PRIVACY POLICY

OF SOCIETY ELECTRA M&E ROMANIA S.R.L.

1. General information

This Privacy Policy (“Policy”) explains how the company ELECTRA M&E ROMANIA S.R.L. (hereinafter: “ELECTRA M&E ROMANIA S.R.L.” or “The Company”) collects, processes and protects your personal data.

ELECTRA M&E ROMANIA S.R.L. knows the importance of your data and is committed to protecting their confidentiality and security, processing your personal data in full compliance with Regulation (EU) 2016/679 (“General Data Protection Regulation” or “GDPR”), with Law 190/2018 on measures to implement Regulation (EU) 2016/679.

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

Regarding the personal data we collect, ELECTRA M&E ROMANIA S.R.L. is “data operator”, that is, the entity that establishes the purposes and means by which personal data is processed.

If you wish to contact us regarding your personal information or this Policy, please use the following contact details:

Company name: ELECTRA M&E ROMANIA S.R.L.

Address: ROMANIA, BUCHAREST, SECTOR 5, BD. TUDOR VLADIMIRESCU NO. 29A, AFI TECH PARK OFFICE BUILDING 1, FLOOR 2 Registration data at the Trade Register: no. J40/2098/2008, CUI RO 18483455,

Phone: +4(0).021.330.2086

2. Principles related to the processing of personal data

“Legality, fairness and transparency”: Personal data is processed in a legal, fair and transparent manner towards the data subject.

“Purpose limitations”: Personal data is collected for specific, explicit and legitimate purposes and is not further processed in a way incompatible with these purposes;

“Data minimization”: Personal data is adequate, relevant and limited to what is necessary in relation to the purposes for which it is processed;

“Accuracy”: Personal Data is accurate and, where necessary, will be updated; personal data that are inaccurate, given the purposes for which they are processed, are deleted or rectified without delay;

“Limitations related to storage”: Personal data are kept in a form that allows the identification of the data subjects for a period that does not exceed the period necessary to fulfill the purposes for which the data are processed;

“Integrity and confidentiality”: Personal data is processed in a way that ensures adequate data security, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, by taking appropriate technical or organizational measures.

“Responsibility”: ELECTRA M&E ROMANIA S.R.L. apply effective procedures and policies to comply with European and national legislation on the protection of personal data in force.

3. The purposes and grounds for the collection and processing of your personal data

ELECTRA M&E ROMANIA S.R.L. collects and processes your personal data for the following purposes:

– for carrying out the contractual relationship between you and ELECTRA M&E ROMANIA S.R.L., respectively to process your orders, for the validation, dispatch and invoicing of the order placed by you, informing you about the status of the order, organizing the return of ordered products, etc.

The processing of your data for this purpose is based on the contract concluded between you and ELECTRA M&E ROMANIA S.R.L.. The provision of your personal data is necessary for the execution of this contract. Refusal to provide data may result in the impossibility of carrying out contractual relations between you and ELECTRA M&E ROMANIA S.R.L.

– for marketing purposes, to inform you about promotional campaigns, to communicate news about our products, if you give your consent;

– to fulfill the legal obligations incumbent upon ELECTRA M&E ROMANIA S.R.L. in the context of the services provided through the Site, including the obligations in fiscal matters, as well as in matters of archiving.

The processing of your data for this purpose is necessary based on legal obligations.

– at the same time, we use your personal data to improve our products and your experience when shopping with us through any sales channel.

4. Types of data collected:

Data collected by ELECTRA M&E ROMANIA S.R.L. are: name and surname, gender, e-mail address, delivery address, billing details, payment method, phone number, bank card details, etc.

5. How we collect:

– by ordering (via the Internet or by phone) – when you order products, you must provide us with your personal data so that we can process your order;

– by registration – in the context of creating a user account, in the context of placing an order through our site ELECTRA-ME.COM/ or in any other way resulting from the use of the Site.

6. Duration for which we process your data

ELECTRA M&E ROMANIA S.R.L. will process your personal data as much as is necessary to achieve the processing purposes mentioned above.

If you are a customer, we will process your data for the entire duration of the contractual relationship and subsequently according to the legal obligations falling under the responsibility of ELECTRA M&E ROMANIA S.R.L. (e.g., in the case of financial-accounting supporting documents for which the legal retention period is 10 years from the end of the financial year during which they were drawn up).

If you are a customer and exercise the option to delete your user account, we will no longer send you e-mails and/or sms of this kind. However, we would like to inform you that deleting your account will not automatically delete your personal data.

If you want your personal data to stop being processed or if you want the data to be deleted, you can exercise your rights detailed in point 9 below. If you request the deletion of the account, but there is at least one active order on that account, the request to delete the account can only be registered after the delivery of the products and the completion of the last active order.

If you withdraw your consent for data processing for marketing purposes ELECTRA M&E ROMANIA S.R.L. will stop processing your personal data for this purpose, without affecting the processing carried out by ELECTRA M&E ROMANIA S.R.L. based on the consent expressed by you before its withdrawal.

7. Disclosure of personal data

To fulfill the processing purposes, ELECTRA M&E ROMANIA S.R.L. may disclose your data to partners, third parties or entities that support ELECTRA M&E ROMANIA S.R.L. in carrying out the activity through the Site (for example courier companies, IT service providers).

8. Transfer of personal data

Personal data provided to ELECTRA M&E ROMANIA S.R.L. they can be transferred outside of Romania, but only to European Union states.

No personal data is transferred to recipients from countries outside the European Union without ensuring the effective protection of such data. In cases where it is absolutely necessary and in the context of the activities and operations of ELECTRA M&E ROMANIA S.R.L., the transfer of personal data outside the European Union may be allowed, exceptionally, as long as effective protection is guaranteed for the safe processing of personal data, in accordance with Regulation No. 679/2016 and taking all the necessary measures before the Data Protection Authority, before the actual data transfer, in those areas where, according to the aforementioned regulation, prior authorization from the competent Authority regarding the data transfer is required.

9. Your rights

Under the conditions provided by the legislation on the processing of personal data, as data subjects, you benefit from the following rights:

– the right to information, respectively the right to receive details regarding the processing activities carried out by ELECTRA M&E ROMANIA S.R.L., according to what is described in this document;

– the right to access data, respectively the right to obtain confirmation from ELECTRA M&E ROMANIA S.R.L. regarding the processing of personal data, as well as details regarding the processing activities such as the manner in which the data are processed, the purpose for which the processing is done, the recipients or categories of recipients of the data, etc.;

– the right to rectification, respectively the right to obtain the correction, without justified delays, by ELECTRA M&E ROMANIA S.R.L. of inaccurate/unjustified personal data, as well as completing – incomplete data; The correction/completion will be communicated to each recipient to whom the data were sent, unless this proves impossible or involves disproportionate efforts you

– the right to delete the data, without undue delay, (“the right to be forgotten”), if one of the following reasons applies: (i) they are no longer necessary to fulfill the purposes for which they were collected or processed; (ii) if consent is withdrawn and there is no other legal basis for processing; (iii) if the data subject objects to the processing and there are no overriding legitimate reasons; (iv) if the personal data were processed illegally; (v) if the personal data must be deleted to comply with a legal obligation; (vi) the personal data were collected in connection with the provision of information society services in accordance with Union law or the internal law to which the operator is subject.

It is possible that, following the data deletion request, ELECTRA M&E ROMANIA S.R.L. to anonymize these data (thus depriving them of their personal character) and continue processing them for statistical purposes under these conditions;

– the right to restrict processing to the extent that you have doubts about the accuracy of the data, as well as in other cases provided by law;

– the right to data portability, respectively (i) the right to receive personal data in a structured way, commonly used and in an easy-to-read format, as well as (ii) the right to have this data transmitted by ELECTRA M&E ROMANIA S.R.L. to another data operator, to the extent that the conditions provided for by law are met;

– the right to opposition – respectively the right to oppose the processing of personal data based on a legal basis on which ELECTRA M&E ROMANIA S.R.L. considers it legitimate. In addition, you have the right to object at any time to the processing of your personal data for direct marketing purposes.

– the right not to be subject to an automatic individual decision, respectively the right not to be the subject of a decision made solely on the basis of automatic processing activities, including the creation of profiles, which produce legal effects that concern the data subject or similarly affect him to a significant extent;

– the right to address the National Supervisory Authority for the Processing of Personal Data or the competent courts, to the extent you consider necessary.

10. Data security

ELECTRA M&E ROMANIA S.R.L. will take appropriate security measures, including informing and training employees, about the protection of personal data against threats such as:

i. accidental loss or theft;

ii. unauthorized access, use or disclosure;

iii. unauthorized copying, alteration, falsification or modification of data;

iv. illegal or unauthorized retention of data; and

v. accidental or unlawful destruction

Employees of ELECTRA M&E ROMANIA S.R.L. will take appropriate measures to prevent misuse or loss of personal data, and to prevent unauthorized access to personal data: employees will report any situation of misuse or suspected misuse, loss or unauthorized access to the Human Resources Department and/or, possibly, to the IT Department, if the above actions are caused by technical or technological problems.

Protection level control:

ELECTRA M&E ROMANIA S.R.L. regularly performs checks on the procedures regarding the collection, storage and processing of personal data to verify the effectiveness of the measures applied in order to protect the data.

For any additional questions regarding how personal data is processed and to exercise your rights mentioned above, please contact us with a request to the email address: OFFICE@ELECTRA-ME.COM

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ELECTRA M&E ROMANIA S.R.L.