Privacy notice

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This Privacy Notice (further as: Notice) describes the way trading company INTERBRANDS Orbico S.R.L. with headquarters in One Cotroceni Park, Building A, 3rd floor, Str. Nutu Ion 44, Sector 5, Bucharest, Romania, VAT nr.: RO 3786280 (hereinafter: "Orbico") processes your personal data. 

This Notice is harmonized in line with respect to Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016 on the protection of individuals in connection with processing of personal data and on the free movement of such data and on the repeal of Directive 95/46/EC (General Data Protection Regulation) (hereinafter: „GDPR“).

To help better understand (or remind) you what processing and personal data mean in the sense of GDPR, please see below table. 

Personal data
Any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one 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 the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Personal data processing
any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

1. Scope

This Notice governs the general way Orbico processes personal data. In this sense, Orbico is the so-called Data controller with regard to the personal data it processes. Also, this Notice applies to Orbico and does not apply to the services of other companies within the group to which Orbico belongs, nor to companies managed by third parties. 

Note that for processsing of personal data in specyfic cases, for example purchase of our goods, a separate privacy policy is applicable, which you can access on the respective webpage.

2. Purposes and legal bases for data processing

Administrative communication
communication with you about Orbico services and any inquiries you may have when contacting us, either using the contact form on this page or any other means of communication (such as our profile on various social media platforms).
Processing purpose: Responding to your inquiries.
Legal basis: Orbico’s legitimate interest to respond to your inquiry – GDPR Article 6. Par 1 (f).

Prize games/Award winning contests
we process personal information you provide us when registering to such an event. If you won any of the main prizes, and invited to the award ceremony. That event may be recorded and the recording published publicly.    
Processing purpose: To facilitate participation in prize game/award winning contest and organize distribution of awards for winners.
Legal basis: Your consent to participate in the prize game/award winning contest – Article 6. par. 1 (a) GDPR.

Cookies 
Orbico only stores cookies you selected upon opening this website. You can read more about those cookies in our cookie policy
Processing purpose: Provision of the website, analytical tools for improving the website and user experience. 
Legal basis: Your consent to accept the cookies – Article 6. par. 1 (a) GDPR.

In any case, Orbico does not carry out automated decision-making based on your personal data, nor does Orbico create profiles of data subjects for this purpose.

3. Transfer and disclosure of your personal data

Depending on the type of process within which we process your personal data, some data may be transferred to third parties. In these cases the subject entities are acting as processors and are processing data in accordance with our instructions. These parties are required by contract to safeguard any personal data they receive from us and are prohibited from using them contrary to our instructions. 

These third parties may refer to:
• Companies within the Group of which Orbico belongs to;
• Third party service providers which process your personal data on behalf of Orbico and which are obliged to preserve the confidentiality of your personal data. (e.g.  IT support providers,  logistical support providers, etc.);
• Public authorities, regulatory agencies  for the purpose of complying with applicable legislation;
• Professional advisers – persons which provide to us certain consultancy services may have access to your personal data if this is required for providing the subject service. 

Your personal data are processed and transferred within the territory of the European Union. 

If personal data would be transferred to other countries outside the European Union (third countries) Orbico shall rely on  Standard Contractual Clauses, i.e. Commission Implementing Decision (EU) 2021/914 of June 4, 2021 on standard contractual clauses for the transfer of personal data to third countries in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council. 

The transfer of data based on the aforementioned mechanism is envisaged in Article 46 of the GDPR in those situations where the European Commission has not issued a Decision on Adequacy for the third country to which personal data is to be transferred.

4. Your personal data storage period

The storage period of your personal data will primarily depend on the purpose for which it was collected, or the reason for which we process your personal data. In this sense, we guarantee that we will not store your data longer than is absolutely necessary to fulfill the purpose for which it was collected.
If the processing is based on consent , we retain your personal data for the period your consent was given, or until you withdraw your consent.
If the procssing is based on our legitimate interest, we retain your personal data as long as our legitimate interest exists.
If the processing is based on our legal obligation, we retain your personal data as long as we are required by law which is the basis for such processing. 

5. Your rights

You can exercise your rights regarding your personal data by contacting us through privacy.orbicobeautyro@orbico.com. You can use our Data Subject Request Form to exercise your rights available on our web site. Please note that you can only exercise your rights regarding your personal data.

With respect to you personal data you have the following rights: 

Access to your personal data
You have the right to ask us to confirm whether we process your personal data, as well as access to your personal data that we process.

Rectification of personal data
You have the right to ask us to correct your inaccurate personal data, as well as the right to supplement your personal data.

The right to withdraw consent
You have the right to withdraw your consent for further processing of personal data at any time. The withdrawal of consent does not affect processing performed on the basis of consent prior to its withdrawal.

Deletion of personal data (the right to be forgotten)
If you withdraw your consent to the processing of your personal data or when the legal basis for the processing of your personal data ceases or in other cases provided by the General Data Protection Regulation, you have the right to ask us to delete your personal data.

Portability of personal data
If we process your personal data based on your consent or based on our contract, you have the right to request us to transfer your personal data in an appropriate manner.

Objection to the processing of personal data
If we process your personal data for the purposes of direct marketing or based on our legitimate interest, you have the right to object to further processing of your personal data.

Limitation of processing
If you dispute the accuracy of your personal data or in other situations provided for in the General Data Protection Regulation, you have the right to ask us to limit the processing of your personal data until such a situation is resolved.

The right to complain to the Personal Data Protection Agency
At any time, you have the right to complain before the personal data protection authority relevant for your respective country (https://edpb.europa.eu/about-edpb/about-edpb/members_en) regarding the processing and protection of your personal data.

You exercise your rights without cost. However, if you frequently or excessively (for example, requesting all your personal information in writing) request access to or transfer of your personal information, we have the right to ask you to bear our costs before carrying out such an action.

6. Data safety

We also inform you that Orbico uses a wide range of data security measures to ensure the confidentiality and integrity of your personal data. 
However, given the nature of the Internet, we would like to draw your attention to the fact that there may be security flaws in the transmission of data via the Internet (e.g. communication via e-mail) and that complete protection of data from access by third parties is not possible. However, as we have stated, Orbico pays great attention to the protection of your personal data and in this sense, considering the described nature of this medium, has organized and is conducting significant technical and security measures.

7. Changes in the Policy

We reserve the right to change this Notice at any time.