Privacy policy
Last updated: October 2020
I. General information
The confidentiality of your personal data is one of the main concerns of Enetix Software SRL (headquartered in Miercurea Ciuc, Str. Szek nr. 7/A, jud. Harghita, Romania, registration number J19/505/2006, VAT number RO18765987), as data controller.
This document is intended to inform you about the processing of your personal data while using the https://app.gelior.com application (“Platform”), in accordance with Regulation 679/2016 of the European Parliament and of the Council, about the processing of personal data and the free movement of such data (“GDPR”).
II. Categories of personal data processed
II.1. If you are a customer of the Platform, Enetix Software SRL will process your personal data, such as name and surname, telephone, e-mail address, billing address, delivery address, data on how you use the Platform (for example your behavior/preferences/habits), as well as any other data that you provide directly in the context of the creation of the user account, in the context of placing an order through the Platform or in any other way that results from the use of the Platform.
If you choose to create a user account only before completing the order of a product available on the Platform, you will be asked for your e-mail address based on which an account will be created automatically. If you do not finalize the order, the e-mail address and other data provided will not be stored by Enetix Software SRL, and the account created will be deleted automatically.
II.2. If you are a visitor to the Platform, Enetix Software SRL will process your personal data that you provide directly in the context of using the Platform, such as the data that you provide in the contact/questions/complaints section, to the extent that you contact us in this way.
III. Purposes and grounds for data processing
III.1. If you are a customer of the Platform, Enetix Software SRL processes your personal data as follows:
– to carry out the contractual relationship between you and Enetix Software SRL, for taking over, validating, shipping and invoicing an order placed on the Platform, informing you on the status of the order, organizing the return of ordered products, etc.
Rationale: The processing of your data for this purpose is based on the contract concluded between you and Enetix Software SRL, defined in the Terms and Conditions. The provision of your personal data is necessary for the execution of this contract. Refusal to provide data may result in the impossibility of conducting contractual relations between you and Enetix Software SRL.
– for fulfilling the legal obligations incumbent on Enetix Software SRL in the context of the services provided through the Platform, including the obligations in fiscal matters, as well as in archiving.
Rationale: The processing of your data for this purpose is necessary on the basis of legal obligations. Providing your data for this purpose is necessary. The refusal to provide the data may result in the impossibility of Enetix Software SRL to comply with its legal obligations and therefore in the impossibility of offering you the services through the Platform.
– for marketing activities, respectively for the transmission, through the means of remote communication (e-mail, SMS) of commercial communications regarding the products and services offered by Enetix Software SRL through the Platform.
Rationale: The processing of your data for this purpose is based on your consent, if you choose to provide it.
You can give your consent to the processing of data for this purpose by checking the appropriate box at the time of account creation, or after account creation, in the My Account Information section. To unsubscribe from receiving such commercial communications you can use the option at the end of each email / SMS containing commercial communications. Additionally, you can unsubscribe by accessing the My Account Information section.
Providing your data for this purpose is voluntary. Refusal to provide consent for the processing of your data for this purpose will not have negative consequences for you.
– in order to perform various analyzes, reports on the operation of the Platform, the creation of consumer preference profiles, mainly in order to improve the experience offered on the Platform.
Rationale: The processing of your data for this purpose is based on the legitimate interest of Enetix Software SRL to permanently improve the customer experience on the Platform. Providing your data for this purpose is voluntary. Refusal to provide data for this purpose will not have negative consequences for you.
III.2. If you are a visitor of the Platform, Enetix Software SRL processes your personal data as follows:
– for marketing activities, respectively for the transmission, through the means of remote communication (e-mail, SMS), of commercial communications regarding the products and services offered by Enetix Software SRL, through the Platform.
Rationale: The processing of your data for this purpose is based on your consent, if you choose to provide it.
You can express your consent to the processing of data for this purpose by filling in and checking the appropriate box on the newsletter subscription form available on the Platform. To unsubscribe from receiving such commercial communications you can use the option at the end of each email / SMS containing commercial communications.
Providing your data for this purpose is voluntary. Refusal to provide consent for the processing of your data for this purpose will not have negative consequences for you.
– to resolve complaints, grievances and to monitor traffic and improve your experience on the Platform.
Rationale: The processing of your data for this purpose is based on the legitimate interest of Enetix Software SRL to ensure the proper functioning of the Platform, as well as to permanently improve the experience of visitors to the Platform, including by resolving various comments, questions or complaints.
Providing your data for this purpose is voluntary. Refusal to provide data for this purpose will not have negative consequences for you.
IV. The length of time we process your data
In principle, Enetix Software SRL will process your personal data as long as necessary to achieve the processing purposes mentioned above.
If you are a customer, we will process your data throughout the contractual relationship and subsequently in accordance with the legal obligations incumbent on Enetix Software SRL (e.g. in the case of financial-accounting supporting documents for which the retention period provided by law is 10 years from the date of the end of the financial year in which they were drawn up).
If you are a customer and exercise the option to delete the user account, by pressing the Delete account button in the My Account Information section, Enetix Software SRL will interpret this action as your option to unsubscribe from receiving commercial communications through which we keep you informed about the products and services offered through the Platform. In this regard, if you choose to delete your user account, we will no longer send you such emails and / or text messages. However, we would like to inform you that deleting your account will not automatically have the effect of deleting your personal data. If you no longer wish to have your personal data processed or if you wish to have your data deleted, you can exercise the rights detailed in point VII below. If you request the deletion of your account, but there is an active and unfulfilled order tied to that account, the account deletion request can only be registered after the delivery of the products and the completion of the last active order.
If you withdraw your consent for the processing of data for marketing purposes, Enetix Software SRL will stop the processing of your personal data for this purpose, without affecting the processing carried out by Enetix Software SRL based on your consent before its withdrawal.
V. Disclosure of personal data
For the purpose of processing, Enetix Software SRL may disclose your data to partners, third parties or entities that support Enetix Software SRL in carrying out the activity through the Platform (e.g. courier companies, IT service providers), or to the authorities central/local public, in the following exemplary cases listed:
– for the administration of the Platform;
– in situations where this communication would be necessary for the awarding of prizes or other facilities to the persons concerned, obtained as a result of their participation in various promotional campaigns organized by Enetix Software SRL through the Platform;
– to maintain, personalize and improve the Platform and the services provided through it;
– for data analysis, testing and research, monitoring usage and activity trends, developing security features and user authentication;
– for the transmission of commercial marketing communications, under the conditions and limits provided by law;
– when the disclosure of personal data is provided by law.
VI. Transfer of personal data
Personal data provided to Enetix Software SRL may be transferred outside of Romania and/or the European Union.
VII. Your rights
Under the conditions provided by the legislation on the processing of personal data, you enjoy the following rights:
– the right to information, respectively the right to receive details regarding the processing activities performed by Enetix Software SRL, as described in this document;
– the right to access data, respectively the right to obtain confirmation from Enetix Software SRL regarding the processing of personal data, as well as details on the processing activities such as the way the data is processed, the purpose for which the processing is done, the recipients or categories of data recipients, etc;
– the right to rectification, respectively the right to obtain the correction, without justified delays, by Enetix Software SRL of inaccurate/unjustified personal data, as well as the completion of incomplete data; rectification/completion will be communicated to each recipient to whom the data have been transmitted, unless this proves impossible or involves disproportionate effort.
– the right to delete data, without undue delay, (“right to be forgotten"), applies in one of the following situations:
they are no longer necessary for the purposes for which they were collected or processed;
if the consent is withdrawn and there is no other legal basis for the processing;
if the data subject objects to the processing and there are no legitimate reasons prevailing;
if personal data have been processed illegally;
if personal data must be deleted in order to comply with a legal obligation;
personal data have been collected in connection with the provision of information society services under Union or national law under the control of the controller.
It is possible that, following the request to delete the data, Enetix Software SRL to anonymize this data (thus depriving it of personal character) and to continue in these conditions the processing for statistical purposes;
– the right to restrict processing to the extent that:
the person disputes the accuracy of the data, for a period that allows us to verify the correctness of the data;
the processing is illegal and the data subject opposes the deletion of personal data, instead requesting the restriction of their use;
the controller no longer needs personal data for the purpose of processing, but the data subject requests them for the establishment, exercise or defense of a right in court; or
the data subject has objected to the processing (other than direct marketing), for the period of time in which it is verified whether the legitimate rights of the controller prevail over those of the data subject.
the right to data portability, namely (i) the right to receive personal data in a structured, commonly used and easy-to-read format, and (ii) the right to have such data transmitted by Enetix Software SRL to another data operator, insofar as the conditions provided by law are met;
– the right to object – in respect of processing activities may be exercised by submitting a request as indicated below:
at any time, for reasons related to the particular situation of the data subject, that the data concerning him shall be processed in the legitimate interest of Enetix Software SRL or in the public interest, unless Enetix Software SRL can demonstrate that has legitimate and compelling reasons justifying the processing and prevailing over the interests, rights and freedoms of data subjects or that the purpose is to establish, exercise or defend a right in court;
at any time, free of charge and without any justification, that the data concerning it be processed for the purpose of direct marketing.
– the right not to be subject to an automatic individual decision, i.e. the right not to be the subject of a decision taken solely on the basis of automatic processing activities, including profiling, which produces legal effects concerning the data subject or similarly affects him to a significant extent;
– the right to contact the National Authority for the Processing of Personal Data or the competent courts, to the extent deemed necessary.
VIII. Information on security measures
Enetix Software SRL has invested in the adoption of technical and organizational data processing measures, updated in accordance with GDPR requirements, in order to protect your personal data against any actions of unauthorized access, misuse or disclosure, unauthorized modification, destruction or accidental loss. All employees and collaborators of Enetix Software SRL, as well as any third parties acting on behalf of and on Enetix Software SRL are obliged to respect the confidentiality of your information, in accordance with the provisions of this Policy.
IX. Data Protection Officer (DPO)
Visitors of the Platform have the opportunity to communicate at any time with the Data Protection Officer directly, for any subject related to this Policy, using the contact details below:
Enetix Software SRL (postal address: Miercurea Ciuc, Str. Szek nr. 7/A, jud. Harghita, Romania).
For any questions regarding the way personal data is processed and to exercise your rights mentioned above, please send an email to: office@gelior.com.