Privacy policy

Privacy policy

This Privacy Policy regulates the way in which the personal data that Sophie Lashes Trading collects from its USERS or CLIENTS natural persons, including the personal data of the representatives of partner companies, or the data they provide, will be processed by to Sophie Lashes Trading. The definitions in the Terms and Conditions document also apply to this Privacy Policy.

By continuing to use the SITE, you understand that browsing Sophie Lashes Trading's website(s) and interacting with the Company's products and/or services involves requesting certain personal data belonging to you, and refusing to provide us with this data may results in the impossibility of selling and respectively delivering to you the products sold on the SITE.

Thus, we provide you with transparent information about the personal data we collect and how we use your personal data, and we also inform you about your rights as data subjects and how you can exercise these rights.

Before you provide us with personal data by accessing the SITE, you will be asked to consent to some of the processing activities of your personal data carried out by Sophie Lashes Trading in accordance with Article 3 of this Policy.

If you send Sophie Lashes Trading a request for access to the processing activities of your personal data in order to receive information, please note that due to the continuous processing of your personal data and taking into account the routine established in our IT systems for deletion of processed information under the terms of the data retention (storage) Policy, we are committed to keeping your data up-to-date and accurate at all times. Thus, this routine processing may involve changing or deleting the personal information we process, after you have submitted a request to us. In this case, Sophie Lashes Trading will provide the information it has at the time of sending the response to you, even if it will be different from the information stored at the time of sending the request. Please note that the deletion of your personal data is a procedure that Sophie Lashes Trading would have carried out even if you had not sent the request.

1. Contact information of the entity that carries out the processing activities described:

Sophie Lashes Trading SRL company
WEBSITE: https://www.sophielashes.ro
Address of the registered office: Str. Burebista no. 5, Block H4, staircase A, floor 6, apartment 25, Pitesti, Romania

You can contact us via:
Email: contact@sophielashes.ro
By phone: 0745296942 (call with normal rate in the Orange network);
By mail: Str. Burebista no. 5, Block H4, staircase A, floor 6, apartment 25

1. Collection, storage and processing of personal data
   
   We store and process personal data only in cases where you have voluntarily provided us with this data, such as by placing an order, filling in a contact form, subscribing to the company newsletter or creating an account. As a result of the collection of any other personal data, you will be informed in this Policy or in the respective web sections about the intended purpose of using this data and, if necessary, we will ask for your consent to store and process the personal data. Your personal data will only be disclosed or otherwise transmitted if it is necessary to implement the contract, to provide our services or to obtain your prior consent.
   
   Your personal data includes information that enables us to identify you directly or by combining this data with other information, for example your name, telephone number, assigned customer number, order number or your email address. All information that cannot be used to identify you, including when combined with other information, is classified as non-personal data.
   
   Sophie Lashes Trading collects personal data of USERS or CLIENTS, natural persons, for the following purposes:

• we ensure that the SITE and its sections are relevant to the needs of our CUSTOMERS;
• for displaying the products sold and their related services;
• publishing content accessible to our CUSTOMERS in relation to their preferences;
• the ACCOUNT information registered on the company's WEBSITE, to allow easy access to the CONTENT without the need to create an account and to recommend products to you;
• to detect potential fraud attempts, ensure you meet the mandatory age criteria and show you the products you want to see first;
• for the purpose of executing a remote contract concluded with you (in particular to deliver the products you ordered, we send SMS messages to inform you about the arrival of the order and respectively to inform you about our products or promotions as well as the latest news about products and offers, by e-mail or post, but for the latter only with your express consent), for these purposes we process your name and other contact information such as home address, delivery or billing, personal telephone number and email address;
• limiting access to certain sections of the SITE, as appropriate;
• participating in a competition or promotional campaign sponsored or organized by Sophie Lashes Trading or by a third party on our behalf;
• the transmission of correspondence, the conclusion of distance contracts and the delivery of ordered products, as well as for the collection of the sums paid by you for the products ordered and delivered as a result of the execution of a distance contract concluded with CUSTOMERS and to prevent possible fraud by detecting fraudulent behavior or of a nature to prejudice the company or the interests of other CUSTOMERS;
• collecting information about purchases made, products saved (in the shopping cart) and the history of orders placed, including the history of interactions with the content of our website, for the purpose of maintaining contact with CUSTOMERS and for the purpose of detecting and preventing inappropriate behavior on the website, by likely to harm the CLIENT or the company's activity;
• to provide social media functions and to analyze traffic on the SITE, respectively how you use the SITE to display the most suitable selection of products in relation to your preferences;
• we use cookie files within the SITE, thus temporarily storing personal data, in order to improve the security of access and traffic on the website, as well as to adapt the services offered, to meet our CUSTOMERS.

1. 
   The personal data we use and the legal basis for processing
   
   Sophie Lashes Trading offers you a wide range of products that you can access in different ways. Whether you wish to contact us online, by telephone or by any other means available to you, personal data and information is requested by Sophie Lashes Trading or submitted by you. In most cases, this data is provided by you when you use our services, for example when you register by creating an account on the website or when you place an order without opting to create an account (as a "visitor"). , or when you enter your email address during the ordering process, to subscribe to commercial emails, or your postal address for delivery.
   
   We also receive technical information about the device from which you access the website or access data such as geographic location, obtained automatically when you interact with our services. We thus collect information that we use for analysis and study purposes to evaluate our business activity. We may also receive information about you from third parties, partners of Sophie Lashes Trading, such as companies promoting our services to a target group, conducting opinion surveys, or information transmitted or obtained from the payment processor partner in connection with a transaction made by you on the SITE.
   
   In relation to Sophie Lashes Trading, we ask you to give us certain specific information, and you can refuse to give us this information, because you decide what information you give us. However, if you refuse to provide some of the requested information, we may be unable to optimally provide you with the requested services. For example, we cannot deliver your package without sending us your delivery address and contact information to keep you updated on the status of your order. In the event that a certain piece of information is mandatorily required to provide a certain service, we will inform you by qualifying that information as "mandatory". The mandatory information is usually the name and e-mail address, which will also constitute registration (log-in) information on the website. Other mandatory information may also be requested to access personalized or free services, such as date of birth - for example on the occasion of a CUSTOMER's birthday or offering him products specific to your age and interests.
   
   We process the following categories of personal data:
   
   Data necessary for the provision of services – name, surname, home address, date of birth. The legal basis of this processing is the execution of the remote contract concluded between the parties, or to carry out the steps necessary to process the order placed;
   Profile data – first and last name, contact data, your preferences through the analysis of traffic data, for example in relation to the products viewed, accessed, the type of product selected or the weight, as well as any data voluntarily added by you to the shopping cart or you want to use your CUSTOMER account to access services that require mandatory additional information. The legal basis for this processing is the execution of the remote contract concluded between the parties or for the implementation of the steps necessary to process the placed order ;
   Contact data – email, phone number (mobile, landline or both), address or data about the profile used in a certain social network (for example, if you contact us via the Facebook platform, we receive information about your Facebook ID) . If you contact us we collect your contact data, depending on the means of contact used in relation to Sophie Lashes Trading (phone number or email). The legal basis of this processing is the execution of the remote contract concluded between the parties or to carry out the steps necessary to process the order placed;
   Data about your behavior as a CLIENT – data from online activity (on the Internet) respectively online purchases limited to activity on our SITE, details about the products ordered (name, type, price and, as the case may be, weight), information about how of making the payment, messages sent in connection with the purchase made (information about the intention to return, complaints, withdrawal from the contract or other messages sent to Sophie Lashes Trading), the status of the delivery and of the payments made, the status of the return processing and information received from the providers of service partners involved in the execution of the contract (for example, the courier company that delivers the parcel ordered by you). The legal basis of this processing is the execution of the remote contract concluded between the parties or to carry out the steps necessary to process the order placed;
   Data about campaigns and studies – your name and email address are usually requested if you participate in a campaign or prize competition organized by Sophie Lashes Trading to inform you if you have won one of the prizes or to ensure that each participant is part of the respective campaign or contest. We process this information necessary for the purpose of demonstrating our legitimate interest in promoting and improving the services, so that your rights and freedoms are not restricted. If you participate in a competition with prizes or a campaign organized by Sophie Lashes Trading, we request your personal data to carry out our customer satisfaction studies in order to carry out market analysis (for example, if you participate in a campaign in that a partner of ours who awards the prize in question, requests information about you in order to award you that prize, but in such cases, we will inform you punctually within the framework of the competition rules or the terms and conditions applicable to the campaign regarding the information requested and how this information is used).
   Digital data – IP address, websites and personal pages in social media networks (Facebook, Instagram), applications used or the geographical location from which you access our services, as well as other public data and information available on the Internet. The legal basis of the processing is our legitimate interest in the continuous development of the functionalities of our website in order to provide you with relevant products and services. When you access services via the Internet or mobile services, data and technical information will inevitably be processed in order to provide you with the content and functionality that we make available by displaying them on your electronic device (smartphone, tablet, laptop). This data is processed every time you access services via the Internet, regardless of who the operator is.
   Marketing messages – first and last name, email address, mobile phone number, which we use to inform you in real time about our products, campaigns and promotions. These communications will only be sent to the extent that you have explicitly provided us with this information for marketing purposes (for example voluntarily entering your email address followed by its confirmation in order to receive communications with commercial content from Sophie Lashes Trading or our e-mail marketing partner), or with your prior consent. The legal basis for this processing of information for marketing purposes is our legitimate interest in promoting the company's products and services in order to offer you a varied range of quality products accompanied by reliable services. You have the possibility to stop or restrict the receipt of commercial messages from Sophie Lashes Trading at any time, either by accessing the settings in your CUSTOMER account, by pressing the "unsubscribe" link or by contacting our customer relations department. Once you have done this, we will update the information in your profile to ensure that you no longer receive commercial communications from Sophie Lashes Trading. However, please be aware that Sophie Lashes Trading is interconnected with a complex network of services and it will take a few days for our systems to be fully updated, so in the meantime you may still receive messages from us in while processing your request to unsubscribe or restrict this service. Opting out of receiving marketing messages or restricting them does not mean that you will no longer receive messages about order processing or delivery status.
   Personal data from messages or content following a conversation with Sophie Lashes Trading - communications made by you via telephone, mail, social network account, contact forms on the website or other means of communication, we collect and store the content these messages. The legal basis for this processing is the execution of the remote contract concluded between the parties or to carry out the steps necessary to process the order placed. These messages may be forwarded to the department responsible for resolving the request brought to the attention of Sophie Lashes Trading, and if we use this information in relation to other partners (for example to convey your opinion about a purchased product), you have the option to restrict the use certain information indicating exactly what data we can disclose, and in this case, we will not transmit the information to our partner or we will do it without transmitting your personal data.
   At this time, we will not record telephone conversations with Sophie Lashes Trading representatives .
   
   You do not have to provide us with personal data, but if you do not, you may not be able to purchase products from our SITE and you are unlikely to have an optimal experience with Sophie Lashes Trading. Opting out is your choice and we respect that choice.
   
   Also, to the extent that the volume of processed data will become considerable, we consider implementing security solutions to anonymize and aggregate your personal data (so that they do not identify you) and to use them for purposes such as testing our IT systems , research and data analysis, improving the functionality of the SITE and developing new products and services. Security measures may be implemented in relation to third parties.
   
   
   
   
   Principles of personal data processing

• We respect the principles of data processing and protection thus, your personal data will be:
• processed legally, fairly and transparently;
• collected only for a valid purpose that we have clearly explained and not used in a way inconsistent with that purpose;
• relevant to the purpose we communicated to you and limited to those purposes only;
• correct and up-to-date;
• will not be kept longer than necessary for the purposes described;
• stored safely.

1. 
   How we get this data:
   
   Directly from you:

• After registering on the SITE by creating an ACCOUNT;
• After you have filled in the forms with predefined fields available on the SITE in order to contact Sophie Lashes Trading or to initiate a contact using the information available in the "Contact" section or the existing information on the company page in social networks (Facebook, Instagram), or by subscribing to the newsletter ;
• After your telephone interaction with company representatives or via electronic mail (e-mail);
• By ordering our products with or without creating an ACCOUNT.

1. 
   To whom we transmit your personal data and the results of our processing activities (reports, lists, etc.):
   
   Our suppliers
   We disclose/transmit information to our suppliers to ensure the processing of your personal data in complete security and to represent us in the marketing communications we carry with you, to provide you with the content of the SITE, to display the products sold and to provide you with means to make their payments as well as to deliver the products to you.
   
   In any case, we disclose/transmit your personal data or information about this data, if necessary, in the format that is requested of us and that corresponds to the purposes described in this Privacy Policy and only to our contractual partners with whom we have entered into data processing agreements your personal data and which guarantees the protection of your personal data, the rights and freedoms guaranteed in relation to the applicable legislation. The updated list of contractual partners, in relation to which Sophie Lashes Trading processes your personal data can be sent on request by e-mail or physically, by post, using the contact details provided in article 1 of this Policy.
   
   Our contractual partners who carry out the delivery activities of the products ordered by you on the SITE, may request your identity card in order to identify the person who receives the package with the person who must receive the delivered product. The courier company that requests your identity card or an identification document has the right to request this document by the Act that regulates courier activities and postal services at national level, so it is not a requirement of Sophie Lashes Trading.
   
   Transactions made using card payment on the SITE are explained below:
   
   Sophie Lashes Trading does not in any way process the information on your credit or debit card with which you make TRANSACTIONS on the SITE. We put at your disposal frequently used means of payment available in the online environment, giving you the possibility to make online payments in advance, for the desired products. We collect information related to the payment made as this information is made available to Sophie Lashes Trading by the CLIENT in the course of performing a contract. We may also receive other information in connection with a payment made, from the payment processor partner with whom we work to complete a transaction or to verify the financial credit of our customers.

Details of a transaction may include:

• Billing address;
• The payment method you have opted for;
• The IBAN account used for the transaction;
• Details of the credit or debit card used.

Step I : Sophie Lashes Trading ensures the successful completion of the payment made by you on the SITE through the direct link provided in the trading platform of the Partner Payment Processor, to which the information about the intended transaction and about the card from which this transaction is directly transmitted it is desired to be made to the Payment Processor, respectively in the platform);

Step II : The payment processor sends the payment to the Card Brand (VISA, MasterCard, etc.);

Step III : The Card Brand establishes certain payment rules applicable to companies, such as the number of installments in which the payment is made, and connects the acquirer's IT system with the Issuing Bank of the card.

Step IV : Finally, the Card Brand sends the payment information to the Issuing Bank of the card and the latter performs an identification of the balance on the account attached to this card and then authorizes or rejects the payment.

We disclose/transmit your personal data or information about this data only if necessary, in the format that is requested and that corresponds to the purposes described in this Privacy Policy, only to our contractual partners with whom we have concluded agreements for the processing of your personal data and who guarantee the protection of this personal data, the rights and freedoms guaranteed in relation to your personal data. We are also obliged in some cases to disclose to public authorities (for example, authorities with powers to investigate fraud, the financial administration, the National Consumer Protection Authority, financial supervisory authorities, etc.), your personal data or information about the activities of processing that we carry out, but only to comply with well-defined legal obligations.

8. Legality of personal data processing

Sophie Lashes Trading is responsible for the processing activities of your personal data throughout the commercial relationship between you and the company. We comply with the processing principles established under the General Data Protection Regulation (GDPR) and integrate these principles into our internal company processes and business practices.

The processing activities carried out by Sophie Lashes Trading are necessary for the execution of contracts to which the CLIENT is a party or are necessary for the initiation of steps to conclude a contract, at the express request of the CLIENT. Also, the processing activities are carried out by the company for the purpose of its commercial interest, namely that of selling products on the Internet (online) in accordance with the applicable legislation in the matter.

The Marketing activities carried out (promotions and campaigns to present the company's products, profiling activities for marketing purposes) regardless of the means of carrying them out, are carried out by the company exclusively by obtaining the prior consent of the CLIENT.

1. 
   Where do we process your data?
   In order to carry out our activity, we process your personal data in accordance with the conditions presented in this Policy. We process your personal data nationally, respectively in Romania where Sophie Lashes Trading has its registered office and carries out its commercial activity, in Ireland where Google and Facebook have located servers, as well as in the United States of America in accordance with the Privacy Shield (Privacy Shield) given that the online store managed under the company name Sophie Lashes Trading is developed on the Shopify Inc. platform. (for details please access this link: https://www.privacyshield.gov/participant?id=a2zt0000000TNSNAA4&status=Active).

If our providers process your personal data in countries that do not provide a sufficient level of protection for your rights, we carefully assess all the circumstances and ensure that appropriate safeguards have been put in place so that your rights are not in any way way violated. In cases where we process your data outside the European Economic Area, we ensure through permissible legal instruments, according to the applicable laws and we regularly check the level of security provided by our providers regarding the personal data processed on our behalf. We ensure that you have the necessary means to exercise your rights and that we protect your rights and freedoms.

1. 
   Processing candidates' data in order to fill available jobs within Sophie Lashes Trading
   
   Personal data means any information that identifies you or that could be used to identify you.
   
   We process the data of candidates who apply for jobs available within the company for the legitimate purpose of concluding an employment contract. We ensure that we only process your personal data that is strictly necessary for the stated purpose.
   
   For the purpose of selection and recruitment, we may process the following categories of personal data depending on the purpose pursued:
   
   Identification data - surname, first name, address, national insurance number, identification document number, photo, etc.
   Contact details - email address, phone number, address, etc.
   Work life data - employer, experience, position, salary, education, etc.
   We specify that for certain functions that involve the management of the company's assets (especially the management of money), the company may request the presentation of a criminal record without storing the personal data from the document and without retaining this document in its archive.
   Digital data - cookies, IP addresses, website and social network activities and other data publicly available on the Internet, etc., if you access our SITE;
   Special categories of data (sensitive data) - personal data that reveal racial or ethnic origin, trade union membership, health data for occupational medicine control.
   
   How do we collect data?
   
   Directly from you:

• In the selection and recruitment process or by sending your CV to the email address suport@delicatessen.ro or through the recruitment platforms of our contractual partners.

From other sources:

• By recommendation;
• External company for the purpose of evaluating the suitability of the candidate during the recruitment process;
• Occupational health and safety or other providers of occupational safety or medical services;
• From the former employer.

How long do we keep your data?
As a general rule, we keep your personal data for a period necessary to achieve the purpose of their processing, namely for the duration of the recruitment and selection process which is, in most cases, including if it does not materialize by signing an individual employment contract, after 3 months. When we keep your personal data for another specific purpose, the storage period will be specified in https://delicatessen.ro/pages/politica-retentie. Your consent will be required if we consider it necessary to extend the data storage period beyond this initial period. All unsolicited CVs will be destroyed or deleted immediately.

1. 
   Your rights

• Before exercising your rights, we need to identify you to protect your personal data against any fraudulent attempts.
• Your requests regarding the processing of personal data by Sophie Lashes Trading will be honored as soon as possible. With regard to our internal processes, we will make efforts to deliver any response in relation to the processing activities of your personal data, within a maximum of one month, by sending an email to the address suport@delicatessen.ro by calling by phone using the phone number displayed in the "Contact" section of the SITE.
• You have the right to receive information at any time regarding the purposes of processing your personal data, categories and sources, recipients, storage periods of your personal data and your rights.
• You have the right not to be subject to an automated decision, with the possibility to object to an automated decision-making process. Sophie Lashes Trading does not currently carry out automated decision processes.
• You have the right to access your personal data, including the right to obtain a copy of the personal data we process.
• You have the right to portability (transfer) of the data you provided us by creating the account and completing the delivery and billing information, or the data we process, based on your consent and which are processed by automated means. We will provide this data to you in a secure format that is electronically processable for you to store or disclose to other service providers. You may also provide us with your data obtained from other companies. You can also ask us to provide your personal data to another operator, however, this can be done when the transmission of the data is technically possible. As the file contains your personal data, please store this data securely on your device. Thus, the portability (transfer) of the data will be carried out to the extent that the aforementioned conditions are met, and the portability process from us to the new indicated operator is technically feasible, or if the operator indicated to receive the data does not refuse the portability. In any case, data portability refers to the data we currently hold, not including the results of the processing carried out by our means and in the company's systems, before receiving the portability request.
• We update your personal data, asking you to review it from time to time and whenever the need to update is provided by law. However, if you find that some data is incorrect or inaccurate, you can request that incorrect data be rectified and/or updated and incomplete data completed.
• You can rectify or complete your personal data by contacting us and providing us with the correct or additional data. You can request the restriction of the processing of your data, if the accuracy of the data is contested for a period that allows us to verify that accuracy.
• You have the right to restrict processing, which means that we store your personal data but do not use it for any other purpose.
• You have the right to request the deletion of your personal data. You can exercise both rights under the conditions provided by law. We will assess your request for deletion in terms of the law and our internal procedures, taking into account the existence of an ongoing contract, and will provide a written response within the agreed time frame, which will not exceed 30 calendar days from the date of receipt deletion request.
• If you have obtained the restriction of processing, you will be informed before the lifting of the restriction of data processing.
• You have the right to contact us at any time if you believe that your rights under data protection law have been breached.
• You have the right to appeal to the Data Supervisory Authority, respectively the National Supervisory Authority for the Protection of Personal Data, with the address Bulevardul General Gheorghe Magheru 28-30, Sector 1, postal code 010336, Bucharest, Romania, or to a competent court , if you believe that your rights regarding the processing of personal data have been violated.

1. 
   Cookies
   Cookies are text files placed on your computer, smartphone or tablet to collect standard internet login information and information regarding your behavior on the SITE. This information is used, for example, to track your use of the website in order to draw up statistical reports on the activity carried out on the SITE and to ensure the functionality of the sections of the SITE that you can access. You can set your browser not to accept cookies.
   
   How long do we keep your data?
   If you are the representative of our contractual partner (legal entity), we have the right and the legal obligation to retain all necessary personal data that you have provided to us for contract management purposes. We will keep your data for the entire duration of the validity of the contract and for the period provided by the financial-accounting legislation, i.e. at least 5 years after the termination of legal relations between the company and the client, for possible legal actions and other purposes expressly provided for by law.
2. How do we protect your data?
   In order to ensure that your rights and freedoms are not jeopardized and that compliance with the relevant legislation and regulations in the field of personal data protection is respected, we implement appropriate technical and organizational measures to ensure a sufficient level of security for processing personal data. These measures consist in regular training and testing of our employees and partners, in the introduction of relevant policies and processes, which are reviewed and updated regularly, under the supervision of a consultant in the field of personal data processing. We also ensure that we carefully assess our service providers to ensure they provide an appropriate level of protection for your personal data and enter into personal data processing agreements with them to ensure that each contractual partner entering in contact under our authority and with your personal data, carry out the contracted processing activities in complete safety and that they comply with the provisions of the legislation in force in the matter.
3. 
   update
   Our privacy policy may change from time to time (generally to comply with data protection laws and practices). The updated versions will be published on our web page, and to the extent that the changes/completions/updates are likely to affect you considerably from a legal point of view, we will notify you promptly, using the means of contact received from you.