Imprint

This document called Privacy Policy (“Privacy Policy”) is intended to help you understand the information we collect when you visit www.alexakosmetik.com (hereinafter named the “Site”), whether you are or not you are registered, and also describe how we use such information.
Where appropriate, this privacy policy will also describe how we process the information you provide us or we collect about you when you visit the stores directly managed by us (“Stores”) or during any other contacts with us. The present policy is complementary to any other information provided under other circumstances.

This Site is a site with a general audience; nevertheless, our services are for people aged 16 or over. We do not request, collect, use, or disclose personal data provided by a person under the age of 16, both online and in our Stores. If we found out that we have collected personal data from a child, we will delete such data.

If you are under 16, please do not register or proceed with your online purchase and request the assistance of an adult (one of your parents or legal guardians) to proceed with the necessary procedures.

Who are we?
Abenor Kosmetik S.R.L .is a fresh company, duly established and functioning in accordance with Romanian law, with registered office in Braila, no. 60 Ap.57 registered with the Trade Registry under no. J09 /698 /2019, Unique Registration Code 41540482.

This document gives you important information regarding the following issues:
1. PERSONAL DATA OPERATOR
2. STORAGE OF PERSONAL DATA
3. WHO HAS ACCESS TO PERSONAL DATA
4. WHAT IS THE LEGAL GROUND FOR PROCESSING
5. YOUR RIGHTS AND EXERCISE OF THE RIGHTS
6. PROCESSING OF PERSONAL DATA
7. COLLECTED PERSONAL DATA
8. HOW WE USE PERSONAL DATA
9. PERSONAL DATA SECURITY AND CONFIDENTIALITY
10. RIGHT TO LODGE A COMPLAINT WITH A SUPERVISORY AUTHORITY
11. CONFIDENTIALITY POLICY UPDATE

By visiting our Site, by using its services or, interacting in any other way with us, through our sales points, newsletters and/or sites, you acknowledge to have read and understand this Privacy Policy and agree to that we may collect, use, transmit and disclose personal data that we collect through our Sites and Stores, in accordance with this Privacy Policy. If you have not already registered, we may ask you to register (for instance, by ticking a check box) if we consider it is appropriate to protect your rights or if it is required by relevant laws. If you do not agree with the terms of this Privacy Policy, please do not access this Site, do not create an account, and do not use or send personal information to this Site or do not register when this option is offered to you in accordance with relevant laws.


1. PERSONAL DATA OPERATOR
Abenor Kosmetik S.R.L. is the operator of the personal data you provide us and is responsible for your personal data in accordance with the relevant law in terms of data protection (hereinafter referred to as collectively, “Abenor Kosmetik”, “we”, “us” or “ours” in this Privacy Policy).

Our contact details are:
ABENOR KOSMETIK S.R.L.
Braila, ROMANIA
Calarasilor street No. 60 Ap.57
J09 /698 /2019, RO 41540482
E-mail: office@alexakosmetik.com

The CEO of Abenor Kosmetik S.R.L. as the owner of the webstore alexakosmetik.com will permanently ensure that we process personal data in an open, accurate and legal manner. You may contact the CEO of Abenor Kosmetik at the address office@alexakosmetik.com, mentioning DPO in the subject of the message.

2. PERSONAL DATA STORAGE
The data we collect from you is stored in the Abenor Kosmetik data centre of Romania.

3. WHO HAS ACCESS TO PERSONAL DATA
We do not transmit, sell, or cede your personal data to third parties for marketing purposes outside the ABENOR KOSMETIK company. The data sent to third parties is used only in order to provide you our services. You will find the categories of third parties in each specific process mentioned here below.

Part of the collected data will be transferred to a third party for:
1. ORDERS DISPATCH to you – in this situation, we will transfer your contact details to the courier companies, or/and DEUTSCHE POST that deliver the orders and cash in their counter value on our behalf;

4. WHAT IS THE LEGAL GROUND FOR PROCESSING
Depending on the scope for which the data are used, the basic legal grounds for processing your data may be the following:
• Your consent;
• Our legitimate interest, which could be:
a. Improving our products and our services: more precisely, our business interests to help us understand even better your needs and expectations, and thus improve our services, sites/applications/devices, products and brands in the benefit of our consumers;
b. Fraud prevention: to make sure that payment is complete and no fraud has been committed.
c. Securing our instruments: keeping your instruments safe (our sites/applications/devices) and ensuring that they work properly and that they are undergoing a continuous process of improvement.
• Fulfilment of a contract: more precisely, to carry out the services you request from us;
• Legal reasons for which data processing is required by law.
For every specific processing of the personal data we collect from you, we will inform you whether the provision of personal data is required by regulations in force or whether it is necessary to sign a contract, whether it is obligatory to provide us with your personal data and what are the possible consequences in case of your refusal.

5. YOUR RIGHTS AND EXERCISE OF RIGHTS
The right of access means that you have the right to obtain a confirmation from ABENOR KOSMETIK on whether we are processing your data or not, and if so, to grant you access to these data as well as to information on the processing.

The right to rectification means that you have the right to request the rectification of your personal data if these data are incorrect, including the right to fill in incomplete personal data. If you have a ABENOR KOSMETIK account, then you can edit your personal data from your account.

The right to delete the data means that you have the right to obtain at any time the deletion of the personal data processed by ABENOR KOSMETIK in any of the following cases: the data are no longer necessary for the purposes for which they were collected or processed; you withdraw your consent and there are no other legal grounds for the processing; you oppose the processing; data were processed illegally; the data must be deleted for conformity with a legal obligation or the collection has been made in respect with the provision of information society services.
Nevertheless, your data shall be retained to finalise the following situations:
* you have an unsolved request submitted to Customer Service;
* you have an open order that has not yet been shipped or partially shipped;
* you have an unpaid debt at ABENOR KOSMETIK, regardless of the method of payment;
* if you have made a purchase, we will keep your personal data in relation with your transaction in compliance with accounting legislation in force.

The right to restrict processing means you have the right to obtain restriction of processing in the following cases:
* if you dispute the accuracy of the data, for a period that permits ABENOR KOSMETIK to verify data accuracy;
* if the processing is illegal, and you are opposed to the deletion of your personal data, requesting instead the restriction of their use;
* if you have opposed your processing, for the length of time, it is being verified that ABENOR KOSMETIK’s legitimate rights override your rights;
* if ABENOR KOSMETIK no longer requires your personal data, but they are required to defend your rights in court.

The right to portability refers to the fact that you have the right to obtain your personal data in a structured format, currently used and that can be readable automatically, and you are entitled to communicate these data to another data operator.

The right to oppose means that you have the right to oppose the processing of your personal data on the grounds of the legitimate interest of ABENOR KOSMETIK. ABENOR KOSMETIK will not continue to process personal data unless we can prove a legitimate, solid reason for this processing, a reason that prevails over your interests and rights or if the processing is done based on court procedures.

The right to refuse the automated decision-making process that you have the right not to be the subject of a decision based exclusively on automatic processing, including profile creation, unless you have explicitly expressed your consent or automatic processing is not necessary to sign or perform a contract.

Your right to oppose direct marketing:
You have the right to oppose direct marketing, including also profile analysis for direct marketing purposes.

You may unsubscribe from direct marketing by following the instructions in each marketing e-mail or in a letter sent by any of the contact methods mentioned in the present document.

How can you exercise your rights?
We gave high importance to personal data protection and, consequently, we have dedicated customer support personnel to handle all your requests for your rights mentioned above. Our dedicated staff is always available at the following address office@alexakosmetik.com.

6. PERSONAL DATA PROCESSING
“Personal data” means any information relating to an identified or identifiable natural person (“data subject”); an identifiable natural person is a person who can be identified, directly or indirectly, especially by referring to an identifier, such as a name, an identification number, location data, an online identifier, or one or several specific elements of his/her physical, physiological, genetic, psychic, economic, cultural or social identity;

“Processing” means any operation or set of operations performed on personal data or on personal data sets, carried out with or without the use of automated means such as the collection, recording, organization, structuring, storage, adaptation or modification, extraction, consultation, use, disclosure by transmission, dissemination or available in any other way, alignment or combination, restriction, erasure or destruction;

“Operator” means a natural or legal person, a public authority, an agency or other authority that, on its own or with others, establishes the purposes and means of the personal data processing; where the purposes and means of processing are set out by the European Union law or by national law, the operator or the specific criteria for its designation may be established in the Union or national law;
When we use the term “personal data” within this privacy policy, we refer to any information that permits us to identify you or a third party whose personal data you provide to us, directly or indirectly, by enclosing any information that refers to the purchase of goods or services; or to the information you have chosen to transmit or share with us or with third parties while using the Website or our Stores.

We will process your personal data in compliance with Regulation (EU) 2016/679 “GDPR Regulation” and with the Romanian legislation. We reserve the right to carry out further processing within the limits of the law in a criminal investigation or other investigation or proceedings.

7. COLLECTED PERSONAL DATA
Data source
We collect personal data from you only when you voluntarily provide us with such information as:
The site alexakosmetik.com: when you place an order through the Site, as a Customer; when you create an account or modify your account; when you create a favourite product list; when you participate in a contest, a tombola or a promotion; when you look for information on the Site; when you contact us with a comment or a question; when you sign up to receive newsletters;

Our stores: when you fill in the fidelity card form, during unofficial discussions when visiting boutiques or outlets, when you participate in a contest, a tombola or a promotion in one of our stores; when you buy merchandise; Events: when you participate in our events, market surveys and research or any other promotions, including those organised online (for instance, actions that we run on third-party social media, like Facebook);

Our customer service: when you seek assistance, special services or before and after sale services;

E-mail, text, and other type of electronic messages: when we communicate with you;

If you provide us with personal information from third parties (for example, Family members, other third parties), you must make sure that these third parties are fully informed and you are authorized to use their data, as described in this Privacy Policy.

Data categories
We may collect and use various types of personal data according to our purpose, as described below:
a. personal data such as name, surname, sex, age/date of birth, country of origin and other personal details (hair and skin type etc.) as allowed by applicable law;
b. contact details like address, e-mail address, telephone number, mobile number and other contact details, in conformity with applicable law in force;
c. payment details such as payment instrument (credit and debit card)
d. sales information like the products or services provided, the place of purchase, the product codes, the amount, the total sales, the complaints, the returns, the reimbursements and other sales related information, in conformity with applicable law in force;
e. practices and profiles, like your purchase data (purchase history, including the Store where the sale takes place, the type, the quantity and the price of the products bought), client relationship management, habits (wish list, preferred product categories, how did you find out about our brands, the comments on the quality of the purchased products, the habits or the needs you have declared), other information (job, education, hobbies information and lifestyle activities), in conformity with the applicable laws in force;

8. HOW WE USE PERSONAL DATA
Personal data can be used for the following goals, varying according to the specific circumstances in which you interact with us.

When you use our Site
When you use our Site to look for our products and services and to view the information we are providing, a number of cookies are used by us as well as by third parties in order to enable the site functioning, to collect useful information about visitors and to help you have the best user experience possible.

Some of the cookies we use are strictly necessary for our site to function and we do not ask for your consent to store them on your device. These cookies are listed below:

  The user’s accept for the use of cookies

Cookie name

Scope   

Other information

ASP.NET_SessionId

Identifying the session of the user on each device/browser

Providing login support, shopping cart, saving shopping cart, retaining useful information in the checkout process

alexakosmetik-cookies-accepted

The user’s accept for the use of cookies

 

ShoppingCartProducts

The temporary shopping cart content, meaning the products codes and their quantities

 

Cookies regarding campaign

Display specific promotional banners in a controlled manner

 


Besides the cookies we use, third parties also store other cookies on the device with your consent. These are listed below.
 

Third pary name

Description link

Google

https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage

Mailchimp

https://mailchimp.com/legal/cookies/

Facebook

https://www.facebook.com/policies/cookies/

VE Interactive

https://www.ve.com/privacy-policy

Yahoo

https://policies.yahoo.com/xa/en/yahoo/privacy/topics/cookies/index.htm

Criterio

https://www.criteo.com/privacy/



When you send a request using our Site
When you submit a request through our Site, according to the information that is of interest to you, we may need the following information: your first and last name, your phone number contact details, e-mail address, postal address, gender and age.

We use this information to answer your request, included to provide the information requested about our products and services. Also, we may also send you more e-mails once you have submitted a request to satisfy your interest and to make sure that we have answered your request. We will do so on the grounds of our legitimate interest to provide accurate information before the sale.

Your request is stored and processed as an e-mail hosted by Microsoft within the European Economic Area (EEA).
We do not use the information you provide to make automated decisions that may in any way affect you.

When you purchase a product from our Site
When you buy products from our online shop, we request contact information like your name and surname, address, contact number, e-mail address and card information credit (when the order is paid by online payment). At the same time, we register the IP address (Internet Protocol), which is the address of your device on the Internet.

We use this information to manage your online purchases on alexakosmetik.com, to process your order as well as to deliver your products. We will send you a confirmation e-mail and a shipping confirmation e-mail and, where appropriate, we will use your phone number to contact you regarding your purchase. Furthermore, we will use your data to manage product complaints as well as warranties. We use personal information both for identifying and confirming your legal age for online shopping and for confirming your address to external partners.

We request this information for processing the payment, delivering your products and fulfilling the contract concluded with you. Card data are processed through the PayPal payment processor, and ABENOR KOSMETIK does not save any details regarding the card of the Client. We register your IP address to show that the sale has been properly charged, which is a legal obligation.

Your personal data communicated to third parties is used solely with the purpose to provide you with the services mentioned above for operations carried out by warehouse and distribution service providers in connection with the delivery of your order for processing payments by payments service providers.

We do not use the information you provide to make automated decisions that may in any way to affect you.


When you sign up to receive our newsletters:
You can subscribe to newsletters by using one of the following methods:
– From the main page of the Site, filling in the e-mail address in the form specially designed;
– When you sign up for a new account by checking the option of the newsletter sign-up;
– On the check out page at the end of the order, checking the options for subscribing to related newsletters
– In the suggestion forms, opinions, advice from the Site specialist, selecting the newsletter sign-up option;
– From the alexakosmetik Facebook page, by filling in the e-mail address in the form provided.

When you sign up to receive our newsletters, we can ask you for: your first and last name, e-mail address, gender, hair type, skin type, age and postal address.

We will ask for your consent to use these data to e-mail the newsletter that contains information on our products and other information that we might consider to be of interest to you.

You can withdraw your consent at any moment, by simply following the instructions in each newsletter and we will immediately stop to send you the newsletter.

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We do not use the information you offer us to make automated decisions that may affect you in any way.

When you create a Client account
When you create a Client account, we ask you for the following categories of personal data: first and last name, e-mail address, password, date of birth, gender, skin type, hair type.

We will process the following categories of personal data if you proceed with a purchase:
* Order history;
* Delivery information (postal address and contact phone number);
* Payment history.

In addition, we will process the following categories of personal data related to your cookies:
* Click history;
* browsing and navigation history.

We will use your personal data for creating and managing your alexakosmetik account as well as for providing you with a personalized and relevant experience on the alexakosmetik site.

We will record and manage the benefits offered to your Client account, we will send you information about your rewards, such as discounts, tips and advice, surprises and events.

We will provide you with the order history and the details of your orders and allow you to manage your account settings (including also the marketing preferences). Also, we will provide you with simple methods to correct and update your information, such as contact details and payment information. More than that, we will allow you to save the items in the shopping cart as well as to evaluate and write reviews of the products you have bought from us.

To provide you with relevant recommendations on ABENOR KOSMETIK products, we will process your navigation history on our digital platforms (including the Site and the application); the shopping history and product reviews and also the data you have sent using your account.

If you have not chosen direct marketing, we will use your personal data to send you marketing, information polls and invitations via e-mails, text messages, phone calls and mail.

The processing of your personal data for your account is based on your consent provided upon the creation of the ABENOR KOSMETIK account.

Processing your personal data to offer you relevant product information rely on our legitimate interest.

You have the right to close your account at any moment. If you choose to do so, your account will be closed and you will be considered an inactive user.

You have the right to oppose the processing of your personal data on the grounds of ABENOR KOSMETIK’s legitimate interest by contacting office@alexakosmetik.com. Your account will then be deleted and we will not be able to offer you our services any longer.

When you send a review on one of the Abenor Kosmetik products
When submitting a Abenor Kosmetik product review, we will register your name and first name, e-mail address, sex, age, skin type and IP address, which is the address of your device on the Internet.

We use this information to offer our potential clients with independent, verified opinions on our products. The name, age, skin type, and review content (but not your e-mail address or IP address) may be publicly displayed on our Site. We will do so on the basis of our legitimate interest in terms of marketing our products and services.
We do not use the information you offer us to make automated decisions that may affect you in any way.

You may ask us to remove your review at any moment.

When you participate in our feedback polls
When you participate in our feedback polls, we may ask for your name, e-mail address, organization name, information about your profession, and answers to the questions we ask regarding your opinion on our products and their use.

We use this information to develop and improve our products and services as well as client relationships. Information regarding your profession, organization, and some or all of your comments may be publicly displayed on our Site under the testimonial section. We will do so on the basis of our legitimate interest in terms of marketing our products and services.

Your details may be shared with a third-party survey system located in the European Economic Area (EEA).

We do not use the information you offer us to make automated decisions that may affect you in any way.

You may ask us to remove at any moment a testimonial that relies on your feedback from the content of our Site.

Direct marketing
On the basis of your consent, we will process the following categories of personal data:
*contact information such as name, e-mail address, telephone number and postcode;
* sex (if you opt to transmit this information);
* products and offers you have viewed.

If you have a alexakosmetik account, we will also process your personal data communicated in regard to your account, data such as: name; address; age; order history; how you navigated and what you clicked on the site.

We use personal data to send you marketing offers, polls and invitations via e-mail, text messaging, phone calls and mail.

For optimizing your alexakosmetik.com experience, we will provide you relevant information, product recommendations and we will send you customized offers, invitations to competitions, tombola or promotions and other advantages for registered clients. All these excellent services are based on previous orders, the items you have clicked, and the information you have sent.

Data send to third-party is used solely to provide you with the services mentioned above, and those sent to media agencies and to technical suppliers aim at distributing direct physical and digital marketing.
We do not transmit, sell, or disclose your data to third parties for marketing purposes.

The processing of your personal data is done on the basis of your consent when you agree to direct marketing.

You have the right to withdraw your consent to the processing of personal data at any moment.
When you do so, alexakosmetik will stop sending you other direct marketing offers or information on the basis of your consent.

You may unsubscribe from direct marketing by following the instructions included in each marketing message.

Retention time of your personal data

We will store your information as long as required by the law in force. Unless there is a legal requirement, we will only store them for as long as necessary.

9. PERSONAL DATA SECURITY AND CONFIDENTIALITY
We have implemented suitable measures to secure your personal data from accidental loss as well as to prevent unauthorized access, use, modification and disclosure. For instance, when you offer order information, we use the Secure Socket Layer (SSL) technology, an encryption tool to provide security while transmitting this information over the Internet. In addition, we use firewall protection, password control and other technological and procedural safeguards for the maintenance of this Site. Even if we have implemented the security measures mentioned above for this Site, you must be aware of the fact that 100% security is not possible. Consequently, your personal data is provided on our own responsibility and to the fullest extent allowed by applicable law in force, so we will not have any responsibility as a result of the disclosure of your personal information as a result of unauthorized errors, omissions or acts to third parties during or after their communication to us. We recommend that you update your software to protect data transmission over networks on a regular base (for instance, antivirus software) and you ensure that the electronic communications service supplier has adopted appropriate means to secure data transmission over networks (for instance, firewall spam filters and spam filters); (ii) keep your privacy and do not disclose to any person the username and password to access your account; (iii) change your password regularly, and (iv) not use the same password for all of your accounts.

In the unlikely event that we discover that the security of your personal information in our possession or control has been or may be compromised, we will notify you of this situation, under the terms of the applicable law, using any of the methods described therein (by providing us with your e-mail, you agree to receive such electronic notification through this e-mail address).

10. RIGHT TO LODGE A COMPLAINT WITH A SUPERVISORY AUTHORITY
If you think that ABENOR KOSMETIK is processing your personal data in an incorrect manner and you have a complaint on the use of your data by us, we would prefer to contact us directly in the first instance, so that we can address the complaint.

Also, you have the right to file a complaint with a supervisory authority.

11. CONFIDENTIALITY POLICY UPDATE
We regularly review and, where appropriate, update this privacy policy and when our services and the use of personal data evolve. If we wish to use your personal information in a way we have not previously identified, we will contact you to provide you with more information about it and, when and if necessary, to ask for your consent.

We will update the version number and date of this document every time this document is modified.

Applicable starting with 25.08.2019

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