Privacy Policy

I. General Information

The confidentiality of your personal data is one of the main concerns of SC NAVROM DELTA SA, VAT ID RO11791202, Trade Register No. J36/196/1999 (hereinafter referred to as the WEBSITE OWNER), acting as data controller. This document is intended to inform you about the processing of your personal data in the context of your use of the website you are visiting.

II. Categories of Personal Data Processed

II.1. If you are a customer of the Site, the WEBSITE OWNER will process your personal data, such as your first and last name, telephone number, email address, billing address, delivery address, data concerning the manner in which you use the Site, for example your behaviour/preferences/habits in relation to the WEBSITE OWNER, as well as any other categories of data that you provide directly when creating a user account, when placing an order through the Site, or in any other manner resulting from your use of the Site. If you use your Facebook or Google account to create a user account on the Site, the WEBSITE OWNER will process the following public profile data displayed by those applications: username and email address. If you choose to create a user account only before completing an order for a product available on the Site, you will be asked to provide your email address, based on which an account will be created automatically. If you do not complete the order, the email address and the other data provided will not be stored by the WEBSITE OWNER, and the account created will be automatically deleted.

II.2. If you are a visitor to the Site, the WEBSITE OWNER will process the personal data that you provide directly in the context of using the Site, such as the data you provide in the contact/questions/complaints section, where you contact us in this manner.

III. Purposes and Legal Bases of Processing

III.1. If you are a customer of the Site, the WEBSITE OWNER processes your personal data as follows:

  • for the performance of the contractual relationship between you and the WEBSITE OWNER, namely for receiving, validating, dispatching and invoicing the order placed on the Site, informing you about the status of the order, arranging the return of ordered products, etc.

Legal basis: The processing of your data for this purpose is based on the contract concluded between you and the WEBSITE OWNER, as defined in the Terms and Conditions. Providing your personal data is necessary for the performance of this contract. Refusal to provide the data may result in the impossibility of carrying out the contractual relationship between you and the WEBSITE OWNER.

  • for compliance with the legal obligations incumbent upon the WEBSITE OWNER in connection with the services provided through the Site, including tax and archiving obligations.

Legal basis: The processing of your data for this purpose is necessary for compliance with legal obligations. Providing your data for this purpose is necessary. Refusal to provide the data may result in the WEBSITE OWNER being unable to comply with its legal obligations and, consequently, being unable to provide you with services through the Site.

  • for marketing activities, namely sending commercial communications by means of distance communication (email, SMS) concerning the products and services offered by the WEBSITE OWNER through the Site.

Legal basis: The processing of your data for this purpose is based on your consent, if you choose to provide it. You may express your consent to the processing of data for this purpose by ticking the appropriate box when creating your account or, after creating your account, in the My Account Information section. To unsubscribe from such commercial communications, you may use the option provided at the end of each email/SMS containing commercial communications. In addition, you may unsubscribe by accessing the My Account Information section.

Providing your data for this purpose is voluntary. Refusal to provide consent to the processing of your data for this purpose will not have any negative consequences for you.

  • for carrying out various analyses and reports on the operation of the Site and creating consumer preference profiles, mainly in order to improve the experience provided on the Site.

Legal basis: The processing of your data for this purpose is based on the legitimate interest of the WEBSITE OWNER in continuously improving the customer experience on the Site. Providing your data for this purpose is voluntary. Refusal to provide data for this purpose will not have any negative consequences for you.

III.2. If you are a visitor to the Site, the WEBSITE OWNER processes your personal data as follows:

  • for marketing activities, namely sending commercial communications by means of distance communication (email, SMS) concerning the products and services offered by the WEBSITE OWNER through the Site.

Legal basis: The processing of your data for this purpose is based on your consent, if you choose to provide it. You may express your consent to the processing of data for this purpose by completing and ticking the appropriate box in the newsletter subscription form available on the Site. To unsubscribe from such commercial communications, you may use the option provided at the end of each email/SMS containing commercial communications. Providing your data for this purpose is voluntary. Refusal to provide consent to the processing of your data for this purpose will not have any negative consequences for you.

  • for resolving complaints and claims, monitoring traffic, and improving your experience on the Site.

Legal basis: The processing of your data for this purpose is based on the legitimate interest of the WEBSITE OWNER in ensuring the proper operation of the Site and in continuously improving the experience of Site visitors, 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 any negative consequences for you.

  • The Period for Which We Process Your Data

As a general rule, the WEBSITE OWNER will process your personal data for as long as necessary to fulfil the processing purposes mentioned above. If you are a customer, we will process your data throughout the contractual relationship and thereafter in accordance with the legal obligations incumbent upon the WEBSITE OWNER (e.g. in the case of supporting financial and accounting documents, for which the retention period prescribed by law is 10 years from the end of the financial year during which they were drawn up). If you are a customer and choose to delete your user account by sending an email to the email address mentioned above, the WEBSITE OWNER will interpret this action as your choice to unsubscribe from commercial communications through which we keep you informed about the products and services offered through the Site. Accordingly, if you choose to delete your user account, we will no longer send you emails and/or SMS messages of this kind. However, please note that deleting the account will not automatically result in the deletion of your personal data. If you no longer wish your personal data to be processed, or if you wish the data to be deleted, you may exercise the rights detailed in Section VII below. If you request the deletion of your account while at least one active order exists on that account, the request to delete the account may be processed only after the products have been delivered and the last active order has been completed. If you withdraw your consent to the processing of data for marketing purposes, the WEBSITE OWNER will cease processing your personal data for that purpose, without affecting processing carried out by the WEBSITE OWNER on the basis of your consent before its withdrawal.

  • Disclosure of Personal Data

To fulfil the processing purposes, the WEBSITE OWNER may disclose your data to partners, third parties, or entities that support the WEBSITE OWNER in carrying out its activities through the Site (for example, courier companies and IT service providers), or to central/local public authorities, including in the following cases:

  • for the administration of the Site;
  • where such disclosure is necessary for awarding prizes or other benefits to data subjects, obtained as a result of their participation in various promotional campaigns organised by the WEBSITE OWNER through the Site;
  • for maintaining, customising, and improving the Site and the services provided through it;
  • for data analysis, testing and research, monitoring usage and activity trends, developing security features, and authenticating users;
  • for sending marketing communications, subject to the conditions and limits provided by law;
  • where disclosure of personal data is required by law, etc.
  • Transfer of Personal Data

The personal data provided to the WEBSITE OWNER will not be transferred outside Romania.

VII. Your Rights Under the legislation governing personal data processing, as data subjects, you have the following rights:

  • the right to information, namely the right to receive details regarding the processing activities carried out by the WEBSITE OWNER, as described in this document;
  • the right of access to data, namely the right to obtain confirmation from the WEBSITE OWNER as to whether personal data is being processed, as well as details regarding the processing activities, such as the manner in which the data is processed, the purpose of the processing, and the recipients or categories of recipients of the data, etc.;
  • the right to rectification, namely the right to obtain, without undue delay, the correction by the WEBSITE OWNER of inaccurate or unjustified personal data, as well as the completion of incomplete data. The rectification/completion will be communicated to each recipient to whom the data has been disclosed, unless this proves impossible or involves disproportionate effort.
  • the right to erasure of data, without undue delay (the “right to be forgotten”), where one of the following grounds applies:
    • the data is no longer necessary for the purposes for which it was collected or processed;
    • consent is withdrawn and there is no other legal ground for the processing;
    • the data subject objects to the processing and there are no overriding legitimate grounds;
    • the personal data has been unlawfully processed;
    • the personal data must be erased for compliance with a legal obligation;
    • the personal data was collected in connection with the offering of information society services in accordance with Union or national law applicable to the controller.

Following a request for data erasure, the WEBSITE OWNER may anonymise the data (thereby removing its personal nature) and continue processing it in this form for statistical purposes;

  • the right to restriction of processing where:
    • the data subject disputes the accuracy of the data, for a period enabling us to verify the accuracy of the data;
    • the processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of its use instead;
    • the controller no longer needs the personal data for the purposes of processing, but the data subject requires it for the establishment, exercise, or defence of legal claims; or
    • the data subject has objected to processing (other than direct marketing), pending verification of whether the legitimate grounds of the controller override those of the data subject.
  • the right to data portability, namely (i) the right to receive personal data in a structured, commonly used and machine-readable format, and (ii) the right to have such data transmitted by the WEBSITE OWNER to another data controller, insofar as the conditions provided by law are met;
  • the right to object – with regard to processing activities, this right may be exercised by submitting a request as indicated below:
    • at any time, on grounds relating to the data subject’s particular situation, to the processing of personal data concerning them on the basis of the legitimate interests of the WEBSITE OWNER or in the public interest, unless the WEBSITE OWNER demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or where the purpose is the establishment, exercise, or defence of legal claims;
    • at any time, free of charge and without giving any reason, to the processing of personal data concerning them for direct marketing purposes.
  • the right not to be subject to an automated individual decision, namely the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning the data subject or similarly significantly affects them;
  • the right to lodge a complaint with the National Supervisory Authority for Personal Data Processing or to apply to the competent courts, where you consider this necessary.