The content of the website www.frenchrevolution.ro (hereinafter referred to as the “ Website ”) is the property of French Revolution SRL , a legal entity under Romanian law, with its registered office in Bucharest, Romania, Str. Constantin Ghercu, No. 1B, Bridge Building 3, Ground Floor, Sector 6, registered with the Trade Register Office under No. J40/4987/2013, Unique Registration Code 31511366, (hereinafter referred to as “ French Revolution ” or the “ Owner ”).

As a data controller, French Revolution constantly monitors and ensures that the processing of personal data strictly complies with the principles and legislation on the protection of personal data, in particular the provisions of Regulation (EU) 2016/679 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/EC (hereinafter “GDPR”).

The Privacy Policy is valid from 30.04.2019 and is intended to inform you about how French Revolution processes your personal data when you visit our Website, when you use the functions available on the Website, when you send us orders or other requests by email.

This Privacy Policy may be updated later, in which case we will inform you by publishing the updated version on the Website. To ensure that you are always informed about how French Revolution processes your personal data, you can consult the Privacy Policy each time you return to our Website or when you use the features available on it.

The Website may include Links to other websites that are managed by other entities/legal persons for which French Revolution is not responsible and which are not related to our activity. When you access these websites through our Website, we recommend that you consult the privacy policies of those websites to be informed about how your personal data is processed by the owners of those websites.

" Customer " means the natural or legal person who purchases one or more Products by placing an order on the French Revolution Website.

" Personal Data " means any information relating to an identified or identifiable natural person ("data subject"); an identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to his or her physical, physiological, genetic, mental, economic, cultural or social identity.

" Processing " (and its derivatives, including without limitation "to process") means any operation or set of operations performed on Personal Data, including without limitation collection, recording, storage, alteration, use, disclosure, access, transfer or destruction thereof.

" User" means any person who accesses or uses the Website.

Other capitalized terms that have not been defined in this Privacy Policy will have the meaning assigned to them according to the definitions in the Website Terms and Conditions of Use - more details here.

Your Personal Data provided when using the Website, such as in the context of placing online orders; submitting orders or other requests by e-mail; requesting offers; improving services, or otherwise provided through the use of the Website, or within the relationship with French Revolution, may be processed directly by French Revolution and/or through its agents, based on the following purposes and grounds:

III.1. If you are a User of the Website , your Personal Data is processed as follows:

III.1.1. To improve your browsing experience , but also to provide you with the requested services , our Website uses cookies.

Grounds for processing: consent, contract execution or legitimate interest, according to the provisions of Law 506/2004 and those detailed in the Cookies Policy.

For more details on the use of cookies, please access the Cookies Policy.

III.1.2. For the management of requests sent via our email addresses on the Website.

Grounds for processing: legitimate interest.

III. 2. If you are a private individual Customer.

When you place an order online on our Website , via our email addresses or by phone , your Personal Data is processed as follows:

III.2.1. To comply with legal obligations, in order to achieve the following purposes :

• fulfilling financial, accounting and fiscal obligations, including preparing accounting records, keeping supporting documents that form the basis of accounting records;
• resolving requests/complaints regarding the exercise of your rights in the context of data processing, indicated below in Section XII;
• internal audit;
• archiving documents according to legal provisions and in compliance with deadlines;
• managing relations with public authorities or other entities that provide a public service.

Grounds for processing: legal obligation.

III.2.2. For the conclusion and execution of contracts, in order to achieve the following purposes :

• processing orders, such as but not limited to, taking over, validating, shipping and invoicing the Customer's order, informing the Customer about the status of the order and delivering the ordered products to the Customer;
• managing Customer accounts created on the Website for the purchase of products (i.e., Eclairs), but also to facilitate the placement of subsequent orders;
• managing requests/complaints/suggestions received in connection with the performance of the contract, respectively regarding the ordered products and their delivery.

Basis of processing: contract *

*In the case of online orders, the contract is concluded, for example, by accepting the Terms and Conditions of use of this function on the Website.

III.2.3. To fulfill the legitimate interests of French Revolution, in order to achieve the following purposes :

• the establishment, exercise or defense of French Revolution's rights in court, as well as in any other judicial proceedings;
• for the purpose of carrying out various analyses, reports on the functioning of the Website, creating profiles of consumer preferences, mainly in order to improve the products, functionalities and services made available by French Revolution. The statistical data may be transmitted to French Revolution partners, in aggregate form, without including data that could lead to the identification (directly or indirectly) of the data subjects.
• handling any other requests/complaints/suggestions.

Grounds for processing: legitimate interest

III.2.4.

Basis for processing: consent*

* Your consent for direct marketing activities may be withdrawn at any time. The withdrawal of your consent will have future effect, without affecting the lawfulness of the processing carried out prior to the withdrawal. Although in the event of withdrawal you will no longer receive direct commercial messages, French Revolution may still process your Personal Data lawfully, on other grounds and for other purposes such as the fulfillment of certain legal obligations to which we are subject, the execution of the contract or our legitimate interest (e.g. to improve services, resolve complaints received, defend rights and interests).

III.3. If you are a contact person for our legal entity Clients, we may process your data:

III.3.1. To comply with legal obligations, in order to achieve the following purposes :

• fulfilling financial, accounting and fiscal obligations, including preparing accounting records, keeping supporting documents that form the basis of accounting records;
• resolving requests/complaints regarding the exercise of your rights in the context of data processing, indicated below in Section XII;
• internal audit;
• archiving documents according to legal provisions and in compliance with deadlines;
• managing relations with public authorities or other entities that provide a public service.

Grounds for processing: legal obligation

III.3.2. To fulfill the legitimate interests of French Revolution, in order to achieve the following purposes :

• processing orders, such as but not limited to, taking over, validating, shipping and invoicing the Customer's order, informing the Customer about the status of the order and delivering the ordered products to the Customer;
• handling any other requests, complaints, suggestions.

Grounds for processing: legitimate interest.

The categories of Personal Data that we process depend on your interaction with our Website and the relationships created with the Data Controller.

Thus, French Revolution may process the following Categories of Personal Data:

• for creating online accounts: name, surname, email address, telephone number, delivery address;
• for online or email orders: name, surname, email address, telephone number, delivery address;
• for telephone orders: name, surname, telephone number, delivery address;
• for the transmission of commercial communications according to section III.2.4. above: name, surname, e-mail address;
• any other categories of Personal Data that you will provide to us directly in relation to the intended purpose.

To fulfill the processing purposes, French Revolution may disclose certain categories of Personal Data to the following categories of recipients:

• the data subject in the context of requests for the exercise of the right of access;
• contractual partners such as payment processors in the context of online payments for processing your orders, courier companies for the delivery of your orders, external consultants in various fields such as accounting, legal, tax or other partners who assist French Revolution for various purposes such as maintaining accounts created within the Website, performing statistical analyses and reports on how the Website is used, including with regard to online orders, as well as for the transmission of marketing communications, under the conditions and limits provided by law;
• to public authorities , in response to a request for information made in compliance with legal provisions or in any case for French Revolution to fulfill a legal obligation;
• to third parties , in connection with or during negotiations regarding a merger, sale of French Revolution assets, consolidation or restructuring, financing or acquisition of French Revolution or a portion thereof by other entities.

French Revolution will process your Personal Data for the period necessary to achieve the processing purposes and subsequently in accordance with our internal policies, as well as in order to comply with applicable legal obligations, including, but not limited to, provisions relating to the archiving obligation or financial-accounting and fiscal obligations (for example, in the case of financial-accounting supporting documents for which the retention period provided by law is 10 years from the date of the end of the financial year during which they were drawn up).

In certain situations, it is possible that, following the fulfillment of the legal retention/archiving deadlines, French Revolution may order the anonymization of the data, thus depersonalizing it and continuing to process the anonymous data for statistical purposes.

With regard to Personal Data processed for direct marketing purposes, they will be processed as long as we have your consent to receive these communications, as well as thereafter for the period necessary to demonstrate compliance with legal requirements (such as the general 3-year limitation period).

Your requests regarding the exercise of the rights in relation to the processing of Personal Data set out in Section XII below, as well as French Revolution's responses thereto, including the steps taken to respond to your requests, will be kept for the period necessary to demonstrate compliance with legal requirements (such as the 4-year period taking into account the limitation periods provided for by specific legislation).

Personal Data provided to French Revolution will not be transferred outside Romania and therefore, not to states outside the European Economic Area.

Providing the requested Personal Data is necessary for the purpose of registering, processing and delivering orders, respectively issuing invoices in your name, and the refusal to provide this data may make it impossible for us to register your order, deliver the products to you and issue your invoices. Therefore, this data is necessary in order to benefit from the services that French Revolution makes available to you through the Website or to be able to send us your order by e-mail or by phone.

In the case of direct marketing communications, providing your data for this purpose is voluntary.

Although in certain situations French Revolution asks for your consent to process certain Personal Data, such consent may not always be required by law. In such situations, French Revolution may use other grounds for processing the data, such as the performance of the contract for order processing or legitimate interest as detailed above in Section III.

French Revolution attaches great importance to the confidentiality and security of your Personal Data and understands to ensure their security during the processing activities under this Privacy Policy. In this regard, we implement appropriate technical and organizational measures to ensure a level of security appropriate to the risks associated with the types of data processed and the processing operations.

When, in the context of the orders placed, you provide us with the contact details of third parties for the collection of orders from French Revolution's work points or for delivery to the indicated address, you are responsible for properly and completely informing these persons about how their personal data will be processed by French Revolution and for communicating to them the content of this Policy, including informing them that this data is used for the purpose of processing your order and what rights they have under the law.

With regard to the processing of Personal Data indicated in this Privacy Policy, you, as a data subject, benefit from the following rights, in accordance with the applicable legal provisions:

• the right to information – the right to receive a minimum content of information regarding the processing activities carried out by French Revolution, described in this Privacy Policy;
• right of access to data – the right to request and receive confirmation from French Revolution regarding the processing of your Personal Data by us, and if so, access to that data and information related to aspects such as the purposes of the processing, the recipients of the data, the third countries to which this data may reach as well as the transfer guarantees (if applicable), the storage period, the source of the data (for data not collected directly from you, etc.);
• the right to rectification – the right to obtain rectification of your Personal Data when it is inaccurate, or to obtain completion when it is incomplete, including by providing an additional statement;
• the right to erasure of data (“the right to be forgotten”) – the right to obtain the erasure of Personal Data concerning you, without undue delay, in the following situations:
• French Revolution no longer needs your data;
• you have withdrawn your initial consent to the use of your data;
• you have objected to the processing of your data for marketing purposes or to processing based on our legitimate interest, and there are no overriding legitimate reasons in favor of the processing;
• French Revolution has a legal obligation to delete the data;
• the data was collected in connection with the provision of online services to a child pursuant to Article 8(1) of the GDPR.

However, French Revolution will not be able to comply with the deletion request in any of the following cases: processing is necessary for the exercise of the right to freedom of expression and information; compliance with a legal obligation or the performance of a task carried out in the public interest; for archiving purposes in the public interest or for statistical purposes; for the establishment, exercise or defence of legal claims.

• the right to restriction of processing – the right to obtain restriction of processing when:
• you have contested the accuracy of your data;
• the processing is unlawful and you oppose the deletion of your data;
• French Revolution no longer needs the data that is the subject of the request, but you ask us to retain it for the establishment, exercise or defense of a right in court;
• you have objected to the processing, during the verifications that French Revolution carries out regarding the prevalence of its own interests;
• the right to data portability , namely your right:
• to receive Personal Data in a structured, commonly used and easily readable format, as well as
• that this data be transmitted by French Revolution to another data controller, to the extent that the conditions provided by law are met;
• right to object – the right to object for reasons related to your particular situation, which you will bring to the attention of French Revolution when making the request; With regard to direct marketing activities, you have the right to object to this processing at any time;
• the right not to be subject to an automated individual decision that produces legal effects or similarly significantly affects you or to request human intervention where such decisions are permitted under the GDPR;
• the right to address the National Supervisory Authority for Personal Data Processing to exercise and defend any rights guaranteed by the relevant legislation, without prejudice to the possibility of addressing the competent courts;
• the right to withdraw your consent where processing is based on it. Withdrawing consent does not affect the lawfulness of processing carried out on the basis of consent before its withdrawal.

To exercise the rights mentioned above, but also for more information regarding the processing of Personal Data, you can write to us using the following contact details:

• Address: 1B Sergent Constantin Ghercu Street, Bucharest 060201, Romania
• E-mail: contact@frenchrevolution.ro
• Phone: 0755 222 800