Last updated: August 2018

I. General Information

The confidentiality of your personal data is one of the main concerns of SC PerfectSwim SRL, Tax ID: 33530755, RC:J12/2552/29.08.2014, Ion Mihalache Street, no. 7, Cluj Napoca, Cluj County, Romania, as data controller.

This document aims to inform you about the processing of your personal data in the context of using the website www.babyswim.ro.

II. Categories of Personal Data Processed

If you are a visitor to the site, PerfectSwim SRL will process your personal data that you provide directly in the context of using the site, such as the data you provide in the contact section, if you contact us by email, for the purpose of communication initiated by you.

III. Purposes and Legal Basis of Processing

If you are a visitor to the site, PerfectSwim SRL processes your personal data as follows:

• for marketing activities, namely for sending, through remote communication means (email, SMS), commercial communications regarding the products and services offered by PerfectSwim SRL through the site. Legal basis: The processing of your data for this purpose is based on your consent, if you choose to provide it. Providing your data for this purpose is voluntary.
• for resolving complaints, claims and to monitor traffic and improve your experience on the site. Legal basis: The processing of your data for this purpose is based on the legitimate interest of PerfectSwim SRL to ensure the proper functioning of the site, as well as to continuously improve the experience of site visitors, including by resolving various comments, questions or complaints.

IV. Duration for Which We Process Your Data

As a principle, PerfectSwim SRL will process your personal data for as long as necessary to achieve the processing purposes mentioned above.

If you are a customer, we will process your data for the entire duration of the contractual relationship and subsequently according to the legal obligations incumbent upon PerfectSwim SRL (e.g., in the case of financial-accounting supporting documents for which the retention period provided by law is 10 years from the end of the financial year during which they were prepared).

V. Disclosure of Personal Data

To fulfill the processing purposes, PerfectSwim SRL may disclose your data to partners, to third parties or entities that support PerfectSwim SRL in carrying out activities through the site (for example IT service providers), or to central/local public authorities, in the following cases listed as examples:

• for site administration;
• in situations where this communication would be necessary for awarding prizes or other benefits to data subjects, obtained as a result of their participation in various promotional campaigns organized by PerfectSwim SRL through the site;
• for maintaining, customizing and improving the site and the services provided through it;

VI. Transfer of Personal Data

Personal data provided to PerfectSwim SRL may be transferred outside Romania, but only to states within the European Union.

VII. Your Rights

Under the conditions provided by legislation on the processing of personal data, as data subjects, you benefit from the following rights:

• the right to information, namely the right to receive details regarding the processing activities carried out by PerfectSwim SRL, as described in this document;
• the right of access to data, namely the right to obtain confirmation from PerfectSwim SRL regarding the processing of personal data, as well as details regarding processing activities such as how the data is processed, the purpose for which the processing is carried out, the recipients or categories of recipients of the data, etc.;
• the right to rectification, namely the right to obtain correction, without undue delay, by PerfectSwim SRL of inaccurate/unjustified personal data, as well as completion of incomplete data; The rectification/completion will be communicated to each recipient to whom the data has been transmitted, except where this proves impossible or involves disproportionate effort.
• the right to erasure of data, without undue delay, (“the right to be forgotten”), if one of the following reasons applies:
  • they are no longer necessary for the purposes for which they were collected or processed;
  • if consent is withdrawn and there is no other legal basis for processing;
  • if the data subject objects to the processing and there are no overriding legitimate grounds;
  • if the personal data has been processed unlawfully;
  • if the personal data must be erased to comply with a legal obligation;
  • the personal data has been collected in connection with the provision of information society services in accordance with Union law or national law under which the controller falls.

It is possible that, following a request for data erasure, PerfectSwim SRL may anonymize this data (thus depriving it of its personal character) and continue under these conditions processing for statistical purposes; the right to restriction of processing to the extent that:

• the person contests the accuracy of the data, for a period that allows us to verify the correctness of the data;
• the processing is unlawful, and the data subject opposes the erasure of the personal data, requesting instead the restriction of their use;
• the controller no longer needs the personal data for the purposes of processing, but the data subject requests them for the establishment, exercise or defense of a legal claim; or the data subject has objected to processing (other than direct marketing), for the period of time in which it is verified whether the legitimate rights 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, as well as (ii) the right to have this data transmitted by PerfectSwim SRL to another data controller, to the extent that the conditions provided by law are met;
• the right to object – regarding processing activities, it can be exercised by submitting a request as indicated below;
• at any time, for reasons related to the particular situation of the data subject, that data concerning them be processed on the basis of the legitimate interest of PerfectSwim SRL or on the basis of public interest, except in cases where PerfectSwim SRL can demonstrate that it has compelling legitimate grounds which justify the processing and which override the interests, rights and freedoms of data subjects or that the purpose is the establishment, exercise or defense of a legal claim;
• at any time, free of charge and without any justification, that data concerning them be processed for direct marketing purposes.
• the right not to be subject to automated individual decision-making, namely the right not to be the subject of a decision based solely on automated processing activities, including profiling, which produces legal effects concerning the data subject or similarly significantly affects them;
• the right to address the National Supervisory Authority for the Processing of Personal Data or the competent courts, to the extent that you consider it necessary.

For any additional questions regarding how personal data is processed and to exercise the rights mentioned above, please contact us at the email address: info@babyswim.ro.

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