WHAT PERSONAL DATA DO WE COLLECT?

We may collect the following information about you:

  • your name, age/date of birth and gender;
  • your contact details: postal address including billing and delivery addresses, telephone numbers (including mobile numbers) and e-mail address;
  • purchases and orders made by you;
  • your social media handles;
  • your online browsing activities on any of our websites including what items you store in your shopping bag;
  • your password(s);
  • information about the device you use to browse our websites including the IP address and the device type;
  • when you make a purchase or place an order with us, your payment card details;
  • your communication and marketing preferences;
  • your interests, preferences, feedback and competition and survey responses;
  • your location;
  • your correspondence and communications with us; and
  • other publicly available personal data, including any which you have shared via a public platform (such as Instagram, YouTube, Twitter or public Facebook page).

This list is not exhaustive and, in specific instances, we may need to collect additional data for the purposes set out in this Notice. Some personal data are collected directly, for example when you set up an online account on our websites, or send an email to our Customer Relations team. Other personal data are collected indirectly, for example, when you browse our websites or undertake online shopping activity. We may also collect personal data from third parties who have your consent to pass your details to us, or from publicly available sources.

We may anonymise and aggregate personal data for insight and research but this will not identify anyone.

Our websites are not intended for children and we do not knowingly collect data relating to children.

HOW WE USE YOUR DATA

General

Rosenberg & Partners Trading SRL (and trusted partners acting on our behalf) use your personal data:

  • to provide goods and services to you;
  • to make a tailored website available to you;
  • to manage any account(s) you hold with us;
  • to verify your identity;
  • for crime and fraud prevention, detection and related purposes;
  • to contact you electronically about promotional offers, events, products and services which we think may interest you;
  • for analysis, insight and market research purposes to better understand your needs and ensure we are giving you what you like;
  • to administer competitions and identify and contact competition winners;
  • to enable us to manage customer service interactions with you; and
  • where we have a legal right or duty to use or disclose your information (for example in relation to an investigation by a public authority or in a legal dispute).

Marketing

Rosenberg & Partners Trading SRL use your personal data for marketing purposes and may send you postal mail, texts and/or emails to update you on our latest offers and events.

We aim to update you about products and services of interest and relevance to you as an individual.

You have the right to opt out of receiving promotional communications at any time, by:

  1. contacting our Customer Relations team via email office@comerciantidediamante.ro or by telephone on 004 0764 704 704 or post to Customer Relations,Calea Dorobanti 172-174, Bloc 16, 010582 Bucharest ; or
  2. making use of the simple "unsubscribe" link in our emails.

This may not stop service messages such as order updates.

Personalisation and Automated Decision Making

In order to improve your shopping experience with us, when you visit any of our websites, you may receive personalised banner advertisements whilst browsing websites of other companies. Any banner advertisements you see will relate to your browsing activity on our websites from your computer or other devices.

These advertisements are provided by us via external market leading specialist providers using 'cookies' placed on your computer or other devices (see further information on the use of cookies in our Cookie Policy ). 

We may collect data directly from you, as well as analysing your browsing and purchasing activity, both online and in store, and your responses to marketing communications. The results of this analysis, together with other demographic data, allow us to ensure that we contact you with information on products, services, events and offers that are relevant to you. To do so, we use software and other technology (automated decision-making including profiling).

We may do this to decide what marketing communications are suitable for you and this activity is based on our legitimate interests to develop and improve our products and services for you.

In order to provide more personalised services and experiences, we may also ask your permission to review third party data about you, for example, your Twitter or Facebook feeds, to get to know you better and to provide more effective personalisation. Some of our services enable you to sign-in via a third party service, such as Facebook. If you choose to sign-in via a third party app, you will be presented with a dialog box which will ask your permission to allow us to access your personal information (e.g. your full name, date of birth, email address and any other information you have made publicly accessible).

SHARING DATA WITH THIRD PARTIES

We will never sell or rent your personal information to other organisations for marketing purposes.

We will not disclose your personal information to any third party, except for those referred to below. 

We may share your data with:

  • other companies within our group;
  • purchasers, investors, funders and advisers if we sell our business or assets or restructure whether by merger, re-organisation or otherwise;
  • our legal and other professional advisers, including our auditors;
  • credit reference agencies where necessary for card payments;
  • governmental bodies, regulators, law enforcement agencies, courts/tribunals and insurers where we are required to do so:- 
    to comply with our legal obligations and/or the administration of justice; 
    to exercise our legal rights (for example in court cases); 
    for the prevention, detection, investigation of crime or prosecution of offenders; and 
    for the protection of our employees and customers.
  • our service providers and suppliers.

In order to make certain services available to you, we have partnered with certain trusted third parties including IT, mailing, payment services, delivery and marketing service providers. We may need to share your personal information with some of our service partners. We only allow our service providers to handle your personal information when they have confirmed that they apply appropriate data protection and security controls. We also impose contractual obligations on service providers relating to data protection and security, which mean they can only use your information to provide services to us and to you, and for no other purposes.

LEGAL BASIS FOR USING DATA

We are required to set out the legal basis for our 'processing' of your personal data.

We collect and use customers' personal data:

  1. as necessary to perform our contract with you 
    - for the purposes of complying with our duties and exercising our rights under contracts for the sale of goods or services to customers; or
  2. as necessary for the pursuit of our legitimate interests including: 
    - selling and supplying goods and services to our customers; 
    - promoting, marketing and advertising our products and services; 
    - sending promotional communications which are relevant and tailored to individual customers (including administering loyalty schemes); 
    - to administer competitions and promotions and identify and contact competition winners; 
    - understanding our customers' behaviour, activities, preferences, and needs; 
    - improving existing products and services and developing new products and services; 
    - protecting customers, employees and other individuals and maintaining their safety, health and welfare; 
    - good governance, accounting and managing and our operations and complying with our legal obligations; 
    - preventing, investigating and detecting crime, fraud or anti-social behaviour and prosecuting offenders, including working with law enforcement agencies; 
    - handling customer contacts, queries, complaints or disputes; 
    - managing insurance claims by customers; 
    - protecting our company, its employees and customers, by taking appropriate legal action against third parties who have committed criminal acts or are in breach of legal obligations to us; 
    - handling any legal claims or regulatory enforcement actions taken against us; and 
    - fulfilling our duties to our customers, colleagues, shareholders and other stakeholders or
  3. as necessary for complying with our legal obligations including 
    - where you exercise your rights under data protection laws; 
    - for compliance with legal and regulatory requirements; or 
    - to establish or defend our legal rights; or
  4. based on your consent

You have the right to withdraw consent at any time. Where consent is the only legal basis for processing your personal data, we will cease to process your personal data for that purpose after consent is withdrawn.

 

HOW WE PROTECT YOUR DATA

Our controls

Rosenberg & Partners Trading SRL is committed to keeping your personal data safe and secure.

Our security measures include:

  • encryption of data;
  • regular cyber security assessments of all service providers who may handle your personal data;
  • regular planning to ensure we are ready to respond to cyber security attacks and data security incidents;
  • daily penetration testing of systems;
  • security controls which protect the our IT systems infrastructure and our premises from external attack and unauthorised access; and
  • internal policies setting out our data security rules for our personnel
  • regular training for our employees.

WHAT YOU CAN DO TO HELP PROTECT YOUR DATA

You should always be cautious when sharing your personal data. No one from our company will ever ask you to confirm any bank account or credit card details via email. If you receive an email claiming to be from Rosenberg & Partners Trading SRL asking you to do so, please ignore it and do not respond.

If you are using a computing device in a public location, we recommend that you always log out and close the website browser when you complete an online session.

In addition, we recommend that you take the following security measures to enhance your online safety:

  • keep your account passwords private because anyone who knows your password may access your account or be compromised if your account is accessed without authority.
  • when creating a password, use a difficult word/number combination of at least 8 characters and something that is not easily guessed by hackers such as dictionary words, your name, email address, or other personal data that can be easily obtained. Also, frequently change your password. 
  • avoid using the same password for different online accounts.

HOW LONG WE KEEP YOUR DATA

We will not retain your data for longer than necessary for the purposes set out in this Notice. Different retention periods apply for different types of information, and our Data Retention Policy sets out the length of time we will usually retain personal data and where these default periods might be changed.

In summary, various laws, accounting and regulatory requirements applicable to us require us to retain certain records for specific amounts of time. In relation to your personal data, we will hold this only for so long as we require that personal data for legal or regulatory reasons or for legitimate organisational purposes and we will not keep your data for longer than is necessary for the purposes for which we collect them.

INTERNATIONAL TRANSFERS

To deliver products and services to you, it is sometimes necessary to share your personal information outside of the European Economic Area (the EEA). This will typically occur when service providers are located outside the EEA or if you are based outside the EEA. These transfers are subject to special rules under data protection laws.

If we transfer your personal information outside the EEA, we will ensure that the transfer will be compliant with data protection law and all personal data will be secure. Our standard practice is to assess the laws and practises of the destination country and relevant service provider and the security measures that are to be taken as regards the data in the overseas location; Alternatively, we use standard data protection clauses.

YOUR RIGHTS

You have the following rights:

  • the right to be informed about our processing of your personal data which is the aim of this Notice;
  • the right to request access to personal data that we hold about you at any time;
  • the right to ask us to update and correct any out-of-date or incorrect personal data that we hold about you;
  • the right to object to processing of your personal data and/or to withdraw any consent you have given us and to opt out of any marketing communications that we may send you.
  • the right to prevent processing that is likely to cause damage or distress to you or anyone else;
  • the certain rights in relation to automated decision-making processes including the right to object to profiling;
  • the right to request that we erase or destroy your personal data in certain circumstances (the right to be forgotten) for example when the data are no longer necessary for the purpose for which we collected them;
  • the right to have your personal data provided to you by us in a structured, commonly used and machine-readable format and the right to have that data transmitted to another data controller. This is known as the right to data portability.