This policy applies to the online store tinyrevolution.ro – commercial name as ENERGYFREE SRL, legal entity with registered office in the Municipality Piatra Neamț, Strada Mărăței, Nr.1, Bloc S2, Scara B, Etaj 3, Ap. 31, Județ Neamț, Reg. com.: J27/1156/2022 , CIF: 46818491.
ENERGYFREE SRL considers access to the protection of personal data an essential right of users, therefore, in full compliance with Regulation (EU) 2016/679 (“General Data Protection Regulation” or “GDPR”), as well as with any other legislation applicable on the territory of Romania, we have prepared this document by which we want to inform you about how we collect, use, transfer and protect your personal data when you interact with us in relation to our products and services, including through our website web.
Any changes in the legislation, our internal practices, the website or the technology used may lead to the modification of this policy, which is why we draw your attention to check the date of the last update and the content of any changes. If we make material changes before they become effective, we will notify you by email (sent to the email address specified in your account) or by a notice on the website. We will consider that you accept the changes if you continue to use the website and your user account after the update date. You can withdraw at any time – in writing – the consent you have given for the use of your data.
If you do not agree with the changes, please stop using the website.
By using this website and creating a user account, you expressly declare that you are at least 18 years old and that you allow us to use your personal data as described in this material. Otherwise, please do not use the website.
What categories of personal data we process
We generally collect your personal data directly from you, so you have control over the type of information you give us. By way of example, we receive information from you as follows:
When you create a customer account, you send us: e-mail address, first and last name, access password (this password is generated by you during account creation);
Within your personal page (My Account) on the tinyrevolution.ro website, you can add additional information, such as: mobile phone number, delivery addresses.
When you place an order, you provide us with information such as: desired product, name and surname, delivery address, invoicing details, when applicable – data regarding the company you represent (and on behalf of which you act), payment method, number phone.
We may also collect and further process certain information about your behavior while visiting our website in order to personalize your online experience and provide you with offers tailored to your profile.
In the future, if we request other personal data from you, we will inform you and ask for your consent.
We do not collect or otherwise process sensitive data, included by the General Data Protection Regulation in special categories of personal data. We also do not want to collect or process data of minors.
- Anonymous information
Through the cookies and Action Tags that – we and our partners (through advertising servers, content servers, website analysis agents, etc.) – use on this website, we can have access to anonymous information that are related to you:
- IP address;
- The country and server to which your computer is connected;
- The operating system, type of browser and computer you use;
- Configuring Java or cookies;
- Your purchase preferences and behavior on this website (the pages you visited, the searches you performed and the products you viewed and purchased, the date and time of your visit or order, the number of visits and orders, number of visits per browsing session and server type, URLs where you came from, domain names and web pages you browse), hobbies and lifestyle, groups you belong to;
- Demographic information (number of household members, age, gender) and area code information associated with your server;
- Applications and plug-ins, as well as any search terms used on our website;
- The address of the website that led you to our website.
We collect this information in a manner that does not allow you to be personally identified. However, we and/or our partners may at some point associate this information with your identity if you have a user account.
Please read more about the types of cookies and how we use them (including how to disable them) on the Cookies details page.
PURPOSE OF PERSONAL DATA COLLECTION
We will use your personal data for the following purposes:
To provide our services for your benefit.
This general purpose may include, as appropriate, the following:
- a) Account creation and administration within the tinyrevolution.ro website
- b) Processing orders, including their receipt, validation, dispatch and invoicing;
- c) Solving cancellations or problems of any nature related to an order, goods or services purchased;
- d) Returning products according to legal provisions;
- e) Reimbursement of the counter value of the products according to the legal provisions;
- f) Providing support services, including providing answers to your questions regarding your orders or goods sold on tinyrevolution.ro.
The processing of your data for these purposes is in most cases necessary for the conclusion and execution of a contract between ENERGYFREE SRL and you. Also, certain processing subsumed for these purposes is required by applicable legislation, including tax and accounting legislation.
To improve our services
We always want to give you the best online shopping experience. For this, we may collect and use certain information related to your Shopping behavior, we may invite you to complete satisfaction surveys following the completion of an order, or we may conduct, directly or with the help of partners, studies and market research.
We base these activities on our legitimate interest in carrying out commercial activities, always taking care that your fundamental rights and freedoms are not affected.
We want to keep you informed about the best offers for the products/services that interest you. In this regard, we may send you any type of message (such as: e-mail/SMS/telephone/mobile push/webpush/etc.) containing general and thematic information, information regarding products similar to or complementary to those we you have purchased them, information about offers or promotions, information about products added to the “Account/My Basket” section or the “Account/Favorites” section or you have shown interest in purchasing them, as well as other commercial communications such as research market and opinion polls, and we may display personalized recommendations on the Website. In order to provide you with information of interest to you, we may use certain data regarding your purchasing behavior (e.g. products viewed / added to wishlist / purchased) to create a profile for you. We always ensure that this processing is carried out with respect for your rights and freedoms and that the decisions made on the basis of them do not have legal effects on you and do not similarly affect you to a significant extent.
In most cases, we base our marketing communications on your prior consent. You can change your mind and withdraw your consent at any time by:
– Accessing the unsubscribe link displayed in the messages you receive from us; or through
– Contacting ENERGYFREE SRL via email at firstname.lastname@example.org
In certain situations, we may base our marketing activities on our legitimate interest in promoting and developing our business. In any situation where we use information about you for our legitimate interest, we take care and take all necessary measures to ensure that your fundamental rights and freedoms are not affected. However, you can ask us at any time, by the means described above, to stop processing your personal data for marketing purposes, and we will comply with your request.
To defend our legitimate interests
There may be situations where we will use or share information to protect our rights and business. These may include:
– Protection measures for the website and users of the tinyrevolution.ro website against cyber attacks;
– Measures to prevent and detect fraud attempts, including the transmission of information to the competent public authorities;
– Measures to manage various other risks.
The general basis for these types of processing is our legitimate interest in defending our commercial activity, it being understood that we ensure that all measures we take ensure a balance between our interests and your fundamental rights and freedoms.
Also, in certain cases we base our processing on legal provisions such as the obligation to ensure the protection of goods and valuables provided by the applicable legislation in this matter.
We will inform you if, in the future, we want to use your data for purposes other than those above, and you will have the opportunity to accept or refuse.
As a general rule, we will store your personal data as long as you have an account on the tinyrevolution.ro website. You may request us to delete certain information or close your account at any time, and we will comply with such requests, subject to the retention of certain information including after account closure, where applicable law (tax or general) or our legitimate interests require it.
WHO CAN ACCESS YOUR DATA. PERSONAL
To whom we transmit your personal data
As appropriate, we may transmit or provide access to certain of your personal data to the following categories of recipients:
– if applicable, to companies within the same group as ENERGYFREE SRL;
– courier service providers;
– payment/banking service providers;
– marketing / telemarketing service providers;
– market research service providers;
– providers of accounting services;
– insurance companies;
– IT service providers;
– other companies with whom we can develop joint programs for offering our goods and services on the market.
– To third parties-partners who provide us with services (such as providers of e-commerce platforms, couriers who deliver the products, those who host the website, etc.). Our partners are: Google, Facebook, Instagram, Instagram shop by Snapppt, MailChimp);
We have contractual relationships with these third-partners to ensure the security of your personal data that they can access through our website. They have agreed to adhere to our strict standards for providing quality products and services, and may only use your data for the agreed purposes.
Online payment details (such as credit or debit card numbers) are provided directly to our bank partner – STRIPE. ENERGYFREE SRL does not have access to and does not store this information – all of which ends up being processed by Stripe. We invite you to read Stripe’s personal data policy.
If we are under a legal obligation or if it is necessary to defend a legitimate interest, we may also disclose certain personal data to public authorities.
We ensure that access to your data by third-party legal entities under private law is carried out in accordance with the legal provisions on data protection and information confidentiality, based on contracts concluded with them.
ENERGYFREE SRL does not rent or sell your personal data to other companies.
To which countries we transfer your personal data
Currently, we store and process your personal data on the territory of Romania.
However, we may transfer certain of your personal data to entities located in the European Union or outside the Union, including countries that have not been recognized by the European Commission as having an adequate level of personal data protection.
We will always take steps to ensure that any international transfer of personal data is handled carefully to protect your rights and interests. Transfers to service providers and other third parties will always be protected by contractual commitments and, where applicable, other safeguards such as standard contractual clauses issued by the European Commission or certification schemes such as the Privacy Shield for the Protection of Personal Data transferred from within the EU to the United States of America.
You can contact us at any time using the contact details set out above to find out more information about the countries to which we transfer your data and the safeguards we have put in place in relation to these transfers.
How we protect your personal data
We are committed to ensuring the security of personal data by implementing appropriate technical and organizational measures in accordance with industry standards.
The transmission of your personal data is done using state-of-the-art encryption algorithms and we store them on secure servers, ensuring data redundancy at the same time.
Despite the measures taken to protect your personal data, we draw your attention to the fact that the transmission of information over the Internet in general or through other public networks is not completely secure, there is a risk that the data will be seen and used by third parties unauthorized parties.
ENERGYFREE SRL will not be responsible when data loss is caused by system vulnerabilities that are not under our control.
Also, when you enter your data through your user account, we encrypt the information with Secure Socket Layer (“SSL”) technology.
Bank card data
We do not store your details of payments you make online with your credit or debit card. These are stored and used by Stripe (our secure payment processing partner). Based on our contractual understanding with Stripe, we have received all necessary assurances regarding the safety and protection of this data. ENERGYFREE SRL will not be liable to you if Stripe does not comply – for any reason – with those contractual terms.
We invite you to read Stripe’s policy regarding the personal data it collects and how it may use it.
Links to other websites
ENERGYFREE SRL is not responsible for the practices of the respective websites regarding the use of personal data.
The General Data Protection Regulation recognizes a number of rights in relation to your personal data.
In order to exercise your rights, you can contact us using the contact details set out above. Please note the following points if you wish to exercise these rights:
Identity. We take the privacy of all records containing personal data seriously. For this reason, please send us your requests regarding such records using the e-mail address related to the account opened on tinyrevolution.ro. Otherwise, we reserve the right to verify your identity by requesting additional information aimed at confirming your identity.
Fees. We will not charge a fee to exercise any right in relation to your personal data, unless your request for access to the information is unfounded, repetitive or excessive, in which case we will charge a reasonable amount in such circumstances. We will inform you of any fees applied before we settle your claim.
Response time. We aim to respond to any valid requests within a maximum of one month, unless this is particularly complicated or you have made multiple requests, in which case we will respond within a maximum of two months.
Third Party Rights. We must not comply with a request if it would adversely affect the rights and freedoms of other data subjects.
You can ask us:
- to confirm whether we are processing your personal data;
- to provide you with a copy of this data;
- to provide you with other information about your personal data, such as what data we have, what we use it for, who we disclose it to, whether we transfer it abroad and how we protect it, how long we keep it, what rights you have, how you can make a complaint, where we obtained your data, to the extent that the information has not already been provided to you by this notice.
You can ask us to correct or complete your inaccurate or incomplete personal data.
We may attempt to verify the accuracy of the data before rectifying it.
You can ask us to delete your personal data, but only if:
- they are no longer necessary for the purposes for which they were collected; or
- you have withdrawn your consent (if data processing was based on consent); or
- exercise a legal right to object; or
- they were processed illegally; or
- we have a legal obligation to do so.
We are not obliged to comply with your request to delete your personal data where the processing of your personal data is necessary:
- to comply with a legal obligation; or
- for establishing, exercising or defending a right in court.
There are certain other circumstances in which we are not obliged to comply with your data deletion request, although these two are the most likely circumstances in which we may refuse your request
Before exercising this right, it is important to download from your tinyrevolution.ro account and save all the documents related to the orders made on tinyrevolution.ro, regardless of whether the billing was done to you or to another natural or legal person (such as: invoices , warranty certificates). If you do not do this before exercising your right to deletion, you will lose all these documents and ENERGYFREE SRL will be unable to make them available to you, as the case may be, because the process of deleting the data, respectively the account tinyrevolution.ro, with all its related data and documents, is an irreversible process.
Restriction of data processing
You can ask us to restrict the processing of your personal data, but only if:
- their accuracy is contested (see rectification section), to allow us to verify their accuracy; or
- the processing is illegal, but you do not want the data to be deleted; or
- they are no longer necessary for the purposes for which they were collected, but you need them to establish, exercise or defend a right in court; or
- you have exercised your right to object, and checking whether our rights prevail is ongoing.
We may continue to use your personal data following a restriction request if:
- we have your consent; or
- to establish, exercise or ensure the defense of a right in court; or
- to protect the rights of ENERGYFREE SRL or of another natural or legal person.
You may ask us to provide your personal data in a structured, commonly used and machine-readable format, or you may request that it be “ported” directly to another data controller, but in each case only if:
- the processing is based on your consent or the conclusion or performance of a contract with you; and
- processing is done by automatic means.
You can object at any time, for reasons related to your particular situation, to the processing of your personal data on the basis of our legitimate interest, if you consider that your fundamental rights and freedoms prevail over this interest.
You can also object to the processing of your data for direct marketing purposes (including profiling) at any time without giving any reason, in which case we will stop this processing as soon as possible.
Automated decision making
You can ask not to be the subject of a decision based solely on automated processing, but only where that decision:
- produces legal effects regarding you; or
- affects you in another similar and significant way.
This right does not apply if the decision reached by automated decision-making:
- it is necessary for us to enter into or perform a contract with you;
- is authorized by law and there are adequate safeguards for your rights and freedoms; or
- is based on your explicit consent.
You have the right to lodge a complaint with the supervisory authority regarding the processing of your personal data. In Romania, the contact details of the supervisory authority for data protection are as follows:
The National Supervisory Authority for the Processing of Personal Data
G-ral Blvd. Gheorghe Magheru no. 28-30, Sector 1, postal code 010336, Bucharest, Romania
Telephone: +40.318.059.211 or +40.318.059.212;
Without prejudice to your right to contact the supervisory authority at any time, please contact us in advance, and we promise to make every effort to resolve any problem amicably.