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Privacy Policy
SC REFRESH MARKETING SRL, with registered office in Romania, Sat. Dincani, Nr. 65, Com. Vedea, Jud. Argeș (hereinafter “Refresh Marketing”), Administrator of the Refresh Mag website declares that all personal data (hereinafter “data”) are considered strictly confidential and are managed in accordance with Regulation (EU) No 679/2016 of the European Parliament and of the Council on the protection of individuals with regard to the processing of personal data and on the free movement of data and repealing Directive 95/46/EC (GDPR).
Please also check the Cookie Policy for more information on how we use cookies on this website.
Personal data and its processing
Personal data is any information relating to an identified or identifiable natural person (“data subject”); 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, a location, an online identifier or by reference to one or more factors specific to his or her physical, physiological, genetic, mental, economic, cultural or social identity.
Categories of personal data
In general, you can use this site without providing any information. However, in order to respond to requests you submit through the contact form available on the site, certain information about you will be required. In such circumstances, we collect the following types of data: (i) name and (ii) e-mail address. In addition, if you submit more than one piece of personal information through the “message” field, we will process that data in accordance with your request.
Purpose of processing personal data
First, we process your name and e-mail address in order to respond to your request.
Secondly, we may process personal data for the following purposes:
To send you an offer regarding our services (in case you request such an offer);
Where we have your express consent;
To improve our services and systems (including this website) based on our legitimate interest derived from our freedom of doing business and our interest in improving our services for competitive success.
Transfer of personal data to third parties
We will not transfer or disclose your personal data to third parties, unless the transfer is required or permitted by law, if it is necessary to respond to any request from you. However, we will transfer your data to third parties where such transfer is based on a legal obligation, legitimate interest or where we have your prior consent, to the following:
Public authorities (e.g. courts, police, etc.);
Service providers engaged by us to support the provision of services to the highest standards (e.g. IT service providers, etc.).
Personal data security and retention period
Security of personal data
In order to prevent unauthorized access or disclosure, we have put in place physical, electronic, and managerial procedures to safeguard and secure the information we collect online.
Refresh Marketing is committed to protecting the privacy of personally identifiable information that we collect from you as a result of your use of the Site.
Refresh Marketing has implemented generally accepted standards of technology and operations security to protect personally identifiable information from loss, misuse, alteration or destruction. Only authorized Refresh Marketing personnel have access to personally identifiable information, and employees and/or contractors are required to treat the information as confidential. Notwithstanding these security measures, we cannot guarantee that unauthorized persons will not attempt to gain access to personally identifiable information.
Furthermore, we require our processors to demonstrate compliance of their systems with the GDPR.
Duration of processing
We process and store personal data:
For as long as necessary to respond to your request submitted via the contact form, but no longer than 3 months after the request has been resolved;
for as long as Refresh Marketing is required by law;
for as long as necessary to fulfill the purpose of the data collection;
in other cases, the processing of the data results from the purpose of the processing as required by law.
In all cases, we will not process or store your personal data for a further period if the purpose has been achieved.
Rights of data subjects
Right to be informed – you have the right to be informed at the time the data is collected. This obligation does not depend on a request from you and it is our duty to comply with the obligation, regardless of whether or not you are interested in that information.
Right of access – you have the right to obtain from us, upon request, information about the processing of your personal data, which will be communicated to you in an intelligible manner.
Right to rectification – you have the right to request rectification of your personal data. Data accuracy is essential for us to ensure a high level of data protection.
The right to erasure (“right to be forgotten”) – this right does not apply to personal data that Refresh Marketing needs to fulfill its contractual and/or legal obligations or to protect its legitimate interests.
Right to restrict processing – you have the right to temporarily restrict the processing of data by us. You can request restriction of processing when:
you contest the accuracy of your personal data;
the processing is unlawful and you request restriction of processing and not erasure;
the data must be kept for the exercise or defense of legal claims;
a judgment is pending as to the legitimate interest of the controller overriding those of the data subject.
The right to data portability – you have the right to request data portability where the data provided to us are processed by automated means on the basis of consent or where the processing is necessary for the performance of a contract and is carried out by automated means. This means that the right to data portability does not apply in situations where the processing of personal data is based on a legal provision other than consent or a contract.
The right to object – you may invoke the right to object to the processing of your personal data on grounds relating to your particular situation and in relation to the processing of data for direct marketing purposes.
Automated decision-making and profiling rights – automated decisions are decisions made using data processed solely by automated means without human intervention. Refresh Marketing does not process data in this way.
Contact data
If you have any questions, comments or requests relating to this Policy or intend to exercise any of the aforementioned rights, please do not hesitate to contact us on our contact page.
