PRIVACY POLICY

CONCERNING THE PROCESSING OF PERSONAL DATA

Respect for your privacy is one of our fundamental commitments and therefore we pay the utmost attention to the processing of your personal data in accordance with applicable law. 

REILIN TREE SRL, based in INT. MARGĂRITARULUI, NO. 2, ET.PARTER, AP.CAM 1, Otopeni, Ilfov, fiscal identification code 31699074, registered at the Trade Registry Office under no. J23/1104/2014 ("REILIN TREE SRL","we") processes, as an operator, your personal data ("Personal data"). The purpose of this information note ("policy") is to detail how REILIN TREE SRL processes your Personal Data.

1. PERSONAL DATA PROCESSED, PROCESSING PURPOSES AND PROCESSING BASIS 

1. Contacting the customer online

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

Purpose of processing	The legal basis
Contacting the customer online in relation to the requested offer or in relation to the solution of the indicated problem	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)

2. Ordering and delivery of products

2.1. Making the payment

Personal data processed: name, surname, payment amount, bank card details.

Purpose of processing	The legal basis
Making payment for purchased products	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)

2.2. 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	The legal basis
Order completion and placement	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)

3. Marketing (Newsletter, promotions, offers)

3.1. Commercial messages

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

Purpose of processing	The legal basis
Sending commercial messages for the purpose of promoting the company's services	Consent of the data subject (art. 6, par. 1, letter a of the GDPR)

4. Customer opinion (feedback)

Personal data processed: name, surname, e-mail address, other information mentioned by the customer.

Purpose of processing	The legal basis
Soliciting and analyzing customer feedback to improve services	Consent of the data subject (art. 6, par. 1, letter a of the GDPR)

5. Dispute Resolution

5.1. Contentious issues

Personal data processed: name, surname, home address.

Purpose of processing	The legal basis
Defending legitimate rights and interests and supporting any claims before judicial bodies or any other public authorities	The legitimate interest of the Company (art. 6, paragraph 1, letter f of the GDPR) Details: the legitimate interest of the company to defend its rights or legitimate interests or to support claims resulting from or closely related to the conclusion or execution of the contract or in order to exercise the right of defense in the event of the initiation of litigious proceedings against the company

2. PROVIDING PERSONAL DATA

You may refuse to provide certain Personal Data but, in such case, you may not be able to benefit from certain services specific to the relationship described in this Policy.

3. ABOUT THE LEGAL GROUNDS

The legal basis for processing differs depending on the specific situation and the Personal Data processed.

In situations where we will process your Personal Data based on consent, we will request your free, informed, specific and unequivocal consent for said processing. By expressing your consent, you agree that we may collect, use, disclose, process and transfer your Personal Data in accordance with this Policy.

4. SOURCE OF PERSONAL DATA

The source of Personal Data is: the online customer. 

5. AUTOMATIC PROCESSING OF PERSONAL DATA

Your Personal Data will not be processed in order to generate decisions based exclusively on automatic processing that would produce legal effects on you or affect you to a significant extent, within the meaning of the provisions of art. 22 para. (1) of the GDPR.  

6. PROCESSING DURATION

The duration of processing of Personal Data differs depending on the specific processing operation:

operation	Duration
Contacting the customer online	the time required to resolve the request
Making the payment	until the payment is completed
Placing the order	3 years
Commercial messages	until the withdrawal of consent
Customer opinion (feedback)	the time needed to analyze the opinion
Contentious issues	the time required to resolve the dispute

In certain circumstances, we may retain Personal Data for longer periods of time in order to have an accurate record of your dealings with us in the event of any complaints or if we reasonably believe there is a prospect of litigation.

7. TRANSFER OF PERSONAL DATA

We may transfer Personal Data, to the extent necessary, to the following categories of recipients: IT service providers, payment service providers, marketing service providers, state authorities.

These recipients may be located in the European Union and/or the European Economic Area, as well as outside them, including in countries that are not recognized as ensuring an adequate level of protection, in which case the transfer of Personal Data is carried out only if there is appropriate safeguards in accordance with applicable law (such as standard contractual clauses issued by the European Commission). You can request a list of recipients from third countries, as well as a copy of the agreed provisions that ensure an adequate level of protection of Personal Data. 

8. SECURITY OF PERSONAL DATA 

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 them, such as limiting access to Personal Data, encryption or anonymization of 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 all times. 

9. RIGHTS REGARDING THE PROCESSING OF PERSONAL DATA

Right of access: You have the right to obtain confirmation from us that your Personal Data are processed by us, as well as information regarding the specifics of the processing such as: the purpose, the categories of Personal Data processed, their recipients, the period for which they are kept, their source, whether we transfer them abroad and how we protect them, your rights, the right to lodge a complaint with a supervisory authority. 

Right to rectification: You have the possibility to request the rectification of your Personal Data, provided that the applicable legal requirements are met. In the event of errors, after notification, we will immediately correct your Personal Data. 

Right of deletion: In certain cases, you have the possibility to request the deletion of Personal Data, such as when: (i) it is no longer necessary for the purposes for which we collected and processed it; (ii) you have withdrawn your consent for the processing of the Personal Data and we can no longer process the Personal Data on the basis of other legal grounds; (iii) Personal Data are processed contrary to the law; (iv) exercise a legal right to object. We are not obliged to comply with your deletion request if the processing of Personal Data is necessary to comply with a legal obligation, or to establish, exercise or defend a right in court. There are also other circumstances in which we are not obliged to comply with this request to delete Personal Data. 

Restriction of processing: You may request that we restrict the processing of your Personal Data in the following situations: (i) if you dispute the correctness of the Personal Data, for a period that allows us to verify the accuracy of the Personal Data in question; (ii) if the processing is unlawful, and you object to the deletion of the Personal Data, requesting instead the restriction of its use; (iii) if we no longer need the Personal Data for the purpose of processing, but you request it for a court action; (iv) if you have objected to the processing, for the period of time in which it is checked whether our legitimate rights as an operator prevail over those of the data subject. We may continue to use Personal Data following a restriction request if: (i) we have your consent; (ii) to ascertain, exercise or ensure the defense of a right in court; or (iii) to protect the rights of another natural or legal person.

The right to data portability: To the extent that Personal Data is processed on the basis of your consent or for the execution of the contract and the processing is done by automated means, you have the right to have your Personal Data provided to you in a structured, commonly used format that can be read automatically and you have the right to transmit this Personal Data to another operator. This right does not adversely affect the rights and freedoms of others.

The right to opposition: In certain situations, such as when we process your Personal Data based on a legitimate interest, you have the right to object to our processing of your Personal Data. In case of unjustified opposition, REILIN TREE SRL is entitled to continue processing the Personal Data. You can also object to the processing of your Personal Data for the purpose of sending commercial messages.

Revocation of consent: To the extent that we process your Personal Data on the basis of your consent, you may revoke your consent at any time, without affecting the lawfulness of the processing based on consent prior to its withdrawal.

The automated individual decision-making process: You have the right not to be subject to a decision based solely on automated processing, including profiling, that produces legal effects on you or similarly affects you to a significant extent. This right does not apply where the decision: (i) is necessary for the conclusion or performance of a contract between you and us; (ii) is authorized by law that provides and provides adequate safeguards for your rights and freedoms; (iii) is based on your explicit consent.

The right to address the supervisory authority: You have the right to lodge a complaint with the National Authority for the Supervision of the Processing of Personal Data (“ANSPDCP”) in relation to any violation of your rights regarding the processing of your Personal Data. The contact details of ANSPDCP are: B-dul G-ral. Gheorghe Magheru 28-30, Sector 1, postal code 010336 Bucharest, Romania; e-mail: anspdcp@dataprotection.ro.

To exercise the rights mentioned above, please contact us at the e-mail address: info@trapped.ro.

10. CONTACT

If you have questions or concerns regarding this Policy or its implementation, you can contact us at the email address: info@trapped.ro.