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PRIVACY POLICY AND COOKIE POLICY



WHO WE ARE

This policy applies to the website www.toff.ro, hereinafter referred to as the “Website”.

The Website belongs to the data controller TERMINAL FASHION SRL, headquartered at Calea 13 Septembrie 90, COMPLEX MULTIFUNCȚIONAL GRAND, THE GRAND AVENUE, GROUND FLOOR, AXES D-E/6-7, Bucharest, Sector 5, registered under J40 /5170 /2010 and CUI 26951107, Telephone: +40737 66 66 22, Email: [email protected] (hereinafter referred to as the “Organization” or “TOFF” or “We”).

Contact details for personal data protection matters: Calea 13 Septembrie 90, COMPLEX MULTIFUNCȚIONAL GRAND, THE GRAND AVENUE, GROUND FLOOR, AXES D-E/6-7, Bucharest, Sector 5, registered under J40 /5170 /2010 and CUI 26951107, Telephone: +40737 66 66 22, Email: [email protected]


LEGAL BASIS FOR THE PROCESSING OF PERSONAL DATA

Definitions:

‘Personal data’ means any information that could identify you either directly or indirectly (for example, first name, last name, email/home address, IP address, username, etc.)

‘Personal data’ means any information that could identify you either directly or indirectly (for example, first name, last name, email/home address, IP address, username, etc.)

‘Processing’ means any operation or set of operations performed on personal data or on sets of personal data, whether or not by automated 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.


WHAT INFORMATION DO WE COLLECT FROM YOU AND HOW?

We collect and process the following types of information about you:


    1. General information:


    • when you subscribe to our newsletter


    • when you enter competitions and prize draws organized by us


    • when you register on our Website, by phone or by email, or by filling in personal information that we request from you or that we complete at your request in our stores


    • when you place an order on our Website


    • if you request to receive personalized online content, such as personalized advertising


    • if you contact or communicate with us (by phone, email, or otherwise) to find out more about a product or our customer support services, to report an issue with the Website, with a product, or for any other reason

 

With your consent, we process the following personal data that you provide when interacting with the Website and using its related services and features. The data may include your first and last name, gender, date of birth (day, month, and year), email address, telephone number, address, financial information (such as credit or debit card details), delivery address, billing address, and any other information you consider necessary to share with TERMINAL FASHION S.R.L..

The information collected from you through the Website will be compared/verified with the personal information you may have provided in one of our stores. This verification helps us ensure that the data we hold about you is accurate and up to date.

In certain situations, even without your prior consent, we may process your data in order to comply with legal obligations arising from laws, regulations, and EU legislation, to exercise rights in legal proceedings, to pursue our legitimate interests, and in all cases provided for under Articles 6 and 9 of the GDPR, where applicable.

Processing is carried out both by using computers and on paper, and always involves the implementation of the security measures required by applicable law.


    1. Information about you collected by other members of TERMINAL FASHION S.R.L.

 

This information is what we receive about you when you make a purchase in one of our stores. These stores will also provide us with a record of the transaction made by you.


    1. Information we receive about you from other sources

 

We work closely with third-party providers, for example business partners, subcontractors for technical, payment and delivery services, advertising networks, analytics service providers, and search information providers (SEO). If we receive information about you from them, we will ensure that such disclosure is made in compliance with data protection laws and that you have been informed that they may share your data. We may use this information to update our records about you and keep them current.


WHY DO WE USE YOUR DATA?

TERMINAL FASHION S.R.L. may use the personal data collected for the following purposes (the purposes for which we need your consent are marked with *):


    • to fulfill obligations arising from the contracts concluded between you and us and to provide you with the information, products, and services you request from us, namely to process and complete your orders and payments;


    • to remind you of the products you placed in your cart on the Website but did not complete the purchase process for *;


    • to adapt the content of our Website to your needs and preferences *


    • to prevent, detect, and investigate fraud, security breaches, violations of the law, or other misuse of the Website, and to enforce our General Terms and Conditions, which you can find here;


    • to respond to questions, requests, concerns, or complaints you have raised;


    • for our internal operations, including data analysis, testing, research, statistical purposes, or to resolve any Website functionality issues;


    • to provide you with information about other products and services we offer that are similar to those you have already purchased or enquired about. We will contact you by email with such information if you have given your prior consent. More information about this is set out below under the section “legal basis for processing” *;


    • to provide you with relevant advertising, for example newsletters *; and


    • to propose suggestions and recommendations regarding other products or services that may be of interest to you *.


    • to carry out automated profiling in order to identify the information or advertising you may wish to use, for example by creating individual or group profiles. *

 

Your data may be processed, even without your consent, for the purpose of complying with laws, regulations, and EU legislation (Art. 6.1(c) GDPR), to compile statistics regarding the use of the Website and to ensure its proper functioning (Art. 6.1(f) GDPR), to apply the Code of Conduct of TERMINAL FASHION S.R.L., and to establish or defend legal claims in the company’s interest.

We may also use and share anonymous non-personal data that we receive or collect without restriction.


WHAT IS THE LEGAL BASIS FOR PROCESSING YOUR DATA?

For some uses of your personal data (as described above), there is a legal basis under applicable data protection laws that allows us to use such personal data without your consent (these uses are not marked with *). For example, where it is necessary to use the information to enter into a contract with you or to take steps at your request before entering into a contract with you, such as processing an order, providing customer support services, or managing the customer account you registered on our Website. It also includes circumstances (as described below) where we have a legitimate interest in using your data, provided that your rights and interests are protected:


    • to ensure that we organize our database efficiently and understand how our customers make purchases in different parts of the world;


    • to send you marketing communications. You may opt out of our marketing communications at any time using the unsubscribe button at the bottom of each email or by contacting us at [email protected]


    • to show you personalized offers on our Website, through social media channels such as Facebook and Instagram, and by placing banner ads on third-party websites


    • to carry out research and analysis of your data (including purchase information), because this helps us get to know and better understand our customers, who they are, and how they interact with TERMINAL FASHION S.R.L.


    • to improve and ensure the security of the Website (for example, for statistical, testing, and analytical purposes, and to resolve functionality issues); and


    • to ensure that you are informed of any changes to the Website or to the terms of this Privacy Policy.

 

Where we have a legal basis to use your information without consent (as described above), this Privacy Policy fulfills our duty to process personal data fairly and lawfully by giving you appropriate notice and an explanation of how your personal data will be used.

Where consent is required for the use of your personal information, ticking the appropriate consent box or otherwise communicating your consent (for example, by email, by providing non-mandatory information, verbally in store, or on a store card) constitutes your consent for the use of your information for the purposes for which you have given consent. For example, we will only process your personal information for marketing purposes if we have your consent to do so.


MARKETING COMMUNICATIONS AND OTHER NOTICES

If you have given us your consent, we will send you information about the products, services, events, sales, and commercial communications of TERMINAL FASHION S.R.L. (including personalized online content and advertising, social media platforms, or about our online partners).

1. Our mailing list

We will ask whether you would like us to send you marketing messages when you tick the relevant boxes at the end of your shopping session, when you subscribe to our newsletter or updates, or when you register through the Website, by phone, by email, or through the personal information card in store.

2. Can I be removed from the mailing list?

We will send you special offers and promotions by email. If you no longer wish to receive offers and promotions by email, all you need to do is click the unsubscribe button/link in any email. You can unsubscribe at any time.

3. Will you share my data with third parties?

We will never share your email address for marketing purposes (except where third parties contact you on behalf of TERMINAL FASHION S.R.L.). We respect the confidentiality of your data and are committed to protecting it.


HOW DO WE STORE AND PROTECT YOUR DATA?

The confidentiality of your data as a natural person and as a customer is important to us, so we do not use the information you provide through the Website to know more about you than is necessary to process your orders and provide you with services such as updates or reminder services. Any personal data collected by us as a result of your use of the Website will be recorded electronically and used only in compliance with the GDPR.

Regarding any transfer of data outside the European Union, including to countries that do not guarantee the same level of personal data protection as provided by European legislation, TERMINAL FASHION S.R.L. informs you that such transfer will take place in accordance with the methods permitted by the GDPR.

How do we protect the information we hold about you in our systems? We protect the confidentiality of your data in several ways: Personal data is entered into our IT systems in full compliance with data protection legislation, including security and confidentiality profiles and based on principles of best practice, lawfulness, and transparency of processing. Access to information about your customer account is limited to those who need access in order to perform their job duties. We use full login and password controls in our system. All calls are recorded and monitored for training and security purposes. Database confidentiality and access control are periodically reviewed and updated as necessary to further protect the personal data we hold.

Persons who have access to personal data. The data is accessible to authorized personnel of TERMINAL FASHION S.R.L. authorized to process personal data, in particular personnel belonging to the following categories: IT and administrative staff, customer support services, marketing, as well as other persons who need to process the data in order to perform their job duties.


WITH WHOM WILL WE SHARE YOUR PERSONAL DATA?

Your data may be stored in a database that we, as well as other members of TERMINAL FASHION S.R.L., may access. We do this to help us efficiently organize our databases and understand how our customers may make purchases in different parts of the world.

We may also disclose your data to the following categories of third parties, in accordance with this Privacy Policy:


    • service providers (for example, IT services), business partners, suppliers, and subcontractors for the performance of any contract we enter into with you (such as, but not limited to, Website operations, payment services, couriers, fraud investigations, invoice collection, and affiliate and rewards programs);


    • analytics and search service providers that help us improve and optimize the Website;


    • law enforcement or regulatory agencies or authorized third parties, in response to a verified request relating to a criminal investigation or alleged illegal activity or any other activity through the Website that may expose us and/or the user or any third party to legal risks or liability; and


    • other business entities if we intend to merge with or be acquired by such entity. If such a situation occurs, we will require the resulting new entity to comply with this Privacy Policy in relation to your data.

 

These third parties that may receive your data will process such data for the purposes specified above and in accordance with applicable law. TERMINAL FASHION S.R.L. will keep a list of the third parties with whom the data is shared, which will be made available upon request.


HOW DO WE STORE YOUR DATA AND HOW CAN YOU ACCESS IT?

We will store your data for as long as is strictly necessary to provide you with the relevant services, for as long as you wish to stay in touch with us, or for as long as is necessary to provide you with customer support reports and analysis. Even if you ask us to delete your data, we may retain it in a form that does not identify you. If it is reasonably necessary or required to comply with legal or regulatory requirements, resolve disputes, prevent fraud and abuse, or enforce our terms and conditions, we may also retain certain information as necessary even after you close your account or it is no longer required for us to provide services to you. If you have not given your consent for us to use your data for marketing purposes, we will retain your data for 6 years after you have made a purchase from us.

TERMINAL FASHION S.R.L. does not knowingly collect personal data through its Website from persons under the age of 16. Therefore, if you are under the age of 16, please ask your parent or guardian to contact us at [email protected]. If a parent or guardian becomes aware that their child’s personal data has been provided to TERMINAL FASHION S.R.L., they must immediately inform TERMINAL FASHION S.R.L. If TERMINAL FASHION S.R.L. discovers that a person under the age of 16 has provided personal data, TERMINAL FASHION S.R.L. will delete such information from its systems immediately, unless the parent or guardian gives explicit consent for TERMINAL FASHION S.R.L. to process the child’s personal data for the specified purposes.


WHAT ARE YOUR RIGHTS?

You have the following rights regarding your personal data:


    • Right of Access. You have the right to access the data we hold about you, as well as an up-to-date list of the persons who may access your data. We will need you to prove your identity before providing your personal data.


    • Right to Rectification or Erasure. You have the right to request that we rectify or erase the personal data we hold about you (except where we have a legal right or legal obligation to retain it).


    • Right to Restriction of Processing. You have the right to restrict the processing of personal data where the data is inaccurate, our processing of the data is unlawful, or where we no longer need to use the data for the purposes for which we hold it.


    • Changing preferences. You may modify your data processing preferences at any time. For example, if you previously consented to direct marketing but have changed your mind, you can opt out of receiving marketing communications by contacting us using the details provided below or by clicking the “unsubscribe” link in any communication you receive from us.


    • Automated decision-making. If you have questions regarding automated decision-making processes or their accuracy, please let us know or change your preferences as referred to above.


    • Right to Data Portability. You have the right to obtain the personal data we hold about you in a structured, electronic format and to transmit it to another data controller where the data is (a) personal data you have provided to us and (b) where we process that data on the basis of your consent (such as your marketing preferences) or in order to perform a contract with you (such as managing your online account).


    • Complaints. If, for any reason, you are not satisfied with the way we have handled your personal data, please contact us. If you remain dissatisfied, you have the right to lodge a complaint with the National Supervisory Authority for Personal Data Processing (“ANSPDCP”) www.dataprotection.ro.

 

To exercise any of the rights mentioned above, please write to us at: Calea 13 Septembrie 90, COMPLEX MULTIFUNCTIONAL GRAND, THE GRAND AVENUE, GROUND FLOOR, AXES D-E/6-7, Bucharest, Sector 5, or send us an email at [email protected]

If you ask us to stop processing your personal data in a certain way or to delete your personal data, but that type of processing or those data are necessary to facilitate your use of the Website or are necessary to allow us to provide you with a service (such as managing your online account), you may not be able to use the Website or the service as you did before.

The rights mentioned above do not extend to data that does not fall within the category of personal data under the GDPR.


WHAT ARE COOKIES? HOW DO WE USE THEM?

A cookie is a small file stored on your computer by a website in order to provide you with a unique ID. The cookie helps make your use of our Website easier and faster because it can remember whether you have visited the Website and helps us provide you with the information you need about your shopping activity or your account details—when and where you need it. A cookie generated by our Website does not contain information about you. It contains only a numerical code that, for example, allows you to retrieve your account details or shopping list. In accordance with the Privacy Policy regarding customer information, we analyze the data collected through cookies only in aggregate form, not at the level of each customer.

We use cookies to create a pleasant and easy online shopping experience for you. We use them to determine the browser you use, the device type, unique code, computer and connection information, page view statistics, traffic to and from the Website, referring URL, IP address (“IP”), and standard web log information.

By using the TERMINAL FASHION S.R.L. Website, you agree that we may store cookies on your device. If you prefer, you can configure your internet browser not to accept cookies, but this may reduce your online experience.

1. Types of Cookies we use and why we use them:

There are two types of cookies that may be used during your visit to the TERMINAL FASHION S.R.L. Website:


    • technical cookies: these are necessary for the Website to function properly and to allow user navigation; without them, a user may not be able to view pages correctly or use certain functions.


    • profiling cookies: these are used to create user profiles in order to send advertising messages in accordance with the preferences shown by the user while browsing.

 

Cookies, whether “technical” or “profiling”, may also be classified as:


    • site functionality cookies: these cookies are used to identify users between webpage loads and are essential to allow you to browse a given website, such as remembering certain user settings. Without them, certain services provided (such as using the shopping cart) on the Website could not be delivered.


    • analytics cookies: these cookies are used to measure and analyze how visitors use a website (for example, site traffic, total sales through the website, the pages users visit most often, and the pages from which users receive error messages) in order to continuously improve the Website and the customers’ shopping experience. All information collected by these cookies is anonymous and is not used to identify you.


    • customer preference cookies: functional cookies remember your preferences and behavior and help us personalize your shopping experience.


    • marketing and advertising cookies: these cookies may be used to deliver personalized advertisements that are more relevant to you. They also limit the number of times you see one of our online ads and help us measure the effectiveness of our marketing campaigns.


    • third-party cookies: TERMINAL FASHION S.R.L. has partnerships with third-party companies for marketing and advertising purposes. These cookies allow us to make more informed decisions about what our customers want from us. Third-party companies may use a mix of session and persistent cookies. Any information they collect is anonymous.

 

What cookies do we use on our Website:

Cookie

Web domain

Description

Expiration period

Type

_cfduid

toff.ro

This cookie is used by CDN services such as CloudFare to identify individual clients behind a shared IP address and to apply security settings on a per-client basis. It does not correspond to any user ID in the web application and does not store any personally identifiable information.

One month

Necessary

quform_session

toff.ro

Functionality cookie: Contact form – Allows you to use our Website in a way that makes your browsing experience more convenient

24 hours

Functional

yith_wcwl_session

toff.ro

Functionality cookie: Cookie that stores information about the list of items marked as favorites

24 hours

Functional

_ga

toff.ro

This cookie is installed by Google Analytics. The cookie is used to calculate data about visitors, sessions, campaigns, and to track site usage for the site analytics report. Cookies store information anonymously and assign a randomly generated number to identify unique visitors.

2 years

Analytics

_gid

toff.ro

This cookie is installed by Google Analytics. The cookie is used to store information about how visitors use a website and helps create an analytics report on how the website performs. The data collected, including the number of visitors, the source they came from, and the pages visited, appears in anonymous form.

One day

Analytics

_gat

toff.ro

These cookies are installed by Google Universal Analytics to limit the request rate in order to restrict data collection on high-traffic websites.

1 minute

Analytics


RECAPTCHA

We use the reCAPTCHA service provided by Google Inc. (Google) to protect your submissions through online forms on this Website. This plugin checks whether you are a human in order to prevent certain Website functions from being abused by spam bots (especially comments). This plugin query includes the transmission of the IP address and, where applicable, other data requested by Google for the Google reCAPTCHA service. For this purpose, your information will be communicated to and used by Google. However, your IP address is truncated/shortened by Google within member states of the European Union or in other states party to the Agreement on the European Economic Area and is therefore anonymized before being transferred to countries outside the EU/EEA. Only in exceptional cases is a full IP address transmitted to a Google server in the United States and truncated/shortened there. On behalf of the operator of this Website, Google will process this information in order to evaluate your use of this service. The IP address provided by reCAPTCHA from your browser will not be combined with other data from Google.

This data collection is subject to Google’s data protection regulations (Google Inc.). For more information about Google’s privacy policy, please visit: https://www.google.com/intl/ro/policies/privacy/

By using the reCAPTCHA service, you agree to the processing of your data by Google in the manner and for the purposes stated above.


CAN I DELETE OR CONTROL MY COOKIES?

If you prefer, you can configure your internet browser not to accept cookies. You should still be able to use our Website without having cookies enabled. However, please note that disabling cookies may affect your ability to use the Website and/or may prevent you from fully benefiting from the available features and services.

If you wish to remove cookie files stored on your devices and configure your web browser to refuse cookie files, you can use the preference settings in your web browser. Usually, you can find the browser settings related to cookies in the “Options”, “Tools”, or “Preferences” menus of the web browser you use to access our Websites. Depending on the existing web browsers, various means may be used to disable cookies. For more information, please visit your browser’s website:

Cookie settings in Internet Explorer – Internet Explorer; hyperlink to – https://support.microsoft.com/en-us/help/17442/windows-internet-explorer-delete-manage-cookies#ie=ie-11

Cookie settings in Firefox – Firefox; hyperlink to – https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences

Cookie settings in Chrome – Chrome; hyperlink to – https://support.google.com/chrome/answer/95647?hl=en&hlrm=en

Cookie settings in Safari – Safari; hyperlink to – https://support.apple.com/ro-ro/guide/safari/manage-cookies-and-website-data-sfri11471/mac

Cookie settings in Edge – Edge; hyperlink to – https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy

Cookie settings in Opera – Opera; hyperlink to – https://www.opera.com/help/tutorials/security/privacy/.

To find out more about cookies, please visit www.allaboutcookies.org or see www.youronlinechoices.eu, which contains additional information on behavioral advertising and online privacy.

For information or requests based on the rights of data subjects under the GDPR, you may contact the Data Protection Officer at the email address above.


HOW WE MAY MAKE CHANGES TO THIS POLICY

We will notify you of changes to this Privacy Policy by posting the revised terms on the Website.

If you do not agree with the new terms of this Privacy Policy, you must stop using the Website and, if you are a registered user, you may cancel your account within thirty (30) days by contacting us at [email protected]. Your account will be closed and you will not be bound by the new terms. You may also ask us to delete your data (as mentioned above).

Otherwise, your continued use of the Website after the effective date of the changes constitutes acceptance of the new terms of this Privacy Policy.


CONTACT US

We are always pleased to hear from our customers. If you have questions about our Privacy Policy, if you would like us to stop using your personal data, if you would like to exercise the rights mentioned above, or to file a complaint, please contact us.

You can contact our team responsible for data privacy by email at [email protected] or at our customer relations address [email protected] or by phone at +40737 66 66 22. Or you can write to us at the following physical address:

TERMINAL FASHION S.R.L.

Calea 13 Septembrie 90, Sector 5, postal code 050726, Bucharest