1.1. This document will explain how we use your personal data in compliance with the Regulation (EU) 2016/679 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (“GDPR”).
1.2. In this Privacy Policy, you will find all relevant information applicable to our use of the personal data of our users (“Users”).
1.3. We undertake that during the data processing procedure, we will be fully transparent and inform you what we do with your personal data, the implications of the way in which we use your data, and the rights you are entitled to in relation to your data.
2.1. If you interact with our website, Cinque Amici Leather Ltd. (seat: Romania-547367 Corunca, Principala street 140A; company registration No.: J26/552/2020) (“We”) will act as the data controller of your data.
2.2. As data controllers we are entitled to determine how and for what purpose the personal data provided to us is processed. We are also responsible for implementing appropriate technical and organizational measures to ensure that your personal data is processes in accordance with the GDPR.
3.1. GDPR defines “personal data” as any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
3.2. We collect your personal data when you register to our website or provide us with your contacts in our shop, when you sign up for our newsletter, when you respond to a survey or any marketing communications, when you make a purchase online or simply surf the website.
3.3. When we ask you to fill in your personal data, we always mark certain fields as compulsory. Without these data we would not be able to provide you with the required service or to afford you access to certain functionalities of the website. Please take into account that, if you decide not to make such data available to us, you may be unable to complete your user registration or may not be able to enjoy certain services or functionalities.
4.1. Depending on the purpose for which we process your data we collect and use different kind of personal data. The personal data that we collect belongs to one of the following categories:
(i) personal data concerning your identity (e.g. your name, language, your contacts; etc.);
(ii) personal data concerning your transactions (e.g. your payments, credit/debit card details, information on your purchases, orders, returns, etc.);
(iii) personal data concerning your connection and/or browsing data (e.g. your IP address, your location etc.);
(iv) commercial information about you (e.g. if you have subscribed to our newsletter),
(v) information about your tastes and preferences based on your browsing history on our site.
4.2. We collect and use your personal data for the following purposes indicated in first column of the below:
| PURPOSE | DATA TYPE | DESCRIPTION |
| 1. To manage your registration as user on the website | Personal data concerning your identity:
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If you decide to become a registered user of our website, we need to process and store your data to identify you as a user and grant you access to its various functionalities, products and services. |
| 2. To perform the purchase contract that you concluded with us through the website | Personal data concerning your identity:
Personal data concerning your transactions:
Personal data concerning your connection, geolocation and/or browsing data:
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This purpose includes processing your data, mainly:
|
| 3. To contact you in case any question would arise in connection with your order, the ordered products, the delivery or the return. | Personal data concerning your identity:
Personal data concerning your transactions:
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Should you have any concerns regarding your order or its return, our customer service is happy to assist you, however without your personal data we would not be able to get in contact with you and to meet your requests. |
| 4. To send you newsletters, offers tailored to your interests and needs and other marketing materials | Personal data concerning your identity:
Information about your tastes and preferences based on your browsing history on our site:
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If you subscribe to our newsletter, we will process your personal data to manage your subscription and to send you customized information on our products or services via email.
Furthermore, please consider that to be able to send you customized marketing materials, as part of the data processing we need to analyze your profile and browsing/purchase history to determine your preferences to understand which products and services fits your style best and send you relevant materials accordingly. Remember that you can always unsubscribe from our newsletter at any time by sending us an email to [email protected] or clicking on the “unsubscribe” button on the bottom of our newsletter. |
| 5. To perform promotional actions (for example, to organize competitions). | Personal information provided to us as part of the promotional action. | On participating in any promotional action, you authorise us to process the personal data that you have shared with us depending on the promotional action and disclose them through different media such as social networks or the website itself.
If we organize a promotional action, we will always make available the terms and conditions to inform you about the extent and the rule of our data processing activity related your personal data provided to us. |
| 6. To analyze the usability and quality of our website | Browsing data | If you access our website, we will process your browsing data for analytic and statistic purposes, i.e., to understand the manner in which users interact with our website and to be able to introduce improvements.
In addition, we occasionally perform unanimous quality surveys and actions to know the degree of satisfaction of our customers and users and detect those areas in which we may improve. |
Pursuant to the applicable regulation, no personal data shall be processed without valid legal basis. The legal basis of our data processing depends on the purpose for which the given personal data is processed.
We summarize the legal basis of our data processing in the following table.
| PURPOSE | LEGAL BASIS |
| 1. To manage your registration as user on the website. | We process your related personal data upon your consent provided by you by accepting our Privacy Policy at registration process and because it is necessary for the performance of our contract or for taking steps at your request prior to entering into the contract. |
| 2. To perform the purchase contract that you concluded with us through the website. | We process your related personal data for the performance of our contract or for taking steps at your request prior to entering into the contract.
Certain processing of data related to the purchase process is activated only because you request or authorize it, as is the case of the storage of payment (card) data for future purchases. In these cases, our processing of your data is supported by your own consent. We consider that we have a lawful interest to carry out the necessary verifications to detect and prevent potential fraud when you make a purchase. We understand that the processing of such data is positive for all the participating parties when a purchase is paid and in particular for you, since this allows us to establish measures to protect you from fraud attempts by third parties. |
| 3. To contact you in case any question would arise in connection with your order, the ordered products, the delivery or the return. | We consider that we have lawful interest in answering your questions concerning your order.
Furthermore, the processing of these data for this purpose is also beneficial to you to the extent that it enables us to assist you adequately and answer your questions. Consequently, when you contact us – especially in connection with incidents related to your order or the product/service acquired through the website – the processing of your data is necessary to fulfill the purchase contract. When the issue is related to the exercise of your rights over your personal data or to claims on our products or services, we are legally permitted to process your data for compliance with our legal obligations. |
| 4. To send you newsletters, offers tailored to your interests and needs and other marketing materials. | We process your related personal data upon your consent provided by you by accepting to receive marketing materials and customized information through our website or personally.
In order to send you customized information, we consider that we have a lawful interest to conduct a profiling with the information that we have about you (such as your browsing, preferences or purchase history) and the personal data that you have provided us, such as the age range or language, since we understand that the data processing of these data is also beneficial to you because it allows you to improve your user experience and access the information in accordance with your preferences. |
| 5. To perform promotional actions (e.g. to organize competitions). | We process your related personal data upon your consent provided by you by accepting to receive marketing materials and customized information through our website or personally. |
| 6. To analyze the usability and quality of our website. | We consider that we have a lawful interest in analyzing the website’s usability and the user’s satisfaction degree, because we understand that the processing of such data is also beneficial for you because the purpose is to improve the user experience and provide a higher quality service. |
In general, we process your personal data for the time required for the purposes set out in this Privacy Policy or for the period specified by the relevant regulations. Consequently, the time for which we store your data depends on the purposes for which we process the data (and partially the legal basis of the data processing), as summarized in the below table:
| PURPOSE | TIME OF DATA PROCESSING |
| 1. To manage your registration as user on the website. | We will process your data as long as you remain a registered user, until you decide to terminate your account. |
| 2. To perform the purchase contract that you concluded with us through the website. | We will process your data for the time required for the completion of the purchase contract, including potential returns, complaint period or as long as claims related to the purchase of the product in question exist.
If we process your data for this purpose on the basis of your consent (e.g. the details of your credit/debit card), we will process your data up to the point of the withdrawal of your consent or the termination of your account. |
| 3. To contact you in case any question would arise in connection with your order, the ordered products, the delivery or the return. | We will process your data for the time strictly necessary to meet your request or application, but at least until the expiry of the return and warranty period. |
| 4. To send you newsletters, offers tailored to your interests and needs and other marketing materials. | We will process your data until you unsubscribe or cancel your subscription to the newsletter or until you otherwise withdraw your consent. |
| 5. To perform promotional actions (e.g. to organize competitions). | If it is not determined differently in the specific privacy policy of the respective promotional action, then if you participate in promotional actions, we will keep the data for 1 (one) year period calculated from the last day of the promotional action. |
| 6. To analyze the usability and quality of our website | We will process your data occasionally for the time during which we proceed to carry out a specific quality action or survey. |
Further to the above, please note that although we only process your data for the time strictly necessary to fulfill the respective purpose, thereafter – to serve our lawful interests – we will keep the personal data duly stored and protected in compliance with the legislation in force for the time being. Once the deadline of each potential actions expires, we will duly delete your personal data.
In the course of our operation to be able to provide you with our services we may utilize the services of third-party service providers, who may act as data processors in relation to your personal data, in order to handle and process your personal data for specific purposes, on our behalf and according to our instructions.
The following third-party service providers may act as data processors in relation to your personal data:
(a) Logistic, transport and delivery partners and service providers to deliver the product that you purchased on our website;
(b) Payment service providers and other financial institutions to process the payments you initiated on our website;
Paylike acts as data processor in regards to your payment instrument information, see their privacy policy for more information about the processing.
(c) Email service provider platform, in order to facilitate communication with you after purchase and to send you marketing materials and promotional actions;
(d) Technological service providers;
(e) Other third-party service providers involved by us for data processing.
Our data processors shall process the personal data pursuant to the data processing agreement concluded between our company and the data processor. The data processor is not allowed to engage another data processor without our prior specific or general written authorization.
If you have any data protection related questions, or if you wish to exercise your rights or file a complaint, please contact us at [email protected].
Pursuant to the applicable regulation, regardless of the purpose or legal basis of the data processing, you have the following data processing-related rights:
You have right to information concerning the processing of your personal data, therefore you are entitled to request information from us about how we handle your personal data and what are your rights in this regard.
You may request us any time to provide you with access to the data we have available on you.
You are entitled to request us to rectify without undue delay your inaccurate personal data that we have available on you, furthermore considering the purposes of the processing, you have the right to have your incomplete personal data completed, including by means of providing a supplementary statement.
Further to that, please note that as a registered user you are responsible for providing your true and correct personal data. If your user information is not correct or outdated then shall access the relevant personal data section of your account and change or update your personal data through our website.
You may request us to erase your personal data and upon your request we shall erase personal data without undue delay, if the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed.
You have the right to demand the restriction of the processing of your personal data.
If the processing of your personal is restricted then such personal data shall, with the exception of storage, only be processed with your explicit consent or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the European Union or of a Member State.
If we process your personal data based on your consent, then you also have the right to withdraw such consent at any time.
Provided that we process your data based on your consent or based on its necessity for the performance of the contract or if the data processing is procured through automated means, then you have the right to request and receive your personal data that you made available to us in a structured, commonly used and machine-legible format, to be able to transmit them to another data controller.
If the processing of your data is based on our lawful interest, you will also have the right to object to the processing of your data.
You are entitled to request that we do not apply any such decisions to you that is based solely on automated processing (including profiling), if such decision would have legal or other significant consequences for you.
Finally, we inform you that you have the right to file a claim before the Romanian Data Protection and Freedom of Information Authority (address: Romania, 010336 Bucharest, B-dul G-ral Gh. Magheru 28-30; email: [email protected]; website: https://www.dataprotection.ro) the responsible data protection regulatory authority.
Your personal data is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the personal data confidential.
To ensure the safety of our website, from time to time we scan the website for security holes and other vulnerabilities. We implement a variety of security measures when a user places an order, submits, or accesses their information to maintain the safety of your personal data.
We may amend the information contained in this Privacy Policy when we consider this appropriate.
We suggest you to review this Privacy Policy from time to time in case minor changes are made or we make any interactive improvement, taking the opportunity that you will always find it as a permanent point of information on our website.
If we wish to use your personal data for a new purpose, not covered by this document, we will provide you with a new Privacy Policy, explaining all detail to the new processing. If required, we will seek your consent before commencing the new data processing activity.
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Please read our Cookies Policy to understand with greater detail the cookies and similar devices that we use, their purpose and other information of interest.
