GDPR Policy

GDPR Policy

General policy on the protection and confidentiality of personal data

1. Overview

1.1 Introduction. Legal framework. Purpose

Legal framework: Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 ("GDPR") transposed into domestic law by Law No. 190 of 18 July 2018 on implementing measures for Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) and by Law No. 102 of 3 May 2005 on the establishment, organisation and functioning of the National Supervisory Authority for the Processing of Personal Data;

«PREMIER GENERATION» SRLprocesses personal data in relation to customers, suppliers and other persons with whom the company has concluded a contract or with whom it is in a relationship.

This policy describes how personal data is collected, used and stored to be consistent with company standards and relevant legal provisions.

This policy applies to all persons who have access to personal data held by «PREMIER GENERATION» SRL, as well as to the systems and processes that constitute the company's infrastructure and IT support through which personal data is stored and processed.

This policy applies to all processing of personal data, regardless of whether the data is stored in electronic format, on paper or on another type of medium.

1.2. Purpose of the policy

This Policy outlines the general practices of «PREMIER GENERATION» SRL regarding the processing of your personal information in accordance with the law, for the purposes mentioned below, including the types of information we collect, how we use and protect it, and how you can correct/intervene in this process.

This data protection policy has been designed and implemented to ensure:

Compliance with personal data protection legislation and best practices at this level;

Protection of the rights of data subjects: for example, partners, customers, suppliers;

An efficient and secure way of storing and processing individuals' data;

Protecting the company from possible risks related to data security breaches.

1.3. Objectives and scope of this policy

The company «PREMIER GENERATION» SRL attaches great importance to the adequate protection, security and confidentiality of all personal information belonging to the persons whose personal data it holds, such as: customers, visitors, contractual partners or their representatives.

Therefore, «PREMIER GENERATION» SRL undertakes to comply with the requirements of applicable data protection legislation, namely Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 ("GDPR").

A large part of the personal data that «PREMIER GENERATION» SRL processes was obtained directly from the data subject, but there is also personal data obtained from external sources.

In order to protect the collected data, «PREMIER GENERATION» SRL has implemented security and encryption measures, so as to avoid as much as possible any possible security breach. The measures applied are periodically re-evaluated in order to update with new technologies.

Our procedures regarding the protection of personal data, organizational and technical measures, are structured in order to ensure the confidentiality and security of personal data and all information under our care. We periodically verify the adequacy of the measures implemented.

At the same time, we commit to using all technical and organizational measures at our disposal to ensure the security of your personal data, protecting it against destruction, modification, disclosure or unauthorized access to it.

1.4. Scope of application

This policy applies to all contractors, suppliers and other persons working on behalf of «PREMIER GENERATION» SRL This policy applies to all data that «PREMIER GENERATION» SRL holds in relation to individuals and which may lead to their identification. Personal information is collected and used fairly, stored securely. Illegal use of personal data held by «PREMIER GENERATION» SRL is not permitted;

«PREMIER GENERATION» SRLsanctions any attempt at illegal use of personal data.

1.5. Definitions

The definitions of the concepts on which this policy is based are as follows:

Personal data	any information relating to an identified or identifiable natural person (the "data subject")
The person concerned	an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to his or her physical, physiological, genetic, mental, economic, cultural or social identity
Processing	any operation or set of operations which is performed upon personal data or upon sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Operator	the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of the processing are determined by Union or national law, the controller or the specific criteria for its designation may be laid down in Union or national law
Person authorized by the operator	the natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller

1.6. Principles regarding the processing of personal data

The processing of personal data is based, according to the GDPR Regulation, on a series of fundamental processing principles.

Personal data is:

processed lawfully, fairly and transparently in relation to the data subject ("lawfulness, fairness and transparency");

collected for specified, explicit and legitimate purposes and not further processed in a way incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes is not considered incompatible with the initial purposes, in accordance with Article 89(1) (‘purpose limitation’);

adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed (“data minimisation”);

accurate and, where necessary, kept up to date; all necessary steps must be taken to ensure that personal data which are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay ("accuracy");

kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the data are processed; personal data may be stored for longer periods insofar as they will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1), subject to the implementation of appropriate technical and organisational measures provided for in this Regulation to safeguard the rights and freedoms of the data subject (‘storage limitations’);

processed in a manner that ensures adequate security of personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, by taking appropriate technical or organizational measures ("integrity and confidentiality").

Thus, your personal data:

are processed lawfully, fairly and fairly in relation to you;

are obtained only for specified, legitimate, specified and relevant purposes for meeting operational needs and will not be processed in any manner incompatible with the purposes for which they were obtained;

are processed in a transparent manner.

relevant data are processed and personal data are not processed in excess of the purpose or purposes for which they are processed, are relevant and strictly limited to what is absolutely necessary for the purposes for which they are processed, in the sense that personal data will not be kept longer than is necessary in relation to that purpose or purposes;

Your personal data will be accurate and, where applicable, kept up to date. The processing of personal data will be carried out in the most secure conditions, aiming at protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, by taking appropriate technical or organizational measures.

1.7. Rights of the data subject

These rights consist of:

The right to withdraw consent;

The right to information;

Right of access;

The right to rectification;

The right to erasure of data ("right to be forgotten");

The right to restriction of processing;

The right to data portability;

The right to object to processing;

The right not to be subject to a decision based solely on automated processing, including profiling;

The right to file a complaint with the Authority;

The right to seek justice.

You can ask us what information we hold about you and ask us to correct it if it is inaccurate. If we have asked for your consent to process your personal data, you can withdraw this consent at any time. If we process your personal data to perform a contract or on the basis of consent, you can ask us to provide you with a copy of the information in a machine-readable format so that you can transfer it to another provider. If we process your personal data on the basis of consent or legitimate interest, you can request the erasure of your data.

You have the right to ask us to stop using your information for a period of time if you believe we are not doing so lawfully. To submit a request regarding your personal data by email, post or telephone, please use the contact information provided by us on this site.

1.8. Grounds for processing

There are six alternative ways in which the lawfulness of a specific case of personal data processing can be established under the GDPR Regulation.

Consent

Unless required for a reason permitted by the GDPR, «PREMIER GENERATION» SRL will always obtain the explicit consent of a data subject for the collection and processing of data. Information about the use of our personal data will be provided to data subjects at the time of obtaining consent and explaining their rights with respect to their data, such as the right to withdraw consent.

If the personal data is not obtained directly from the data subject, this information will be provided to the data subject within a reasonable period of time after obtaining the data.

Conclusion or execution of a contract

If the personal data collected and processed are necessary to enter into or perform a contract with the data subject, explicit consent is not required. This will be the case if the contract cannot be concluded without the personal data in question, for example a delivery cannot be made without an address to which it can be delivered.

Legal obligation

If personal data must be collected and processed to comply with the law, explicit consent is not required.

Vital interests of the data subject

If the personal data are necessary to protect the vital interests of the data subject or of another natural person, then this may be used as the legal basis for the processing. «PREMIER GENERATION» SRL will keep reasonable, documented evidence that this reason is used as the legal basis for the processing of personal data.

Activity carried out in the public interest

If «PREMIER GENERATION» SRL needs to perform a task that it considers to be in the public interest or as part of an official obligation, then the consent of the data subject will not be requested. The assessment of the public interest will be documented and made available as evidence when necessary.

Legitimate interest

If the processing of specific personal data is in the legitimate interests of «PREMIER GENERATION» SRL and is considered not to significantly affect the rights and freedoms of the data subject, then this can be defined as the lawful ground for processing. Again, the reasoning behind this point of view will be documented.

2. The purposes and grounds on which we process/collect your personal data

«PREMIER GENERATION» SRLmay process/collect your personal data, in your capacity as a client, business partner and/or their representative/employee, for the following purposes:

for financial and accounting purposes, for the purpose of carrying out contractual relations;

for the purpose of storing contact details of the company's contractual partners;

conducting contractual business relationships;

We will use your data (obtained online or in person) to manage your registration as a user, to manage your purchases of products or services, to answer your questions, and, if you wish, to send you our personalized communications.

We process your data to execute the contract you enter into with us when you register and when you purchase any product or to benefit from any of our services or functionalities, but there are also other reasons that legitimize us, such as, among others, the interest in answering your questions or the consent you give us to send you our newsletter.

Depending on the products, services or functionalities that you wish to benefit from at any time, we will need to process certain personal data, which, in general, will be as follows:

identification data (e.g. name, surname, language and country from which you interact with us, contact information, etc.);

economic and transactional information (e.g. payment or bank card information, information about purchases, orders, returns, etc.);

connection, geolocation and navigation data (if you interact with us, for example, from your mobile phone);

commercial information (for example, if you are subscribed to our newsletter);

data about your tastes and preferences

When we ask you to fill in your personal data to provide you with access to certain functionalities or services of the platform, we will mark some fields as mandatory because this is information that we need to be able to provide you with the service or to provide you with access to that functionality.

If you decide not to provide us with this information, you may not be able to complete your registration as a user or benefit from these services or functionalities.

Depending on how you interact with our platform, we will process your personal data for the following purposes:

To manage your registration as a user of our platform: if you decide to register as a user on our platform, we need to process your data to identify you as a user of it and to provide you with access to its various functionalities, products and services available to you as a registered user. You can cancel your registered user account by contacting us using the information provided in the "Contact information" section. You can also use access or log in via a social network, such as Facebook, G+, In, either to register as a new user or to associate the login with your current account. In this case, your login data, as well as your email address if you approve this, will be imported from your account on the social network. By using this login option, the social network may send us some additional information from your profile. public, such as: name, gender, age or profile picture, in accordance with the terms of use of the social network, which we recommend that you read carefully. If you do not give us your consent, we will not keep this additional information. Also, using this functionality may involve providing certain information about your activity on the social network. In any case, please check the privacy settings and privacy policy of the social networks to know how this data is processed by the social networks.

For the execution of the sales-purchase or services contract that you have concluded with the undersigned «PREMIER GENERATION» SRL on the Platform. This purpose includes the processing of personal data, mainly as follows:

To contact you regarding updates or informative communications regarding contracted functionalities, products or services, including sending surveys regarding the quality of the products or services provided;

Managing payments for purchased products, regardless of the payment method used; for example: when you purchase one of our products through the Website and choose to activate the function of saving card data for future purchases, we must process the data indicated for the activation and development of said functionality. Consent to activate this functionality allows your payment data to be automatically filled in for future purchases, so that you do not have to re-enter them for each new purchase and they will be considered valid and valid for subsequent purchases. You can modify or delete your cards at any time through the payment information section, either in your user account or in our application.

Enabling the necessary mechanisms to prevent potential fraud against you and us during the purchase process. If we assess that the transaction may be fraudulent, this processing may lead to the transaction being blocked.

Managing possible returns after you have made a purchase and managing requests for information regarding the availability of items sold by the subscriber, or to reserve products through the platform;

For billing purposes and to provide you with receipts and invoices related to purchases you have made on the platform.

To ensure your use of other available functionalities or services such as promotions, offers, etc.

To respond to requests or inquiries you make through our website: we only process personal data strictly necessary to manage or resolve your request or inquiry;

For marketing purposes: this purpose includes the processing of personal data, mainly for:

To the extent that you subscribe to the Newsletter, we will process your personal data to manage your subscription, including sending you personalized information about our products or services by various means (such as by email or SMS). Therefore, please note that this data processing involves analyzing your user or customer profile for the purpose of creating profiles through which we determine your preferences. We will also make suggestions to you regarding products that we believe may interest you, based on your shopping and browsing history.

You can unsubscribe from the Newsletter at any time and completely free of charge through the "Newsletter" section of our Platform, as well as through the instructions provided in each communication.

To carry out promotional actions (for example, to run contests or send the list of saved items to the email address you indicate to us). By participating in any promotional action, you authorize us to process the data provided related to each action and which we may communicate through various means, such as social networks or even on our website. For each promotional action in which you participate, you will be able to access the terms and conditions section, in which we will provide you with more detailed information regarding the processing of your data.

Conducting surveys by the subscriber to determine the degree of satisfaction of our customers and users, in order to improve products and services.

We will share your data with service providers who help or support us, whether they are external collaborators with whom we have entered into an agreement and who are located within or outside the European Union.

3. How we may process/collect your personal data

«PREMIER GENERATION» SRLcollects the personal data of the data subjects from the moment of the commencement of contractual relations, of the beginning of your collaboration with «PREMIER GENERATION» SRL

The types of personal data we may collect/process:

We collect personal data of our customers and potential customers who are individuals, representatives of organizations and their contact persons, the contact data of the people we interact with and those who act on our customers' instructions, our suppliers and people who contact us untimely, as well as of relevant people who make their personal data publicly available.

We also collect and retain personal data as part of our customer acceptance and contract execution procedures. For certain services or activities, we may also collect special categories of personal data when we obtain consent, in writing, by IT means or when it is publicly available, as well as when the law obliges us.

The data collected varies from case to case. At most, we collect the first and last name of the contact person, the company name, the position, the telephone number, the email address, the postal address, the date, the time and any other contact details that help us remember the context of the interaction with us. We do not want to collect the personal identification number, so we only do this if the law obliges us and always with appropriate security measures. If such data incidentally comes to our attention, we delete it immediately.

For the purposes mentioned above, »PREMIER GENERATION» SRL collects and/or processes the following categories of data regarding customers, business partners, their representatives/employees:

Name, surname, telephone, fax, email address, address, signature, for financial-accounting purposes, for the purpose of carrying out contractual relations pursuant to Art. 6 (1) (c) of the GDPR - processing is necessary for the fulfillment of a legal obligation to which the operator is subject (keeping accounting records) and Art. 6 (1) (f) - processing is necessary for the purposes of the legitimate interests pursued by the operator;

Name, surname, telephone, fax, email, address, signature in order to store the contact details of the company's contractual partners, pursuant to Art. 6 (1) (f) - processing is necessary for the purposes of the legitimate interests pursued by the operator;

4. Storage of personal data

The storage period of your data will depend on the purposes for which we process them, as follows:

4.1. Managing your registration as a user of our website: we will process your data for as long as you have the status of a registered user of our website (i.e. until you decide to unsubscribe);

4.2. Development, fulfillment and execution of the sales or service contract: we will process your data for the time necessary to manage the purchase of the products or services you have purchased, including any returns, claims or complaints related to the purchase of the product or service in question. In some situations, we will process the data only until the time you determine, as is the case with payment data (by card) that you ask us to store for possible future purchases.

4.3. Marketing: we will process your data until you unsubscribe or cancel your newsletter subscription. If you participate in promotional actions, we will store the data for a period of 6 months from the end of the promotional action.

Regardless of how we process the data for the period strictly necessary to achieve the intended purpose, we will subsequently store and protect it appropriately for the period of time during which responsibilities derived from that processing may arise, in accordance with the regulations in force. Once the possible actions are prescribed in each case, we will proceed to delete the personal data.

Personal data is stored on the «PREMIER GENERATION» SRL server, is not used to make any automated decisions based on them and will be kept as long as necessary for the assumed processing, and longer periods of storage of personal data are exceptions associated with legal provisions, as follows:

for financial-accounting purposes, for the purpose of carrying out contractual relations: for the duration of the contract, for a period of 10 years after registration in the accounts;

for the purpose of preserving the contact details of the company's contractual partners: for the duration of the contract, for a period of 3 years from the date of termination of the contracts.

Personal data will be subject to appropriate technical and organizational measures reasonably necessary to protect it against unauthorized or accidental destruction, loss, alteration, access or other processing.

«PREMIER GENERATION» SRLwill take measures regarding the security of data processing and, accordingly, will establish its own internal policy for the security of personal data processing.

5. Disclosure of personal data

Regarding the disclosure of personal data to third parties located in Romania or outside Romania, »PREMIER GENERATION» SRL will disclose the personal data of the data subjects, in the case of contractual partners/representatives of the contractual partners of »PREMIER GENERATION» SRL to the contractual partners. It is necessary to grant access to your personal data to third parties who provide us with support in the services we offer you, namely: financial institutions, bodies specializing in the detection and prevention of fraud, technology service providers, suppliers and collaborators of logistics, transport and delivery services, suppliers and collaborators of services related to marketing and advertising.

6. Your right as a data subject to make requests and file complaints

If you have a complaint regarding the use of your information, please contact us first, so that we can resolve the request amicably. To this end, for any issues, questions or complaints regarding the way we process your personal data you can send us an email at   office@voore.ro However, you can also contact the National Supervisory Authority for Personal Data Processing for Information via their website at http://www.dataprotection.ro/ or write to them at: B-dul G-ral. Gheorghe Magheru 28-30, Sector 1, postal code 010336, Bucharest, Romania

Requests will be exempt from any fee. The undersigned »PREMIER GENERATION» SRL will be obliged to provide a response within a maximum of one month, and in certain exceptional cases within a maximum of two months from receipt of the request.

«PREMIER GENERATION» SRLwill always verify the identity of any person. »PREMIER GENERATION» SRL respects the following deadlines for responding to requests from data subjects:

Data request	Time graph
The right to be informed	When data is collected (if provided by the data subject) or within one month (if not provided by the data subject)
Right of access	One month
Right to rectification	One month
Right to erasure	No unjustified delays
The right to restrict processing	No unjustified delays
Right to data portability	One month
The right to object to processing	Upon receipt of the objection
Rights related to the decision-making process and automated prophylaxis.	Unspecified

«is obliged to communicate to the petitioner the response to the request made according to the terms indicated above, calculated from the date of registration of the request. This term may be extended with justification by a maximum of 15 calendar days if »PREMIER GENERATION» SRL has several requests to resolve and/or the request is complex.

«PREMIER GENERATION» SRLwill send the data subject the response to the above request by letter with acknowledgment of receipt to the address indicated by the data subject or by e-mail.

7. DPA notification in case of personal data breach

In the event of a personal data breach, »PREMIER GENERATION» SRL shall notify the National Supervisory Authority for Personal Data Processing without undue delay and, if possible, within 72 hours of having become aware of it.
The above notification:

describe the nature of the personal data breach, including, where possible, the categories and approximate number of data subjects concerned, as well as the categories and approximate number of personal data records concerned;

will communicate the name and contact details of the data protection officer or another contact point from which more information can be obtained;

describe the likely consequences of a personal data breach;

will describe the measures taken or proposed to be taken by »PREMIER GENERATION» SRL to remedy the personal data security breach, including, where applicable, measures to mitigate its possible negative effects.

«PREMIER GENERATION» SRLkeeps documents relating to all personal data breaches, which include a description of the factual situation in which the personal data breach occurred, its effects and the remedial measures taken. This documentation allows the DPA, the National Supervisory Authority for Personal Data Processing, to verify compliance with the provisions of the GDPR.

If the personal data breach is likely to result in a high risk to the rights and freedoms of natural persons, »PREMIER GENERATION» SRL shall inform the data subject without undue delay of the breach.

8. Privacy Policy Updates

«PREMIER GENERATION» SRLperiodically checks whether this Policy is correct and complete in terms of the information to be covered, fully implemented and accessible, in accordance with the requirements of applicable legislation and its principles. If any changes to this Policy are necessary or deemed appropriate, »PREMIER GENERATION» SRL will inform you of them in a timely manner.

You can raise any questions, comments regarding this Policy and the processing of your personal data, including regarding applicable law or international transfers, by contacting us.

This Policy will be brought to the attention of all customers, collaborators, business partners or other third parties by publication on the website.