CONFIDENTIALITY POLICY AND PERSONAL DATA PROCESSING

General information

Starting from May 25, 2018, Regulation 2016/679/EU on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter "the Regulation") will be applied by all the states of the European Union. By means of this Regulation, it is desired to create a unitary and uniform legislative framework on the territory of the European Union that no longer requires national implementation measures.

It is responsible for the operation of the web page www.HidroStyle.ro and has the quality of operator HIDROSTYLE SRL with headquarters in Bucharest, Bucharest Sector 1, Şos. Gheorghe Ionescu-Siseşti, no. 146-156, block A, ground floor, apartment 1, room 1, sector 1, having CUI RO33276925, through legal representative Mihaela Ionita.

This web page is intended exclusively for users over the age of 16.

In order to comply with our obligations deriving from the Regulation, and considering that the protection of your data is a major and constant concern for us, we have developed this document, which sets out the categories of personal data that we collect when you visit our website, the purpose and basis of the processing, the duration of the processing, where we store and to whom we transmit this data, as well as the rights you have as a data subject, specifically implemented to ensure the protection of your fundamental rights and freedoms and in particular of their right to the protection of personal data.

1. Definitions

• "personal data" any information regarding an identified or identifiable natural person ("data subject"); an identifiable natural person is a person 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 many specific elements, specific to its physical, physiological, genetic, psychological, economic, cultural or social identity.
• "processing" means any operation or set of operations performed on personal data or sets of personal data, with or without the use of automated means, such as collection, recording, organization, structuring, storage, adaptation or modification, extract, consult, use, disclose by transmission, disseminate or otherwise make available, align or combine, restrict, delete or destroy;
• "operator" means the natural or legal person, public authority, agency or other body which, alone or together with others, determines the purposes and means of processing personal data; when the purposes and means of processing are established by Union law or domestic law, the operator or the specific criteria for its designation may be provided for in Union law or domestic law;
• "authorized person" means the natural or legal person, public authority, agency or other body that processes personal data on behalf of the operator;

We assure you that your personal data is processed legally, fairly and transparently, only for the fulfillment of the explicit purposes that have been brought to your attention.

HIDROSTYLE SRL, as operator, processes data in a way that ensures adequate security of personal data, including protection against unauthorized or illegal processing and against accidental loss, destruction or damage, by taking appropriate technical or organizational measures.

1. What kind of data we collect

Accessing the Site implies your acceptance that personal data will be kept and processed by the company HIDROSTYLE SRL.

Information regarding your identity and contact details, including name, email address, phone number, billing and delivery addresses. This situation may also concern information regarding the identity and contact details of another person that you make available to us exclusively for the purpose of us being able to perform our obligations under a contract, for example if you want us to deliver certain products directly to a third person. To the extent that this situation becomes applicable, you declare and guarantee that you have properly obtained the express consent of that person to make his Personal Data available to us, exclusively for the purposes mentioned above.

Information on use, which include information about how you use our Services (including your delivery instructions, orders/order history, search criteria, preferences, activity on the Website).

Technical information, such as the equipment you use to access our Website, the unique ID of the equipment, the Internet Protocol (IP) you use, the type and version of the browser, the time zone and location, the display settings, the types and versions of plug-in programs used for the browser, operating system and platform, as well as other technological aspects on the equipment you use to access our Website.

Marketing and communication information, including any communication we may receive from you, and your preferences regarding receiving notifications, marketing and other communications from us.

We also collect certain information regarding payments and transactions made through our Website. These do not include the details of the card with which you made the payment, which you provide directly to our payment processors. We do not collect or store payment card details.

When and how your personal data is used

We only collect from you the personal data that is necessary for us to be able to provide you with the possibility to use our website, to be able to fulfill your orders and to be able to provide you with access to our products and to be able to keep you up to date with our products, services and offers (direct marketing), to the extent permitted by law or based on your consent.

In general, we process the following personal data of yours:

• Name and surname
• Contact address and delivery address
• Phone number
• Email address
• IP

Each category of data will be collected for specific, explicit and legitimate purposes and are not subsequently processed in a way incompatible with these purposes and will be for a period that does not exceed the period necessary to fulfill the purposes for which they are processed.

In order to ensure the principle of information transparency when processing your personal data, we inform you in the following how we process your data, the purposes and the legal basis (legal basis) of the activities through which we process your data.

• When creating a user account on our website HidroStyle.ro,we request and collect your name, surname, address, no. phone number and email address.

Your personal data will be kept for the entire existence of the created account, until the account is deleted, but no longer than a period of 3 years from the date of the last login to the account or the last order. To the extent that after the creation of the account you placed an order, your data will be kept for a period of 3 years from the date of placing the last order, this being the limitation period.

The user account can be closed at any time by you via an e-mail sent to the e-mail address office@HidroStyle.ro . The creation of the user account will not affect the legality of the processing carried out before its closure.

• When completing and finalizing the order form, we request and collect from you your name, surname, contact address, delivery address, no. phone and email address and IP.

These personal data are necessary for us for contractual purposes, to be able to honor your orders, deliver the products to the indicated address, execute our warranty obligations associated with the products, or, as the case may be, make a product return. The basis of the processing is the contractual obligation between the parties as established by the Terms and Conditions. To the extent that you do not agree with the processing of your data, HIDROSTYLE SRL will not be able to honor and deliver your orders.

At the same time, your personal data is necessary for us to complete and deliver the tax invoices related to the delivered products. Your online payment data will not be accessible or stored by HIDROSTYLE SRL but only by the provider of the electronic payment service or by another entity authorized to provide card identification data storage services, whose identity you will be informed, before actually entering the details of the card you use for online payment. The only payment data we will store is the date the transaction was initiated and completed, as well as the payment status. Pursuant to the legal obligation, your personal data required for the preparation of payment documents will be provided to our contractual partners who provide us with IT services and will be used to submit tax and accounting returns to the tax authorities.

We will keep your Personal Data for as long as necessary to fulfill the purposes for which we collected it, including to satisfy any legal, accounting or reporting requirements, as follows:

• for the duration of the Contract, the Personal Data necessary for its execution, as well as the Personal Data for which you have given your consent to be used for marketing purposes; and
• for another 5 years after the termination of the Contract, for those Personal Data that we are obliged to keep according to the law (for example, information needed for accounting or fiscal purposes).

In order to be able to execute on time and according to the obligations assumed, your personal data will be disclosed:

1. a) To trusted third parties and our carefully selected service providers:

• the provider of the data storage service on external servers located in Romania;
• provider of accounting services
• the provider of communications and email transmission services
• the mobile phone service provider that helps us keep in touch with you, located in Romania;
• Our authorized delivery drivers and couriers, as necessary to fulfill any orders you have placed.
• our information technology service providers, such as hosting service providers for Websites and mailing lists.
• online payment service processors.

As mentioned above, we do not disclose your payment information to our payment processors – instead, you provide this information directly to these processors. We use NETOPIA Mobilpay services. For information on how they use your Personal Data, please read their privacy notices at https://www.mobilpay.ro/public/politica-de-confidientialitate/

If you have accepted cookies, we will disclose certain Personal Data to Google Analytics. For more information, please read the "Cookie Policy" Section on the Site.

We will disclose your Personal Data only to third party service providers under conditions of confidentiality, and they will use your Personal Data exclusively for the purposes mentioned in this policy.

1. b) If you choose to share them via social media

If you choose to interact with us on a public forum, such as social media, our communications may be visible to other users of the platform.

Your personal data may be disclosed or transferred to potential or current buyers, or investors in or creditors of our business or any of our assets, or any of the consultants or representatives of any of the above. In this case, we will ensure that there are appropriate confidentiality agreements.

On rare occasions we may disclose your Personal Data when we believe it is necessary to comply with the law, regulations or legal requirements (including a court order or governmental request); to enforce or apply the terms of use or other agreements; in the context of a company reorganization or restructuring; or to protect the rights, property, safety of HIDROSTYLE SRL, our staff, our users or other people.

The purpose of processing your personal data

The purpose of collecting the data specified above is that stated in the section in which your data is requested and depending on the options selected, and by purpose one or more of the following situations can be identified:

– to improve the quality of HIDROSTYLE SRL products and services, through HidroStyle .ro, so as to meet the needs of users and to provide news about the products and services offered;

– online marketing of products and/or services, including their invoicing and delivery;

– information about the order placed, favorite products or included in the list of preferences or alerts;

– sending newsletters and occasional offers;

- website optimization according to traffic data;

- provision of advertising, marketing and advertising services;

- creation of a database for the creation of statistical reports, information about HidroStyle promotions or any other promotions or activities carried out by HidroStyle through any means of communication (mail, e-mail, telephone, SMS, etc.).

If you are a visitor to the Site, the personal data you provide directly in the context of its use will be processed, such as the data provided in the contact/comments section, newsletter subscription, account creation, response to some questionnaires.

The rights you benefit from

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 www.HidroStyle.ro, according to what is described in this document;

– the right to access the data, respectively the right to obtain confirmation from the www.HidroStyle.ro 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 delay, by www.HidroStyle.ro 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.

- the right to delete data, without undue delay, ("the right to be forgotten"), if one of the following reasons applies:

– they are no longer necessary to fulfill the purposes for which they were collected or processed;

– if consent is withdrawn and there is no other legal basis for processing;

– if the data subject objects to the processing and there are no legitimate reasons to prevail;

– if the personal data were processed illegally;

– if personal data must be deleted to comply with a legal obligation;

- the personal data were collected in connection with the provision of information society services according to the Union law or the internal law to which the operator is subject.

It is possible that, following the data deletion request, the Site will anonymize this data (thus depriving it of its personal character) and continue processing for statistical purposes under these conditions;

– the right to restrict processing to the extent that:

- the person contests the accuracy of the data, for a period that allows verification of the correctness of the data;

– the processing is illegal, and the data subject opposes the deletion of personal data, requesting instead the restriction of their use;

- the operator no longer needs the personal data for the purpose of processing, but the data subject requests them for establishing, exercising or defending a right in court;

– the data subject has objected to the processing (other than those for direct marketing), for the time interval in which it is checked whether the legitimate rights of the operator prevail over those of the data subject.

– 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 to the Site to another data operator, to the extent that the conditions provided for by law are met;

– the right to opposition;

– the right not to be subject to an automated individual decision, i.e. the right not to be the subject of a decision taken solely on the basis of automated processing activities, including the creation of profiles, which produce legal effects that concern the data subject or affect him in a similar way 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.

1. Newsletter – Direct Marketing

Subscribing and unsubscribing to the HIDROSTYLE SRL newsletter is free and voluntary and is done exclusively based on your consent. The newsletter is a means of periodic, exclusively electronic (e-mail, SMS) information on Goods, Services, Promotions, etc. to the Seller within a certain period, without any commitment on the part of the Seller with reference to the information contained therein.

In order to provide marketing services, we collect your e-mail address, no. phone number, name, surname. This data will be used exclusively to keep you informed about our products, services and offers. The basis for the processing of personal data is your consent, the duration of the processing being the entire duration of the existence of the consent.

The consent can be withdrawn at any time by an email sent to the email address office@HidroStyle.ro or by accessing the unsubscribe link in the e-mail received from us and will result in the termination of processing. The withdrawal of consent will not affect the legality of the processing carried out before its withdrawal.

Links

This site contains links to other sites. HIDROSTYLE SRL is not responsible for the privacy policy practiced by them. We recommend that you consult in advance the legal terms and other information regarding the collection of personal information. The rules set out in this text apply only to the information collected on this site.

When you access a web page that contains plugins, your browser establishes a direct connection to the servers of the respective providers. The content of the plugins will be transmitted by the respective provider directly to your browser and will be integrated by it into the web page. By integrating the plugins, the respective provider receives the information that your browser has accessed our website. This happens regardless of whether you have a profile on that social network or have just logged in.

If you are logged in to the respective social network, it can assign your visit to our website to your profile on the respective social network. If you interact with plugins, for example by pressing the "Like" button on Facebook or making a comment, the corresponding information will be transmitted directly to the respective provider and stored there.

Information on the purpose and volume of data collection, processing and further use of personal data by the respective provider, as well as your rights and setting possibilities regarding them in order to protect your privacy can be found in the data protection instructions of the respective provider .

Security of your personal data

The security of your personal data is a priority for us. We assure you that any data processing is carried out in compliance with the principles guaranteed by the Regulation and processed in a way that ensures the adequate security of personal data, including protection against unauthorized or illegal processing and against accidental loss, destruction or damage , by taking appropriate technical or organizational measures, by implementing appropriate internal data protection policies.

This site adopts all necessary security measures to protect the personal information of our users. When filling in personal data on our website, the information will be protected both offline and online. All personal information will be processed through secure pages that use the SSL encryption system, marked with a lock symbol, positioned at the bottom of the Microsoft Internet Explorer browser window.

Notwithstanding the foregoing, no transmission of information over the Internet or electronic storage is completely secure. Although we have taken appropriate measures to protect against unauthorized disclosure of information, we cannot guarantee the security of your information.

Modification of this policy

This Policy is completed with the other specific policies of HIDROSTYLE SRL and the Terms and Conditions that you can access from our website. We may change this privacy notice over time. We will post any revised notice on this Website, and if the changes are significant, we will notify our members by email. Any change in the terms of this policy will be communicated to users by e-mail, so that they are permanently informed about the information we collect, how we use it and under what circumstances, if any, we make it public. Users will be able to agree or disagree with the use of information for other purposes. We will use the information in accordance with the policy under which the information was collected.

This notice to you is limited to our web page and does not apply to third party web pages that may be accessed through this web page. We have no influence on the processing of data by these third-party operators and assume no responsibility or liability in relation to these web pages.