Privacy Policy - Autumn Tales

– last updated: 25 June 2024 –

1. Introduction

1.1 We are committed to safeguarding the privacy of our customers.

1.2 This policy applies where we are acting as a data controller with respect to the personal data of such persons; in other words, where we determine the purposes and means of the processing of that personal data.

1.3 In this policy, “we”, “us” and “our” refer to Autumn Tales SRL. [For more information about us, see Section 8.]

2. Credit

2.1 This document was created using a template from Docular (https://seqlegal.com/free-legal-documents/privacy-policy).

3. The personal data that we collect

3.1 In this Section 3 we have set out the general categories of personal data that we process and, in the case of personal data that we did not obtain directly from you, information about the source and specific categories of that data.

· Identity Data: includes first name, maiden name, last name,

· Contact Data: includes billing address, email address, company name, website.

· Financial Data: includes VAT number and payment card details.

· Transaction Data: includes details about payments to and from you and other details of products and services you have purchased from us.

· Technical Data: includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this Site or the Services.

· Profile Data: includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.

· Usage Data: includes information about how you use our Site and Services, including the full Uniform Resource Locators (URL) clickstream to, through and from our Site and Services (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.

· Marketing and Communications Data: includes your preferences in receiving marketing from us and our third parties and your communication preferences.

· Aggregated Data: We also collect, use and share statistical or demographic data for any purpose. This Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.

· Special Category Data: We do not collect, store and/or use special category data about you. This means details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data.

4. Purposes of processing and legal bases

4.1 In this Section 4, we have set out the purposes for which we may process personal data and the legal bases of the processing.

4.2 Operations – We will process your personal data for the purposes of providing our services, generating invoices, bills and other payment-related documentation, credit control and data analytics to improve our Site and Services, marketing, customer relationships and experiences. The legal basis for this processing is our legitimate interests, namely the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

4.3 Relationships and communications – We may process contact data, and/or communication data for the purposes of communicating with you (including communicating for the purposes of direct marketing and/or requests of reviews of service provided ) by email, SMS and/or telephone, providing support services and complaint handling. The legal basis for this processing is our legitimate interests, namely communications with our service users, individual customers and the proper administration of our services and business.

4.4 Record keeping – We may process your personal data for the purposes of creating and maintaining our databases, back-up copies of our databases and our business records generally. The legal basis for this processing is our legitimate interests, namely ensuring that we have access to all the information we need to properly and efficiently run our business in accordance with this policy.

4.5 Security – We may process your personal data for the purposes of security and the prevention of fraud and other criminal activity. The legal basis of this processing is our legitimate interests, namely the protection of our services and business, and the protection of others.

4.6 Legal claims – We may process your personal data where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

4.7 Legal compliance and vital interests – We may also process your personal data where such processing is necessary for compliance with a legal obligation to which we are subject or in order to protect your vital interests or the vital interests of another natural person.

5. Providing your personal data to others

5.1 We may disclose your name, email, billing address to our suppliers or subcontractors [accounting suppliers, invoicing suppliers, hosting suppliers, booking or ticketing providers, payment service providers] insofar as reasonably necessary for the purposes of record keeping, invoicing.

5.2 Financial transactions relating to our services may be handled by our payment services providers. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds.

5.3 In addition to the specific disclosures of personal data set out in this Section 5, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise, or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

5.4. Our Service may contain links to other websites that are not operated by us. This Privacy Policy does not address the privacy policy and other practices of any third parties, including any third party operating any website or service that may be accessible via a link on the Service. We strongly advise you to review the privacy policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

6. Retaining and deleting personal data

6.1 This Section 7 sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

6.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

6.3 We will retain your personal data as follows:

(a) Contact data wil be retained for a period of 5 years following the date of the most recent contact between you and us;

(b) Transaction data wil be retained for a period of 5 years following the date of the most recent contact between you and us;

6.4 Notwithstanding the other provisions of this Section 7, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

7. Your rights

7.1 In this Section 8, we have listed the rights that you have under data protection law.

7.2 Your principal rights under data protection law are:

(a) the right to access – you can ask for copies of your personal data;

(b) the right to rectification – you can ask us to rectify inaccurate personal data and to complete incomplete personal data;

(d) the right to restrict processing – you can ask us to restrict the processing of your personal data;

(e) the right to object to processing – you can object to the processing of your personal data;

(f) the right to data portability – you can ask that we transfer your personal data to another organisation or to you;

(g) the right to complain to a supervisory authority – you can complain about our processing of your personal data; and

(h) the right to withdraw consent – to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.

7.3 These rights are subject to certain limitations and exceptions. You can learn more about the rights of data subjects by visiting [https://edpb.europa.eu/our-work-tools/general-guidance/gdpr-guidelines-recommendations-best-practices_en and https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/].

7.4 You may exercise any of your rights in relation to your personal data [by written notice to us, using the contact details set out below].

8. Our details

8.1 We are registered in Romania under registration number J40/10077/2023, and our registered office is at Soseaua Pantelimon, nr.252, Bloc 55A, Scara A, etaj 2, Ap.7, Cam.1, Sector 2, Bucharest.

8.2 You can contact us:

– by email, using contact@autumntales.ro