Remarkt Privacy Policy

  1. WHO WE ARE
  2. WHAT KIND OF PERSONAL DATA DO WE PROCESS, FOR WHAT PURPOSES AND ON THE BASIS OF WHICH BASIS?
  • 1 Creating and using an account on our Site
  • 2 Answer your questions, complaints or requests
  • 3 Purchasing products / services and monitoring orders to identify a risk or fraud
  • 4 Providing after-sales services related to purchases made on the Site
  • 5 Direct marketing communications
  • 6 Promotional campaigns
  • 7 Surveys, customer satisfaction surveys and customer feedback
  • 8 Browsing the Website. Use of cookies
  • 9 Plugins for Facebook, Twitter, Pinterest
  • 10 Interactions with social media users
  • 11 Organization, implementation and participation in the Loyalty Program
  • 12 Carrying out statistical analyzes in the context of the Loyalty Program

 

  1. AUTOMATED DECISION MAKING AND AUTOMATED PROFILING
  2. STORAGE OF PERSONAL DATA
  3. TRANSMISSION OF YOUR PERSONAL DATA
  4. TRANSFER OF PERSONAL DATA ABROAD
  5. DATA PROCESSING OF PERSONS OVER 18 YEARS OLD
  6. SECURITY OF DATA PROCESSING
  7. REFUSAL TO PROVIDE DATA AND ITS CONSEQUENCES
  8. THE RIGHTS OF THE PERSONS CONCERNED
  9. change
  10. CONTACTS

This Privacy Policy ("Politics ”) describes how your personal data is collected, used and transmitted when you visit or make a purchase from the site www.remarkt.ro, as well as in the context of the implementation of the Remarkt Loyalty Program.

We undertake to respect your confidentiality, in compliance with all data protection laws and regulations, including General Data Protection Regulation (EU) 2016/679 ("GDPR”). Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

  1. WHO WE ARE

The data operator is REMARKT MAGAZINE SRL., a limited liability company with registered office in Calea Floreasca no. 165, One Tower Building, Floor 3, Sector 1, Bucharest, Romania, registered at the Bucharest Trade Registry under no. J40/3283/2013, having unique registration code 31357586, e-mail online@remarkt.ro, telephone number 0374342444 („Note" or "The Company").

  1. WHAT KIND OF PERSONAL DATA DO WE PROCESS, FOR WHAT PURPOSES AND ON THE BASIS OF WHICH BASIS?

When you visit the Site, you may provide us with your personal data directly (on the Site, by e-mail, via social media or other communication channels), or we may indirectly collect some of the personal data that refers to you, such as your IP address and data about some of the cookies that are installed on your device. In addition, as you browse the Site, we collect from our partners information about the web pages or individual products you view, the websites or search terms that sent you to the Site, and information about how you interact with The site. We refer to the latter information automatically collected as "Device Information".

We will also collect your personal data when you request enrollment in the Loyalty Program by filling in the loyalty card issuance form at the Customer Info in Remarkt hypermarkets and at any cash register within the Remarkt minimarkets ("Loyalty card"). Within the Loyalty Program, Personal Data will be collected directly from you, either by completing the Loyalty Card issuance form, or by using the Loyalty Card when making purchases.

When we talk about "Personal Data" in this Policy, we are referring to both Device Information and any other information that may lead to your identification as a data subject.

We will process Personal Data for the following purposes, based on the legal grounds indicated for each of them:

  • Creating and using an account on our Site

In the process of using the Site you have the opportunity to create your personal account online. For this purpose, the Personal Data processed are: name, surname, e-mail address, order history, a list of favorite products or those you are interested in.

 

Purpose

Legal basis

1

Account creation and use

Processing is required for the execution of a contract (terms and conditions available on the Site)

 

  • Answering your questions, complaints or requests

We will process your Personal Data, such as name, surname, e-mail address, mailing address if you request us to provide a response to that address, telephone number, unique Loyalty Card code if necessary (then when you hold such a card), and any other information or details that you may provide to us in correspondence, in order to resolve and respond to your questions, complaints or requests, depending on the communication channel through which you contact us ( for example email, via the contact form on the Site or when you contact us by phone), as described below.

 

Purpose

Legal basis

1

Responding to your questions, complaints or requests

The processing is based on a legitimate interest in maintaining a good relationship with customers, allowing us to provide answers to your questions, complaints or requests.

 

  • Purchasing products / services and monitoring orders to identify a risk or fraud

In addition, when you make a purchase or attempt to make a purchase through the Site, we collect the following information from you: first and last name, billing address, shipping address when you choose this method of receiving your order, or address the store where you pick up your order, as well as the date and time of pick-up, your email address and phone number, the products or services purchased, the order reference number generated and the order date. We will not access or store the data related to your payment card, the payment is made through our payment service provider. We refer to this information as "Order Information".

We generally use the Order Information we collect to honor orders placed through the Site (including arranging for shipping or picking up orders from one of the Remarkt locations and making invoices and / or order confirmations available to you). . We also use this Order Information to monitor our orders for potential risk or fraud.

 

Purpose

Legal basis

1

Purchasing products / services

The processing is necessary for the execution of the contract to which you are a party (the terms and conditions available on the Site), as well as the fulfillment of the obligations according to the financial-accounting legislation for invoicing.

2

Monitoring orders to identify potential risk or fraud

The processing is based on the legitimate interest of the Company to ensure the proper conduct of its business by avoiding potential fraud.

 

  • Providing after-sales services related to purchases made on the Site

To provide you with certain services or facilities, such as resolving orders to cancel orders or resolving any issues related to the execution of the order, returning products based on applicable legal provisions on distance selling and reimbursement of their value, and ensuring replacement, repair , or refund of the value of the products during the warranty period, we will use the following Personal Data: first name, last name, billing address, delivery address, telephone number, e-mail address, purchased products, order reference number and the date of the order, the date on which the products were picked up from the Remarkt pick-up point, the data from the tax invoice issued (if applicable), the signature (if applicable), the bank details (bank account details) when requesting a refund. another bank account (other than the one from which you made the payment), as well as other data that we can provide communicate during the correspondence related to after-sales services.

 

Purpose

Legal basis

1

Providing after-sales services

The processing is necessary for the execution of the contract to which you are a party (terms and conditions available on the Site)

 

  • Direct marketing communications

We will process your Personal Data, such as name and surname, e-mail address for subscribing and for sending our newsletters through which we will inform you about our products, services and promotional offers. This Personal Data will be processed for direct marketing purposes only with your consent and using the communication channels (e.g. e-mail) that you agreed to when you gave your consent.

The data of customers who agree to the processing of Personal Data for receiving newsletters when completing the Loyalty Card issuance form will also be recorded on our Website www.remarkt.ro, this registration being necessary for sending communications.

  • campaign promotional

We will process Personal Data collected from you by completing participation forms on our Website or other similar forms to organize promotional campaigns and / or contests, or to award prizes to winners of promotional campaigns, as well as to analyze the effectiveness of our promotional campaigns, when such campaigns become available. The Personal Data processed are those provided by you such as: first name, last name, date of birth, e-mail address or telephone number, and they may differ depending on each contest or campaign. If we collect data such as the serial number and number of your ID card or personal numerical code, or other data from your ID card, it will be collected and used for the above purpose only to comply with our tax obligations related to the prizes awarded to the winners. campaigns and / or competitions.

Your participation in such promotional campaigns and / or contests is voluntary. As a result, you decide whether to provide us with your Personal Data, by completing the participation forms on our Website or other similar forms provided by the regulations of promotional campaigns or contests.

If there are any specific details regarding the processing of your data in certain contests or campaigns, please refer to the relevant sections of the related campaign regulations that will be made available.

 

Purpose

Legal basis

1

Organizing promotional campaigns and / or contests and awarding prizes to the winners

The processing will be necessary for the execution of the contract represented by the respective regulation of the campaign or of the contest or terms, promotional offers based on which they are organized

2

Processing the data of the winners of promotional campaigns / contests in order to comply with the legal tax requirements

The processing is based on the fulfillment of certain legal obligations when the applicable legislation imposes certain tax obligations related to the winners.

 

We will not publish on the Site the name, surname, photo or other Personal Data of the winners of the promotional campaign and / or the contest, unless the data subject has given us his / her consent in this respect.

  • Surveys, customer satisfaction surveys and customer feedback

We will process your Personal Data when you decide to participate in our surveys or market research, customer satisfaction surveys or provide us with feedback on our products and services. Such Personal Data will be processed for the above purpose only on the basis of your consent, also taking into account our legitimate interest in helping us understand the needs and expectations of customers regarding our products and services. Your participation in such surveys or market research is voluntary. Accordingly, it is your choice whether or not to provide us with Personal Data (such as first and last name, email address, information on shopping preferences and habits or other Personal Data that you offer to provide to us), by completing the participation forms on our Website (when available), by providing reviews of our products in the dedicated section of the Site, or other similar forms provided in those surveys or studies. Also, in the case of product reviews on the Site, we will be able to verify their veracity, by verifying the e-mail address used for the review with the data about the orders made associated with that e-mail address. Incompatible reviews may be deleted from the Site.

 

Purpose

Legal basis

1

Surveys or market research, customer satisfaction surveys or when you provide feedback on our products and services

The processing is based on your consent and in some cases, the legitimate interest in helping us understand the needs and expectations of customers regarding our products and services.

 

  • Browsing the Website. Use of cookies.

When you visit the Site, we collect Device Information using the technologies “Cookie”, Which are data files placed on your device or computer and often include an anonymous unique identifier. This data may identify the user, such as the IP address or type of internet browser used to browse our Website. For more information on the above-mentioned technologies used on this Site and the purposes for which they are used, as well as on the possibilities to control / deactivate them, and the duration of information retention, please consult Our cookie policy.

  • Plugins for Facebook, Twitter, Pinterest

For the purpose of continuous functional optimization and maximum ease of use, some of our online services use the plugins listed below.

You can recognize the plugins by the Facebook, Twitter, Pinterest logos inserted on our Site. When you click on each logo, Facebook / Twitter / Pinterest are informed that you have accessed Facebook / Twitter / Pinterest from our Site. We would like to point out that the use of your Personal Data by using the Facebook / Twitter / Pinterest pages is subject to the terms and conditions and privacy policies established by those companies, over which Remarkt has no control or responsibility. For more information on the privacy policies adopted by these companies, visit: (i) for Facebook - https://www.facebook.com/policy.php , (ii) for Twitter - https://twitter.com/en/privacy , (iii) for Pinterest - https://policy.pinterest.com/en/privacy-policy.

  • Interactions with social media users

We will process your Personal Data, such as first and last name, image, username, and, where applicable, e-mail address, telephone number and any other information or details that you communicate to us by mail, when you decide to interact with us through social media channels such as Facebook / Twitter / Instagram / YouTube on the official pages of the Company or when you ask us questions, complaints or requests through these communication channels.

Access to our official pages active on these social media platforms is made under the conditions established exclusively by Facebook / Twitter / Instagram / YouTube. Each social media platform has its own data privacy policy. If you have any questions about the use of your Personal Data by those platforms, or for information about the purpose or categories of Personal Data collected and processed by those social media platforms, as well as about your rights and possibilities To protect your privacy, please refer to their privacy policies.

 

Purpose

Legal basis

1

Interactions with social media users

The processing is based on the legitimate interest of allowing interaction with persons interested in the information published on social media profiles managed by Remarkt and to provide an answer to questions, complaints or requests from users addressed through social media channels.

 

  • Organization, implementation and participation in the Loyalty Program

If you participate in the Remarkt Loyalty Program, we will process your Personal Data in order to organize, conduct and allow you to participate in the Loyalty Program conducted by Remarkt, including to detect and prevent attempts to use the Card fraudulently or improperly Loyalty issued under the program.

For this purpose, the Personal Data processed are: name and surname, telephone number, e-mail address, place of residence/residence, the unique code assigned to each Loyalty Card (which will also appear on each tax receipt for purchases for which the Loyalty Card was used), signature, date of completion of the form, data resulting from the use of the Loyalty Card and your interactions with Remarkt in relation to it.

 

Purpose

Legal basis

1

To organize, carry out and allow you to participate in the Loyalty Program carried out by Remarkt, including to detect and prevent attempts to use the Loyalty Card issued within the program in a fraudulent or non-compliant manner

The processing is necessary for the execution of a contract - the terms and conditions of the Loyalty Program, which you accepted when completing the Loyalty Card issuance form and to which you are a party

 

  • Carrying out statistical analyzes in the context of the Loyalty Program

If you participate in the Remarkt Loyalty Program, we will process your Personal Data to carry out statistical analyses, such as the analysis of the localities where the Loyalty Cards are used within the program or analyzes of the effectiveness of the promotions carried out within the Loyalty Program.

For this purpose, the Personal Data processed are: the place of residence/residence provided by you, the unique code of the Loyalty Card and data related to purchases.

 

Purpose

Legal basis

1

Carrying out statistical analyses, such as the analysis of the localities where the Loyalty Cards are used within the program or analyzes regarding the effectiveness of the promotions carried out within the Loyalty Program

The processing is based on the legitimate interest of Remarkt to understand and analyze the operation of the Loyalty Program depending on the area in which the Loyalty Card is used and to analyze and improve the effectiveness of the promotions carried out within the Loyalty Program

 

  1. AUTOMATED DECISION MAKING AND AUTOMATED PROFILING

The Personal Data referred to herein is not subject to automated decision-making processes, including profiling.

Remarkt will be able to send you personalized offers based on your shopping history when you subscribe to our newsletter, but this processing will be done by Remarkt employees and will not involve an automated decision, but an appreciation of the designated Remarkt employees. who will analyze your shopping history.

  1. STORAGE OF PERSONAL DATA

In the context of the processing of your Personal Data for the purposes mentioned above, Remarkt keeps this data as follows:

  1. We may retain your Personal Data associated with your user account for the period in which your account is active and for a subsequent period of 3 years necessary to protect the rights of the Company; please note that deleting the account will not automatically lead to the deletion of the Personal Data we hold about you, but for such deletion it is necessary to exercise your right of deletion in accordance with section 10 below;
  2. In order to answer your questions, complaints or requests, Remarkt will retain your Personal Data for the time necessary to process and issue a response to your request and for the time necessary to protect the Company's rights, taking into account the applicable law, including the limitation period. ;
  3. In the context of purchasing products/services, monitoring orders for the purpose of fraud prevention and after-sales services, Remarkt will keep your Personal Data associated with orders made through the customer account, taking account of accounting legislation, for a period of up to at 10 years;
  4. Your Personal Data used for the purpose of sending direct marketing communications will be kept for a period of 5 years from the expression of consent, or until the moment you request the Company to unsubscribe (withdraw your consent) or delete this data;
  5. Your Personal Data for the organization and administration of promotional campaigns and / or contests, will be kept during the campaign or contest and for the award of prizes to the winners, as well as for the period necessary to protect the rights of the Company, given the applicable law, including the limitation period and storage periods provided for by tax law;
  6. For surveys, customer satisfaction surveys or feedback, Remarkt will retain your Personal Data until the end of the survey or market study and the completion of the analysis of the results, after which personal data will be anonymized or destroyed. ; when you provide us with feedback by completing reviews of our products in the dedicated section of the Site, we will keep that data on the Site for a maximum period of 5 years;
  7. In the context of organizing, conducting and participating in the Loyalty Program Remarkt will keep your Personal Data for the duration of the Loyalty Program, as well as for the period necessary to protect the Company's rights, taking into account the applicable law, including the limitation period and storage periods provided by fiscal legislation;
  8. Your Personal Data used for the purpose of performing statistical analyzes in the context of the Loyalty Program will be stored for the duration mentioned in section 4.7 above. Statistical analyzes that do not contain Personal Data will be kept for the duration deemed necessary by the Company.
    1. TRANSMISSION OF YOUR PERSONAL DATA

We transmit your Personal Data to several contractual partners to help us achieve the aforementioned purposes, as described above. Some of them are authorized persons, such as Shopify International Limited, which provides us with the infrastructure for the development and hosting of the Website, is active in the IT industry and operates in Ireland, as well as Third Blink Software Inc. which provide back-up services for the data on the Site and Zapiet Ltd. which provide the IT application that helps us manage orders and deliveries / pick-ups from the store, and they may be provided with your Personal Data for use within the limits the obligations they have assumed towards the Company. The Personal Data that we disclose to our authorized persons is limited to the minimum personal information that is necessary for the provision of those services and we ask them not to use the Personal Data for any other purpose. We make every effort to ensure that all entities we work with store your Personal Data securely and securely.

Some of them are, in turn, data controllers, such as: (i) the payment service provider, Ireland-based Stripe Payments Europe Ltd., which collects Personal Data directly from you when you make the payment. online on our Site (without being communicated to us), (ii) courier service providers, which have their headquarters or representative office in Romania for the delivery of orders placed on the Site at the indicated delivery address (when this option will be available on the Site) and in certain cases, for organizing product returns, (iii) the Orderify application provider, Funly LLC (Customer First focus), for editing orders placed on the Site, which does not store data but can access it to operate the cancellation / modification of orders, (iv) the payment service provider in stores Global Payments SRO Prague through its branch in Bucharest, when we will reimburse the amounts paid with the card in Remarkt locations.

In the context of the Remarkt Loyalty Program, the entities to which we may disclose Personal Data are:

  1. for the management of the database in relation to the Loyalty Cards issued under the Loyalty Program, including for the use of benefits, the Personal Data will be uploaded to the SmartCash management system provided by Magister Software SRL, which operates in Romania; for the implementation of a reporting system (QlikSense) to carry out analyzes regarding the effectiveness of promotions, personal data will be accessed by Relevance Management SRL, which operates in Romania;
  2. the transmission of our newsletters (direct marketing) is carried out through the Site remarkt.ro, so that the data of customers who agree to data processing (surname, first name, e-mail address) for receiving newsletters, when completing the Loyalty Card issuance form, will be recorded through the Site and will be transmitted to our partners contractual Shopify International Limited and Third Blink Software Inc. mentioned above.

Some of the entities to which we disclose your Personal Data are third parties who do not intend to process the data, but may have access to it in the performance of their duties or in their interactions with the Company, such as companies that provide technical maintenance, financial or legal auditors .

Finally, we may transmit your Personal Data to public authorities, auditors or other institutions competent to carry out inspections and controls over the Company's activity and assets in order to comply with applicable laws and regulations, to respond to a subpoena or other lawful requests for information we receive or to otherwise protect our rights. These authorities or public institutions can be the Romanian Police, courts, ANSPDCP, ANAF, public notaries, bailiffs, etc. Your Personal Data may also be made available or transmitted to third parties to comply with a legal requirement or to protect the rights and assets of our Company or another entity or person, when we may disclose the data to lawyers or mediators. Likewise, your Personal Data may be transmitted to third-party acquirers, to the extent that the Company's activity would be transferred (in whole or in part), and the data of the data subjects would be part of the assets that are the subject of such a transaction.

  1. TRANSFER OF PERSONAL DATA ABROAD

In the context of the operations described above, your Personal Data may only be transferred abroad to European Union countries ("UE") Or the European Economic Area ("EES").

We hereby inform you that any transfer made by the Company to an EU or EEA Member State will comply with the legal requirements set out in the GDPR.

  1. DATA PROCESSING OF PERSONS OVER 18 YEARS OLD

All Personal Data processing activities presented in this Policy refer exclusively to persons who are at least the age of majority in the state or province of residence (in Romania this age is 18). The use of the systems, as well as the results of the processing, is prohibited with regard to persons who have not reached this age.

Remarkt does not knowingly collect, store or use data of persons under the age of 18 even in connection with the Loyalty Program, as the Loyalty Program is only intended for adults. By accepting and enrolling in the Program, participants represent that they are at least 18 years of age.

If, despite our reasonable efforts to prevent, such processing still takes place, we will stop it once we notice that the users/participants have not reached the age mentioned above.

  1. SECURITY OF DATA PROCESSING

The company hereby informs you that it constantly evaluates and updates the security measures implemented to ensure the safe and secure processing of Personal Data.

  1. REFUSAL TO PROVIDE DATA AND ITS CONSEQUENCES

The Personal Data provided in the following sections: (i) 2.1 - in order to create and use the account on the Site, 2.3 - in order to purchase products/services online, 2.4 - in order to provide after-sales services, 2.6 - in some cases, in order to organize promotional campaigns and/or contests, 2.11 - in order to organize, conduct and participate in the Loyalty Program, represents a contractual/necessary obligation in order to conclude a contract with the Company and (ii) 2.3 - in order to purchase online products/services, as provided by the financial-accounting legislation for invoicing, as well as 2.6 - in order to process the data of the winners of promotional campaigns/contests in order to comply with legal tax requirements, represents a legal obligation of Remarkt, and the person concerned must provide Personal Data.

If the data subject does not provide the Personal Data for the purposes mentioned above, it will not be possible to use all the facilities provided by the Site, the products/services will not be able to be provided, and the registration for campaigns/contests, as well as the entry in possession of the prizes, they will not be possible, respectively the concerned person will not be able to use the Loyalty Card and its associated benefits.

  1. THE RIGHTS OF THE PERSONS CONCERNED

In the context of the processing of your Personal Data, you have the following rights:

  1. Right of access to Personal Data processed: you have the right to obtain confirmation that your Personal Data is or is not processed and, if so, to have access to the type of Personal Data and the conditions under which it is processed, by addressing a request to that effect to the data controller;
  2. The right to request the rectification or deletion of Personal Data: you have the possibility to request, by addressing a request in this regard to the data operator, the rectification of inaccurate Personal Data, the completion of incomplete data or the deletion of your Personal Data in the event that (i) the data not above necessary for the purpose initially (and there is no new legal purpose), (ii) the legal basis of the processing is the data subject's consent, the data subject withdraws his consent and there is no other legal basis, (iii) the data subject exercises his right to object, and the operator does not have legitimate reasons that prevail to continue processing, (iv) the data has been processed illegally, (v) deletion is necessary to comply with EU or Romanian legislation, or (vi) the data has been collected in connection with information society services offered to children (if applicable) when specific consent requirements apply;
  3. The right to request the restriction of processing: you have the right to obtain a restriction on the processing in cases where: (i) you consider that the Personal Data processed is inaccurate, for a period that allows the operator to verify the accuracy of the Personal Data; (ii) the processing is illegal, but you do not want us to delete your Personal Data, but to restrict the use of this data; (iii) if the data controller no longer needs your Personal Data for the purposes mentioned above, but you need data to establish, exercise or defend a right in court; or (iv) you have as opposed to processing, for the time interval in which to verify whether the legitimate grounds of the data controller prevail over the rights of the data subject;
  4. The right to withdraw your consent to the processing, when the processing is based on consent, but without affecting the legality of the processing activities carried out up to that point;
  5. The right to object to the processing of data for reasons related to the particular situation you are in, when the processing is based on a legitimate interest, as well as to oppose, at any time, the processing of data for direct marketing purposes, including the creation of profiles;
  6. The right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning the data subject or affects him in a similar manner in a significant manner;
  7. The right to data portability, meaning the right to receive your Personal Data that you have provided to the data controller in a structured, commonly used and automatically readable form, as well as the right to transfer that data to another controller, if the processing is based on your consent or the performance of a contract and is carried out by automatic means;
  8. The right to file a complaint to the supervisory authority - the National Supervisory Authority for the Processing of Personal Data (ANSPDCP) and the right to apply to the competent courts.

The above rights can be exercised at any time. To exercise these rights, we encourage you to use the available form here, or send a written, dated and signed request or in electronic format to the following address: Calea Floreasca no. 165, One Tower Building, Floor 3, Sector 1, Bucharest, Romania or by e-mail at online@remarkt.ro. In some cases, we may ask you for some additional Personal Data to identify you when you exercise these rights. Also, if you wish to withdraw your consent to the purposes of direct marketing, you may use the option "unsubscribe”Which is included in every marketing communication.

  1. change

We may update this Privacy Policy at certain intervals to reflect, for example, changes in our practices or for other operational, legal or regulatory reasons. The Company will notify you of any material or substantial changes to this Privacy Policy and will ensure that such notification is made in a manner that ensures that you become aware of them, for example by using the e-mail address on which you have provided to us, or any appropriate means to ensure effective communication.

  1. CONTACTS

For more information about our privacy practices, if you have any questions or would like to make a complaint, please contact us at the contact details in the introductory part of this Privacy Policy.

Date of last update: March 16, 2023