Privacy Policy

This Privacy Policy (hereinafter referred to as "Privacy Policy") describes the practices of VERJEL & ASOCIAȚII – SOCIETATE CIVILĂ DE AVOCAȚI, established by Decision of the Bucharest Bar Council no. 758 of 25.04.2023, with registered office at 17 Thomas Masaryk Street, ground floor, sector 2, Bucharest, with tax code no. 48145170 (hereinafter referred to as "V&A" "we", "us", "our", or "Company"), regarding the collection, use, storage and disclosure of personal data (as defined below) provided to us by you and, in general, by users of the website www.scavas.ro (hereinafter referred to as the "Site"), as well as the content, products and services offered on the Site (hereinafter referred to together with the Site as the "Services"). This Privacy Policy constitutes an integral part of the Terms and Conditions, which are incorporated by reference. Each capitalized term in the Privacy Policy that is not defined herein shall have the meaning given to that term as defined in the Site Terms and Conditions. The title specifies the latest update to the Privacy Policy. Please visit the Site and review the Privacy Policy periodically as it may be amended from time to time. Each time you visit the Site or provide information to us, you are accepting the practices described in the Privacy Policy as amended and applicable at that time. This Privacy Policy implements the requirements of the new European regulations on the protection of personal data.

1. Introduction.We respect and support your right to privacy and personal data protection. We are aware of the importance of protecting personal information and we make every effort to ensure that every user of our Site can browse safely and securely. As a result of this goal, we have developed this privacy policy to inform you of our practices regarding the collection, use and disclosure of personal data.

For the purposes of this Privacy Policy, "Personal Data" means any information relating to an identified or identifiable natural person, i.e. first and last name, family member's first and last name, gender, date and place of birth, nationality, signature, vital records, telephone/fax, home/residence address, email, ip, cookie information, information about the device used (e.g. device type and web browser),information about how you use our website (which pages you accessed), date/time you accessed our website and what you clicked on, geographical location from which you accessed our website (based on IP address), profession, job, training, family situation, economic and financial situation, data on assets owned, bank data, image, Card number, Card expiry date, IBAN code, personal number code, ID card series and number. We will collect, use or disclose your personal data in accordance with the provisions of this Privacy Policy in force at the time and the provisions of applicable national and European legislation regarding the collection, use and disclosure of your personal data (REGULATION No 679 of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data). By requesting the submission of free information on the Company's offerings, as well as by accessing the Services you have been informed and understand that you expressly agree that V&A may use your personal data for the purpose(s) described in this Privacy Policy.

THE USER DECLARES THAT HE/SHE HAS BEEN INFORMED THAT HE/SHE HAS THE FOLLOWING RIGHTS IN RELATION TO THE PERSONAL DATA COLLECTED AND PROCESSED BY US IN ACCORDANCE WITH THIS PRIVACY POLICY:

• you have the right to access your data and receive information about its use
• you have the right to request correction and/or completion of the information
• you have the right to request deletion of your data
• you have the right to restrict the use of your data
• you have the right to receive data in a portable format
• you have the right to object to the processing of your data.
• you have the right to withdraw your consent to the processing of your data.
• you have the right not to be subject to a meaningful decision about you solely on the basis of automated processing of your data, including profiling
• you have the right to appeal to a supervisory authority

2. Warning for minors. Minors under the age of 18 and persons subject to a restraining order under applicable jurisdiction are prohibited from using the Site or any of the Services. We ask that such persons do not provide us with any information.
3. Information about the personal data we collect. During the process of registering or using the Site and the Services, you will be asked to provide us with personal data, including but not limited to your first and last name, e-mail address, date of birth, home address, telephone number, information regarding education and profession, marital status, and generally other information, which may be used to identify you.

We do not knowingly or intentionally collect sensitive personal information from individuals and you should not send us sensitive personal information. "Sensitive personal data" is information about an individual that reveals an individual's racial or ethnic origin, political opinions, religious or philosophical beliefs or trade union membership, genetic information, biometric information for the purpose of uniquely identifying an individual, health information or information about an individual's sex life or sexual orientation. If, however, you inadvertently or intentionally transmit sensitive personal information to us, you will be deemed to have explicitly consented to us processing your sensitive personal information in accordance with Article 9(2)(a) of the General Data Protection Regulation. We will use and process your sensitive personal information for the purpose of deletion.

4. Information on personal data collected by other sites. By accessing our Site, there may be links to other sites operated by third parties, as we may have such collaborations now and in the future. When you access such a link and browse and/or use the services of third parties, whether or not they contain our name, trademark or any other intellectual property right of ours, you are advised that V&A does not control the business practices of such third parties, and that this Privacy Policy does not apply to those third parties or the sites they own. V&A allows these companies to display advertisements on the Site and/or collect certain anonymous information when you visit the Site. These companies are permitted to use non-private information when you visit the Site or other sites for the purpose of providing advertisements for products and services of possible interest to you. These companies typically use cookies or "beacons" to collect this information.
5. Use of your personal data.We use your personal data for the following purposes:

• to carry out the contractual relationship between you and V&A, namely for taking, validating, dispatching and invoicing the order placed on the Site, informing you about the status of the order, organizing the return of ordered products, etc.;
• for the fulfilment of V&A's legal obligations in the context of the services provided through the Website, including tax obligations and archiving;
• for marketing activities, such as sending you emails with news about the Site and our Services, updating and adjusting Site content and product offerings, analyzing Site usage, sending you updates and information based on your interests - such as banners and offers, and to monitor traffic and improve your experience on the Site. You can consent to the processing of your data for this purpose by ticking the appropriate box at the time of account creation, or after account creation by completing the consent form. To unsubscribe from receiving such commercial communications you can use the option at the end of each email containing commercial communications.
• for relaying messages from other users or members. We may also use your personal data to provide you with information about products and services provided by third parties.
• to facilitate communication with other members or users of the Site and Services.
• to resolve disputes, and enforce the policies and rules governing use of the Site.

Providing us with your personal data is optional. However, on certain occasions, if you do not grant us access to your personal data, you will not be able to access some or all of our services.

6. Disclosure of personal data.We do not sell your personal data to third parties and we have not authorised any third party to use it. However, in the course of our business activities, we may disclose some of your personal data to our business partners and third parties acting on our behalf, or where required or permitted by applicable personal data protection law. The legal grounds for such disclosures are either legitimate interest or legal obligation of our company.
7. Service providers.We may use third party service providers (such as website hosting service providers; data management service providers, etc.) to administer one or more aspects of our business activities, including the processing and provision of personal information. Where your personal data is used by another company or an affiliate, we ensure that your personal data is processed in accordance with this Privacy Policy through contractual commitments or other appropriate means. Your information will be shared with these service providers where necessary to provide you with the service you have requested, whether that request is to access our website or order goods and services from us.
8. Disclosure of information under the law.We may disclose your personal data to the extent permitted or required by law. For example, we may be required to disclose your personal data as a result of the enforcement of a court order, an order issued by a prosecutor, or pursuant to the decision of a person or administrative body with the authority conferred by law to compel disclosure of such information. If we reasonably believe that your personal data could be useful in the investigation of illegal activities, we may disclose such information to the appropriate state authorities. We will also use your information in connection with the enforcement or potential enforcement of our legal rights, including, for example, exchanging information with debt collection agencies, if you fail to pay amounts due when you are contractually obligated to do so. Our legal rights may be contractual (where we have entered into a contract with you) or non-contractual (such as legal rights we have under copyright or tort law). We may need to use your information if we are involved in a dispute with you or a third party, for example, either to resolve the dispute or as part of mediation, arbitration or a court judgment or similar process.
9. Processing time. Further use of the data In order to achieve the purposes mentioned, the V&A will process personal data for the duration of the activities until the user expresses the right to object, the right to request deletion of the data or to restrict the use of the data. Subsequent to the end of the processing of personal data for the purposes for which they were collected, until such time as the aforementioned rights are exercised in accordance with the law, these data will be archived by the V&A indefinitely or will be destroyed, taking into account the following criteria:

• the purpose(s) and use of your information both now and in the future (for example, whether it is necessary for us to continue to store that information in order to continue to perform our obligations under a contract with you or to contact you in the future);
• whether we have a legal obligation to continue processing your information (such as any record-keeping obligations imposed by law or relevant regulations);
• whether we have any legal basis to continue processing the information (such as your consent);
• how valuable your information is (both now and in the future);
• any agreed industry practices regarding the retention period of information;
• the levels of risk, cost and liability involved in continuing to hold information;
• how difficult it is to ensure that information can be current and accurate; and
• any relevant surrounding circumstances (such as the nature and status of our relationship with you).

10. Rights of data subjects You may exercise all the rights set out in point 1. of this Privacy Policy as well as the right to address the National Supervisory Authority for the Processing of Personal Data or the courts. You may exercise these rights by sending to the V&A, at the correspondence address VERJEL & ASOCIAȚII – SOCIETATE CIVILĂ DE AVOCAȚIestablished by the Decision of the Bucharest Bar Council no. 758 of 25.04.2023, with registered office at str. Thomas Masaryk no. 17, sector 2, Bucharest, with fiscal code no. 48145170, e-mail office@scavas.roa written request, dated and signed. The V&A will take all reasonable steps to ensure that its representatives or employees do not use for personal gain or for the benefit of another, directly or indirectly, personal data and information that they hold or of which they have become aware in any way.
11. Dispute resolution.If at any time you have questions or concerns about this Privacy Policy, or believe that we have violated this Privacy Policy, please email us at: office@scavas.roand we will try to resolve any issues you may have. We also inform you that as a data subject you have the right to object at any time, free of charge and without justification, to your data being processed for direct marketing purposes or being disclosed to third parties for such purposes. In order to exercise these rights you will submit a written request to us, dated and signed. Please specify in your request whether you want the information to be communicated to you at a specific address, which may be an e-mail address. We will inform you of the action taken within 15 days of receipt of your request. If you do not receive a reply within the specified time limit or are not satisfied with our response, then you have the right to address the National Authority for Personal Data Protection. Without prejudice to the possibility of complaining to the supervisory authority, you have the right to take legal action to defend any rights guaranteed by law that have been violated.
12. Cookies.For your convenience while using the Site, we use cookies, a technology that, through the use of alphanumeric identifiers, stores a small amount of information on a Site user's computer so that the Site can track the user's future visits when browsing from the same computer. Cookies are intended to enhance convenience and improve the use of the site. For example, the information provided through cookies is used to identify you as a former user of the site, to provide personalized site content and information about how you can use the site, and to facilitate your experience while browsing the site. You may refuse the use of cookies if your browser permits, but doing so may affect the quality of use of the site and your ability to access certain features and transactions. More information about deleting or controlling cookies is available at www.aboutcookies.org.
13. Tracking information Please be advised that we may use web beacons or pixel tags for tracking information and in particular for tracking our users and collecting evidence and information regarding site user demographics, navigation and site access patterns, statistical analysis, etc. We may pass on the above information to advertisers and others in order to improve our services or to provide similar services. None of this information may be linked to your identity or other personal data of individual users. Since Web beacons work like any other request for information on the site, you cannot refuse them, but you can make them ineffective by withdrawing them from cookies or changing your browser's cookie settings. Also, for our research purposes, we may link tracking information through Web beacons with personally identifiable information voluntarily provided by users of the site. In the event of such linking, all linked information is considered and treated as personal data, which is used and disclosed only in accordance with this Privacy Policy.
14. Data transfer All your information is stored in Romania. Personal data provided to Nomilus may be transferred outside Romania, but only to countries within the European Economic Area. Apart from complying with any legal obligations to which we are subject (e.g. compliance with a court order), we do not intend to transfer your information outside the European Economic Area or to an international organisation. In the unlikely event that we are required to transfer your information outside the EEA (or to an international organisation) for such a purpose, we will provide appropriate safeguards and protections.