Regarding the processing of personal data

We consider ensuring the right to the protection of personal data as a fundamental commitment of Comnord, therefore we will devote all the necessary resources and efforts to process your data in full compliance with Regulation (EU) 2016/679 (“General Data Protection Regulation” or “GDPR”), as well as with any other legislation applicable on the territory of Romania. As one of the essential principles of this legal framework is transparency, we have prepared this document to inform you about how we collect, use, transfer and protect your personal data when you interact with us in relation to our products and services including through our website.

We reserve the right to periodically update and amend this Privacy Policy to reflect any changes in the way we process your personal data or any changes in legal requirements. In case of any such change, we will display on our website the modified version of the Privacy Policy, which is why we ask you to periodically check the content of this Privacy Policy.

Who we are and how you can contact us

Comnord is a legal entity of Romanian nationality, with its registered office in Bucharest, Calea Grivitei 136, sector 1, with order number in the Commercial Register J40/493/1991, unique tax registration code 1590368 (hereinafter “Comnord” or “we”). For the purposes of data protection legislation, we are the controller when we process your personal data.

As we are always open to your views, as well as to provide you with any additional information you may need regarding the processing of your data, we encourage you to contact Comnord’s Data Protection Officer at data.protection@cnotechno .com or by post or courier to the address Calea Grivitei 136 sector 1 Bucharest – with the mention: to the attention of Comnord’s Data Protection Officer.

What categories of personal data we process

We generally collect your personal data directly from you, so you have control over the type of information you give us. By way of example, we receive information from you as follows:

• When you create a Comnord account, you provide us with: your email address, first and last name;
• Within your personal page (My Account) in the Comnord platform you have mobile phone number, landline number, date of birth, education level, delivery addresses, alternative e-mail address, bank card details, etc.;
• When you place an order, you provide us with information such as: desired product, name and surname, mailing address, telephone number, etc.

We also offer you the possibility to register in the Comnord platform through your Facebook or Google account. If you opt for one of these options, you will be directed to a page managed by Facebook Inc / Google LLC, where they will inform you about the transfer of your data to Comnord. You can consult the privacy policies of Facebook and Google, respectively, using the following links:

https://www.facebook.com/about/privacy

https://policies.google.com/privacy

We may also collect and further process certain information about your behavior while visiting our website in order to personalize your online experience and provide you with offers tailored to your profile. We invite you to learn more details in this regard by consulting the section regarding the purposes of processing below.

On our website we may store and collect information in cookies and similar technologies, according to the Cookie Policy.

We do not collect or otherwise process sensitive data, included by the General Data Protection Regulation in special categories of personal data. We also do not wish to collect or process data of minors under the age of 16.

What are the purposes and grounds of the processing

We will use your personal data for the following purposes:

1. For the provision of Comnord services for your benefit

This general purpose may include, as appropriate, the following:

• Providing support services, including providing answers to your questions about Comnord.

The processing of your data for these purposes is in most cases necessary for the conclusion and execution of a contract between Comnord and you. Also, certain processing subsumed for these purposes is required by applicable law, including tax and accounting law.

2. To improve our services

We always want to give you the best online shopping experience. For this, we may collect and use certain information related to your Shopping behavior, we may invite you to complete satisfaction surveys following the completion of an order, or we may conduct, directly or with the help of partners, studies and market research.

We base these activities on our legitimate interest in carrying out commercial activities, always taking care that your fundamental rights and freedoms are not affected.

3. For marketing

We want to keep you informed about the best offers for the developments made by our company. In this regard, we may send you any type of message (such as: e-mail/SMS/telephone/mobile push/webpush/etc.) containing general and thematic information, as well as other commercial communications such as market research and opinion polls , and we may display personalized recommendations on the website. We always ensure that this processing is carried out in compliance with your rights and freedoms, and that the decisions made on the basis of them do not have legal effects on you and do not similarly affect you to a significant extent.

In most cases, we base our marketing communications on your prior consent. You can change your mind and withdraw your consent at any time by:

• Accessing the unsubscribe link displayed in the messages you receive from us; or through
• Contacting Comnord using the contact details described above.

In certain situations, we may base our marketing activities on our legitimate interest in promoting and developing our business. In any situation where we use information about you for our legitimate interest, we take care and take all necessary measures to ensure that your fundamental rights and freedoms are not affected. However, you can ask us at any time, by the means described above, to stop processing your personal data for marketing purposes, and we will comply with your request.

4. To defend our legitimate interests

There may be situations where we will use or share information to protect our rights and business. These may include:

• Measures to protect the website and users of the Comnord platform against cyber attacks:
• Measures to prevent and detect fraud attempts, including the transmission of information to the competent public authorities;
• Measures to manage various other risks.

The general basis for these types of processing is our legitimate interest in defending our commercial activity, it being understood that we ensure that all measures we take guarantee a balance between our interests and your fundamental rights and freedoms.

Also, in certain cases we base our processing on legal provisions such as the obligation to ensure the protection of goods and valuables provided by the applicable legislation in this matter.

How long we keep your personal data

As a general rule, we will store your personal data while the Comnord project is in operation. You may request that we delete certain information or close your account at any time, and we will comply with such requests, subject to the retention of certain information including after account closure, where applicable law or our legitimate interests require it.

To whom we transmit your personal data

As appropriate, we may transmit or provide access to certain of your personal data to the following categories of recipients:

• companies within the same group of companies;
• IT service providers;
• other companies with which we can develop joint programs for offering our goods and services on the market.

If we are under a legal obligation, or if it is necessary to defend a legitimate interest, we may also disclose certain personal data to public authorities.

We ensure that access to your data by third parties under private law is carried out in accordance with the legal provisions on data protection and information confidentiality, based on contracts concluded with them.

To which countries we transfer your personal data

Currently, we store and process your personal data on the territory of Romania.

How we protect the security of your personal data

We are committed to ensuring the security of personal data by implementing appropriate technical and organizational measures in accordance with industry standards.

The transmission of your personal data is done using state-of-the-art encryption algorithms and we store them on secure servers, ensuring data redundancy at the same time.

Despite the measures taken to protect your personal data, we draw your attention to the fact that the transmission of information over the Internet, in general, or through other public networks, is not completely secure, and there is a risk that the data will be seen and used by third parties unauthorized. We cannot be responsible for such vulnerabilities of systems that are not under our control.

What rights do you have?

The General Data Protection Regulation recognizes a number of rights in relation to your personal data. You can request access to your data, correct any mistakes in our files and/or object to the processing of your personal data. You can also exercise your right to complain to the competent supervisory authority or go to court. If applicable, you may also benefit from the right to request the deletion of your personal data, the right to restrict the processing of your data and the right to data portability.

More information about each of these rights can be obtained by consulting the table below.

In order to exercise your rights, you can contact us using the contact details set out above. Please note the following points if you wish to exercise these rights:

Identity. We take the privacy of all records containing personal data seriously. For this reason, please send us your requests regarding such records using the e-mail address related to the Comnord account. Otherwise, we reserve the right to verify your identity by requesting additional information aimed at confirming your identity.

Fees. We will not charge a fee to exercise any right in relation to your personal data, unless your request for access to the information is unfounded, repetitive or excessive, in which case we will charge a reasonable amount in such circumstances. We will inform you of any fees applied before we settle your claim.

Response time. We aim to respond to any valid requests within a maximum of one month, unless this is particularly complicated or you have made multiple requests, in which case we will respond within a maximum of two months. We will let you know if we need more than a month. We may ask if you can tell us exactly what you want to receive or what you are concerned about. This will help us act faster and shorten the response time to your request.

Third Party Rights. We must not comply with a request if it would adversely affect the rights and freedoms of other data subjects.

Entitled rights	Description
Access	You can ask us: to confirm whether we are processing your personal data; to provide you with a copy of this data; to provide you with other information about your personal data, such as what data we have, what we use it for, who we disclose it to, whether we transfer it abroad and how we protect it, how long we keep it, what rights you have , how you can make a complaint, where we obtained your data, to the extent that the information has not already been provided to you by this notice.
Correction	You can ask us to correct or complete your inaccurate or incomplete personal data. We may attempt to verify the accuracy of the data before rectifying it.
Data deletion	You can ask us to delete your personal data, but only if: it is no longer necessary for the purposes for which it was collected; or you have withdrawn your consent (where the data processing was based on consent); or exercise a legal right to object; or they were processed illegally; or we have a legal obligation to do so. We are under no obligation to comply with your request to delete your personal data where the processing of your personal data is necessary: ​​to comply with a legal obligation; or for establishing, exercising or defending a right in court. There are certain other circumstances in which we are not obliged to comply with your request to delete data, although these two are the most likely circumstances in which we may refuse this request. Please note that before exercising this right, you download from the Comnord account and to save all the documents related to the orders made from Comnord, regardless of whether the invoicing was done to you or to another natural or legal person (such as: invoices, warranty certificates). If you do not take this step before exercising your right to deletion, you will lose all these documents and Comnord will be unable to make them available to you, as the case may be, because the process of deleting the data, respectively the Comnord account , with all the related data and documents, is an irreversible process.
Restriction of data processing	You can ask us to restrict the processing of your personal data, but only if: its accuracy is disputed (see rectification section), to allow us to verify its accuracy; or the processing is illegal, but you do not want the data to be deleted; or they are no longer necessary for the purposes for which they were collected, but you need them to establish, exercise or defend a right in court; or you have exercised your right to object and checking whether our rights prevail is ongoing. We may continue to use your personal data following a restriction request if: we have your consent; or to establish, exercise or ensure the defense of a right in court; or to protect the rights of Comnord or another natural or legal person.
Data portability	You may ask us to provide your personal data in a structured, commonly used and machine-readable format, or you may request that it be “ported” directly to another data controller, but in each case only if: the processing is based on your consent or the conclusion or performance of a contract with you; and the processing is done by automated means.
Opposition	You can object at any time, for reasons related to your particular situation, to the processing of your personal data on the basis of our legitimate interest, if you consider that your fundamental rights and freedoms prevail over this interest. You can also object to the processing of your data for direct marketing purposes (including profiling) at any time without giving any reason, in which case we will stop this processing as soon as possible.
Automated decision making	You can ask not to be subject to a decision based solely on automated processing, but only when that decision: produces legal effects in relation to you; or otherwise affects you in a similar and significant way. This right does not apply where the decision reached through automated decision-making: is necessary for us to enter into or perform a contract with you; is authorized by law and there are adequate safeguards for your rights and freedoms; or is based on your explicit consent.
Claims	You have the right to lodge a complaint with the supervisory authority regarding the processing of your personal data. In Romania, the contact details of the supervisory authority for data protection are as follows: National Authority for the Supervision of Personal Data Processing B-dul G-ral. Gheorghe Magheru no. 28-30, Sector 1, postal code 010336, Bucharest, Romania Phone: +40.318.059.211 or +40.318.059.212; E-mail: anspdcp@dataprotection.ro Without affecting your right to contact the supervisory authority at any time, please contact us in advance, and we promise that we will make every effort to solve any problem amicably .

We remind you that you can contact the Comnord Data Protection Officer at any time by sending your request through any of the following methods:

• by e-mail to the address: dataprotection@cnotechno.com or
• by post or courier to the address: Calea Grivitei 136 sector 1 Bucharest – with the mention to the attention of Comnord’s Data Protection Officer.