Personal data processing

Privacy Policy regarding the processing of personal data

We consider ensuring the right to personal data protection a fundamental commitment, therefore we will dedicate all necessary resources and efforts 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 legislation in the territory of Romania. As transparency is one of the essential principles of this legal framework, we have prepared this document to inform you about how we collect, use, transfer, and protect your personal data when you interact with us in relation to our products and services, including through our website or mobile applications.

We reserve the right to periodically update and amend this Privacy Policy to reflect any changes in the way we process your personal data or any changes in legal requirements. In the event of any such change, we will display the amended version of the Privacy Policy on our website, which is why we ask you to periodically check the content of this Privacy Policy.

Who we are and how you can contact us

The site is owned by the commercial company Cleverstore.ro S.R.L, a legal entity of Romanian nationality, with its registered office in Bihor, with order number in the Trade Register J05/1098/2019, unique fiscal registration code RO 42061518 (hereinafter “we“). For the purposes of data protection legislation, we are the controller when we process your personal data.

What categories of personal data do we process?

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

When you create an account on the site, you provide us with: your email address, first and last name;

When you place an order, you provide us with information such as: the desired product, first and last name, delivery address, billing details, payment method, phone number, etc.

We also offer you the possibility to register on the platform through your Facebook or Google account. If you opt for one of these options, you will be directed to a page managed by Facebook Inc / Google LLC, where they will inform you about the transfer of your data to us.

We may also collect and subsequently process certain information about your behavior while visiting our website or using the smartphone application, to personalize your online experience and provide you with offers tailored to your profile. We invite you to find out more details in this regard by consulting the section on the purposes of processing below.

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

We do not collect or otherwise process sensitive data, included by the General Data Protection Regulation in special categories of personal data. We also do not wish to collect or process data of minors under the age of 16.

What are the purposes and grounds for processing?

We will use your personal data for the following purposes:
For the provision of services for your benefit.
This general purpose may include, as appropriate, the following:

• Creating and managing the account within the platform;
• Processing orders, including taking, validating, shipping, and invoicing them;
• Resolving cancellations or any issues related to an order, goods, or services purchased;
• Returning products in accordance with legal provisions;
• Refunding the value of products in accordance with legal provisions;

The processing of your data for these purposes is in most cases necessary for the conclusion and execution of a contract between us and you. Also, certain processing subsumed under these purposes is required by applicable law, including tax and accounting legislation.

To improve our services

We constantly strive to offer you the best online shopping experience. For this, we may collect and use certain information related to your Buyer behavior, we may invite you to complete satisfaction questionnaires subsequent to the finalization of an order, or we may conduct, directly or with the help of partners, market studies and research.

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

For marketing

We want to keep you up to date with the best offers for the products/services that interest you. In this regard, we can send you any type of message (such as: e-mail/SMS/telephone/mobile push/webpush/etc.) containing general and thematic information, information on products similar or complementary to those you have purchased, information on offers or promotions, information on products added to the "Account/My Cart" section or the "Account/Favorites" section or that you have shown interest in purchasing, as well as other commercial communications such as market research and opinion polls, and we can display personalized recommendations on the website and in the smartphone application. To provide you with information of interest to you, we may use certain data about your buyer behavior (e.g., products viewed / added to wishlist / purchased) to create a profile for you. We always ensure that these processing operations are carried out with respect for your rights and freedoms and that the decisions taken based on them do not have legal effects on you and do not similarly affect you to a significant extent.

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

Accessing the unsubscribe link displayed within the messages you receive from us;

Contacting us 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. In any situation where we use information about you for our legitimate interest, we take care and all necessary measures to ensure that your fundamental rights and freedoms are not affected. However, you can ask us at any time, by the means described above, to stop processing your personal data for marketing purposes, and we will comply with your request.

To defend our legitimate interests

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

Measures to protect the website and platform users against cyber-attacks:

Measures to prevent and detect fraud attempts, including transmitting information to the competent public authorities;

Measures to manage various other risks.

The general basis for these types of processing is our legitimate interest in defending our business, it being understood that we ensure that all measures we take guarantee a balance between our interests and your fundamental rights and freedoms.

Also, in certain cases, we base the processing on legal provisions such as the obligation to ensure the security of goods and assets provided for by the applicable legislation in this matter.

How long we keep your personal data

As a general rule, we will store your personal data as long as you have an account on the platform. You can request us at any time to delete certain information or close your account, and we will comply with these requests, subject to the retention of certain information even after the account is closed, in situations where applicable law or our legitimate interests require it.

To whom we transmit your personal data

As the case may be, we may transmit or provide access to some of your personal data to the following categories of recipients:

• 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 can develop joint programs for offering our goods and services on the market.

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

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

How we protect the security of your personal data

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

The transmission of your personal data is done using state-of-the-art encryption algorithms and we store them on secure servers, while also ensuring data redundancy.

For making payments, we use the services of the payment processor EuPlatesc.ro. Any payment information is encrypted using HTTPS technology with TSL 1.2 encryption.

Despite the measures taken to protect your personal data, we draw your attention to the fact that the transmission of information via the Internet, in general, or through other public networks, is not completely secure, there being a risk that the data may be seen and used by unauthorized third parties. We cannot be responsible for such vulnerabilities of systems that are not under our control.

What rights you have:

The General Data Protection Regulation recognizes a series of rights in relation to your personal data. You can request access to your data, the correction of any errors in our files, and/or you can object to the processing of your personal data. You can also exercise your right to complain to the competent supervisory authority or to go to court. Where applicable, you may also benefit from the right to request the deletion 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 obtained by consulting the table below.

To exercise your rights, you can contact us using the contact details set out 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 send us 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 aimed at confirming your identity.

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

Response time. We aim to respond to any valid requests within a maximum of one month, unless this is particularly complicated or if you have made several requests, in which case we will respond within a maximum of two months. We will let you know if we need more than a month. We may ask you if you can tell us exactly what you want to receive or what you are concerned about. This will help us act faster and shorten the response time to your request.

Third-party rights. We do not have to comply with a request if it would adversely affect the rights and freedoms of other data subjects.

Rights of the data subject

As a data subject, you have the following rights exclusively concerning your personal data, as provided by the General Data Protection Regulation:

a. The right to information: the right to be informed about the identity and contact details of the controller and the Data Protection Officer (if applicable), the purposes for which the data is processed, the categories of personal data concerned, the recipients or categories of recipients of the data, the existence of the rights provided by the legislation on personal data protection for the data subject and the conditions under which they can be exercised;

b. The right of access to data: the right to obtain from the data controller confirmation as to whether or not personal data concerning you are being processed by them;

c. The right to rectification: the right to obtain the rectification of inaccurate data concerning you, as well as the completion of incomplete data;

d. The right to erasure of data ("the right to be forgotten"): the right to obtain, insofar as the legal conditions are met, the erasure of personal data concerning you;

e. The right to restriction of processing: the right to obtain, insofar as the legal conditions are met, the limitation of the further processing of personal data concerning you;

f. The right to data portability: the right to receive personal data in a structured, commonly used and machine-readable format, as well as the right to have this data transmitted by the Controller to another data controller, insofar as the legal conditions are met;

g. The right to object: the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you, insofar as the legal conditions are met;

h. The right not to be subject to an individual decision: the right to request and obtain the withdrawal, cancellation or re-evaluation of any decision based exclusively on processing carried out by automated means (including profiling) which produces legal effects concerning you or similarly significantly affects you;

i. The right to address the courts or ANSPDCP: the right to lodge a complaint with ANSPDCP, or to address the courts for the defense of any rights guaranteed by the applicable legislation in the field of personal data protection, which have been violated.

To exercise these rights, you can submit a written, dated, and signed request to the Controller by email at info@cleverstore.ro

If you submit a request regarding the exercise of your data protection rights, the Controller will respond to this request within 30 days, under the conditions provided by the General Data Protection Regulation.

The personal data Controller processes your data under conditions of legitimacy, while also implementing appropriate technical and organizational measures to ensure the integrity and confidentiality of the data in accordance with the General Data Protection Regulation.

You have the right to lodge a complaint with the supervisory authority regarding the processing of your personal data. In Romania, the contact details of the data protection supervisory authority are as follows:

The National Supervisory Authority for Personal Data Processing

B-dul G-ral. Gheorghe Magheru nr. 28-30, Sector 1, postal code 010336, Bucharest, Romania

Phone: +40.318.059.211 or +40.318.059.212;

E-mail: anspdcp@dataprotection.ro

Without prejudice to your right to contact the supervisory authority at any time, please contact us beforehand, and we promise that we will make every effort to resolve any issue amicably.

We remind you that you can contact our Data Protection Officer at any time by sending your request by e-mail to: info@cleverstore.ro