Retrozone SRL will always show special care towards your personal data, so that they are processed safely. We inform you that we are aware of and comply with the requirements imposed by the GDPR Regulation (EU) 2016/679 on data protection, laws 2018/190 and 2018/363 on the implementation of EU Regulation 2016/679 on the protection of natural persons in terms regarding the processing of personal data, as well as the guides and other informative materials regarding the application of the "General Data Protection Regulation" issued by the National Supervisory Authority for the Processing of Personal Data. In addition, the website www.retrospace.ro uses the 'Official GDPR Compliance' module of the Prestashop platform in which it is built, which ensures compliance with GDPR rules at the EU level.

Below we present our data processing policy in detail. In the event that, after reading all the materials provided, you no longer wish to appear in our database, please send us an email at office@retrospace.ro. In the absence of this request, after accepting the terms and conditions at the time of creating an account, we will consider that we have received your consent to data processing. For any other additional information, you can contact us at office@retrospace.ro.

This Data Processing Policy can be modified or updated at any time by the company when we consider that certain changes occur in the activities through which we process your data. We will publish on our website www.retrospace.ro any such changes and inform you accordingly by e-mail.

1. Who are we?

Retrozone SRL, a legal entity of Romanian nationality, with its place of business in the town of Oradea, Str. Ion Vidu, No. 1, Bihor county, registered at the Oradea Trade Registry Office on 11.09.2020; CIF 43038343; no. registration: J05/1635/2020; EUID: ROONRC.J05/1635/2020 is the operator of your data and the entity that provides you, through the online store www.retrospace.ro, products from the electronic categories, audio equipment, audio-visual, Hi-Fi.

2. What is personal data?

Personal data means any data or information that helps us to identify you directly (for example your name and surname) or indirectly (for example the personalization of some offers according to your website usage profile). Certain information is less obvious, such as your shopping preferences and habits or the IP from which you access the Internet, which associated with the user helps us to identify you, and thus falls under the notion of "personal data". The policy of www.retrospace.ro is to collect and process only the data that is necessary for us to offer you the most pleasant experience when browsing/shopping on the online store website.

3. What kind of data do we process and in what way or purpose?

www.retrospace.ro collects and processes your data for honoring the orders you place and delivering the products you want, improving the online store experience, offering assistance and support in using the online store / customer account, to create a profile by the client in order to send personalized offers, and to collect data for various statistics.

The type or categories of personal data that we process are divided into 3 stages, as follows:

1. When a customer account is created (required only to be able to complete an order, not to browse the website), the following categories of personal data will be processed, in this order:

• Mode of address (Mr. / Ms.);

• First and last name;

• Email address;

• Personal password;

• Date of birth - specifying that although it appears as an optional field on the site, we will not accept marketing to users under the age of 18, so filling in the date of birth is mandatory and will be checked on time;

2. In addition, after activating the account when placing an order - filling in the delivery address from the customer account, the following categories of personal data will be processed, in this order:

• Alias ​​(optional);

• Name and CIF code of the company (optional);

• Full address;

• Complementary address (optional);

• Postal code, town and country;

• Telephone number - specifying that although it appears as an optional field on the website, in general each order will be confirmed by telephone and for any inconsistency, delay or any other problem you will also be contacted by telephone, so filling in this field is strongly recommended. In addition, all the products on the website can be ordered by phone after accepting in advance the terms and conditions and the personal data processing policy.

All this data can also be used to contact you regarding the confirmation and honoring of orders, communication between the buyer and merchant regarding the order/delivery status, the obligations associated with the products and the execution of the purchase-sale contract, the return of products if necessary, the communication of details not specified on site or inconsistencies that appeared in the meantime, etc.

3. Once you log into the customer account and browse www.retrospace.ro, the following indirect data will be linked to your account, thus becoming personal data:

• The general geo-location of the device from which you navigate/log in to the customer account;

• Information about purchased products and services;

• The degree of use, your activities and preferences on the online store platform;

Data of minors

As we mentioned above, www.retrospace.ro does not allow the processing of personal data of customers who have not reached the age of 18 and will not sell products to minors.

In the process of creating an account or placing an order in the online store, customers must confirm that they have reached the age of 18.

Payment of purchases and refund of payment in case of product return / order cancellation

The details of the card you use to pay by card for purchases in the online store will not be accessible or stored by www.retrospace.ro, but only by the entity authorizing the transaction or by another entity authorized to provide card identification data storage services, about whose identity you will be informed, prior to the effective entry of the card details that you will use for online payment.

www.retrospace.ro uses the online payment module with the REDSYS card - multicommerce, multiterminal and multicurrency support that uses the latest version of 3D Secure (3DS2 - PSD2). 3D Secure means a security measure that involves redirecting the customer at the time of payment to a secure page where the registration of each cardholder is done by assigning an authorization code for each online transaction. Cards accepted for payment are debit or credit cards accepted by banks, issued under the VISA, MasterCard, American Express, Maestro, Euro6000 logos.

www.retrospace.ro processes the following data that it sends to the online payment/transaction authorization partner: (1) name, first name; (2) Order ID; (3) date of initiation and completion of the transaction; (4) payment situation; (5) the amount transacted (as applicable). In case of returns / order cancellations, we also collect and process the IBAN and the bank where you opened the bank account in order to refund you the money for the returned products / canceled orders.

Delivery of products

We deliver the products to the indicated address, through our couriers, with whom we strictly share the data necessary for the delivery of the products: (1) name, surname; (2) delivery address; (3) telephone number; (4) the value of the amount payable by cash on delivery (as the case may be).

Execution of the contract

We take all the necessary measures to fulfill our obligations related to the management and delivery of the products to the customer in the agreed terms and times. For the execution of the sale-purchase contract, honoring and confirmation of orders, for support regarding the customer account, any kind of communication between www.retrospace.ro and the customer, or to solve any kind of complaint, the following data will be used ( entered in the customer account): (1) name, surname; (2) e-mail address and telephone number; (3) Order ID.

Loyalty actions and promotional campaigns

It is possible that, in the future, www.retrospace.ro would reward its loyal customers with various discounts, offers and benefits, related to monitoring the online behavior of customers. These loyalty actions can be tracked in the customer account (vouchers, discounts, etc.) or the customer can be contacted by www.retrospace.ro.

In the same way, it is possible to organize promotional campaigns, contests, promotions or raffles. For online contests held on the www.retrospace.ro website, we collect users' e-mail addresses. We also organize contests on the official Retrospace - Vintage Audio Facebook page, where we collect, depending on the campaign, the following data necessary to participate in the contest, respectively, to validate the winners via random.org: (1) first and last name; (2) e-mail address or telephone number. If you are the winner, we will mention your name and surname on the official Retrospace Facebook page or on www.retrospace.ro.

Profiling our customers

There is a possibility, in the future, that www.retrospace.ro will send personalized offers according to the user profile. When personalized offers are sent through direct marketing channels by www.retrospace.ro (e-mail, notifications, etc.), certain 'profiling techniques' can be used, respectively a method of automatic data processing consisting in particular in the analysis and interpretation of the personal data necessary to evaluate or foresee some aspects related to your preferences and interests in purchasing in the online store. We use profiling to communicate and present personalized promotional offers to you in a relevant and useful way for the user. www.retrospace.ro will not have advertisements, banners, promotions or external marketing on the website and will not benefit financially in this way - we consider that too many sites are too full of advertisements.

For profiling purposes, www.retrospace.ro will in no case ask for, have access to, and will not process sensitive data regarding sexual orientation, religious beliefs or political affiliations. Depending on your interactions and behavior in the online store website and in the mobile application, we collect and process the following data to create the customer profile for the subsequent transmission of personalized offers: (1) name and surname; (2) e-mail address or telephone number; (3) the history of your interactions on the site - which products you viewed, searched or ordered, which products were added to the shopping cart, which orders were initiated and subsequently completed or canceled, which products were delivered and paid for ; (4) your preferences regarding shopping in the online store; (5) online identifiers obtained from the device used when browsing the website; (6) demographic data such as age, gender, city. You have the right to object to customer profiling at any time, and please contact us in such cases.

You can object to profiling for direct marketing purposes, on any of the communication channels to which you previously gave your consent, by unsubscribing from our newsletter via the link in the Newsletter (Footer / bottom of the page), or by communicating directly with us by email (office@retrospace.ro) or by phone.

The use of cookies (see also Cookies)

When you visit the website, log in to your customer account or use our mobile application, we also collect with the help of cookies and data obtained from the computer, phone, tablet or other device used, information with which we can identify you online - identifiers online - which can be used for marketing profiling: (1) IP address; (2) the Internet browser; (3) HTTPS/HHTP protocol data; (3) duration of the visit / activity on the website; (4) the general location of the device (if geo-location is enabled) - most devices will give you the option to disable geo-location services in the respective device settings.

The purpose and manner in which cookies are processed and used are detailed in the "Policy for the use of cookies".

If you do not want to participate in the monitoring by cookies for the purpose of sending profiling or online advertisements, you can refuse the setting of a cookie in this sense by setting the browser that generally disables the automatic setting of cookies. It is also possible to disable the cookies for the advertising services of a browser service provider (e.g. Google) by setting the browser so that the cookies of the respective domain are blocked.

Website maintenance and security

We use the following online identifiers for the maintenance and security of the www.retrospace.ro website: (1) IP address; (2) the Internet browser used; (3) HTTP/HHTP protocol data; (4) device location (if geo-location is enabled). More precisely, we process your data to: (1) ensure the proper functioning of the website - the correct display of the content, the correct retention of authentication data when this option is requested, the improvement of the website, etc.; (2) to ensure the security of the website and the protection of users against any kind of fraud or IT security breaches on the online store; (3) identifying and fixing malfunctions that prevent the use of our website or your customer account.

Fiscal, legal and special cases

We can also process your data for:

a. The annual financial audit, as well as for the submission of tax and accounting declarations to the tax authorities.

b. To comply with the legal obligations imposed by the applicable legal provisions in fiscal and accounting matters.

c. Defense of rights in court - when we defend our rights in court for the recovery of sums owed, or when we protect our interests against unjustified claims/complaints, we will process your data necessary for the formulation of objections, written conclusions, requests and specific documents.

d. Legitimate interest - the exercise of any defenses/rights before the courts, or public authorities or institutions/control.

e. Procedures and investigations of the authorities and/or judicial bodies - exceptionally and in accordance with the law, we will provide the competent authorities and institutions, as part of formal procedures/investigations or other steps provided by law, according to the procedure provided by law, the following data: name, surname, address, e-mail, telephone. www.retrospace.ro will document any such steps.

f. Requirements of legal provisions - for compliance with the specific legal obligations imposed by the applicable legal provisions in the matter of protection against fraud, money laundering and terrorism.

Data we collect from other sources

If you like our Facebook page or if you log into your customer account with your Facebook address and password, we will receive this data without using it other than to be able to communicate with you and possibly send you some personalized offers with your consent yours.

4. How long do we keep your data?

www.retrospace.ro processes your data for the period necessary to fulfill the purposes for which they were collected and according to our personal data retention policies. In certain cases, some legal provisions may require or allow us to retain data for a longer period.

The data retention period mainly depends on the following:

• for what period do we need the data to provide you with the requested products and fulfill our obligations towards you and for the purposes mentioned above;

• if you have an open customer account on our website. In this case, we will keep your data as long as this customer account is active, but not more than 5 (five) years from the date of the last account login or the last order in the online store (without account login);

• if you have expressed your consent for data processing for a longer period, we will maintain the data for this entire period, unless you withdraw your consent in the meantime;

• legal or contractual obligations require us to keep your data for a certain period of time (for example the periods prescribed by law to defend our rights in court);

We will keep your data only as long as you have a customer account and/or continue to shop in the online store. If you deactivate your customer account and expressly ask us to completely delete the data, the data associated with your customer account will be deleted or anonymized so that you can no longer be identified in our data record systems, unless we are obliged to keep the data for a longer period, based on the law or our legitimate interest. In this way we will ensure full control over your personal data. We will collect and process the data again when reactivating or creating a new customer account in the online store.

5. Your consent regarding the storage and use of personal data

For the purposes for which you give us your consent to data processing, highlighted above, we will process your data for that purpose until you withdraw your consent, unless we are required to keep this data for a longer period according to the law , for reports to public authorities, or to defend our rights in court.

We inform you that we rely on your consent and when we process your data to transmit:

• personalized offers based on online behavioral advertising;

• personalized offers based on the profiling we do for direct marketing purposes, through email communication channels and/or notifications;

• offers based on personalized audiences (customer lists) in Facebook;

*Consent – ​​means your free, specific and informed agreement, by which you accept without doubt that your data will be processed by www.retrospace.ro for the purposes detailed in this policy. On the website, you will be obliged to give your consent when creating a customer account / subscribing to the newsletter / returning products / etc. by checking the box "I have read and agree with the terms and conditions and the data protection policy".

6. Who do we share your data with?

If we collaborate with external partners, we will not send them any personal data without your consent, and we will take all measures to ensure that they, in turn, are in accordance with the current protection policy of personal data at EU level.

Specifically, we may transmit some data to third parties to perform the functions and services necessary to operate the online store activities, such as:

• the supplier who provides us with data storage / hosting services on their domains / servers - xServers Romania with a physical database in Bucharest, S.C. Web Class IT SRL;

• the provider of communications and email transmission services, also hosted by xServers Romania;

• the mobile phone service provider that helps us keep in touch with you, located in Romania;

• third-party couriers authorized by us to deliver the products purchased by you (Fan Courier, Posta Romana);

• payment processors that are authorized by us to mediate payments in the 3D Secure system;

In order to give you the chance to more easily find the website or products customized to your interests and preferences, we process certain data with some partners who help us to address you with personalized offers, such as: (i) data processing through the Facebook platform to deliver personalized offers through targeted advertising using the Custom Audiences feature on customer lists, or (ii) data processing to deliver personalized offers based on online behavioral advertising run with Google AdWords.

Transmission of data to authorities and public institutions or judicial bodies

We may transmit certain personal data to competent authorities or public institutions, when required by law (e.g. fraud investigation, money laundering prevention, filing of declarations, financial statements with tax authorities, etc.), or we may transmit this data to judicial courts when we defend ourselves in court, or in front of other public authorities.

7. How do we ensure the security of your data?

RETROZONE SRL and respectively RETROSPACE - www.retrospace.ro ensure the necessary technical and organizational measures for the collection, processing and safe keeping of data, including against unauthorized access, unauthorized use of data, destruction, loss or alteration of data. We are committed to keeping your personal data secure and take all necessary safeguards to do so, as described in this policy.

All the personnel responsible for www.retrospace.ro are trained and have taken note of the current regulations regarding the protection and processing of personal data at the EU level, as well as the internal laws implementing this regulation and informative materials regarding the application of the 'General Data Protection Regulation' ' issued by the National Supervisory Authority for the Processing of Personal Data. In addition, the website www.retrospace.ro uses the 'Official GDPR Compliance' module of the Prestashop platform in which it is built, which ensures compliance with GDPR rules at the EU level.

8. What rights and options do you have regarding your data?

We want to make sure that at all times you have full control over your data and that you can effectively exercise the rights and options given by the GDPR - RGPD laws. To ensure that you have effective control over your data, we inform you of the following possibilities:

• you can manage from the customer account the direct access, rectification or deletion of some data available in the customer account in the online store;

• you can delete the cookies or browsing history from the browser settings you use so as to restrict the tracking of your behavior in the online store by cookies - we mention that these restrictions can affect the browsing experience in the online store;

• social media platforms and search engines (e.g. Google or Facebook) offer you the possibility to manage various options regarding how you choose to have your data processed;

In addition, the GDPR gives you, as a data subject, the rights described below. Before complying with any request regarding your rights, we will ensure that you are the owner of the data regarding which you choose to exercise these rights, and for this purpose we may request some information / data for identity verification or more details about request. The correspondence we will have with you will be kept to ensure that we keep track of requests and responses regarding your rights.

Any of the following rights can be exercised, in writing, by sending a written request to the email address office@retrospace.ro.

1. The right to be informed - you have the right to receive clear, transparent, easily understandable and easily accessible information about how we process your data, including details about your rights as a data subject. This information about the data, the purpose and how we process your data is included in this policy.

2. The right to access data - you have the right to access the data we process about you, without charging any kind of fee for providing data. If copies of the data already provided will be needed, a mutual decision will be made regarding the administrative costs. We reserve the right to refuse excessive / repeated unjustified requests.

3. The right to data rectification - if you identify that your data that we process is incorrect, incomplete or inaccurate, you can send us a rectification request.

4. The right to object to direct marketing (including profiling for direct marketing purposes) - you can object at any time and unsubscribe from our direct marketing communications. You can do this easily by unsubscribing from our newsletter, by accessing the link in the newsletter email, in the Footer / bottom of the page or by contacting us directly by email (office@retrospace.ro) or by phone.

In addition, you can opt for the withdrawal of your previously expressed consent for the transmission of personalized offers based on profiling through the same channels through which we communicate these offers to you, respectively: email or notifications. Withdrawal of consent (by unsubscribing or written request) does not affect the legality of data processing based on consent prior to its withdrawal.

5. The right to object to processing based on legitimate interest - you can object at any time to any data processing when such processing is based on our legitimate interest (see such cases described above).

6. The right to delete data (the right to be forgotten) - you have the right to ask us to delete your data in any of the following situations:

a. The personal data are no longer necessary to fulfill the purposes for which we specified them previously;

b. You withdraw your consent on the basis of which we processed your data and there is no other legal basis on which we can base future processing;

c. You object to data processing when it is processed for direct marketing purposes (including profiling for direct marketing purposes);

d. You oppose the processing of data based on our legitimate interest and we cannot demonstrate that we have legitimate reasons that justify the processing and that prevail over your interests, rights and freedoms;

e. Personal data are processed against the law;

f. Personal data must be deleted to comply with our legal obligations. This is not an absolute right. We may refuse your data deletion request if: (i) we are required to comply with legal terms to retain the data; or (ii) if the data is necessary for us to establish, exercise or defend our legal rights.

7. The right to restrict data processing - you have the right to obtain from us the restriction of data processing in one of the following situations:

a. The accuracy of the data is disputed by you (data subject), for a period that will allow us to verify the correctness of the data;

b. Data processing is illegal and you (the data subject) oppose the data deletion and ask us to restrict the processing of this data;

c. We no longer need your data, but they are requested by you (the data subject) to establish, exercise or defend legal claims;

d. You (the data subject) raise some objections to the processing of data based on our legitimate interests, based on the verification of whether the legitimate reasons of the operator exceed those of the data subject.

8. The right to portability - when we process your data based on your consent or contract execution, you will automatically have the right to request the transfer of your data: (i) to you; or (ii) to another operator indicated by you. The second situation involves the option to ask us to transmit the data associated with the customer account to another data operator (e.g. to an operator who manages another online store website). More precisely, you will only be able to request the porting of personal data from those that you have directly and actively provided to us (excluding any data derived or created / developed by www.retrospace.ro. In such cases, we will transmit the requested data as specified here in a structured and reusable data format (eg XML, JSON, CSV).

9. The right to make complaints to the supervisory authority - you have the right to submit any complaints to the National Supervisory Authority for the Processing of Personal Data (ANSPDCP) about the way in which we process your personal data. However, as we mentioned above, we prefer that any misunderstanding be resolved amicably and we hope that you will decide to talk to us before filing a complaint. Once again we mention that data protection is very important to us and we will take all necessary measures to solve any problem regarding the control and security of your data. You can also address various questions directly to ANSPDCP.

9. Questions and requests regarding the protection and processing of personal data

RETROSPACE - www.retrospace.ro and respectively the company RETROZONE SRL and all its staff will be at your disposal for any concerns, clarifications or any details you need regarding this data processing policy. For any matter that needs to be clarified, but also for suggestions, comments or opinions related to this policy or the way we collect and use your data, you can always find us at:

Retrozone SRL, RETROSPACE

Address: Str. Ion Vidu, No. 1, 410089, Oradea, Romania

Email: office@retrospace.ro

Phone: +40720087701

   

With thanks,

The RETROSPACE team