Ensuring the right to personal data protection is a fundamental commitment of our company, and we will make every effort to process your data in full compliance with Regulation (EU) 2016/679 (“General Data Protection Regulation” or “GDPR”), as well as with any other applicable legal provisions in Romania.

This document explains how we collect, use, transfer, and protect your personal data when you interact with us regarding our products and services, including through our website or via mobile applications.

We reserve the right to periodically update and modify this Privacy Policy to reflect any changes in how we process your personal data or any changes in legal requirements. In the event of any such changes, we will post the updated version of the Privacy Policy on our website, so please check it periodically.

Who We Are and How to Contact Us

We are always open to hearing your feedback and providing any additional information you may need regarding the processing of your data. If you wish, you may contact the Data Protection Officer at the contact email address with the subject line: “To the attention of the Data Protection Officer.”

What categories of personal data do we process

We collect your personal data directly from you, so you have control over the type of information you provide to us. For example, we receive information from you as follows:

When you contact us by sending a message through our website, you provide us with: your email address, first name, and last name.

We may also collect and subsequently process certain information regarding your behavior while visiting our website to personalize your online experience and provide you with content tailored to your profile. We invite you to learn more about this by consulting the section on processing purposes below.

On our website, we may store and collect information in cookies and similar technologies, in accordance with our Cookie Policy.

We do not collect or otherwise process sensitive data, as defined by the General Data Protection Regulation as special categories of personal data. Furthermore, we do not intend to collect or process data from minors under the age of 16.

What are the purposes and legal bases for processing your data

We will use your personal data for the following purposes:

1. To provide services for your benefit.

This general purpose may include, as applicable, the following:

• Processing requests, including receiving, validating, and billing them;
• Resolving cancellations or issues of any kind related to a request, or to the goods or services requested;
• Refunding the cost of services in accordance with legal provisions;
• Providing support services, including answering your questions about our services.

Processing your data for these purposes is, in most cases, necessary for the conclusion and performance of a contract between us and you. Additionally, certain processing activities related to these purposes are required by applicable law, including tax and accounting laws.

2. To improve our services

We are constantly striving to provide you with the best possible experience when interacting with our website. To do this, we may collect and use certain information related to your behavior as a user, invite you to complete satisfaction surveys after the provision of certain services, or conduct, directly or with the help of partners, market studies and research.

We base these activities on our legitimate interest in conducting business, always ensuring that your fundamental rights and freedoms are not compromised.

3. For marketing

We want to keep you informed about the best offers for the products/services that interest you. To this end, we may send you any type of message (such as: email, SMS, mobile push, web push, etc.) containing general information, information regarding products and/or services similar to or complementary to those you have purchased or requested, information regarding offers or promotions, information regarding services you have shown interest in purchasing, as well as other commercial communications such as market research and opinion polls, and we may display personalized recommendations. To provide you with information of interest to you, we may use certain data regarding your purchasing behavior (e.g., services viewed/purchased) to create a profile for you. We always ensure that this processing is carried out in a manner that respects your rights and freedoms, and that decisions made based on it do not have legal effects on you or similarly affect you to a significant extent.

In most cases, we base our marketing communications on your prior consent. You may change your mind and withdraw your consent at any time by:

• Clicking the unsubscribe link included in the messages you receive from us; or by
• Contacting the company using the contact details described above.

In certain situations, we may base our marketing activities on our legitimate interest in promoting and developing our business. Whenever we use information about you for a legitimate interest of ours, we take care to ensure that your fundamental rights and freedoms are not compromised. However, you may request at any time, through the means described above, that we stop processing your personal data for marketing purposes, and we will comply with your request.

4. To protect our legitimate interests

There may be situations in which we use or share information to protect our rights and business operations. These may include:

• Measures to protect the website and platform users from cyberattacks;
• Measures to prevent and detect fraud attempts, including the transmission of information to the relevant public authorities;
• Measures to manage various other risks.

The general basis for these types of processing is our legitimate interest in protecting our business operations, with the understanding that we ensure all measures we take strike a balance between our interests and your fundamental rights and freedoms.

Furthermore, in certain cases, we base our processing on legal provisions such as the obligation to ensure the security of goods and valuables as provided by applicable legislation in this area.

How long we retain personal data

As a general rule, we will store your personal data for a period of five years.
You may request at any time that we delete certain information or close your account, and we will comply with such requests, subject to the retention of certain information, including after account closure, in situations where applicable law or our legitimate interests require it.

To Whom We Disclose Your Personal Data

As appropriate, we may share or provide access to certain personal data about you with the following categories of recipients:

• companies within the same group of companies;
• courier service providers;
• payment/banking service providers;
• marketing/telemarketing service providers;
• market research service providers;
• insurance companies;
• IT service providers;
• other companies with which we may develop joint programs to market our goods and services.

If we have a legal obligation to do so, or if it is necessary to protect a legitimate interest, we may also disclose certain personal data to public authorities.

We ensure that access to your data by third-party private legal entities is carried out in accordance with legal provisions regarding data protection and information confidentiality, based on contracts concluded with them.

To which countries do we transfer your personal data

Currently, we store and process your personal data within Romania. However, we may transfer certain personal data to entities located within the European Union or outside the Union, including to countries that the European Commission has not recognized as having an adequate level of personal data protection.

We will always take steps to ensure that any international transfer of personal data is carefully managed to protect your rights and interests. Transfers to service providers and other third parties will always be protected by contractual commitments and, where appropriate, by other safeguards, such as standard contractual clauses issued by the European Commission or certification schemes, such as the Privacy Shield for the protection of personal data transferred from within the EU to the United States.

You can contact us at any time using the contact details provided above to learn more about the countries to which we transfer your data, as well as the safeguards we have implemented regarding these transfers.

How We Protect the Security of Personal Data

We are committed to ensuring the security of personal data by implementing appropriate technical and organizational measures in accordance with industry standards.

Personal data is transmitted using state-of-the-art encryption algorithms and stored on secure servers, while ensuring data redundancy.

Despite the measures taken to protect your personal data, we must draw your attention to the fact that transmitting information over the Internet, in general, or through other public networks, is not completely secure, as there is a risk that data may be viewed and used by unauthorized third parties. Consequently, we cannot be held responsible for such vulnerabilities in systems that are not under our control.

What rights do you have

The General Data Protection Regulation grants you a number of rights regarding your personal data. You may request access to your data, the correction of any errors in our records, and/or object to the processing of your personal data. You may also exercise your right to file a complaint with the competent supervisory authority or to seek judicial remedy. Where applicable, you may also have the right to request the erasure of your personal data, the right to restrict the processing of your data, and the right to data portability.

More information about each of these rights can be found in the table below.

To exercise your rights, you may contact us using the contact details provided above. Please note the following if you wish to exercise these rights:

Identity. We take the confidentiality of all records containing personal data seriously. For this reason, please submit your requests regarding such records using the email address associated with your account. Otherwise, we reserve the right to verify your identity by requesting additional information to confirm who you are.

Fees. We will not charge a fee for you to exercise any right regarding your personal data, unless your request for access to information is unfounded, repetitive, or excessive, in which case we will charge a reasonable fee under such circumstances. We will inform you of any fees charged before processing your request.

Response time. We aim to respond to any valid requests within one month, unless the matter is particularly complex or you have made multiple requests, in which case we will respond within two months. We will let you know if we need more than a month. We may ask you to tell us exactly what you would like to receive or what specifically concerns you. This will help us act more quickly and shorten the response time to your request.

Third-party rights. We are not required to comply with a request if it would negatively affect the rights and freedoms of other data subjects.