Obsentum Privacy Policy

The company is committed not only to providing you with products of the highest quality standards and at an unbeatable price, but also to ensuring the highest degree of protection of your personal data. The Company processes a range of personal data of Members / potential Members (including Users when they access the Website).

This privacy policy ("Policy") describes what types of personal data are processed, how they are used, what your choices are in relation to such processing, and how the Company will respect your rights as a data subject under personal data protection law, including Regulation (EU) 2016/679 ("GDPR").

Throughout this Privacy Policy, the terms personal data, controller, processing, basis of processing, purpose of processing, data subjects shall have the meaning given by the GDPR.

BEFORE USING THE WEBSITE, WE RECOMMEND THAT YOU READ THIS POLICY CAREFULLY TO UNDERSTAND HOW YOUR PERSONAL DATA IS PROCESSED.

Who is responsible for processing your data?

Millenium ProDesign SRL, Str. Sulfinei nr.3, Otopeni, Jud. Ilfov, is the controller of personal data, in accordance with the legislation on personal data protection including GDPR, regarding the personal data of Users collected and processed through the Website.

What data do we process?

Data you provide directly

When you create a user account you must provide us with a number of details such as: first name, last name, e-mail address, mobile phone number (optional).

When you purchase a product as a Customer, we process the following categories of data for billing purposes: delivery address, billing address (to the extent they are not identical), e-mail, and telephone number.

We also collect and process data resulting from orders placed and transactions carried out with us.

You may provide us with additional personal data when you contact us by any means of communication (e.g. requests sent by e-mail, via the Website interface or by telephone).

Data collected or generated by Us as a result of your interaction with Us / the Website -

We log information about how you use the Website, such as when you access your Account or purchase products from the Obsentum.com Platform, including how you use the Website as a User.

In addition to personal information, our systems automatically collect a variety of anonymous information that helps us better understand how the Website is used and how we can improve our Services. This data includes the IP address of the computer with which you access the Website, the operating system used, the browser software used and the time spent in the Account.

We also use cookies and similar technologies to recognise you and your devices. We also allow others to use cookies. How we use these technologies are described in our Cookie Policy.

We receive information about your visits and interaction with services provided by other entities when you visit other providers' services that include advertisements, cookies or similar technologies.

Why do we process your personal data?

1. Account Creation and Use of the Services by Users

   We process the data in the context of enrolling in the Obsentum Platform and creating the Online Account.

   We also process your data in the context of orders placed through the Obsentum Platform.

   Legal basis: conclusion and performance of the contract

2. Member/Customer Relationship Management and Support Services All telephone conversations we have with Members or other callers are recorded. Persons who do not wish to be registered may contact us at [email protected] or by sending a written request to the correspondence address indicated on the Website.

   Recording calls helps us to manage our internal work in the relevant department and is also an essential means of evidence to prove the issues discussed with the User / person contacting us by phone. These records may also be used to check how claims have been dealt with, or as evidence in the event of any disputes/disputes relating to the way we manage our business in relation to our Customers.

   Legal basis: legitimate interest for the recording of the conversation - consent and legitimate interest if the recordings are subsequently necessary to defend our rights and interests in court, conduct disciplinary investigations of our employees, or are otherwise necessary in managing our business with Users

3. Sending commercial communications, invitations to participate in competitions, questionnaires or surveys We intend to send you commercial communications (such as announcements about Campaigns and other promotional sweepstakes, offers, news on available products, etc.), to issue invitations to participate in surveys, or to respond to questionnaires, as well as to communicate other similar information that we believe may be of interest to you. These communications will be transmitted if we have your consent.

   You can unsubscribe from these communications at any time by pressing the "Unsubscribe" button in any email communication or by contacting us at [email protected].

   If you withdraw your consent to commercial communications we will no longer be able to send you our offers or you will not be able to participate in our surveys and questionnaires. Legal basis: consent

4. Participation in promotional lotteries organised by us

   You can participate in competitions and prize draws organised by us and our partners. We will enter you in competitions/promotions if you enter voluntarily or otherwise if we have your consent.

   If you withdraw your consent you will no longer be eligible to participate in our competitions / lotteries.

   Legal basis: consent

5. Analysing your interaction with the Company in order to provide personalised offers and optimise our business

   We can carry out various reports, analyses and statistical studies on the marketing campaigns organised and their success, or on the Company's sales activity.

   In certain situations, we may use information collected from you in combination with data we obtain from our sales and/or marketing teams about your interaction with the Company to use in the context of our marketing communications. We want to streamline our marketing activity by providing our customers with relevant and personalised products/services.

   Legal basis: interest and consent (in case of advanced marketing analysis)

6. Analysis and statistics on the functioning of the Website, cookies and similar technologies

   We also use cookies and other similar technologies in our analysis and statistics in accordance with our Cookie Policy.

   Cookies and similar technologies are also used to deliver interest-based advertising to you.

   Legal basis: legitimate interest Depending on the type of cookies used and similar technologies, the legal basis is: legitimate interest or User consent.

7. Formalities for awarding claimed prizes, investigation of fraud, application of competition rules

   If you have been declared a winner of our competitions and have claimed the prize(s), depending on the type of prize awarded, we may need to process certain personal data (e.g. where the prizes consist of certain goods/services for which the provision of personal data may be required).

   Legal basis: legitimate interest

8. We may process certain data for the resolution of any complaints in relation to the organisation and conduct of the campaigns and the awarding of prizes; the enforcement of the provisions of the campaign rules, including the investigation of possible violations of their provisions.

   Legal basis - legitimate interest and fulfilment of legal obligations.

9. Fulfilment of legal obligations incumbent on us, such as:

   • operations relating to the invoicing of purchased products;
   • paying relevant taxes and contributions, reporting to the relevant tax authorities and keeping accounting records;
   • publication of the names of winners and prizes awarded in prize competitions;
   • archiving data in accordance with applicable law.

   Defending the rights and interests of the Company in legal, administrative or similar proceedings

   The Company may also process your personal data for the establishment, exercise or defence of a legal claim in court, administrative or other official proceedings in which the Company is involved.

   Legal basis: fulfilment of legal obligations

Who do we disclose data to?

We may disclose personal data to:

1. partners of the Company, such as, partners involved in organising our campaigns/contests and awarding prizes, notary publics/lawyers appointed to assist in organising and running prize competitions;
2. providers of services related to marketing activities - marketing agencies, companies providing e-mail marketing services;
3. courier service providers, mobile telephony;
4. web development and maintenance service providers; web hosting and data centre service providers;
5. providers of the email/cloud communication platforms that the company uses;
6. public authorities or other categories of recipients, if the disclosure is based on a proper legal basis (such as a legal obligation, consent or legitimate interest);
7. third party providers of cookies and similar technologies as described in the Cookie Policy.

How long do we keep the data?

We retain your personal data for as long as necessary to fulfil the purposes for which it was collected, subject to internal data retention procedures, including applicable archiving rules.

In general, Users' data is kept as long as they have an active Online Account. If a User is inactive for more than 36 months, the Company may deactivate his/her Account and delete the related personal data. Users may at any time request deactivation of the Account and deletion of personal data. Certain personal data of Members may be kept for the entire period required by law for the archiving and storage of financial and accounting documents.

Data related to cookies and similar technologies are stored according to the specific terms set for those technologies, the storage period can be between the duration of the browsing session and up to 2 years.

What rights do you have as a data subject?

Under the law, you have the following rights as a data subject.

1. Right of access: you can obtain confirmation from us that we are processing your personal data, as well as information on the specifics of the processing;
2. The right to correct data: you can ask us to amend your personal data that is incorrect or, where applicable, to complete data that is incomplete;
3. Right to erasure: you can request the deletion of personal data when: (i) they are no longer necessary for the purposes for which we collected and process them; (ii) you have withdrawn your consent to the processing of the data and we can no longer process them on other lawful grounds; (iii) the data are processed unlawfully; or (iv) the data must be erased in accordance with the relevant legislation;
4. Withdrawal of consent and right to object: you may withdraw your consent to the processing of data based on consent at any time. You may also object at any time to processing for marketing purposes, including profiling carried out for this purpose, as well as to processing based on the legitimate interest of the Company, for reasons relating to your specific situation;
5. Right to restrict processing: under certain conditions you can request restriction of the processing of your personal data;
6. Right to data portability: to the extent that we process data by automated means, you can ask us, under the law, to provide your data in a structured, frequently used and machine-readable form. If you request us to do so, we may transmit your data to another entity if technically possible.
7. Right to lodge a complaint with the supervisory authority: you have the right to lodge a complaint with the data processing supervisory authority if you consider that your rights have been infringed:

National Authority for Personal Data Supervision in Romania B-dul G-ral. Gheorghe Magheru 28-30 Sector 1, postal code 010336 Bucharest, Romania [email protected]

TO EXERCISE THE RIGHTS MENTIONED ABOVE, YOU MAY CONTACT US USING THE CONTACT INFORMATION MENTIONED IN SECTION 1 (MILLENIUM PRO DESIGN S.R.L., Str. Sulfinei nr.3, Otopeni, Jud. Ilfov, for the attention of Mrs Oana Preda, e-mail: [email protected] ).

The Company can also be contacted using the contact details and mechanisms available on the Website. Members can also exercise certain rights (right to edit, rectify, oppose commercial communications or delete) directly on the Website via the settings in the MY ACCOUNT section.