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Privacy policy

This Privacy Policy of EUREST ROM S.R.L. includes information on processing and protection of personal data within the online platforms of the company, respectively: - the product delivery application (Food4Family), including the parts dedicated to corporate customers; - website-urile www.urban1886.ro www.eurest.ro, www.scolarest.ro, www.delimarche.ro, www.compass-group.ro individually referred to below as „Website”.

1.Identification of the Controller

The company EUREST ROM SRL, having its registered office in Bucharest, District 4, Calea ŞERBAN VODĂ, Nr. 133, CLADIREA B, Etaj 1, registered with the Trade Register under no. J40/5103/23.05.2001, fiscal code / C.U.I.: RO 13904170, as Controller according to the Regulation (EU) 679/2016 (General Data Protection Regulation, hereinafter referred to as „GDPR”), hereby informs you about the processing of personal data, in accordance with GDPR.

2. Data Protection Officer

For any details on the processing of personal data and the exercise of your rights (provided in point 7 of this Privacy Policy), you can contact the Data Protection Officer („DPO”) at the e-mail address gdpr@eurest.ro.

3. Purposes of data processing, categories of personal data processed, legal grounds of processing

A. BROWSING THE SITE

When you visit our website, we use cookies to automatically collect technical information to identify the user, such as IP address, type of internet browser used to browse our site, operating system, name or domain host through which the user browses the site.

We also use cookies to offer you a personalized and relevant experience when browsing our website and to understand how you interact with our advertising content, as the case may be.

For more information on the use of cookies on this website and the purposes for which they are used, as well as on the possibilities to control and/or deactivate these cookies, please consult our cookie policy.

B. CREATING A USER ACCOUNT AND ENSURING THE FUNCTIONALITY OF ACCOUNTS

Using the function of creating an account on the Site (for our Sites that provide this feature) involves providing personal data to ensure identification and authentication of account users, potential measures and security checks and communication between us and the account users (such as first and last name, e-mail, phone number). The basis for processing is performance of a contract to which you are a party (Article 6(1)(b) of GDPR), represented by your acceptance of our Terms and Conditions for the purpose of creating the account.

It is necessary to provide your data in order to generate the account, your refusal leading to the impossibility of creating a valid account.

C. REGISTRATION, RECORDS AND DELIVERY OF ONLINE ORDERS (SALES)

For the purpose of registration, records (on the ordered products) and delivery of orders, we process certain categories of personal data: identification data of the buyer (first and last name), contact/correspondence details (postal address, e-mail address, phone number), delivery address and data related to the products purchased (such as any preferences).

The legal basis for this processing is performance of a contract to which you are a party (Article 6(1)(b) of GDPR), represented by your acceptance of our Terms and Conditions for the purpose of placing the order.

It is necessary to provide your data in order to generate the account, your refusal leading to the impossibility of creating a valid account.

D. ANSWER TO QUESTIONS, NOTIFICATIONS OR COMPLAINTS

To be able to manage communication with you if you ask us questions or send us notifications/complaints, we process certain categories of personal data, such as: identification data (first and last name), contact details (e-mail, phone number, postal address) and any other information or details you may provide within communication with us, necessary or related to your request or communication with you for this purpose.

Processing is based on:

E. MARKETING

We will process your identification data and contact details (e-mail address, phone number) to inform you on the services and products we can offer (for example: new products, promotional offers).

Usually, such personal data will be processed for marketing purposes only based on your consent expressed in advance to receive such communication (Article 6(1)(a) of GDPR) and by using the communication channels (e-mail and/or phone) for which you have expressed your option. However, insofar as you provided us with your e-mail address when purchasing a product or service from us, we may use your e-mail address, in compliance with the legal provisions in force that allow us to present our commercial communications on similar products and services, based on our legitimate interest in this regard (Article 6(1)(f) of GDPR). In such case, when we obtain your e-mail address from you and subsequently, for each marketing message we may send you, we will offer you the option of opposing to the further use of your e-mail address for communication purposes (unsubscribe option). If you refuse to provide us with your personal data, you will not receive communications about our products and services. Revocation of marketing consent is possible at any moment by using the unsubscribe option, which can be found in our marketing messages or by sending an e-mail at the address gdpr@eurest.ro.

F. SURVEYS/CUSTOMER SATISFACTION STUDIES

We will process your personal data when you decide to participate in our surveys, customer satisfaction studies or when you offer feedback (opinions, suggestions etc.) on our products and services. Such personal data will be processed based on your consent expressed through your voluntary option to participate/express your opinion. Therefore, it is your choice whether you provide us with your personal data (such as first and last name, information on your preferences and purchase habits or other personal data you may offer to us), filling in the participation forms on our website/in the application or forms provided by the surveys or studies in question.

G. PROMOTIONS AND CONTESTS - PROMOTIONAL CAMPAIGNS

Within our promotional campaigns we can request (depending on the specifics of the campaign) certain categories of personal data of participants. Your participation in such campaigns and/or promotional contests is voluntary. Therefore, it is your choice to decide whether you provide us with personal data, filling in the participation forms on our website or similar forms provided by the rules of the respective promotional campaigns or contests.

Processing is based on:

- Performance of a contract to which you are a party (Article 6(1)(b) of GDPR), represented by the terms and conditions that govern such promotional campaign (Article 6(1)(b) of GDPR);

- Fulfillment of legal obligations of Eurest Rom S.R.L., related to publication of winners' data and for the calculation and payment of any taxes/duties (Article 6(1)(c) of GDPR); and

- Our legitimate interest to ensure management of potential referrals or analyze certain aspects on campaign development (Article 6(1)(f) of GDPR). More details on the processing of personal data are mentioned in the terms and conditions of the regulation governing each such promotional campaign.

H. RECRUITMENT

When you choose to send us through the Site (for those Sites that have the option to send CV and data related to applications for vacant positions), we will collect and process the data you provide us (included in the online form of the application, as well as data included in the CV, letter of intent), for carrying out the recruitment process for the vacant positions and maintaining a database on applicants for future positions.

Processing is based on:

- Performance of precontractual formalities with the view of concluding the individual employment agreement (Article 6(1)(b) of GDPR);

- The legitimate interest (Article 6(1)(f) of GDPR) of holding certain records and respectively a database (excluding profiling or automated individual processes, when they are not used in the recruitment process), in order to ensure a proper conduct of the recruitment process.

Provision of personal data is necessary in order to carry out the recruitment process and a potential denial from your on data provision will result in the impossibility of going through the recruitment process as far as you are concerned, for the position you want to apply for. Subsequently, we will keep your CV for other recruitments that may be carried out, for a period of maximum 12 months from the date when you sent an application to us. If you don't want to be included in our database for future positions during the aforementioned period, please send us your refusal in this regard at the e-mail address gdpr@eurest.ro

4. CATEGORIES OF PROCESSORS (entities providing services and ensuring support in the processing of personal data, under our coordination)

In carrying out the various processing activities subject to this policy the following categories of processors are involved: providers of development/maintenance, hosting and IT security services; providers of marketing and related services, recruitment, other contractual partners collaborating with us for the purpose of providing our services/products, involved in our activity.

5. CATEGORIES OF RECIPIENTS (entities that may receive/access/use the processed personal data)

The following categories of recipients may have access to your personal data: processors that assist us in carrying out the processing activities; other contractual partners providing services (consultants, auditors, as the case may be), to central/local public authorities - upon request, as well as to other companies within our group, for purposes of centralizing information on the activity of our company at group level and only ensuring the adequate proportionality of disclosure (the minimum necessary personal data in relation to the purpose of disclosure) and the appropriate safeguards for the transfer of data abroad, as applicable.

6. TRANSFER OF PERSONAL DATA TO OTHER COUNTRIES

Personal data subject to processing are usually processed in Romania. However, the data may be transferred, for determined and justified purposes, to countries in the European Union, which ensure an adequate level of data protection. If it is necessary to make any transfer outside the European Economic Area, we will ensure the appropriate safeguards for this purpose, according to GDPR requirements.

7. ESTIMATED DURATION OF PROCESSING

Personal data will be processed for the duration necessary to reach the purpose of processing and, subsequently, for purposes of archiving/keeping for the protection of our rights/legitimate interests, when such need is established (e.g. in case of investigation, dispute etc.). Upon expiry of the applicable duration, the personal data will be irreversibly erased/anonymized, as the case may be, based on the relevant data protection procedures at the level of Eurest Rom S.R.L.

8. PROCESSING OF PERSONAL DATA OF PERSONS UNDER THE AGE OF 18 YEARS

All processing of personal data presented in this document and carried out by Eurest Rom S.R.L. through online platforms (websites, applications etc.) refer exclusively to persons who are at least 18 years old. The use of systems and the results of processing are conditional for children between 14 and 18 years of age upon approval by the parents/guardian and are forbidden for children under 14 years of age, unless the consent of their parents/guardian has been obtained. If such processing takes place, despite our reasonable efforts to prevent it, we will cease processing if we become aware that users to not follow the above rules.

9. YOUR RIGHTS REGARDING THE PROTECTION OF YOUR PERSONAL DATA AND EXERCISING THEM

In the context of processing of your personal data, you benefit from the following specific rights:

- Right of access (to obtain from the controller confirmation as to whether or not your data are being processed and, where that is the case, relevant details on processing);

- Right to rectification (if your data are inaccurate);

- Right to erase the data (under certain conditions, as well as when the data are no longer necessary);

- Right to withdraw consent when it was granted, without, however, affecting the lawfulness of the processing previously carried out;

- Right to object (to oppose to processing under the conditions of the applicable legislation - General Data Protection Regulation);

- Right not to be subject to a decision based solely on automated processing, including profiling;

- Right to restriction of processing (in some cases, such as when you claim that the data are inaccurate);

- Right to data portability (to receive the personal data you previously provided in a structured, commonly used and machine-readable format and to request the transmission of such data to another Controller);

- Right to address to the relevant data protection authority (ANSPDCP) and competent courts. Below you can read more details about these rights:

Right of access

You have the right to obtain confirmation as to whether or not your personal data are processed and, if they are processed, to have access to the categories of personal data and conditions of processing, by sending a request in this regard to the data controller.

Right to request rectification or erasure of personal data

You have the right to request the data controller to rectify the inaccurate personal data, to complete the incomplete data or erase your personal data if (i) the data are no longer necessary in relation to the purposes for which they were initially processed (and there is no new legal purpose), (ii) the legal basis of processing is your consent and you withdraw your consent in conditions in which there is no other legal ground for processing, (iii) you exercise the right to object and the controller has no legitimate reasons to continue processing, (iv) the data were unlawfully processed, (v) erasure is necessary to comply with EU legislation or Romanian legislation or (vi) the data was collected in relation to information society services provided to children (if applicable), where specific consent requirements apply

Right to restriction of processing

You have the right to request restriction of processing where one of the following applies:

• you consider that your personal data processed are inaccurate, for a period enabling the controller to verify the accuracy of the personal data;

• the processing is unlawful and yet you do not want us to erase your data, but restrict the use of the data;

• if the controller no longer needs your personal data for the purposes mentioned above, but you request the data for the establishment, exercise or defense of legal claims or

• you have objected to processing pending the verification whether the legitimate grounds of the controller override yours;

Right to withdraw your consent - when processing is based on consent, without affecting the lawfulness of processing carried out based on it until withdrawal;

Right to object to the processing of data

You may object to the processing of data for reasons related to your particular situation, when the processing is based on a legitimate interest. You may also object to the processing of data for direct marketing purposes, including profiling, at any time. The right not to be the subject of a decision exclusively based on automated processing, including profiling, which produces legal effects that concern you or similarly affects you to a significant extent;

Right to data portability

You have the right to receive the personal data which you have provided to the controller, in a structured, commonly used and machine-readable format and the right to transmit those data to another controller, if processing is based on your consent or on a contract and is carried out by automatic means. The exercise of the above rights may be performed at any time. To exercise the aforementioned rights, please contact us using the contact details included in section 2 - Data Protection Officer.

Right to lodge a complaint with the competent Supervisory Authority at national level (National Supervisory Authority for Personal Data Processing - ANSPDCP - https://www.dataprotection.ro/) and the right to apply to the competent courts.

10. Amendments

We reserve the right to amend this Privacy Policy at certain intervals, in which case we will visibly report subsequent changes to users.

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