Privacy Policy in regard to the GDPR

We consider the right to the protection of personal data as a fundamental commitment of SC 21EASTGROW S.R.L., so we will 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 on the territory of Romania. One of the key principles of this legal framework is transparency.

This is why we have prepared this document through which we want to inform you about how we collect, use, transfer and protect your personal data when interacting with us about our products and services.

We reserve the right to periodically update and modify this Privacy Policy to reflect any changes in the way we process your personal data or any changes to your legal requirements. In the event of any such change, we will display on our website the modified version of the Privacy Policy, so please periodically review the contents of this Privacy Policy.

Who we are and how you can contact us

acob à porter is a commercial trademark of SC 21EASTGROW S.R.L., a legal entity of Romanian nationality, having its headquarters in Bucharest, Str. C-tin Brancusi no. 23, cam. no. 1, bl. T4-T5, Sc. 1, Et. 10, Ap. 39, with serial number in the Trade Register J40 / 10296/2017, unique fiscal registration code 37831491 (hereinafter “21EASTGROW S.R.L.” or “us”). within the meaning of data protection legislation, we are an operator when we process your personal data.

Since we are always open to your views and to provide you with any further information you may need regarding the processing of your data, we encourage you to contact the 21EASTGROW S.R.L. Data Protection Officer at the data.protection@acobaporter.com or by post or courier at: Bucuresti, Str. C-tin Brancusi no. 23, cam. no. 1, bl. T4-T5, Sc. 1, Et. 10, Ap. 39 – with the mention: in attention of the Data Protection Officer 21EASTGROW S.R.L.

Which categories of personal data we process

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

When you create a 21EASTGROW S.R.L. account, you are sending us: the e-mail address, the first and last name;

Within your personal page (My Account) from 21EASTGROW S.R.L. you can add additional information such as: delivery addresses, alternative email address, phone number, etc .;

When placing an order, you provide us with information such as the product you want, name and surname, delivery address, billing details, payment method, phone number, etc.

We can also collect and then process certain information about your behavior while visiting our website to personalize your online experience and provide you with offers tailored to your profile. We invite you to find out more details in this respect by consulting the section on the purposes of processing below.

On our website we can store and collect information in cookies and similar technologies, according to the Cookie Policy.

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

What are the purposes and basics of processing:

We will use your personal data for the following purposes:

To provide 21EASTGROW S.R.L. for your benefit.

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

a) Creating and administering the account within the platform 21EASTGROW SRL;
b) Processing of orders, including taking over, validating, dispatching and invoicing;
c) Solving cancellations or problems of any kind related to an order, to the goods or services purchased;
d) Return of the products according to the legal provisions;
e) reimbursement of the value of the products according to the legal provisions;
f) Provide support services, including providing answers to your questions about your orders or the 21EASTGROW SRL goods and services.

The processing of your data for these purposes is in most cases necessary for the conclusion and performance of a contract between 21EASTGROW SRL and you. Also, certain processing underlying these purposes is required by the applicable legislation, including tax and accounting legislation.

To improve our services

We always want to offer you the best online shopping experience. For this, we may collect and use certain information about your Buyer’s behaviour, we may invite you to fill in satisfaction queries subsequent to the completion of an order.

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

For marketing

We want to keep you informed about the best offers for the products or services you are interested in. In this regard, we may send you any kind of message (such as: e-mail / SMS / telephone / etc) containing general and thematic information, information about similar or complementary products to those you have purchased, information on offers or promotions, product information added in the “Account / My Basket” section or the “Account / Favourites” section or you have shown interest to acquire them, as well as other commercial communications such as market research and surveys opinion, and we can display customized recommendations on the website. In order to provide you with information of interest to you, we may use certain data about your buyer behaviour (e.g. products viewed / added to wish list / purchased) to create a profile. We always ensure that such processing is done with due respect for your rights and freedoms and that decisions made thereon do not have legal effect on you and do not affect you to a significant extent.

In most cases, we prioritize marketing communications on your prior consent. You can revoke and withdraw your consent at any time by:

– Changing the client account settings in the “GDPR” section;
– Accessing the unsubscribe link displayed in the messages you receive from us;
– By contacting 21EASTGROW SRL using the contact details described above.

In some situations, we can base our marketing activities on our legitimate interest in promoting and developing our commercial activity. In any situation in which we use information about you for our legitimate interest, we take care and take all necessary measures to ensure that your fundamental rights and freedoms are not affected. However, you may at any time request us, by the means described above, to stop processing your personal data for marketing purposes, following your request.

To defend our legitimate interests

There may be situations where we use or transmit information to protect our rights and commercial activity. These may include:

– Measures to protect the website and users of the 21EASTGROW SRL platform against cyber attacks:
– Measures to prevent and detect fraud attempts, including transmission of information to competent public authorities;
– Measures to manage various other risks.

The general reason for these types of processing is our legitimate interest in protecting our commercial activity, since it is understood that we are ensuring that all the measures we take guarantee a balance between our interests and your fundamental rights and freedoms.

Also, in some cases, we are working on legal provisions such as the obligation to safeguard the goods and values provided by the applicable legislation in this field.

How long do we keep your personal data

As a general rule, we will store your personal data as long as you have an account in 21EASTGROW S.R.L. platform. You may request us at any time to delete certain information or account closure and we will respond to these requests, subject to the preservation of certain information, including after the closure of the account, in situations where the applicable law or legitimate interests impose it.

This can be done expressly upon a request to delete the personal data available in your account, the GDPR section.

Who we send your personal data to

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

– courier service providers;
– IT service providers;
– other companies with whom we can develop joint marketing programs for our goods and services.

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

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

In which countries transfer your personal data

We currently store and process your personal data in Romania.

However, it is possible to transfer certain personal data to entities located in the European Union or outside the Union, including in countries where the European Commission has not recognized an adequate level of personal data protection.

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

You can contact us at any time, using the contact details listed above, to find out more about the countries where we transfer your data, the pairs, and the safeguards that we have applied to these transfers.

How do 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 stored on secure servers while ensuring data redundancy.

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

What rights do you have

The General Data Protection Regulation will recognize a series of rights with respect to your personal data. You may request access to your data, correct any mistakes in our files, and / or you may oppose the processing of your personal data. You can also exercise the right to complain to the competent supervisory authority or to address the court. As the case may be, you also have the right to request the deletion of your personal data, the right to restrict your data processing and the right to data portability.

More information about each of these rights can be obtained by consulting the table below.

In order to exercise your rights, you can contact us using the contact details listed above. Please note the following if you wish to exercise these rights:

Identity.

We take seriously the confidentiality of all records that contain personal data. For this reason, please send us your requests regarding such records using the e-mail address of 21EASTGROW SRL. Otherwise, we reserve the right to verify your identity by requesting additional information to confirm your identity.

Fees.

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

Response time.

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

Rights of third parties.

We do not have to respect an application if it would adversely affect the rights and freedoms of other individuals.

Rights concerned:

Access

You can ask:

– To confirm that we process your personal data;
– Provide a copy of these data;
– To provide other information about your personal data, such as data we have, what we use, who we divulge, whether we transfer them abroad, and how we protect them, how long we keep them, what rights you have how you can make a complaint, where we have obtained your data, to the extent that the information has not already been provided to you through this information.

Correction

You may ask us to rectify or complete your inaccurate or incomplete personal data.
It is possible to try to verify the accuracy of the data before correcting it.

Delete data

You may ask us to delete your personal data, but only if:

– They are no longer necessary for the purposes for which they were collected,
– You have withdrawn your consent (if the data processing is based on consent);
– You have a legal right to oppose you;
– They have been illegally processed;
– We have a legal obligation to do so.

We have no obligation to comply with your request to delete your personal data if processing of your personal data is required:

– to comply with a legal obligation;
– for finding, exercising or defending a right in court.

There are certain other circumstances in which we are not obliged to respect your request for data deletion, although these two are the most probable circumstances in which we may refuse this request

Please note that prior to the exercise of this right you must download from 21EASTGROW S.R.L. and save all documents related to orders made at 21EASTGROW S.R.L., regardless of whether the invoicing has been made to you or to another person or entity ( such as: invoices, warranty certificates, manuals, etc.). if you do not do this before exercising the right to delete, you will lose all these documents and 21EASTGROW S.R.L. will be unable to provide you, as the case may be, because the process of deleting the data or the account 21EASTGROW S.R.L., with all the data and documents related to it, is an irreversible process.

Restriction of data processing

You may ask us to restrict the processing of personal data, but only if:
– their accuracy is contested (see rectification section) to allow us to verify the accuracy of these;
– processing is illegal, but you do not want the data to be deleted;
– they are no longer necessary for the purposes for which they were collected, but you need them to find, exercise or defend a right in court;
– you have exercised the right to oppose you, and checking whether our rights are prevailing is underway.

We may continue to use your personal data following a restriction request if:

– we have your consent;
– to establish, exercise or secure the defense of a right in court;
– to protect the rights of 21EASTGROW SRL or any other natural or legal person.

Data portability

You may ask us to provide your personal data in a structured format that is currently used and can be read automatically, or you may request that it be “ported” directly to another data operator, but in each case only if:

– processing is based on your consent or on the conclusion or execution of a contract with you;
– processing is done by automatic means.

Opposition

You may oppose at any time, for reasons related to your particular circumstances, the processing of your personal data on our legitimate interest, if you believe that your fundamental rights and freedoms prevail over this interest.

You can also oppose processing of your data at any time for direct marketing purposes (including creating profiles), without invoking any reason, in which case we will terminate this processing as soon as possible.

Making automated decisions

You can ask that you not be the subject of a decision based solely on automatic processing, but only when that decision:
– produces legal effects on you;
– It affects you in a similar way and to a significant extent.

This right does not apply if the decision reached has been taken following the automatic decision making:

– we are required to conclude or run a contract with you;
– is authorized by law and there are adequate safeguards for your rights and freedoms;
– is based on your explicit consent.

Claims

You have the right to file a complaint with the supervisory authority about the processing of your personal data. in Romania, the contact data of the supervisory authority for data protection are as follows:

National Authority for the Supervision of 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 in advance, and we guarantee that we will do our best to resolve any issues amicably.

We would like to remind you that you can contact the Data Protection Officer 21EASTGROW SRL at any time by submitting your request in any of the following ways:

– by e-mail at: data.protection@acobàporter.com or
– by post or courier at: Bucuresti, Str. C-tin Brancusi no. 23, cam. no. 1, bl. T4-T5, Sc. 1, Et. 10, Ap 39 with reference to the Data Protection Officer 21EASTGROW SRL.