This document (“Privacy Notice“) explains how we collect and process your personal data when you use or interact with our website, www.chilli-ideas.ro, (“Site”).

We, Chilli Ideas S.R.L., (“Chilli Ideas” or “We“) process your personal data as a data controller and treat confidentiality seriously in accordance with data protection legislation. Our registered office is registered at Str. Știrbei Vodă nr. 114-116, DOMUS II Building, 1st floor, sector 1, Bucharest. Chilli Ideas is registered with the Trade Registry Office under number J40/17352/2007, having the fiscal code fiscal code RO22418870.

Your opinion matters to us – if you have any questions or concerns regarding the information presented in this Information Note, you can write to us at privacy@chili-ideas.ro e-mail address or at: Str. Știrbei Vodă nr. 114-116, DOMUS II Building, 1st floor, sector 1, Bucharest.

WHO ARE WE ADDRESSING?

This Information Note targets the following categories of data subjects (collectively referred to as “Data Subjects“):

• representatives (legal or conventional) of clients, legal persons, as well as contact persons designated/authorised to act on their behalf (“Representatives”); We refer to Representatives of current clients, as well as those of potential or former clients of Chilli Ideas;
• clients of Chilli Ideas who wish to conclude or have concluded a contractual relationship with us and are natural persons who carry out their activity within a regulated profession (e.g. self-employed persons, liberal professions, etc.) (“Natural Persons Clients“);
• natural persons who (i) access and interact in any other way with the Site, without having the capacity of Representative, as well as (ii) Representatives when they access and use the Site on behalf of customers (“Users”). We will consider you to be a User also if you are a) an employee/collaborator of a customer or (b) a relative, relative or other natural person directly or indirectly related to the Representative who benefits from Chilli Ideas products and services as a result of contracting products and services by that customer, or c) any natural person browsing the Site or accessing or otherwise interacting with our professional pages on social media platforms.

WHAT ARE THE CATEGORIES OF DATA WE PROCESS?

Depending on how you interact with Us and our products and services, including the Site and Online Store, we may process the following categories of personal data:

• identification data, such as:
  • name, surname, form of address (gender), signature.
  • tax identification data and similar unique identifiers, for example, tax identification code or registration number with the Trade Register – in cases where you act as a Natural Person Customer.
• contact details, such as: home address, correspondence (business) address, e-mail, telephone;
• account data, such as: preferred and/or purchased products and services, information on company logos (Representatives).
• Authentication data, such as: username, control questions, suggestions, and similar security information used for authentication and account access;

• customer management data, such as (i) details of complaints made on personal behalf or on behalf of clients, (ii) records of your interaction with our customer service teams (e.g. recording a call or correspondence on our professional social media pages), (iii) requests to exercise rights with respect to your personal data,  (iv) any other records of your interactions; with us;
• data collected by cookies and other similar technologies. Details regarding data processing through such technologies can be found by accessing  the section Analysis of how to use the Site and the Online Store and online advertising adapted below:

We can obtain this data:

1. if you are  a Natural Person Customer, in order to conclude the service or sales contract with you;
2. if you are a Representative, when you provide us with this data or the client (including the Natural Person Client), on whose behalf you contract, transmits this data to us, respectively if you contact us to express your dissatisfaction with us;
3. if you are a User, whenever you browse our Site or interact with the Online Store, or if you contact us to express your interest in receiving communications regarding our products and services or also to send us various complaints or requests. 

When we receive data directly from you. We will consider them to be true, accurate, complete and relate to you. We will make reasonable efforts to ensure that the data is real, correct and belongs to you, and if we suspect that you are sending us incorrect, incomplete data or that you are using another person’s data without authorization, we will take steps to clarify and remedy the situation. These measures could consist of: updating, completing or deleting data, limiting access to illegally used data – including deleting accounts associated with data that do not belong to you.

We may also collect data from external sources, such as:

1. public sources, for example, third-party websites or social media platforms, public databases (including the Trade Register database, Ministry of Finance databases, etc.);
2. third party entities, for example, our partner suppliers or contractors, data brokers, or the client, a legal person, when you act as its Representative ;
3. public authorities or institutions, for example, in the context of litigations or requests of courts.

WHY DO WE PROCESS PERSONAL DATA?

1. If you are  a Natural Person Customer  and/or Representative, Chilli Ideas processes your personal data for the following purposes and grounds:
2. Purpose: Contracting Chilli Ideas products and services. Billing and payment processing

We process your personal data. personal information in the process of contracting Chilli Ideas products and / or services, respectively for placing, taking, validating, shipping and invoicing the placed order, informing you. on the status of the order, etc.

In certain situations generated by this contracting process, we may use your personal data. to contact you through various channels (e.g. telephone, e-mail, SMS) by virtue of being a Representative to communicate to you various aspects related to the status of the order or the contracted service.

Processing of your personal data personal clearance is required for this purpose. Refusal of Supply and Your Objection with regard to data processing, it may result in the impossibility of carrying out the contractual relations between customers and Chilli Ideas regarding the purchased services and products.

Legal bases:

1. a) conclusion and execution of the contract with the Natural Person Customer, respectively
2. b) our legitimate interests in the conclusion, optimal execution and efficient management of contracts with corporate customers.

• Purpose: Customer relationship support and management

We may use your personal data, contact information, account details and customer management data to contact you regarding any issues related to our business relationship with the customer, for example:

1. processing payments due by the customer or where we have been unable to collect payment for certain products and/or services;
2. informing about the amounts owed by the client, the due date, any additional payment amounts applied (late payment penalties) and / or other consequences caused by the client’s non-compliance with the contractual provisions; In this regard, in order to recover the damages suffered, we may use the data we hold about you. contact you periodically, appoint debt collection agencies on behalf of Chilli Ideas and/or assign claims owed to us by customers to third parties (in which case we may also provide those entities with your identification, account and contact details);
3. to meet your needs. and respond to any questions/requests made by you. on behalf of customers.

Legal basis: our legitimate interests, supported by commercial needs regarding the implementation and conduct of customer relationship management activities and those regarding the organization and conduct of debt collection activities.

• Purpose: Organization and optimization of Chilli Ideas activity and services

We analyze our services and products, as well as your interaction or experience. with these because we want to continuously improve our services and products.

We also use the personal data of Data Subjects to optimally organize and streamline our business and services. By way of example, data can be used:

1. to understand and evaluate the performance of the current offer in order to be able to develop and offer you new services and products;
2. managing investigations initiated by public authorities and defending the interests and rights of Chilli Ideas in various investigations, administrative and judicial proceedings, litigation, etc.;
3. to investigate fraud in the conduct of contractual relations;
4. for the organization of clients in internal databases and their management by internal structures and departments;
5. as a result of internal audits and/or investigations conducted by Chilli Ideas.

Legal basis:  our interest  consisting in our legitimate needs to analyze the performance and functionality of our services and how we can improve our services and products, as well as to defend our rights and interests in the context of fraud / customer disputes, as the case may be, to make information available to public authorities / courts or to keep certain data.

• Purpose: Commercial communications to customers

We will use your contact details to keep you informed about Chilli Ideas customer products and services. Thus, we may send you (i) newsletters or other similar materials, (ii) inform you about offers, promotions, contests, promotional sweepstakes or other similar marketing actions, and/or (iii) invite you to participate in our surveys or market studies, or when you provide us with feedback on our products and services. 

We will send you these communications using electronic mail (email address and/or SMS). We will design marketing campaigns in such a way as to avoid transmitting them excessively. If you do not wish to be contacted for this purpose, please let us know.

Legal basis: The processing of your data for this purpose is based on your consent, if you choose to provide it.]

• Purpose: Compliance with legal requirements

We process (including share) your personal data. personal information if necessary to comply with regulatory requirements (national or European Union level).

Legal grounds: (i) compliance with  legal obligations or (ii) our legitimate interest in addressing and managing the relevant legal requirements applicable to Chilli Ideas.

1. If you are  a User, Chilli Ideas processes your personal data for the following purposes and grounds:
2. Purpose: User account registration

We process your personal data. identification and authentication in order to provide you with access to the functionalities of our Online Store where you can purchase products and/or services on behalf of the customers who have appointed you and/or manage the customer’s activity regarding the relationship with Chilli Ideas (e.g. placing and paying orders, consulting order status, etc.).

Legal basis: conclusion and performance of the contract with you

• Purpose: Customer relationship support and management

We may use your personal data. identification and contact for:

1. Transmission to you messages regarding purchased services and products. These messages may rather be relevant to the customer on whose behalf you are acting (for example, changes to our terms and conditions) and thus may not be of interest to you; In this case, please disregard them.
2. To answer any questions and address any issues you may have with your account. by the User, the Site and/or the Online Store.

Legal basis: our legitimate interest in providing Users with relevant and up-to-date information about the products and services that customers purchase, as well as the proper implementation and conduct of customer relationship support and management (including Users designated by the customer).

• Purpose: Commercial communications to customers

We will use your contact details to keep you informed about Chilli Ideas customer products and services. Thus, we may send you (i) newsletters or other similar materials, (ii) inform you about offers, promotions, contests, promotional sweepstakes or other similar marketing actions, and/or (iii) invite you to participate in our surveys or market studies, or when you provide us with feedback on our products and services.

We will send you these communications using electronic mail (email address and/or SMS). We will design marketing campaigns in such a way as to avoid transmitting them excessively. If you do not wish to be contacted to receive information about our offers, please let us know.

Legal basis: The processing of your data for this purpose is based on your consent, if you choose to provide it.

• Purpose: Analysis of the  use of the Site and the Online Store and adapted online advertising

When you access or use our Site and/or Online Store, we collect through cookies and other similar technologies statistical and aggregated information, which cannot identify you individually, for the purpose of performing analyzes on their functionality and performance. We are directly interested in how you use the Site and the Online Store (e.g., frequently visited pages or the amount of time you spent on a particular section of the Site) to understand the needs of the customers you represent and provide them with a better experience in terms of interacting with these platforms.

We may also use the results of these analyses in combination with other tracking technologies to analyze your behavior and interests. online to serve you personalized advertising.

Legal bases: Depending on the categories of cookies, we rely on (i) our legitimate interest in ensuring that our services function properly with regard to so-called “necessary cookies”, or (ii) your consent to so-called   “analytics cookies” and “tailored online advertising”.

More details about the use of cookies can be found in our Cookies Policy.

TO WHOM DO WE DISCLOSE PERSONAL DATA?

We may disclose the personal data of Data Subjects, as appropriate, to:

1. Our clients with whom Data Subjects are related.
2. Support and/or auxiliary service providers, such as: survey or commercial communications services, data storage service providers, bailiffs and debt collection agencies, IT services (e.g. maintenance, support, development), audit services, archiving services, logistics, courier and transport services, legal services or other specialized consultancy services.
3. Public institutions and authorities in Romania, such as:

• courts and other judicial authorities;
• other relevant public authorities (e.g. ANAF, ANSPDCP).

1. Third parties, in the event of a merger, acquisition or other type of reorganization or sale.

TRANSFER OF DATA ABROAD

In general, personal data collected by us through the Site and the Online Store will not be transferred outside the European Economic Area (EEA).

If we transfer your personal data. personal data in a country that is not located in the EEA or for which the European Commission has not issued a decision certifying that that country has implemented adequate safeguards with respect to the protection of personal data, we will ensure that your personal data is safe. are adequately protected. As a rule, we will ensure that there is an appropriate agreement on the transfer of data, in accordance with standard contractual clauses approved by the European Commission (https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en).

If the transfer cannot be based on standard contractual clauses, we will take the necessary steps to ensure that the transfer is based on another mechanism provided by law to ensure the protection of your data. personal data, including, where applicable, we will ask for your consent to such transfer.

HOW LONG DO WE KEEP DATA SUBJECTS?

We keep the personal data of the Data Subjects as long as necessary to fulfill the purposes for which they were collected, in compliance with the applicable legal provisions in the field, as well as with the internal procedures regarding data retention.

If the legislation in force requires us to keep the data for longer periods, we will comply with the retention periods established according to the legal obligations (eg, in the case of financial-accounting supporting documents for which the retention period provided by law is 5 years from the end of the financial year during which they were drawn up).

Data related to cookies and similar technologies are kept according to specific terms established for those technologies, the storage term may be between the duration of the browsing session (for necessary cookies) and a duration of up to 3 years (for analysis / marketing cookies). More details about the storage duration of cookies can be found in our Cookies Policy.

If you withdraw your consent to data processing for marketing purposes, Chilli Ideas will cease processing your data. personal data for this purpose, without affecting the processing carried out on the basis of your consent. before its withdrawal.

WHAT ARE THE RIGHTS OF THE DATA SUBJECT?

According to the law, Data Subjects benefit from the following rights related to the processing of personal data:

• the right of access: respectively the right to obtain confirmation from Chilli Ideas regarding the processing of personal data, as well as details of processing activities such as: the way in which the data are processed, the purpose for which the processing is done, the recipients or categories of recipients of the data, etc.;
• the right to rectify data:  Data Subjects may ask us to amend incorrect data on Data Subjects or, as the case may be, to complete data that is incomplete; The rectification / completion will be communicated to each recipient to whom the data were transmitted, unless this proves impossible or involves disproportionate efforts
• the right to erasure: Data Subjects may request the erasure of their personal data when: (i) they are no longer necessary for the purposes for which we collected and process them; (ii) consent to the processing of personal data has been withdrawn and we can no longer process it on other legal grounds; (iii) personal data are processed contrary to the law; i.e. (iv) personal data must be deleted in accordance with the relevant legislation;
• withdrawal  of consent: Data Subjects may withdraw their consent to the processing of personal data processed on the basis of consent at any time;
• the right of opposition: Data Subjects may object at any time to processing for marketing purposes, as well as to processing based on the legitimate interest of CHILLI IDEAS, for reasons related to their specific situation;
• the right to restrict  processing: Data Subjects may request restriction of processing of their personal data if: (i) they contest the correctness of the personal data, for a period that allows us to verify the accuracy of the data in question; (ii) the processing is unlawful and the Data Subject opposes the erasure of the personal data, requesting instead the restriction of their use; (iii) the data are no longer necessary for our processing, but the Data Subject requests them for legal action; respectively (iv) if the Data Subject has objected to the processing, for the period of time during which it is verified whether the legitimate rights of Chilli Ideas as controller prevail over the rights of the Data Subject.
• the right not to be subject to an automatic individual decision: respectively the right not to be the subject of a decision taken solely on the basis of automatic processing activities, including profiling, which produces legal effects concerning your person or similarly affects you to a significant extent;
• the right to portability: Data Subjects may request, under the law, that we provide their personal data in a structured, frequently used and machine-readable form, when we process their data based on their consent / contract concluded with them. If Data Subjects request us to do so, we may transmit such data to another entity, if technically possible.
• the right to address the National Supervisory Authority for Personal Data Processing or the competent courts, to  the extent that you consider it necessary.

For any questions about this Information Note, or if Data Subjects wish to exercise their rights, we may be contacted as follows:

CHILLI IDEAS: Attn: Data Protection Officer CHILLI IDEAS (DPO)

Mailing Address: privacy@chili-ideas.ro