visitor characteristics, evaluating the impact of our marketing communications and adjusting them to detected trends, planning future marketing activities, preparing our business analysis, personalizing services and communications for you, targeting advertising, or providing direct marketing of the same or similar products and services.

If you are subscribed to our newsletter, you may receive our marketing materials. We may process the personal data you provided to distribute promotional materials, make announcements about additions and changes to our services, personalize this site and our marketing communication for you, send email notifications (e.g., about our offers), newsletters, and our email magazines (you can inform us at any time if you are no longer interested in these materials), or send marketing communications related to our activities that we believe may be of interest to you.

9. Legal Grounds for Data Processing

1. Contract Performance (Article 6(1)(b) of GDPR)
2. Personal data of employees, clients, potential clients, suppliers, collaborators under copyright transfer agreements, partners, and others can be processed to conclude, execute, and finalize a contract. Processing is necessary:
   • For a contract that the individual has entered into in their name; or
   • Because the individual has taken steps before entering into a contract.
3. Consent (Article 6(1)(a) of GDPR)
   • For processing special personal data, profiling, participating in market analysis/surveys, communicating with the individual for marketing purposes, and/or sending invitations to other future shows/programs.
4. Legal Compliance (Article 6(1)(c) of GDPR)
   • When we must comply with a legal obligation provided either by applicable audiovisual laws or specific to labor relations, accounting, auditing, copyright, and other relevant laws in the Operator’s activity.
5. Public Interest (Article 6(1)(e) of GDPR) and Publicly Available Data (Article 9(2)(e) of GDPR)
   • For certain processing carried out for journalistic purposes, the Operator may base processing on fulfilling a task serving the public interest and/or processing relates to personal data manifestly made public by the individual.
6. Legitimate Interest (Article 6(1)(f) of GDPR)
   • The legitimate interest of Comedy Box S.R.L in connection with media production and distribution, including:
     • Preselection and selection of candidates/participants for Comedy Box S.R.L shows;
     • Verification of information provided by candidates/participants regarding their capacity to participate in a program/contest/show;
     • Protecting the vital interests of participants in contests/shows/programs and providing appropriate protective measures;
     • Offering direct access for participation in shows/programs;
     • Developing and distributing audiovisual programs;
     • Providing information, news, materials, and shows of an informative or public debate nature, for journalistic, artistic, and/or entertainment activities;
     • Resolving complaints received by Comedy Box S.R.L regarding participation in various shows/programs;
     • Keeping all audio-video materials/programs and personal data contained therein in the Comedy Box S.R.L archive for rebroadcasting or other commercial purposes.

In all cases where processing is carried out based on our legitimate interest in providing services arising from our specific field of activity, the Operator will analyze whether the right to free expression, as provided by current legislation, prevails over the right to image or private life, and if not, will cease processing that infringes on these rights.

10. Categories of Recipients of Collected Personal Data

We do not disclose the personal data we collect about you, except as described in this Policy or in separate notifications provided in connection with certain activities. We may share your personal data under the following circumstances and to the following recipients:

• Comedy Box S.R.L Personnel (employees, collaborators);
• Third Parties (processors, joint controllers, independent controllers under Regulation (EU) 2016/679), whom the Operator engages for business reasons, often specialized, professional services that can manage the volumes and technologies necessary for Comedy Box S.R.L to conduct its activities (e.g., service providers offering administrative, professional, and technical support, business partners, agents, production companies, co-producers, advertising agencies, analysis service providers, subcontractors);
• Government Authorities or Law Enforcement if required by law, such as the National Agency for Fiscal Administration, the National Audiovisual Council, the Territorial Labor Inspectorate, the Health Insurance House, and the Pension House, for submitting various requests and forms, as well as other authorities to fulfill other legal obligations;
• Courts, Regulatory Authorities, Lawyers, or Other Persons if it is reasonably necessary to establish, exercise, or defend a right in court or a natural right, or for an alternative, confidential dispute resolution process.

Except as detailed above, we will not disclose, sell, or rent any of your personal data to any third party without notifying you or, if applicable, obtaining your prior consent.

11. Transfer of Personal Data

The information we collect from you will be processed within the European Economic Area (EEA) and may also be transferred outside the EEA, depending on the purpose of the processing. COMEDY BOX S.R.L will apply appropriate safeguards to protect the confidentiality and security of your personal data during the transfer and will use it only in accordance with your relationship with COMEDY BOX S.R.L and the practices described in this Privacy Policy. Any data transfer will be carried out in compliance with the security requirements applicable to processing within the European Community, which includes adhering to EU standards for personal data processing, thereby ensuring compliance with the objectives set out in personal data protection legislation.l Economic European si pot ajunge și în afara Spațiului Economic European, în funcție de scopul prelucrării. COMEDY BOX S.R.L va aplica garanții adecvate pentru a proteja confidențialitatea și securitatea datelor dvs. personale în timpul transferului și pentru a le utiliza numai în conformitate cu relația dvs. cu COMEDY BOX S.R.L și cu practicile descrise în această Politică de confidentialitate. Orice transfer de date se va efectua cu respectarea cerințelor de securitate la care sunt supuse procesările din cadrul Comunității Europene, a căror componență o reprezintă respectarea standardelor UE privind prelucrarea datelor personale, asigurând astfel îndeplinirea dezideratelor prevăzute de legislația în materie de protecție a datelor cu caracter personal.

12. Your Rights

The GDPR provides certain rights to data subjects, as follows:

1. Right to Information and Access: , You can request confirmation from the controller as to whether or not personal data concerning you is being processed, and if so, access to that data and information on how it is processed
2. Right to Data Intervention: , This means you can obtain, upon request and free of charge, the rectification, updating, blocking, restriction, or deletion of data whose processing is not in accordance with the law, particularly of inaccurate data, data that is no longer necessary for the purposes for which it was collected, or when you withdraw consent based on which the processing is carried out.
3. Dreptul la rectificarea (corectarea) datelor dvs. personale prelucrate de noi dacă acestea sunt inexacte sau nu mai corespund realității.
4. Right to Rectification: You have the right to correct your personal data processed by us if it is inaccurate or no longer reflects reality.
5. Right to Erasure ("Right to be Forgotten"): You can request the deletion of your data under certain circumstances, such as: (i) the personal data is no longer necessary for the purposes for which it was collected or processed; (ii) your data was processed unlawfully; (iii) the processing was based on your consent, which you have withdrawn.
6. Right to Restriction of Processing: You can request the cessation of data processing under certain circumstances, such as: (i) you contest the accuracy of the data for a period allowing us to verify its accuracy; and (ii) your data has been processed unlawfully, and you oppose its deletion, requesting restriction of its use instead.
7. Right to Data Portability: When technically feasible, we will provide your personal data at your request or transfer it directly to another controller. If access cannot be provided within a reasonable time, we will provide a date when the information will be transmitted.
8. Right to Object: You have the right to object to the processing of your personal data for legitimate and justified reasons related to your particular situation. You also have the right to object at any time, free of charge and without any justification, to the processing of your data for commercial or direct marketing purposes by the Controller.
9. Other Rights Guaranteed by Legal Provisions:
   • The right not to be subjected to a decision based solely on automated processing, including profiling;
   • The right to address the court to defend any rights guaranteed by law;
   • The right to be notified by the Controller of security breaches that have or could have an impact on the data subjects.

To exercise the aforementioned rights, data subjects should send a written, signed, and dated request electronically to the Data Protection Officer at support@comedybox.ro. The data subject will receive a response as soon as possible, but no later than one month from the receipt of the request. In addition to the aforementioned rights, data subjects may file a complaint against the way data is processed directly with COMEDY BOX S.R.L, specifying the request, reason for dissatisfaction, and/or the rights they believe have been violated. They may also file a complaint with the National Supervisory Authority for Personal Data Processing (www.dataprotection.ro) no sooner than 30 days after submitting a complaint to the Operator. Contact details for the National Supervisory Authority for Personal Data Processing are:

National Supervisory Authority for Personal Data Processing

Address: Bucharest, General Gheorghe Magheru Blvd. No. 28-30, Sector 1, Postal Code 010336

Website: https://www.dataprotection.ro

Adresa de e-mail: anspdcp@dataprotection.ro

Telefon: +40.318.059.211; +40.318.059.212

Fax: +40.318.059.602

13. Retention of Personal Data

Your personal data is stored by COMEDY BOX S.R.L on its servers. Your personal data will be deleted or removed when it is no longer necessary for the purposes for which it was collected or when you request its deletion by exercising your right to be forgotten and COMEDY BOX S.R.L no longer has a legal obligation to continue storing the data. Notwithstanding the other provisions of this section, we will retain information and documents (including electronic documents) containing personal data:

• As required by law;
• If the information/documents are relevant to any ongoing or potential legal proceedings; and
• To establish, exercise, or defend our legal rights (including providing information to others for the purpose of preventing fraud).

14. Processing of Minors' Data

COMEDY BOX S.R.L places great importance on protecting minors' personal data. Data of minors under the age of 16 will not be processed without prior consent obtained from parents or legal representatives. COMEDY BOX S.R.L reserves the right to take reasonable measures to verify whether the person has reached the minimum age required to express their own consent or to verify that the person giving consent on behalf of the minor holds parental responsibility.

15. Security of Personal Data

To protect the confidentiality of your data and the information you transmit through this website, we maintain physical, technical, and administrative safeguards. We continuously update and test our security technology. We restrict access to your personal data to employees who need to know that information to provide benefits or services to you. Additionally, we train our employees on the importance of confidentiality and maintaining the confidentiality and security of your information.

If a personal data breach occurs, we will take all necessary steps to eliminate it and assess the risk level associated with the breach in accordance with our personal data breach policy. If the breach is likely to result in physical, material, or non-material harm to you (e.g., discrimination, identity theft, fraud, or financial loss), we will contact you without undue delay, unless otherwise provided by law. All our actions will be taken in full cooperation with the competent Supervisory Authority.

16. Changes to the Privacy Policy

We may update this information document from time to time by publishing a new version on this website. Considering that personal data protection laws, interpretations by state bodies, and recommendations by supervisory authorities change and improve from time to time, this privacy notice and terms of use may also change. We reserve the right to modify this information document at any time, for any reason, and without notice. Any changes to our privacy policy will be posted on this page so that you are always aware of our policies. The provisions contained in this document replace all previous announcements or statements regarding our privacy practices and the terms and conditions governing the use of this website.

17. Third-Party Websites

This site may include hyperlinks and details about third-party websites. We have no control over and are not responsible for the privacy policies and practices of third parties.

18. Site Security

We cannot guarantee that data transmissions over the Internet can be 100% secure. Consequently, we cannot ensure or guarantee the security of information you transmit, and you understand that any information you transfer to COMEDY BOX S.R.L is done at your own risk. However, the Operator uses site security measures in accordance with best practices to protect the website, emails, and mailing lists. These measures include technical, procedural, monitoring, and tracking measures intended to protect data from misuse, unauthorized access or disclosure, loss, alteration, or destruction.

We are aware that incidents of misuse or unauthorized program intrusions may occur, which is a possibility for almost every website. In such situations, our objectives are to act quickly to isolate the issue, ensure or restore proper functionality, and minimize user inconvenience. If necessary, COMEDY BOX S.R.L will notify the relevant authorities about these misuse or unauthorized intrusion incidents on its sites.

19. Questions, Concerns, Complaints

If you have questions regarding your personal information or if you wish to exercise your rights or have concerns or complaints, please contact us by sending an email to the Data Protection Officer at support@comedybox.ro

You can also send a written request to the company's registered office address.

To update or correct your personal data, please contact the Data Protection Officer at support@comedybox.ro