We consider ensuring the right to personal data protection as a fundamental commitment of REFURBINI, therefore we will dedicate all necessary resources and efforts to process your data in full compliance with Regulation (EU) 2016/679 ("General Data Protection Regulation" or "GDPR"), as well as with any other applicable legislation in Romania. As one of the essential principles of this legal framework is transparency, we have prepared this document through which we want 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 mobile applications.
We reserve the right to update and modify this Privacy Policy periodically, to reflect any changes in how we process your personal data or any changes in legal requirements. In case of any such modification, we will display the modified version of the Privacy Policy on our website, which is why we ask you to periodically check the content of this Privacy Policy.
REFURBINI is the trade name of S.C. REFURBINI SRL, CUI 44037079, J12/1643/2021, with its registered office at Str. Poet Grigore Alexandrescu nr. 47 Sc. 1, Ap.10 Cluj-Napoca, Cluj County. (hereinafter referred to as REFURBINI). For the purposes of data protection legislation, we are a data controller when we process your personal data.
As we are always open to hearing your opinions and providing you with any additional information you may need regarding the processing of your data, we encourage you to contact REFURBINI's Data Protection Officer at the e-mail address contact@liviualexa.com or by mail or courier to the address Str. Poet Grigore Alexandrescu nr. 47 Sc. 1, Ap.10 Cluj-Napoca, Cluj County, with the mention: "for the attention of REFURBINI's Data Protection Officer".
In general, we collect your personal data directly from you, so you have control over the type of information you provide to us. For example, we receive information from you as follows:
When you create a REFURBINI account, you provide us with: your e-mail address, first name and last name;
Within your personal page (My Account) on the REFURBINI platform, you have the option to add additional information, such as: photo, gender, nickname, mobile phone number, landline phone number, date of birth, education level, 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 last name, delivery address, billing details, payment method, phone number, bank card details, etc.
We may also collect and subsequently process certain information regarding your behavior during your visit to our website or when using the smartphone application, to personalize your online experience and provide you with offers tailored to your profile. We invite you to find out more details in this regard by consulting the section on processing purposes below.
On our website and in the smartphone application, we may store and collect information in cookies and similar technologies, in accordance with the Cookie Policy.
We do not collect or otherwise process sensitive data, included by the General Data Protection Regulation in special categories of personal data. Also, we do not wish to collect or process data of minors under the age of 16.
We will use your personal data for the following purposes:
1. For the provision of REFURBINI services for your benefit.
This general purpose may include, as appropriate, the following:
a) Creation and administration of the account within the REFURBINI platform;
b) Processing of orders, including their taking, validation, shipping, and invoicing;
c) Resolution of cancellations or problems of any nature related to an order, purchased goods, or services;
d) Return of products according to legal provisions;
e) Refund of the value of products according to legal provisions;
The processing of your data for these purposes is in most cases necessary for the conclusion and execution of a contract between REFURBINI and you. Also, certain processing subsumed to these purposes is imposed by applicable legislation, including tax and accounting legislation.
2. For improving our services
We constantly want to offer you the best online shopping experience. For this, we may collect and use certain information related to your Buyer behavior, we may invite you to complete satisfaction questionnaires subsequent to the completion of an order or we may conduct, directly or with the help of partners, market studies and research.
We base these activities on our legitimate interest in conducting commercial activities, always taking care that your fundamental rights and freedoms are not affected.
3. For marketing
We want to keep you informed about the best offers for products/services that interest you. In this regard, we may send you any type of message (such as: e-mail/SMS/telephone/mobile push/webpush/etc.) containing general and thematic information, information regarding similar or complementary products to those you have purchased, information regarding offers or promotions.
To provide you with information of interest to you, we may use certain data regarding your buying behavior (e.g., products viewed / added to wishlist / purchased) to create a profile for you. We always ensure that these processing operations are carried out in compliance with your rights and freedoms and that the decisions made based on them do not have legal effects on you and do not significantly affect you in a similar way.
In most cases, we base our marketing communications on your prior consent. You can change your mind and withdraw your consent at any time, by:
– Changing the settings in your customer account in the "My Subscriptions" section;
– Accessing the unsubscribe link displayed in the messages you receive from us; or by
– Contacting REFURBINI using the contact details described above.
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. However, you can always ask us, by the means described above, to stop processing your personal data for marketing purposes, and we will comply with your request.
4. For defending our legitimate interests
There may be situations where we will use or transmit information to protect our rights and commercial activity. These may include:
– Measures to protect the website and the users of the REFURBINI platform against cyber attacks;
– Measures to prevent and detect fraud attempts, including transmitting information to 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.
Also, 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 law in this matter.
As a general rule, we will store your personal data as long as you have an account on the REFURBINI platform. You can ask us at any time to delete certain information or close your account, and we will comply with these requests, subject to retaining certain information even after closing the account, in situations where applicable law or our legitimate interests require it.
As appropriate, we may transmit or offer access to certain of your personal data to the following categories of recipients:
– companies within the same group of companies as REFURBINI;
– 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 programs for offering our goods and services on the market.
If we have a legal obligation or if it is necessary to defend a legitimate interest, we may also disclose certain personal data to public authorities.
We ensure that access to your data by private legal entities is carried out in accordance with legal provisions on data protection and information confidentiality, based on contracts concluded with them.
Currently, we store and process your personal data in Romania. However, we may transfer certain of your personal data to entities located in the European Union or outside the Union, including in countries for which the European Commission has not recognized an adequate level of personal data protection. We will always take measures to ensure that any international transfer of personal data is carefully managed with the aim of protecting your rights and interests. Transfers to service providers and other third parties will always be protected by contractual commitments and, where appropriate, by other safeguards, such as standard contractual clauses issued by the European Commission or certification schemes, such as the Privacy Shield for the protection of personal data transferred from within the EU to the United States of America. You can contact us at any time, using the contact details provided above, to find out more information about the countries to which we transfer your data, as well as the safeguards we have implemented regarding these transfers.
We undertake to ensure the security of personal data by implementing appropriate technical and organizational measures, according to industry standards.
The transmission of your personal data is done using state-of-the-art encryption algorithms and we store them on secure servers, while ensuring data redundancy.
For payments, we use the services of the STRIPE payment processor.
Despite the measures taken to protect your personal data, we draw your attention to the fact that the transmission of information via 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 unauthorized third parties. We cannot be responsible for such vulnerabilities of systems that are not under our control.
The General Data Protection Regulation recognizes a series of rights in connection with your personal data. You can request access to your data, correction of any errors in our files, and/or you can object to the processing of your personal data. You can also exercise your right to complain to the competent supervisory authority or to appeal to the courts. Where appropriate, you may also benefit from the right to request the deletion of your personal data, the right to restrict the processing of your data, and the right to data portability.
More information about each of these rights can be obtained by consulting the table presented below.
To exercise your rights, you can contact us using the contact details provided above. Please note the following if you wish to exercise these rights:
Identity. We take the confidentiality of all records containing personal data seriously. For this reason, please send us your requests regarding such records using the email address associated with your REFURBINI account. Otherwise, we reserve the right to verify your identity by requesting additional information aimed at confirming your identity.
Fees. We will not charge a fee for exercising any right regarding your personal data, unless your request for information access is unfounded, repetitive, or excessive, in which case we will charge a reasonable amount in such circumstances. We will inform you of any applicable fees before resolving your request.
Response time. We aim to respond to any valid requests within a maximum of one month, unless this is particularly complicated or if you have made multiple requests, in which case we will respond within a maximum of two months. We will let you know if we need more than one month. We may ask you if you can tell us exactly what you want to receive or what you are concerned about. This will help us act faster and shorten the response time to your request.
Third-party rights. We do not have to comply with a request if it would negatively affect the rights and freedoms of other data subjects.
Affected Rights.
Description
Access
You can ask us:
• to confirm whether we process your personal data;
• to provide you with a copy of these data;
• to provide you with other information about your personal data, such as the data we have, what we use it for, to whom we disclose it, whether we transfer it abroad and how we protect it, how long we keep it, what rights you have, how you can make a complaint, where we obtained your data, to the extent that the information has not already been provided to you through this notice.
Rectification
You can ask us to rectify or complete your inaccurate or incomplete personal data.
We may try to verify the accuracy of the data before rectifying them.
Data deletion
You can ask us to delete your personal data, but only if:
• they are no longer necessary for the purposes for which they were collected; or
• you have withdrawn your consent (if data processing was based on consent); or
• you are exercising a legal right to object; or
• they have been processed unlawfully; or
• we have a legal obligation to do so.
We are not obliged to comply with your request to delete your personal data if the processing of your personal data is necessary:
• to comply with a legal obligation; or
• for the establishment, exercise, or defense of a right in court.
There are certain other circumstances in which we are not obliged to comply with your request to delete data, although these two are the most probable circumstances in which we might refuse this request.
Please note that before exercising this right, you should download from your REFURBINI account and save all documents related to orders placed with REFURBINI, regardless of whether the invoicing was done to you or to another natural or legal person (such as: invoices, warranty certificates). If you do not take this step before exercising your right to erasure, you will lose all these documents and REFURBINI will be unable to provide them to you, as appropriate, because the process of deleting data, i.e., the REFURBINI account, with all its associated data and documents, is an irreversible process.
Restriction of data processing
You can ask us to restrict the processing of personal data, but only if:
• their accuracy is contested (see the rectification section), to allow us to verify their accuracy; or
• the processing is unlawful, but you do not want the data to be deleted; or
• they are no longer necessary for the purposes for which they were collected, but you need them to establish, exercise, or defend a right in court; or
• you have exercised your right to object, and the verification of whether our rights prevail is ongoing.
We may continue to use your personal data following a request for restriction, if:
• we have your consent; or
• for the establishment, exercise, or defense of a right in court; or
• to protect the rights of REFURBINI or another natural or legal person.
Data portability
You can ask us to provide you with your personal data in a structured, commonly used, and machine-readable format, or you can ask for it to 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 execution of a contract with you; and
• the processing is carried out by automated means.
Objection
You can object at any time, for reasons related to your particular situation, to the processing of your personal data based on our legitimate interest, if you consider that your fundamental rights and freedoms prevail over this interest.
You can 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 can ask not to be subject to a decision based solely on automated processing, but only when that decision:
• produces legal effects concerning you; or
• similarly significantly affects you.
This right does not apply if the decision reached as a result of automated decision-making:
• is necessary for us to conclude or perform a contract with you;
• is authorized 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 supervisory authority for data protection are:
National Supervisory Authority for Personal Data Processing
B-dul G-ral. Gheorghe Magheru no. 28-30, Sector 1, postal code 010336, Bucharest, Romania
Phone: +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 beforehand, and we promise that we will make all necessary efforts to resolve any issue amicably.
• We remind you that you can contact REFURBINI's Data Protection Officer at any time by submitting your request through any of the following methods:
– by e-mail to: contact@liviualexa.com or
– by mail or courier to: Str. Poet Grigore Alexandrescu nr. 47 Sc. 1, Ap.10 Cluj-Napoca, Cluj County – with the mention "for the attention of REFURBINI's Data Protection Officer".