CONFIDENTIALITY POLICY ON THE PROCESSING OF PERSONAL DATA

 

We consider ensuring the right to the protection of personal data as a commitment of BELT, therefore we will devote all the resources and efforts necessary to process your data in full compliance with Regulation (EU) 2016/679 ("General Data Protection Regulation" or " GDPR "), as well as any other legislation applicable in the territory of Romania. As 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 interacting with us in connection with our products and services, including through our website www.belt-concept.com

We reserve the right to periodically update and modify this Privacy Policy, to reflect any changes in the way we process your personal data or any changes to legal requirements. In the event of any such changes, we will post the modified version of the Privacy Policy on our website. As such, we kindly ask you to periodically check the contents of this Privacy Policy.

WHO WE ARE AND HOW YOU CAN CONTACT US

BELT is the commercial name of BELT STORE SRL, a legal entity of Romanian nationality, having its registered office in 6 Scarisoara Street, 1st Floor, Ap. 12, Sector 1, Bucharest, Romania, registered with the Trade Register under no. J40/4377/2017, having unique fiscal registration code 37305659 (hereinafter "BELT STORE SRL" or "us"). For the purpose of data protection legislation, we are an operator when we process your personal data.

Since we are always open to find out your opinion, as well as to provide you with any additional information you may need regarding the processing of your data, we encourage you to contact us by e-mail at contact@belt-concept.com or by post or courier at the following address of our workshop: BELT STORE SRL, 63 Mihai Viteazu Street, Selimbar, 557260, Sibiu County, Romania.

WHAT PERSONAL DATA CATEGORIES WE PROCESS

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

• When you create a personal account on our website, you send us: the e-mail address, first and last name;

• Within your personal page (My Account) from the website you can add additional information, such as: mobile phone number, landline number, delivery addresses, billing addresses, etc.;

• When placing an order, you provide us with information such as: the desired product, first and last name, delivery address, billing address and details, payment method, e-mail address, telephone number, bank card details etc.

We may also collect and process certain information about your behaviour while visiting our website, to personalize your online experience and to provide you with offers tailored to your profile. If you are a visitor to our website, we will process your personal data you provide:

(i)           Directly in the context of using the site, such as the data you provide in the contact/questions/complaints section, as long as you contact us in this way; or

(ii)        Indirectly, such as IP address, browser used, browsing duration, search history, operating system used, language and pages viewed, full URLs, click sequence to, through and from our site, information or products viewed / searched, the duration of visits to certain pages, information on the interaction with the pages (e.g. scrolling, clicks, mouse swipes), data on user behaviour.

We invite you to find out more details in this regard by consulting the section regarding the purposes of processing below.

On our website we can store and collect information in cookies and similar technologies, according to the Cookies Policy.

We do not collect and otherwise process sensitive data, included in the GDPR in special categories of personal data. Also, we do not want to collect or process data of minors. BELT STORE SRL does not have the purpose of requesting information of any kind from persons under the age of 18 (eighteen) years. If, by mistake, we enter into possession of such information and we are informed of such fact, we will make our best efforts to obtain the appropriate parental consent to use the respective information or, if such is not possible, we will delete the information from our servers. If you wish to inform us on any persons under the age of 18 (eighteen) that took contact with us or our website, please write to us on email at contact@belt-concept.com.

WHAT ARE THE PURPOSES AND GROUNDS FOR PROCESSING PERSONAL DATA

We will use your personal data for the following purposes:

1. To provide our products and services to your benefit

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

• Creation and administration of the account within the www.belt-concept.com platform;

• Processing of orders, including taking, validating, shipping and billing of orders;

• Solving cancellations or problems of any kind regarding an order, the goods or services purchased;

• Returning the products according to the legal provisions;

• Reimbursement of the value of the products according to the legal provisions;

• Providing support services, including providing answers to your questions.

The processing of your data for these purposes is in most cases necessary for the conclusion and execution of a contract between BELT STORE SRL and you. Also, certain processing subordinated to these purposes is required by the applicable law, including tax and accounting legislation.

2. To improve our services

We always want to offer you the best online shopping experience. For this purpose, we may collect and use certain information regarding your behavior as buyer, we can invite you to complete satisfaction questionnaires following the completion of an order or we can carry out, directly or with the help of our partners, studies and market researches.

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 updated on the best offers for the products/services you are interested in. In this regard, we can send you any type of message (such as e-mail/SMS/telephone/mobile push/webpush etc.) containing general/thematic information or offers, information on products similar or complementary to those you have purchased, information about offers or promotions, information about products added in the "Account”, “Order History”, “Wishlist" sections or about products that you have shown interest in, as well as other commercial communications such as market researches and opinion polls and we can display personalized recommendations on the website. In order to provide you with information of interest to you, we may use certain data about your buyer behavior (e.g, products viewed/added to wishlist/purchased) in order to create your profile. We always make sure that these processes are carried out in compliance with your rights and freedoms and that the decisions taken based on them have no legal effects on you and will not affect you to a significant extent.

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 the client account in the "My Account" section;

• Accessing the unsubscribe link displayed in the messages you receive from us; or

• Contacting us using the contact details described above.

In certain situations, we can base our marketing activities on our legitimate interest to promote and develop our commercial activity. In any situation where we use information about you for our legitimate interest, we take care and take all necessary measures so that your fundamental rights and freedoms are not affected. However, you can request us at any time, by the means described above, to stop the processing of 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 to protect our rights and commercial activity. These may include:

• Protecting the website and users of the website against cyber-attacks;

• Measures to prevent and detect fraud attempts, including the transmission of information to the competent public authorities;

• Management measures for various other risks.

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

Also, in certain cases we start processing on legal provisions, such as the obligation to ensure the protection of goods and values provided by the applicable legislation in this field.

HOW LONG TIME WE KEEP YOUR PERSONAL DATA

As a general rule, we will store your personal data as long as you have an account on the www.belt-concept.com platform. You can request us at any time to delete certain information or to close the account and we will further respond to these requests, subject to the preservation of certain information including after closing the account, in situations where the applicable law or our legitimate interests require it.

TO WHOM WE TRANSMIT YOUR PERSONAL DATA

As the case may be, we may transmit or provide access to certain personal data of your own to the following categories of recipients:

• companies within the same group of companies as BELT STORE SRL;

• courier service providers;

• payment / banking service providers;

• marketing / telemarketing service providers;

• market research service providers;

• insurance companies;

• IT service providers;

• to other companies with which we can develop joint programs to offer 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 third parties which are legal persons of private law is made in accordance with the legal provisions on data protection and confidentiality of information, based on contracts entered into with them.

IN WHICH COUNTRIES WE TRANSFER YOUR PERSONAL DATA

Currently, we store and process your personal data on the territory of Romania.

However, it is possible to transfer certain personal data of your own to entities located in the European Union or outside the European Union, including in countries where the European Commission has not recognized an adequate level of protection of personal data.

We will always take steps to ensure that any international transfer of personal data is carefully managed in order to protect your rights and interests. Transfers to service providers and other third parties will always be protected by contractual commitments and, as the case may be, by other guarantees, such as standard contractual clauses issued by the European Commission or certification schemes.

You can contact us anytime, using the contact details set out above, to find out more information about the countries in which we transfer your data, as well as the guarantees we have implemented regarding these transfers.

HOW DO WE PROTECT THE SECURITY OF YOUR PERSONAL DATA

We are committed to ensuring 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.

To make payments we use the services of the payment processor Europayment Services (euplatesc). All payment information is encrypted.

Despite the measures taken to protect your personal data, we draw your attention that the transmission of information over the internet, in general, or through other public networks, is not completely secure, with the risk that the data may be viewed and used by unauthorized third parties. We cannot be held responsible for such vulnerabilities of systems that are not under our control.

WHAT RIGHTS DO YOU HAVE

The General Data Protection Regulation will recognize a number of rights in relation to your personal data. You may request access to your data, correct any errors in our files and/or object to the processing of your personal data. You can also exercise your right to complain to the competent supervisory authority or to bring justice. If applicable, 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 details presented below.

In order to exercise your rights, you can contact us using the contact details above. Please keep in mind the following:

Identity.

We take seriously the confidentiality of all records that contain personal data. For this reason, please send us your requests regarding such registrations using the email address of the registered account. Otherwise, we reserve the right to verify your identity by requesting additional information that aims to confirm your identity.

Fees.

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

Duration of response.

We set ourselves to respond to any valid requests within 10 (ten) business days, unless this is particularly complicated or impossible due to external circumstances or if you have made several requests, in which case we will respond within one month. We will let you know if we need more than 10 (ten) business days. It may be possible that we ask you several questions on what you want to receive or what you are worried about. This will help us act faster and shorten the response time to your request.

THIRD PARTY RIGHTS.

We should not comply with a request if it would adversely affect the rights and freedoms of other referred people.

OTHER RIGHTS

Access

 You can ask us:

• to confirm if we process your personal data;

• to make available a copy of this data;

• to provide you with other information about your personal data, such as the data we have, what we use, to whom we disclose, if we transfer them abroad and how we protect them, how long we keep them, what rights you have, how you can make a complaint, from where we obtained your data, to the extent the information in cause has not been already provided to you before.

Rectification

You may ask us to rectify or supplement your inaccurate or incomplete personal data. It is possible for us to try to verify the accuracy of the data before we rectify it.

Deletion of Data

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 the data processing is based on your consent); or

• pursue a legal right to oppose; or

• they were processed illegally; or

• we have a legal obligation in this regard.

We have no obligation to comply with your request for deletion of your personal data in case the processing of your personal data is required:

• for compliance with a legal obligation; or

• for finding, exercising or defending a right in court.

On a case by case basis, there might be certain other circumstances in which we will have no obligation to comply with your request for deletion of data.

Please note that prior to exercising this right you must access your account on www.belt-concept.com in order to download and save all documents related to orders placed on the website, regardless whether the billing was done to you or to another natural or legal person (such as: invoices, warranty certificates). If you do not do this before you exercise your right to delete the information, you will lose all these documents and information and BELT STORE SRL will be unable to restore them or to make them available, as the case may be, as the deletion process (including the deletion of the account) is irreversible.

RESTRICTION OF DATA PROCESSING

You can ask us to restrict the processing of personal data, but only if:

• their accuracy is challenged (see the rectification section), to allow us to check their accuracy; or

• processing is illegal, 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 find, exercise or defend a right in court; or

• You have exercised your right to oppose and checking whether our rights prevail is in progress.

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

• we have your consent; or

• to ascertain, exercise or ensure the defense of a right in court; or

• to protect the rights of BELT STORE SRL or of other natural or legal persons.

PORTABILITY OF DATA

You can ask us to provide you with your personal data in a structured, commonly used and automatically readable format, or you can request that this to be "ported" directly to another data operator, but in each case only if:

• processing is based on your consent or on the conclusion or execution of a contract with you; and

• processing is done by automatic means.

OPPOSITION

You may object at any time, for reasons related to the particular situation in which you are, to the processing of your personal data based on our legitimate interest, if you consider that your fundamental rights and freedoms prevail over that interest.

Also, you can oppose at any time to the processing of your data for the purpose of direct marketing (including the creation of profiles), without invoking any reason, in which case we will stop this processing as soon as possible.

AUTOMATIC DECISION MAKING

You can ask not to be the subject of a decision based solely on automatic processing, but only if the decision in cause:

• produces legal effects on you; or

• it will affect you in a similar way and to a significant extent.

This right does not apply if the decision reached following the automatic decision making:

• is necessary for us to conclude or carry out a contract with you;

• is authorized by law and there are adequate guarantees 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 the following:

National Supervisory Authority for Personal Data Processing (Autoritatea Nationala de Supraveghere a Prelucrarii Datelor cu Caracter Personal)

28-30 G-ral Gheorghe Magheru Boulevard, Sector 1, ZIP 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 before you do that and we promise we will make every effort to resolve any problem amicably.

Please note that you can contact us at any time by sending your request as follows:

  • by email at: contact@belt-concept.com or
  • by post or courier to the address of our workshop: BELT STORE SRL, 63 Mihai Viteazu Street, Selimbar, 557260, Sibiu County, Romania.