Personal data protection policy

The policy regarding the confidentiality of websites/online stores is made available by ADULT CONSTRUCT defined as a service provider in this document.

This notification regarding the confidentiality of personal data is published pursuant to Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016 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 (General Data Protection Regulation).

The service provider respects your confidentiality and undertakes to protect your personal data.

The purpose of the privacy notice is to inform you about how we protect your personal data when you visit our website and to inform you about your privacy rights, but also about how the applicable law protects you .

This privacy notice is provided in an easy-to-understand language, so as to facilitate your navigation in the following key sections.

1. Information regarding data protection

2. The personal data we collect

3. Methods of collecting personal data

4. Use of personal data

5. Communication of personal data

6. Securing and storing personal data

7. Rights you have and how to exercise them

8. Terms and definitions

1. Information regarding data protection

This privacy notice is intended to provide you with information about how the service provider collects and processes your personal data through the use of this website, including any data you provide when you access this website (subscribe to our newsletter, purchase a product or service or participate in a contest).

This website is not aimed at children and we do not knowingly collect data related to children.

It is important that you read this privacy notice together with any other privacy notice or processing notice we may provide in certain situations when we collect or process personal data about you, so that you are fully aware of how in which we use your data. This privacy notice complements the other announcements and does not intend to overwrite them.

The service provider is the inspector and is responsible for personal data.

You have the right to make a complaint/report at any time to the ANSPDCP (National Authority for the Supervision of Personal Data Processing), the personal data supervisory authority in Romania. We would appreciate the chance to deal with your complaint before calling ANSPDCP, so please contact us in the first instance.

Modification of the data protection notice and your duty to inform us of any changes.

It is important that your personal data, which we hold, is correct and current. Please let us know if your personal data changes throughout your collaboration with our company.

Links to third parties

This website may contain links to third parties, plugins and applications in various programming languages. Accessing these external links, activating certain options and implementing some applications or plugins, will allow third parties to collect or store your personal data. We do not control these third-party websites and are not responsible for their notices/statements or privacy policies. After you leave our website, we suggest you read the privacy policy of each website you visit.

2. Personal data we collect

By personal data or information we refer to the information with the help of which a person can be identified. The data in which the identity has been deleted (anonymous data) are not included.

We may collect, use, store and transfer different types of personal data about you. The data is grouped as follows:

- Identity data include (surname, first name, username or a similar identifier, appellative)

- Contact data include (billing address, delivery address, email address, phone number)

- Financial data include (bank account)

- Transaction data include (details about the payment method chosen, necessary details regarding the purchase of products/services provided by our company)

- Technical data include (internet protocol – IP address, authentication data, browser type and version, time zone, operating system, platform type and other technologies or devices used to access the website )

- Profile data include (your username and password, your purchases and orders, your interests and preferences, feedback, survey results)

- Datele de utilizare includ (informatii despre cum utilizati website-ul, produsele sau serviciile)

- Marketing and communications data includes (your preferences regarding our or third parties' marketing and your preferences for communications)

Aggregate data such as statistical and demographic data may also be collected, used and stored for any purpose. Aggregated data can derive from personal data, but from a legal point of view they are not considered personal data because this type of data does not directly or indirectly reveal your identity. For example, we can aggregate usage data to calculate the percentage of users who access a specific page or section of the website. However, if we intersect and correlate the Aggregate Data with your personal data, so that you are identified directly or indirectly, we will consider and treat the correlated data as personal data that will be used in accordance with the provisions of this privacy notice.

We do not collect any special category of personal data about you (this category includes details regarding race or ethnicity, religion or belief, sexual orientation, political preferences and other sensitive information). We also do not collect any information about criminal convictions or offences.

Failure to provide personal data

In situations where it is necessary to collect personal data provided by law or within the contractual provisions with you and you fail to provide this data, when requested, it is possible that we will not be able to perform the services or deliver the products contracted or that we are trying to contract them. In this event, we may need to cancel an order, product or service provided by us, but we will notify you if this is the case at the time.

3. Methods of collecting personal data

We use different methods to collect data from and about you, including through:

Direct interactions.

It is possible to provide us with your personal data (Identity Data, Contact Data, Financial Data) by filling in some forms or by corresponding with us by phone, post, email or other direct interactions. These types of interactions include the personal data you provide when:

  • Order or purchase products or services offered by our company
  • Create an account on the company's website
  • You subscribe to the company's services or information
  • Request the sending of marketing campaigns by our company
  • Sign up for a contest, promotion or survey offered by our company
  • You give us feedback

Technologies or automated interactions.

As you interact with our website, it is possible to automatically collect Technical Data about the devices used, actions and navigation patterns. We collect this personal data by using cookies, server sessions or other similar technologies. (Also. it is possible for us to receive technical data about you, if you visit other websites that use our cookies). For more details, please check the Cookies Policy.

Third parties or publicly available sources.

We may receive personal data about you through various third parties (and public sources) as stated below:

- Technical data provided by the following third parties:

- Providers of analysis services/data (Google Analytics, Google Analytics Ecommerce, StatCounter and other monitoring systems)

- Networks and promotion channels (Google Adwords, Google Remarketing, affiliate systems, Social Media – Facebook, Instagram, Twitter, YouTube and other social networks used)

- Websites aggregating offers or comparing prices (Compari.ro, ShopMania.ro, Cauti.ro. Okazii.ro, Price.ro)

- Online chat solutions and services (SmartSupp)

  • Online card payment processors (NETOPIA - mobilPay, EuPlatesc, PlatiOnline)
  • Invoicing systems in the cloud
  • Systems for automatic issuance of AWBs for courier companies

4. Use of personal data

We will use your personal data only within the legal limits allowed. In most cases, we will use your personal data in the following situations:

  • If necessary, we issue or conclude a contract with you.
  • If the personal data is necessary for our legitimate interests (or those of third parties) and your fundamental interests and rights do not exceed our legitimate interests.
  • In case we have to comply with legal obligations and provisions.

Generally, we do not rely on consent as the legal basis to process your personal data except in connection with the transmission of this data to third parties for direct email marketing communications or text messages.

You can contact us at any time, in order to withdraw this marketing communication agreement through the contact form on the website.

 The purposes for which personal data are used

In the table below you can find a description of all the ways we intend to use your personal data, but also what are the legal/legislative bases we use for using this data. We have also identified our legitimate interests where appropriate.

It should be noted that we can process personal data for more than one legal basis, depending on the specific purpose for which we use your data. Please contact us if more details are needed about certain legal bases on which we rely regarding the processing of your personal data, if more than one purpose has been stated below:

Purpose / Activity - To register you as a new customer.

Types of data - Identity data, Contact data

Legal basis for processing - Data necessary for the exercise of a contract with you.

Purpose / Activity - To process and deliver the order, including:

  • Management of payments, commissions and taxes
  • Collection and/or recovery of the sums owed

Types of data - identity data, contact data, transaction data, marketing and communications data.

Legal basis for processing:

  • Data necessary for the exercise of a contract with you.
  • Data necessary for our legitimate interest (to recover debts to us, if applicable).

Purpose / Activity - To manage the relationship with our company, including:

  • Notifications regarding changes to our privacy policy terms.
  • Asking for a review or doing market research.

Types of data - identity data, contact data, transaction data, marketing and communications data

Legal basis for processing:

  • Data necessary for the exercise of a contract with you.
  • Data necessary to comply with a legal obligation.
  • Data necessary for our legitimate interest (to update our database and to observe how our customers use our products/services.

Purpose / Activity - To allow you to participate in a sweepstakes, competition or survey

Types of data - Identity data, Contact data, Profile data, Usage data, Marketing and communications data.

Legal basis for processing:

  • Data necessary for the exercise of a contract with you.
  • Data necessary for our legitimate interest (to observe how customers use our products/services, to develop our business).

Purpose / Activity - To manage and protect our business and this website (including solving possible technical problems, data analysis, testing, system maintenance, support, reporting and hosting data, goods and services that could be of interest to you)

Types of Data - Identity Data, Contact Data, Technical Data, Usage Data, Profile Data.

Legal basis for processing: Data necessary for our legitimate interest (to carry out our company's activities, to provide administration and IT services, network security, to prevent fraud, in the context of a restructuring of our company).

Marketing activities

We want to offer you options regarding the use of certain personal data, especially regarding online marketing and advertising. We have created this privacy notice so that you can make certain decisions regarding the use of your personal data and through the mechanisms below.

Announcements and promotional offers

It is possible for us to use your personal data (Identity Data, Contact Data, Technical Data, Usage Data, Profile Data) to form an opinion on what you think you want to purchase or need or v- might be of interest. This is how we can decide which products, services or offers may be relevant to you.

You will receive marketing communications from us if you requested information from us, purchased goods or services from us or provided us with your data when you participated in a contest or signed up for a promotion and in each of the mentioned situations, you have not opted out of the marketing communications sent by our company.

Marketing activities provided by third parties

We will ask for your express consent before providing your personal data to any third party outside the service provider for marketing purposes.

Disclaimer

You can ask us or third parties to stop sending marketing messages at any time by logging into the account created on our website and checking or unchecking the relevant boxes to adjust your preferences regarding marketing communications or by selecting the opt-out links present in any marketing message sent or you can contact us directly whenever you want, through the contact form.

In cases where you opt out of receiving marketing messages, this opt-out option does not apply to personal data provided as a result of the purchase of goods or services, guarantees or other transactions.

Cookies

You can set your browser to refuse certain cookies or all cookies. You can also set the browser to warn you when websites set or access cookies. If you refuse or disable browser cookies, we inform you that certain sections of the website may become inaccessible or will not function properly.

For more information about the cookies used by our website, please consult the "Policy for the use of cookies".

Changing the purpose of collection

We will use your personal data for the purposes for which we collected it, unless we reasonably believe that we need to use it for another reason, and the reason is compatible with the original purpose. If you would like to receive an explanation of how the processing of the new purpose is compatible with the original purpose, please contact us.

5. Communication of personal data

If it will be necessary to use your personal data for an independent purpose, we will notify you and explain the legal bases that allow us to do so.

Please note that we may process your personal data without your consent or consent in accordance with the rules above, if this is necessary or permitted by law.

It is possible to provide your personal data to the parties presented below, for the purpose established in the table at point 4.

  • Internal Third Parties as defined in the Terms and Definitions
  • External third parties as defined in the Terms and definitions
  • Certain third parties as mentioned in point 4
  • Third parties with whom we may merge or sell, transfer parts of our business or assets. Alternatively, we may seek to merge with or acquire other businesses. In the event of an organizational change, the new owners may use your personal data for specific purposes and in accordance with our instructions.

We ask all third parties to respect the security of your personal data and to treat this data in accordance with the law. We do not allow third parties who provide us with services to use your personal data for their own purposes, but we will allow them to process your personal data for the purposes mentioned and in accordance with our instructions.

International data transfer

 We do not transfer your personal data outside the European Economic Area (EEA).

 

6. Securing and storing personal data

We have applied appropriate measures to prevent accidental loss of personal data, unauthorized use or access, modification or disclosure of personal data. In addition, we limit access to your data to all people in the company, such as employees, agents and other third parties. They will only process personal data according to our instructions and will be subject to an obligation of confidentiality.

We have procedures in place to deal with any personal data breaches and will notify you and any applicable regulatory authority of a breach if we are legally required to do so.

We will keep personal data for as long as necessary to fulfill the purposes, including the purposes of satisfying any legal, accounting or reporting requirements.

To determine the appropriate period of retention of personal data, we consider the value, nature and sensitivity of the personal data, the potential risk caused by the unauthorized use or disclosure of your personal data, the purposes for which we process the personal data and can achieve it by other means and applicable legal requirements.

Details about the retention period for the different aspects of personal data (will be available in our data retention policy, which you can request from us by contacting us or presenting the table from point 4 above).

In certain circumstances you can ask us to delete data: see [Request data deletion] below for further information.

In certain circumstances we have the possibility to anonymize personal data (so that it is no longer associated with you) for research or statistical purposes, in which case we can inform you without any additional notice.

 

7. Rights you have and how to exercise them

In certain circumstances you have the right in accordance with the laws regarding the protection of personal data by requesting this through the contact form:

  • Request access to personal data.
  • Request the correction of personal data.
  • The object of personal data processing.
  • Request restrictions on the processing of personal data.
  • Request the transfer of personal data.
  • The right to withdraw consent on personal data.

If you wish to exercise any of the rights mentioned above, please contact us.

You will not have to pay any fee (or claim any right). However, we may charge a fee if your request is unclear, repetitive or excessive. We have the possibility to refuse your request in this situation.

In order to honor your request, we may ask you for specific information to help us identify you and ensure that you have the right to access that personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to a person who does not have the right to receive it. We may also contact you to request additional information regarding your request.

We try to respond to all requests within a month. Occasionally, it may take longer if your request is complex or if you have several questions. In this case, we will notify you.

8. Terms and definitions

Legal Basis - Legitimate interest is the interest of our business in running and managing it to allow us to offer you a potential impact and your rights before processing your personal data for our interests. We do not use your personal data for our own activities (if we do not have your consent or if it is not permitted by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in relation to certain activities relating to contacting us.

Fulfillment of the contract - represents the processing of personal data where it is necessary for the performance of a contract to which you are a party or to take measures on your request before concluding such a contract.

Complying with a legal obligation or regulation - means the processing of your personal data if they are necessary to comply with a legal obligation or regulation to which we are subject.

Third parties are considered:

- Service providers (acting as processors) from Romania that provide IT and systems administration services.

- Professional advisers (acting as joint data processors or collectors) including lawyers, bankers, auditors and insurers from Romania providing consulting services, legal services, banking services, insurance services, accounting services.

Your rights are the following:

Request access to your personal data - This right allows you to receive a copy of the personal data we hold about you and check whether we are processing this data according to legislative norms.

Request the correction of personal data we hold about you - This will allow you to ask us to correct any incomplete or inaccurate data we hold about you, being it may be necessary to check the correctness of the new data you provide us.

Request the deletion of your personal data - This will allow you to request the deletion of your personal data, if there are no valid reasons for continuing to process this data. You also have the right to ask us to delete your personal data in cases where you have successfully exercised your right to object to the processing of personal data, in situations where we have processed your information illegally or in cases where we are obliged to delete your personal data in accordance with local law. We may not be able to comply with your request to delete personal data, for legal reasons.

Objection to the processing of your personal data - In the event that we rely on a legitimate interest (or those of a third party) and there is a particular situation that will cause you to object regarding the processing of your personal data and to the extent that your rights and fundamental freedoms are violated. You also have the right to object if we process your personal data for direct marketing purposes. In some cases, we can demonstrate that we have compelling legitimate reasons to process your information that exceed your fundamental rights and freedoms.

Request the restriction regarding the processing of your personal data - This will allow you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the accuracy of the data; (b) if the use of the data is illegal, but you do not want to delete this data; (c) if you need to store the data, even if we no longer need this data, because you need it to establish, exercise legal claims or (d) you have allowed us to use your data, but we need to check if we have reasons legal grounds to use them

Request the transfer of your personal data to you or to a third party. - We will provide you or a third party you have designated, your personal data in a commonly used format, in electronic format. Please note that this right only applies to automated information on which you have initially given us explicit consent to use this data or where we have used the information to enter into a contract with you.

Withdrawal of consent at any time when we rely on your consent to process your personal data. - However, this will not affect the legality of any processing carried out before withdrawing your consent. If you withdraw your consent, we may not be able to offer certain goods or services. We will notify and advise you in this eventuality, when you withdraw your consent.