TZUBY TOYS S.R.L., headquartered in ȘOS. BERCENI, NR.96, CAMERA 44, BL.A, AP.12.05, Bucharest, Sector 4, fiscal identification code 43993609, registered at the Trade Register Office under no. J40 / 5553/2021 (“TZUBY TOYS S.R.L.”, “we”) processes your personal data as an operator (“Personal Data”). The purpose of this disclosure note (“Policy”) is to detail how TZUBY TOYS S.R.L. processes your Personal Data.
Personal data processed : name, surname, e-mail address, telephone number.
| Purpose of processing | Legal basis |
| Contacting the customer online in connection with the requested offer or in connection with solving the indicated problem | Execution of a contract to which the data subject is a party or to take action at the request of the data subject before concluding a contract (art. 6, paragraph 1, letter b of the RGPD) |
Personal data processed : name, surname, payment amount, bank card details.
| Purpose of processing | Legal basis |
| Payment for purchased products | Execution of a contract to which the data subject is a party or to take action at the request of the data subject before concluding a contract (art. 6, paragraph 1, letter b of the RGPD) |
Personal data processed : name, surname, products purchased, delivery address, telephone number, any additional information provided by the customer.
| Purpose of processing | Legal basis |
| Delivery of the placed order | Execution of a contract to which the data subject is a party or to take action at the request of the data subject before concluding a contract (art. 6, paragraph 1, letter b of the RGPD) |
Personal data processed : name, surname, products purchased, delivery address, telephone number, e-mail address, any additional information provided by the customer.
| Purpose of processing | Legal basis |
| Completing and placing the order | Execution of a contract to which the data subject is a party or to take action at the request of the data subject before concluding a contract (art. 6, paragraph 1, letter b of the RGPD) |
Personal data processed : name, surname, product added.
| Purpose of processing | Legal basis |
| Add the product to your shopping cart | Execution of a contract to which the data subject is a party or to take action at the request of the data subject before concluding a contract (art. 6, paragraph 1, letter b of the RGPD) |
Personal data processed : name, surname, home address, products purchased, payment amount.
| Purpose of processing | Legal basis |
| Issuing the invoice for the purchased products | Fulfillment of a legal obligation of the Company (art. 6, paragraph 1, letter c of the RGPD)Details: fulfillment of tax obligations |
Personal data processed : name, surname, e-mail address.
| Purpose of processing | Legal basis |
| Creating the client’s user account | Execution of a contract to which the data subject is a party or to take action at the request of the data subject before concluding a contract (art. 6, paragraph 1, letter b of the RGPD) |
Personal data processed : image.
| Purpose of processing | Legal basis |
| Completing the user profile of the client | Consent of the data subject (art. 6, paragraph 1, letter a of the RGPD) |
Personal data processed : name, surname, order date, products ordered, payment amount.
| Purpose of processing | Legal basis |
| Display order history | Execution of a contract to which the data subject is a party or to take action at the request of the data subject before concluding a contract (art. 6, paragraph 1, letter b of the RGPD) |
Personal data processed : name, surname, telephone number, e-mail address.
| Purpose of processing | Legal basis |
| Sending business messages in order to promote the company’s services | Consent of the data subject (art. 6, paragraph 1, letter a of the RGPD) |
Personal data processed : name, surname, e-mail address, other information mentioned by the customer.
| Purpose of processing | Legal basis |
| Requesting and analyzing customer reviews in order to improve services | Consent of the data subject (art. 6, paragraph 1, letter a of the RGPD) |
Personal data processed : name, surname, home address.
| Purpose of processing | Legal basis |
| Protecting legitimate rights and interests and upholding any claims before the judiciary or any other public authority | The legitimate interest of the Company (art. 6, paragraph 1, letter f of the RGPD)Details: the legitimate interest of the company in defending the legitimate rights or interests or in supporting the claims arising out of or in close connection with the conclusion or performance of the contract or in order to exercise the right of defense in the event of litigation against the company |
You may refuse to provide certain Personal Data, but in such a case you may not be able to benefit from certain services specific to the report described in this Policy.
The legal basis for processing differs depending on the actual situation and the Personal Data processed.
In the event that we process your Personal Data on the basis of your consent, we will request your free, informed, specific and unequivocal consent to such processing. By expressing your consent, you agree that we may collect, use, disclose, process and transfer Personal Data in accordance with this Policy.
The source of Personal Data is: the online customer.
Your Personal Data will not be processed in order to generate decisions based exclusively on automatic processing that would produce legal effects on you or affect you to a significant extent, within the meaning of those provided by art. 22 para. (1) of the RGPD.
The processing time of the Personal Data differs depending on the specific processing operation:
| operation | time |
| Contacting the customer online | the time required to resolve the request |
| Making the payment | until payment is completed |
| Order delivery | the time required to deliver the products |
| Placing the order | 3 years |
| Add to cart | until the order is completed or until the products are deleted from the cart |
| Invoice issuing | 10 years |
| User account creation | the duration of the account |
| Completing the user profile | the duration of the account |
| Order history | the duration of the account |
| Commercial messages | until the moment of withdrawal of consent |
| Customer feedback | the time required to analyze the opinion |
| Disputed issues | the time required to resolve the dispute |
In certain circumstances, we may retain your Personal Data for longer periods of time in order to have an accurate record of your relationship with us in the event of any complaints or if we reasonably believe that there is a prospect of litigation.
We may transfer Personal Data, to the extent necessary, to the following categories of recipients: IT service providers, payment service providers, courier service providers, accounting service providers, marketing service providers, state authorities.
These recipients may be located in the European Union and / or in the European Economic Area, as well as outside them, including in countries that are not recognized as providing an adequate level of protection, in which case the transfer of Personal Data is carried out only if there is appropriate guarantees, in accordance with applicable law (such as standard contractual clauses issued by the European Commission). You can request a list of recipients from third countries, as well as a copy of the agreed provisions that ensure an adequate level of protection of Personal Data.
The security of your Personal Data is important to us. Therefore, your Personal Data will be processed by the application of reasonable technical and organizational measures to protect it, such as restricting access to Personal Data, encrypting or anonymizing Personal Data, storing it on secure media. However, despite our best efforts, we cannot always guarantee the effectiveness of the security measures implemented, and therefore we cannot guarantee the security of Personal Data at any time.
Right of access: You have the right to obtain confirmation from us that your Personal Data is processed by us, as well as information on the specifics of the processing such as: purpose, categories of Personal Data processed, their recipients, period for which they are kept , their source, if we transfer them abroad and how we protect them, your rights, the right to file a complaint with the supervisory authority.
Right to rectification: You have the right to request the rectification of your Personal Data, provided that the applicable legal requirements are complied with. In the event of errors, after notification, we will immediately correct your Personal Data.
Right to delete:In certain cases, you may request the deletion of Personal Data, such as when: (i) it is no longer necessary for the purposes for which it was collected and processed; (ii) you have withdrawn your consent to the processing of Personal Data and we may no longer process Personal Data on other legal grounds; (iii) Personal Data are processed against the law; (iv) exercise a legal right to object. We are under no obligation to comply with your request for deletion if the processing of Personal Data is necessary to comply with a legal obligation, or to establish, exercise or defend a right in court. Also,
Processing restriction:You may request that we restrict the processing of your Personal Data in the following situations: (i) if you challenge the correctness of the Personal Data, for a period that allows us to verify the accuracy of the Personal Data in question; (ii) if the processing is illegal, and you object to the deletion of the Personal Data, requesting in return the restriction of their use; (iii) if we no longer need the Personal Data for the purpose of processing, but you request it from us for a court action; (iv) if you objected to the processing, for the period during which it is verified that our legitimate rights as an operator prevail over those of the data subject. We may continue to use Personal Data following a request for a restriction, provided that: (i) we have your consent; (ii) to establish, exercise or ensure the defense of a right in court; or (iii) to protect the rights of another natural or legal person.
Right to data portability: To the extent that Personal Data is processed on the basis of your consent or for the performance of the contract and processing is done by automatic means, you have the right to have your Personal Data provided to you in a structured, used format. automatically and automatically readable and you have the right to transmit this Personal Data to another operator. This right does not adversely affect the rights and freedoms of others .
Right to object: In certain situations, such as when we process your Personal Data on the basis of a legitimate interest, you have the right to object to the processing of your Personal Data by us. In case of unjustified opposition, TZUBY TOYS SRL is entitled to further process the Personal Data. You may also object to the processing of your Personal Data for the purpose of sending commercial messages.
Revocation of consent: To the extent that we process your Personal Data on the basis of your consent, you may revoke your consent at any time without prejudice to the lawfulness of the consent-based processing prior to its withdrawal.
Automated individual decision-making: You have the right not to be subject to a decision based solely on automated processing, including profiling, which has legal effects on you or similarly affects you to a significant extent. This right does not apply if the decision: (i) is necessary for the conclusion or performance of a contract between you and us; (ii) is authorized by law to provide adequate safeguards for your rights and freedoms; (iii) is based on your explicit consent.
Right to contact the supervisory authority: You have the right to file a complaint with the National Authority for the Supervision of Personal Data Processing (“ANSPDCP“) in connection with any violation of your rights regarding the processing of your Personal Data. The contact details of ANSPDCP are: B-dul G-ral. Gheorghe Magheru 28-30, Sector 1, postal code 010336 Bucharest, Romania; e-mail: anspdcp@dataprotection.ro.
To exercise the rights mentioned above, please contact us at the e-mail address: hello@tzubytoys.ro.
If you have any questions or concerns regarding this Policy or its implementation, you may contact us at hello@tzubytoys.ro.
