Privacy and personal data processing policy

ONLINE PLATFORM DESPRESPA.RO

Desprespa.ro and the owners of the desprespa.ro platform assure you that it will process personal data in an honest, transparent and informed manner, in accordance with the changes and amendments brought by the General Data Protection Regulation (EU) 2016/679 ("GDPR").

The company Exclusive About SPA SRL assures you that it respects the confidentiality of your data and, therefore, Exclusive About SPA SRL, hereinafter referred to as despreSpa.ro, is committed to protecting any information that identifies or may contribute to the identification of an individual ("personal data"), which it collects, processes and/or has access to.

The manner in which personal information is collected, processed, transmitted and shared depends on the purposes and legal grounds on which the collection and processing of such data is based, as well as on the specific consent given by you in this regard.

This site, despreSpa.ro, is provided and managed by the company Exclusive About SPA SRL, with registered office in the head office: Str. Emil Racovita 35-39, cartier Azur, Vila AZ 15, Pipera, Ilfov, Unique Registration Code:25044541, tax attribute RO, Trade Register Number: J23/226/02/02/2009, Share Capital: 1180 RON, by e-mail: office @despreSpa.ro or phone +4 0745.411.411.111.

By means of this Personal data protection policies (hereinafter the "GDPR Policy") we want to ensure that you have access to adequate information about the collection and processing of your personal data, as required by the applicable regulations on the protection of personal data.

This Privacy Policy may be supplemented by terms and conditions that apply to this website or to which you have consented by interacting with us.

What personal data means?

'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, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to his or her physical, physiological, genetic, mental, economic, cultural or social identity. 

What personal data processing means?

"Processing" shall mean any operation or set of operations which is performed upon personal data or sets of personal data, whether or not by automatic means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction. 

We collect your data in accordance with the principles of processing and collection of personal data.

Your personal data is processed lawfully, fairly and transparently towards you. It is collected for specified, explicit and legitimate purposes and not further processed in a way incompatible with those purposes. Your personal data is adequate, relevant and limited to what is necessary in relation to the purposes for which it is processed ensuring at all times that we only process data that is strictly necessary. We strive to ensure that your personal data is accurate and, where necessary, kept up to date. We ensure that we take all necessary steps to ensure that personal data that is inaccurate, having regard to the purposes for which it is processed, is erased or rectified without delay. Your data shall be kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the data are processed; personal data may be stored for longer periods insofar as they will be processed solely for the discharge of legal obligations, subject to the implementation of appropriate technical and organizational measures laid down in the Regulation to safeguard the rights and freedoms of the data subject. Your data shall be processed in a manner that ensures adequate security of personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction or accidental damage, by taking appropriate technical or organizational measures.

Technical and organizational measures

We ensure the necessary technical and organizational measures to collect, process and keep data secure, including against unauthorized access, unauthorized use of data, or destruction, loss or alteration of data. We are committed to keeping your personal data secure and take all reasonable safeguards to do so.

We implement systematic processes to train the people responsible for IT security and to monitor and audit the security of IT systems and infrastructures according to policies.

In addition, we make all reasonable efforts to ensure (including through our contracts with them) that our trusted partners also manage appropriate technical and organizational measures for the processing of the data we share with them.

What data do we process?

In order to communicate marketing materials, we process the following personal data: e-mail address, first and last name, telephone number. Please do not provide us with any other personal data. 

  • In order to place online orders for a voucher, eVoucher or spa card you agree to entrust personal data to us full name, age, gender, e-mail address, telephone number, city and home address, geo-location general of the device from which you are browsing/login to your customer account, product information and services purchased, degree of use and your activities on the Online platform; interests and preferences related to products from desprespa.ro other information depending on the product or service requested. We also do not collect personal data from minors. Bank account data, bank and card data (card type, card number, cardholder name, expiration date and security code) are not retained and stored by the desprespa.ro platform but directly by the financial service providers. 

In addition to personal data of customers, Exclusive About SPA SRL may also collect personal data of partners, job candidates, employees, readers, website users, community members, registered consultants, event participants, etc.

Data of minors.

Exclusive About SPA SRL does not allow the processing of personal data of customers under the age of 18.

Grounds and purposes for processing personal data

The personal data provided with your consent will be collected and processed by us solely for the purposes of providing the requested service, your use of our customer service or to send you commercial information and material for marketing purposes (e.g., offers, holiday greetings, other information in connection with the provision of our services, etc.), other communications, security and fraud detection and prevention, legal reasons, communicating with you.

  1. Sales and orders: despreSpa.ro uses your personal data in order to finalize and administer your order.
  2. Customer service: we use the data we ask you to provide you with the highest possible standards of service.
  3. Marketing activities: despreSpa.ro uses your personal data for marketing activities. Where we will carry out direct marketing activities such as commercial newsletters and communications about our products and services, we will also include an unsubscribe link that you can use when you no longer wish to receive messages from us. We may also invite you by email to write a review on our website about the product or service you purchased. If you submit a comment, it may be posted on our website.
  4. Other communications: there may be situations in which we will contact you by e-mail, sms, or other means of communication depending on the contact details you have provided us with for various reasons:

Completing/delivering an online service;

Solving some of your needs 

  1. Security, fraud detection and prevention: we may use a range of personal data that you provide to us to prevent and investigate fraud. We may disclose personal data to third parties (authorities) as required by law and to our external consultants. 
  2. Legal reasons: there may be situations in which we may need to process personal data in order to resolve legal disputes or complaints or to comply with requests from law enforcement authorities to the extent that there are legal provisions governing such requests.

In accordance with the provisions of Art. 1 of Regulation 679/2016, the legal bases for the processing operations described above are: contract, consent, legal obligation and legitimate interest.

For the purposes set out in points I and II, we rely on the fulfillment of a contract for the supply of products and/or services. The use of your data is necessary for the fulfillment of the object of the contract you have with us (e.g. if you use our services to place an order online, despreSpa.ro will use your data to fulfill the obligation assumed by the contract between the parties, namely to complete and administer the order placed by you).

For the purposes referred to in III, despreSpa.ro will obtain your consent before processing personal data for direct marketing purposes. Your consent will be given in a transparent manner, in an understandable and easily accessible form, with clear and simple language. We provide for the withdrawal of consent at any time. Your consent will not be linked or conditioned to the delivery of goods or provision of services by despreSpa.ro. In this case the absence of your consent will in no way affect our relationship with you or the delivery of goods or provision of services.

In view of the purposes in paragraphs III, IV and VI, we base our processing of personal data on our legitimate interests. When we use your personal data to serve our commercial interests we guarantee that we will balance your rights and interests in protecting your information against our rights and interests and ensure appropriate technical and organizational measures. Our interests include aspects such as providing, maintaining and improving our services, developing new services and features.

According to Art. 1 lit. a of Regulation 679/2016 (GDPR) personal data may be processed if the data subject has consented to the processing of his/her personal data for one or more specific purposes. In this regard, we inform you that if we need to process your personal data for purposes other than those for which we have requested your consent, in order to fulfill our business purpose, we will also request your consent for the processing of this data.  

They are summarized below, Personal Data that we process, the manner in which they are processed, the purpose, the legal basis of the processing and the origin of such data. 

Data provided directly by the data subject for placing orders for voucher, eVoucher or spa card, delivery of products, payment of products, refund of payment for return/withdrawal. Customer assistance and support. Choose the desired products and launch the order. Delivery is made to the address indicated, which is your home address or another indicated address. The following data is collected and processed for each order placed: name and surname; delivery address; e-mail address; telephone number. Provision of the necessary support for processing by the entity authorized to mediate payment for the ordered products. 

The details of the card used to pay for products Online are not accessible and are not stored by Exclusive About SPA SRL, but only by the entity authorized to provide services for storing card identification data. It is possible to process only the following data that we transmit to the online payment/transaction authorization partner: name, surname; order ID; transaction initiation date, completion date; transaction ID; payment status (payment made/not made); amount transacted. For return/cancel order: IBAN and the bank where you opened the bank account. The legal basis for data processing is the performance of the contract. The processing is necessary for the performance of a contract to which the data subject is party. The processing is necessary for the fulfillment of orders, for the delivery and delivery of products. To provide the necessary support for the processing by the entity authorized to mediate payment for the ordered products. 

Data provided directly by the data subject for the purposes of promotional campaigns, loyalty campaigns, contests, promotions or sweepstakes. For the purpose of entering competitions and the awarding of prizes. For marketing policy purposes. DespreSpa.ro may grant discounts and benefits related to our loyalty actions (in the form of vouchers, discounts, etc.). For loyalty actions, online contests run on the site we collect e-mail address and, depending on the campaign, the following personal data necessary to participate in the contest, respectively, to validate the winners: name and surname; e-mail address, or; telephone number, having legal basis consent. Consent may be given by any free, specific, informed and unambiguous expression of will by which the data subject accepts, by means of a declaration or unequivocal action, that personal data concerning him or her may be processed. You have the right to withdraw your consent at any time. Withdrawing consent can be as simple as giving it. Personal data collected automatically for Customer profiling for direct marketing and online behavioral advertising. Depending on the visitor's or customer's interactions and behavior, personal data is collected and processed to create the customer profile. For the creation of this profile we process the following data: name, surname, e-mail and/or correspondence address and mobile phone number; history of interactions with desprespa.ro: products viewed, searched or ordered; orders initiated and completed or canceled; online identifiers (cookies) obtained from the device used when accessing despreSpa.ro. Based on your browsing and Online behavior, tracked by cookies, we may provide online advertisements to some of our products may be in line with your specific interests. Based on your Online browsing information you are placed in an interest group with other similar customers in terms of browsing behavior and we will thus deliver advertisements based on those interests, legally based on consent. Opting out of online behavioral advertising will not stop the display of general advertisements, but they are no longer individualized based on specific interests. For profiling and sending personalized offers. For cookies that track online behavior. Personal data collected automatically to maintain and secure aboutSpa.ro. To maintain and secure the site we use: IP address; Internet browser and operating system version; HHTP/HTTPS protocol data. Based on legitimate interest, iImplementing and maintaining the functionality and security measures of despreSpa.roWe process this data for: ensuring the functionality and security of the Online Platform. Financial statements and reporting defense of legal claims and proceedings of state authorities. We process data for financial statements as well as for filing tax and accounting returns with tax authorities. For legal actions to which we are a party or the protection of interests against abusive or unjustified claims/ claims. To provide personal data to the competent authorities and institutions, in the framework of proceedings/investigations or other steps required by law. To comply with the legal obligations imposed by applicable tax and accounting legal provisions. To exercise and defend legitimate rights. To comply with specific legal obligations imposed by legal provisions.

Who has access to your data?

Personal data submitted by you are processed only by Exclusive About SPA SRL and will not be disclosed to other third parties without your explicit consent unless there is a legal/contractual obligation on us to disclose this data.  

Exclusive About SPA SRL will share your personal data with banking and non-banking financial institutions, public authorities, judicial bodies, external consultants to whom we have outsourced the provision of certain services and other categories of recipients. Exclusive About SPA SRL may, depending on the specific circumstances, communicate your personal data to partners or third party service providers with whom Exclusive About SPA SRL cooperates.

Please be aware that the aboutSpa.ro website may contain links to other websites that may have a different personal data processing policy than Exclusive About SPA SRL, the undersigned assumes no responsibility for the information sent or collected by these third parties.

Depending on the context there is a possibility that we may find ourselves in the situation of providing information, both globally and internally or externally, to our partners with whom we transfer data in compliance with the provisions of Regulation 679/2016, by virtue of ensuring the most professional services. The information controlled by Exclusive About SPA SRL may be transferred, transmitted, stored or processed in the EU or in countries other than the country in which you are a resident, for the purposes described in this policy. 

How long is your data stored?

The personal data provided by you will be processed and stored for the maximum period required by the laws in force. Thus:

  • When you use our services, we keep your personal data for the entire duration of our contractual relationship and thereafter for the period established by the financial accounting legislation, i.e. for a period of 10 years;
  • In case you want to send us various requests (e-mails requesting offers, questions about events) we keep your personal data for a period not exceeding 1 year from the last correspondence sent.
  • If you create an account on our website, your data will be kept until you decide to delete your account.
  • If you participate in a promotional offer, we will retain your personal data for the duration of the promotional offer and then for 90 days.
  • If you have given us your consent to use your personal data for marketing purposes, we keep this data until you ask us to delete it or after the end of the marketing campaign, for 90 days. Please note that data stored in our database for direct marketing communications is deleted 90 days after the last interaction with you.
  • If cookies are stored on your computer, we keep them as long as necessary to achieve the purposes and for a period defined in accordance with legal regulations. We note that the data processed by cookies (to provide us with online behavioral advertising, to enable the distribution of our content on social media sites, etc.) will be kept for a maximum of 1 year after their collection based on your consent. 

Exclusive About SPA SRL will review the need for continued retention of your personal data: every 90 days we review the collected and processed data in order to filter, sort and maintain processing only for data for which the purpose of processing is current. 

We delete your data at the time you request us to do so, except for data the provision and processing of which is required by a legal provision, which we delete within the time limit prescribed by law for doing so. 

What are your rights?

You have a number of rights under applicable data protection regulations. 

  1. Right to access data.You have the right to obtain confirmation as to whether or not your personal data is processed by us. In addition, you have the right to obtain more detailed information as to the personal data stored and as to their processing by us and, in certain circumstances, you have the right to obtain a copy of such personal data.
  2. Right to rectification of data.You have the right to request the rectification of incorrect personal data and, taking into account the purpose for which they are processed, to request the completion of missing personal data.
  3. Right to erasure. In certain cases, you have the right to have your personal data deleted without undue delay. These circumstances include:
  • when personal data are no longer necessary in relation to the purposes for which they were collected or processed;
  • when you withdraw your consent to consent-based processing;
  • when the processing is for direct marketing purposes;
  • where personal data have been processed without complying with the applicable law. 

There are certain general exceptions to the right to erasure. These general exceptions include cases where processing is necessary: 

    • for exercising the right to freedom of expression and information;
    • to fulfill legal obligations;
    • for the establishment, exercise and defense of legal claims.
  1. Right to restriction of processing.In certain situations, you have the right to restrict the processing of your personal data. Where processing has been restricted, we may continue to store your personal data. Otherwise, we will process it only when:
  • we have your consent;
  • are necessary for the establishment, exercise or defense of legal claims;
  • are necessary to protect the rights of another natural or legal person;
  • for public interest considerations.
  1. The right to data portability.You have the right to move, copy, transfer the data concerning you from our database to another database. This applies only to data you have provided, where the processing is based on your consent or based on a contract and is implemented by automated means. However, this right does not apply where its exercise would adversely affect the rights and freedoms of others.
  2. Right to oppose. You may object at any time to the processing of your data where such processing is based on a legitimate interest.
  3. Right to withdraw consent.To the extent that the lawful basis for processing the data derives from your consent, you have the right to withdraw that consent at any time. Withdrawal of consent given by you does not affect the lawfulness of processing based on consent prior to the withdrawal of consent. 
  4. Right to disable cookies - You have the right to disable cookies in the settings of internet browsers, which are usually programmed by default to accept cookies. Many cookies are used to enhance the usability or functionality of websites, so disabling cookies may prevent you from using certain parts or applications of websites. If you wish to restrict or block all cookies set by our website/applications, you can do so by changing your browser settings. Link to aboutSpa.co.uk Cookie Policy. 
  5. Right to complain to the data protection supervisory authority.You have the right to register a complaint with your local data protection supervisory authority at any time. The data protection supervisory authority in Romania is:

National Supervisory Authority for Personal Data Processing

Address. General Gheorghe Magheru 28-30, 010336, Bucharest, Romania

Phone: +40318059211

Website: http://www.dataprotection.ro/

Exclusive About SPA SRL makes every effort to protect your personal data and to comply with data protection regulations in force. If you have any dissatisfaction with the processing and protection of your personal data or with the information we have provided to you, we encourage you to notify us so that we can improve our services. Please also contact us without hesitation when you wish to exercise your rights.

Please contact us using the contact details indicated at the beginning of this document. Please also provide us with information relevant to processing your request, including your full name and e-mail address, so that we can identify you. We will process your request without undue delay. 

In order to help facilitate communication with you, we have designated a contact person who can be reached by e-mail office@despreSpa.ro or phone +4 0745.411.411.111

How is your data stored?

The processing of personal data is carried out by automated and manual means, in compliance with legal requirements and under conditions that ensure the security, confidentiality and respect for the rights of data subjects.

All documents containing personal data shall be recorded and follow the rules for storage, processing, duplication, transportation, transmission, destruction and archiving laid down by the legal regulations in force and by internal procedures.

Legal requests

Exclusive About SPA SRL accesses, retains and provides your information to regulators, law enforcement or other entities:

      1. In response to legal requests when the law requires us to do so.
      2. When we believe, in good faith, that it is necessary to detect, prevent and respond to acts of fraud, to protect us (including our rights, property and materials), you and others, including in regulatory investigations or inquiries. The information we receive about you may be stored for a longer period of time when subject to a legal demand or legal obligation. 

How do you have access to your data?

You can modify the data provided or request information about the processing of your personal data, including requests to exercise your rights, by sending an e-mail to the following address: office@despreSpa.ro, or if you have an account directly from your account settings. 

You can unsubscribe from the newsletter by selecting the option unsubscribein the footer of any newsletter.

Exclusive About SPA SRL will provide information in electronic format where possible, unless you request another format.

The information provided, as well as any communication to be transmitted in electronic form and the steps taken in exercising your above rights are provided by Exclusive About SPA SRL and despreSpa.ro free of charge. However, if your claims are unfounded or excessive, in particular because of their repetitive nature, Exclusive About SPA SRL SRL may:

  • or to charge a fee taking into account the administrative costs of providing the information or communication or of taking the action requested;
  • or refuse to comply with the request.

AboutSPA.ro team

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