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Privacy Policies

Privacy policies

 

We always pay special attention to the protection of your personal data. We choose to always inform you about the reasons why we need your data and about the period of time for which we keep them. Thus, you have the opportunity to decide for what purposes we will be allowed to use your data. To ensure the highest level of security, the information is always transmitted to us in encrypted form.

 Content

1. General information

1.1. Processing of personal data

1.2. The personal data operator

1.3. The rights of data subjects

1.4. Data disclosure to authorities


2. Collection and processing of personal data when you visit our site

2.1. Cookies

2.1.1 Strictly necessary cookies

2.1.2 Functionality and performance cookies

2.1.3 Cookies based on agreement

2.1.4 Management and deletion of all cookies

2.2 Web Analytics service

2.2.1 Google Analytics

2.3 Online advertising

2.3.1 Google Ads (formerly Google Adwords)

2.3.1.1 Google Ads Conversion

2.3.1.2 Google Ads Retargeting

2.3.2 Google Remarketing

2.3.3 Campaign Manager (Doubleclick)

2.3.4 Facebook Custom Audiences ("Facebook Pixel")

2.4 Google Tag Manager

2.5 Captcha’s

2.6 Online communication systems (Facebook Messenger)

2.7 Backup storage systems

2.8 Data and site security systems

2.9 Using Opencart and Opencart plugins

 

3. Online Store

3.1 Contact / Communication

3.2 Ordering and delivery of products

3.3 User account

3.4 Newsletter

3.5 Authentication profile

3.6 Ratings and reviews

3.7 Land mail communication

3.8 Dispute resolution

3.9 Recruitment

3.10 SMS notification system

3.11 Methods of payment

3.12 Courier services

3.13 Banking services

3.14 Email service hosting services

3.15 Site hosting services

 

4 Withdrawal of consent for the processing of personal data

4.1 Exemption from liability

4.2 Updating the Personal Data Processing Policy

4.3 Imposition of this policy

4.4 Express and unequivocal consent

4.5 Data processing consent

 

 1. General information

The purpose of this data privacy policy is to provide you with information about the processing of personal data when using our site and related services. This privacy policy applies to all sites or services that relate to this privacy policy.

The site and/or software and/or sofiaman.ro represents the website belonging to SOFIAMAN IMPEX SRL, Str. Marasesti, Nr. 215, Târgu Neamț, through which the user has access to information, services and software offered by SOFIAMAN IMPEX SRL, through the sofiaman.ro website, Facebook pages and its related domains.

We reserve the right to modify this document whenever necessary without prior notice. Any modification made to this document enters into force immediately after its publication on the site. Users of the site will be informed about the modification of this document directly on the site, or as the case may be, by e-mail. Notwithstanding the above, if the User of the site continues to use the site after a change in this document has occurred, it is considered that the User agrees with the changes made.

Please note that by accessing our site, you unconditionally accept:

1) Privacy Policy,

2) Cookies Policy

as well as

3) General Terms and Conditions of use of the site and software.

If a User does not agree with one or all of the conditions set forth in the General Terms and Conditions of Use of the site or with the Privacy Policy and / or Cookies Policy, he may not use the site and related software, and it is recommended that you stop using this site.

We strive to ensure the protection of your privacy when you use our services. Therefore, we have a policy designed to determine how your personal data will be processed and protected.

 

1.1. Personal data processing

Personal data within the meaning of Article 4 of the General Data Protection Regulation (GDPR) are all information relating to an identified or identifiable natural person, such as name, address, email address, etc.


1.2. The personal data operator

The person responsible for the processing of personal data within the meaning of Art. 4 (7) of the GDPR is: SOFIAMAN IMPEX SRL with its registered office in Str. Marasesti, Nr. 215, Târgu Neamț, Registration number for VAT purposes: RO4536401, Registration number at the Trade Register: J27 / 105/1996 email: office [at] sofiaman.ro

The contact details of the data protection officer are: office sofiaman.ro or at the postal address of the personal data controller to the attention of the "Personal Data Protection Officer".


1.3. The rights of data subjects

As a person affected by the data processing activity, you benefit from the following rights in connection with your personal data, in accordance with the legal provisions

Right of access;

Right of rectification and deletion;

The right to restrict processing;

The right to data portability;

The right to oppose.

In addition, you have the right to lodge a complaint with a supervisory authority regarding the processing of your personal data.

When we work on the above right, we can ask you for proof of your identity. For more information about how we process your data, see 3.1.


1.4. Disclosure of data to authorities

In the event of a legal obligation, we reserve the right to disclose information about your personal data to the competent authorities or to the law agencies that request it.

Legal basis Art. 6 (1) c) GDPR.


2. Collection and processing of personal data when you visit our site

When you visit and use our site solely for informational purposes, (for example, if you do not register or otherwise provide us with information) we will only collect personal data that your browser transmits to our server, which are technically necessary to be able to display your site and to guarantee stability and technical security.

We transfer the collected data to the relevant internal departments, for processing, and to other companies external service providers, contractors (eg: site hosting - hosting, content management system - Opencart) depending on the purpose (for displaying the site and setting the content).

Processing basis:

Our legitimate interest in improving our Platform and in managing the capabilities of the server and in maintaining our Platform without errors (GDPR, art. 6 paragraph. 1, letter f);

Fulfilling the legal duties regarding the security aspects of our systems (GDPR, art. 6 paragraph 1, letter c).


2.1 Cookies

In addition to the data mentioned above, cookies and other similar storage technologies such as pixel-s (hereinafter referred to as "Cookies") are installed on your computer when you visit and use our site.

Cookies are small text files that are stored by the browser on your device (in order to save certain information) or image files (img), such as pixels. The next time you visit our site on the same device, the information saved in cookies will be transmitted later either to our site ("First Party Cookie") or to another site to which those cookies belong ("Third Party Cookie"). ”).

Through the saved and returned information, that site acknowledges that you have already accessed and visited it through the browser you use on that device. We use this information to be able to develop and display the site optimally, according to your preferences. In this regard, only the cookie itself is identified on your device. Beyond this limit, your personal data will be saved only with your explicit consent or if absolutely necessary in order to use the services offered and accessed by you properly.

Our site uses the following types of cookies, the scope and functionality of which are explained below:

Strictly necessary cookies (eg session cookies, shopping cart save)

Performance cookies (functionality) (eg traffic analysis, conversion analysis)

Management cookies, based on agreement (eg: Marketing, Advertising)

More information on the types of cookies set and used can be found in this data privacy policy.


2.1.1 Strictly necessary cookies (essential)

Strictly necessary cookies guarantee the functions without which you cannot use the pages of our site. These cookies are used exclusively by us and are therefore "First Party Cookies". This means that all information stored in cookies is reproduced on our website.

Strictly necessary cookies serve, for example, to ensure that you are always logged in as a registered user when you access various subpages on our site. Therefore, you will not need to enter your registration details every time you access a new page.

The use of these types of cookies on our site is possible without your consent. For this reason, strictly necessary cookies cannot be activated or deactivated individually. However, you have the option to disable them from your browser at any time.

Legal basis: Art. 6 (1) b of the GDPR.


2.1.2 Functionality and performance cookies

Functionality cookies allow the site to retain information already provided (such as username or selected language) and to provide you with optimal and personalized features, based on this information. These cookies only collect and keep anonymized information, which means that they do not track how you browse other sites.

Performance cookies collect information about how the pages of the site are used, in order to increase their attractiveness, content and functionality. Such cookies help us, for example, to determine if the subpages of our site are visited, which of them are visited and what type of content is of interest to users. In particular, we record the number of visits to a page, the number of web pages that are accessed, the time spent on the site, the sequence of pages visited, what keywords brought you to the site, country, region and, if applicable, city or town. the city from which the pages were accessed, as well as the proportion of mobile terminals that access the pages of the site. We also record movements such as "clicks" and "scrolling" to understand which areas of the site are of higher interest to users. As a result, we can adjust the content of the site according to the requirements of our users to give them a personalized experience. You can adjust your cookie settings at any time (on or off).

Legal basis: Art. 6 (1) f of the GDPR.


2.1.3 Targeting cookies, based on agreement (Advertisement, Advertising)

Cookies that are neither strictly necessary nor for the purpose of functionality or performance will be used only with your explicit consent, for example, marketing and advertising cookies.

Thus, we reserve the right to use the information we obtain with the help of cookies from an anonymous analysis of user behavior on our site, to display specific advertising material for certain products. We believe that, as a user, you benefit from this functionality because we display advertising material or content that we believe is appropriate to your interests, based on your browsing behavior. Thus, you will not see randomly displayed advertising material or content that may be of less interest to you.

Marketing cookies come from external advertising companies ("Third party cookies") and are used to collect information about the sites visited by the user, in order to display targeted advertising on target groups for the user.

Disclaimer of cookies used for online advertising

You can manage the cookies of online advertising companies with the tools available through self-regulatory programs in many countries, such as in the EU http://www.youronlinechoices.com/ro/your-ad-choices.

You can withdraw your consent to the use of cookies based on the agreement (Advertising and Advertising) at any time, with effect for the future, by changing the cookie settings accordingly.

Legal basis: Art. 6 (1) of the GDPR.


2.1.4 Management and deletion of all cookies

You can set your web browser so that cookies cannot generally be saved on your device and/or you are asked each time if you agree with their activation. You can also delete cookies that you have previously activated at any time. You can learn more about these options from the help function of your browser.

Please note that, in general, disabling cookies may lead to restrictions on the operation of our site.


2.2 Web analytics service (Analytics)

2.2.1 Google Analytics

This website uses Google Analytics, a web analytics service owned by Google Inc. (“Google”). Google Analytics uses a specific form of cookie that is stored on your computer and allows you to analyze how you use the site. The information generated by cookies regarding the use of this site is generally transmitted to a Google server in the USA and stored there.

Google uses this information on our behalf to analyze your use of this site, to compile reports on site activity, and to provide additional services related to your use of the site and your use of the internet by your site operator. Google may also transfer this information to third parties, as required by law, or where such third parties process such data on Google's behalf.

You can prevent the storage of cookies by setting the appropriate settings in the browser used. In addition, you can prevent Google from registering data generated by cookies about how you use the site (including your IP address), as well as their processing, by downloading and installing the browser plug-in available at https://tools.google.com/dlpage/gaoptout?hl=en.

Google Information: Google Dublin, Google Ireland Ltd, Gordon House, Barrow Street, Dublin 4, Ireland, Fax: +353 (1) 436 1001. Google Analytics Terms of Service: https://www.google.com/ analytics / terms / gb.html, overview of security and privacy principles applicable to Google Analytics: https://support.google.com/analytics/answer/6004245?hl=en, but also Google's data privacy policy: https : //policies.google.com/privacy? hl = en.

In addition, this site uses the Google Analytics service for a traffic analysis, independent of the device from which the site is accessed, based on the user ID (User ID). You can turn off multi-device tracking of how you use the site in your Google Account in the "My Information", "Personal Information" section.

Cookies used: type of functionality and performance.

Duration of cookies: up to 12 months (this provision applies exclusively to cookies that have been set by this website).

Maximum data retention period: up to 26 months.

Legal basis: Art. 6 (1) f of the GDPR.

Data transfer: Intracomunitar EU (Ireland - Google Ireland)

Google Analytics advertising features

If you agree to the use of Google Analytics advertising features, this site uses extended Google Analytics features in addition to the standard features. The Google Analytics advertising features implemented on this site include demographic reports and Google Analytics interest reports.

We use Google Analytics to analyze and regularly improve the operation of our site. We can use the statistics obtained to improve our offer but also to make it more interesting for you, as a user. In addition, we obtain information about the functionality of our site (for example: page navigation problems).

You can prevent participation in this tracking process in several ways:

a) by setting your browser software accordingly;

b) through your Google ad settings at https://www.google.com/ads/preferences/?hl=en_US;

c) setting the cookie preferences accordingly. Please note that in this case you may not be able to fully use all the features of this offer.

Storage period: up to 26 months. Legal basis: Art. 6 (1) of the GDPR.

Data transfer: Intracomunitar EU (Ireland - Google Ireland)


2.3 Online advertising

2.3.1 Google Ads (formerly Google Adwords)

2.3.1.1. Google Ads Conversion

We use Google Ads services to draw attention to our promotional offers, with the help of advertising materials (so-called Google Ads) on external sites. We can determine, in relation to the data coming from the advertising campaigns, the degree of success achieved by certain concrete advertising measures. We are interested in showing you ads that are of interest to you, to make our site more interesting to you, and to make a correct calculation of advertising costs.

The advertising materials are delivered by Google through the so-called "Ad Servers". For this purpose, we use ad server cookies, through which certain parameters can be measured to quantify success, such as displaying ads or clicks per user. If you access our site through a Google advertisement, the Google Ads application keeps a cookie on your device. Generally, these cookies expire after 30 days and are not intended to identify you personally. For this cookie, the unique cookie identification code, the number of impressions per placement (frequency), the last impression (relevant to post-view conversations) and the opt-out information (which indicates that the user no longer wishes to be contacted) are retained. usually in the form of analysis values.

These cookies allow Google to recognize your Internet browser. If a user visits certain pages on a Google Ads customer site and the cookies stored on their device have not expired, Google and the customer may acknowledge that the user clicked on the ad and was redirected to that page. Each Google Ads Client is assigned a different cookie. Therefore, cookies cannot be tracked through Google Ads client sites. We do not collect or process personal data through the advertising means mentioned above. We only receive statistical analysis from Google. Based on these analyzes, we can recognize which of the advertising media used are most effective. We do not receive any additional data as a result of the use of advertising material; in particular, we cannot identify users based on this information.

Through the marketing tools used, your browser automatically initiates a direct connection to a Google server. We have no influence on the extent of use and subsequent use of the data that is collected through the use of this tool by Google and, accordingly, inform you to the best of our knowledge: by integrating the Google Ads conversion application, Google receives information that you have accessed a corresponding part of our appearance on the Internet or you clicked on one of our ads. If you are registered with a Google service, Google may associate your visit with your account. Even if you are not registered with Google or you are not logged in to your account, providers may be able to obtain and retain your IP address.

Cookies used: Advertising and Publicity.

For more information, you can see the Cookies section.

Cookie validity period: up to 2 years (this provision applies exclusively to cookies that have been set by this website). Legal basis: Art. 6 (1) of the GDPR.

Data transfer: Intracomunitar EU (Ireland - Google Ireland)


2.3.1.2. Google Ads Retargeting

We use the retargeting functionality in the Google Ads service. This feature allows us to show users of the platform ads based on their interests on other platforms (websites) within the Google network (in the Google search engine or the YouTube platform, the so-called ‘Google Ads’ or on other websites). For this purpose, we analyze the interaction of users with our platform (example: why offers was the user of interest) in order to display targeted ads to users who have visited our platform on other websites. To do this, Google stores a number in the search engine of users who access certain Google services or websites in the Google Display Network. This number, also known as a ‘cookie’ is used to record the visits of these users. This number is used to identify a search engine on a particular device and not to identify a person; personal data is not stored.

You can prevent participation in this tracking process in several ways:

a) by setting the browser correctly, especially by disabling third party cookies, you will not receive any announcements from third party providers;

b) by disabling conversion tracking cookies, by setting your browser so that cookies are blocked on the domain www.googleadservices.com, https://www.google.de/settings/ads, setting that will be deleted when you delete cookies;

c) by disabling ads based on the interests of suppliers that are part of the self-regulatory campaign "About Ads" using the link http://www.aboutads.info/choices, a setting that will be deleted when delete cookies;

d) by permanently disabling ads in Firefox, Internet Explorer or Google Chrome using the link http://www.google.com/settings/ads/plugin,

e) by setting your cookie preferences accordingly. In this case, you will not be able to use all the functions in this offer in full.

For more information on the purpose and extent of the collection, processing and subsequent use of data by Google, please refer to the data privacy policy. You will find out more about your rights in this regard and about the setting options to protect the privacy of your personal data.

Cookies used: Advertising and Publicity.

For more information, you can see the Cookies section.

Cookie validity period: up to 2 years (this provision applies exclusively to cookies that have been set by this website).

Legal basis: Art. 6 (1) of the GDPR.

Data transfer: Intracomunitar EU (Ireland - Google Ireland)


2.3.2 Google Remarketing

We may use the Google Remarketing application to contact you again within the next 12 months. With this application, after visiting our site, our ads can still be shown to you while you browse the Internet. This is done through cookies stored in your browser, used to record and evaluate your user behavior by Google when visiting various sites. This way, Google can establish your previous visits to our site. According to Google's own statements, Google does not combine the data collected in the context of remarketing with your personal data, which may be stored by Google. According to Google, the pseudonym remarketing procedure is used.

You can prevent participation in this tracking process in several ways:

a) by setting the browser correctly, especially by disabling third party cookies, you will not receive any announcements from third party providers;

b) by disabling conversion tracking cookies, by setting your browser so that cookies are blocked on the domain www.googleadservices.com, https://www.google.de/settings/ads, setting that will be deleted when you delete cookies;

c) by disabling ads based on the interests of suppliers that are part of the self-regulatory campaign "About Ads" using the link http://www.aboutads.info/choices, a setting that will be deleted when delete cookies;

d) by permanently disabling ads in Firefox, Internet Explorer or Google Chrome using the link http://www.google.com/settings/ads/plugin,

e) by setting your cookie preferences accordingly. In this case, you will not be able to use all the functions in this offer in full.

Cookies used: Advertising and Publicity type.

For more information, you can see the Cookies section.

Legal basis: Art. 6 (1) of the GDPR.

Data transfer: Intracomunitar EU (Ireland - Google Ireland)


2.3.3. Campaign Manager (Doubleclick)

This website also uses the (instrumental) online marketing tool Campaign Manager Google. Campaign Manager uses cookies to display relevant ads to users, to improve reports on campaign performance, or to prevent a user from seeing the same ad multiple times. Google uses a cookie identifier to track which ads have been shown in the search engine and prevents these ads from showing on multiple occasions. In addition, Campaign Manager may use cookie identification files to collect conversion information based on ad requirements. In this case, for example, when a user views a Campaign Manager ad for a product, service, etc. and then access the website with the same search engine (browser) and buy that product, service, etc.

According to Google, cookies, Campaign Manager do not contain personal information.

Your search engine (your browser) automatically accesses a direct connection to the Google server when you visit our website. We cannot influence in any way the level or how the data collected by Google will be used by using this tool. This is how we inform you accordingly: By integrating Campaign Manager, Google receives information that you have accessed correspondence of our online presence or clicked on an advertisement. If you're registered with one of Google's services, Google may associate your visit with your Google Account. Even if you are not registered or logged in, providers may obtain and store your IP address.

In addition, Campaign Manager cookies (DoubleClick Floodlight) allow us to understand if you take certain actions on our website (our platform) after viewing one of our ads in Google display / video or on other platforms, by Campaign Manager or if you have accessed any of them (conversion tracking). Campaign Manager uses cookies to understand what content you interacted with from the website in order to send targeted ads.

You can prevent participation in the tracking process through several ways (methods):

a) By setting the appropriate search engine software, in particular by disabling third-party cookies, advertisements from third-party providers will no longer be displayed;

b) Disabling cookies for tracking conversions by setting your browser so that cookies are blocked by the domain www.googleadservices.com, https://www.google.de/settings/ads. This setting is deleted when you delete cookies;

c) Disabling third party vendor-based ads that are part of the ‘About Ads’ campaign, which can be accessed at http://www.aboutads.info/choices. This setting is deleted when you delete cookies.

d) Permanently disabling Firefox, Internet Explorer or Google Chrome under the link http://www.google.com/settings/ads/plugin or Setting cookie preferences. in this case all functionality of this offer will not be valid.

In addition, you can prevent Google from collecting information generated by cookies and transmitting your use of websites and processing this data by Google by downloading and installing the plugin available under 'Display settings',' Extension for Campaign Manager Deactivation at https://support.google.com/adsense/answer/142293?hl=en.

Cookies type files used: Advertisement type.

For more information, see the Cookies section.

Legal basis: Article 6 (1) GDPR

Data transfer: Intracomunitar EU (Ireland - Google Ireland)


2.3.4 Facebook Custom Audiences ("Facebook Pixel")

This site uses Facebook Inc.'s "Custom Audiences" remarketing feature. ("Facebook") to contact you again in the next 12 months. This allows website users to see advertisements based on their stated interests ("Facebook ads") when visiting the social network Facebook or other websites, which also use this tool.

Your browser automatically establishes a direct connection to the Facebook server. We have no influence on the extent and subsequent use of the data collected by Facebook by using this tool, and therefore inform you based on our level of knowledge: by including Facebook's "Custom Audiences" feature, Facebook receives information that you have accessed the site. corresponding to our Internet presence or you clicked on one of our ads. If you are registered with a Facebook service, Facebook can associate your visit with your account. Even if you are not registered with Facebook or you are not logged in to your account, there is a possibility that the providers can obtain and keep your IP address, as well as other identifying information.

The "Facebook Custom Audiences" function can be deactivated in the cookie settings, and for the authenticated users, at https://www.facebook.com/settings/?tab=ads#_.

Cookies used: Advertising and Publicity type.

Place of processing: Intracomunitar EU Meta Ireland - Privacy policy: https://www.facebook.com/about/privacy/

Legal basis: Art. 6 (1) of the GDPR.


2.4 Google Tag Manager

This site uses the Google Tag Manager service. This service allows site "tags" to be managed through an interface. Google Tag Manager only implements tags. This means that no cookies are used and no personal data is collected. Google Tag Manager triggers other tags, which in turn collect data as needed. However, Google Tag Manager does not access that data.

Place of processing: Intracomunitar EU -  Google Ireland, Privacy policy: https://policies.google.com/privacy


2.5 Captchas (reCAPTCHA)

This site uses Google reCAPTCHA v3 in some cases to avoid the use of text fields by bots or automated programs. In this way, the security of the site is improved and SPAM for users is avoided. This is also our legitimate interest, but also our legal obligation.

The data collected is hardware and software information, such as information about the device and applications, but also the results of integrity checks. The data will not be used by Google for personalized ads.

Place of processing: Intracomunitar EU - Google Ireland, Privacy policy: https://policies.google.com/privacy

Legal basis:

Art. 6 (1) c of the GDPR (data processing agreement with a legal obligation)

Art. 6 (1) f of the GDPR (data processing according to the legal interest mentioned above).

2.6 Online communication services (Whatsapp Facebook Messenger)

We can also be contacted on Facebook Messenger or Whatsapp in order to solve some of your requests, in order to offer support in certain situations, or in order to provide information about products.

Data collected: Name, Delivery address, Phone number, Email, analytics (IP, browser, location), tracking cookies

Processing purpose: Order processing, requesting information about items

Processing basis: Art. 6 paragraph 1 letter a)

Shelf life: maximum 3 years

Sharing with third parties: Whatsapp, Facebook Messenger (Meta Ireland)

Place of processing: Meta Ireland.


2.7 Backup storage systems (Hezner)

Data collected: Site account data, Order data, IP, Address, Phone number, Email

Purpose of processing: Data protection and security

Processing basis: Art. 6 paragraph 1 letter f) GDPR

Shelf life: maximum 3 years

Sharing with third parties: Hezner, Germany.

Privacy Policy: https://www.hetzner.com/de/rechtliches/datenschutz


2.8 Data and site security systems

The security of your Personal Data is important to us. Therefore, your Personal Data will be processed by applying reasonable technical and organizational measures to protect it, such as limiting access to Personal Data, encrypting or anonymizing Personal Data, storage on secure media. However, despite our best efforts, we cannot always guarantee the effectiveness of the security measures implemented, and therefore we cannot guarantee the security of Personal Data at any time.

Data collected: IP, Site requests, Site activity

Processing purpose: Data security

Processing basis: Art. 6 paragraph 1 letter f) GDPR

Shelf life: maximum 3 years

Data transfer: Cross-border USA, Canada or other countries outside the European Economic Area. As an adequate protection measure, we agreed on the standard contractual clauses in accordance with art. 46 GDPR with these providers.


2.9 Opencart and Opencart plugins

Opencart is a "personal publishing" software platform and content management system (CMS), a program that runs on the server and allows the creation and distribution of a website of textual or multimedia content, easy to manage and dynamically updatable.

By default, Opencart does not collect personal visitor data and only collects data displayed on the Registered User Profile screen.

For users who register on the website (if registered users are present), the personal information they provide in their user profile is also stored. All users can view, edit or delete personal information at any time (except the username they cannot change). Website administrators can also view and edit this information.

We have integrated other Opencart plug-ins to facilitate the process of selling our products and services. Opencart is an open-source platform for publishing sites.

The operator of Opencart is OpenCart Limited, headquartered in Tuen Mun Central Square, 22 Hoi Wing Road, Tuen Mun, Hong Kong.

Data transfer: Intracomunitar EU - servers located in Europe


3. Online Store

In addition to the purely informative use of our site, we offer you various other products and services, for which we process your personal data.

If we call on contracted service providers for specific functions we offer or if we wish to use your data for advertising purposes, we will inform you in detail about the respective processes below.


3.1 Contact / Communication

Purpose / Information:

When you communicate or collaborate with us, for example by e-mail or through the contact form on our website, through chat services  the data you provide us (e-mail address, if applicable name and telephone number, or personal data transmitted during the conversation - such as address, telephone) they will be stored and processed for - for example answering your questions, requests to execute orders, for the purpose of business correspondence.

We will delete the data in this context after storage is no longer required, unless there are legal retention obligations or prescription periods must be observed.

Purpose of processing: Contacting the customer online in connection with the requested offer or in connection with solving the indicated problem.

Legal basis: Execution of a contract to which the data subject is a party or to take steps at the request of the data subject before concluding a contract (art. 6, paragraph 1, letter b of the GDPR).

Recipients:

We process your data within the company for internal communication and for appropriate administrative purposes. You may be subject to such processing. In the case of requests from data subjects through our internal consumer management tool, personal data will usually be deleted after three years. Exceptionally, the data will be retained longer if it is necessary to establish, exercise or defend legal claims.

We transfer the collected data to the internal departments responsible for data processing and to other companies providing external service providers, persons authorized by the operator, on a contract basis (eg hosting service providers, call centers, accounting services) depending on the necessary purposes ( for example, for establishing contacts, business correspondence and customer support).

Providers who will have access to personal data are from EEA - Hotjar Malta.

See their privacy policy: https://www.hotjar.com/legal/policies/privacy/

Delete / objection:

We delete the resulting data in this context, after storage is no longer necessary, unless there are legal retention obligations or retention periods must be observed. In the case of consumer requests through our internal consumer management tool, personal data will usually be deleted after three years. Exceptionally, the data will be kept longer if the data is necessary for the establishment, exercise or defense of legal rights. You may object to these processes in accordance with the requirements of point 4.


3.2 Ordering and delivery of products

3.2.1 Making the payment

Personal data processed: name, surname, payment amount, bank card details. We do not store bank card data on our servers

Purpose of processing

Legal grounds

The payment for the purchased goods.

Execution of a contract to which the data subject is a party or to take steps at the request of the data subject before concluding a contract (art. 6, paragraph 1, letter b of the GDPR)

Processing time: Until payment is made.


3.2.2 Delivery of the order

Personal data processed: name, surname, products purchased, delivery address, telephone number, any additional information provided by the customer. 

Purpose of processing

Legal grounds

Order shipping

Execution of a contract to which the data subject is a party or to take steps at the request of the data subject before concluding a contract (art. 6, paragraph 1, letter b of the GDPR)

 Processing time: 12 months.


3.2.3 Adding to the shopping cart

Personal data processed: name, surname, product added.

Purpose of processing

Legal grounds

Adding the product in the shopping cart.

Execution of a contract to which the data subject is a party or to take action at the request of the data subject before concluding a contract (art. 6, paragraph 1, letter b of the GDPR)

 Processing time: until the order is completed or until the products are removed from the basket.

3.2.4 Placing the order

Personal data processed: name, surname, products purchased, delivery address, telephone number, e-mail address, any additional information provided by the customer.

Purpose of processing

Temeiul legal

Completing and placing the order

Execution of a contract to which the data subject is a party or to take action at the request of the data subject before concluding a contract (art. 6, paragraph 1, letter b of the GDPR)

Processing time: 36 months.


3.2.5 Issuance of the invoice

Personal data processed: name, surname, home address, products purchased, payment amount.

Purpose of processing

Legal ground

Issuing the invoice related to the purchased products

Fulfillment of a legal obligation of the Company (art. 6, paragraph 1, letter c of the GDPR)

Details: fulfillment of tax obligations

Processing time: 10 years.


3.3 User account

3.3.1 Creating the user account

Personal data processed: name, surname, e-mail address.

Purpose of processing

Legal ground

Creating the user account

Execution of a contract to which the data subject is a party or to take action at the request of the data subject before concluding a contract (art. 6, paragraph 1, letter b of the GDPR)

Processing time: the duration of the account existence.

3.3.2 Completing the user profile

Personal data processed: user image, other personal information.

Purpose of processing

Legal ground

Filling the user profile

Consent of the data subject (art. 6, paragraph 1, letter a of the GDPR)

 Processing time: the duration of the account existence.


3.3.3 Order history

Personal data processed: name, surname, order date, ordered products, payment amount.

Purpose of processing

Legal ground

Displaying order history

Execution of a contract to which the data subject is a party or to take action at the request of the data subject before concluding a contract (art. 6, paragraph 1, letter b of the GDPR)

 Processing time: the duration of the account existence.

 

3.4 Newsletter / Email via Mailchimp

Purpose / Information collected: email, name, surname, tracking cookies

The newsletter contains news, offers and other information about our products. By subscribing to the newsletter, (you will receive it in accordance with the consent you have given in each case), you will benefit from personalized information about our products and services or proposals to participate in campaigns, price reductions, such as raffles or product testing.

Once you sign up for the newsletter, you will receive a personalized newsletter based on your needs (whether the newsletter is individualized or personalized). We evaluate your behavior on our website or in the newsletter, in order to synthesize information relevant to you.

We also use remarketing features to show you relevant online ads.

Place of processing: Transfrontalier, USA.

As an adequate protection measure, we agreed on the standard contractual clauses in accordance with art. 46 GDPR with these providers. More information on this topic is published here https://mailchimp.com/legal/data-processing-addendum/

The data will be sent to the management platform of our customers, which can be accessed by external service providers, for the creation and setting of the newsletter.

Delete / objection

This collected data is automatically deleted after 18 months, if a user no longer responds to the newsletter, for example no newsletter is opened for a period of 18 months (inactivity). If you don’t with to receive our newsletter, you can unsubscribe at any time. Access the link included in each newsletter and you will be redirected to the unsubscribe process or you can send us by email your request..

Additional information about the data protection provided by MailChimp can be found at: https://mailchimp.com/legal/privacy/. Relationships regarding personal data can be requested from personaldatarequests@mailchimp.com

Address: The Rocket Science Group LLC 675 Ponce de Leon Ave NE Suite 5000 Atlanta, GA 30308 USA

Legal basis: Art. 6 (1) of the GDPR.


3.5 Login profile (Wishlist)

Purpose / Information:

By registering on the site, we offer you the opportunity to create a list of your favorite products and receive an informative newsletter. In addition, we will only provide you with personalized content in the future, based on your behavior and history; you agree that your data will be stored and used for purposes related to surveys / market research and advertising. We can then send you personalized advertising with the products or services in your portfolio.

Containers:

We transfer the collected data to the internal departments responsible for data processing and to other companies external service providers, persons authorized by the operator, on a contract basis (eg hosting service providers, shipping, processing, newsletter) depending on the necessary purpose (for conducting the advertising campaign, etc.).

Platform / Hosting providers that will have access to personal data may also be from a third country (countries outside the European Economic Area). As an adequate protection measure, we agreed on the standard contractual clauses in accordance with art. 46 GDPR with these providers.

Delete / objection:

Your data will be deleted immediately after you delete your account, unless this is contrary to the legal obligations to keep data or limitation periods. To delete your data, please log in to your customer account and use the delete function or send us the intention to cancel the processing of data by email. We will delete your personal data automatically after 24 months of inactivity.

Legal basis: Art. 6 (1) of the GDPR.


3.6 Ratings and reviews, Feedback

Purpose / Information:

Registered users have the opportunity to submit ratings and reviews for products, processes or other assessments that are the subject of offers presented on the site, in compliance with the terms of use. It is in our legitimate interest for users to be able to freely express their opinion about our products.

Your reviews may be posted next to your username. Reviews are checked before publication. We reserve the right to delete comments if they are considered illegitimate by third parties.

Recipients:

We transfer the collected data to the internal departments responsible for data processing and to other external service providers, persons authorized by the operator, on a contract basis (eg hosting service providers, dispatch, processing) depending on the necessary purpose (for publication on site).

Your data will be deleted as soon as you log out of the program, unless this is in conflict with your legal storage obligations or limitation status. To delete your data, log in to your customer account and complete the unsubscribe process or send your withdrawal to data processing via email.

Delete / objection:

Comments can be deleted based on the appropriate login account.

The legal basis is Art. 6 (1) f of the GDPR


3.7 Postal correspondence

Purpose / Information:

As a customer selected business partner, tester and / or consumer, you will also receive individual product information, news offers and product samples from us by mail (letter).

This is a special form of direct marketing, which is also in our legitimate interest and enhances customer and consumer loyalty by providing exclusive information to the people mentioned above.

Delete / objection:

Your data will be deleted as soon as you unsubscribe, unless this conflicts with your legal storage obligations or limitation status. You can unsubscribe or object to subsequent mailings, as stated in the letter or objection below [link to 4. objection]. We will automatically delete your personal data after 24 months of inactivity (for example, when you do not use sent coupons).


3.8. Dispute resolution

Purpose / Information:

Personal data processed: name, surname, home address.

Purpose of processing

Legal ground

Defending legitimate rights and interests and upholding any claims before the judiciary or any other public authority

The legitimate interest of the Company (art. 6, paragraph 1, letter f of the GDPR)

Details: the legitimate interest of the company to defend the rights or legitimate interests or to support the claims resulting or closely related to the conclusion or execution of the contract or to exercise the right of defense in case of initiating litigation against the company.

Processing time: the time required to resolve the dispute.


3.9. Recruitment

Purpose / Information:

When you contact us for a position in our company, in order to conclude the individual employment contract or any other contract that produces effects similar to it, and after their conclusion, during the employment relationship, we will collect from you the following personal data:

identification data included in the CV;

contact details (e.g., name, phone number, email);

data entered in the submitted CV (including education, professional experience, hobbies);

other information you provide during the interviews (if applicable).

Activities related to the recruitment process may consist of:

evaluating the general training and compatibility within our company and for the desired position;

contacting about your application, including about the positions that become available later and for which we consider that you have the right professional profile;

evidence of any previous recruitment processes of ours in which you participated and of the reasons why you were not offered a job offer or for which the offer was rejected;

any other activities related to the good administration of the recruitment process, if they are compatible with those mentioned.

We inform you that there are no negative consequences for you, insofar as you decide not to provide us with this personal data. However, your personal data is necessary for the recruitment process, in which case if you do not provide us with this data, we cannot continue the process.

We collect personal data that you provide to us voluntarily, related to the time of sending your application, as well as later, at the time of the interview and / or evaluation. Auxiliaryly, we collect personal data necessary for recruitment and through recruitment sites and agencies (ie BestJobs, Ejobs, Hipo, Indeed jobs, LinkedIn, Adecco Romania SRL, CVO Recrutiment, Qualia or other recruitment agencies), if which you applied for a job posting on such a site or I found your resume on such a site.

Thus, your personal data is collected either from you orally, through written forms, by phone or email, or from our suppliers or through the recruitment platforms used by us.

Recipients:

For the processing of personal data we can use suppliers for business administration, for example, recruitment agencies (CVO Recruitment) to which we transmit your personal data in order to carry out the first stages of the recruitment process. Thus, we have concluded with these providers personal data processing agreements with appropriate clauses to ensure that the data processing is done in full compliance with applicable laws. Subsequently, in order to perform the recruitment, the supplier will perform the first stages of the recruitment process, and if necessary, he will send us the result of the first stages of your recruitment process for the position you applied for.

Delete / objection:

Personal data will be stored for a limited period of time, of 3 years, for its establishment taking into account the time of completion of the recruitment process and our legitimate interest in keeping the data of rejected candidates for the possible settlement of complaints or requests. Exceptionally, the data will be kept longer if the data is necessary for the establishment, exercise or defense of legal rights.

However, if you will not be recruited for the position in question, we will be able to process your personal data for the purpose of contacting you, for a period of up to 2 years from the time of completion of the recruitment process, when you have expressed your interest in being contacted in the future in order to be informed of other opportunities that might interest you. You may withdraw your consent to this in accordance with the requirements of point 4.

Legal basis:

Art. 6 (1) b GDPR (data processing in the context of a contract or a situation similar to a contract)

Art. 6 (1) f GDPR (data processing according to the legitimate interest mentioned above).


3.10 SMS notification system

Purpose / Information:

We can share your phone number with external courier service providers for pre-delivery notification and preparation for delivery in the best conditions.

Data collected: Telephone number

Purpose of processing: Notifications related to the execution of orders and services on the site.

Processing basis: Art. 6 paragraph 1 letter a) GDPR

Processing time: maximum 3 years

Third party sharing: external providers for courier services.


3.11 Methods of payment by card (Mobilpay)

This site does not store card data. We use the integrated payment service (Mobilpay) in order to process payments.

The Mobilpay payment service is operated by the company NETOPIA Payments SRL, registered at the Trade Register under no. J40 / 9170/2003, unique registration code RO15565496, based in Bd. Dimitrie Pompeiu 9-9A, IRIDE BUSINESS PARK, Building 24, floor 4, Sector 2, Bucharest, 020335, which acts as owner and administrator of the platform NETOPIA Payments.

The company has appointed a Data Protection Officer (DPO), who can be contacted at gdpr@netopia.ro.

The legal basis for the use of these services is Art. (6) (1) (f) of the GDPR.


3.12 Courier services

In order to ship the orders placed by you, we use the following means: Own distribution network and express courier services.

Your data (name, address, telephone, order value, payment method) are shared with these services in order to execute the contract, in this case the delivery of the ordered products.

The legal basis for the use of these services is Art. (6) (1) (f) of the GDPR.


3.13 Banking services

Your data is shared with our banking service provider when we record payments in your account. They are protected by contractual clauses regarding the Protection of personal data.

The legal basis for the use of these services is Art. (6) (1) (f) of the GDPR.


3.14 Financial accounting services

For financial accounting services, our company can collaborate with outsourced providers of accounting services, who have access to personal data in order to prepare the financial-accounting statements required by law.

The legal basis for the use of these services is Art. (6) (1) (f) of the GDPR.


3.15 Email hosting services

Our company uses messaging services (e-mail) with the cloud computing component. The personal data, which you (as a client / proxy / beneficiary of our services / contractual partner) provide us in the interaction with us, may be the subject of our internal communication through the persons authorized by us.

They assume specific obligations regarding the security of the data stored on the servers on which they operate, take adequate and reasonable internal measures - technical and security - against unauthorized access, exposure, distribution, destruction or accidental loss of data.

The legal basis for the use of these services is Art. (6) (1) (f) of the GDPR.


3.16 Site hosting services (Hetzner)

The web hosting service provider of the site (s) assumes specific obligations regarding the security of the data stored on the servers on which it operates.

It assumes specific obligations regarding the security of data stored on the servers on which it operates, and takes appropriate and reasonable internal measures - technical and security - against unauthorized access, exposure, distribution, destruction or accidental loss of data.

More details can be found here: https://www.hetzner.com/rechtliches/datenschutz

The legal basis for the use of these services is Art. (6) (1) (f) of the GDPR.


4. Withdrawal of the agreement for the processing of personal data

If the activity of processing your personal data is based on the evaluation of interests (Art. 6 (1) f of the GDPR), you can oppose the processing. This situation applies if the processing activity is not specifically required for the conclusion of a contract between the parties, detailed in the description of the functions and services below. If you exercise your right to file such an objection, we will ask you to explain why we should not process your personal data as before. In the event of a justified opposition on your part, we will analyze the situation and either stop or adjust the data processing, or we will point out the reasons that oblige us to data protection, and based on this justification we will continue the processing activity.

Of course, you can object to the processing of your personal data for advertising and data analysis purposes, at any time. You can inform us about your opposition using the contact details mentioned above of the personal data controller


4.1 Exemption from liability

The site (s) may contain links to other sites and / or other web pages that are not the property of our company. Therefore, we do not assume any responsibility for the content of these sites and, therefore, we cannot be held responsible for the content, advertising, goods, services, software, information or other materials available, presented or marketed. through these sites.

At the same time, we will not be responsible for the loss of personal data, for any negative effects on the personal data of visitors or for other moral and / or patrimonial damages caused by the access to the respective sites.


4.2 Updating the Personal Data Processing Policy

Please keep in mind that this Personal Data Protection Policy may be subject to periodic content changes by updating the site (s).

Please check the policy and the date of the last change periodically, and if you do not agree with this, please do not continue to use our site (s).

The terms of this policy shall be construed in accordance with applicable law.

We reserve the right to periodically update and amend this Policy to reflect any changes to the way we process personal data or any changes to legal requirements without prior notice.

In the event of any such changes, the organization will display the amended version of the Policy on the site, for which reason Users are asked to periodically check the content of this Policy to take note of its new provisions.


4.3 Imposition of this Policy

If you have any questions regarding the Privacy Policy or you wish to be informed about the personal data processed by us and which concern you directly, please contact us using the data above.


4.4 Express and unequivocal consent

By accepting this consent form you confirm that you have been informed of the personal data concerning you, which is to be collected, stored, processed and used, you agree that this personal data will be processed and used within such limits. specified, during the course of our activity.


4.5 Data processing consent

By using our site (s), placing orders or submitting information through the forms used by them, you agree to accept and accept the following statements:

(1) I have read and fully understood the provisions of this document and

(a) I consent to the processing and use of my Personal Data for the purposes specified in this document

(b) by accepting the use of the site I express my consent to the processing of personal data, so you can use the information to communicate with me about the requests submitted, processing orders, forms, etc.

(c) allow me to be contacted for (i) the transmission of the response, the provision of technical-financial solutions that may also involve my own or collaborators' services and / or products, (ii) the processing and delivery of placed orders, (iii) the provision of consent given.

We inform you that at any time you have the right, unconditionally, to request the withdrawal of your consent by contacting us by email at office@sofiaman.ro.

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