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Translation from Romanian

PRIVACY NOTICE

The company processes some personal data of the Users (registered or not) when they use the Website and/or any Service provided by CLARFON S.A. (for example, when you take part in our campaigns).

This privacy notice (”THE PRIVACY NOTICE”) describes the types of personal data processed, how they are used, your options in respect of these types of processing, and how we will observe your rights as data subject according to the personal data protection laws, including the Regulation (EU) 2016/679 (”GDPR”).

BEFORE USING OUR WEBSITE OR ANY OF OUR SERVICES, WE RECOMMEND YOU TO READ CAREFULLY THIS NOTICE IN ORDER TO UNDERSTAND HOW YOUR PERSONAL DATA IS PROCESSED.

WHO IS RESPONSIBLE FOR THE PROCESSING OF YOUR DATA?

CLARFON S.A., a limited liability company, based in Romania, is the data controller, according to the personal data protection laws, including the GDPR, in respect of the Users’ personal data, collected and processed via the Website and/or in the context of the Services provided via or in connection to the Website.

As regards the personal data processing, the Company may be contacted by using the following contact details:

Data Protection Officer

CLARFON SA
TIN (Tax Identification Number): 10863793
Trade Registry: J40/7833/1998
Address: Str. Academiei  Nr. 28-30, Etaj 9, Bucharest
Phone: 0730110120
E-mail: dpo@clarfon.ro

WHICH DATA DO WE PROCESS?

The Company processes the personal data that you provide us when you use the Website (for example, when you use the chat application), when you register on our page, when you enter our campaigns (and/or the campaigns organised together with our partners), when you want to receive commercial communications or to take part in our polls or questionnaires or when you contact us by any communication means.

Also, we use cookie modules and similar technologies in order to recognise you and your devices. We also allow other persons to use cookie modules. The Cookie Policy describes how we use these technologies.

The performance of the contract concluded with us.

When you request the supply of products, we may process certain personal data required for these purposes (for example, last name and first name, the delivery / supply address, trading data, etc.)

The management of relationships with the Users and support.

It is in our interest to provide adequate services via the Website to all persons accessing it. Therefore, we process a series of personal data in order to manage the relationships with the Website Users, for example when they address us various questions or requests concerning the functionalities of the Website, questions concerning the Company’s Services offered via the Website, etc. Legal base: art.6(1)(f) GDPR –  legitimate interest consisting in our interest to provide adequate services.

Reviews and statistics concerning the functioning of the Website, cookies and similar technologies.

We may use the personal data provided by the Users or collected by us in the context of using the Services in order to perform reviews and statistics concerning our Services, including the manner in which the Website functions or the Services are provided. The reviews and the statistics that we perform help us to understand better how we could improve our Services or the Website functionalities. When performing the reviews and the statistics, we also use cookies and other similar technologies according to the Cookie Policy.

Also, the cookies and the similar technologies are used in order to provide you with interest-based advertising.

Connection via the social networks.

We have implemented various mechanisms of interconnection with the social media pages, such as Facebook, Twitter, YouTube and Instagram, so that you are able to access more easily the content posted by us on the Website and/or our associated accounts on those social networks. If you access the content posted on those social networks or you make comments on those social networks or you access the Website via the Facebook account, a series of public data of your profile on those social networks shall also be sent to us by the operators of those social networks.

The defence of rights and interests in court

In order to find, exercise or defend a right in the framework of legal proceedings in court, of administrative proceedings or of other official proceedings involving the Company.

 

TO WHOM DO WE DISCLOSE THE DATA?

We may disclose your data to (i) the entities and/or the persons authorised by us (from the EEA or third – party states) involved in the provision of Services, including the provision of commercial communications (such as the providers of data centres, the providers of payments services for various payment facilities, the providers of e-mailing platforms like Google Mail), in our promotions (including when they are organised in partnership with other entities); (ii) if we are bound to disclose the personal data in order to comply with any legal obligation or decision of a judiciary authority, public authority or governmental body; or (iii) if we are asked or if we are allowed in other way to do this according to the applicable legislation.

Also, your personal data may be disclosed to third party providers of cookies and similar technologies according to the aspects described in the Cookie Policies.

 

HOW LONG DO WE KEEP THE DATA?

We keep your personal data as long as required for meeting the objectives in respect of which they have been collected, in compliance with the internal procedures concerning the data retention, including the applicable archiving rules. For example, if you are one of our subscribers, your personal data shall be kept for the entire duration of the contractual relationships, plus a minimum period of 3 years from the cessation (the limitation period for legal claims).

 

WHICH ARE YOUR RIGHTS AS DATA SUBJECT?

According to the law, the following rights are recognised to you as data subject:

  1. The right of access – you may obtain from us the confirmation that we process your personal data, and information concerning the specificity of the processing
  2. The right to rectification of data – you may request us to modify your inaccurate personal data or, as appropriate, to complete the incomplete data.
  3. The right to erasure – you may request the erasure of your personal data when: (I)  the personal data are no longer necessary in relation to the purposes for which we have collected and processed them; (ii) you have withdrawn the consent on which the processing is based, and there is no other legal ground for their processing by us; (iii) the data are processed according to the law; respectively (iv) the personal data have to be erased according to the relevant legislation.
  4. The withdrawal of consent and the right to object you may always  withdraw your consent concerning the data processing based on consent. Also, you may always object to the processing for marketing purposes, including the profiling performed for this purpose, and to the processing based on the legitimate interest of the Company, for reasons related to your specific situation.
  5. Restriction – under certain conditions, you may request the restriction of the processing of your personal data
  6. The right to data portability – to the extent that we process data by automated means, you may request us, according to the law, to provide your data in a structured, commonly used and machine-readable format. If you request this, we may send your data to other entity, if this is technically possible.
  7. The right to lodge a complaint with a single supervisory authority – you are entitled to lodge a complaint with the data protection supervisory authority if you think that your rights were violated: The Romanian Supervisory Authority for Personal Data Processing, B-dul G-ral. Gheorghe Magheru 28-30 Sector 1, zip code 010336 Bucharest, Romania, anspdcp@dataprotection.ro

 

IN ORDER TO EXERCISE THE ABOVE-MENTIONED RIGHTS, YOU MAY CONTACT US BY USING THE CONTACT DETAILS SPECIFIED IN SECTION 1 (CONTACT DETAILS).