Privacy Policy
INTRODUCTION
This Privacy Policy explains what we do with your personal data. It describes how we collect, use and process your personal data, and how, in doing so, we comply with our legal obligations to you. Your privacy is important to us, and we are committed to protecting and safeguarding your data privacy rights.
This Privacy Policy applies to the personal data of our contributors; contractors, agency and temporary workers; customers and clients; advisors and consultants; potential recruits, job applicants and candidates; suppliers; complainants, respondents and enquirers; and website users. It also applies to the emergency contacts of our staff. This policy does not apply to employees of Bad Bella Productions, LLC. If you are an employee you should refer to the Staff Privacy Policy.
For the purpose of applicable data protection legislation (including but not limited to the General Data Protection Regulation (Regulation (EU) 2016/679) (the GDPR), the company responsible for your personal data (“Bad Bella Productions, LLC” or “us”) can be found below.
It is important to point out that we may amend this Privacy Policy from time to time. Please visit this page if you want to stay up to date, as we will post any changes here.
You have certain legal rights in relation to the matters dealt with in this Privacy Policy and so, where relevant, we have described these as well.
This Privacy Policy applies in relevant countries throughout our international network. Different countries may approach data privacy in slightly different ways and so we also have some country-specific parts to this Privacy Policy. You can find country-specific terms for your jurisdiction below. This allows us to ensure that we're complying with all applicable data privacy protections, no matter where you are.
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WHAT KIND OF PERSONAL INFORMATION DO WE COLLECT?
The kind of personal data that we collect differs widely depending on the kind of relationship that you have with us.
We collect a wide range of data on contributors (freelance dubbing actors, freelance authors, directors, translators, timecoders, transcribers), contractors, agency and temporary workers. In this context, we collect data to enable us to ensure that our relationships runs smoothly and so that we are each able to comply with our contractual and other duties to each other. For this purpose we collect master data relating to the person (name, age, gender, contact data, staff number) but also data relating to other aspects of the relationship like our payments (e.g. remuneration and bank details), the performance or the professional development of our counterpart (like e.g. CV, education details). We also collect data in order to comply with our duties to third parties such as tax authorities and government agencies (like marital status, immigration status, social security number).
We also collect a wide range of data on potential recruits, job applicants and candidates in order to run our selection and recruitment process and comply with legal requirements in that context. For this purpose, we collect master data relating to the person (name, age, gender, contact data) and in addition mostly data relating to the professional development (like e.g. CV, education details),
By contrast, we collect only very limited data on customers and clients, advisors and consultants as well as suppliers as we only need to hold some data in order to ensure that the relationship to these counterparts runs smoothly. We may also hold extra information that someone in the organisation of our counterpart has chosen to tell us.
On complainants, respondents and enquirers, we only collect the names and contact details and whatever information these persons choose to tell us.
On people whose data we receive from candidates and contractors, agency and temporary workers (such as referees, emergency contacts and dependants) we only collect such data that enables us to support the purpose of their involvement.
CONTRIBUTORS’ DATA (freelance dubbing actors, freelance authors, directors, translators, timecoders, transcribers)
Depending on the relevant circumstances and applicable local laws and requirements, we will collect some or all of the information listed below to enable us to work with contributors and provide services to customers and clients.
(In some jurisdictions we are restricted from processing some of the data outlined below. In such cases, we will not process the data in those jurisdictions.)
o Name and contact details (title, first name, surname, phone number, email address, postal address, country of residence)
o Age (and birthdate, if required for compliance purposes)
o Qualification data and other information from CVs (school, further education and vocational training details and qualifications; and information relating to social interests)
o Sex/gender
o Photograph
o Marital status
o Emergency contacts and details of any dependants
o Criminal background check information
o Trade union membership (if required)
o Social security number (or equivalent in your country) and any other tax-related information
o Referee details
o Immigration status (whether you need a work permit)
o Nationality/citizenship/place of birth
o Start date or availability date
o A copy of your driving licence and/or passport/identity card
o Bank details
o Diversity information including racial or ethnic origin
o Religious affiliation if relevant for tax reasons
o Disability-related information
o Next-of-kin details
o Performance data (e.g. staff assessments and other information that relates to your interaction with colleagues)
o Staff number/other identifier
o Details of any grievance or disciplinary matters, whether brought by or against you or in which you are or have been otherwise involved
o Information regarding communications with and services provided to clients
o Log data on the use of Bad Bella Productions, LLC’s IT systems Some dubbing project contributors may be under 18, in which case Bad Bella Productions, LLC will hold the name and contact details of their parent or guardian
o Extra information that you choose to tell us
o Extra information that your referees choose to tell us about you
o Extra information that our clients may tell us about you, or that we find from other third party sources such as social media, LinkedIn or job sites
o IP address
o The dates, times and frequency with which you access our services, CCTV footage if you attend our premises
If any situation arises where we collect additional data, we will inform you. To the extent that you access our website or click through any links in an email from us, we will also collect certain data from you.
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CONTRACTORS’, AGENCY AND TEMPORARY WORKERS’ DATA
Depending on the relevant circumstances and applicable local laws and requirements, we will collect some or all of the information listed below in order to ensure that our relationship runs smoothly and that we are able to comply with our contractual and other duties to each other, and to our clients and customers, and our duties to third parties such as tax authorities and government agencies.
(In some jurisdictions, we are restricted from processing some of the data outlined below. In such cases, we will not process the data in those jurisdictions.)
o Name and contact details (title, first name, surname, phone number, email address, postal address, country of residence)
o Age (and birthdate, if required for compliance purposes)
o Qualification data and other information from CVs (school, further education and vocational training details and qualifications; and information relating to social interests)
o Sex/gender
o Photograph
o Marital status
o Emergency contacts and details of any dependants
o Criminal background check information
o Trade union membership (if required)
o Social security number (or equivalent in your country) and any other tax-related information
o Referee details
o Immigration status (whether you need a work or residence permit)
o Nationality/citizenship/place of birth
o Start date or availability date
o A copy of your driving licence and/or passport/identity card
o Bank details
o Financial information (where we need to carry out financial background checks as far as relevant for the position of the contractor or worker)
o Details of any sickness absence during the relationship including health related information if relevant for workplace safety or re-integration management
o Diversity information including racial or ethnic origin,
o Disability-related information
o Religious affiliation if relevant for tax reasons
o Next-of-kin details
o Performance data (e.g. staff assessments and other information that relates to your employment, your interaction with colleagues and employment-related issues that arise)
o Information regarding communications with and services provided to clients
o Log data on the use of Bad Bella Productions, LLC’s IT systems
o Staff number/other identifier
o Details of any grievance or disciplinary matters, whether brought by or against you or in which you are or have been otherwise involved
o Details of any leave you take or request, or sickness absence including health-related information
If any situation arises where we collect additional data, we will inform you.A number of elements of the items listed above are required to enable us to fulfil our contractual duties to you or to others. Some, for example your social security number (or equivalent) are required by statute or other laws. Other items may simply be needed to ensure that our relationship can run smoothly, or to run our business.
Depending on the type of personal data in question and the grounds on which we may be processing it, should you decline to provide us with such data, we may not be able to fulfil our contractual requirements or, in extreme cases, may not be able to continue with our relationship.
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CUSTOMER AND CLIENT DATA
This category covers our customers, clients and others to whom Bad Bella Productions, LLC provides services in the course of its business or whom Bad Bella Productions, LLC reasonably considers would be interested in our services.
The data we collect about customers and clients is actually very limited. We generally only need to have your contact details or the details of individual contacts at your organisation (such as their names, telephone numbers and postal and email addresses) to enable us to ensure that we can provide our services to you and ensure our relationship runs smoothly.
We may also hold extra information that someone in your organisation has chosen to tell us.
To the extent that you access our website or click through any links in an email from us, we will also collect certain data from you.
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ADVISORS’ AND CONSULTANTS’ DATA
We don’t collect much data about advisors and consultants – we simply need to make sure that our relationship runs smoothly. We'll collect the details for our contacts within your organisation, such as names, telephone numbers and postal and email addresses. We'll also collect bank details, so that we can pay you. We may also hold extra information that someone in your organisation has chosen to tell us.
To the extent that you access our website or click through any links in an email from us, we will also collect certain data from you.
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POTENTIAL RECRUITS’, JOB APPLICANTS’ AND CANDIDATES’ DATA
Depending on the relevant circumstances and applicable local laws and requirements, we will collect some or all of the information listed below to communicate with you in the context of recruitment. (In some jurisdictions we are restricted from processing some of the data outlined below. In such cases, we will not process the data in those jurisdictions.)
o Name and contact details (title, first name, surname, phone number, email address, postal address, country of residence)
o Age (and birthdate, if required for compliance purposes)
o Qualification data and other information from CVs (school, further education and vocational training details and qualifications; and information relating to social interests)
o Sex/gender
o Photograph
o Marital status
o Criminal background check information
o Trade union membership (if required)
o Social security number (or equivalent in your country)
o Referee details
o Immigration status (whether you need a work or residence permit)
o Nationality/citizenship/place of birth
o Start date or availability date
o A copy of your driving licence and/or passport/identity card
o Bank details
o Financial information (where we need to carry out financial background checks as far as relevant for the position of the applicant)
o Diversity information (racial or ethnic origin
o Disability-related information
o Details about remuneration and benefits arrangements at a previous employer
We may also collect other information about you, for example, where we have found you by searching LinkedIn or other job sites, we might collect information such as your employment history, education, qualifications, skills and interests, as well as any extra information which you have included on a profile or in a CV which you have uploaded to one of these sites.
To the extent that you access our website or click through any links in an email from us, we will also collect certain data from you.
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SUPPLIER DATA
We don't collect much data about suppliers – we simply need to make sure that our relationship runs smoothly. We'll collect the details for our contacts within your organisation, such as names, telephone numbers and postal and email addresses. We'll also collect bank details, so that we can pay you. We may also hold extra information that someone in your organisation has chosen to tell us.
To the extent that you access our website or click through any links in an email from us, we will also collect certain data from you.
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COMPLAINANTS AND RESPONDENTS; ENQUIRERS
We’ll only collect your name and contact details (title, first name, surname, phone number, email address, postal address) and whatever other information you choose to tell us.
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PEOPLE WHOSE DATA WE RECEIVE FROM CANDIDATES AND CONTRACTORS, AGENCY AND TEMPORARY WORKERS (SUCH AS REFEREES, EMERGENCY CONTACTS AND DEPENDANTS)
All we need from referees is confirmation of what you already know about a prospective member of staff. Emergency contact details give us somebody to call on in an emergency. To ask for a reference, we'll obviously need the referee's contact details (such as name, email address and telephone number). We'll also need these details if a potential recruit has put you down as their emergency contact so that we can contact you in the event of an accident or an emergency.
We will collect your date of birth, contact details and potentially some health information if a contributor who is under 18 has put you down as a dependant. We may also be provided (by inference) with some limited information about your sexual orientation if a contributor or contractor identifies you as a spouse or partner when putting you down as a dependant, next of kin or emergency contact.
The information described above is of course in addition to any personal data we are required by law to process in any given situation.
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HOW DO WE COLLECT YOUR PERSONAL DATA?
We generally obtain personal data direct from individuals via email, post or telephone.
Some information is obtained from other sources like agencies, referees, colleagues, clients, customers, suppliers, tax authorities or other third parties.
To the extent that you access our website or read or click on an email from us, where appropriate and in accordance with any local laws and requirements, we will also collect your data automatically or through you providing it to us.
We collect your data automatically via cookies, in line with cookie settings in your browser. If you are potential recruit, job applicant or candidate we will use data from your use of our websites to enhance other aspects of our communications with or service to you.
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HOW DO WE USE YOUR PERSONAL DATA?
Having obtained data about you, we then use it in a number of ways. The ways we use your personal data depend on the type of relationship we have with you.
In general, we use your personal data in order to perform the contract as far we have a contractual relationship with you (as a contributor, contractor, agency or temporary worker, customer, client, advisor or consultant, supplier). In that context, we use your personal data primarily in order to provide or to receive services, to make or receive payments, to help us establish, exercise or defend against legal claims and perform legal and regulatory obligations.
As far as you are a complainant, responder or enquirer, we use your personal data primarily in order to act on your complaint, response or enquiry, to perform legal and regulatory obligations and to establish, exercise or defend against legal claims.
As far as you are a person whose data we receive form others (such as a referee, emergency contact or dependant) we use your personal data in ways that enable us to support the purpose of your involvement
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WHO DO WE SHARE YOUR PERSONAL DATA WITH?
Where appropriate and in accordance with local laws and requirements, we may share certain of your personal data: within the Bad Bella Productions, LLC which means with group companies and colleagues within Bad Bella Productions, LLC, and for the conduct of business outside theBad Bella Productions, LLC with clients, customers and suppliers as well as for the performance of a contract with tax, audit or other authorities. We may also share your personal data with other recipients like for example third party service providers who perform functions on our behalf, third party outsourced IT and document storage providers or third parties who we have retained to provide services such as reference, qualification and criminal convictions checks.
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HOW DO WE SAFEGUARD YOUR PERSONAL DATA?
We put in place appropriate measures that are designed to prevent unauthorized access to, and misuse of, your personal data. These include measures to deal with any suspected data breach.
If you suspect any misuse or loss of or unauthorised access to your personal data please let us know immediately.
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HOW LONG DO WE KEEP YOUR PERSONAL DATA FOR?
If you are a contributor, customer, client or a supplier we will retain your personal data in order to provide you with services or to receive services from you.
If we engage you as a contractor or agency or temporary worker, we will ordinarily process your data throughout the course of your relationship with us and will then retain it for a period after we have parted ways. The precise length of time will depend on the type of data, our legitimate business needs and other legal or regulatory rules that may require us to retain it for certain minimum periods.
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HOW CAN YOU ACCESS, AMEND OR TAKE BACK THE PERSONAL DATA THAT YOU HAVE GIVEN TO US?
· One of the GDPR's main objectives is to protect and clarify the rights of EU citizens and individuals in the EU with regards to data privacy. This means that you retain various rights in respect of your data, even once you have given it to us. These are described in more detail below.
· To get in touch about these rights, please contact us. We will seek to deal with your request without undue delay, and in any event within one month (subject to any extensions to which we are lawfully entitled). Please note that we will, where necessary, keep a record of your communications to help us resolve any issues which you raise.
· Right to object: this right enables you to object to us processing your personal data where we do so for our legitimate interests. We have explained above where we do this. If your objection relates to us processing your personal data because we deem it necessary for your legitimate interests, we must act on your objection by ceasing the activity in question unless we can show that we have compelling legitimate grounds for processing which overrides your interests or we are processing your data for the establishment, exercise or defence of a legal claim.
· Right to withdraw consent: Where we have obtained your consent to process your personal data for certain activities (for example, in order to use cookies in certain jurisdictions), you may withdraw this consent at any time and we will cease to carry out the particular activity that you previously consented to unless we consider that there is an alternative reason to justify our continued processing of your data for this purpose in which case we will inform you of this condition.
· Data Subject Access Requests (DSAR): You may ask us to confirm what information we hold about you at any time, and request us to modify, update or delete such information. We may ask you to verify your identity and for more information about your request. If we provide you with access to the information we hold about you, we will not charge you for this unless your request is manifestly unfounded or excessive. If you request further copies of this information from us, we may charge you a reasonable administrative cost where legally permissible. Where we are legally permitted to do so, we may refuse your request. If we refuse your request we will always tell you the reasons for doing so.
· Please note that in certain of the jurisdictions in which we operate, we comply with additional local law requirements regarding data subject access requests and may refuse your request in accordance with such laws.
· Right to erasure: You have the right to request that we erase your personal data in certain circumstances. Normally, the information must meet one of the following criteria:
o the data are no longer necessary for the purpose for which we originally collected and/or processed them;
o where previously given, you have withdrawn your consent to us processing your data, and there is no other valid reason for us to continue processing;
o the data has been processed unlawfully (i.e. in a manner which does not comply with the GDPR);
o it is necessary for the data to be erased in order for us to comply with our legal obligations as a data controller; or
o if we process the data because we believe it necessary to do so for our legitimate interests, you object to the processing and we are unable to demonstrate overriding legitimate grounds for our continued processing.
· Please note that in certain of the jurisdictions in which we operate, we comply with additional local law requirements regarding data subject right to erasure and may refuse your request in accordance with local laws.
· We would only be entitled to refuse to comply with your request for one of the following reasons:
o to exercise the right of freedom of expression and information; or
o to exercise or defend a legal claim.
· When complying with a valid request for the erasure of data we will delete the relevant data.
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WHO IS RESPONSIBLE FOR PROCESSING YOUR PERSONAL DATA
You can find on our site which Bad Bella Productions, LLC entity is responsible for processing your personal data and where it is located
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HOW DO WE STORE AND TRANSFER YOUR DATA INTERNATIONALLY?
In order to carry out the purposes described in this Privacy Policy, your data will be transferred:
To ensure that your personal information receives an adequate level of protection, we have put in place appropriate procedures with the third parties we share your personal data with to ensure that your personal information is treated by those third parties in a way that is consistent with and which respects the law on data protection.
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OUR LEGAL BASES FOR PROCESSING YOUR DATA
Under the GDPR, we can process your data where it is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by your interests or fundamental rights or freedoms which require protection of personal data.
For contributors, customers and clients, and suppliers, we will also process personal data because it is necessary for the performance of a contract with you (or in order to take steps at your request before to entering into a contract).
We also have other legal obligations that we need to comply with and the GDPR states that we can process your personal data where this processing is necessary for compliance with a legal obligation to which we are subject.
Sometimes it will be necessary for us to process personal data and, where appropriate and in accordance with local laws and requirements, sensitive personal data in connection with exercising or defending legal claims. The GDPR allows this where the processing is necessary for the establishment, exercise or defence of legal claims or whenever courts are acting in their judicial capacity.
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ANNEX 2 – HOW TO CONTACT YOUR LOCAL SUPERVISORY AUTHORITY
Details of your local supervisory authority
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Belgium
Data Protection Authority Rue de la Presse - Drukpersstraat 35 1000 Brussels Belgium Telephone: +32 (0)2/274.48.00 Email: commision@privacy commission.be Website: www.gegevensbeschermingsautoriteit.be/ (Dutch) www.autoriteprotectiondonnees.be/ (French) www.dataprotectionauthority.be/ (English)
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Bulgaria
Peronal Data Protection Commission 15 Acad. Ivan EvstatieV Geshov Blvd., Sofia 1431, Bulgaria Telephone: +359 2 91 53 515 Email: kzld@government.bg Website: www.cdpd.bg
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Denmark
Datatilsynet (The Data Protection Agency) Borgergrade 28, 5 DK-1300 Copenhagen K Telephone: +45 33 19 32 00 Email: dt@datatilsynet.dk Website: www.datatilsynet.dk
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Finland
The Data Protection Obmudsman (Teitosuojavaltuutettu) The Office of the Data Protection Ombudsman Ratapihantie 9 00520 Helsinki Finland Telephone: +358 29 56 66700 Email: tietosuoja@om.fi Website: www.tietosuoja.fi
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France
Commission Nationale de L'informatique et des Libertés (CNIL) 3 Place de Fontenoy TSA 80715 75334 Paris CEDEX 07 Telephone: 01 53 73 22 22 Website : www.cnil.fr
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Germany
Berliner Beauftragte für Datenschutz und InformationsfreiheitMaja Smoltczyk Friedrichstraße 219 10969 Berlin Telefon: 030/138 89-0 Telefax: 030/215 50 50 E-Mail: mailbox@datenschutz-berlin.de
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Hong Kong
Privacy Commissioner for Personal Data 12/F 248 Queen’s Road East Wanchai Hong Kong Telephone: +852 2827 2827 Email: enquiry@pcpd.org.hk
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Hungary
President of the NAIH 22c Szilágyi Erzsébet fasor Budapest H-1125 Hungary Telephone: +36 (1) 391-1400 Email: ugyfelszolgalat@naih.hu Website: www.haih.hu
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Italy
Garante per la protezione dei dati personali Piazza di Monte Citorio n. 121 00186 Rome Italy Telephone: +39 06.69677.2917 Email: garante@gpdp.it Certified email: protocollo@pec.gpdp.it Website: www.garanteprivacy.it
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Korea
Personal Information Protection Commission 4th Floor Government Complex (03171) 209 Sejong-daero, Jongno-gu Seou
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Malaysia
Personal Data Protection Commissioner www.pdp.gov
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Netherlands
College Bescherming Persoonsgegevens (Data Protection Commission) Juliana van Stolberglaan 4–10 2595 AJ Den Haag PO Box 93374 2595 CL Den Haag The Netherlands Telephone: +31 70 888 8500 Email: info@cbpweb.nl Website: www.cpbweb.nl
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Norway
The Data Inspectorate PO Box 8177 Dep N-0034 Oslo Norway (mail) Tollbugt 3 Oslo Norway (visitors) Telephone: +47 22 39 69 00 Email: postkasse@datatilsynet.no Website: www.datatilsynet.no
Poland
Prezes Urzędu Ochrony Danych Osobowych ul. Stawki 2,00-193 Warsaw Telephone: +48 22 531 03 00 Email: kancelaria@giodo.gov.pl
Romania
The National Supervisory Authority for Personal Data Processing Bucharest, Romania, 28-30 G-ral Gheorghe Magheru Bld., District 1, post code 010336 E-mail: anspdcp@dataprotection.ro Telephone: +40.318.059.211
Singapore
Personal Data Protection Commission 10 Pasir Panjang Road #03-01 Mapletree Business City Singapore 117438 Telephone: +65 6377 3131 Email: qsm@imda.gov.sg Website: www.pdpc.gov.sg
UK
The Information Commissioner's Office Wycliffe House Water Lane Wilmslow Cheshire SK9 5AF Telehone: 0303 123 1113 Email: casework@ico.org.uk Website: www.ico.gov.uk
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In addition to the information specified above, in Romania we also collect CNP (assigned at birth), CI / BI series and number (identification card for all citizens), photograph, copy of CI, birth certificate of the child (if applicable, e.g. to identify child voice actors where the contract is made with parent or guardian). Where contributors are under 18, statements are obtained from a parent or guardian as to their legal responsibility, social health insurance, maintenance arrangements etc. (if applicable). Personal data is transmitted to ANAF (National Agency for Fiscal Administration); Revisal Labor Inspectorate; banks at each payment, in accordance with local law.