Privacy Policy

1. Identification

SC REDEYE'S CORP SRL

Because we have an open policy with each customer we want to hear your views as well as provide you with any additional information you may need regarding the processing of your data, so we encourage you to contact us with any concerns had.

2. Privacy

First of all, it is extremely important to inform you of SC REDEYE'S CORP SRL's commitment to all customers and collaborators, through which we show our intention to comply with all requirements regarding the protection of personal data and confidentiality, this being a fundamental commitment of SC REDEYE'S CORP SRL.

Considering the company's role, we assure you that we will make every effort to process your data in full compliance with Regulation (EU) 2016/679 ("General Data Protection Regulation" hereinafter referred to as "GDPR"), as well as with any other legislation applicable on the territory of Romania, of which we mention by way of example:

1. Directive 2000/31/EC of the European Parliament and of the Council of June 8, 2000, on certain legal aspects of information society services, especially electronic commerce, on the internal market (Electronic Commerce Directive);
2. Law 365/2002 on electronic commerce and related methodological norms;
3. GEO 34/2014 regarding consumer rights in contracts concluded with professionals;
4. Law 449/2003 on the sale of products and associated guarantees.
5. Law no. 190 of July 18, 2018, on measures to implement Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016, on the protection of natural persons with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (General Data Protection Regulation)

As one of the essential principles of this legal framework is transparency, we have prepared this document to inform you about how we collect, use, transfer and protect personal data when you interact with us in relation to our products and services , including through our website or social media.

SC REDEYE'S CORP SRL reserves the right to present any changes to the Privacy Policy, to reflect any changes in the way we process your personal data or any changes in legal requirements. Any change will be brought to the attention of users/customers in a timely manner so that they are informed and in a transparent way on the web page. This data processing policy also applies to personal information that we collect through other means and that we add to personal information collected through the operation and delivery of our services and products.

We want to make sure you understand what information we collect, how and why we use it, who we may disclose it to, what security measures we take to protect it, what rights you have and how you can exercise them. By using this website and creating a user account, you expressly declare that you are at least 18 years old and that you allow us to use your personal data as described in this material. Otherwise, please do not use the website.

The core of our approach is the "Privacy by design" & "Data protection by default" policy, meaning we will be proactive in all explanations and website design.

3. What are the categories of data/information processed?

To better understand the category of personal data processed, we present the following types of data collected:

• personal data that can identify you when you voluntarily create a user account using the registration system that we make available on this website, we collect the following personal data: e-mail address; access password (you generate this password during account creation). Without this information, it is impossible to register and create an account.
• after registration and authentication in the user account and when you purchase a product from the website or use the website in any way, we may ask you to enter other information, such as: name and surname; billing address and/or delivery address; Phone number; Date and place of birth; When applicable - data regarding the company you represent (and on behalf of which you act), as well as your profession; Certain information regarding your financial situation; information necessary for invoicing. For example, when you place an order, you provide us with information such as: desired item, name and surname/company name, delivery address, billing details, payment method, phone number, bank card details, etc.
• when a product order is placed over the phone by calling our customer service, we may record the phone conversation and keep a recording of your voice, which will be brought to your attention

Anonymous information will also be collected through cookies and the Action Tags that - we and our partners (through advertising servers, content servers, website analysis agents, etc.) - use on this website, we may have access to anonymous information related to you: IP address; The country and server to which your computer is connected; The operating system, type of browser and computer you are using; Configuring Java or cookies; Your purchase preferences and behavior on this website (the pages you visited, the searches you performed and the products you viewed and purchased, the date and time of your visit or order, the number of visits and orders, the number of visits per browsing session and server type, the URLs you came from, the domain names and web pages you browse), your hobbies and lifestyle, the groups you belong to; Demographic information (number of household members, age, gender) and area code information associated with your server; Applications and plug-ins, as well as any search terms used on our website; The address of the website that directed you to our website. We collect this information in a manner that does not allow you to be personally identified. However, it is possible that at some point - we and/or our partners - associate this information with your identity, if you have a user account.

4. Purposes and legal bases of processing

The purposes and bases of the processing refer to the following:

• to register as a user of the website, to create your account and communicate
• for the delivery of the product ordered through the website. This purpose involves a series of indissoluble objectives such as:
1. Creation and administration of any account within the website;
2. Order processing, including receiving, validating, shipping and invoicing them;
3. Solving cancellations/revocations or problems of any nature related to an order, goods or services purchased;
4. If necessary, return the products according to the legal provisions and according to the terms of use;
5. Reimbursement of the counter value of the products according to legal provisions;
6. Providing support services, including providing answers to your questions about your orders.

The processing of your data for these purposes is in most cases necessary for the conclusion and execution of a contract between SC REDEYE'S CORP SRL and you. Also, certain processing subsumed for these purposes is required by applicable legislation, including tax and accounting legislation.

• To improve our services. We always want to give you the best online buying/purchasing experience. For this, we may collect and use certain information related to your Buyer behavior, we may invite you to complete satisfaction surveys following the completion of an order, or we may conduct, directly or with the help of partners, studies and market research. We base these activities on our legitimate interest in carrying out commercial activities, always taking care that your fundamental rights and freedoms are not affected.
• For marketing. In all cases, we base our marketing communications on your prior consent. You can change your mind and withdraw your consent at any time by sending an email or by phone. To the extent that we will use your comments regarding our product, we will use the pseudonymization procedure so that your data will not be recognized. We will not automatically send you the newsletter without your prior notice or consent.
• To defend our legitimate interests. There may be situations where we will use or share information to protect our rights and business. These may include: Measures to protect the website and platform users against cyberattacks: Measures to prevent and detect fraud attempts, including the transmission of information to the competent public authorities; Measures to manage various other risks.

5. How long will we use your personal data?

As a general rule, we will store your personal data while you use the website. You may request us to delete certain information at any time, and we will comply with such requests, subject to the retention of certain information including after the account is closed, in situations where applicable law or our legitimate interests require it, for example to preserve the accounting situation.

We do not pass on personal data to third parties unless 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 parties under private law is carried out in accordance with the legal provisions on data protection and information confidentiality, based on contracts concluded with them and with your prior information.

Currently, we store and process your personal data on the territory of Romania. However, we may transfer certain of your personal data to entities located in the European Union or outside the Union, including countries that have not been recognized by the European Commission as having an adequate level of personal data protection.

We will always take steps to ensure that any international transfer of personal data is handled carefully to protect your rights and interests. Transfers to service providers and other third parties will always be protected by contractual commitments and, where applicable, other safeguards such as 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.

6. To whom do we provide information about your personal data?

Considering the commercial specifics of the activity, for legitimate purposes, the data will also be known by the following categories:

• Employees, consultants and authorized persons who need to know them;
• Companies from the group of which SC REDEYE'S CORP SRL, its associates are part;
• To third parties-partners who provide us with services (such as e-commerce platform providers, postal factors/couriers who deliver the products, those who host the website, those who help us monitor and optimize the website, those who provide the support service customers, other companies that help us deliver communications and promotional offers, partners that serve personalized ads and behaviorally targeted advertising, other authorized companies.
• Online payment details (such as credit or debit card numbers) are provided directly to our banking partner. SC REDEYE'S CORP SRL does not have access to and does not store this information - all of which ends up being processed by a third party.
• In case of a sale, reorganization, merger or association of companies involving the activity of SC REDEYE'S CORP SRL (including negotiations for this); in such a case, you will be notified by e-mail or through a notice displayed on the website, and you will be asked for your consent;
• If a crime has been committed or a complaint has been made regarding the content you have posted on this website;
• If we are required by law or by a competent authority.

7. What protection measures do we offer you?

The main protection measure envisages the implementation of appropriate technical and organizational measures, which provide minimum protection guarantees, the underwriter committing to perform the necessary diligence against any attack.

The Company will not be responsible when the loss of data results from a cause beyond our control, nor for the actions of third parties who may use your data in an unauthorized or illegal manner.

We draw your attention to the fact that the transmission of information over the Internet, in general, or through other public networks, is not completely secure, there is a risk that the data will be seen and used by unauthorized third parties. We cannot be responsible for such vulnerabilities of systems that are not under our control.

In the event of an incident, we undertake to inform you immediately about this aspect so that all necessary measures can be taken.

Unless a personal data breach is unlikely to result in a risk to the rights and freedoms of natural persons, we will notify the supervisory authority of any data breach without undue delay within no more than 72 hours from the date on which he became aware of it. (Art. 33 of the G.D.P.R.)

8. What are user rights?

By accessing and using the site, you are given a number of specific legal rights related to the personal data we collect from you.

As a data subject, we inform you of the rights established under G.D.P.R. and national legislation.

A. Right of access and information. (art. 13, 14, 15 of the G.D.P.R. Regulation)

This right allows you to request information from us on whether or not we are processing your personal data and for what purpose it is processed, to request that we 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, who we disclose it to, whether we transfer it abroad and how we protect it, how long we keep it, what rights you have , how you can make a complaint, where we obtained your data, to the extent that the information has not already been provided to you by this notice.

B. The right to transparency of information, communications and ways of exercising rights.

C. The right to rectification and intervention on data. (Art. 16 of the G.D.P.R. Regulation)

You can ask us to correct or complete your inaccurate or incomplete personal data. Before rectification, we will proceed to verify the veracity of the information provided.

D. The right to be forgotten (Art. 17 of the G.D.P.R. Regulation)

We inform you of your right to withdraw consent so that you are aware of it before consent is actually given.

The deletion request can only be accepted if:

• the processing is no longer necessary for the purposes for which they were collected; or,
• you have withdrawn your consent (if data processing was based on consent); or exercise a legal right to object; or they were processed illegally; or we have a legal obligation to do so.
• the data subject objects to the processing according to the conditions for exercising the right to opposition;
• personal data were processed illegally;
• personal data must be deleted to comply with a legal obligation incumbent on the operator

We are not obliged to comply with your request to delete your personal data where the processing of your personal data is necessary:

• to comply with a legal obligation; or
• for establishing, exercising or defending a right in court or in other cases.

Before exercising the right to deletion, we recommend that you download from your account and save all the documents related to the orders made, regardless of whether the invoicing was done to you or to another natural or legal person. If you do not do this before exercising your right to deletion, you will lose all these documents and the subscriber will be unable to make them available to you, as the case may be, because the process of deleting the data, respectively the account, with all the related data and documents, it is an irreversible process.

The right to erasure also covers the possibility of requesting us to transform into anonymous data those data that we do not legally process.

You can access and intervene on your personal data that we use free of charge - by contacting us using the details in the Contact section. The written request must be dated and personally signed. To the extent that more than one application per year will be submitted, we may charge a fee, according to the legal provisions.

NOTA BENE!

In case of withdrawal of consent, all data processing operations that were based on that consent and took place before its withdrawal and in accordance with Regulation (EU) 2016/679, continue to be legal, but we will stop the processing actions concerned. If there is no other legal basis to justify the processing of the data, it will be deleted. (Art. 7 of GDPR)

E. Restriction of data processing. (Art. 18 of the G.D.P.R. Regulation)

Restriction may be requested when processing is contested to allow us to verify the veracity of the data. Restriction can also be requested when the processing is illegal, but you do not want the data to be deleted; or they are no longer necessary for the purposes for which they were collected, but you need them to establish, exercise or defend a right in court; or you have exercised your right to object and checking whether our rights prevail is ongoing.

We may continue to use your personal data following a restriction request if: we have your consent; or to ascertain, exercise or ensure the defense of a right in court; or to protect the rights of the subscriber or another natural or legal person.

F. Portability of personal data. (Art. 20 of the G.D.P.R. Regulation)

You can ask us to provide 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 only if: the processing is based on your consent or the conclusion or performance of a contract with you and the processing is done by automated means.

G. The right of opposition. (Art. 21 of the G.D.P.R. Regulation)

The right of opposition, regardless of the data processed, can be exercised at any time for well-founded and legitimate reasons related to your specific situation. The right of opposition can be exercised at any time, free of charge and without any justification. Objection to processing for direct marketing purposes (including profiling) can be made at any time without giving any reason, in which case we will cease this processing as soon as possible.

H. The right not to be subject to an automated individual decision. (Art. 22 of the G.D.P.R. Regulation)

I. The right to appeal to judicial authorities in case of violation of rights.

J. The right to make a complaint. (Art. 77 of the G.D.P.R. Regulation)

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 supervisory authority for data protection are as follows: National Authority for the Supervision of Personal Data Processing, B-dul G-ral. Gheorghe Magheru no. 28-30, Sector 1, postal code 010336, Bucharest, Romania Phone: +40.318.059.211 or +40.318.059.212; E-mail: anspdcp@dataprotection.ro, https://www.dataprotection.ro.

Without prejudice to your right to contact the supervisory authority at any time, please contact us in advance, stating that we promise to make every effort to resolve any problem amicably.

9. Commercial communications (e.g. newsletter)

Commercial communications will be carried out in accordance with G.D.P.R. and with Law 365/2002 on electronic commerce and related methodological norms.

We inform you that we will not make commercial communications to you, regardless of the method of transmission, without having previously expressed your express consent to receive such communications.

Consent can be obtained in any form and can be proven by any means of evidence. The burden of proof rests with SC REDEYE'S CORP SRL, as a service provider.

The consent communicated through a message sent by electronic mail is validly expressed if the following conditions are cumulatively met:

1. is sent from the mailbox where the recipient wishes to receive commercial communications;
2. the subject of the message consists of the concatenation of the text "ACCEPT COMMERCIAL COMMUNICATIONS FROM PARTEA", written in capital letters, and the name or designation of the person on whose behalf the commercial communications will be sent.

The subject of e-mail messages, which constitute commercial communications, must begin with the word "ADVERTISEMENT" written in capital letters. Commercial communications must include at least the following information regarding the person on whose behalf they are made:

1. full name or title;
2. unique registration code;
3. headquarters;
4. telephone and fax numbers;
5. email address

You have the right to revoke your consent for commercial communications by simply notifying SC REDEYE'S CORP SRL. The procedure is free, accessible including by electronic means, by e-mailing us to the contact address or even by phone.

The revocation by electronic means will operate in our database within no more than 48 hours from the initiation of the procedure. We will also inform you of this right in messages containing commercial communications.

In order to exercise the rights specified above, it is necessary to send us a simple dated and signed Request and communicate it to us regardless of the chosen means (electronic/physical) to the contact details specified in the Contact section.

Pursuant to art. 12 of the G.D.P.R. we will provide the response to the actions taken following a request under articles 15-22 of the Regulation within a maximum of one month after receiving the request. This period can be extended by two months when necessary, taking into account the complexity and number of requests. In the event of an extension, within one month we will inform you of any extension giving you the reasons for the delay.