Information note
Information notice regarding the protection of personal data Policolor
Summary
This document, constitutes the information note regarding the activities carried out by Policolor SA in which your personal data are involved, will provide the necessary aspects to be informed in the most appropriate way about the course of this data within the organization .
Thus, Policolor SA represents the entity that will process your personal data. These data can most often be: name, surname, telephone number, e-mail address, and will be received and processed in various situations, such as: selling products, issuing loyalty cards, marketing activities, etc. If it will be the case, we will obviously have to use your personal data in order to respond to your requests or to communicate to you aspects that you need to know.
We also want you to be informed of the fact that the personal data we work with may come directly from you (when you place an order in physical stores or online, for example), from a third party (if the agencies marketing with which we collaborate provides us with your data as a participant in organized contests) or from the activities carried out in the commercial relations between you. and Policolor.
What entitles us to process your personal data is, first of all, the need to conclude and execute the contract for the sale of Policolor products and/or the provision of services, (according to art. 6 letter b) in the absence of the provision and use of personal data being unable to exist such a contract. Another basis on which we process personal data is the consent you give us, (according to art. 6, para. 1, lit a) regarding certain activities that cannot be carried out without such an agreement. We process personal data based on the legitimate interest to carry out some activities involving such data when appropriate (according to art. 6 paragraph 1 letter f).
In addition, we want you to be aware of certain rights, detailed in Chapter VIII of this document, which you can exercise whenever it is appropriate and you have reason to do so.
Important to keep in mind is that you can always contact us at the e-mail address gdpr@policolor.ro if you want to get in touch with us regarding the processing and protection of your personal data.
All this being said, in short, in what follows you have their details available, in order to form the widest possible picture regarding the course of personal data.
ContentChapter I Introduction
Chapter II Definitions and clarification of some notions
Chapter III The purposes of processing personal data and their type related to each purpose
1. Processing of personal data for the purpose of selling the products made available by Policolor
1.1. Sale of Policolor products in the online store (remote sale of products)
1.2. Selling Policolor products through various platforms
2. Processing of personal data for the purpose of registering Policolor customers in the loyalty program
3. Prelucrarea datelor cu caracter personal în scopul desfășurării concursurilor organizate de către Policolor
4. Processing of personal data for market research
5. Other categories of processing
Chapter IV Duration of data storage
Chapter V Use of service providers for personal data processing/data processing in countries outside the European Economic Area
Chapter VI Source of personal data
Chapter VII The legal basis for the processing of personal data
Chapter VII Data security
Chapter VIII Your Rights
1. Right of access
2. The right to withdraw consent
3. Right of rectification
4. Right to erasure
5. The right to data portability
6. The right to object
7. The right not to be subject to a decision based exclusively on automatic processing
Chapter IX Changes to the personal data protection policy
Chapter X Contact (for exercising the rights of data subjects)
Chapter XI The right to file a complaint
Chapter XII Questions about data protection
Chapter I Introduction
The protection of personal data is an important objective of our organization. We respect your privacy and personal life.
From May 25, 2018, 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 of repeal of Directive 95/46/EC (General Data Protection Regulation).
We manage to fulfill the provisions prescribed by this Regulation, by implementing all the protection measures related to the processing of personal data.
One of them is informing in a transparent and precise way all the users of our website www.policolor.ro (where you will find the present note), as well as Policolor’s customers.
Therefore, we will inform you below about the processing of personal data when you choose to be a customer of one of the Policolor entities or when you use the options included in our website for example the contact form.
As the operator, Policolor SA, hereinafter referred to as Policolor or the Company, is a Romanian legal entity, with headquarters in Bucharest, Bd. Timisoara, no. 98, sector 6, registered at the Trade Register J40/205/1991, having CUI RO 326318.
This personal data protection policy describes our practices regarding the processing of data, communicated directly or indirectly to our organization, as well as the use of personal data for the purpose of providing services:
· The sales process carried out through the Policolor online store;· Registration in the loyalty programs of our stores, for the registration of the loyalty card and also for the granting of loyalty bonuses.
· Sales through various platforms that facilitate this process (for example, eMag);
· Participation in various contests organized by Policolor in the online environment: Instagram, Facebook, etc.
· Marketing activities carried out through the website (eg advertising spots).
In our activity, we are responsible for strictly complying with the existing principles at the level of the Regulation, as follows:
· the principle of legality, fairness and transparency – in the sense that data processing is done in a concise, understandable form, only on the basis of a legal basis, respecting the conditions imposed by this regulation;· the principle of purpose-related limitation – data processing is carried out for a clear, well-defined and established purpose from the beginning;
· the principle of data minimization – the processed data will be only those relevant to the situation and limited only to the established purpose;
· the principle of accuracy – provides that the processed data must be accurate and up-to-date.
Our data protection practices comply with applicable law. However, if for any reason the terms set out in this data protection policy are not acceptable to you, you may notify us of your objection. at the address gdpr@policolor.ro.
Chapter II Definitions and clarification of some notions
1. Personal data
Personal data is all data that relates to you personally. In general, this includes identification data and personal characteristics (surname, surname, CNP, citizenship, home address/residence, telephone number, etc.), electronic identification data (identification elements from various applications, IP, Skype ID, ID Facebook, Instagram, etc.).2. Data subject. Processing. Operator, respectively person authorized by the operator
First of all, we would like to explain the notion of data subject, often found in this notice and beyond. By this notion is meant the person whose personal data is processed, and who benefits from protection and safety thanks to the requirements of the Regulation implemented by the operator in his activity. In Policolor’s business, this can be represented, for example, by people who use our website or people who choose to purchase our products. 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, extraction , consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, deletion or destruction. Therefore, whenever the personal data provided by you is collected and then used for the purposes described in this information note, a processing of your personal data takes place. According to the Regulation, operator means the natural or legal person, public authority, agency or other body “which, alone or together with others, establishes the purposes and means of personal data processing”. Policolor fulfills the role of operator, processing the personal data received from the concerned persons, being the one that establishes the purposes and means of processing this data. Thus, it is obliged to ensure the compliance of its processing activity with the rules imposed by the Regulation, with the aim of providing data security to the data subjects, who entrust their personal data to fulfill certain purposes. Also in the text of the Regulation, the notion of a person authorized by the operator is defined as “the natural or legal person, public authority, agency or other body that processes personal data on behalf of the operator”. It will not process the personal data of the persons concerned except with the consent of the operator, within the limits and conditions imposed by it. In the present situation, the persons authorized by the operator may be the persons with certain duties within its activity and who come into contact with the personal data of the persons concerned in the course of their activities, such as various suppliers or collaborators (for example, the advertising agency).Chapter III The purposes of processing personal data and their type related to each purpose
In the following, we will present in turn the purposes for which your data of a personal nature are processed at the level of our organization, exemplifying for each of these purposes the categories of personal data discussed. 1. Processing of personal data for the purpose of selling the products made available by Policolor As its main activity, Policolor offers specific products to interested parties: paints, varnishes, finishing materials, etc. As its main activity, Policolor offers specific products to interested parties: paints, varnishes, finishing materials, etc.1.1. Sale of Policolor products in the online store (remote sale of products)
In this activity, the Company processes the following categories of personal data, necessary for the invoicing process: · name surname;· residential address;
· email address;
· customer account details;
· name of the person who takes/receives the products.
· financial data related to payments (bank card, bank account)
· delivery address details (where applicable)
· opinions related to the purchased products or recommendations regarding use
1.2. Selling Policolor products through various platforms
· company/personal e-mail address;
· title;
· signature.
· financial data related to payments (bank card, bank account)
· delivery address details (where applicable)
2. Processing of personal data for the purpose of registering Policolor customers in the loyalty program
As part of this process, if you are interested in being part of Policolor’s loyalty program, you will have at your disposal in partner stores/online platforms/Policolor representatives, filling out a form with the following personal data: · name,· surname,
· phone number,
· email address.
After completing the form, your card can be registered and you can use it for its intended purpose.
3. Processing of personal data for the purpose of running the contests organized by Policolor
Occasionally, the Company organizes, in collaboration with a specialized marketing agency, contests on the Policolor platforms (Instagram, Facebook, other social media platforms). These contests have Policolor products as prizes, and registration in them takes place by registering the user ID on one of these platforms. If you are the winner of one of these contests, you will be asked for the following personal data: • name surname;• telephone number and/or e-mail address;
• prize delivery address.
For the awarding of prizes/gifts, the previously mentioned data can be supplemented with:
• identification data from the identity card: CNP, address, series and CI number• financial data: bank account
4. Processing of personal data for market research
We process your data of a personal nature for the purpose of market research and opinion polls. You can revoke the given consent at any time (with effect for the future, without stating your reasons), following which the data will be anonymized based on the express request. For this purpose, your data will be anonymized, used by us exclusively for statistical purposes, no correlations can be made with you. under no circumstances. This data processing serves in particular to improve service offers that are more relevant to you.5. Other categories of processing
Also, the processing of personal data may take place for the following processes: · updating the data,· customer satisfaction ratings,
· responses to requests,
· telephone contacts,
Our company does not request or process personal data from special categories, only non-sensitive, necessary and relevant data, unless it is legally required to do so at a later stage.
Also, it should be noted that in the sales activity carried out by Policolor, situations can also be encountered in which the customer/buyer is a person who has not yet reached the age of 16 (the case of sales-purchase contracts of products, made in the name and on behalf of minors by their legal representatives/guardians, or even by minors themselves – depending on the value of the purchased products). In this situation, the operator will ensure that all the necessary measures are taken so that the processing of their personal data will be carried out in accordance with art. 8 of the Regulation. As a clarification, the data of persons who have not reached the age of 16 will be collected only for the purpose explained above.
Chapter IV Duration of data storage
Regarding how long we keep your data is 10 years, in order to ensure continuity in case after completing the current orders or request you want to continue or make other orders or requests also through our teams. It is also good to know that your data will be kept for the entire duration of the contract.Chapter V Use of service providers for personal data processing/data processing in countries outside the European Economic Area
For the smooth development of purchase and delivery activities, it is possible to transfer data to various companies with the role of ensuring the transport of purchases (identification data, delivery location, contact data will be transferred). Independent Operators can also be used for the processing of electronic payments, for example EuroPayment Service SRL, the company that will ensure the processing of card data. For all the cases mentioned above, Policolor ensures the early validation of the supplier/independent operator and the early signing of data transfer protection clauses in accordance with the request of the Regulation Policolor does NOT use to provide the services and process your data. suppliers from outside the European Economic Area. In the event that this happens, we will ensure that our suppliers and collaborators ensure confidentiality and provide adequate protection for your data. personal, based on signed agreements.Chapter VI Source of personal data
Personal data can be obtained from the following sources: a. directly from you when: you provide the necessary billing data when you purchase our products; complete the form in order to obtain the loyalty card, etc.;b. indirectly from third parties, such as where we receive your data personal data from third parties with whom we collaborate (for example, the eMag platform or other own or partner platforms through which you place an order, the advertising agency that organizes the competitions in which you participate);
c. through the activities you carry out while you are our customer/user of the Policolor website.
Chapter VII The legal basis for the processing of personal data
The legal bases of the personal data processing operations described in this notice are: (i) the execution of a contract to which you are a party or to take steps before the conclusion of a contract of sale of our products;We would like to point out that in cases (i) and (ii), in the absence of the personal data necessary to complete the respective contract, it will be impossible to conclude it.
Our legitimate interests or those of a third party include our requirements to use your data. personal in litigation, authority investigations, marketing or advertising or for other legal purposes involving Policolor.If Policolor is obliged by a normative act (law, regulation, decision), ordinance or court ruling to communicate personal data, compliance can and will be fulfilled without the need to inform or consent to the person concerned.
Chapter VII Data security
To prevent unauthorized access, maintain data accuracy and ensure fair use of data, we implement reasonable and appropriate physical, IT and organizational security measures to effectively protect all personal data we process. The information you provide through the online platforms will be subsequently transmitted in encrypted form using the SSL (Secure Socket Layer) protocol to prevent improper use of the data by third parties. You can identify this by the fact that in the status bar of your browser a closed lock symbol appears and the URL starts with “https”. In order to improve the measures presented in the current Personal Data Protection Policy, we will make every effort to ensure that the data is correct, complete, current and relevant for the intended use, and the changes that will occur will be described in the updated version. Policolor will periodically test and review the effectiveness of the measures to protect the data against the risks of loss, incorrect use, unauthorized access, disclosure, modification or deletion/destruction without right. Your Provision of Personal Information is entirely voluntary and you have the right not to provide personal information. If you need assistance in accessing, updating, correcting or deleting personal information or if you no longer want our services, you can always send a request in this regard to the e-mail address: gdpr@policolor.ro. Among the organizational measures taken by our organization and which guarantee the safety of the processing of your personal data, the fact that the training procedure for our own employees and the persons authorized by the operator and their employees is carried out, in the sense of compliance with GDPR rules and awareness their importance. If there is a transfer of personal data from the operator to the persons authorized by him or to the employees, it is carried out under legal and security conditions, meeting the necessary guarantees. If we, as an operator, collaborate with another operator in the processing of personal data, we guarantee the conclusion, in a legal and transparent manner, of an agreement on the processing of personal data, in the content of which the disclosure is explained in detail personal data to the other operator, all done under conditions that ensure the protection of your data processing. personal.Chapter VIII Your Rights
1. Right of accessYou have the right to request information from us at any time about the data stored about you, including, among other things, its origin, the recipients or categories of recipients to whom this data is transmitted and the purpose of storage. For all other copies except the first copy, reasonable administrative costs may be charged. This does not apply to the communication of information by electronic means.
2. The right to withdraw consent If you have given your consent to the use of data on the basis of the legal basis of consent, you can withdraw it at any time with effect for the future without stating your reasons. For this, it is enough to send an e-mail to gdpr@policolor.ro. This action of yours it will not affect the data processing carried out up to that point, which remains a legal and valid process. 3. Right of rectification If your data collected by our organization are incorrect, you can request their correction at any time by contacting the project/service of interest to you. or the representative you are in contact with. 4. Right to erasureYou have the right to obtain from Policolor the deletion of your data, which can be exercised in certain circumstances provided by applicable law, including:
· the situation in which the personal data are no longer necessary in relation to the purposes of the processing;· the situation in which the data subject objects to the processing and there are no other legitimate interests that prevail for the processing;
· the situation in which personal data have been processed illegally.
Deletion of your personal data can be done at any time by requesting it through the methods already stated or using our general contact details for each project/service. As a rule, your data is deleted immediately, but no later than one month after requesting this right. If the deletion is contrary to the interests of the organization or the retention of the data is necessary according to the data retention obligations established by law, contract or by legislative or commercial regulations or other reasons provided by law, instead of deletion, only the blocking of your data can be carried out. If this is the case for your customer account, you will receive a notification from us to this effect. After deleting your data, it is no longer possible to receive information.
5. The right to data portability If you request the personal data provided to us, if you wish, we will provide or communicate to you. or another person designated by you. data in a structured, common and electronically processable format. The latter only if this is technically feasible and only related to the data you have entrusted to us. 6. The right to object You have the right to object to data processing under the conditions and cases provided by applicable law (situations that include e.g. data processing for direct marketing purposes), at any time and without stating your reasons. In addition, we inform you that by refusing all data processing processes, it is possible that the performance of the contract regarding the engaged services and the performance of the customer programs may be limited or no longer possible, thus please analyze with caution before submitting such requests. 7. The right not to be subject to a decision based exclusively on automatic processing We do not make decisions based solely on automated processing. If in the future we use automatic processing and creation of profiles within the meaning of art. 4.4, this will be done with human intervention and respecting the right to challenge the decision and express your point of view. If Policolor refuses a request from you, for example based on the right of access, we will provide you with an explanation of this decision, which you in turn have the right to legally challenge.Chapter IX Changes to the personal data protection policy
Policolor reserves the right to modify the Personal Data Protection Policy whenever necessary. If and when changes occur they will be reflected in due course in the updated version of this document. You may periodically return to this privacy policy to be informed of the latest version of this document.Chapter X Contact (for exercising the rights of data subjects)
If you contact us by e-mail at gdpr@policolor.ro or by post at the address: Bd. Tudor Vladimirescu no. 29A, et. 6, sect. 5, AFI Tech Park 1 building, Bucharest, the information provided by you. (your email address, your name and your phone number if applicable) will be stored by us to respond to your questions or requests.Chapter XI The right to file a complaint
You have the right to file a complaint with the ANSPDCP, the competent supervisory authority regarding the processing of your data. of a personal nature, if you believe that your data protection rights have been violated by using the data available in Chap. XII. Chapter XII Questions about data protection Questions related to all data processing can be directed at any time to:Adresa: Bd. Tudor Vladimirescu no. 29A, et. 6, sect. 5, cladirea AFI Tech Park 1, Bucuresti
Responsible for data protection: Serban Popa
E-mail: gdpr@policolor.ro
Telefon: 021 345 1730
Last but not least, you have the right to contact the National Supervisory Authority for the Processing of Personal Data (ANSPDCP), at the following contact details:
Web page: http://www.dataprotection.ro
e-mail: anspdcp@dataprotection.ro
Tel.: 40.318.059.211/ +40.318.059.212
Version updated on 19.08.2021