(GDPR) Processing of Personal Data

Privacy Policy regarding the processing of personal data

We consider ensuring the right to protection of personal data to be a fundamental commitment of Alexandra Catana®, and we will therefore dedicate all necessary resources and efforts to process your data in full accordance with Regulation (EU) 2016/679 (the “General Data Protection Regulation” or “GDPR”), as well as with any other applicable legislation on the territory of Romania. Since 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 your personal data when you interact with us in connection with our products and services, including through our website or through the applications available on mobile phones.

We reserve the right to periodically update and modify this Privacy Policy, in order to reflect any changes in the way we process your personal data or any changes in legal requirements. In the event of any such change, we will post the amended version of the Privacy Policy on our website, which is why we ask you to periodically check the content of this Privacy Policy.

Who we are and how you can contact us

Alexandra Catana® is the trading name of the online sales platform for goods produced and marketed by Dumi Terra S.R.L., a legal entity of Romanian nationality, with its registered office in Bucharest, Șoseaua Pantelimon, no. 283, sector 2, registered with the Trade Register under no. J40/17044/2008, tax identification number RO24565436 (hereinafter Alexandra Catana® or “we”). For the purposes of data protection legislation, we are the controller when we process your personal data, under the conditions provided by law.

What categories of personal data we process

In general, we collect your personal data directly from you, so that you have control over the type of information you provide to us. By way of example, we receive information from you as follows:

• When you create an Alexandra Catana® account, you provide us with: your e-mail address, first name and surname;
• On your personal page (My Account) on the Alexandra Catana® platform, you have the option to add additional information, such as: nickname, mobile phone number, billing details matching those on your ID card, delivery addresses, alternative e-mail address, bank card details, etc.;
• When you place an order, you provide us with information such as: the desired product, first name and surname, delivery address, billing details, payment method, phone number, bank card details, etc.

We do not otherwise collect or process sensitive data included by the General Data Protection Regulation in special categories of personal data. We also do not wish to collect or process data of minors who have not reached the age of 16.

What are the purposes and legal grounds for processing

We will use your personal data for the following purposes:

1. To provide Alexandra Catana® services for your benefit

This general purpose may include, as applicable, the following:

• Creating and administering the account on the Alexandra Catana® platform;
• Processing orders, including receiving, validating, shipping and invoicing them;
• Resolving cancellations or issues of any nature relating to an order, or to the goods or services purchased;
• Returning products in accordance with legal provisions;
• Refunding the value of products in accordance with legal provisions;
• Providing support services, including answering your questions regarding your orders or Alexandra Catana®’s goods and services.

Processing your data for these purposes is, in most cases, necessary for the conclusion and performance of a contract between Alexandra Catana® and you. In addition, certain processing activities carried out for these purposes are required by applicable legislation, including tax and accounting legislation.

2. To improve our services

We constantly want to offer you the best online shopping experience. To this end, we may collect and use certain information related to your behaviour as a Buyer, we may invite you to complete satisfaction questionnaires after completing an order, or we may carry out, directly or with the help of partners, market studies and 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.

3. For marketing

We want to keep you up to date with the best offers for the products/services that interest you. To this end, we may send you any type of message (such as e-mail/SMS/telephone/mobile push/webpush/etc.) containing general and thematic information, information about products similar to or complementary with those you have purchased, information about offers or promotions, information relating to products added to the “Account/My Basket” section or the “Account/Favourites” section, or that you have shown interest in purchasing, as well as other commercial communications such as market research and opinion polls, and we may display personalised recommendations on the website and in the smartphone application. In order to provide you with information of interest to you, we may use certain data regarding your behaviour as a buyer (e.g. products viewed/added to the wishlist/purchased) to create a profile for you. We always ensure that this processing is carried out with respect for your rights and freedoms, and that decisions made on this basis do not have legal effects on you and do not similarly affect you to a significant extent.

In most cases, we base our marketing communications on your prior consent. You may change your mind and withdraw your consent at any time, by:

• Changing the settings in your customer account, in the “Preferences” section;
• Accessing the unsubscribe link displayed in the messages you receive from us;
• or by contacting Alexandra Catana® using the contact details described on the site.

In certain situations, we may base our marketing activities on our legitimate interest in promoting and developing our commercial activity. In any situation where we use information about you for our legitimate interest, we take care and take all necessary measures to ensure that your fundamental rights and freedoms are not affected. Nevertheless, you may ask us at any time, through the means described above, to stop processing your personal data for marketing purposes, and we will comply with your request.

4. To defend our legitimate interests

There may be situations in which we will use or transmit information in order to protect our rights and commercial activity. These may include:

• Measures to protect the website and users of the Alexandra Catana® platform from cyberattacks;
• Measures to prevent and detect attempted fraud, including transmitting information to the competent public authorities;
• Measures to manage various other risks.

The general basis for these types of processing is our legitimate interest in defending our commercial activity, it being understood that we ensure that all measures we take guarantee a balance between our interests and your fundamental rights and freedoms.

In addition, in certain cases we base our processing on legal provisions, such as the obligation to ensure the security of goods and valuables provided by applicable legislation in this area.

How long we keep your personal data

As a general rule, we will store your personal data for as long as you have an account on the Alexandra Catana® platform. You may ask us at any time to delete certain information or close your account, and we will comply with such requests, subject to retaining certain information even after the account is closed, in situations where applicable legislation or our legitimate interests require this.

Who we transmit your personal data to

As applicable, we may transmit or provide access to certain personal data of yours to the following categories of recipients:

• companies within the same group of companies;
• courier service providers;
• payment/banking service providers;
• marketing/telemarketing service providers;
• market research service providers;
• insurance companies;
• IT service providers;
• other companies with which we may develop joint programmes for offering our goods and services on the market.

If we are subject to a legal obligation, or if 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-party private legal entities is carried out in accordance with legal provisions on data protection and confidentiality of information, based on contracts concluded with them.

Which countries we transfer your personal data to

We currently store and process your personal data within the territory of Romania.

How we protect the security of your personal data

We are committed to ensuring the security of personal data by implementing appropriate technical and organisational measures, in accordance with industry standards.

Transmission of your personal data is done using state-of-the-art encryption algorithms, and we store it on secure servers, while also ensuring data redundancy.

For payment processing, we use the banking services of ING Bank and Netopia. Any information relating to payments is encrypted.

Despite the measures taken to protect your personal data, 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, and there is a risk that data may be seen and used by unauthorised third parties. We cannot be held responsible for such vulnerabilities in systems that are not under our control.

What rights you have

The General Data Protection Regulation grants you a series of rights in relation to your personal data. You may request access to your data, correction of any errors in our files, and/or object to the processing of your personal data. You may also exercise your right to lodge a complaint with the competent supervisory authority or to bring proceedings before the courts. As applicable, you may also benefit from the right to request the deletion of your personal data, the right to restriction of the processing of your data, and the right to data portability.

To exercise your rights, you may contact us using the contact details set out on the site. Please note the following aspects if you wish to exercise these rights:

Identity.

We take seriously the confidentiality of all records containing personal data. For this reason, please send us your requests regarding such records using the e-mail address associated with your Alexandra Catana® account. Otherwise, we reserve the right to verify your identity by requesting additional information for the purpose of confirming your identity.

Fees.

We will not charge a fee for you to exercise any right in relation to your personal data, unless your request for access to information is unfounded, repetitive or excessive, in which case we will charge a reasonable amount in such circumstances. We will inform you of any fees applied before dealing with your request.

Response time.

We aim to respond to any valid requests within a maximum of 30 days, unless this is particularly complicated or you have made several requests, in which case we will respond within a maximum of 60 days. We will let you know if we need more than 30 days.

We may ask you if you can tell us exactly what you would like to receive or what specifically concerns you. This will help us act more quickly and shorten the time it takes to respond to your request.

Rights of third parties.

We do not have to comply with a request if it would adversely affect the rights and freedoms of other data subjects.

Rights covered

Access

You may ask us:

• to confirm whether we are processing your personal data;
• to provide you with a copy of this data;
• to provide you with other information about your personal data, such as the data we hold, what we use it for, who we disclose it to, whether we transfer it abroad and how we protect it, how long we retain it, what rights you have, how you can lodge a complaint, and where we obtained your data from, to the extent that this information has not already been provided to you through this notice.

Rectification

You may ask us to rectify or complete your inaccurate or incomplete personal data.

We may attempt to verify the accuracy of the data before rectifying it.

Erasure of data

You may ask us to erase your personal data, but only where:

• it is no longer necessary for the purposes for which it was collected; or
• you have withdrawn your consent (where processing is based on consent); or
• you exercise a legal right to object; or
• it has been processed unlawfully; or
• we are subject to a legal obligation to do so.

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

• for compliance with a legal obligation; or
• for the establishment, exercise or defence of a legal claim.

There are certain other circumstances in which we are not obliged to comply with your erasure request, although these two are the most likely circumstances in which we might refuse such a request.

Please note that, before exercising this right, you should download from your Alexandra Catana® account and save all documents related to orders placed with Alexandra Catana®, regardless of whether invoicing was carried out to you or to another natural or legal person. If you do not do this before exercising your right to erasure, you will lose all these documents, and Alexandra Catana® will be unable to provide them to you afterwards, as applicable, since the process of deleting data, respectively the Alexandra Catana® account, together with all associated data and documents, is an irreversible process.

Restriction of processing

You may ask us to restrict the processing of your personal data, but only where:

• its accuracy is contested (see the rectification section), to allow us to verify its accuracy; or
• the processing is unlawful, but you do not want the data to be erased; or
• it is no longer necessary for the purposes for which it was collected, but you need it to establish, exercise or defend a legal claim; or
• you have exercised your right to object, and verification as to whether our rights override yours is in progress.

We may continue to use your personal data following a restriction request, where:

• we have your consent; or
• for the establishment, exercise or defence of a legal claim; or
• to protect the rights of Alexandra Catana® or of another natural or legal person.

Data portability

You may ask us to provide you with your personal data in a structured, commonly used, machine-readable format, or you may request that it be “ported” directly to another data controller, but in each case only if:

• the processing is based on your consent or on the conclusion or performance of a contract with you; and
• the processing is carried out by automated means.

Objection

You may object at any time, on grounds relating to your particular situation, to the processing of your personal data based on our legitimate interest, where you consider that your fundamental rights and freedoms override that interest.

You may also object at any time to the processing of your data for direct marketing purposes (including profiling), without giving any reason, in which case we will stop this processing as soon as possible.

Automated decision-making

You may request not to be subject to a decision based solely on automated processing, but only where that decision:

• produces legal effects concerning you; or
• similarly affects you in a significant way.

This right does not apply where the decision reached as a result of automated decision-making:

• is necessary for us to enter into or perform a contract with you;
• is authorised by law and there are adequate safeguards for your rights and freedoms; or
• is based on your explicit consent.

Complaints

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 data protection supervisory authority are as follows:

National Supervisory Authority for Personal Data Processing

28-30 G-ral. Gheorghe Magheru Blvd., Sector 1, postal code 010336, Bucharest, Romania

Telephone: +40.318.059.211 or +40.318.059.212;

E-mail: anspdcp@dataprotection.ro

Without affecting your right to contact the supervisory authority at any time, please contact us first, and we promise to make every effort necessary to resolve any issue amicably.