Privacy Policy

Privacy Policy on the processing of personal data

We consider ensuring the right to protection of personal data as a fundamental commitment, therefore we will devote all necessary resources and efforts to process your data in full compliance with Regulation (EU) 2016/679 (“General Data Protection Regulation” or “GDPR”), as well as with any other legislation applicable in Romania. Since one of the essential principles of this legal framework is transparency, we have prepared this document to inform you about how we collect, use, transfer and protect your personal data when you interact with us in connection with our products and services, including through our website. We reserve the right to periodically update and amend this Privacy Policy to reflect any changes in the way we process your personal data or any changes in legal requirements. In the event of any such changes, we will post the revised Privacy Policy on our website, so please check the content of this Privacy Policy periodically.

Who we are and how to contact us

Danube Caviar is the trade name of SC DANUBE RESEARCH CONSULTING SRL, a legal entity of Romanian nationality, with registered office at 8 Presei Street, bl. 6, Sector 1, Bucharest, with order number in the Trade Register J36/13/2002, unique tax registration code RO 14393740 (hereinafter “Danube Caviar” or “we”). For the purposes of data protection legislation, we are a controller when processing your personal data. As we are always open to hearing your views, as well as providing you with any additional information you may need regarding the processing of your data, we encourage you to contact the Danube Caviar Data Protection Officer at [email protected] – with the mention: For the attention of the Danube Caviar Data Protection Officer.

What categories of personal data we process

In general, we collect your personal data directly from you, so that 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 Danube Caviar account, you provide us with: your e-mail address, first and last name, and telephone number. You will also provide us with your delivery address, which will remain active on your account. – When you place an order, you provide us with information such as: the product you want, your first and last name, delivery address, billing details, payment method, telephone number, credit card details, etc. 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. We invite you to learn more about this by consulting the section on the purposes of processing below. On our website we may store and collect information in cookies and similar technologies. 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 wish to collect or process data from minors under the age of 16.

What are the purposes and grounds for processing

We will use your personal data for the following purposes: For the provision of Danube Caviar services for your benefit This general purpose may include, as applicable, the following: Account creation and administration within the Danube Caviar platform;
– Order processing, including order fulfillment, validation, shipping and invoicing;
– Resolution of cancellations or problems of any nature relating to an order, goods or services purchased;
– Returning non-conforming products;
– Refunding the value of products as provided by law;
– Providing support services, including providing answers to your questions regarding your orders or Danube Caviar goods and services. The processing of your data for these purposes is in most cases necessary for the conclusion and performance of a contract between Danube Caviar and you. In addition, certain processing for these purposes is required by applicable legislation, including tax and accounting legislation.

Improving our services

We always want to provide you with the best online shopping experience. To do this, we may collect and use certain information about your shopping behavior, we may invite you to complete satisfaction questionnaires following the completion of an order, or we may conduct, directly or with the help of partners, market research and studies. We base these activities on our legitimate business interests, always taking care that your fundamental rights and freedoms are not affected.

For marketing

We want to keep you informed about the best offers for the products/services that interest you. For this purpose, we can send you any type of message (such as: e-mail/SMS/phone/SMS/mobile push/webpush/etc.) containing general and thematic information, information about products similar or complementary to the ones you have purchased, information about offers or promotions, information about products added in the “Account/My Account” or “Account/Favorites” section or you have shown interest in purchasing them, as well as other commercial communications such as market research 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 about your shopping behavior (e.g., products viewed/added to wishlist/purchased) to create a profile of you. We always make sure that this processing is carried out with respect for your rights and freedoms, and that the decisions taken on the basis of this processing do not have legal effects on you and do not affect you in a similar way to a significant extent. Also, by subscribing to our text marketing channel you give your consent to be called in order to improve our services and you agree to receive special offers that may be communicated over the phone. In case you no longer wish to be part of our text marketing channel you can mention this to our consultant during the phone call or you can unsubscribe by replying with STOP , END , CANCEL , UNSUBSCRIBE OR QUIT to one of the text marketing messages you receive. 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:

• Access the unsubscribe link displayed in the messages you receive from us;

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 steps to ensure that your fundamental rights and freedoms are not affected. However, you may at any time request us, by the means described above, to stop the processing of your personal data for marketing purposes and we will comply with your request.

In defense of our legitimate interests

There may be situations in which we will use or disclose information to protect our rights and business. These may include: measures to protect the website and users of the Danube Caviar platform from 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 business, and we are committed to ensuring that any measures we take strike 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 security of goods and valuables provided for by the applicable legislation in this matter.

How long we keep your personal data

As a general rule, we will store your personal data as long as you have an account on the Danube Caviar platform. You may at any time request us to delete certain information or to close your account, and we will comply with such requests, subject to the retention of certain information even after the account is closed, where required by applicable law or our legitimate interests.

To whom we transmit your personal data

Where appropriate, we may transmit or provide access to certain of your personal data to the following categories of recipients:

• courier service providers;
• payment/banking service providers;
• marketing / telemarketing service providers;
• market research service providers;
• insurance companies;
• IT service providers;
• other companies with which we can develop joint programs to offer our goods and services on the market.

If we have a legal obligation to do so, or if necessary to protect a legitimate interest, we may also disclose certain personal data to public authorities. We ensure that the access to your data by third parties, legal entities governed by private law, is carried out in accordance with the legal provisions on data protection and confidentiality of information, on the basis of contracts concluded with them.

To which countries we transfer your personal data

Currently, we store and process your personal data in Romania and the European Union. However, we may transfer some of your personal data to entities located in the United States of America. We will always take steps to ensure that any international transfer of personal data is carefully managed in order to protect your rights and interests. Transfers to service providers and other third parties will always be protected by contractual undertakings and, where appropriate, 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. 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 respect of these transfers.

How we protect the security of your personal data

We are committed to ensuring the security of personal data by implementing appropriate technical and organizational measures according to industry standards. Your personal data is transmitted using state-of-the-art encryption algorithms and stored on secure servers, while ensuring data redundancy. For payments we use the services of payment processors. We do not store card data online on our servers. Any payment information is encrypted using HTTPS technology with TSL 1.2 encryption. Despite the measures taken to protect your personal data, please note that the transmission of information over the Internet in general, or over other public networks, is not completely secure, and there is a risk that the data may be seen and used by unauthorized third parties. We cannot be responsible for such vulnerabilities in systems not under our control.

What rights do you have

The General Data Protection Regulation gives you a number of rights in relation to your personal data. You can request access to your data, correct any mistakes in our files and/or object to the processing of your personal data. You may also exercise your right to complain to the competent supervisory authority or to go to court. Where applicable, you may also have the right to request erasure of your personal data, the right to restriction of the processing of your data and the right to data portability. More information about each of these rights can be obtained by consulting the table below. To exercise your rights, you can contact us using the contact details set out above. Please note the following if you wish to exercise these rights:

Identity.

We take the confidentiality of all Records containing personal data seriously. For this reason, please send us your requests concerning such Records using the e-mail address of your Danube Caviar account. Otherwise, we reserve the right to verify your identity by requesting additional information to confirm your identity.

Honoraria.

We will not charge a fee for exercising any of your rights in relation to your personal data, unless your request for access to information is unfounded, repetitive or excessive, in which case we will charge a reasonable fee in such circumstances. We will inform you of any fees charged before we resolve your request.

Response time.

We aim to respond to any valid requests within a maximum of one month, unless this is particularly complicated or if you have made multiple requests, in which case we will respond within a maximum of two months. We will let you know if we need more than one month. We may ask you if you can tell us exactly what you want to receive or what you are worried about. This will help us to act faster and shorten the response time to your request.

Third party rights.

We must not comply with a request if it would adversely affect the rights and freedoms of other data subjects.

Rights concerned

Access

You can ask us:
– to confirm whether we are processing your personal data;
– to provide you with a copy of that data;
– to provide you with other information about your personal data, such as what data we hold, 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 complain, where we obtained your data, To the extent the information has not already been provided to you in this notice.

Correction

You may ask us to rectify or complete inaccurate or incomplete personal data. We may attempt to verify the accuracy of the data before rectifying it.

Deleting data

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 (where the processing of the data is based on consent); or
  – you are exercising a legal right to object; or
  – they have been processed unlawfully; or
  – we have a legal obligation to do so.

We are not obliged to comply with your request to delete your personal data if the processing of your personal data is necessary:

• for compliance with a legal obligation; or
• for the establishment, exercise or defense of a right in court.

Restricting data processing

You may ask us to restrict the processing of personal data, but only if:

• their accuracy is contested (see the rectification section), to enable us to verify their accuracy; or
  – the processing is unlawful, 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 the verification of 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 defend a legal right in court; or
  – to protect the rights of Danube Caviar or another natural or legal person.

Data portability

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:

• processing is based on your consent or on the conclusion or performance of a contract with you; and
  – processing is carried out by automated means.

Opposition

You may object at any time, on grounds relating 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 override this interest. You may also object at any time to the processing of your data for direct marketing purposes (including profiling), without giving any reason, in which case we will cease such processing as soon as possible.

Automatic decision making

You can ask not to be subject to a decision based solely on automated processing, but only when that decision:

• produces legal effects in relation to you; or
  – affects you in another similar way and to a significant extent.
  This right does not apply if the decision reached as a result of automated decision-making:
• 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.

Complaints

You have the right to lodge a complaint to the supervisory authority about the processing of your personal data. In Romania, the contact details of the data protection supervisory authority are as follows: National Supervisory Authority for the Processing of Personal Data B-dul G-ral. Gheorghe Magheru nr. 28-30, Sector 1, postal code 010336, Bucharest, Romania Telephone: +40.318.059.211 or +40.318.059.212; E-mail: [email protected] Without prejudice to your right to contact the supervisory authority at any time, please contact us in advance, and we promise that we will make every effort to resolve any problem amicably. We remind you that you can contact the Danube Caviar Data Protection Officer at any time by sending your request in any of the following ways: by e-mail to: [email protected] or
by phone call to 0722.204.144

What are cookies?

Cookies are pieces of text placed on your computer by the websites you visit. This automatic data storage technology is very widespread and is used to collect information such as browser type and operating system, source page, domain name from which the visitor connected to the Danube Caviar website, etc., in order to understand how visitors use this website. “Cookies help us to tailor the content of the website to your needs.

How and why do we use cookies?

We use cookies to improve the usability and functionality of our website and to better understand how visitors use it. Storing cookies on your computer provides us with an easy and convenient way to personalize or enhance your experience on our sites and to make your next visit more enjoyable. We do not use cookies to collect personal information, such as your name, however, we may link the information contained in a cookie to your personal information collected through other means (e.g., contact forms).

How can I change my cookie settings?

You can at any time change your cookie settings (e.g. to be alerted when cookies are sent to your computer) from your internet browser settings. If you do so, please be aware that you may not be able to use all features of the site that require registration or information collection. We reserve the right to make any changes and corrections to this document. Please check this page from time to time to review this information.