PERSONAL DATA PROCESSING POLICY
According to the changes and amendments made by the General Data Protection Regulation (EU) 2016/679 (“GDPR”).we have decided to inform you through this Personal Data Processing Policy (“Data Processing Policy” or “Policy”) about:
Who are we?
What is personal data?
What data do we process about you?
How do we collect and process your data?
How long do we keep your data?
Who we share your data with?
When do we transfer your data outside the space of the European Union or EEA?
What security measures do we take to protect your data?
What are your rights and choices regarding the data we process?
We will take the same approach every time you visit us or shop on our website, or if you use the ENAIZOBOLS S.R.L. mobile app.
This Data Processing Policy may be modified or updated at any time by ENAIZOBOLS S.R.L.,when we consider that certain changes occur in the activities through which we process your data. We will publish on , any such changes and inform you accordingly by e-mail.
WHO ARE WE?
ENAIZOBOLS S.R.L. , with registered office in Bucharest, Sector 2, Șos. Colentina nr. 16, Bl. A5, ap. B44, Sector 2, registered with the Trade Register under number CUI 43355090 and registration number at the Trade Register Office J40/15888/2020 (“ENAIZOBOLS S.R.L.”). or “Operator” or “We” or “Us”), is the operator of your data and the entity that provides you, through the Power JAN application, with power banks at various locations in your city.
You can contact us anytime at:
Address. Bucharest, Sector 2, Șos. Colentina nr. 16, Bl. A5, ap. B44, Sector 2 Phone: +40 745 150 342
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ENAIZOBOLS S.R.L. has appointed a Personal Data Protection Representative. If you have any questions or concerns regarding this Policy, the way ENAIZOBOLS S.R.L. processes your data or your rights, you can contact us at the dedicated e-mail address firstname.lastname@example.org or at the postal address Mun. Bucharest, Sector 2, Șos. Colentina nr. 16, Bl. A5, ap. B44, Sector 2.
WHAT DATA DO WE PROCESS ABOUT YOU?
What is personal data?
Personal data means any data or information that helps us to identify you directly (e.g. your name, surname) or indirectly (e.g. based on the profile we create to send you personalised offers). Some information is less obvious (such as your shopping preferences and habits, the IP of your device), but associated with your person, helps us to identify you and thus falls under the notion of “personal data”.
ENAIZOBOLS S.R.L.’s policy is to collect and process only the data we need to provide you with the most enjoyable experience when browsing/shopping on the Power JAN app.In general, we process the following data about you:
Name; E-mail address;
General geo-location of the device from which you are browsing/logging into your customer account; Information about products and services purchased;
Your use of and activities on the site;
To be more specific, in the table below we have listed the personal data (“Data” or “Personal Data”) that we collect directly from you,that result from interacting with you and that we or our partners track in order to provide you with the products/services you have ordered or to provide you with various personalised offers,when browsing/shopping on the website or when using various devices (tablet or mobile phone).
Data about minors.
ENAIZOBOLS S.R.L. does not allow the processing of personal data of customers under the age of 18.
In the process of creating an account or placing an order on the app, customers must confirm that they are 18 years of age or older.
HOW DO WE PROCESS YOUR DATA?
ENAIZOBOLS S.R.L. collects and processes your data for the purpose of fulfilling orders you place, improving your experiences in the Power JAN App, providing assistance and support when you use the Power JAN App/customer account, or creating a customer profile to send you personalized offers (direct marketing).
We have listed in the table below how we process your data, the purposes and the legal basis (legal basis) of the activities through which we process your data.
Why do we collect and process your data?
What data do we collect and how do we process it?
What is the legal basis for data processing?
Data you provide us directly
Creating your customer account
• • •
We can create a customer account for you on the Power JAN App only if you provide us with the following personal data, either (a) in the process of your request to open a new customer account or (b) following the placement of an order, for the first time, on the Power JAN App (and we, on this occasion, activate a customer account for you in order to be able to honour your order):
name; e-mail, and
Alternatively, you can create a customer account by logging into your Facebook, Google or Apple account, using your email orphone number and password from that social network.
Login to your customer account
We offer you the option to log into your customer account by connecting to your existing Facebook, Google or Apple account, (social media login). To sign in, you are redirected to your social network page (Facebook, Google or Apple), where you can log in with your user details. In this way, your Facebook, Google, or Apple profile is linked to your customer account in the Power JAN App.After registration, Facebook Inc., Google Inc. and Apple Inc. automatically send us the following information:
The numeric ID for the social network;
first and last name; Facebook, Google, or Apple username;
your user account has been verified (e.g. “confirmed”).
In addition, the operator of the social networking service receives information about the linking of that account to our page.We store and use this data submitted by Facebook, Google or Apple to identify you as an authorized customer and offer you our services in the Power JAN App.
Purchasing in the Power JAN App
You can only place an order if you have activated a customer account, place some products in your shopping cart and then place an order. You can make purchases on the Power JAN app to which you log in from your ENAIZOBOLS S.R.L. account, after having agreed to the Terms and Conditions of the App.
– Each time you submit an order we will collect and process the following data:
name and phone number
In order to be able to process your orders, hand over the products at the pick-up points, fulfill our warranty obligations associated with the products.
Payment of purchases/ refund of payment in case of product return/ cancellation of order
The details of the card you use for 3D Secure payment of purchases in the Power JAN App will not be accessible or stored by ENAIZOBOLS S.R.L., but only by the entity authorizing the transaction or by another entity authorized to provide card identification data storage services, whose identity you will be informed of, prior to the actual entry of the details of the card you use for online payment.
To ensure the necessary processing support by our partners authorized to mediate payment for products ordered by you.
involves redirecting the customer at the time of payment to a secure page where each cardholder is registered by assigning an authorisation code for each online transaction. Cards accepted for payment are those issued under the VISA (Classic and Electron) and MASTERCARD (including Maestro, if they have a CVV/CV2 code)].
-ENAIZOBOLS S.R.L. processes only the following data which it sends to the online payment/transaction authorization partner:
first name, surname;
Transaction initiation date,
payment status (payment completed/failed);
– In case of returns/order cancellation we collect and process:
Your IBAN and the bank where you opened your bank account,
in order to refund the money paid for returned products/services/cancelled orders.
and – To be able to provide you with support on
Execution of the contract
your customer account / orders you place on the site, we will identify you by confirmation:
your e-mail address and phone number;
– We may process, with your prior consent, your voice from recordings of telephone calls with you in order to respond to your requests for assistance.
– We will also process the same data to process your complaints.
Fulfillment of our responsibilities/activities during the contract period
ENAIZOBOLS S.R.L. grants and allocates various discounts and benefits related to our loyalty actions (in the form of vouchers, discounts, etc.) You can view in your customer account the vouchers you have benefited from at a given time.
In order to carry out our loyalty actions and offer commercial discounts in relation to you
Promotional campaigns, contests, promotions or lotteries
For online contests run on the Power JAN app, we collect your email address. We also organize contests on the official Facebook/Instagram page of ENAIZOBOLS S.R.L. , where we collect, depending on the campaign, the following data necessary for your participation in the contest, namely, winners random.org:
a first and last name;
For the purpose of your participation in competitions organised by ENAIZOBOLS S.R.L. and the awarding of respective prizes.
If you are a winner, we will mention your name and surname on the official Facebook and/or Instagram page of ENAIZOBOLS S.R.L.
Data we collect automatically
Creating customer profiles for direct marketing purposes
Based on your interactions and behaviour in the mobile app, we collect and process through our partners your data to create your customer profile in order to send you
For profiling purposes we process the following data:
your name, surname, email and/or mailing address and mobile phone number;
o your history of interactions with us in the mobile app, respectively:
– what products/services have you added to your basket
offers (“offers by
– what products/services have been delivered to you, have been paid for;
o your preferences when shopping on the site (what products/services you bought, on what date/time, how you paid);
o online identifiers obtained from the device you use when browsing the mobile app;
For profiling and sending personalized offers through communication channels to which you consent (sms, email, push-up notifications).
More details on how we do profiling for direct marketing purposes can be found below under ” Profile”. You have the right to object to profiling at any time.
When you log into your customer account, or use our mobile app, we also collect data from your phone, tablet or other device (“device”) with cookies, information by which we can identify you online (“online identifiers”), which we use to profile you for direct marketing purposes:
o IP address;
o Internet browser
browser you are using and the version
-of shopping and subsequently deleted, ordered/purchased them;
which orders you initiated and subsequently completed or cancelled;
of your device;
o Duration of visit/activity
on the application;
o General location of the device (if geo-location is enabled) from which you are connecting to the app.
[Please note that most devices give you the option to disable geo-location services right from your device settings]
Online behavioural advertising
BBased on your browsing and behaviour in the mobile application, tracked by cookies, we will provide you with online advertisements for some of our products/services that may be of interest to you. Based on information about your browsing in the mobile app, we will match you to an interest group with other similar customers in terms of browsing behaviour and thus deliver advertisements (banners) based on those interests.
For cookies that monitor your behaviour on the site.
If you do not wish to participate in cookie tracking for the purpose of delivering online advertisements (banners) based on your interests, you can refuse to have a cookie set for this purpose by setting your browser to generally disable automatic cookie setting. You can also disable cookies for advertising services of a service provider.
For example, a “books” interest profile can be inferred from your data by evaluating the products you have visited in the mobile app and in this way a cookie is placed on your device to match you as someone interested in the “books” category, and you will then receive some specially personalized advertising messages from the “books” category.
browser (e.g. Google) by setting your browser in such a way that the cookies of that domain are blocked. You can do this very easily from the following page www.youronlinechoices.com/ro/optiunile- my
Opting out of online behavioural advertising will not stop the display of general ads that are not tailored to your interests.
Offers based on customised audiences (on customer lists)
With your consent, we will use your email address and mobile phone number to create an encrypted list of customers (“hash data”), and then use the encrypted data from this list to match your data (and other customers in an interest group) with data from people on Facebook/Instagram, to send personalised offers via this channel to your Facebook/Instagram account via targeted ads.
Facebook/Instagram encodes the hash data, uploads it to the social platform and thus forms an audience,using this hashed data exclusively for linking to your Facebook/Instagram account data, without distributing this data to third parties (or, other commercial advertisers) and will be automatically deleted by Facebook/Instagram immediately after linking.
For sending personalised offers on Facebook (using the personalised audience service based on customer lists
Mobile App website maintenance and security
We use the following online identifiers to maintain and secure the Online Store website:
o IP address;
you are using and the version of the operating system of the device you are connecting with;
o HHTP/HTTPS protocol data;
o Location of the device (if geo-location is enabled) from which you are connecting to the mobile app.
Specifically, we process your data for:
– Ensure the proper functioning of the app, respectively:
o display the content of the mobile app correctly;
o retain your login details (when you ask us to);
o improve the mobile application;
o setting the device from which you log in/login to the requirements of the mobile app.
Implementation, parameterization and maintenance of security measures of the Power JAN mobile application.
– to ensure the security of the website and to ensure that we protect you against fraud or any IT security breach in relation to the Power JAN App.
-identification and remediation of flaws prevents the use of our application or your customer account.
Audit and reports
We process your data for the annual financial audit as well as for filing tax and accounting returns with the tax authorities.
Cerințe prevederi legale
In order to comply with the legal obligations imposed by the applicable tax and accounting provisions
Defending legal rights
When defending our rights in court for the recovery of sums due, or when protecting our interests against unjustified claims/claims, we will process your data necessary for the formulation of specific statements of defence, written conclusions, requests and documents.
The exercise of any defences/rights before the courts, or public/ supervisory authorities or institutions.
Proceedings and investigations by authorities and/or judicial authorities
Exceptionally and in accordance with the law, we will provide the competent authorities and institutions, in the framework of procedures/investigations
formal or other steps provided for by law, in accordance with the procedure laid down by law, the following data: name, surname, address, e-mail, telephone. ENAIZOBOLS S.R.L. will document any such steps.
In order to comply with the specific legal obligations imposed by the relevant legal provisions
on protection against fraud, money laundering and terrorism.
Data we collect from other sources
Browsing on social media
If you like/follow our page
Delivering personalized offers on Facebook (using the personalized audience service based on customer lists)
DIRECT MARKETING PROFILING
When we send you personalized offers through direct marketing channels (sms, e-mail, push-up notifications) we may use certain “profiling techniques” i.e. a way of automatically processing your data consisting in particular in the analysis and interpretation of your personal data necessary to evaluate or predict certain aspects related to your preferences, interests when shopping in the Power JAN App. For profiling purposes, ENAIZOBOLS S.R.L. does not process sensitive data relating to sexual orientation, religious beliefs or political affiliations.
Your personal shopping behavior and preferences are based on your history of visits and/or purchases in the Power JAN App, your use of the mobile app, your financial situation resulting from the purchases you make, and other personal interests you have provided to us that are common to other customers.
• • •
based on your website browsing behaviour, products viewed, products added to cart; based on demographics: age, city;
based on purchase history and monetary value.
We collect your data when we do profiling from sources such as our website http://powerjan.md/ and advertising service providers we work with.
We use profiling to communicate and present you with personalised promotional offers in a way that is relevant and useful to you.
We may offer you the possibility to change your marketing preferences directly in your customer account on http://powerjan.md/ at any time after you have registered as an ENAIZOBOLS S.R.L. customer by indicating this option in your customer account.
You may object to profiling for direct marketing purposes on any of the communication channels to which you have previously consented by withdrawing your consent to unsubscribe from a particular communication channel to which you have previously opted in. For more details, see the “Your Rights and Choices” section below.
HOW LONG DO WE KEEP YOUR DATA?
ENAIZOBOLS S.R.L. processes your data for the period necessary to fulfil the purposes for which it was collected and in accordance with our personal data retention policies. In certain cases, some legal provisions may require or allow us to retain data for a longer period.
The data storage period depends mainly on the following:
for what period we need your data in order to provide you with the requested products and fulfil our obligations to you and for the purposes set out above in this Policy;
whether you have an open customer account on the Mobile App. In this case we will retain your data for as long as this customer account is active, but no longer than 5 (five) years from the date of your last account login or last order in the Power JAN App (without account login); we will notify you before closing your customer account and deleting all data associated with this customer account;
if you have consented to the processing of your data for a longer period, we will retain your data for this period unless you withdraw your consent in the meantime;
legal or contractual obligations require us to keep your data for a certain period of time (e.g. periods prescribed by law for the defence of our legal rights).
Specifically, ENAIZOBOLS S.R.L. creates your customer profile as follows:
We will only keep your data for as long as you hold a customer account and/or continue to shop in the Power JAN App. If you deactivate your customer account in the Power JAN App and expressly request us to delete it completely, the data associated with your customer account will be deleted or anonymised so that you can no longer be identified in our data record systems, unless we are obliged to retain your data for a longer period of time based on law or our legitimate interest.
In this way, we will ensure that you have full control over your personal data. We will collect and process your data again if you provide it to us again in the mobile app.
For the purposes for which you have given us consent to process your data, highlighted in the table above, we will process your data for that purpose until you withdraw your consent to the processing for that purpose, unless we are obliged to keep that data for a longer period by law, for reporting to public authorities, or to defend our rights in court.
We inform you that we rely on your consent when we process your data to send you:
personalised offers based on online behavioural advertising;
personalised offers based on profiling that we make for direct marketing purposes, through sms, email and push-up notifications communication channels;
offers based on personalised audiences (on customer lists) in Facebook/Instagram.
*Consent – means your free, specific and informed consent by which you accept without doubt that your data will be processed by Us for the purpose for which you give your consent. In the Power JAN App you can express your consent by ticking the relevant box associated with the purpose and means of processing specified in this Information Notice.
WHO DO WE SHARE YOUR DATA WITH?
Your personal data may be shared with and processed by our trusted partners to provide you with products
In order to provide you with the products ordered in the Power JAN App, we will share your data with our trusted partners. We carefully select partners and suppliers who perform operations on our behalf in support of our business. We share with them only the personal data necessary to perform the specific activities we entrust to them.
When we outsource certain activities to our trusted partners we make every reasonable effort to check in advance that they ensure the protection of your data through strict data security measures and we will enter into data processing contracts with each of them.
Specifically, we share some data with third parties (our suppliers and partners) to perform the functions and services necessary to operate the Online Store activities, such as:
Transmission of data to public authorities and institutions or legal authorities
We may send some of your personal data to the relevant public authorities or institutions when required to do so by law (e.g. investigating fraud; preventing money laundering; filing returns, financial statements with tax authorities, etc.), or we may send this data to the courts when defending ourselves in court, or before other public authorities.
Access for auditors and consultants
If we decide in the future to dispose of the shares or the business of ENAIZOBOLS S.R.L. we will provide access to or pass on to the auditors and consultants of the potential buyer(s) the data of our clients to carry out the audit necessary for the acquisition of the shares/business. For this purpose, we will ensure that any potential buyer will follow and implement the necessary security measures for the protection of your data, and the parties will sign a data processing agreement in advance for the purpose of the transaction.
WHEN DO WE TRANSFER YOUR DATA OUTSIDE THE EU OR SEE?
As a rule, your data is not stored in a country outside the European Union or the European Economic Area (“EEA”).
If we transfer your data to other partners/suppliers of ENAIZOBOLS S.R.L. located in countries that do not ensure an adequate level of protection of the data transmitted, we undertake to take all necessary measures to ensure that those partners/suppliers comply with the terms and conditions set out in this Policy. These measures may further include the implementation of data protection standards (e.g. ISO 27001), standard contractual clauses adopted by the European Union Commission, as well as systems of direct control of these mechanisms.
HOW DO WE ENSURE THE SECURITY OF YOUR DATA?
ENAIZOBOLS S.R.L. ensures the necessary technical and organisational measures for the secure collection, processing and storage of data, including against unauthorised access, unauthorised use of data, or destruction, loss or alteration of data. We are committed to keeping your personal data secure and take all reasonable safeguards to do so.
We implement systematic processes for training the persons responsible for IT security and for monitoring and auditing the security of IT systems and infrastructures according to ENAIZOBOLS S.R.L. internal policies. .
In addition, we make a reasonable effort to ensure (including through our contracts with them) that our trusted partners also manage appropriate technical and organisational measures for processing the data we share with them.
WHAT RIGHTS AND OPTIONS DO YOU HAVE REGARDING YOUR DATA?
We want to ensure that at all times you have full control over your data and that you can effectively use your rights and options under the GDPR.
To ensure that you have effective control over your data, we inform you that you have the following possibilities based on the technologies available to you:
you can manage from your client account the direct access, rectification or deletion of data available in your client account in the Power JAN Application;
social media platforms and search engines (e.g. Google or Facebook) give you the possibility to manage various options on how you choose to have your data processed.
In addition to these options, the GDPR gives you, as a data subject, the rights described below. Before we can grant any request for your rights, we will ensure that you are the data subject in respect of whom you choose to exercise these rights, and for this purpose we may ask you for certain information/data
to verify your identity, or we may ask for more details about your request. The correspondence we have with you we may keep to ensure that we keep a record of requests and responses to your rights.
The right to be informed. You have the right to receive clear, transparent, understandable and easily accessible information about how we process your data, including details of your rights as a data subject. This information about the data, the purpose and how we process your data is also included in this Policy.
Right of access to data. You have the right to access the data we process about you, without charging any fee for the first time you provide the data. If you need copies of data already provided, we may charge a reasonable fee taking into account the administrative costs of providing the data. We will have the right to refuse excessive or repeated and unjustified requests.
The right to rectify data. If you identify that your data that we are processing is incorrect, incomplete or inaccurate: you can send us a request for rectification to the e-mail address email@example.com
The right to object to direct marketing (including profiling for direct marketing purposes). You can always object and unsubscribe to our direct marketing communications at any time. You can do this easily by clicking on the “unsubscribe” link in any email we send to you or from your account in the “Account Settings” section.
To exercise your right of access, you can send us your request by:
personalised offers based on profiling through the same channels through which we communicate these offers to you.
personalised offers based on profiling through the same channels through which we communicate these offers to you.
offers, i.e. email, sms or push-up notifications.
Withdrawal of consent (by unsubscribing or written request) does not affect the lawfulness of processing based on consent prior to withdrawal.
The right to object to processing based on legitimate interest. You may object at any time to any processing of data where such processing is based on our legitimate interest. See the section “What is the legal basis for data processing?” in the table above to identify when our processing is based on our legitimate interest.You can exercise this right in writing by sending a written request to the e-mail address: firstname.lastname@example.org
Right to delete data (right to be forgotten). You have the right to ask us to delete your data in any of the following situations:
a) the personal data are no longer necessary for the purposes for which they were previously processed;
b) you withdraw your consent on the basis of which we have processed your data and there is no other legal basis on which we can base further processing;
c) you object to data processing when we process data for direct marketing purposes (including profiling for direct marketing purposes),
d) you object to the processing of your data based on our legitimate interest and we cannot demonstrate that we have legitimate grounds justifying the processing which override your interests, rights and freedoms;
e) personal data are processed unlawfully;
f) personal data must be deleted in order to comply with our legal obligations. This is not an absolute right. We may refuse your request to delete data if: (i) we are required to comply with legal obligations to retain the data; or (ii) if the data is necessary for us to establish, exercise or defend our rights in court. You can exercise this right in writing by sending a written request to the e-mail address
The right to restrict processing. You have the right to obtain from us the restriction of data processing in one of the situations described below.
(a) the accuracy of the data is disputed by you (the data subject), for a period that will allow us to verify the accuracy of the data;
(b) the data processing is unlawful and you (the data subject) object to the erasure of the data and request us to restrict the processing of this data;
(c) we no longer need your data, but they are requested by you (the data subject)
for the establishment, exercise or defence of legal claims;
(d)you (the data subject) object to the processing of the data based on our legitimate interests, on the basis of a check whether the legitimate interests of the controller outweigh those of the data subject (i.e. you).
You can exercise this right in writing by sending a written request to
Right of portability. Where we process your data on the basis of consent or contract performance, and automatically, you will have the right to request us to transfer your data: (a) to you or (ii) to another controller indicated by you. The second situation means that you have the option to request us to transfer the data associated with your customer account to another data controller (e.g. to a controller that manages another online shop website). Specifically, you will only be able to request the porting of personal data that you have actively provided to us directly (excluding any data derived or created/developed by XYZ Company, such as a profile of customer profile).You can exercise this right in writing by sending a written request to the e-mail address: email@example.com. We will send your requested data as specified here in a structured and reusable format (e.g. XML, JSON, CSV).
The right to complain to the supervisory authority. You have the right to lodge any complaints with the National Supervisory Authority for Personal Data Processing (“N.S.P.D.P.”) about the way we process your personal data.
Although, we hope that you will decide to talk to us first, before filing any complaints with A.N.S.P.D.C.P. The protection of your data is very important to us and we will take all necessary steps to resolve any issues regarding the control and security of your data. You can also address your questions to A.N.S.P.D.C.P.,
the data protection supervisory authority in Romania. You can find some guides and guidelines on your rights on the authority’s website http://www.dataprotection.ro/.
QUESTIONS AND REQUESTS ON DATA PROTECTION
ENAIZOBOLS S.R.L. is at your disposal for any questions, clarifications or any details you need regarding this Data Processing Policy.
You may also contact us for any suggestions or comments regarding this Policy or how we collect and use your data at the DPO contact details below.
ENAIZOBOLS S.R.L. has appointed a Data Protection Officer whom you can contact on any matter relating to the processing of personal data at the following contact details:
Data Protection Officer
Address: Str. Voinicului, Nr. 11, Sector 3, Bucharest Email: firstname.lastname@example.org