Data Security Policy

Introduction

S.C. StarShinerS. S.R.L , generically named StarShinerS, as an author, owner, manager of the website www.StarShinerS.com, respects the private character and data security when you access this website, including personal data information, creating this Security Policy for this purpose.

The access/ the visit of this website involves respecting the Terms and Conditions and the Security Policy, and implies your acceptance regarding these and represents the agreement between the two parties.

StarShinerS has the right to change and update the website www.StarShinerS.com content anytime, as well as the present Security Policy and the Terms and Conditions of usage without notice. That is why we ask you to visit this section periodically to check the Terms and Conditions you have agreed to respect.

The presented terms and conditions are valid and are applied to all the websites in the field where StarShinerS and for which S.C. StarShinerS. S.R.L. has the quality of author/ owner/ manager. All these websites (as they exist now or will be implemented in the future), as well as StarShinerS website will be generic named, in a collective or individual manner, Site and/or Sites as following.

In the present document, the singular words include the plural, the plural words include the singular, the words denoting masculine include the feminine, and the words denoting feminine include the masculine.

StarShinerS engages itself to protect the client’s privacy and takes seriously the responsibility regarding the security of clients’ information. We will be clear and transparent regarding the information we collect and the way we will use them.

This Policy will establishes the following:

• 1. What personal data we collect and process about you regarding your relationship with us as a client and your usage of our site and the online services;
• 2. Where we get the data from;
• 3. What we do with these data;
• 4. How we store the data;
• 5. To whom we transfer/ share these data;
• 6. How we take care of your rights to secure the data;
• 7. And how we respect the rules of data security.

All the private data are collected and processed according to the legislation regarding personal data security in Romania and EU.

Data processor

“StarShinerS”(mentioned “We”, “our” or StarShinerS in this policy) refers to StarShinerS S.R.L. mainly. Our society is registered in Romania at Trade Register Office Bihor under no J05/729/2008, with fiscal code RO 23508416, located in Oradea, Czaran Gyula street, no 5, 410240, Bihor county. StarShiners is the data processor of all the personal information collected and used in connection to StarShinerS’s clients under the Romanian rule in its field and the EU Statute no 679/2016 regarding personal data processing. StarShinerS. S.R.L is personal data processor registered at ANSPDCP with number 10834.

What type of data we collect

Your personal data means any information regarding yourself that allows us to identify you, as your name, your contact information, payment details and information about your access to our site.

We can collect personal data from you only when you create a StarShinerS account, in order to estimate our offers or to purchase a product in our on-line shop, when you use the website or other sites accessible by means of our site, when you take part in a survey, a contest or when you contact us.

Moreover, we can collect the following types of information:

• a. Name, your residence address, your e-mail address, phone number, credit card or other payment details;
• b. Detailed information about buyers, which include name, date of birth, sex;
• c. Information about the way you use your site;
• d. Communications you have with us or you direct to us by letters, e-mails, chat services, calls and social networks.

We will process any type of other data only if you expressed your explicit consent or this is required by actual laws at that moment or you have deliberately made them public.

What are we using your personal data for, why and how long

Your data may be used in the following purposes:

• a. To provide products or services you require: we use the information you give us in order to perform the services you have required about your acquirements, including required changes connected to these acquirements;
• b. In order to contact you in case of change of purchasing conditions. These information do not have a commercial purpose and you cannot unsubscribe to them;
• c. In order to check your credit card or any other type of card used for payment: we use your payment information for accountancy purposes, for billing, audit, and to detect/ prevent any fraudulent activity;
• d. For administrative or juridical purposes: we use you data for statistical marketing analysis, testing systems, studies about clients’ satisfaction, maintenance and development , or to solve a controversy or a request. Our society does not perform data profiling on basis of the data we collect from you for purposes of statistical and marketing analyses. Any profiling activity will be performed only with your preceding consent and making efforts to ensure that all the data they rely on are correct.
• e. Security, health, management, preventing/ detecting, crimes: it is possible to transmit your information to the governmental authorities or law organs in order to respect the legal requests;
• f. For communications of Public relations department: we use your data to manage our relationship with you as our client and improve our services and your experience with us;
• g. To provide custom services: we use your data to provide information that we think you are interested in before, while and after your acquirement to customize the services we offer to you, such as special offers;
• i. Marketing: we will contact you periodically to give you information about special offers and auxiliary products by means of on line communications.

Nevertheless, you will have the option to subscribe or unsubscribe to such communications by indicating this when you fill in your StarShinerS account. As well, for any online communication from us, you will have the possibility to indicate that you don’t want to receive any direct marketing materials from us..

We will process your data only we have a legal basis to do this. The legal basis will depend on the reasons we have collected and for which we have to use your personal data

Most of the times, we will have to process your personal data in order to introduce them in our purchase contract with you.

As well, we can process your data in one or some of the following cases:

• - In order to respect a legal duty (for example fiscal or custom requirement or those regarding consumer protection);
• - You have given your accept to use your personal data (for example for commercial purposes);
• - To protect your vital interests or any other person’s;

It’s a part of our justified interests to work as a commercial society (for example, for administrative purposes).

Only children with the age of minimum 16 years old can give their consent. For children under this age, parents’ or legal tutors’ consent is necessary.

We won’t keep your data more than necessary in order to accomplish the purpose they are processed for. In order to determine the right storage period we are taking into account the quantity, nature and sensitiveness of personal data, the purposes we are processing them for and whether we can touch this purposes by other means.

As well, we have to take into account the periods when keeping your personal data should be necessary (for example, connected to requests about returning products) or to handle complaints, questions, and to protect our legal rights in case of any demand.

When we don’t need your personal data, we will delete or destroy for sure. As well, we will take into account whether and how we can minimize in time the quantity of personal data we are using and whether we can assure the anonymity of your personal data so that they no longer be associated with yourself or to identify you, in this case we can use this information without future notice.

Your personal data security

We respect strict security procedures in storing and revealing your personal data and to protect them against the loss or any accidental damage. The data you are providing us with are protected by means of SSL technology ( Secure Socket Layer).SSL is the standard method in industry to crypt the personal information and the credit card data, in order to assure a safe transfer by the internet..

All the payment details are transmitted with an SSL connection type by means and are stored in accordance with the Standards regarding Data Security in Credit Card payment industry.

It’s possible to share some information about you to third reliable parties with the purposes established by this Security policy. We ask all the third parties to dispose of technical and operational security measures in order to protect your personal data, in accordance with Romanian and EU data protection rules.

The international data transfer

StarShinerS does not transfer collected personal data abroad, no matter it’s about EU members or outside the Economical European Space.

Sharing your personal data

Your personal data are not communicated to other partner or associated companies.

Still, by ways of exception, we can share your personal data with the next third parties in the purpose described in this Security Policy:

• a. The government authorities, law applying organisms and regulation authorities in order to respect the legal requests;
• b. Credit and debit cards companies that make easy the money transfer to us and anti-fraud screening, which could need information about your method of payment and delivery of the product in order to process the payment and assure your payment operation security;
• c. Legal advisors and other professionals, courts, and legislative bodies in all the areas of activity, in order to impose our legal rights connected to our contract with you;

The Section My ACcount

All the data collected to register in the section My Account will be processed in accordance with the present security policy.

We understand the importance of taking additional steps to protect children privacy and safety. This way, children under 16 years will not be able to create a StarShinerS account. We will delete any account for a child who is not 16 years old yet, as soon we are informed about that.

When the usage of your personal data relies on your consent, you have the option to back out your processing consent and delete your personal data anytime with a click on the button Delete in the section My Account.

We keep the personal information in the section My Account as long as you own the account. Remember that the main periods of storage are applied to all the persons we collect to contract with you or to accomplish the contract or because we have a legal duty to process them.

Cookie modulus and managing the site

This internet page uses Cookies in order to allow us to improve the services we offer and provide some functions you will find useful. These may include cookie modulus of media and advertising partners that are saved on your device when you visit our page. Please, visit our partners’ pages to find out information about their security policy and regarding modulus cookie.

Modulus cookie are little text files that are transferred on your computer’s hard drive by web browser in order to allow us recognize your browser and help us monitor the visitors on our web page; thus, these allow us understand better the products and the services that suits you the best. A cookie modulus contains your contact data and information that allow us identify your computer when you skim through our pages, in order to help you finish the booking. Most of web browsers accept modulus cookie automatically, but if you want to, you can change this browser set up by accepting, declining and deleting cookie modulus. “Help” section of the tool bars of many browsers will tell you how to avoid accepting new cookie modulus by your browser, how to set your browser to inform you when you receive a cookie modulus or how to completely disable cookie modulus. If you choose to change these settings, it’s possible to state that some functions and features will not work as they were expected to. Cookie modulus that we are using do not detect any stored information on your computer.

In order to find out more about cookie modulus and how to prevent their installing, please visit our web page : http://www.allaboutcookies.org

Data protection responsible

We have appointed a data protection responsible (“DPR”) in order to supervise the policy observance. If you have questions regarding this policy or about the way we take care of your personal data, please contact DPR at gdpr@starshiners.com . You have the right to address a complaint any moment to a supervising authority. The National Authority of Personal data Supervising( A.N.S.P.D.C.P.) is the main authority of data protection for StarShinerS, as a Romanian data operator.

Your rights regarding data protection

Under some circumstances, you have the legal right:

• 1.To ask for information about the fact that we own personal information about you, and, if yes, what information it is about and why we are keeping/ using them.
• 2.To ask for access to your personal data (known as “access request for a concerned person”). This allows you to receive a copy of your personal information we own about you and check if we are processing them legally.
• 3.To ask for the correction of personal data that we own about you. This allows you to correct any incomplete or inaccurate information about you.
• 4.To ask for the deletion of your personal data. This allows you to ask us to delete or remove the personal information when there are no well-founded reasons to continue processing them. As well you have the right to ask us to delete or remove your personal information in case you exercised your right to oppose to data processing( as to be seen below);
• 5.To get opposed to personal data processing in case we rely on a justified interest (or a third parties) and there is something about your personal situation that makes you want to object against processing for this reason. As well, you have the right to object in case we process personal data information for direct marketing purposes.
• 6. To get opposed regarding the automatic making of decisions, including profile analysis, this meaning not to represent the object of any automatic decision by using your personal information or your profile analysis.
• 7.To ask for restrictions regarding your personal information processing. This allows you to stop processing your personal information, for example if you want us to establish the accuracy or the reason for this processing.
• 8.To ask for your personal information to be transferred in an electronic and structured way by yourself or to some other parties (generally known as “data mobility”). This allows you to take your personal data from us in an electronic size and makes possible the transfer to another electronic size.
• 9.To withdraw your consent. Under the limited circumstances you offered your agreement to collect, process, transfer your personal information for a certain purpose, you have the right to withdraw any moment your consent for the certain data processing. Once we receive the notice that you withdrew your consent, we will stop processing your personal information for the purposes you have initially agreed, excepting the case we have a legal right.

If you want to exercise any of these rights, please send us a completed request to the following link, or send an e-mail to our data protection responsible at the e-mail address gdpr@starshiners.com or contact him by post to the following address: StarShinerS S.R.L, Czaran Gyula , No 5, 410240, Oradea city, Bihor county.

You won’t have to pay any tax to access your personal data information ( or to exercise any of the other rights you have). Nevertheless, it’s possible for us to ask for a reasonable tax if your access request is obviously unfounded or exaggerated. As well, we can refuse to admit your request under these circumstances.

We might ask for specific information to confirm your identity and to assure the right access these information (or to exercise the other rights). This is another security step taken to make sure that your personal information are not divulged to any other person that hasn’t got the right to receive it.

Changes in our Security Policy

Our security policy may be changed periodically, and any change of statement will be announced by an e-mail or a notification on our site.