Privacy Policy

PRIVACY POLICY

(USER CUSTOMERS)

I. ABOUT US

ARTFUL LIVING S.R.L. , with registered office in Str. Lainici nr. 44-46, et. 2, ap. 5, cam. 1, Bucharest, Sector 1, Romania , CUI 44961583, registered with the Trade Register under no. J40/16599/2021 (hereinafter "Artful Living" or "we" or "us") is the personal data controller and the entity providing the Artful Living Application ("Application") available online on mobile.

We treat issues of personal data privacy seriously and responsibly, and the protection of your personal data is one of our priorities, in compliance with the principles set out in the applicable data protection legislation in Romania, including the provisions of the General Data Protection Regulation (EU) 2016/679 ("GDPR").

This privacy policy is intended for customers who are users of the App. This policy is intended to provide you with information about the processing of personal data provided to us by you or collected by us about you in our dealings with you through the App and through your access to the services available on the App ("Services"), as well as products sold by third party vendors on the App ("Products").

We make every effort and take all reasonable steps to ensure the confidentiality and protection of personal data processed through the Application. At the same time, please be aware that third party providers who offer their Services and Products through the App ("Providers") and who have access to some of your personal data through the App, perform activities specific to their field of activity, for which they are fully responsible. From a personal data protection perspective, please be aware that the Providers are themselves personal data controllers who are independently and separately responsible for the way they process your data. Thus, they are joint controllers with Artful Living only with respect to your personal data to which they have access through the App for (i) placing an order for Services/Products with the Suppliers and managing it (section II. 1 (4) below), and (ii) managing comments, reviews and other feedback related to the Services/Products/Supplier (section II. 1 (10) below).

With respect to any other processing operations that the Providers perform on the data, including but not limited to: resolving any complaints or requests related to the provision of the Service, non-conformities, return of the Products and refund of the price paid, warranty, validity of the Products, transmission of data to third parties contracted by the Supplier (e.g. to the extent necessary for the delivery of the Products or the provision of the Services), any processing activities related to the provision of the Service ordered and for which it is necessary to collect any personal data additional to those received from Artful Living through the Application (such as, for example, situations where the Supplier provides medical, financial or legal services, for the performance of which it is necessary to request additional personal data), own storage obligations or processing for marketing purposes, they will act as separate and independent personal data controllers. For details of the data processing carried out by the Providers, please refer to the information provided by them or request such information directly from them.

Please read the following carefully to understand our practices regarding the processing of your personal data and how we will treat it.

II. PROCESSING OF PERSONAL DATA

In the following sections you will find information on the purposes of the processing of personal data by Artful Living, the legal basis of the processing for each applicable purpose, the categories of data processed, the duration of the processing, the source of the data collection, the recipients and the transfer of personal data.

1. Purposes, categories of data, legal grounds and duration of processing

1. Purpose: To create a user account in the Application and provide access to the Application.

Categories of data: name, surname, e-mail address, phone number, date of registration in the App.

The conclusion and execution of the contract concluded between you and Artful Living in order to allow your use and access to the App and implicitly to the Services and Products available on the App.

The duration of the use of the Application, as well as the period necessary to protect Artful Living's rights, taking into account the law applicable to the contract, including the limitation period (3 years).

2. Purpose: To provide communications regarding the use of the App or the provision of the Services and Products available on the App, via the App chat or other means of communication agreed upon by the parties, in all situations required under the contract between you and Artful Living, including for the resolution of your requests related to orders.

Categories of data: name, surname, e-mail address, telephone number and/or any other data made available to Artful Living in the course of communications.

The performance of the contract entered into between you and Artful Living to enable your use of and access to the Services and Products available on the App.

Artful Living's legitimate interest in maintaining a good relationship with users by providing answers to any questions, suggestions, requests or complaints.

3. Purpose: To provide Services provided directly by Artful Living through the App.

Categories of data: identification data (name, surname, delivery address, e-mail address, telephone number), order data (Services purchased, order reference number generated and order date); the totality of the data on the desired Services you requested through the Application and any other data provided to Artful Living.

Performance of the contract between you and Artful Living to enable your use of and access to the Services provided through the App.

The legal obligations laid down by financial and accounting legislation.

The duration of the concluded contract (terms and conditions of the Application), as well as the period necessary to protect the rights of Artful Living, taking into account the law applicable to the contract, including the limitation period (3 years) and the deadlines provided for by tax and accounting legislation (archiving of supporting documentation after termination of the contract).

4. Purpose: To place orders for Supplier Services/Products and manage them.

Categories of data: identification data (name, surname, billing address, delivery address, e-mail address and telephone number); order data (Services or Products purchased, order reference number generated and order date.

The execution of the contract concluded between you and Artful Living in order to allow your use and access to the Services/Products available in the App.

The legal obligations laid down by financial and accounting legislation.

5. Purpose: To facilitate the processing through the App of payment for purchases of Services/Products available in the App and refunds/reimbursements and invoicing of orders (when invoicing through the App will be available).

Categories of data: identification data (name, surname, billing address, e-mail address); order data (Services/Products purchased, price, order reference number generated and order date); bank card data.

The execution of the contract concluded between you and Artful Living in order to allow your use and access to the Services/Products available in the App.

The legal obligations laid down by financial and accounting legislation.

Consent to retain bank card details for future payments (when this option will be available in the App).

6. Purpose: To provide promotional information about the Services available in the App or marketing communications about Artful Living's business.

Categories of data: first name, last name, email address

Consent.

The duration of the contractual relationship determined by the use of the Application or until consent is withdrawn.

7. Purpose: To manage, maintain and ensure the functionality of the Application (including fraud prevention).

Categories of data: any data in the App, including data contained in your user account, entered by you or the Provider into the App, or relating to information about your activity in the App.

Artful Living's legitimate interest in the management of its IT and communications systems.

8. Purpose: To organise the recovery of debts and to settle any legal situations arising in connection with the performance of the contract.

Categories of data: identification data (name, surname, e-mail address, postal address (domicile), telephone number) and/or any other data made available to Artful Living during the performance of the contract, insofar as the processing of such data is necessary on the basis of the legitimate interest of our company or, where applicable, required by law.

Artful Living's legitimate interest in protecting its financial situation and assets.

The legal obligation to provide data for the purpose of legal proceedings, judicial or extra-judicial formalities in connection with the performance of the contract.

The duration of the concluded contract (terms and conditions of the Application), as well as the period necessary to protect the rights of Artful Living, taking into account the law applicable to the contract, including the limitation period (3 years) and the deadlines provided for by tax and accounting legislation (archiving of supporting documentation after termination of the contract).

9. Purpose: To manage comments, reviews and other types of feedback that the customer submits about a specific Service/Product or about the Supplier.

Categories of data: first and last name, customer comment.

Artful Living's legitimate interest in providing services to the highest standards through the App and providing the opportunity to provide feedback.

The duration of the contractual relationship determined by the use of the Application.

2. Collection of personal data

Artful Living collects your personal data from the following sources: when you make it available to us directly through the App or under other contractual relationships between us and you, from the Providers in the App, or through information stored in the App related to the Services and Products purchased.

In order to provide the App and Services/Products to the best of its ability or to fulfil its legal obligations or in pursuit of its legitimate interests according to the processing purposes set out above, Artful Living may disclose personal data to the following categories of recipients: (i) our contractual partners and service providers (including proxies). These partners may be: Vendors registered on the App who offer their Services/Products through the App, the provider RCC Media Development SRL who provides us with technical maintenance services for the App, as well as the Worldline provider providing payment processing services for the payment of the Services/Products available on the App (your payment data will be transmitted directly to the payment processing service provider for processing the transaction and Artful Living will not access, store or save any data related to your card by which you make the payment, unless you give us your express consent to do so); (ii) public authorities, financial or legal auditors, or institutions with powers to carry out inspections and controls over our business and assets. These public authorities or institutions may be: The National Supervisory Authority for Personal Data Processing, the National Tax Administration Agency or other authorities with the power to audit our activity; (iii) for compliance with a legal requirement or to protect the rights and assets of our company or other entities or persons, such as courts, lawyers, notaries, bailiffs ; (iv) third party acquirers, to the extent that Artful Living's business would be transferred (in whole or in part) and the data of the data subjects would be part of the assets subject to such transaction.

The personal data that we disclose to third parties is limited to the minimum personal information necessary for disclosure and with the imposition of certain obligations on the third party processors in relation to data processing, such as the obligation not to use the personal data for any purpose other than that for which it was disclosed. Thus, we make every effort to ensure that all recipients of personal data comply with data safety and security obligations.

3. Transfer of personal data abroad

Our company transfers personal data outside Romania, to states in the European Union ("EU") or the European Economic Area ("EEA").Any future transfers made by Artful Living outside EU or EEA member state will comply with the legal requirements set out in the GDPR. Currently, both the App and the physical and electronic database containing personal data are hosted/stored on secure servers in Germany monitored by Artful Living. To the extent that Artful Living transfers personal data abroad in the future, it will ensure compliance with the legal requirements under the GDPR in this regard.

III. WHAT HAPPENS TO YOUR PERSONAL DATA AFTER THE PROCESSING HAS CEASED

Artful Living processes personal data only for the period of time necessary to achieve the processing purposes explained in the above section, while complying with the legal requirements in force. Should Artful Living determine that it has a legitimate interest or legal obligation to further process your personal data for other purposes, you will be duly informed to this effect.

Once the processing period indicated above expires and Artful Living no longer has legal or legitimate grounds to process your personal data, the data will be deleted in accordance with our internal procedures, which may involve archiving or destruction.

IV. REFUSAL TO PROVIDE DATA AND ITS CONSEQUENCES

The provision of your personal data is necessary for the purposes of registration in the App and the provision of the Services and Products and is in some cases a contractual obligation, an obligation necessary to enter into a contract with Artful Living, and in some cases a legal obligation, according to the purposes mentioned above in section II.1, points 1 - 5 and 9. Refusal to provide personal data, necessary to achieve the purposes mentioned above, will result in Artful Living being unable to register your application in the Application and, implicitly, to give you access to the Services and Products available in the Application.

V. SECURITY OF DATA PROCESSING

Artful Living is particularly and constantly concerned with evaluating and updating the security measures implemented to ensure safe and secure processing of personal data. In our efforts to provide a high degree of protection for the personal data we process, we have also implemented a number of special measures relating to network security, auditing and testing of infrastructure, training of employees involved and our own servers.

VI. TALE'S RIGHTS REGARDING DATA PROCESSING

As a data subject you have the following rights:

a) Right of access to personal data processed: the right to obtain confirmation as to whether or not your personal data are being processed and, if so, to have access to the type of personal data and the conditionsunder which they are processed;

b) The right to request rectification or erasure of personal data: The possibility to request rectification of inaccurate personal data, completion of incomplete data, or deletion of your personal data if (i) the data is no longer necessary for the original purpose (and there is no new lawful purpose), (ii) the legal basis for the processing is the data subject's consent, the data subject withdraws consent and there is no other lawful basis, (iii) the data subject exercises the right to object and the controller has no overriding legitimate grounds for continuing the processing, (iv) the data have been unlawfully processed, (v) erasure is necessary for compliance with EU or Romanian law, or (vi) the data have been collected in connection with information society services offered to children (if applicable), where specific consent requirements apply;

c) Right to request restriction of processing: the right to obtain restriction of processing in cases where: (i) you consider that the personal data processed is inaccurate, for a period allowing the controller to verify the accuracy of the personal data; (ii) the processing is unlawful, but you do not want us to erase the personal data, but to restrict the use of such data; (iii) if the data controller no longer needs your personal data for the purposes mentioned above, but you need the data in order to establish, exercise or defend a legal claim; or (iv) you have objected to the processing, for the period of time within which to verify whether the data controller's legitimate grounds outweigh the data subject's rights;

d) The right to withdraw your consent to processing, where the processing is based on consent, without affecting the lawfulness of the processing carried out up to that point;

e) The right to object to the processing of data on grounds relating to your particular situation, where the processing is based on legitimate interest, and to object at any time to the processing of data for direct marketing purposes, including profiling;

f) The right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning the data subject or otherwise significantly affects him or her;

g) The right to data portability, meaning the right to receive the personal data you have provided to the data controller in a structured, commonly used and machine-readable form, and the right to transfer that data to another controller where the processing is based on your consent or the performance of a contract and is carried out by automated means;

h) The right to lodge a complaint with the Data Protection Authority (ANSPDCP) and the right to apply to the competent courts.

ANSPDCP contact details: at its headquarters in B-dul G-ral Gheorghe Magheru nr. 28-30, district 1, Bucharest, postal code 0103336

- by accessing https://www.dataprotection.ro section "complaints"

- e-mail: anspdcp@dataprotection.ro

The above rights can be exercised at any time. To exercise these rights, we encourage you to send a request in writing, dated and signed or in electronic format to the contact details below.

VII. HOW TO CONTACT US

You can ask any questions using the following contract details:

ARTFUL LIVING S.R.L., postal address: Str. Lainici nr. 44-46, et. 2, ap. 5, cam. 1, Bucharest, District 1, Romania, for the attention of [Ionut Popescu Chiliment], e-mail address: ionut@didsecure.ro

VIII. CHANGES TO THIS POLICY

This policy may be amended from time to time and may be updated by Artful Living as necessary. Artful Living will notify you of any material or substantive changes to this policy and will ensure that such notification is made in a manner that ensures that you are aware of them, for example by posting them on the App or by any appropriate means that ensures effective communication.

The policy was last updated on 11.01.2022