NOTIFICATION OF CONFIDENTIALITY

Data confidentiality is of particular importance to ANGORA CLOTHING SRL. We want to be open and transparent about the processing of personal data. Therefore, we have a policy defining how to process and protect your personal data.

The purpose of this document is to inform you in a correct, specific and unambiguous on the manner and order in which these data are collected, processing period which are stored the data, ways to exercise individual rights and information about the secondary purpose of processing, if the data will be processed in a purpose other than the one for which they were collected by the associated operators.

We reserve the right to update and periodically modify this Privacy Policy to reflect any changes in the way we process your personal data or any changes to your legal requirements. In the event of any such change, we will display on our website the modified version of the Privacy Policy, so, please, periodically review the contents of this Privacy Policy.

This applies to all websites owned by ANGORA CLOTHING SRL, namely:www.raspberryfashion.ro and www.raspberrystore.ro

1. Who is the operator of personal data?

ANGORA CLOTHING SRL is the owner of the online stores raspberryfashion.ro and raspberrystore.ro, and the operator of the personal data that is transmitted to us by you and is responsible for your personal data in accordance with the applicable data protection legislation.

Our identification data is as follows:

Company name: ANGORA CLOTHING SRL

Address, headquarters: Spatarului Street, Number 5A, Buzau County, Romania

Registered with the National Trade Register Office

Company Registration Number: J17 / 1375/2018

Authorized representative: VOICU VALENTINA GEANINA

VAT registration number: CODE OF VAT: RO39951729

Phone number: (+4) 0742.817.638

2. What categories of personal data do we process?

We generally collect and store data directly from you so you have direct control over them. When you create an account on the Raspberry website, please send us the following information: name and surname, email address.

Subsequently, when placing an order or editing by yourself from the Client Account, you can add: address, postal code, phone, password. When completing the return form or sending it by email, you voluntarily give us your bank account and bank name. By offering these data you give your consent freely expressed and unequivocally that all your personal data is in our database, with due respect of the legal provisions regarding the protection of individuals with regard to the processing of personal data and the free circulation of such data. According to the legitimate interest stipulated in GDPR, we mention that the reasons we need this data are: online trade, sending our offers by email and, marketing and advertising messages, etc.

Minors' data.

Raspberry does not allow the processing of personal data of customers who are under the age of 18.

When creating an account or placing an order in the Online Store, customers must confirm that they are 18 years of age.

3. What are the purposes and bases of processing?

The primary purpose of data collection is to deliver our services to your advantage.

The purpose of data collection is:

- Informing customers / buyers about the situation of their Raspberry account, informing users / clients about the evolution and status of orders, evaluating the products and services offered, commercial activities to promote products and services marketing, advertising, media, administrative, development, market research, statistics, tracking and monitoring of sales, but also consumer behavior, making payments and returning money to the client's account.

This general purpose may include, as appropriate, the following:

a) Account create and management within the Raspberry platform;

b) Processing of orders, including taking over, validating, shipping and billing;

c) Solving cancellations or problems of any kind related to an order, to the goods or services purchased;

d) Return of the products according to the legal provisions;

e) Reimbursement of the value of the products according to the legal provisions;

f) Provide support services, including answers to your questions about your orders or Raspberry goods and services.

Processing your data for these purposes is in most cases necessary for the conclusion and performance of a contract between ANGORA CLOTHING SRL and you. Also, some processing, subsumed for these purposes, is required by applicable law, including tax and accounting legislation.

To improve our services, we always want to offer you the best online shopping experience. To do this, we can collect and use certain information about your buyer behavior, we can invite you to fill in queries of satisfaction subsequent to the completion of an order, or we can conduct market research directly or with the help of partners.

We base these activities on our legitimate interest in doing business, always taking care that your fundamental rights and freedoms are not affected.

4. When do we store your data?

The data we collect from you is stored in the European Economic Area (EEA) but can also be transferred and processed in a non-EEA country. Any such transfer of your personal data will be made in accordance with applicable law.

In the case of data transfers outside the EEA, ANGORA CLOTHING SRL will use the standard contract terms and Privacy Shield as a guarantee for countries failing to take a decision on the adequacy of the protection from the European Commission.

Specifically, our service provider who helps us to send you emails (MailChimp), although located in US territory (outside of the EU territory), owns the Privacy Shield (EU-US Privacy Shield) certification at the non-HR, thus ensuring an adequate level of data security recognized by the European Commission.

When we submit personalized offers through our ads, we appeal to the personalized audience feature managed by Facebook, Inc. located outside the EU / European Economic Area but certified according to publicly available information in accordance with the requirements of the EU-US Privacy Shield (considered to ensure an adequate level of protection of personal data transferred from the European Union to United States Organizations). We recommend that you consult the Facebook Privacy Policy on its site.

In addition, we transfer your data to profiling service providers located in the US with which we have entered into a data transfer agreement under standard data processing conditions approved by the European Commission that has implemented the technical and organizational security measures necessary to ensure the protection of your data.

5. Who has access to your data?

The data is for the exclusive use of ANGORA CLOTHING SRL for the purposes mentioned above and will not be disclosed to a third party except for the following company / companies within the same group of companies as ANGORA CLOTHING

• Partners of ANGORA CLOTHING SRL;

• Courier service providers;

• Banking / Payment service providers;

• Marketing / telemarketing service providers;

• Providers of market research;

• IT service providers.

If we have a legal obligation or if it is necessary to protect our legitimate interest, we can also disclose certain personal data to public authorities on the basis and within the limits of the legal provisions and as a result of expressly formulated requests.

Also, ANGORA CLOTHING SRL may provide your personal information to other companies with which it is in a partnership, but only on the basis of a confidentiality commitment from them, guaranteeing that such data is kept secure and that the provision of these personal information is made according to the legislation in force, as follows: suppliers of marketing services, courier services, payment / bank services, telemarketing or other services, other companies with which we can develop joint programs of market offer of our products and services.

We do not transmit, sell, cease or share your data for marketing purposes outside ANGORA CLOTHING SRL. Data sent to third parties is used only to provide you with our services. You will find the categories of third parties within each specific process above.

6. What is the legal basis for processing?

For each specific processing of personal data that we collect from you, we will inform you whether the provision of personal data is required by regulations or whether it is necessary to conclude a contract, whether it is mandatory to provide us with your personal data and what are the possible consequences if you refuse.

7. Which are your rights?

Right of access:

You have the right to request information about the personal data we hold about you. You may contact ANGORA CLOTHING SRL , which will provide your personal data by e-mail.

The right to portability:

Whenever ANGORA CLOTHING SRL processes your personal data by automated means based on your agreement or consent, you have the right to obtain the transfer of a copy of your data in a frequently used and automatically processed structure to you or to another party. This includes only the personal data you have sent to us.

Right to rectification:

You have the right to request the rectification of your personal data if it is incorrect, including the right to fill in incomplete personal data.

Right to delete data:

You may delete any personal data processed by ANGORA CLOTHING SRL at any time except in the following circumstances:

* You have an unresolved request to the Customer Service;

* You have an open order that has not yet been shipped or has been partially shipped;

* You have an unpaid debt at ANGORA CLOTHING SRL, regardless of the payment method;

* If you have made a purchase, we will retain your personal data in connection with your transaction under the accounting law.

Right to oppose to the processing based on the legitimate interest:

You have the right to oppose the processing of your personal data based on legitimate interest. ANGORA CLOTHING SRL will not continue to process personal data unless we can demonstrate a legitimate reason for processing that takes precedence over your interests or your rights or legal proceedings.

Your right to oppose to direct marketing:

You have the right to opt for direct marketing, including profile analysis for direct marketing purposes.

You can unsubscribe from direct marketing through the following means:

* Following the instructions in each marketing email;

* Modifying your account settings.

Right to Restrict Processing:

You are entitled to request that ANGORA CLOTHING SRL restrict the processing of your personal data in the following situations:

* If you affirm that your personal data is incorrect, ANGORA CLOTHING SRL LLC must restrict any processing of this data until it has verified the accuracy of your personal data.

* If the processing is illegal, you can oppose the deletion of your personal data and request to restrict the use of your personal data.

* If ANGORA CLOTHING SRL no longer needs your personal data, but it is necessary to defend your rights in court.

8. How can you exercise your rights?

We attach great importance to personal data protection, so we have dedicated customer support staff who handles your requests for your above-mentioned rights. Our staff is always available at dpo.raspberry@yahoo.com.

9. Data Protection Officer:

We have appointed a Data Protection Officer to ensure that we continuously process personal data in an open, accurate and legal manner. You can contact the Data Protection Officer at dpo.raspberry@yahoo.com.

8. Right to file a complaint with a supervisor:

If you are of the opinion that ANGORA CLOTHING SRL treats your personal data incorrectly, you may contact us. You also have the right to file a complaint with a supervisor.

10. Updates to the Notification of Confidentiality:

We may need to update our Privacy Notice. The latest version of the Privacy Notification is permanently available on our site. We will disclose any significant changes to the Privacy Notice, for example the purpose for which we use your personal data, the identity of the operator or your rights.

RASPBERRY ACCOUNT

Why do we use your personal data?

We will use your personal information to create and manage your personal account to provide you with a personalized and relevant experience on RASPBERRY.

We'll give you the order history and details of your orders and let you manage your account settings (including marketing preferences). We will also give you simple ways to correct and update your information, such as contact details and payment information. Moreover, we will allow you to save the items in your shopping cart, give you size recommendations, and allow you to evaluate and review the products you have purchased from US.

In order to give you relevant recommendations on RASPBERRY products, we will process your navigation on our digital platforms (including website and application); your shopping history and product reviews, as well as the data you have sent through your account.

What types of personal data do we collect?

When you open an online client account, we store your name and your email address. This information is needed to give you the opportunity to order through the online Raspberry store.

We will process the following categories of personal data if you choose to provide them with:

* Contact information, such as name, address, phone number;

* Date of birth;

* Sex;

* Country;

* Account settings;

We will process the following categories of personal data if you make a purchase:

* Order history;

* Delivery information;

* Payment history.

We will also process the following categories of personal data related to your cookies:

* Click history;

* Browse and browse history.

Who has access to your personal data?

Data sent to third parties is only used to provide you with the above mentioned services, to optimize the website, use web agents and analytics tools to evaluate products.

What is the legal basis for processing of personal data?

The processing of your personal data for your account is based on your consent to the creation of RASPBERRY account.

Processing your personal data to provide you with relevant product information is based on our legitimate interest.

How long do we save your data?

We will keep your data as long as you have an active RASPBERRY account.

You have the right to close your account at any time. If you choose to do so, your account will cease to exist and you will be considered inactive. We will keep your personal data if this is required by law and if there is an open litigation.

Once your account is closed, your data will be deleted.

The right to oppose processing of your data:

You have the right to oppose the processing of your personal data on the basis of the legitimate interest of ANGORA CLOTHING SRL by contacting dpo.raspberry@yahoo.com. Your account will then be deleted and we will not be able to offer you our services.

Raspberry App

When using the Raspberry app, it makes a connection with the current version of our online store. The application takes content and services on the website, it optimized them to be viewed on a different device and allows the use of additional functions.

2. Log files

When viewing a page on our website or application, we automatically record a sequence of data and information in the so-called "log file". Log files may contain the following information:

• Date and time of visit

• The name of the viewed page

• The IP address of the used device

• Device ID (Google AdIP, Apple IDFA)

• Session ID

• Browser and used version

• Operating system

• Referrer (the link from which the page was accessed)

We need these log files for the technical availability of our online store and for optimizing how it is displayed on your device. We also use the data in the log files to detect errors, to recognize potential threats and to protect our online store from malicious attacks.

Articles 6 (1) and 6 (1) c of the EU GDPR (General Regulation on Data Protection in the European Union),

3. How does Raspberry use my data?

Our website allows you to order online products. To process the order and to fulfill the obligations created when it is made, Raspberry processes the personal information it collects. We save your contact details and any other personal information you disclose to us when making an order (including name, address, e-mail, payment and return information) to you can process your order and manage your client account. Article 6 (1) b of the GDPR EU (General Data Protection Regulation in the European Union) gives to the company the Bonprix permission to do so.

a. My Account / Client Account

When you use the online store, you have the option to open a password-protected client account through which you can access your saved data at any time. You also have the option to change, review, or delete any of these data and manage what you have agreed to. When you open an online client account, we will store your name, surname, address, phone number and email address. This information is needed to give you the opportunity to order through the online Raspberry store.

Article 6 (1) b of the EU GDPR (General Regulation on Data Protection in the European Union) gives Raspberry permission to do so.

b. Prevention of fraud

The data you disclose to Raspberry as part of your order can be used to verify activities with respect to some unusual commands (e.g., simultaneous ordering of a large number of products at same address, through different client accounts). ANGORA CLOTHING SRL has a legitimate interest in conducting such checks (e.g., to avoid loss of payments or to prevent identity theft). Data processing is carried out in accordance with Article 6 (1) f of the GDPR EU (General Data Protection Regulation in the European Union).

c. Data transfer to third parties

As part of your order processing, we work with different contractors to provide the following services:

I. Telephone centers

As part of our customer service, we work with third party contractors. To process your order or requests, these companies have access to your name, surname, address, e-mail, phone number, order history, and communications data. Data processing is carried out in accordance with Article 6 (1) b of the GDPR EU (General Regulation on Data Protection in the European Union).

II. Payment providers

We offer a wide range of options when it comes to paying your order (depending on your credit rating). In addition to standard advance payment and cash on delivery, we offer credit card payment. If you select your credit card payment, your order data is sent to that payment provider. This is set out in Article 6 (1) b of the GDPR EU (General Regulation on Data Protection in the European Union).

III. For transport purposes

To deliver your order, Raspberry works with URGENT CARGUS, DPD, and TNT. In order to allow delivery of the order and delivery updates, the following data is sent to the transport contractors: name, surname, address, e-mail, and telephone number. This is set out in Article 6 (1) b of the GDPR EU (General Regulation on Data Protection in the European Union).

IV. Marketing contractors

For our media production (catalogs, newsletters, emails, etc.), we work with different contractors (printers, marketing agencies, e-mail services). This is set out in Article 6 (1) f of the GDPR EU (General Regulation on Data Protection in the European Union).

Online Purchases

Why do we use your personal data?

We will use personal data to manage the purchase online on RASPBERRY, processing orders and returns through our online services and we will send you notifications regarding the delivery status or in case of problems regarding the delivery of your items. We will use personal data to manage payments. Also, we'll use the data to treat complaints and guarantees on products. We use personal information to identify and confirm your legal age for online purchases and to confirm your address to your external partners.

We want to offer you various payment alternatives and we will conduct analyze to find out what payment alternatives were available, including your payment history and credit reviews.

What types of personal data do we process?

We will process the following personal data categories:

* Contact information such as name, address, e-mail address and phone number;

* Information about history and payment history;

* Order information.

If you have a Raspberry account we will also process your personal data transmitted in connection with your account, such as:

* Your account;

* Order history.

Who has access to your personal data?

Your personal data transmitted to third parties are only used to provide the above mentioned services for confirmation of address by external companies to send confirmation of order to communication agents for operations made by suppliers of storage and distribution services in connection with delivery of your order. Payment Processing by Payment Service Providers. Verification of the Identity or credit by information agencies on the credit, and debt collection agencies.

Please note that many of these beneficiary companies have an independent right or obligation to process your personal data.

For how long do we save your data?

We will keep your data as long as you are an active customer.

Direct marketing

1. Why do we use your personal data?

We use your personal information to send you marketing offers, email polls and invitations, text messages, phone calls.

To optimize your Raspberry experience, we will provide you with relevant information, product recommendations, reminders about the products left in your shopping cart, and we will send you personalized offers. All these great services are based on previous orders, articles you've clicked on the information you've sent.

2. What type of data is used for direct marketing purposes?

ANGORA CLOTHING SRL has a legitimate interest in using personal information for marketing purposes. Unless otherwise specified, the use of personal information for marketing activities is based on Article 6 (1) f of the GDPR EU (General Data Protection Regulation in the European Union). There are different ways in which your information can be used:

a. Newsletters

In different areas of our online store, you have the opportunity to take advantage of various benefits by subscribing to our newsletter. Subscribers regularly receive news about discounts, trends, special promotions in the store, and personalized offers. This is done only with your consent.

The Raspberry Newsletter follows your express agreement, in accordance with Article 6 (1), together with Article 7 of the EU GDPR (General Data Protection Regulation in the European Union).

Normally, you can unsubscribe from our newsletter at any time by sending an e-mail to dpo.raspberry@yahoo.com, accessing the online store or following the instructions at the end of each newsletter.

What types of personal data we collect?

We will process the following categories of personal data:

* Contact information, such as email address, phone number and postcode;

* Sex (if you choose to communicate this information);

* Products that you clicked.

If you have a Raspberry account we will process and personal data transmitted in connection with your account, such as:

* Name;

* Address;

* Order history;

* How you navigated what you clicked on the site.

Who has access to your personal data?

Data sent to third parties is used only to provide you with the above mentioned services, and those sent to media agencies and technical vendors are aimed at distributing direct physical and digital marketing.

We do not transmit, sell, cease or share your data for marketing purposes outside ANGORA CLOTHING SRL .

What is the legal basis for the processing of personal data?

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

The right to withdraw your consent:

You have the right to withdraw your consent to the processing of your personal data at any time.

When doing so, ANGORA CLOTHING SRL will not be able to send you other direct marketing offers or information based on your consent.

You can unsubscribe from direct marketing through the following means:

* Following the instructions in each marketing message;

* Modifying your RASPBERRY account settings.

How long do we save your data?

We will keep your data for direct marketing until you withdraw your consent. For e-mail marketing, we will consider you as an inactive client if you have not opened an email in the last year.

After this period, your personal data will be deleted.

Customer service

Why do we use your personal data?

We will use your personal information to handle product queries, complaints, and warranties, as well as to provide technical support via email, chat, telephone and social networks.

We can also contact you if there is a problem with your order.

What types of personal data we collect?

We will process any data you provide to us, including the following categories of data:

* contact information, such as your name, address, e-mail address and phone number;

* Date of birth;

* Payment information and payment history

* Order information

* Account number

* All relevant correspondence.

Who has access to your personal data?

Data sent to third parties is used only to provide you with the above mentioned services. If you are a customer in the Asian region, your data will be transferred to an external customer service agency.

What is the legal basis for the processing of personal data?

The processing of your personal data is based on the legitimate interest of ANGORA CLOTHING SRL.

How long do we keep your data?

We will keep your data for 2 years for telephone and e-mail logs, and correspondence is kept for 12 months for case management.

For store complaints, your personal data will be saved for 2 years.

Right to oppose processing on a legitimate interest:

You may oppose the processing of your personal data on the basis of the legitimate interest of ANGORA CLOTHING SRL.

ANGORA CLOTHING SRL will not continue to process your personal data unless we can demonstrate a legitimate reason for processing that prevails over your interests and rights or legal proceedings.

Development and improvement

Why do we use your personal data?

We will use your data to assess, develop and improve the services, products and our systems for all our clients. For this, we will not analyze individually your data; all processing will be done with pseudonymized data.

This includes analyzes to make our services easier to use, such as modifying the user interface to simplify the flow of information or to highlight the features commonly used by our customers on our digital channels and to improve IT systems to increase security for visitors and customers in general.

The analysis is also used to develop and continually improve the logistics flow of goods by forecasting purchases, inventories and deliveries, as well as our resources in terms of sustainability, by rationalizing the procurement and delivery planning.

In addition, we use data to plan opening new stores and warehouses and to improve our product range.

What types of personal data do we collect?

We will process the following categories of personal data if you chose to provide them to us:

* Customer number

* Date of birth

* Sex

* Country

If you made a purchase, we will process the following personal data categories:

* Order history

* Delivery information

* Payment history

We will process the following categories of personal data related to cookies:

* Click history

* Browse and browse history

Who has access to your personal data?

Data transmitted to third parties and are used only to provide you with services mentioned above. We use web analytics to analyze online customer behavior on a general level.

What is the legal basis for the processing of personal data?

Processing of your personal data to develop and perfect our services and our products are based on our legitimate interests.

For how long do we save your data?

We will keep your data as long as you have an active Raspberry account.

Once your account is closed, your data will be deleted.

The right to oppose processing of your data:

You have the right to oppose the processing of your personal data on the basis of the legitimate interest of ANGORA CLOTHING SRL by contacting dpo.raspberry@yahoo.com. Your account will then be deleted and we will not be able to offer you our services.

Compliance with legal obligations

Why do we use your personal data?

We will use your personal information to comply with legal obligations, judgments, and decisions of the authorities.

This includes the use of personal data for the collection and verification of accounting data in accordance with accounting regulations.

What types of personal data do we collect?

We will process the following categories of personal data:

* Customer number;

* Order number;

* Name;

* Postal address;

* The amount of the transaction;

* The date of the transaction;

Who has access to your personal data?

Your data will be transmitted to ANGORA CLOTHING SRL.

We will distribute your personal data to IT companies that offer solutions to accounting systems.

What is the legal basis for the processing of personal data?

The processing of your personal data is necessary for ANGORA CLOTHING SRL to fulfill its legal obligations.

How long do we save your data?

We will save your data in accordance with the applicable accounting regulations.

Preventing abusive use and offenses

Why do we use your personal data?

We will use your personal data to manage loss prevention by ensuring compliance with terms and conditions, as well as to detect and prevent the heavy use of our services.

We will use your personal data from video surveillance for security reasons to track incidents, to prevent and report criminal offenses committed in our stores.

Your personal data will be used to prevent and investigate abuse of our online services, losses, and fraud by analyzing online shopping behavior.

What types of personal data we collect?

We will process the following categories of personal data:

* Contact information such as name, address, phone number and e-mail address;

* Customer number;

* Order history;

* Delivery information;

* Payment history.

Who has access to your personal data?

Your personal data transmitted to third parties is only used for the purposes mentioned above.

We will distribute your data to companies for exception-based reporting.

Incidents and fraud can be distributed to insurance companies, judicial authorities or to ensuring the compliance with local and global law in order to finalize investigations. Please, remember that these recipients have an independent right or obligation to process your personal data.

What is the legal basis for the processing of your personal data?

Processing your personal data to prevent the heavy use of our services is based on our legitimate interest.

How long do we save your data?

We will keep your data as long as it is necessary to prevent and / or report potential frauds and other offenses.

The right to oppose processing of your data:

You have the right to oppose the processing of your personal data based on the legitimate interest of ANGORA CLOTHING SRL by contacting dpo.raspberry@yahoo.com. Your account will then be cleared and we will not be able to offer you our services.


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