Privacy policy

Information note regarding the processing of personal data

Welcome to the privacy policy of A EOL SRL !

When you want to benefit from the products and services offered by our company, (hereinafter referred to as "Cusut-surfilat.ro " ) or you want us to conclude a partnership with ​Cusut-surfilat.ro , ​you entrust us with information about you, also known under the designation of personal data, by virtue of the trust you have in us. We thank you for this trust, which is why we want to explain to you in a clear and transparent way what our practices are regarding the confidentiality of your data. Our general approach is to take care of the personal data you provide to us.

This notice (also known as the Privacy Policy) will show you how we look after your data when you visit our website (regardless of where you use it) and will tell you about your rights in relation to your personal data and how the law protects you.

➢ Important information & who we are ➢ The data we collect from you ➢ How we collect your personal data ➢ How do we use your personal data?

➢ Disclosure of your personal data ➢ International transfers
➢ Data security
➢ Data storage

➢ Your rights
➢ Changes to this policy

Introduction
The purpose of this information note

This Information Note (hereinafter referred to as the "Note") is intended to inform you about how Cusut-surfilat.ro (to which we may also refer by "we", "the Organization" or "the Company" or "the Company ”) collects and processes your personal data that you provide to us, including any kind of data that you give us when, for example, you subscribe to our newsletter, purchase or download a product.

This Notice applies everywhere you find us in the online environment. In particular, we are present through the site https://Cusut-surfilat.ro / and its subdomains or affiliated sites (which we will collectively call the "Site"), as well as all profiles/pages of media associated with this brand, including but not limited to Facebook, Instagram, YouTube, and we will refer to all of them as "Platform").

For your convenience, we have listed all the profiles we manage below:

Website: Cusut-surfilat.ro

Facebook: https://www.facebook.com/decusut

Instagram: https://www.instagram.com/masinidecusutindustriale

YouTube: https://www.youtube.com/aeolsrl

The Platform is not intended for children under the age of 15, we do not collect and do not knowingly wish to collect data relating to minors. For this we make all the necessary diligence to verify, reasonably, that the person who provides us with the data is not a child, according to the terms defined below - the responsibility for any kind of information that is provided to us with the circumvention of these provisions being entirely of the person who sends us this data or the guardian in the case of minors.

It is important that you read this policy together with all data processing & privacy notices that we will provide on various occasions when we collect or process your personal data so that you are always fully informed about why and how we use this data. This policy comes in addition to the other notices and is not intended to remove them.

Who we are?

Below you can also find our identification data:

Name of A EOL SRL

Unique identification code RO11158856
Email office@aeol.ro

We are under no obligation to appoint a personal data protection officer, so any questions about the use of your personal data should be directed to the contact details above.

If you have any concerns, observations or complaints about us or the personal data we process for you, you can always send us an e-mail at the above address.

According to the legislation, in relation to you we are a personal data operator. In this capacity, we also have a number of obligations, including that of informing you about the data we process, the way we do it, what rights you have and how you can exercise these rights.

Who are you?

According to the legislation, you, the individual beneficiary of our services, the representative or contact person of a company or the person in a relationship of any kind with our company, are a "person

target", i.e. an identified or identifiable natural person. In order to be completely transparent about data processing and to allow you to easily exercise your rights at any time, we have implemented measures to facilitate communication between us, the data controller, and you, as the data subject.

Links from third parties

This Notice does not cover third-party apps and websites that you can reach by following links on our website (including when you go to, for example, our social media community pages, such as Facebook, Instagram, YouTube, etc.). We do not control the websites of these third parties, nor are we responsible for their processing, privacy and security policies. When you leave our site, we encourage you to review the Privacy Policy/Disclosure Notice and terms of use on any site and/or application before providing personal data to them.

Claims

If you believe there is a problem with the processing of your personal data or wish to exercise your rights in section 9, please first send us a request to the address mentioned in section 1.2 – we will make every effort to resolve your request within the shorter time, amicably.

You can also file a complaint with the personal data supervisory authority. For Romania, you can find the contact details below:

Email anspdcp@dataprotection.ro

The data we collect from you

Personal data or personal information means any information about an individual that can help identify that person. Here we also do not include those data where the identity has been removed (anonymized data).

Depending on the products, services or functionalities that you want to benefit from and that we have developed, we will need to collect, use, store or transfer certain personal data, which, in general, will be as appropriate the following, grouped by category:

Category Included data

We also collect, use and share for any purpose Aggregate Data , such as statistical or demographic data. Aggregate Data may derive from your personal data, but it is not considered personal data within the meaning of the law as this information does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users who access a specific functionality of the Site. However, if we combine or match the Aggregated Data with your personal data in such a way that we can directly or indirectly identify you, we will treat the resulting combined data as personal data that will be used as described in this document.

We do NOT collect any Special Categories of Personal Data about you (this includes details of your racial or ethnic origin, political opinions, religious or philosophical beliefs or trade union membership and processing genetic data, biometric data to uniquely identify you, health data or data about your sex life or sexual orientation). We also do not collect information about criminal convictions and offences.

If you do not provide us with the data ...

When we ask you to fill in personal data to give you access to certain functionalities or services of the site, we will mark some fields as mandatory, because this is information we need to be able to provide you with the good/service or to gives you access to that functionality.

Please note that if you choose not to provide us with this information, you may not be able to complete your user registration or benefit from these services or features. In such an event, we may be required to restrict your access to a product or service that you want from us, but we will notify you at the time if this happens.

For example, if you want to download certain materials on the Platform, we will ask for your e-mail address; if you do not provide us with a valid email address, we will not be able to provide you with that material.

Also, if at the time you send us a request at the contact address or through the form on the Platform or by any other means indicated and we cannot verify your identity, we reserve the right not to respond to that request.

How do we collect your personal data?

Your personal data will generally come from you through direct interaction, but there will be situations where we will obtain data about you

indirectly (such as from third parties, institutions, etc.) or with the help of technology.

Thus, we use different methods to collect data about and from you, such as:

Source Data

For example, we will receive personal data about you when: ➢ you subscribe to the newsletter;
➢ you send us a private message via social networks; ➢ you send us an e-mail;

➢ leave a comment on Cusut-surfilat.ro's social networks; ➢ you tag us in posts / pictures on social networks;
➢ distribute our content etc.

How do we use your personal data?

In general, we will use the information we receive about you, either directly or indirectly, for the following purposes:

• ➢ in order to conclude or execute a contract between you and us;

• ➢ to answer your questions and requests;

• ➢ for marketing purposes, but only in the situation in which we have

  your prior consent;

• ➢ to provide and improve the services and products we offer;

• ➢ to diagnose or fix technical problems;

• ➢ to defend ourselves against cyber attacks;

• ➢ for the creation and/or maintenance of accounts;

• ➢ to comply with legislation;

• ➢ to personalize the experience on our website;

• ➢ to personalize the advertising you see on other publisher websites, while limiting the amount of time you see ads;

• ➢ to improve the design and style of the site

• ➢ to inform you about products, services or promotional offers

  which may interest you if you have chosen to receive these types of

  communications.

• ➢ to send you automated messages about your subscription or

  account registration, for example if you clicked on a password reset link. This could be via email, overlay or push notification.

• ➢ to publish and respond to a comment you have sent to us, on the blog, website, etc.;

• ➢ to allow you to share content on the site with others using social media (Facebook, Instagram, Whastapp, SMS or other similar applications) or email;

• ➢ to administer contests and inform you if you have entered a promotion;

• ➢ for compiling customer reviews;

• ➢ for carrying out market studies;

• ➢ to send a product to the address indicated by you;

• ➢ to provide you with access to a service or product that you request from us;

• ➢ to deal with any request/complaint/complaint or

  suggestion you send us;

• ➢ to send you push notifications through the Platform

  ours if necessary.

  In short, we will use the data you provide us (either directly or indirectly) to:

• ➢ conclude or execute a contract with you;

• ➢ to achieve our legitimate interest (or that of a third party

  persons) when it is also in your interest and rights and

  your fundamental freedoms are not affected;

• ➢ to comply with a legal or statutory obligation.

  We generally do not rely on consent to process your personal data, but when we do we will expressly ask for it.

  The purposes for which we collect your personal data

  We have set out below, in tabular format, a description of the ways in which we plan to use your personal data, as well as the legal basis on which we do so. We have also identified our legitimate interests where applicable.

  Please keep in mind that we may process your personal data based on several legal grounds, depending on the purpose for which we use this data. Please contact us at the email address in section 1.2 if you would like more details about the legal grounds we rely on when processing your personal data where there was more than one legal ground highlighted in the table below.

Purpose Personal data Additional information

You will receive marketing communications from us if you have requested information from us, if you have purchased products or services, or if you have chosen to download our materials from the Platform, and you have not chosen to opt out of this type of marketing.

Marketing from third parties

As a general rule, we do not pass on your personal data for marketing purposes to third parties. If we do, we will expressly ask for your consent.

Unsubscribe (opt-out)

You can ask us or third parties to stop sending you marketing messages at any time through the unsubscribe link you will find in that email or by contacting us.

When you opt out of marketing messages, this opt-out will not apply to the personal data you have provided to us when purchasing a product, downloading a material, requesting information or services or other transactions.

Cookies

You can set your browser to refuse some or all cookies or to warn you when sites place or have access to cookies. If you disable or refuse cookies, please keep in mind that certain parts of the Platform will be inaccessible or will not work properly. For more information about cookies, please read the Cookies Policy.

Change of purpose

We will only use your personal data for the purposes for which we collected the data, unless we reasonably believe that we need to use it for another reason and that reason is compatible with the original purpose. If you would like an explanation of how the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for a purpose unrelated to the original purpose, we will notify you and explain the legal basis that allows us to do so.

Please note that we may process your personal data without informing you or needing your consent, in accordance with the rules above, where the law allows us to do so.

What is the legal basis for processing your personal data?

The legal basis for the processing of your personal data can be found below:

• ➢ The processing of your data is necessary for signing the terms

  which govern the use of the site. In other words, for your registration as a user of the site, we need to process your personal data, otherwise we would not be able to manage the registration (the basis being the conclusion or execution of a contract, including previous steps to conclude it).

• ➢ Conclusion and execution of the collaboration contract If you want to support this project, through sponsorships or advertising campaigns, we will conclude a contract, and for this it is necessary to process your personal data.

• ➢ The conclusion and execution of the contract of sale or provision of services that you conclude with us, it is necessary to process your personal data in order to be able to execute the contract for the sale of products or the provision of services that you want from us.

• ➢ As we wrote in the previous section, it is possible that certain data processing will be activated only when you ask us to do so (such as storing payment data for future purchases) or to keep you informed about the stock of our products or with similar new products that we introduce to the site. The legal basis for these cases is your consent that you provide to us.

• ➢ We also have a legitimate interest to carry out the necessary checks in order to detect and prevent possible fraud when you want to make a purchase, this processing being to the advantage of all parties when the payment is made.

• ➢ Requests or requests made through Customer Service/Support, we have a legitimate interest in responding to requests or questions you ask us through the various existing means of contact. We include here even the private messages you send us in which you ask us questions about the podcast, campaigns or want to become our partner.

• ➢ We understand that the processing of this data is also to your advantage, as it allows us to properly assist you and find a solution to your questions. When you contact us, in particular for incident management or ask us for clarifications regarding the order or the product/service purchased, the processing is necessary for the proper execution of the sales contract.

• ➢ When you contact us for order incident management or to make a complaint, the processing of your personal data is done to fulfill our legal obligations in this regard.

• ➢ Marketing, We process your data for marketing purposes based on the consent you give us, for example when you agree to receive personalized information by various means, when you authorize the sending of push notifications on your mobile device or browser or when you accept the legal terms and conditions to participate in a promotional action.

• ➢ In order to present you with personalized information, we consider that we have a legitimate interest in compiling your profile with the information we have about you (such as your browsing, preferences or purchase history) and with the personal data you provide us at a given time, such as age range or language, because we understand that processing this data is also to your advantage as it allows us to improve your user experience and thus access information according to your preferences.

• ➢ Improving services, we consider that we have a legitimate interest when analyzing the way in which our site is used, as well as the degree of user satisfaction.

• ➢ The processing of this data is also to your advantage as the goal is to improve the user experience and provide a higher quality service.

  In short, our grounds for processing your data will generally be as follows:

  1. You have given your consent for the processing of personal data, remember that you can withdraw your consent at any time by following the unsubscribe instructions

("unsubscribe") from each email or by sending a request

written to the e-mail address ​office @aeol.ro .

2. Processing is necessary for the conclusion or execution of a

   contract between you and us

3. Processing is necessary for the purposes of our legitimate interests

   or of another party

4. Disclosure of your personal data, we may transfer your data

   your personal data to the persons below for the purposes mentioned in point 5.1 above. We may disclose your data, subject to applicable law, to business partners or other third parties. For example, if we make a purchase for you, we will pass your data to the partners to our merchants so that the invoice can be issued on your behalf. Another example is the sending of personal data to the email provider with which we send the messages to you.

   Also, if you have a request related to a product and we need to transmit this data to our partners. We always make reasonable efforts to ensure that these third parties have adequate protection and security measures in place. We have contractual clauses with these third parties so that your data is protected. We will inform you of the identity of these companies before we transfer this data or within a reasonable time, and we will ensure that any transfer is legitimate, based on your consent or other legal basis.

We may pass the data on to other parties with your consent or according to your instructions.

We will also be able to provide your personal information to the prosecutor's office, the police, the courts and other competent state bodies, based on and within the limits of the legal provisions and as a result of expressly formulated requests.

We will ensure, within reasonable limits, that your data does not leave the European Economic Area, but to the extent that we transfer data to countries outside the EEA, we will in all cases ensure that the transfers are legitimate, based on your consent explicit or other legal basis.

Other people's access to your personal data
In certain cases, other third parties will also have access to personal data, such as:
Facebook;
Instagram;
Online chat platforms etc.

At this time we do not transfer and do not intend to transfer your personal data or part of it to other companies, organizations or individuals in third countries or to international organizations.

If it will be necessary for us to transfer your data to any of the above destinations, we will send you a new information note about this in advance.

The transfer of personal data to a third country can only take place if the country to which the transfer is intended ensures an adequate level of protection.

The transfer of data to a state whose legislation does not provide a level of protection at least equal to that provided by the General Data Protection Regulation is possible only if there are sufficient guarantees regarding the protection of the fundamental rights of the data subjects. These guarantees will be established by us through contracts concluded with the suppliers/service providers to which your personal data will be transferred.

Some of our service providers may be located outside the European Economic Area (EEA), so their processing of your personal data will involve a data transfer outside the EEA.

Data security

We understand how important the security of personal data is and take the necessary measures to protect our customers and other persons whose data we process from unauthorized access to personal data, as well as from the unauthorized modification, disclosure or destruction of data that we process in the current business .

We have implemented the following technical and organizational security measures for personal data:

Dedicated policies. We adopt and constantly review internal personal data processing practices and policies (including physical and electronic security measures) to protect our systems from possible unauthorized access or other possible threats to their security. These policies are subject to constant review to ensure that we comply with legal requirements and that the systems are working properly.

Data minimization. We ensure that your personal data that we process is limited to only what is necessary, appropriate and relevant for the purposes stated in this Notice.

Restricting access to data. We try to restrict as much as possible access to the personal data we process to the minimum necessary: ​​employees, collaborators and other people who need to access this data in order to process it and carry out a service. Our partners and collaborators are subject to strict confidentiality obligations (either by contract or by law).

Specific technical measures. We use technologies to ensure the security of our customers, always trying to implement the most optimal solutions for data protection. We also make periodic data back-ups to be able to recover them in the event of an incident, and we have implemented periodic audit procedures regarding the security of the equipment used. However, no website, app, or internet connection is completely secure and untouchable (see NASA).

Ensuring the accuracy of your data. Sometimes we may ask you to confirm the accuracy or timeliness of your data to be sure that it reflects reality.

Staff training. We constantly train and test our employees and collaborators on legislation and best practices in the field of personal data processing.

Anonymization of data. Where we can, we try as much as possible to anonymize/pseudonymize the personal data we process, so that we can no longer identify the persons to whom it refers.

However, although we make constant efforts to ensure the security of the data you entrust to us, we may also experience less fortunate events and have security incidents/breaches. In these cases, we will strictly follow the security incident reporting and notification procedure and will take all necessary measures to restore the situation to normal as soon as possible.

Data storage

Please note that at this time we will not process and store all the data elements identified below, but we are constantly working to develop the Platform by introducing new products, benefits and services and have taken into account future implementations, for to be completely transparent with you.

Purpose Additional information

Registration as a User: We will keep your data until you decide to stop being a user (delete your account).

The conclusion and execution of the contract of sale or provision of services that you conclude with us: We will process your data for the period of time necessary to manage the purchase of the products or services you buy, including any returns, complaints, guarantees or complaints related to the purchase the respective product or service.

Requests or requests made through Customer Service/Support: We will process the data for as long as necessary to satisfy the request or request.

Marketing: We will process the data until you unsubscribe from the newsletter/other marketing methods.

Service improvement: We will process the data punctually, only during the respective action (ie. survey, feedback form, etc.)
In short, we will keep your personal data for as long as necessary to fulfill the purposes for which we collected it, including to satisfy any legal, accounting or reporting requirements.

To determine the appropriate retention period for personal data, we consider the value, nature and sensitivity of the personal data, the potential risk of harm caused by the unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve these purposes by other means and applicable legal requirements.

By law we must keep basic information about our customers, contractual partners and sponsors (including contact, identity, financial and transaction data) for 5 years after they are no longer customers for tax purposes.

In certain circumstances, we may anonymize your personal data (so that it can no longer be associated with you) for scientific, historical or statistical research purposes, in which case we may use this information indefinitely without notifying you in advance.

Please note that in certain expressly regulated situations, we store the data for the period required by law.

Your rights

In certain circumstances, you have certain rights regarding your personal data in accordance with legal provisions. To exercise them, please contact us at the email address in section 1.2.

We have also set out these rights in a detailed form below. But, in short, according to the legislation in force, you have the following rights:

The right to withdraw consent – ​​when the processing was based on your consent and there is no other basis for processing. Please note that the withdrawal of consent does not affect the processing that has taken place up to that point.

The right to be informed about the processing of your data - which is achieved through this Information Note.

The right of access to data - you have the right to receive a copy of the data we process about you. Additional copies may be provided for a fee.

The right to rectify inaccurate or incomplete data – you have the right to ask us to amend/complete the data we process about you when you consider that we need to do so

The right to erasure ("the right to be forgotten") - this right allows you to request that, in certain circumstances, when we no longer have any other grounds for processing your data, we delete your data and no longer process it on future.

The right to restrict processing – when we process your data to fulfill our public interest tasks or our legitimate interests (or those of a third party) and there is something about your particular situation that makes you want to object to the processing. You also have the right to ask us to restrict processing when we process your data for direct marketing purposes.

The right to transfer the data we hold about you to another operator – when your data is in a format that allows us to transfer it to another operator in an automated, easily accessible and machine-readable format.

The right to object to data processing - when we process your data to fulfill a public interest or pursue our legitimate interests or those of a third party.

The right not to be subject to a decision based solely on automated processing, including profiling

The right to go to justice

The right to a complaint before a Supervisory Authority, whose contact details you can find below:

Email anspdcp@dataprotection.ro

Please note that:

You can withdraw your consent to direct marketing at any time by following the unsubscribe instructions in each email/text or other electronic message.
If you want to exercise your rights, you can do so by sending a written, signed and dated request to the e-mail address: office@aeol.ro. The rights listed above are not absolute. There are exceptions, therefore each request received will be analyzed in order to decide whether it is justified or not. To the extent that the request is justified, we will facilitate the exercise of your rights. If the request is unfounded, we will reject it, but we will inform you of the reasons for the refusal and of your rights to file a complaint with the Supervisory Authority and to go to court.

Response time: We will try to respond to your request within 30 days. However, the deadline can be extended depending on

different aspects, such as the complexity of the request, the large number of requests received or the impossibility of identifying yourself within a useful period.
What could we need from you? In order to be able to respond to your requests through which you exercise your rights, we may need additional information from you to be able to confirm your identity. If, despite our best efforts, we are unable to identify you and you do not provide us with additional information to identify you, we are not obliged to comply with the request.

Toll. You will not have to pay any fee for exercising your data access right (or any other right). However, you may have to pay a certain reasonable fee if your request is unfounded, excessive or repetitive. Alternatively, we may refuse to comply with your request in these circumstances.

Changes to this Note
We may update this Notice from time to time and will notify you via the Platform or by email of the latest version. All updates and changes to this Notice are effective immediately upon notice, which we will provide by posting on the Site and/or email notification. Even if you do not receive a notification, we encourage you to access and read this Notice periodically to keep up to date with the latest versions.

Note updated on February 12, 2021.