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Privacy Policy 2018-08-03T11:44:08+00:00
 This privacy policy has been compiled to better serve those who are concerned with how their ‘Personally identifiable information’ (PII) is being used online. PII, as used in US privacy law and information security, is information that can be used on its own or with other information to identify, contact, or locate a single person, or to identify an individual in context. Please read our privacy policy carefully to get a clear understanding of how we collect, use, protect or otherwise handle your Personally Identifiable Information in accordance with our website.

WHAT DATA DO WE COLLECT ABOUT YOU, FOR WHAT PURPOSE AND ON WHAT GROUND WE PROCESS IT

Personal data means any information capable of identifying an individual. It does not include anonymized data.

We may process the following categories of personal data about you:

  • Communication Data that includes any communication that you send to us whether that be through the contact form on our website, through email, text, social media messaging, social media posting or any other communication that you send us. We process this data for the purposes of communicating with you, for record keeping and for the establishment, pursuance or defense of legal claims. Our lawful ground for this processing is our legitimate interests which in this case are to reply to communications sent to us, to keep records and to establish, pursue or defend legal claims.
  • Customer Data that includes data relating to any purchases of goods and/or services such as your name, title, billing address, delivery address email address, phone number, contact details, purchase details and your card details. We process this data to supply the goods and/or services you have purchased and to keep records of such transactions. Our lawful ground for this processing is the performance of a contract between you and us and/or taking steps at your request to enter into such a contract.
  • User Data that includes data about how you use our website and any online services together with any data that you post for publication on our website or through other online services. We process this data to operate our website and ensure relevant content is provided to you, to ensure the security of our website, to maintain back- ups of our website and/or databases and to enable publication and administration of our website, other online services and business. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business.
  • Technical Data that includes data about your use of our website and online services such as your IP address, your login data, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website. The source of this data is from our analytics tracking system. We process this data to analyze your use of our website and other online services, to administer and protect our business and website, to deliver relevant website content and advertisements to you and to understand the effectiveness of our advertising. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business and to grow our business and to decide our marketing strategy.
  • Marketing Data that includes data about your preferences in receiving marketing from us and our third parties and your communication preferences. We process this data to enable you to partake in our promotions such as competitions, prize draws and free giveaways, to deliver relevant website content and advertisements to you and measure or understand the effectiveness of this advertising. Our lawful ground for this processing is our legitimate interests which in this case are to study how customers use our products/services, to develop them, to grow our business and to decide our marketing strategy.
  • We may use Customer Data, User Data, Technical Data and Marketing Data to deliver relevant website content and advertisements to you (including Facebook adverts or other display advertisements) and to measure or understand the effectiveness of the advertising we serve you. Our lawful ground for this processing is legitimate interests which is to grow our business. We may also use such data to send other marketing communications to you. Our lawful ground for this processing is either consent or legitimate interests (namely to grow our business).

Sensitive Data

We do not collect any Sensitive Data about you. Sensitive data refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. We do not collect any information about criminal convictions and offenses.

Where we are required to collect personal data by law, or under the terms of the contract between us and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver goods or services to you). If you don’t provide us with the requested data, we may have to cancel a product or service you have ordered but if we do, we will notify you at the time.

We will only use your personal data for a purpose it was collected for or a reasonably compatible purpose if necessary. For more information on this please email us at love@lenkalutonska.com. In case we need to use your details for an unrelated new purpose we will let you know and explain the legal grounds for processing.

We may process your personal data without your knowledge or consent where this is required or permitted by law.

We do carry out automated decision making. These decisions are taken in preparation for, or in relation to, a contract with the individual concerned AND are to give the individual something they have asked for; OR are where steps have been taken to safeguard the legitimate interests of the individual, such as allowing them to appeal the decision.

HOW WE COLLECT YOUR PERSONAL DATA

We may collect data about you by you providing the data directly to us (for example by filling in forms on our site or by sending us emails). We may automatically collect certain data from you as you use our website by using cookies and similar technologies. Please see our cookie policy for more details about this.

We may receive data from third parties such as analytics providers such as Google based outside the EU, advertising networks such as Facebook based outside the EU, such as search information providers such as Google based outside the EU, providers of technical, payment and delivery services, such as data brokers or aggregators.

MARKETING COMMUNICATIONS 

Our lawful ground of processing your personal data to send you marketing communications is either your consent or our legitimate interests (namely to grow our business).

Under the Privacy and Electronic Communications Regulations, we may send you marketing communications from us if (i) you made a purchase or asked for information from us about our goods or services or (ii) you agreed to receive marketing communications and in each case you have not opted out of receiving such communications since. Under these regulations, if you are a limited company, we may send you marketing emails without your consent. However, you can still opt out of receiving marketing emails from us at any time.

Before we share your personal data with any third party for their own marketing purposes we will get your express consent.

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or OR by emailing us at roswitha[at]roswithaherman.com at any time.

If you opt out of receiving marketing communications this opt-out does not apply to personal data provided as a result of other transactions, such as purchases, warranty registrations etc.

DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the parties set out below:

  • Service providers who provide IT and system administration services.
  • Professional advisers including lawyers, bankers, auditors and insurers.
  • Government bodies that require us to report processing activities.
  • Third parties to whom we sell, transfer, or merge parts of our business or our assets.

We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.

We do not sell, trade, or otherwise transfer to outside parties your personally identifiable information unless we provide you with advance notice. This does not include website hosting partners and other parties who assist us in operating our website, conducting our business, or servicing you, so long as those parties agree to keep this information confidential. We may also release your information when we believe release is appropriate to comply with the law, enforce our site policies, or protect ours or others’ rights, property, or safety.

However, non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses.

INTERNATIONAL TRANSFERS

We are subject to the provisions of the General Data Protection Regulations that protect your personal data. Where we transfer your data to third parties outside of the EEA, we will ensure that certain safeguards are in place to ensure a similar degree of security for your personal data. As such:

  • We may transfer your personal data to countries that the European Commission have approved as providing an adequate level of protection for personal data by; or
  • If we use US-based providers that are part of EU-US Privacy Shield, we may transfer data to them, as they have equivalent safeguards in place; or
  • Where we use certain service providers who are established outside of the EEA, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe.

If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.

DATA SECURITY

We have put in place security measures to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed without authorization. We also allow access to your personal data only to those employees and partners who have a business need to know such data. They will only process your personal data on our instructions and they must keep it confidential.

We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach if we are legally required to.

Our website is scanned on a regular basis for security holes and known vulnerabilities in order to make your visit to our site as safe as possible.

We use regular Malware Scanning.

Your personal information is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the information confidential. In addition, all sensitive/credit information you supply is encrypted via Secure Socket Layer (SSL) technology.
We implement a variety of security measures when a user places an order to maintain the safety of your personal information.
All transactions are processed through a gateway provider and are not stored or processed on our servers.

DATA RETENTION

We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

When deciding what the correct time is to keep the data for we look at its amount, nature and sensitivity, a potential risk of harm from unauthorized use or disclosure, the processing purposes, if these can be achieved by other means and legal requirements.

For tax purposes, the law requires us to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they stop being customers.

In some circumstances, we may anonymize your personal data for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

THIRD-PARTY LINKS

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

Occasionally, at our discretion, we may include or offer third party products or services on our website. These third party sites have separate and independent privacy policies. We, therefore, have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our site and welcome any feedback about these sites.

DO WE USE “COOKIES”?

Yes. Cookies are small files that a site or its service provider transfers to your computer’s hard drive through your Web browser (if you allow) that enables the site’s or service provider’s systems to recognize your browser and capture and remember certain information. For instance, we use cookies to help us remember and process the items in your shopping cart. They are also used to help us understand your preferences based on previous or current site activity, which enables us to provide you with improved services. We also use cookies to help us compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future.
We use cookies to:
      Help remember and process the items in the shopping cart.
      Understand and save user’s preferences for future visits.
      Keep track of advertisements.
      Compile aggregate data about site traffic and site interactions in order to offer better site experiences and tools in the future. We may also use trusted third party services that track this information on our behalf.
You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser (like Internet Explorer) settings. Each browser is a little different, so look at your browser’s Help menu to learn the correct way to modify your cookies.
If you disable cookies off, some features will be disabled. It won’t affect the users’ experience that makes your site experience more efficient and some of our services will not function properly.
However, you can still place orders.

HOW DO WE USE COOKIES

  • We use cookies to track your use of our website. This enables us to understand how you use the site and track any patterns with regards how you are using our website. This helps us to develop and improve our website as well as products and / or services in response to what you might need or want.
  • Cookies are either:

– Session cookies: these are only stored on your computer during your web session and are automatically deleted when you close your browser – they usually store an anonymous session ID allowing you to browse a website without having to log in to each page but they do not collect any personal data from your computer; or

– Persistent cookies: a persistent cookie is stored as a file on your computer and it remains there when you close your web browser. The cookie can be read by the website that created it when you visit that website again. We use persistent cookies for Google Analytics.

  • Cookies can also be categorized as follows:

– Strictly necessary cookies: These cookies are essential to enable you to use the website effectively, such as when buying a product and / or service, and therefore cannot be turned off. Without these cookies, the services available to you on our website cannot be provided. These cookies do not gather information about you that could be used for marketing or remembering where you have been on the internet.

– Performance cookies: These cookies enable us to monitor and improve the performance of our website. For example, they allow us to count visits, identify traffic sources and see which parts of the site are most popular.

– Functionality cookies: These cookies allow our website to remember choices you make and provide enhanced features. For instance, we may be able to provide you with news or updates relevant to the services you use. They may also be used to provide services you have requested such as viewing a video or commenting on a blog. The information these cookies collect is usually anonymised.

WHAT RIGHTS DO YOU HAVE AS A USER OF ROSWITHAHERMAN.COM?

The Regulation recognizes a series of 8 important rights (the operator is required to ensure compliance):

The right to information – art. 13 and 14 GDPR. These allow the data subjects to know, from the time they are collected, how those data will be used, to whom they will be disclosed or transferred, what rights the data subjects have on the processed data, etc.

Right of access to the data – art. 15 GDPR. We allow you to obtain from us confirmation of processing or not of the personal data you are interested in and, if so, access to that data and other useful information.

Right to delete data – art. 17 GDPR. It allows you to obtain from us the deletion of your personal data, without undue delays. There are, however, exceptions to this rule, such as the idea that some data are processed to provide the public with the right to information, that they are processed for statistical or archival purposes, that they are processed to meet a legal obligation or that we process them for establishing or defending the right in court.

Right to rectification of data – art. 16 GDPR. It allows you to obtain from us, without undue delays, the rectification or completion of inaccurate personal data concerning you.

Right to Restrict Data – Art. 18 GDPR. It is a temporary right. In some circumstances, between the time when, for example, we make the decision to delete a specific date (we no longer need personal data for processing) and the actual deletion of the data, send a request that you oppose deletion, motivating the fact that you need these data to find, exercise or defend a right in court. As a result of such a request, we will “freeze” the data by stopping their processing for a certain amount of time.

Right to data portability – art. 20 GDPR. You have the right to receive personal data concerning you and which you have provided to the operator (processing them under a contract or by your consent by automatic means) in a structured format that is currently used and may be automatically read and you are entitled to transmit this data to another operator without any barriers on our part. In other words, personal data will be provided in a structured format so that you can decide to download them or, on the contrary, send them to another operator.

Right to the opposition – art. 21 GDPR. You have the right to oppose, for example, the processing of personal data when it is processed for direct marketing purposes. To clarify how you can exercise this right, it should be noted, for example, that in all newsletters coming from Roswithaherman.com (no matter if we are talking about newsletters that offer only newsletters or newsletters promoting law services or products. ) you will always be able to unsubscribe. We offer this possibility in all situations, regardless of whether or not the law compels us (not all emails from us are considered to be direct marketing), because it seems important that your interaction with Roswithaherman.com only exists for as long as possible you want it.

The right not to be the subject of a decision solely based on automatic processing, including the creation of profiles, which produce legal effects which concern the data subject or which affect a significant degree to the same extent. Avocatnet.ro does not develop such profiles to be followed by automated decisions with a significant legal or similar effect on the data subject. When we create such profiles, we will announce and modify this notice.

Right to file a complaint with the National Supervisory Authority for Personal Data Processing. B-dul G-ral. Gheorghe Magheru 28-30, Sector 1, postal code 010336, Bucharest, Romania. +40.318.059.211 / +40.318.059.212, anspdcp@dataprotection.ro.

Please note the following:

Time period: We will try to respond to your request within 30 days and we may extend this term for specific reasons related to the complexity of your request. In all cases, if this period is extended, we will inform you of the extension period and the reasons that led to it.

Restriction of access: In certain situations, we may not be able to provide access to all or some of our personal data due to legal provisions. If we refuse your access request, we will inform you of the reason for the refusal.

No Identity: In some cases, we may not be able to search for your personal data because of the identifiers you provide in your request.

GOOGLE

We do not use Google AdSense Advertising on our website.

CALIFORNIA ONLINE PRIVACY PROTECTION ACT

CalOPPA is the first state law in the nation to require commercial websites and online services to post a privacy policy. The law’s reach stretches well beyond California to require a person or company in the United States (and conceivably the world) that operates websites collecting personally identifiable information from California consumers to post a conspicuous privacy policy on its website stating exactly the information being collected and those individuals with whom it is being shared, and to comply with this policy. – See more at: http://consumercal.org/california-online-privacy-protection-act-caloppa/#sthash.0FdRbT51.dpuf

According to CalOPPA we agree to the following:

Users can visit our site anonymously.
Once this privacy policy is created, we will add a link to it on our home page, or as a minimum on the first significant page after entering our website.
Our Privacy Policy link includes the word ‘Privacy’, and can be easily be found on the page specified above.
Users will be notified of any privacy policy changes:
      On our Privacy Policy Page
Users are able to change their personal information:
      By emailing us

How does our site handle do not track signals?

We honor do not track signals and do not track plant cookies, or use advertising when a Do Not Track (DNT) browser mechanism is in place.

Does our site allow third party behavioral tracking?

It’s also important to note that we allow third party behavioral tracking.

COPPA (Children Online Privacy Protection Act)

When it comes to the collection of personal information from children under 13, the Children’s Online Privacy Protection Act (COPPA) puts parents in control. The Federal Trade Commission, the nation’s consumer protection agency, enforces the COPPA Rule, which spells out what operators of websites and online services must do to protect children’s privacy and safety online.

We do not specifically market to children under 13.

FAIR INFORMATION PRACTICES 

The Fair Information Practices Principles form the backbone of privacy law in the United States and the concepts they include have played a significant role in the development of data protection laws around the globe. Understanding the Fair Information Practice Principles and how they should be implemented is critical to comply with the various privacy laws that protect personal information.

In order to be in line with Fair Information Practices we will take the following responsive action, should a data breach occur:

We will notify the users via email
      Within 1 business day
We will notify the users via in site notification
      Within 1 business day
We also agree to the individual redress principle, which requires that individuals have a right to pursue legally enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data users, but also that individuals have recourse to courts or a government agency to investigate and/or prosecute non-compliance by data processors.

CAN SPAM Act

The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations.

We collect your email address in order to:

      Send information, respond to inquiries, and/or other requests or questions.
      Process orders and to send information and updates pertaining to orders
      We may also send you additional information related to your product and/or service.
      Market to our mailing list or continue to send emails to our clients after the original transaction has occurred

To be in accordance with CANSPAM we agree to the following:

      NOT use false, or misleading subjects or email addresses
      Identify the message as an advertisement in some reasonable way
      Include the physical address of our business or site headquarters
      Monitor third party email marketing services for compliance, if one is used.
      Honor opt-out/unsubscribe requests quickly
      Allow users to unsubscribe by using the link at the bottom of each email


If at any time you would like to unsubscribe from receiving future emails, you can email us at

      Follow the instructions at the bottom of each email and we will promptly remove you from ALL correspondence.

CONTACTING US

If there are any questions regarding this privacy policy you may contact us using the information below.

RoswithaHerman.com

[Empowering Generations SRL-D]

loc. Targoviste, nr 171
Balint, Timis, 307008
Romania
roswitha [at] roswithaherman.com
Last Edited on 3rd of August 2018

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