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I. General Information
We consider the protection of your data to be your fundamental right, and we are committed to dedicating all necessary resources and efforts to process your data in compliance with Regulation (EU) 2016/679 (the "General Data Protection Regulation" or "GDPR"), as well as with any other applicable legislation in the territory of Romania.
The purpose of this document is to inform you correctly, specifically, and unequivocally about the manner and purpose for which this data is collected and processed, the period for which this data is stored, the ways to exercise your individual rights, as well as information related to the secondary purpose of processing, if the data will be processed for a purpose other than that for which it was collected by the joint controllers.
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.
II. Who we are and how you can contact us
DOUBLEYOU STORE S.R.L., with its registered office at Nicolae Caramfil 74 B, One Herastrau Tower, 1st Floor, A 1-3.4 (commercial space), Bucharest, 014142, is the owner of the online store cuanna.ro.
According to the requirements of Regulation no. 679 of 27.04.2016 (GDPR) on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, cuanna.ro has the obligation to manage safely and only for the specified purposes, the personal data you provide about yourself.
As we are interested in hearing your opinion and answering any additional questions regarding Personal Data Processing, we encourage you to contact the cuanna.ro data protection officer at the email address office@cuanna.ro or by post or courier to the address: Nicolae Caramfil 74 B, One Herastrau Tower, 1st Floor, A 1-3.4 (commercial space), Bucharest, 014142, with the mention "for the attention of the cuanna.ro data protection officer".
III. What 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. By way of example, we receive information from you as follows: When you create a cuanna.ro account, you send us: your e-mail address, first and last name;
On your personal page (My Account) on the cuanna.ro site, you have the option to add additional information, such as: shipping address, billing address, phone number.
When you place an order, you provide us with information such as: the desired product, first and last name, shipping address, billing details, payment method, phone number, bank card data, etc.
By providing this data, you give your freely expressed and unequivocal consent for all your personal data to be in our database, in strict compliance with the legal provisions regarding the protection of individuals with regard to the processing of personal data and the free movement of such data. According to the legitimate interest stipulated in the GDPR, we mention that the reasons why we need this data are: online commerce, sending our offers by e-mail and marketing and advertising messages, organizing contests, etc.
We also offer you the possibility to register on the cuanna.ro site through your Facebook or Google account. If you opt for one of these variants, 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 cuanna.ro. You can consult the Facebook and Google privacy policies using the following links:
https://www.facebook.com/about/privacy
https://policies.google.com/privacy
We may also collect and subsequently 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 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, according to 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 who have not reached the age of 16.
IV. What are the purposes and grounds for processing
We will use your personal data for the following purposes:
For the provision of cuanna.ro services and/or products for your benefit.
This general purpose may include, as appropriate, the following:
a) Creating and managing the account within the cuanna.ro site;
b) Processing orders, including taking, validating, shipping, and invoicing them;
c) Resolving cancellations or problems of any nature related to an order, to the goods or services purchased;
d) Returning products according to legal provisions;
e) Refunding the value of products according to legal provisions;
h) Providing support services, including offering answers to your questions regarding your orders or cuanna.ro 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 cuanna.ro and you. Also, certain processing activities under these purposes are required by applicable law, including tax and accounting legislation.
To improve our services.
We constantly want 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/phone/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 related to products added in 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. 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 activities 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:
– Changing the settings in the client account in the "My Subscriptions" section;
– Accessing the unsubscribe link displayed within the messages you receive from us; or by
– Contacting cuanna.ro 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, through the means described above, to stop processing your personal data for marketing purposes, and we will comply with your request.
For the purpose of profiling, monitoring, and sending personalized communications and offers, we use Google Analytics, Google Tag Manager, Hotjar, and Facebook Ads, automated marketing software dedicated to online stores.
• These activities have no legal or other significant similar effect on users. The only consequence of using this profiling is for users to receive personalized marketing discounts and offers. The user can opt out of being profiled or receiving commercial communications, without any effect other than not receiving these discounts or personalized marketing offers.
• For the purpose of processing, monitoring activities (profiling), and interacting with the site, Google Analytics, Google Tag Manager, Hotjar, and Facebook Ads must automatically collect and store the following personal data: e-mail, phone number, name, surname, gender, date of birth, city, county, IP address (including possible location), browser, order ID, discount code, discount value, shipping cost, total order value, individual price of ordered products, product variations, products, device, OS, IP location, timestamps related to page visit, page visit, category visit, brand visit, click on image, mouse over cart, mouse over price, scroll up, scroll down, add to cart, remove from cart, select variation, add to wishlist, comment, Like on Facebook, visited help page.
• The categories of data subjects are visitors, registered users, or customers of the site, as appropriate, depending on the service chosen. Visitors' data will be stored for 2 months, and that of registered users or customers for 3 years.
• To provide their services, Google Analytics, Google Tag Manager, Hotjar, and Facebook Ads use third-party processors (subcontractors) from the EEA and the US (only for push notifications), and the transfer of personal data is made under the EU-US Privacy Shield framework: the data is retained/stored for the duration of the contract between the two parties.
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 cuanna.ro website 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 as provided by the applicable legislation in this matter.
V. To whom we transmit your personal data
Where appropriate, 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 to offer 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 private legal entities is carried out in accordance with the legal provisions on data protection and confidentiality of information, based on contracts concluded with them.
VI. How long we keep your personal data
We will generally store your personal data as long as you have an account on the cuanna.ro platform. You can request us to delete certain information or close your account at any time, 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.
VII. To which countries we transfer your personal data
Currently, we store and process your personal data in the territory of Romania.
However, we may transfer some of your personal data to entities located in the European Union or outside the Union, including in countries for which 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 commitments and, where appropriate, by other guarantees, such as the 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 of America.
You can contact us at any time, using the contact details set out above, to find out more information about the countries to which we transfer your data, as well as the guarantees we have put in place regarding these transfers.
VII. 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. For making payments, we use the services of the Mobilpay payment processor.
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, and there is 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.
DoubleYou Store tries by all means to monitor and limit its employees' direct access to the database but is not responsible for their malicious intent or the theft of the database by them during working hours, which is considered abusive and for which they are liable to criminal penalties and termination of the employment contract, as well as the payment of damages.
DoubleYou Store collects information and processes it into statistical data about which pages you access within the cuanna.ro site, including the IP address from which you visit the cuanna.ro site.
DoubleYou Store uses cookies as a method to improve its activity and the online experience of its users. What are cookies and what cookies do we use? See here - https://cuanna.ro/cookie .
By filling in your data in the account creation and/or Order form, you declare that you accept that your personal data be included in the cuanna.ro database, and you give your express and unequivocal consent that all this personal data be stored, used, and processed without territorial and/or temporal limitation by cuanna.ro, its affiliates, and collaborators for the development and/or carrying out of activities by cuanna.ro, its affiliates, and collaborators such as commercial activities, promotion of products and services, marketing, advertising, media, administrative, development, market research, statistics, tracking and monitoring of sales and consumer behavior.
VIII. 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 mistakes 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. As appropriate, you may also benefit from the right to request the deletion of your personal data, the right to the restriction of 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 presented below.
To be able to exercise your rights, you can contact us using the contact details set out above. Please note the following aspects 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 e-mail address associated with the cuanna.ro 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 resolving 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 might ask if you can tell us exactly what you want to receive or what you are concerned 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 comply with a request if it would adversely affect the rights and freedoms of other data subjects.
Data Subject Rights
Description
Access
You can ask us:
to confirm if we are processing your personal data;
to provide you with a copy of this data;
to provide you with other information about your personal data, such as what data we have, what we use it for, to whom we disclose it, whether we transfer it abroad and how we protect it, how long we keep it, what rights you have, how you can file a complaint, where we obtained your data from, to the extent that the information has not already been provided to you through this notice.
Rectification
You can ask us to rectify or complete your inaccurate or incomplete personal data.
We may try to verify the accuracy of the data before rectifying it.
Deletion of data
You can ask us to delete your personal data, but only if:
it is no longer necessary for the purposes for which it was collected; or
you have withdrawn your consent (if the data processing was based on consent); or
you exercise a legal right to object; or
it has been processed unlawfully; or
we have a legal obligation in this regard.
We are not obliged to comply with your request to delete your personal data if the processing of your personal data is necessary:
for compliance with a legal obligation; or for the establishment, exercise, or defense of a right in court.
There are certain other circumstances in which we are not obliged to comply with your request for data deletion, although these two are the most likely circumstances in which we might refuse your request.
Please note that, before exercising this right, you should download from your cuanna.ro account and save all documents related to the orders placed with cuanna.ro, regardless of whether the invoicing was done to you or to another natural or legal person (such as: invoices, warranty certificates). If you do not perform this action before exercising your right to deletion, you will lose all these documents and cuanna.ro will be unable to provide them to you, as applicable, because the process of deleting the data, respectively the cuanna.ro account, with all its related data and documents, is an irreversible process.
Restriction of data processing
You can ask us to restrict the processing of personal data, but only if:
its accuracy is contested (see the rectification section), to allow us to verify its accuracy; or
the processing is unlawful, but you do not want the data to be deleted; or
it is no longer necessary for the purposes for which it was collected, but you need it to establish, exercise, or defend a right in court; or
you have exercised your right to object, and the verification of whether our rights prevail is ongoing.
We may continue to use your personal data following a request for restriction, if:
we have your consent; or
to establish, exercise, or ensure the defense of a right in court; or
to protect the rights of cuanna.ro or of another natural or legal person.
Data portability
You can ask us to provide you with your personal data in a structured, commonly used, and machine-readable format, or you can request that it be "ported" directly to another data controller, but in each case only if:
the processing is based on your consent or on the conclusion or performance of a contract with you; and
the processing is carried out by automated means.
Objection
You can object at any time, for reasons related to your particular situation, to the processing of your personal data based on our legitimate interest, if you consider that your fundamental rights and freedoms prevail over this interest.
You can also object at any time to the processing of your data for direct marketing purposes (including profiling), without invoking any reason, in which case we will cease this processing as soon as possible.
Automated decision-making
You can request not to be subject to a decision based solely on automated processing, but only when that decision:
produces legal effects concerning you; or
similarly affects you to a significant extent.
This right does not apply if the decision reached following automated decision-making:
is necessary for us to conclude or perform a contract with you;
is authorized by law and there are adequate safeguards for your rights and freedoms; or
is based on your explicit consent.
Complaints
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 affecting 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 the cuanna.ro Data Protection Officer at any time by sending your request through any of the following methods:
– by e-mail to the address: office@cuanna.ro or
– by post or courier to the address: Nicolae Caramfil 74 B, One Herastrau Tower, 1st Floor, A 1-3.4 (commercial space), Bucharest, 014142 with the mention "for the attention of the cuanna.ro data protection officer".