Starting with May 25, 2018, the European Regulation 2016/679 on the protection of individuals regarding the processing of personal data and the free movement of such data (“Regulation”) becomes applicable. Through this Regulation it is desired to create a unitary and uniform legislative framework on the territory of the European Union.
PIRIOS CO SRL knows the importance of your data and is committed to protecting their confidentiality and security. Therefore, we want to provide you with all the information related to the processing of your personal data as data subjects (users of the SKINGURU website, customers, potential customers, consumers, potential consumers) within this Data Processing Policy with personal data, applicable for the purposes listed below.
This Policy promoted by SKINGURU has applicability on all devices used in order to access the website, loaptop devices, computer, smartphone, tablet, etc. If you do not agree with the terms and conditions related to their use (set forth in this document in terms of personal data protection but also in the general terms and conditions, in terms of confidential information, copyright , etc.), please do not use the site www.skinguru.ro.
In accordance with the requirements of the legislation in force for the protection of individuals with regard to the processing of personal data and the free movement of such data, as amended and supplemented, SKINGURU manages safely and only for the specified purposes, the personal data you provide us. about you, in the context of visiting the site and purchasing SKINGURU products.
1. The purposes for which we collect and process your personal data
SKINGURU collects and processes your personal data for the following purposes:
a. Administration, improvement and realization of the services provided by the site www.skinguru.ro
b. Commercial sales activities, including sales, administration and development, respectively online sales on the website www.skinguru.ro, administration of customer accounts, research / market studies, statistics.
c. Advertising, marketing and publicity, activities for the promotion of SKINGURU products and services, development of promotional companies, transmission of newsletters (newsletters), tracking and monitoring of sales and consumer behavior.
d. After sales activities, including customer relations services, informing users / customers regarding the evaluation of the products and services offered (including the evaluation of products on the SKINGURU website.
e. For evidentiary purposes in connection with the above activities and archiving.
2. The categories of personal data that we process
In order to achieve the above purposes, we process the following categories of personal data:
b. For commercial sales activities, including sales, administration and development, respectively online sales on the website www.skinguru.ro, customer account management, research / market studies, statistics: name, surname, address (domicile / residence ), telephone number, e-mail, sex, bank details, in order to make the payment, delivery address.
c. For advertising, marketing and publicity, activities for the promotion of SKINGURU products and services, development of promotional companies, transmission of newsletters (newsletters), tracking and monitoring of sales and consumer behavior: name and surname, sex, telephone / fax, e-mail, address (domicile / residence). In addition, SKINGURU processes data consisting of the personal numerical code and the series and number of the identity card strictly for identifying the winners of the promotional campaigns and for complying with the requirements of the fiscal legislation in case this is required by the fiscal legislation. Also, some of these data are needed as a unique identifier of the person depending on the type of contest / promotion / simulation or game in which they participate.
d. For after-sales activities, including customer relations services, informing users / customers regarding the evaluation of products and services offered (including evaluation of products on the SKINGURU website): name and surname, sex, telephone / fax, e-mail, address (domicile / residence) or other data resulting from the evaluation of products by customers.
In addition, SKINGURU processes data related to: personal numerical code, serial number and identity document number, bank details, only for situations in which replacements or product returns occur.
e. For evidentiary purposes in connection with the above activities and archiving: storage of personal data mentioned for the above purposes, in order to maintain records related to the activities carried out, to protect the rights in court and exercise other rights according to law and concluded contracts, fulfillment of possible archiving requirements, in accordance with the legal provisions.
Personal data that benefit from a special protection regime such as the personal numerical code, series and number of the identity document, will be collected and processed under restrictive conditions and in accordance with legal provisions to ensure compliance with applicable data protection rules. regarding them.
The provision of personal data is necessary for SKINGURU to perform the activities listed according to the above. A refusal on your part to provide us with this data may make it impossible for SKINGURU to provide you with such services, information, to respond to your requests or to perform any other activities listed above.
3. To whom we disclose your personal data
In order to achieve one or more of the above purposes, SKINGURU may disclose your personal data to the following categories of recipients: SKINGURU’s contractual partners (as is the case with companies with which SKINGURU is in partnership, but only under a commitment of confidentiality on their part, which guarantees that this data is kept safe and that the provision of this personal information is made in accordance with current legislation, other companies with which we can develop joint programs to offer our products and services on the market), service providers (marketing, courier, payment / banking services, telemarketing or other services), including entities that assist SKINGURU in data processing as proxies, insurers, public authorities (Prosecutor’s Office, Police, courts and other competent bodies of the state), based on and within the limits of the provisions of and as a result of express requests, to other companies in the same group with SKINGURU as well as you as the data subject in the context of exercising your right of access.
SKINGURU takes all necessary measures to ensure that your personal data is adequately protected regardless of where it is transferred.
By transmitting your personal data to SKINGURU you accept (to the extent that an agreement from you is required by law) that your personal data:
– to be included in the SKINGURU database and for all these personal data to be stored, used and processed by SKINGURU, including its affiliates and collaborators for carrying out and / or carrying out the activities that fall within the above processing purposes; this consent also includes the processing of data related to the location of your equipment, as mentioned above.
– to be transferred by SKINGURU both to its affiliates and to another / other entity in the country, according to the above information, for their development of their own activities related to promotion and marketing and other activities related to them.
By filling in the data in the form provided by SKINGURU, the user declares and unconditionally accepts that his personal data be included in the SKINGURU database and gives his express and unequivocal consent that all such personal data be stored, used and processed by to SKINGURU or the entities that form the SKINGURU brand and their collaborators of activities such as, but not limited to, commercial activities, promotion of products and services, marketing, advertising, media, administrative, development, research market, statistics, sales tracking and monitoring and consumer behavior. Also, the Beneficiary gives its express and unequivocal consent that these personal data may be transferred (assigned) by SKINGURU to the entities that form the SKINGURU brand.
4. By reading this Policy you have become aware of the fact that you are guaranteed the rights provided by law, respectively:
• to be informed about the processing of your personal data, according to the law;
• access to your personal data;
• intervention on your personal data;
• not to be subject to an individual decision of an automatic nature;
• to oppose the processing of personal data concerning you and to request the rectification, updating or deletion of data in accordance with the law – in the case of personal data processed for direct marketing purposes, this right may be exercised at any time, free of charge and without justification ;
• to address the court in case violations of the relevant legislation have been found.
In addition to the existing rights, from the date of application of the Regulation you benefit from additional rights. Here is the complete list of rights you have:
• The right to information – you can request information on the activities of processing your personal data;
• The right to rectification – you can rectify inaccurate personal data or you can complete them;
• The right to delete data (“the right to be forgotten”) – you can obtain the deletion of data, if their processing was not legal or in other cases provided by law;
• The right to restrict the processing – you can request the restriction of the processing in case you dispute the accuracy of the data, as well as in other cases provided by law;
• The right of opposition – you can oppose, in particular, data processing that is based on our legitimate interest;
• The right to data portability – you may receive, under certain conditions, the personal data you have provided to us, in a format that can be read automatically or you can request that the data be transmitted to another operator;
• The right to file a complaint – you can file a complaint regarding the way of processing personal data at the National Authority for Supervision of Personal Data Processing;
• Right of withdrawal of consent – in cases where the processing is based on your consent, you can withdraw it at any time. Withdrawal of consent will have effects only for the future, the processing performed prior to the withdrawal remaining valid;
• Additional rights related to automatic decisions: you can request and obtain human intervention regarding the respective processing, you can express your own point of view on this and you can challenge the decision.
You can exercise these rights by sending an e-mail to SKINGURU at the email address firstname.lastname@example.org or you can write to us at the following address: PIRIOS CO SRL, Str. Pavlicheni no. 17, house 5, Popesti Leordeni, Ilfov, 077160.
Based on a written request, dated and signed, sent to PIRIOS CO SRL, Str. Pavlicheni no. 17, house 5, Popesti Leordeni, Ilfov, 077160., or by sending an email to the email address email@example.com, you can exercise, free of charge, the following rights: – once a year, to be confirmed according to law , whether or not personal data are processed; – to access and intervene on the transmitted data; – to oppose the processing of data for justified and legitimate reasons related to their particular situation (except for direct marketing processing, in which case you can oppose at any time for free and without justification) – to request the deletion of data, except in situations provided by law .
You can oppose at any time and without justification, the processing of your personal data for direct marketing purposes, by sending to SKINGURU, by mail or mail to the addresses mentioned above, a written request, dated and signed in this regard. In this case, your request will be forwarded to the specialized department of SKINGURU which manages these requests; you may receive a message confirming that your option has been noted, as well as any other necessary information, as appropriate.
Also, you can oppose at any time, for good and legitimate reasons, according to the law, that the data that aims to be processed by SKINGURU, unless there are legal provisions to the contrary.
Individuals may request the deletion of personal data if they have been processed illegally, without their consent or if the data are no longer necessary for the purpose for which they were originally processed.
In the case of the right to be forgotten, data processing in the online environment was especially considered. The right to be forgotten is not an absolute one – the specific circumstances of each case will always be analyzed. The Regulation allows the retention of personal data in case it is necessary for the observance of freedom of expression and the right to information, for the observance of a legal obligation, for the performance of a task that serves a public interest or that results from the exercise of public authority. with which the operator is invested, for reasons of public interest in the field of public health, for archiving purposes in the public interest, for scientific or historical research purposes or for statistical purposes or for the establishment, exercise or defense of a right in court.
5. Special provisions related to minors
SKINGURU does not pursue in its data processing activities, the processing of personal data of minors. Special attention is paid by SKINGURU to ensure that any processing of personal data of minors is carried out in accordance with legal requirements and in strictly determined cases.
SKINGURU does not carry out promotional marketing activities directly for minors.
Minors under the age of 14 are not allowed to request services or any communications on the SKINGURU website, or to participate in SKINGURU contests or campaigns, unless this is done on behalf of the minor by the minor’s legal representative or guardian in cause, according to the law.
Minors who have reached the age of 14 can purchase products or services and request and receive communications from SKINGURU only if they have the consent of their legal representative or guardian, according to the law.
Also, any person who provides us with personal data through the site or other applications or devices covered by this Policy guarantees that he is of age, respectively has full capacity to exercise.
Any collection or processing of personal data of minors will be done only in accordance with the law, and taking into account the above.
6. Duration of data processing
The duration of the data processing will generally be determined by the moment of exercising your right to opposition, under the conditions provided by the legislation in force. Exception: For data declared within the call center service, the duration of data processing is 5 years, as a rule, or until the exercise of the right of opposition. Also, SKINGURU may store personal data for such a longer period, for evidentiary and archiving purposes.
At the same time, the storage of personal data for a longer period of time can be done for statistics, improving services, managing customer accounts, research / market studies.
7. Other information
Please check each use of our website this Personal Data Processing Policy to be always informed about it.
At the end of the processing operations, the registered data may be transferred, in whole or in part, to any other legal entity in compliance with the special legislation in force, provided that they will be used for purposes similar to those provided in this document.
8. Disclosure to third parties
Except as set forth below, we will not disclose any information about your data without authorization. Based on your express and unequivocal consent, offered in this way and only within the limits of the legislation in force or for the purpose of fulfilling a legal obligation and / or protecting a legitimate interest, we may transmit your personal data to:
– Service providers in the following fields: marketing, administrative and transaction processing services;
– Other service providers, all of which have signed agreements to maintain the confidentiality of information;
– Organizations or companies that coordinate specific studies and that agree to keep the information received confidential;
– State, governmental agencies, if the legislation stipulates this;
– Other authorities and bodies, in order to fulfill our legislative obligations and / or to protect our legitimate interests;
– Other companies with which we can develop joint programs to offer our products and services on the market;
The transmission of your personal data to the above-mentioned recipients will be done only on the basis of a commitment of confidentiality and ensuring an adequate level of security on their part, which guarantees that the data
e personal are kept safe.
Measures taken to ensure the security of personal data processing
SKINGURU guarantees the security and confidentiality of the data hosted and transmitted through its computer system but does not assume responsibility for the loss of information caused by any defects or errors of the software it is equipped with and which is provided by third party companies producing computer programs. Although SKINGURU has taken security measures to prevent data loss, misuse or misuse and unauthorized access, the absolute security of the data transferred over the internet cannot be guaranteed.
The measures applied by SKINGURU regarding the security of personal data processing comply with the legal provisions and are the following:
1. Identification and authentication of SKINGURU employees, by entering an identification code from the keyboard (a string), which acts under the authority of the companies that form the SKINGURU brand name and which have been recognized as access to personal databases .
2. The department providing technical support may have access to personal data to resolve exceptional cases.
3. The employees of the companies that make up the SKINGURU brand name will be specially designated and authorized for the operations of collection and introduction of personal data in an information system.
4. Any modification of personal data may only be made by specially designated authorized users.
5. Users who have access to personal data are instructed by the operator on confidentiality. Users are forced to log out when they leave work.
6. Any personal data printed in physical format will be stored and archived in a locked room with restricted access.
7. In order to maintain the security of the processing of personal data (especially against computer viruses) the operator shall take measures consisting of:
– prohibiting the use by users of software programs that come from external or dubious sources;
– informing the collaborators who have access to the databases regarding the danger regarding the computer viruses;
– implementation of automatic devirus and security systems for information systems;
– Data encryption through SSL security certificate for encrypting information circulating through Internet channels between the site and its user.
SKINGURU makes all reasonable, commercially justified efforts to protect the personal data collected, we analyze the new technologies in the field and then, if necessary, we apply them in order to upgrade our security systems.