GDPR

Privacy Policy for the Processing of Personal Data

We see ensuring the right to data protection as a fundamental commitment at Indira, dedicating all 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 any other applicable national legislation in Romania. As transparency is a key principle of this legal framework, we have prepared this document to inform you about how we collect, use, transfer, and protect your personal data when you interact with us regarding our products and services, including through our website or mobile applications.

We reserve the right to update and change this Privacy Policy periodically to reflect any changes to how we process your personal data or changes to legal requirements. In case of any such changes, we will display the amended version of the Privacy Policy on our website, so please check the content of this Privacy Policy periodically.

Who we are and how to contact us

Indira is the trade name of Indira Art Distribution S.R.L., a legal entity of Romanian nationality, with registered office at Bucharest, Sf. Vineri 23, bl. 105B, sc. B, fl. 6, apt. 51, registered in the Trade Register under number J40/10658/2016, VAT number RO36408630 (hereinafter “INDIRA” or “we”). In the context of data protection legislation, we act as data controllers when processing your personal data.

We are always open to hearing your opinions and providing you with any additional information you may need regarding your data processing, and we encourage you to contact the Indira Data Protection Officer at data.protection@indira.ro or by mail or courier at Sf. Vineri 23, bl. 105B, sc. B, fl. 6, apt. 51, Bucharest, mentioning: for the attention of the Indira Data Protection Officer.

What categories of personal data we process

Generally, we collect your personal data directly from you, giving you control over the type of information you provide us. For example, we receive information from you like this:

When you create an Indira account, you provide us with: email address, first and last name;

In your personal page (My Account) on the Indira platform, you can add additional information such as: mobile phone number, landline number, date of birth, shipping addresses, etc.;

When placing an order, you provide us with details such as: desired product, full name, shipping address, billing details, payment method, phone number, etc.

We offer you the possibility to register on the Indira platform through your Facebook or Google account. If you choose 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 Indira. You can refer to the privacy policies of Facebook and Google with these links:

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

https://policies.google.com/privacy

We may also collect and later process certain information regarding your behavior during your visit to our website or use of the smartphone application to personalize your online experience and provide tailored offers to your profile. We invite you to learn more in the section below regarding processing purposes.

We can store and collect information in cookies and similar technologies on our website and smartphone application, according to the Cookie Policy.

We do not collect or process sensitive data, categorized by the General Data Protection Regulation as special categories of personal data. Additionally, we do not wish to collect or process data from minors under 16 years of age.

What are the purposes and grounds of processing

We will use your personal data for the following purposes:

1. To provide Indira services for your benefit

This general purpose can include, as applicable, the following:

a) Creating and managing accounts on the Indira platform;

b) Processing orders, including taking, validating, shipping, and billing them;

c) Resolving cancellations or any issues regarding an order, goods, or services purchased;

d) Product return according to legal provisions;

e) Refunding the value of products per legal provisions;

f) Providing support services, including responding to your questions about your orders or Indira goods and services.

Processing your data for these purposes is most often necessary for the conclusion and execution of a contract between Indira and you. Additionally, certain processing activities within these purposes are required by applicable legislation, including fiscal and accounting legislation.

1. To improve our services

We continually aim to offer you the best online shopping experience. To do this, we may collect and use certain information about your shopper behavior, invite you to complete satisfaction surveys following an order, or conduct, directly or with partners, market research studies.

We base these activities on our legitimate interest in conducting commercial activities while always ensuring that your fundamental rights and freedoms are not affected.

2. For marketing

We want to keep you updated on the best offers for the products/services that interest you. Accordingly, we can send you any type of message (such as email/SMS/telephone/mobile push/web push/etc.) containing general and thematic information, information on products similar or complementary to those you have purchased, information about offers or promotions, information on products added to the “Account/My Cart” or “Account/Favorites” sections, or that you have shown interest in purchasing, as well as other commercial communications such as market research and opinion polls, and we may display personalized recommendations on the website and in the smartphone application. To provide you with information of interest to you, we may use certain data about your shopper behavior (e.g., products viewed/added to wishlist/purchased) to create a profile. We always ensure that such processing is done with respect for your rights and freedoms and that decisions based thereon have no legal effects on you and do not similarly affect you significantly.

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:

– Changing your account settings in the “My Subscriptions” section;

– Accessing the unsubscribe link displayed in the messages you receive from us; or by

– Contacting Indira using the contact details above.

In certain situations, we may base our marketing activities on our legitimate interest in promoting and developing our commercial activities. In any situation where we use information about you for our legitimate interest, we care and take all necessary measures to ensure that your fundamental rights and freedoms are not affected. Still, you can always request us to stop processing your data for marketing purposes using the means described above, and we will fulfill your request.

1. To defend our legitimate interests

There may be situations where we may use or transmit information to protect our rights and commercial activity. These may include:

– Website and platform protection measures against cyber attacks;

– Prevention and detection of fraud attempts, including sending information to competent public authorities;

– Measures for managing various other risks.

The general basis of these types of processing activities is our legitimate interest in defending our commercial activity, ensuring that all the 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 safeguard goods and values as stipulated by applicable legislation in this area.

How long do we keep your personal data

As a general rule, we will store your personal data as long as you have an account on the Indira platform. You can request the deletion of certain information or close your account at any time, and we will comply with these requests, subject to retaining certain information even after closing the account in situations where applicable legislation or our legitimate interests require it.

To whom do we transmit your personal data

Depending on the case, we may transmit or provide access to certain personal data of yours to the following categories of recipients:

– courier service providers;

– payment/banking service providers;

– marketing/telemarketing service providers;

– market research service providers;

– insurance companies;

– IT service providers;

– other companies with which we can develop joint programs to offer our goods and services to the market.

If we are required by law or if 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-party legal entities is carried out in accordance with the legal provisions for data protection and confidentiality based on agreements signed with them.

In which countries do we transfer your personal data

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

However, it is possible to transfer certain personal data outside the European Union, including countries not recognized by the European Commission as having an adequate level of data protection.

We will always take measures to ensure that any international personal data transfer is carefully managed to protect your rights and interests. Transfers to service providers and other third parties will always be protected by contractual commitments and, where applicable, by other safeguards such as the standard contractual clauses issued by the European Commission or certification schemes such as the Privacy Shield for protection of personal data transferred from within the EU to the United States of America.

You can contact us at any time, using the contact details above, to find out more about the countries where we transfer your data, as well as the safeguards we have applied concerning these transfers.

How we protect the security of your personal data

We commit to ensuring the security of personal data through implementing technical and organizational measures, according to industry standards.

Your personal data transmission is done using state-of-the-art encryption algorithms, and we store them on secured servers, ensuring data redundancy.

We use MobilPay for payments. Any payment information is encrypted using HTTPS technology with TSL 1.2 encryption.

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

What are your rights

The General Data Protection Regulation recognizes a series of rights related to your personal data. You can request access to your data, correct any mistakes in our files, and/or oppose the processing of your personal data. You can also exercise your right to complain to the competent supervisory authority or address the court. As the case may be, you can 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.

To exercise your rights, you can contact us using the contact details above. Please note the following if you wish to exercise these rights:

Identity. We take the confidentiality of all records containing personal data very seriously. For this reason, please send your requests regarding such records using the email address associated with your Indira account. Otherwise, we reserve the right to verify your identity by requesting additional information to verify your identity.

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

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

Third-party rights. We should not comply with a request where it negatively affects the rights and freedoms of other data subjects.

Data Subject Rights	Description
Access	You can ask us to: confirm whether we are processing your personal data; provide you with a copy of this data; provide other information about your personal data, such as the data we have, how we use it, whom we disclose it to, whether we transfer it abroad, and how we protect it, how long we keep it, what rights you have, how to file a complaint, and where we obtained your data, to the extent that these were not already provided to you in this notice.
Rectification	You can ask us to rectify or complete your inaccurate or incomplete personal data. We may try 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 (if data processing is based on consent); or you exercise a legal right to object; or the data has been processed unlawfully; or a legal obligation applies. We are not obliged to comply with your request to delete your personal data if its processing is necessary for: compliance with a legal obligation; or the establishment, exercise, or defense of a legal claim. There are certain other circumstances where we are not obliged to comply with your request. Before exercising this right, download and save all documents related to orders made at Indira from your account, regardless of whether billing was done to you or another individual or legal entity (such as invoices, warranties). If you do not take these steps before exercising your deletion right, you will lose all these documents as the process of deleting data, the Indira account, and all related data and documents is irreversible.
Restriction of Processing	You can ask us to restrict the processing of your personal data, but only if: their accuracy is disputed (see the rectification section) to allow us to verify their accuracy; or the processing is unlawful, but you do not want the data deleted; or it is no longer necessary for the purposes for which it was collected, but you need it to establish, exercise, or defend a legal right; or you exercised your right to object, and verification if our rights prevail is ongoing. We can continue to use your personal data following a restriction request if: we have your consent; or to establish, exercise, or ensure a legal right defense; or to protect Indira's or another individual's or legal entity's rights.
Data Portability	You can ask us to provide your personal data in a structured, commonly used, and machine-readable format, or you can 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 execution of a contract with you; and the processing is carried out by automated means.
Objection	You can oppose, at any time, reasons related to your particular situation, the processing of your personal data based on our legitimate interest if you consider that your fundamental rights and freedoms prevail over this interest. You can also oppose, at any time, the processing of your data for direct marketing purposes (including profile creation) without providing a reason, in which case we will cease this processing as soon as possible.
Automated Decision Making	You can request not to be subject to a decision based solely on automated processing, but only when the respective decision: produces legal effects with regard to you; or similarly affects you significantly. This right does not apply if the decision resulting from automated decision-making: is necessary for entering into or performing a contract with you; is authorized by law with adequate safeguards for your rights and freedoms; or is based on your explicit consent.
Complaints	You have the right to file a complaint with the supervisory authority regarding the processing of your personal data. In Romania, the supervisory authority's contact details for data protection are: National Supervisory Authority for the Processing of Personal Data B-dul G-ral. Gheorghe Magheru nr. 28-30, Sector 1, postal code 010336, Bucharest, Romania Phone: +40.318.059.211 or +40.318.059.212; Email: anspdcp@dataprotection.roWithout affecting your right to contact the supervisory authority at any time, please contact us beforehand, and we promise to make every effort to resolve any issue amicably.

• We remind you that you can contact the Indira Data Protection Officer at any time by submitting your request via any of the following methods:

– by email at:  data.protection@indira.ro or

– by mail or courier to: Str. Sf. Vineri 23, bl. 105B, sc.B, fl. 6, apt. 51, Bucharest – mentioning for the attention of the Indira Data Protection Officer.