Politica-de-confidentialitate

I. General information

The confidentiality of your personal data is one of the main concerns of BRASHMORE FRANCHISING SRL, a Romanian legal entity seated in Braşov, Str.Aleea Magnoliei no. 12, bldg.99, entrance B, apt.7, Braşov County, Romania, registered with the Trade Registry under no. J8/1768/2011, fiscal ID RO293183399, as personal data controller.

This document informs you about the processing of your personal data within the context of using the www.coffeol.ro website.

TheGeneral Data Protection Regulation no. 679/2016 (“GDPR”) on the protection of natural persons with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/.

When personal data in relation to the information published on this website is processed, each party undertakes to comply with the applicable legislation concerning the processing of personal data, namely Regulation (EU) 2016/679 and any generally mandatory norms adopted in relation to the protection of personal data.

Each party, insofar it discloses to the other party – for the performance of the contract - personal data concerning its employees or representatives, will ensure that only information required for this purpose is disclosed.

Each party will request from the other party only personal data required for the performance of the contract, and insofar another purpose for requesting personal data exists, such request will be justified by providing the information foreseen by the applicable legislation, namely art. 13-14 of Regulation (EU) 2016/679 and/or by any article or norm that replaces or amends such provisions.

Each party that discloses personal data of its employees/representatives will ensure that it has provided to such employees/representatives the information foreseen by art. 13-14 of Regulation (EU) 2016/679 and/or by any article or norm that replaces or amends such provisions.

For the avoidance of any doubt the parties acknowledge and agree that each party should determine independently the purpose/purposes and means of personal data processing in relation to the contract, acting as controller in the sense of art. 4 par. 7 of Regulation (EU) 2016/679.

If circumstances occur where any of the parties acts on behalf of the other party or as a joint controller together with the other party in relation to the contract, the parties undertake to conclude a binding agreement in accordance with the provisions of articles 26 and 28 of Regulation (EU) 2016/679 and/or any article or norm that replaces or amends such provisions.

Each party assumes independently the responsibility for personal data processing. The breach by one party of these provisions as well as of the provisions of Regulation (EU) 2016/679 and of the generally binding norms adopted in relation to the protection of personal data cannot be regarded a joint breach and cannot generate the joint liability in relation to the person or institution that establishes such breach.

II. Categories of processed personal data

II. 1. If you are a client of thewebsite,COFFEOL ROMANIA will process your personal data including: surname and given names, telephone number, e-mail address, data related to how you use the website, like for example your behaviour/preferences/habits within the context ofCOFFEOL ROMANIA, as well as any other categories of data that you provide directly when you set up your user account or in any other way resulting from using the site.

If in order to set up a user account on our site you use Facebook or Google, COFFEOL ROMANIA will process the following public profile data visible in those applications: user name, e-mail address, contact number.

II. 2. If you are a visitor of the site, COFFEOL ROMANIAwill process your personal datathat you provide directly when using the site, like the data you provide within the sections Contact / Join the team / Complaints /Questions / Franchise, insofar you contact us by one of these ways.

III. Purpose and legal grounds for data processing

III.1. If you are a client of the site, COFFEOL ROMANIA will process your personal data:

in order to fulfil the legal obligations incumbent uponCOFFEOL ROMANIA consequently to the services rendered by means of the website, including fiscal and archiving obligations.

Grounds: The processing of your data for this purpose is a legal requirement. Providing your data for this purpose is necessary. Refusal to provide such data may hinderCOFFEOL ROMANIA to comply with its legal obligations and thus to offer you its services by means of the website.

for marketing activities, namely to send via telecommunication means (e-mail, sms text messages) commercial information about products and services offered by COFFEOL ROMANIA through its website.

Grounds: the processing of your data is based on your consent, if you choose to grant it.

You can consent to the processing of the data for this purpose when you set up your account by ticking the relevant box in the My Account Information section. In order to unsubscribe from receiving commercial information you can select the relevant option available at the end of each e-mail or sms text message that includes such communication. You can also unsubscribe by accessing the My Account Information section.

Providing your data for this purpose is voluntary. Refusal to grant your consent to the processing of your personal data for this purpose does not result in any adverse effects for you.

for devising various analyses, reports concerning the operation of the site, consumer preference profiles, mainly in order to improve the experience offered by the website.

Grounds: the processing of your data for this purpose is based on the legitimate interest of COFFEOL ROMANIA to improve customer website experience. Providing your data for this purpose is voluntary. Refusal to grant your consent to the processing of your personal data for this purpose does not result in any adverse effects for you.

III.2. If you are a visitor of the site COFFEOL ROMANIA will process your personal data:

for marketing activities, namely to send via telecommunication means (e-mail, text messages) commercial information about products and services offered by COFFEOL ROMANIA through its website.

Grounds: the processing of your data is based on your consent, if you choose to grant it.

You can consent to the processing of the data for this purpose by ticking the relevant box when you fill in the form provided on the site in order to subscribe to our Newsletter. In order to unsubscribe from receiving commercial information you can select the relevant option available at the end of each e-mail or text message that includes such communication.

Providing your data for this purpose is voluntary. Refusal to grant your consent to the processing of your personal data for this purpose does not result in any adverse effects for you.

for settling complaints, monitoring traffic and improving the experience we offer you on our site.

Grounds: the processing of your data for this purpose is based on the legitimate interest of COFFEOL ROMANIA to ensure the proper functioning of the website as well as to improve permanently customer website experience also by including the settling of various comments, questions or complaints.

Providing your data for this purpose is voluntary. Refusal to grant your consent to the processing of your personal data for this purpose does not result in any adverse effects for you.

IV. Duration of the processing of your data

As a principle, COFFEOL ROMANIA will process your personal data for as long as necessary in order to achieve the purposes mentioned above.

If you are a client, we will process your personal data for the entire duration of the contractual relationship and subsequently according to the legal obligations assumed by COFFEOL (e.g. in the case of financial and accounting documentation that by provision of law must be kept for 10 years after the close of the financial year in the course of which these were devised).

If you are a client and exercise your option to delete your user account by clicking on the “Delete account” button in the “My Account Information” section, COFFEOL ROMANIA will construe this action as your option to unsubscribe from receiving commercial information by which we keep you updated on the products and services offered through the site. In this sense, if you choose to delete your user account, we will no longer send you e-mail or text messages of this type.However, we should like to inform you that by deleting your account your personal data will not be erased automatically. If you wish for your personal data to be processed no longer or if you wish for your personal data to be erased, you can exercise your rights described in section VII below.

If you withdraw your consent for the processing of data for marketing purposes, COFFEOL ROMANIA will cease to process your personal data for this purpose, while, however, any processing completed by COFFEOL ROMANIA based on your consent expressed prior to its withdrawal remains unaffected.

V. Disclosure of personal data

In order to fulfil the purposes of processing COFFEOL ROMANIA may disclose your personal data to partners, third parties or entities that support COFFEOL ROMANIA in its activities conducted over the website (for example IT service providers), or to central/local public authorities in the following cases enumerated as examples:

for the administration of the website;

when such communication is necessary for awarding prizes or granting other facilities to data subjects obtained by these consequently to participating in various promotional campaigns organised by COFFEOL ROMANIA through its website;

for the maintenance, personalisation and improvement of the site and the services provided over it;
for performing data analysis, testing and research, for monitoring utilisation and activity trends, for developing safety and user authentication characteristics;
for commercial marketing communication in compliance with the conditions and limitations provided by law;
when the disclosure of personal data is foreseen by law, etc.

VI. The transfer of personal data

Personal data made available to COFFEOL ROMANIA can be transferred outside Romania only to EU Member States.

VII. Your rights

Under the conditions provided by the legislation concerning the processing of personal data, you, as data subjects, benefit from the following rights:

the right to be informed, that is to receive the details of processing performed by COFFEOL ROMANIA as described in this document;
the right to access the data, that is the right to receive confirmation from COFFEOL ROMANIA concerning the processing of the personal data as well as details of the processing activity, how the data are processed, the purpose of processing, the recipients or categories of recipients of the data, etc;
the right to rectification, that is the right to obtain from COFFEOL ROMANIA without undue delay therectification of inaccurate/unjustified personal data, as well as to have incomplete personal datacompleted; rectifications/completions will be communicated to each recipient to whom that data has been transmitted, except cases when such undertaking proves impossible or entails disproportionate efforts.
the right to the erasure of the data without undue delay, (“the right to be forgotten”), when one of the following grounds applies:

the data are no longer necessary in relation to the purposes for which they were collected or processed;

when consent is withdrawn and there is no other legal ground for the processing;

when the data subject objects to the processing and there are no overriding legitimate grounds for the processing;

when the personal data have been processed unlawfully;

when the personal data must be erased for compliance with a legal obligation;

the personal data have been collected in relation to the offer of information society services according to Union law or internal (Member State) law to which the controller is subject.

It is possible that following a request of data erasure, COFFEOL ROMANIA applies pseudonymisation to such data (thus removing their personal character) and under these conditions continues processing for the purpose of statistics;

the right to restriction of processing, insofar:

the accuracy of the personal data is contested by the data subjectfor a period enabling us to verify the accuracy of the personal data;

the processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead;

the controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims in a court of law; or

the data subject has objected to processing (other than for direct marketing) pending the verification whether the legitimate grounds of the controller override those of the data subject;

the right to data portability, that is (i) the right to receive the personal data in a structured, commonly used and machine-readable format, as well as (ii) the right for those data to be transmitted by COFFEOL ROMANIA to another controller, insofar the legal conditions are complied with;
the right to object – concerning processing activities - can be exercised by submitting a request as specified below:

at any time on grounds relating to the data subject’s particular situation, objectingto the processing of personal data concerning him or her on grounds of the legitimate interest of COFFEOL ROMANIA or on grounds of public interest, unless the COFFEOL ROMANIAcan demonstrate legitimate and compelling grounds that justify the processing and that override the interests, rights and freedoms of the data subjects or can demonstrate that the purpose is the establishment, exercise or defence of legal claims in a court of law;

at any time,free of charge and without any justification, objectingto the processing of personal data concerning him or her for direct marketing purposes.

the right not to be subject to automated individual decision-making, that is the right not to be subject toa decision based solely on automated processing, including profiling, which produces legal effects concerning the data subject or similarly significantly affects this data subject;
the right to lodge a complaint with the National Supervisory Authority for Personal Data Processingand before the competent courts of law insofar you deem this necessary