Cookie Policy

We are pleased that you have visited this website. The protection and security of the personal data of our customers and users are of our utmost priority. We comply with data protection legislation, in particular the General Data Protection Regulation (“GDPR”) and the applicable national data protection legislation. This Privacy Policy provides an explanation of the information (incl. personal data) which we process during your visit and your use of our above-mentioned Internet offer ("Website").

Who is responsible for processing personal data?

The Data Protection Officer may also be contacted using the above-mentioned method at the address adrian.magda@gdprservicii.ro.

What principles do we follow?

We process your personal data in compliance with the legal regulations on personal data protection only if permitted by law or if you have granted your consent. This also applies to processing personal data for promotional and marketing purposes.

This Website may also record / collect information which does not in itself allow us to draw direct conclusions about you. In certain cases, in particular in combination with other data, this information may nevertheless be considered as “personal data” for the purposes of the applicable personal data protection regulations. Furthermore, we may also record / collect information on this Website on the basis of which we cannot identify you directly or indirectly; for example, this is the case of the collecting information on all users of this website.

What data do we process?

1. Log files: When you hit this Website, our web server automatically stores the domain name or possibly the IP address of the computer through which you access our website (usually your Internet access provider), incl. the date, time and length of your visit, the subpages / URLs which you visit, and information about the applications and end devices which you use to visit our Website.

2. Cookies: In order to be able to arrange and organise our offer so that it is as user-friendly as possible for you, we use the so-called cookies, just as many other well-known companies. Cookies are small text files stored in the Internet browser which you use. These files help us identify what our Website visitors prefer and organise our Website accordingly. Most of the cookies used by us are so-called session cookies. They are automatically deleted at the end of your visit. But we also use permanent cookies. These are used to improve the user’s guidance. Our cookies do not collect any personal data and are not suitable for identifying you on the websites of third parties / providers. You can set your browser to notify you about the location of cookies. In this manner, the use of cookies will become transparent for you. In addition, by setting your browser, you can also prevent accepting cookies in principle. However, under certain conditions, this may result in you not being able to use all the features of the Website.

3. Website analysis using Google Analytics:In order to continuously improve our website, we also use Google Analytics, a website analysis service from Google Inc., 1600 Amphitheater Parkway, Mountain View, CA 94043, USA (“Google”). Google Analytics also uses cookies which are stored on your computer and allow analysis of the use of the Website. The information generated by these cookies about your use of this Website is commonly sent to a Google server in Europe (or in one of the Member States of the European Economic Area) for the purpose of anonymising the IP address, so that an association with a specific person is excluded. Once the IP address has been anonymised, the abbreviated IP address is sent to a Google server in the US and stored there. The complete IP address is sent to a Google’s server in the USA and abbreviated there only in exceptional cases. This Website uses Google Analytics with an extension for anonymised recording od IP addresses (so-called IP Masking). At our request, Google uses the collected information to evaluate your visit to the Website, to compile reports on the Website activity and to provide us with other services relating to your use of the Website. The IP address sent within Google Analytics by your browser is not associated with any other Google data. You can prevent the storage of cookies by setting your browser accordingly. However, please note that in this case, you will not be able to use the functions of this Website in full. In addition, you have the option to prevent and recording and uploading the data generated by the cookie regarding your visit to the Website to Google and the subsequent processing by Google by downloading and installing browser plug-ins which are available at the following link: https://tools.google.com/dlpage/gaoptout?hl=en. Alternatively, you can prevent data from being sent to and processed by Google through the following link. If you wish to prevent tracking, please click here. The Opt-Out cookie will be activated, which will prevent future recording of personal data the next time you visit this Website. For more information about personal data protection in the case of Google Analytics, please click here https://policies.google.com/terms?hl= and here https://policies.google.com/privacy?hl=en.

4. Google Remarketing: We also use Google’s Remarketing feature on our website. Owing to this, we can offer you advertising based on your user behaviour during previous visits to our Website, which could correspond to your interests. If you have granted Google your consent, your visits will be recorded across the devices which you use. This advertising will appear only on Google advertising slots, either on Google AdWords ad slots or on the Google Display Network. In order to perform an analysis in which the Website is used as a basis for the placement of advertising based on the interest of the recipient, Google uses cookies through which it records visits to the Website, as well as anonymised data on the use of the website. No personal data of Website visitors will be stored. If you then visit other Google Display Network websites, you will see inline adverts which are more likely to reflect previously searched product and information areas. You may permanently disable the use of cookies by Google by clicking on the following link and downloading and installing the plugins prepared on this link: https://support.google.com/ads/answer/7395996?hl=en. Alternatively, you can disable cookies used by third party providers by visiting the Network Advertising Initiative deactivation site at https://optout.networkadvertising.org/ and following the deactivation instructions. For more detailed information about Google Remarketing and Google’s privacy statement, please visit: https://policies.google.com/technologies/ads?hl=en.

5. DoubleClick: We also use DoubleClick, a service also provided by Google, to serve promotional adverts that may be relevant to you. Google assigns a pseudonymous identification number (ID) to your browser to verify which adverts were displayed in your browser and which were searched. Cookies do not contain any personal data. The use of cookies by DoubleClick allows Google and its Internet partners to only place promotional advertisements based on previous visits to our Website or other sites on the Internet. The information generated by the cookies is sent by Google for the assessment purposes to a server in the USA and this information is stored there. The transfer of personal data by Google to third parties only takes place in accordance with the applicable legal regulations or in the context of processing custom personal data. Under no circumstances will Google associate your personal information with any personal information recorded by Google. You can prevent the storage of cookies by setting your browser accordingly. In addition, you have the option of preventing recording personal data been created by cookies and relating to your visit to the Website, as well as processing the resulting personal data by Google. If you wish to do so, please visit https://adssettings.google.com/u/0/authenticated?hl=en and download, from the DoubleClick Deactivation Extension, and install the relevant browser plugins. Alternatively, you can disable Doubleclick cookies on the Digital Advertising Alliance site: https://optout.aboutads.info/.

6. Facebook Pixel: Our Website uses the Facebook pixel by Facebook, Inc. (1601 South California Avenue, Palo Alto, CA 94304, USA – www.facebook.com – “Facebook”). Through the Facebook pixel, it is possible to monitor the behaviour of users once these users have been brought to some Websites operated by our Company by clicking on a promotional advertisement on Facebook. This procedure is used to evaluate the effectiveness of promotional ads on Facebook for statistical and market research purposes and can help optimise future promotional practices. The data obtained is anonymous to us, therefore they do not allow us to draw any conclusions regarding users, and we do not provide any personal data to Facebook. However, Facebook stores and processes the data, allowing the association with the relevant user profile, and Facebook may use the data in accordance with its Privacy Policy (https://www.facebook.com/about/privacy/). You can allow Facebook and its partners to place promotional ads on and off Facebook. For these purposes, a cookie may also be stored on your computer. If you a Facebook user and do not wish the Facebook Company to collect information about you through the Facebook pixel and you are linked with your user data stored by Facebook, you may reject using the Facebook here. The rejection applies to the browser which you are using.

7. LinkedIn Conversion Tracking: Our Website uses the Conversion Tracking analysis and technology by LinkedIn Corporation (2029 Stierlin Court, Mountain View, CA 94043, USA – www.linkedin.com– “LinkedIn”). With this LinkedIn technology, you can see adverts based on your interests. In addition, we receive aggregated and anonymous reports about display activities and information about how you interact with our Website from LinkedIn. For more information about the LinkedIn Privacy Policy, click here: https://www.linkedin.com/legal/privacy-policy. You can reject LinkedIn’s analysis of your user behaviour and the display of recommendations based on your interests by clicking the “Decline at LinkedIn” (for LinkedIn members) or “Decline” (for other users) fields at the following link: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.

8. Facebook Social Plugin: We have integrated the Facebook button on our Website. You can recognise the Facebook button by the Facebook logo or by the “Like” button. In order to prevent information from being automatically sent to Facebook when you hit our Website, we have implemented a so-called “Double-click solution”: next to the Facebook button, there is another area which resembles a switch. Only once you click on this switch and then on the Facebook button, the information (such as the address of our Website and your user identification) will be sent to Facebook. Even in this case, as the operator, we have no information about the content of the transmitted personal data or about their use by Facebook. We will not know when and which button you clicked. For more information on Facebook’s use of personal information, please refer to Facebook’s Privacy Policy at https://www.facebook.com/privacy/policy.

9. Possibilities of providing information and consultancy.

Through our contact form, we provide you with various options for obtaining information and consultancy. Depending on the possibility or possibilities of your choice, we process various personal data:

a) Contact information

If you contact us using one of the methods listed on our Website so that we can process and deal with your request, we will process the personal data contained in your message and provided by you.

b) Information material

If you have requested sending information materials, we process the personal data you provide in the contact form, at least your name and surname and information about your preferred method of contact with us (mail and/or e-mail) for the purposes of one-off sending of the materials you requested from us.

c) Phone consultancy

If you have requested telephone consultancy, we process the personal data provided by you in the contact form, at least your name and surname and your phone number necessary for performing the required phone consultancy.

d) Personal consultancy

If you have requested personal consultancy, we process the personal data you provided in the contact form, at least your name and surname, as well as your phone number and/or e-mail address, so that we can contact you to arrange a personal appointment.

e) Newsletter via e-mail

If you have subscribed to our newsletters via e-mail, we process the personal data you provided in the contact form, at least your name and surname, and your e-mail address, so that we can send you the newsletter via e-mail.

In addition, we use other information provided by you in the contact form (such as the information about your activities and your area of interest) so that we can send you information tailored to your interests. Furthermore, we evaluate personal information generated when this email is delivered and retrieved, first in the aggregate form (delivery rate, opening rate, click rate, conversation rate, opt-out rate, or exit rate) to analyse the success and use of the email. Secondly, we also evaluate the personal data generated during the retrieval and use of this e-mail by you (the opening moment, hypertext links which you clicked on, or downloaded documents) so that we can provide you with individualised information via e-mail in future newsletters that best reflect your interests and needs.

10. Online orders

You can place an order on our Website without having to register and creating an account. In this case, personal information necessary for processing the order is required (e.g. your name, your billing address or delivery address, if different, your e-mail address and the necessary payment information, delivery methods, and information related to the order).

11. Registration / Customer account

When logging in as a registered user (especially when creating a customer account) we need and collect personal data resulting from the registration form on our Website. We may request the re-entry of personal data obtained during the registration (especially for the purpose of your identification) and collect additional personal data if you use certain information on our Website or wish to place an order.

1. For what purposes and on what legal basis do we process your personal data?

2. Processing personal data or the information contained in the login files takes place in order to enable you to use our Website; this takes place on the basis of Article 6 (1) (f) of the GDPR in order to maintain our legitimate interest in the operation of our Website.

3. Processing personal data collected through cookies (incl. the Google Analytics website analysis services) and pseudonymous user profiles is carried out for advertising purposes, market research purposes, and website layout according to our needs on the basis of Article 6 (1) (f) of the GDPR in order to maintain our legitimate interest in the operation of our Website.

4. Processing personal data for the purposes of offers of information and consultancy takes place in order to process the offers selected by you or for newsletters sent by e-mail for the purpose of registering for newsletters subscription and sending them. This processing is carried out only with your consent on the basis of Article 6 (1) (a) of the GDPR. Processing personal data used to process your requests using any of the methods listed on our Website is always carried out on the basis of our legitimate interest in establishing and maintaining business contacts in accordance with Article 6 (1) (a) (f) of the Regulation. If your request concerns the conclusion of a contract or pre-contractual arrangements, your personal data will be processed in accordance with Article 6 (1) (b) of the Regulation. Please note that you can revoke the consent you have given us at any time with effect for the future, e.g. by clicking on the relevant link in each of our newsletters or by notification sent by post, fax or e-mail to one of the contact methods listed on the first page of this Privacy Policy.

5. If you place an order via our Website or if you register as a user or you open a customer account, we process personal data obtained in this context for the purpose of performing contracts concluded with you pursuant to Article 6 (1) (b) of the GDPR.

6. We may also process personal data obtained in association with the use of our Website in order to comply with the legal obligations and responsibilities which binding on us; this takes place pursuant to Article 6 (1) (c) of the GDPR.

7. If necessary, we process your personal data, in addition to the above purposes, also in order to preserve our legitimate interests or the interests of third parties; this takes place pursuant to Article 6 (1) (f) of the GDPR. Our legitimate interests include:

a) Filing and asserting legal claims and defence in legal disputes;

b) Preventing and detecting crime; and

c) Management and further development of our business and trade activities incl. risk management.

1. Am I obliged to provide my personal data?

Any personal information required in order to register for the subscription of our newsletters, to make offers of information and consultancy, to place orders online or to register as a user or to open a customer account is marked as mandatory data in the relevant section of the Website (e.g. in the online form); without providing the required information, we cannot allow you to use the relevant functions.

If we request and obtain additional personal data from you, we will inform you when making the relevant request whether the provision of this information is prescribed on the basis of a legal obligation or whether it is necessary for the conclusion of the contract. In doing so, we usually indicate the personal data, the provision of which is voluntary and is not necessary to comply with the above legal obligations or is not necessary for the conclusion of the contract.

1. Who will get my personal information?

Your personal data is generally processed within our Company. Depending on the type of personal data, only certain departments / organisational units have access to it. These include, in particular, the specialist departments dealing with the provision of our digital offerings (e.g. websites) and our IT department. Owing to the concept of performing tasks and authorisations, access within our Company is restricted to the functions and to the extent necessary for processing for the specific purpose.

To the extent legally permissible, we may pass on your personal data to third parties outside our Company. These external recipients may in particular include:

Affiliated companies within the Bravo Holding GmbH Group, to which we provide personal data for the purpose of processing data analyses or other administrative work, as well as for marketing purposes (e.g. sending emails, arranging marketing surveys, etc.);

Our authorised service providers who provide us with services on a special contractual basis which may include processing personal data, as well as subcontractors of our service providers involved with our consent;

Non-public and public entities, if we are obliged to transfer your personal data on the basis of the applicable legal regulations and responsibilities.

Is automated-decision making used?

In association with the operation of our Website, we do not use any automated decision-making (including profiling) within the meaning of Article 22 of the GDPR. If we wish to use any procedures of this type in individual cases, we will inform you separately in the legally required extent.

Is personal data sent outside the EU / European Economic Area?

Processing your personal data takes place in principle within the EU or the European Economic Area.

Only in association with the involvement of web analytics service providers may information be sent to recipients in the so-called “third countries”. “Third countries” mean countries outside the European Union or non-State parties to the Agreement on the European Economic Area, in which a level of personal data protection comparable to that within the European Union cannot be expected.

How long is my personal data stored for?

We store your personal data in principle as long as we have a legitimate interest in storing it and unless your interests in discontinuing to store it prevail.

Even without a legitimate interest, we may have personal data stored if we are required to do so by law (e.g. in order to comply with the obligation to retain personal data). We also delete your personal data without you having to do anything about it, as soon as their knowledge is no longer necessary for the fulfilment of the specific purpose of processing or its storage is legally inadmissible.

In general, the following applies:

Login data is deleted within seven days, unless its further storage is necessary for the purposes required by law, such as detection of misuse and detection and elimination of technical defects;

Personal data processed in association with the order will be deleted at the latest upon the expiry of the statutory limitation periods for the storage of personal data;

Personal data processed in association with the registration as a user or with opening a customer account is deleted once the registration is completed or together with the deletion of the customer account.

The personal data which we have to store in order to comply with our obligations to retain personal data will remain stored until the termination of the relevant obligation. If we store personal data solely for the purpose of complying with the obligation to store it, it is usually blocked in such a manner that access to it is allowed only when it is necessary for the purpose of the obligation to store it.

What rights do I have?

As a data subject, you have the following rights:

To information about personal data processed about you pursuant to Art. 15 of the GDPR;

To have the incorrect and incomplete personal data corrected pursuant to Art. 16 of the GDPR;

To have your personal data delete pursuant to Art. 17 of the GDPR;

To have the processing restricted pursuant to Art. 18 of the GDPR;

To personal data transferability pursuant to Art. 20 of the GDPR;

To raise an objection to the processing of personal data concerning your person pursuant to Art. 21 of the GDPR.

If you wish to exercise these rights, you may contact us at any time using one of the contact channels listed at the beginning of this Privacy Policy.

You are entitled to lodge a complaint with the competent supervisory authority for personal data protection pursuant to Art. 77 of the GDPR.

If you have questions about the processing of your personal data, please do not hesitate to contact our Data Protection Officer.

Bravo Europa s.r.o.