I. GENERAL INFORMATION

With registered office in Calarasi, Stirbei Voda Street no. 11, bl. J7, ground floor, registered under no. J51/761/2019, with CUI RO41600401, as data operator.

This document is intended to inform you about the processing of your personal data in the context of your use of the website www.aerooshield.com ("the Site").

II. CATEGORIES OF PERSONAL DATA PROCESSED

1. If you are a client of the Site, HASAW CONSULTING S.R.L. will process your personal data, such as your first and last name, telephone number, e-mail address, billing address, delivery address, data relating to your use of the Site, e.g. your behaviour/preferences/habits within HASAW CONSULTING S.R.L., as well as any other categories of data that you provide directly in the context of creating a user account, in the context of placing an order through the Site or in any other way resulting from the use of the Site.

If you use your Facebook or Google account to create your user account on the Site, HASAW CONSULTING S.R.L. will process the following public profile data displayed by those applications: username, e-mail address.

If you choose to create a user account only before completing an order for a product available on the Site, you will be asked for your e-mail address under which an account will automatically be created. If you do not complete your order, the e-mail address and other data provided will not be stored by S.C. HASAW CONSULTING S.R.L. and the account created will be automatically deleted.

2. If you are a visitor to the Site, S.C. HASAW CONSULTING S.R.L. will process your personal data that you provide directly in the context of your use of the Site, such as the data you provide in the contact/questions/complaints section, to the extent that you contact us in this way.

III. PURPOSES AND GROUNDS FOR PROCESSING

If you are a client of the Site, S.C. HASAW CONSULTING S.R.L. processes your personal data as follows:

to carry out the contractual relationship between you and S.C. HASAW CONSULTING S.R.L., namely for taking, validating, sending and invoicing the order placed on the Site, informing you about the status of the order, organizing the return of ordered products, etc.

Basis: The processing of your data for this purpose is based on the contract concluded between you and HASAW CONSULTING S.C., as defined in the Terms and Conditions [hyperlink to Terms and Conditions]. The provision of your personal data is necessary for the performance of this contract. Refusal to provide data may result in the impossibility of the contractual relationship between you and S.C. HASAW CONSULTING S.R.L..

2. for the fulfilment of the legal obligations incumbent upon HASAW CONSULTING S.R.L. in the context of the services provided through the Site, including obligations in tax matters, as well as in archiving matters.

Basis: The processing of your data for this purpose is required by legal obligations. Providing your data for this purpose is necessary. Refusal to provide data may result in S.C. HASAW CONSULTING S.R.L. being unable to comply with its legal obligations and therefore unable to provide you with services through the Site.

3. for marketing activities, i.e. for the transmission, through remote communication means (e-mail, sms) of commercial communications regarding the products and services offered by S.C. HASAW CONSULTING S.R.L., through the Site.

Basis: The processing of your data for this purpose is based on your consent, if you choose to provide it. [Note: Separate direct marketing consent (tick) must be collected, which does not pre-empt or condition the completion of order placement. Proof of agreement must be retained].

You can consent to the processing of your data for this purpose by ticking the appropriate box when you create your account, or after you have created your account in the My Account Information section. To unsubscribe from receiving such commercial communications, you can use the option at the end of each email/sms containing commercial communications. In addition, you can unsubscribe by going to the My Account Information section.

Providing your data for this purpose is voluntary. Refusal to provide consent to the processing of your data for this purpose will have no negative consequences for you.

for the purpose of performing various analyses, reporting on the functioning of the Site, creating consumer preference profiles, mainly to improve the experience offered on the Site.

Basis: The processing of your data for this purpose is based on the legitimate interest of S.C. HASAW CONSULTING S.R.L. to continuously improve the customer experience on the Site. Providing your data for this purpose is voluntary. Refusal to provide data for this purpose will not have negative consequences for you.

2. If you are a visitor to the Site, S.C. HASAW CONSULTING S.R.L. processes your personal data as follows:

for marketing activities, namely for the transmission, by means of remote communication (e-mail, sms), of commercial communications regarding the products and services offered by S.C. HASAW CONSULTING S.R.L. through the Site.

Basis: The processing of your data for this purpose is based on your consent, if you choose to provide it.

You can express your consent to the processing of data for this purpose by completing and ticking the appropriate box in the newsletter subscription form available on the Site. To unsubscribe from receiving such commercial communications, you can use the option at the end of each e-mail/sms containing commercial communications.

Providing your data for this purpose is voluntary. Refusal to provide consent to the processing of your data for this purpose will have no negative consequences for you.

to resolve complaints, grievances and to monitor traffic and improve your experience on the Site.

Basis: The processing of your data for this purpose is based on the legitimate interest of the S.C. HASAW CONSULTING S.R.L. to ensure the proper functioning of the Site, as well as to continuously improve the experience of visitors to the Site, including by addressing various comments, questions or complaints.

Providing your data for this purpose is voluntary. Refusal to provide data for this purpose will have no negative consequences for you.

IV.THE DURATION FOR WHICH WE PROCESS YOUR DATA

As a matter of principle, HASAW CONSULTING S.R.L. will process your personal data only as much as necessary for the purposes of the processing mentioned above.

Note: If you are a client, we will process your data for the entire duration of the contractual relationship and subsequently in accordance with the legal obligations incumbent on HASAW CONSULTING S.R.L. (e.g. in the case of financial-accounting supporting documents for which the retention period provided by law is 10 years from the end of the financial year in which they were drawn up).

Note: If you are a client and you exercise the option to delete your user account by clicking on the Delete Account button in the My Account Information section, HASAW CONSULTING S.R.L. will interpret this action as your option to unsubscribe from receiving commercial communications by which we keep you informed about the products and services offered through the site. In this regard, if you choose to delete your user account, we will no longer send you e-mails and/or sms of this kind. However, we would like to inform you that deleting your account will not automatically result in the deletion of your personal data. If you wish to stop the processing of your personal data or if you wish to have your data deleted, you can exercise your rights as detailed in point VII below. If you request to delete your account, but there is at least one active order on that account, the account deletion request can only be registered after the delivery of the products and the completion of the last active order.

If you withdraw your consent to the processing of your data for marketing purposes, HASAW CONSULTING S.R.L. will cease processing your personal data for this purpose, without however affecting the processing carried out by HASAW CONSULTING S.R.L. on the basis of the consent expressed by you prior to its withdrawal.

V. DISCLOSURE OF PERSONAL DATA

In order to fulfil the processing purposes, HASAW CONSULTING S.R.L. may disclose your data to partners, to third parties or entities that support HASAW CONSULTING S.R.L. in carrying out its activity through the Site (e.g. courier companies, IT service providers), or to central/local public authorities, in the following cases listed by way of example:

for the administration of the Site;
in situations where this communication would be necessary for the awarding of prizes or other facilities to data subjects obtained as a result of their participation in various promotional campaigns organized by S.C. HASAW CONSULTING S.R.L. through the Site;
to maintain, customize and improve the Site and the services provided through it;
for conducting data analysis, testing and research, monitoring usage trends and activity, developing security features and user authentication;
for the transmission of commercial marketing communications, under the conditions and within the limits provided by law;
where disclosure of personal data is required by law, etc.

VI. TRANSFER OF PERSONAL DATA

Personal data provided to S.C. HASAW CONSULTING S.R.L. may be transferred outside Romania, but only to countries in the European Union.

VII. RIGHTS YOU ENJOY

Under the conditions laid down in the legislation on the processing of personal data, as data subjects, you have the following rights:

the right to information, i.e. the right to receive details of the processing activities carried out by HASAW CONSULTING S.R.L., as described in this document;
the right of access to data, i.e. the right to obtain confirmation from HASAW CONSULTING S.R.L. regarding the processing of personal data, as well as details of processing activities such as the way in which the data are processed, the purpose for which the processing is carried out, the recipients or categories of recipients of the data, etc;
the right to rectification, i.e. the right to have inaccurate/unjustified personal data corrected by HASAW CONSULTING S.R.L. without undue delay and to have incomplete data completed; the rectification/completion will be communicated to each recipient to whom the data was transmitted, unless this proves impossible or involves disproportionate efforts.
the right to erasure of data, without undue delay, ("right to be forgotten"), if one of the following grounds applies:
- they are no longer necessary for the purposes for which they were collected or processed;
- where consent is withdrawn and there is no other legal basis for processing;
- if the data subject objects to the processing and there are no compelling legitimate grounds;
- where personal data have been unlawfully processed;
- where personal data must be deleted to comply with a legal obligation;
- personal data have been collected in connection with the provision of information society services in accordance with Union or national law governing the controller.

It is possible that, following the request for deletion of the data, HASAW CONSULTING S.R.L. may anonymize these data (thus depriving them of their personal nature) and continue processing for statistical purposes under these conditions;

the right to restrict processing to the extent that:
- the person disputes the accuracy of the data for a period that allows us to verify the accuracy of the data;
- the processing is unlawful and the data subject objects to the erasure of the personal data and requests instead that their use be restricted;
- the controller no longer needs the personal data for the purpose of processing, but the data subject requests them for the establishment, exercise or defence of legal claims; or
- the data subject has objected to the processing (other than for direct marketing purposes), for the period of time during which it is verified whether the legitimate rights of the controller prevail over those of the data subject.
- the right to data portability, i.e. (i) the right to receive personal data in a structured, commonly used and easily readable format, and (ii) the right to have such data transferred by HASAW CONSULTING S.R.L. to another data controller, provided that the conditions laid down by law are met;
- the right to object - in relation to processing activities may be exercised by submitting a request as indicated below:
  - at any time, for reasons relating to the data subject's particular situation, that data relating to him or her are processed on the basis of the legitimate interest of HASAW CONSULTING S.R.L. or on the basis of the public interest, except where HASAW CONSULTING S.R.L. can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of data subjects or where the purpose of the processing is the establishment, exercise or defence of legal claims;
  - at any time, free of charge and without any justification, that data concerning him/her be processed for direct marketing purposes.
the right not to be subject to an automated individual decision, i.e. the right not to be subject to a decision taken solely on the basis of automated processing activities, including profiling, which produces legal effects concerning the data subject or otherwise significantly affects him or her;
the right to address the National Supervisory Authority for the Processing of Personal Data or the competent courts, to the extent you consider necessary.

For any further questions on how personal data is processed and to exercise your rights mentioned above, please contact us at the email address: sales@aerooshield.com

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