The company ENTROPIC MEDIA SRL, legal entity with the registered office on str. Câmpina, Nr. 62A, Et. 4, Cluj-Napoca, Romania, with the registration number at the Trade Register J12 / 4999/2021 and CUI 45089998, under the Leo&Lisa brand, hereinafter referred to as Leo&Lisa, as operator, wishes to inform you about the processing of your personal data in the context of operations of providing Leo&Lisa services / products to customers, for the purposes specified below.
By the nature and procedures of the services/ products provided by ENTROPIC MEDIA SRL ("products" or "services" ENTROPIC MEDIA SRL), their users ("Clients" or "Users") transmit certain personal data used to ensure the provision and conduct according to the legal provisions of their own services and procedures, safely and in optimal conditions.
Protecting the personal data of ENTROPIC MEDIA SRL's clients and keeping them safe is one of the important concerns of ENTROPIC MEDIA SRL and of the agents, partners and subcontractors involved in the provision of services.
Personal data means both non-personal data and personal data – information relating to an identified or identifiable natural person. An identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identifier, including but not limited to:
(I) name, surname, address, e-mail, telephone (e.g. landline, mobile, fax);
(ii) information of a financial nature (e.g. income, etc.);
(iii) various information required or requested by authorities specific to the provision of services/products;
(IV) information resulting from video/audio monitoring if the Customer visits one of the locations where the ENTROPIC MEDIA SRL services/products are provided or contacts the support services;
(VI) any other information that derives from them as a result of the processing carried out by ENTROPIC MEDIA SRL (e.g., the segmentation of the clientele according to different criteria, the unique identifier generated at the level of ENTROPIC MEDIA SRL for each client separately, information specific to the services / products offered by ENTROPIC MEDIA SRL, etc.) and any other information that is necessary for carrying out the activities of ENTROPIC MEDIA SRL;
(VII) the IP or the activities performed when you browse our website, www.leoandlisa.ro, or use the applications / services of ENTROPIC MEDIA SRL.
Processing of personal data means any operation or set of operations which is performed on personal data, by automatic or non-automatic means, such as collection, recording, organisation, storage, adaptation or alteration, retrieval, consultation, use, disclosure to third parties by transmission, dissemination or in any other way, joining or combining, blocking, archiving, erasure, destruction, etc.
COLLECTION OF INFORMATION
The information is collected in the process of offering the services/products to users or potential users. The main sources of information are:
1. The forms used to provide the services, data provided when using the websites or applications of ENTROPIC MEDIA SRL, in this case, www.leoandlisa.ro, other means of communication, questionnaires that users or potential users of the services accept (without being obliged to accept) to fill in at our request, other documents that users or potential users make available to us at our request;
2. Transactions that take place between ENTROPIC MEDIA SRL and its agents / partners and between them and the users of the service;
3. External sources – for the fulfillment of specific obligations (competent institutions, public registers, electronic databases, information available in social media as well as on the Internet, or authorized third parties, holders of such information, such as, but not limited to, the following: The National Trade Register Office, the portal of the Romanian courts administered by the Ministry of Justice, other providers of personal data, etc.).
www.leoandlisa.ro collects personal data from its users in three ways:
- Directly from the user;
- Traffic data, from the user's browser;
- Through cookies.
1. Personal data collected directly
(I) When you access the www.leoandlisa.ro or when you create an account or place an order, we may ask for your name, surname, delivery/ email address, telephone number, as well as other data necessary for contracting, delivery and billing.
These data are kept for a period of 3 years from the end of the contract (this being the general limitation period). The data in the invoices are kept for 10 years (where there is a legal tax liability). If you do not provide us with this data, we will be unable to fulfill your order.
(ii) When you access support services, we may ask you for an email address or phone number. We reserve the right to record any communication made for the support services of the services www.leoandlisa.ro for the purpose of improving our services. We will inform you before the start of the communication that it could be registered. This data is used, for example, for the purpose of contacting you. to resolve a complaint/request of yours.
We may request other data that may constitute personal data only to the extent that it is necessary for these purposes.
(III) Also, when you subscribe to our newsletter, please give us an email address to personalize the communication to you. This data is kept until his consent is revoked until your activity is revoked. it shows us that you are no longer interested in our communication.
(IV) When you make a payment; all payments are processed by our partner– Stripe, Inc. So banking information is transmitted to him. Stripe's personal data processing policies are available on this partner's website.
2. Traffic data
When you visit a website, regardless of the device used, you disclose certain information about yourself, such as your ip address. IP, the time of your visit, the place from where you entered our sites, the pages visited. www.leoandlisa.ro, like other operators, record this information for a specified period of time.
www.leoandlisa.ro uses external traffic analytics services, such as Google Analytics. This data is used by www.leoandlisa.ro to improve our website and services, but also to ensure the security of our website.
What is a cookie?
A cookie is a small file, generally made up of letters and numbers, which is downloaded to the memory of a computer (or other equipment used for online browsing – mobile phone, tablet, etc.) when the user accesses a particular website. Cookies are created when the browser used by a user displays a particular website. The website transmits information to the browser and the browser creates a text file. Each time the user accesses that website again, the browser generates and transmits this file to the website's server. In other words, the cookie can be seen as an identification card of the Internet user, which notifies the website every time the user re-accesses that site. A cookie consists of 3 parts: the name, content and value of the cookie. The lifetime of a cookie is determined. Technically, only the web server that sent the cookie can access it again when a user re-accesses the website associated with that web server. Cookies themselves do not require personal information in order to be used and, in most cases, do not personally identify Internet users.
There are 2 main categories of cookies:
(I) session cookies: they are temporarily stored in the cookie folder of the web browser in order for it to store them until the user exits the respective web-site or closes the browser window.
(ii) Persistent cookies: are stored on the hard drive of a computer or device and are enabled again when you visit the site that created that specific cookie. Persistent cookies also include those placed by a website other than the one the user is currently visiting. These are known as "third party cookies", i.e. cookies placed by third parties.
Purpose of cookies
Cookies can ensure faster and easier interaction between users and websites. For example, when a user logs in to a particular website, authentication data is stored in a cookie; the user can then access that site without having to log in again.
In other cases, cookies can be used to store information about the activities carried out by the user on a particular web page, so that he can easily resume those activities upon a subsequent access to the site. Cookies tell the server what pages the user should show so that he does not have to remember this or navigate the entire site from the beginning. Thus, cookies can be assimilated to "bookmarks" that tell the user exactly where he left off on a website.
Cookies may also give websites the ability to monitor users' online activities and establish user profiles, which can then be used for marketing purposes. For example, based on cookies, the products and services agreed by a user can be identified, this information subsequently serving to send appropriate advertising messages to that user.
What is the lifetime of a cookie?
The lifetime of a cookie may vary significantly, depending on the purpose for which it is placed. Some cookies are intended for a single use (as is the case with session cookies), so they are not maintained once the user leaves the site. Other cookies are maintained and reused each time the user returns to the site (persistent cookies). However, cookies can be deleted by the user at any time by using the browser settings.
What are cookies placed by third parties?
Some sections of the content of some sites may be provided through third-party cookies such as an advertisement. Such cookies can be placed on the site and are called cookies placed by third parties because they are not placed by the site owner. Such third parties are in turn obliged to comply with the applicable legal regulations and privacy policies of the respective site owner.
PURPOSES OF THE PROCESSING OF PERSONAL DATA
The purpose of collecting your data is exclusively to respond efficiently and promptly to your request, at all stages of the procurement procedure: checking the correctness of the data entered by you in the order form, checking your order, issuing the invoice for products ordered by you. As well as to be able to contact you in case there are uncertainties about the completion of your order.
The purposes for which ENTROPIC MEDIA SRL processes personal data are:
- selling products and services on www.leoandlisa.ro (with all related activities such as order processing, delivery, payment, billing, etc.), customer service and marketing activities for the www.leoandlisa.ro's own needs
- identification of users / potential users through the means of communication (e.g. telephone, e-mail, mail, internet, fixed or mobile applications that the Client accesses in order to use the services provided);
- identification of users / potential users in order to fulfill the legal obligations incumbent on ENTROPIC MEDIA SRL when providing services;
- monitoring operations and carrying out services and providing support services for users / potential users;
- creating or analyzing profiles for the improvement of services and the conduct of surveys as well as for carrying out any other types of promotion of services and / or carrying out marketing or advertising activities of a general type;
- analyzing the behavior of any person who accesses the websites of ENTROPIC MEDIA SRL, by using cookies, in order to provide content (general and commercial) adapted to the user's preferences;
- conducting internal analyses (including statistical analysis) both on services and on the portfolio of users / potential users, for the provision, improvement and development of services, as well as conducting market studies and analysis on the specific field;
- settlement of any procedural and/ or legal situations related to the provision of services or in the interest of the company;
- archiving both in physical and electronic format of the documents related to the provision of services and / or correspondence with users / potential users;
- reporting to state institutions according to the applicable legal regulations ENTROPIC MEDIA SRL (e.g.: regulatory authorities and legal authorities).
GROUNDS FOR THE PROCESSING OF PERSONAL DATA
ENTROPIC MEDIA SRL processes personal data for the purposes mentioned above, based on the following grounds:
- Execution of the contract and preliminary steps for this contract (art. 6(1) b GDPR) – for data collected through the order form or data received as a result of customer service;
- Legal obligations (Art. 6 (1) c GDPR) for data necessary for billing;
- Consent (art. 6 (1) of gdpr) for data used for marketing for site visitors (e.g. subscribing to newsletters, marketing cookies, etc.);
- Legitimate interest (art. 6 (1) f GDPR for data used for marketing for current customers (according to art. Law 506/2004 art. 12 (2)) of the www.leoandlisa.ro, the security of its own website www.leoandlisa.ro (recital 49 GDPR) and the data used internally to optimize its own website www.leoandlisa.ro (and anonymized or pseudonymized, as the case may be).
IS IT MANDATORY FOR THE USER TO COMMUNICATE THE DATA? WHAT ARE THE CONSEQUENCES IN CASE OF REFUSAL?
The processing of personal data requested from users / potential users by ENTROPIC MEDIA SRL in order to provide services are considered strictly necessary for the provision of services according to the legal provisions and procedures of ENTROPIC MEDIA SRL. Refusing to provide such data makes it impossible for us to provide the services. The user may choose not to have his data processed for direct marketing purposes.
RECIPIENTS OF PERSONAL DATA
In order to fulfill the above-mentioned purposes, the company may transmit customer data, where strictly necessary, to the following categories of third parties:
- Regulatory authorities and legal authorities
- Contractual partners (e.g. company agents, auditors, consultants, etc.), some of whom are also processors with the processing of personal data.
These contractual partners also carry out their commercial activity in Romania, and they can be provided with your personal data to be used within the limits of the obligations they have assumed towards the company. The personal data that we disclose to the persons empowered by us with their processing are limited to the minimum necessary personal data in order to carry out the respective services and, at the same time, we ask them not to use the personal data for any other purpose. We make every effort to ensure that all the entities we work with store your personal data safely and securely. Also, some of them are also operators that carry out their commercial activity in Romania as well. Some of them are third parties who do not have the role of processing personal data, but may have access to them in order to fulfill their obligations or in their interaction with the company, such as technical maintenance companies, financial auditors or legal service providers.
The personal data mentioned above may be made available or transmitted to third parties in the following situations:
(I) Public authorities, auditors or institutions with components in control activities relating to the company's services, activities or assets, which require the company to provide information, on the basis of the legal obligations incumbent on the company;
(ii) To meet a legal requirement, including those related to the provision of services, or to protect the rights and assets of our company or of other entities or persons, such as courts of law;
(III) Acquiring third parties, to the extent that the company's business would be (in whole or in part) transferred and the personal data of the data subjects would be part of the assets representing the object of the transaction. Also, for the purpose of the processing regulated above, we may provide your personal data to the companies that are part of the ENTROPIC MEDIA SRL group, companies that will be subject to the company's instructions regarding the processing of your personal data.
TRANSFER OF PERSONAL DATA OUTSIDE THE COUNTRY
In the context of the operations described above, Customers' personal data may be transferred outside the country to States of the European Union ("EU") or the European Economic Area ("EEA"). Thus, we hereby inform Clients that any transfer made by the company to an EU or EEA member state will comply with the legal provisions of the General Data Protection Regulation no. 2016/679 adopted by the European Parliament ("GDPR").
DURATION OF PROCESSING
We will store customers' personal data only for the period of time necessary to achieve the purposes of the processing, as mentioned above, and in compliance with the legal regulations in force inclusive, but not limited to the provisions in the field of archiving.
WHAT HAPPENS TO PERSONAL USERS' DATA AFTER PROCESSING CEASES
After the time when the duration of the above-mentioned processing expires and the company no longer has legal reasons or a legitimate interest in the processing of your personal data, the personal data will be deleted in accordance with the company's procedures, which may involve archiving, anonymization, or destruction.
AUTOMATED DECISION-MAKING AND PROFILING
The personal data referred to herein may be subject to automated decision-making processes, including the creation / deletion of profiles.
SECURITY OF THE PROCESSING OF PERSONAL DATA
The company constantly evaluates and improves the security measures implemented in order to ensure a safe and secure processing of personal data.
Measures taken to ensure the security of personal data:
- Users who have access to the database of personal information, can access the database only with their own account name and password. All users are obliged to maintain the confidentiality of the data to which they have access, and at each end of the session in the database they will close the session;
- Users access personal data only for the performance of their duties;
- Any operation of collection and / or modification of personal data by users is permanently recorded (the user, date, time and type of change are recorded); all logins and logons of all users to the database are also recorded;
- The printing of personal data is carried out only by authorized users for this operation and only for purposes required by the laws in force (invoices, notices accompanying the goods, commercial contracts).
Personal data is stored electronically in secure, password-protected files. The information on paper is kept in special files, to which only the employees of the company have access, to which the obligation of confidentiality is incumbent.
RIGHTS OF THE DATA SUBJECT WITH REGARD TO THE PROCESSING OF PERSONAL DATA
In the context of the processing of personal data of users / potential users, the data subject has the following rights:
The right to information – Articles 13 and 14 GDPR. Allows the data subjects to know, from the very moment the collection is made, how those data will be used, to whom they will be disclosed or transferred, what rights the persons concerned have with regard to the processed data, etc.;
The right of access to the processed personal data – art. 15 GDPR. Allows the person to obtain, from ENTROPIC MEDIA SRL, a confirmation that personal data concerning him or her are being processed or not and, if so, access to the respective data and other useful information;
Right to rectification or deletion of data – art. 17 GDPR. It allows the person to obtain from ENTROPIC MEDIA SRL the deletion / rectification of personal data concerning him or her, without undue delay. There are, however, exceptions to this rule, such as: some data are processed to give the public the right to information; the data are processed for statistical or archiving purposes; the data are processed for the fulfilment of a legal obligation or are processed for the establishment or defence of a right in court;
The right to request restriction of processing – 18 GDPR: you have the right to obtain the restriction of processing in cases where: (I) you consider that the personal data processed are inaccurate, for a period that allows the controller to verify the accuracy of the personal data; (ii) the processing is unlawful, but you do not want us to delete your personal data, but to restrict the use of such data; (iii) if the data controller no longer needs your personal data for the purposes mentioned above, but you need the data in order to establish, exercise or appear a right in court; (IV) you have opposed the processing, for the period of time during which to verify that the legitimate grounds of the data controller prevail over the rights of the data subject;
The right to data portability – 20 GDPR. It represents the right to receive your personal data that you have provided to ENTROPIC MEDIA SRL in a structured, commonly used and machine-readable form, as well as the right to transfer that data to another operator, if the processing is based on your consent or the execution of a contract and is carried out by automatic means;
The right to withdraw your consent to the processing, when the processing is based on the consent, without affecting the lawfulness of the processing carried out until that moment;
The right to object to the processing of personal data – Art. 21 GDPR – for reasons related to the particular situation in which you find yourself, when the processing is based on legitimate interest, as well as to oppose, at any time, the processing of data for direct marketing purposes, including the creation of profiles;
The right not to be the subject of a decision based solely on automated processing, including profiling, which produces legal effects concerning the data subject or similarly affects him or her to a significant extent;
The right to file a complaint with the National Supervisory Authority for Personal Data Processing (ANSPDCP) and the right to address the competent courts of law.
THE DATA PROTECTION POLICY IS BASED ON THE FOLLOWING DATA PROTECTION PRINCIPLES:
- The processing of personal data will be done in a legal, fair and transparent manner;
- The collection of personal data will be done only for specified, explicit and legitimate purposes and the data will not be further processed in a manner incompatible with those purposes;
- The collection of personal data will be adequate, relevant and limited to the information necessary for the purpose of processing;
- Personal data will be accurate, and where necessary, updated;
- All necessary measures shall be taken to ensure that incorrect data are erased or corrected without delay;
- The personal data will be kept in a form that allows the identification of the data subject and for a period not longer than that in which the personal data are processed;
- All personal data will be kept confidential and stored in a manner that ensures the necessary security;
- Personal data will not be shared with third parties unless it is necessary for the purpose of providing services according to the agreements;
- Data subjects have the right to request access to, rectification and erasure of personal data, opposition or restriction from data processing as well as from the right of data portability.
CHANGES TO THIS STATEMENT REGARDING THE PROCESSING OF PERSONAL DATA
The exercise of the above-mentioned rights can be done at any time. In order to exercise these rights, we recommend that you use the forms that can be found on the www.leoandlisa.ro website or by sending a notification in electronic format to the following address: email@example.com.
If you wish to receive information about the products and services offered by ENTROPIC MEDIA SRL, through the online store www.leoandlisa.ro, please sign up for our newsletter, specifying your email address. If you want to purchase a product or service from the online store www.leoandlisa.ro, please fill in the required data in the order form (name, surname, address, locality, phone number, etc.).
The last update was made on 09.08.2022.