Personal data

Policy for collection and protection of personal data from 

Twiggy Shop

 

We consider guaranteeing the right to the protection of personal data to be a fundamental commitment of Twiggy Shop, therefore we will use and invest all necessary means and efforts to process your data in full compliance with Regulation (EU) 2016/679 ("The EU General Data Protection Regulation" or "GDPR") and any other applicable Romanian legislation.

As one of the main principles of this legal framework is transparency, we have prepared this document to let you know how we collect, use, transfer and protect your personal data when you interact with us in relation to products and services, including through our website.

We reserve the right to periodically update and amend this Privacy Policy to reflect any changes to the way we process your personal data or changes to your legal requirements. In case of such changes, we publish the amended version of the Privacy Policy on our website and therefore, we kindly ask you to check its contents periodically.

 

 Who are we and how to contact us?

Twiggy Shop  is the trade name of "Twiggy Shop International" S. L. R. "Twiggy Shop International S.L.R" Romanian legal entity with registered office: Bucharest, Splaiul Independentei, N 273, corp 3, etaj 3 (6 - district), registered in the Commercial Register with number J40/32/03.01.2019, and EIC 40366710 (called below Twiggy Shop or we)

For the purposes of data protection legislation, we are the controller in the processing of your personal data.

As your opinions are always important to us and we are always ready to provide you with additional information that you may need in relation to the processing of your data, we encourage you to contact the Data Protection Officer by e-mail with address data.protection@twiggyshop.bg or by regular mail or courier to an address Bucharest, Sector 6, Splaiul Independentei, N 273, building 3, floor 3 – by writing the following text: to the attention of Twiggy Shop International's data protection officer.

 

Which categories of personal data do we process?

In general, we collect your personal data directly from you, so you decide what kind of information you provide to us. For example, the information we receive from you is as follows:

      • When you create an account in Twiggy Shop, you send us your e-mail address, first name, patronymic and surname;
      • You can also add additional information to your personal page (my account) from the Twiggy Shop platform such as: photo, gender, nickname, mobile phone number, landline phone number, date of birth, education, delivery address, additional email address, dates on bank cards, etc.;
      • When you place an order, you provide us with the following information: the product you want, first and last name, delivery address, billing data, payment method, phone number, dates on bank cards, etc.

In addition, we may collect and subsequently process certain information about your behavior when browsing our website or using a mobile application in order to personalize your online experience and prepare offers that are tailored to your profile. We invite you to learn more in this regard by reading the section on processing below.

On our website and mobile application, we may store and collect information using cookies and similar technologies in accordance with the Cookie Policy.

We do not collect or otherwise process sensitive data included in special categories of personal data in the General Data Protection Regulation. Furthermore, we 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:

      • Provision of Twiggy Shop services for your benefit

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

      • creating and managing a profile on the Twiggy Shop platform;
      • order processing, including acceptance, validation, dispatch and invoicing of the same;
      • resolve issues related to order cancellations or any other issues related to orders, goods or services purchased;
      • return the products in accordance with the legal provisions;
      • refund of the value of the products according to legal provisions;
      • support, including answering your questions in relation to your orders or the goods and services of Twiggy Shop or the marketplace sellers on the Twiggy Shop online platform;

The processing of your data for these purposes is in most cases necessary for the conclusion and performance of a contract between Twiggy Shop and you. In addition, the fulfillment of these purposes requires processing according to applicable law, including tax and accounting law.

      • Improving our services

We would like to always offer you the best online shopping experience. For this purpose, we may use certain information about your purchasing behavior, invite you to complete surveys about your satisfaction after completing an order, or conduct directly or with the help of partners, market surveys and research.

We base these activities on our legitimate interests in performing business activities, always ensuring that your fundamental rights and freedoms are unaffected.

      • Marketing

We would like you to always be aware of the best offers for the products/services you are interested in. In this regard, we may send you all kinds of messages, using electronic message channels (e-mail / SMS / mobile push / webpush, etc.), which contain general and thematic information, information about similar products or products complementary to those purchased from you products, information about offers and promotions, information about products added to "My Profile/My Cart" sections or if you have expressed interest in purchasing them, and other business communications such as market research and consumer opinion surveys, and we may present personalized recommendations on the website and mobile app. In order to provide you with information of interest to you, we may use certain data about your purchasing behavior (for example, products viewed / products added to wishlist / products purchased) to create a profile. We always ensure that this processing is carried out in compliance with your rights and freedoms and that the decisions taken in relation to them do not give rise to any legal consequences for you and do not similarly affect you to a significant extent.

In most cases, we require your prior consent to send you marketing communications. You can change your mind and withdraw your consent at any time by:

      • change the settings in the client profile in tab
        "My personal data";
      • use the "Unsubscribe" link in communications you receive from us; or like
      • contact Twiggy Shop using the contact details above.

In certain situations, we may base our marketing activities on our legitimate interest in promoting and developing our business. In any case where we use your information for our legitimate interests, we take care and take the necessary measures to ensure that your fundamental rights and freedoms are not affected. However, you may at any time, using the means described above, terminate the processing of your personal data for marketing purposes and we will respond to your request.

      • Protection of our legitimate interests

There may be instances where we use or disclose information to protect our rights and our business. These may include:

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

The main reason for these types of processing is our legitimate interests related to the protection of our commercial activity, with the proviso that we ensure that all measures taken by us ensure a balance between our interests and your fundamental rights and freedoms.

In addition, in some cases, our processing is based on legal provisions such as the obligation to protect goods and values provided by applicable legislation in this regard.

How long do we keep your personal data?

As a rule, we store your personal data for as long as you have a Twiggy Shop account. You may always request that we delete certain information or close your account, and we will respond to that request by retaining certain information, even after the account is closed, when applicable law or legitimate interests require us to do so. 

To whom do we send your personal data?

Depending on the case, we may transfer or give access to some of your personal data to the following categories of recipients:

      • companies from the group of companies to which Twiggy Shop belongs;
      • courier service providers;
      • payment/banking service providers;
      • marketing/telemarketing service providers;
      • providers of market research services;
      • IT service providers;
      • other companies with whom we may develop joint programs to market our goods and services.

If we are required by law, or if this is necessary to protect our legitimate interests, we may also disclose certain personal data to public authorities.

We guarantee that access to your data by third-party private legal entities takes place in accordance with the legal provisions in the field of data protection and information confidentiality, based on contracts concluded with them.

 

To which countries do we transfer your personal data?

 

We currently store and process your personal data in Romania.

However, it is possible that some of your personal data may be transferred to entities located in the European Union or outside it, including countries for which the European Commission has not recognized an adequate level of personal data protection.

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

You can contact us at any time using the contact details provided above to find out which countries we transfer your data to and what safeguards we apply in relation to these data transfers.

 

How do 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 compliance with industry standards.

We store your data on secure servers using the latest encryption algorithms and guarantee the storage of backup copies.

We use the payment processing service PayMill to process the payments. All payment information is encrypted using SSL technology.

Despite the measures we implement to protect your personal data, we are aware that in general the transmission of information over the Internet or other public networks is not completely secure, and there is a risk that the data can be viewed and used by unauthorized third parties. We cannot accept responsibility for these vulnerabilities of systems that are not under our control.

 

What are your rights?

 

The General Data Protection Regulation recognizes a number of rights in relation to your personal data. You can request access to your data, the correction of errors in our files, and/or raise objections regarding the processing of your personal data. You can also exercise your right to file a complaint with the competent supervisory authority or the court. Depending on the case, you may also have 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.

You can get more information about each of these rights by looking at the table below.

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

Identity. We take the privacy of all records containing personal data seriously. For this reason, we ask that you send us your requests regarding these records using your e-mail address listed in your Twiggy Shop account. Otherwise, we reserve the right to verify your identity by requesting additional information to verify it.

Taxis. We will not charge a fee for exercising any rights in relation to your personal data, except where your request for access to information is unfounded, repeated or unnecessarily repetitive, in which case we will charge a reasonable amount. We will inform you of any applicable fees before we consider your request.

Deadline for response. We plan to respond to all valid requests within one month, unless the request is particularly complex, or if 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 one month. We may ask you to tell us exactly what you wish to receive or what you are concerned about. This way you will help us act faster and shorten the time to respond to your request.

Third party rights. We will not need to respond to a request if it adversely affects the rights and freedoms of other data subjects.

 

Complaints

 

You have the right to lodge a complaint with your local supervisory authority regarding the processing of your personal data. In Romania, the contact details for the data protection supervisory authority are as follows:

National Supervisory Authority for the Processing of Personal Data

B-dul G-ral. Gheorghe Magheru no. 28-30, 1st district, postal code 010336, Bucharest, Romania

Phone: +40.318.059.211 or +40.318.059.212;

Email: anspdcp@dataprotection.ro

Without prejudice to your right to contact the supervisor at any time, please contact us in advance and we promise you that we will do our best to resolve your issues amicably.

  

Automatic decision making

 

You may ask us not to be subject to a decision based solely on automated processing, but only where that decision:

      • gives rise to legal consequences for you; or
      • It affects you similarly and significantly.

This right is inapplicable if the decision made after the automatic decision:

      • we need it in order to enter into or perform a contract with you;
      • is permitted by law and there are adequate guarantees for your rights and freedoms; or
      • is based on your express consent.

 

Right to object 

 

You can object at any time for reasons related to your specific situation to the processing of your personal data based on our legitimate interests, if you consider that your fundamental rights and freedoms dominate these interests.

 

In addition, you can object at any time to the processing of your data for direct marketing purposes (including the creation of profiles) without giving any reason, in which case the processing will be terminated as soon as possible.

 

Restriction of data processing

 

You can ask us to restrict the processing of your personal data, but only if:

 

      • their accuracy is disputed (see the data rectification section) so that we can verify their 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 we still need them to establish, exercise or defend a legal claim; or
      • You have already exercised the right to object and are checking whether the dominance of our rights still exists.

We may continue to use your personal data as a result of a restriction request:

      • if we have your consent; or
      • to establish, exercise or defend a legal claim; or
      • to protect the rights of Twiggy Shop or any other natural or legal person.

 

Delete data

 

You can submit a request for deletion of personal data using the link below:

 

Repair

You can submit a request to edit your personal data using the link below:

  

Access

You can check your personal data using the link below:

 

We remind you that you can contact the Twiggy Shop Privacy Officer at any time by sending your request to him in one of the following ways:

    • by e-mail to: data.protection@twiggyshop.bg or
    • by regular mail or courier to:  Bucuresti, Sector 6, Splaiul Independentei, N 273, corp 3, etaj 3 – by typing the text to the attention of Twiggy Shop's Privacy Officer .