PRIVACY POLICY
Thank you for your interest in our company, website, services, and/or products.
When you decide to establish a relationship with us and use the services of our company (hereinafter referred to as Reconnection SRL, the company name Reconnection SRL will be mentioned), you entrust us with information about yourself, referred to as personal data, and we thank you for your trust. The protection and confidentiality of personal data is a very important matter for us, and we strive to store it securely and process it carefully. To this end, we explain our data privacy practices clearly and transparently.
This information is presented in this document (hereinafter referred to as the “Privacy Policy,” “This Document,” or “The Document“), and we kindly ask you to read it alongside the Terms and Conditions section (which you can find here).
Our Privacy Policy aims to inform you about the processing of your personal data in connection with your visit to our website/platform (hereinafter referred to as the “site” or “platform”) and your use of any additional services offered by Reconnection SRL.
By visiting the site, purchasing our products and/or services, or interacting with us through any means, you declare that you agree with the Privacy Policy. If you do not agree with the terms described in this document, please refrain from using our services.
We inform you that Reconnection SRL acts as a personal data controller within the meaning of the GDPR for the processing of personal data.
| 1. Definitions |
Personal Data – means any information relating to an identified or identifiable natural person (“data subject”). An identifiable natural person is one who can be identified, directly or indirectly, particularly by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more specific factors relating to their physical, physiological, genetic, mental, economic, cultural, or social identity.
Processing – means any operation or set of operations performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.
GDPR (General Data Protection Regulation) or RGPD (General Data Protection Regulation) or the Regulation – refers to REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016 on the protection of natural persons regarding the processing of personal data and on the free movement of such data, repealing Directive 95/46/EC.
The Controller or The Company or We – refers to Reconnection SRL, a Romanian company with its registered office at 17-21 Fabrica de Chibrituri Street, building C2, apartment 58, registered in the Trade Register under no. J40/11284/2024, with tax identification number 50195502.
Data Subject – represents any identified or identifiable natural person whose data is processed by us as the controller, such as users, clients, potential clients, or visitors to the site.
Consent – means any freely given, specific, informed, and unambiguous indication of the data subject’s wishes by which they, by a statement or by a clear affirmative action, signify agreement to the processing of personal data relating to them.
Anonymization – means the irreversible removal of the identification of personal data, so that the individual cannot be identified using reasonable time, cost, and technology, whether by the Controller or by any other person. The principles of personal data processing do not apply to anonymized data, as it no longer qualifies as personal data.
| 2. Who are we? |
Below you can find our identification details:
| Name | RECONNECTION SRL |
| Registered Office | FABRICA DE CHIBRITURI 17-21 CORP C2 AP 58 |
| Trade Register Number | J40/11284/2024 |
| Tax Identification Code | 50195502 |
| contact@pellegrinoaida.com | |
| Phone | +974 50106378 |
In accordance with applicable legislation, our company is a personal data controller, and to ensure your data is processed securely, we make every effort to implement reasonable and appropriate technical and organizational measures to protect your personal data.
| 3. Who are you? |
According to legislation, you, as the natural person benefiting from our services/products, the representative or contact person of a company that is our client or potential client, a visitor to our website, or a person in any kind of relationship with us, are considered a “data subject,” meaning an identified or identifiable natural person. To ensure complete transparency regarding data processing and to allow you to easily exercise your rights at any time, we have implemented measures to facilitate the exercise of these rights.
| 4. Other services |
This Privacy Policy does not cover applications and websites of other third parties that you may access via links on our website. We encourage you to review the Privacy Policy of any site and/or application before providing personal data.
We are also not responsible for any links from our business partners or advertisers featured in our podcasts or articles, including those on our social media profiles. When you click on those links, third parties may collect or share your data.
Please note that we do not control any links posted on the site, whether by us or other users (for example, links left in comments, videos, community sections, social media, etc.), and you are fully responsible for accessing such links, accepting any potential damages (direct or indirect) that may result.
| 5. Complaints |
For any issues or concerns regarding the processing of personal data, please note that you have the right to file a complaint with the personal data supervisory authority. However, we kindly ask that you first send us a request at the address mentioned in this document, and we will make every effort to resolve your request amicably and as quickly as possible.
For Romania, the contact details are as follows:
| Name | The National Authority for the Supervision of Personal Data Processing |
| Adress | B-dul G-ral. Gheorghe Magheru nr. 28-30, Sector 1, postal code 010336, Bucharest, Romania |
| Phonr | +40.318.059.211 or +40.318.059.212 |
| anspdcp@dataprotection.ro |
| 6. The Purpose of the Privacy Policy |
The purpose of this Privacy Policy is to explain what information we process (collect, use, share), why we process it, how we process it, your rights under GDPR, and how you can update, manage, export, and delete your data. In this regard, we act as a data controller and are legally required to provide you with this information.
Please note that this Privacy Policy applies wherever you find us online.
| 7.Processing and Types of Personal Data. Rights of Visitors/Registered Users/Clients |
Personal data or personal information refers to any information about an individual that can help identify that person, excluding data where the identity has been removed (anonymized data).
When you browse our website, use our services/products, or contact us for any purpose through any communication channel, you may provide us with your personal data. It may be necessary for us to collect, use, store, or transfer certain personal data, either directly from you or from other sources.
7.1. Processing of Personal Data
In the case of an online order, Reconnection SRL will process the personal data provided by the user during account creation and/or order placement in the data registration form to complete the specific order through our website. Each user of the website www.pellegrinoaida.com has two options for completing an online order and providing their personal data:
a) As a guest visitor. In this case, the user’s personal data will be retained in Reconnection SRL’s archives for ninety (90) days from the delivery or completion of the respective order. The processing will be exclusively for the purpose of executing the remote sales contract. However, information that proves the transaction will be retained for tax purposes (billing document), and the user’s contact details may be used by the Company for commercial advertising purposes, unless the user has opted out of receiving such communications.
b) As a registered user. Once a year, Reconnection SRL will request that the registered user confirm the accuracy of their stored data and update it if there are any changes. The registered user can modify or correct their data at any time by logging into their account at www.pellegrinoaida.com (login) with their username and password.
7.2. Types of Personal Data and Purpose of Processing
Specifically, the personal data that each user must provide (either as a guest visitor or a registered user) to perform any transaction through our website and place orders for products include the following:
- Full name of the individual;
- Product delivery address;
- Billing address for the order (if different from the delivery address);
- Complete billing details, such as name, profession, tax authority, and a tax identification number (if the issuance of a commercial tax invoice is selected);
- Phone number;
- Email address.
In addition to the above, Reconnection SRL collects and stores the following personal data exclusively for registered users:
- Order history;
- Date of the last login;
- Products in the shopping cart or wishlist;
- Participation in promotions.
The credit card details used by the visitor or registered user are not stored on the storage channels of Reconnection SRL during the transaction but are recorded directly in a secure environment of the partner company responsible for card operations.
The registered user is also informed that for communications between Reconnection SRL and the user, in the context of Law No. 365 of June 7, 2002, on electronic commerce, the contact details provided by the user are processed.
Additionally, when registered users receive notifications via SMS, email, etc., about changes to the terms of use of the portal www.pellegrinoaida.com containing a hyperlink, the IP address of their electronic device (mobile phone, tablet, computer, etc.) may be recorded to prove that the registered user has received the notification.
The primary purpose of data processing is to execute the contract and complete the specific order, communicate with the registered user, send informational messages regarding the order processing stages, provide clarifications related to the order, and generally supply information about purchases made, deliver the order to the location chosen by the registered user, confirm and identify the registered user when necessary, and provide updates on the order status.
The registered user is informed that providing the above personal data and mandatory processing data is necessary and constitutes a prerequisite for the proper execution of the order and delivery of products and services. For this reason, consent is not required for this specific processing.
Each registered user who uses www.pellegrinoaida.com is informed that their personal data related to the receipt, execution, and delivery of an order, as well as inquiries regarding purchases, products, and services of Reconnection SRL and orders placed on www.pellegrinoaida.com, will be processed to serve users – clients, both by the competent employees of Reconnection SRL and by third-party recipients and/or processors on behalf of Reconnection SRL in the context of fulfilling an order. These third-party recipients include shipping companies, individual or group courier services, internet and e-commerce service providers, and call centers for customer service, with whom Reconnection SRL collaborates. These entities are subject to specific, strict data processing conditions agreed upon with Reconnection SRL as the data controller. Reconnection SRL requires its employees, website maintenance operators, and third-party partners to take all necessary technical and organizational measures (including policies and procedures to prevent the disclosure of personal data of visitors/registered users – clients that they process and hold). They must also implement personal data management and processing procedures in a lawful manner that ensures data protection in compliance with GDPR.
No further processing or transmission of information regarding visitors/registered users on the website www.pellegrinoaida.com will take place unless prior notification and full consent have been provided, where necessary.
| 8. How We Process Personal Data |
8.1. Account Creation
The account created on www.pellegrinoaida.com serves as a control panel, allowing you to centralize information about your purchases and preferences.
Astfel, contul creat vă oferă posibilitatea de a urmări progresul comenzii dvs., de a consulta istoricul achizițiilor, etc.
The account provides the ability to track the progress of your orders, view purchase history, and more. It also allows you to set your preferences for our marketing communications (personalized offers and communications about discounts, products, services, events we participate in, and product review requests).
Additionally, for certain functionalities on the www.pellegrinoaida.com account, you may be asked for location details. You can choose whether to allow or deny the use of these features. We will not have access to your location, as this data is stored locally on your device. If you choose to enable this feature, you can deactivate it at any time in your device settings.
We may also process certain data from your account for developing new functionalities or ensuring the accuracy and security of your data.
Creating an account is necessary to place orders on www.pellegrinoaida.com.
To create an account, we will process your email address and the password you choose. In some cases, we may also process your country of origin. If you choose to create your account on our site by linking it to your Facebook/Google/Apple account, we will collect the necessary data from these providers: name, surname, and email address.
Additionally, if you update your information on our website, we may process the following information about you: name, surname, phone number, date of birth, gender, delivery address, billing address, purchase history, or other information you may enter into your account.
8.2. Reviews
We value your opinion about our products, services, and website/platform, as it helps us improve the quality of what we offer.
When you leave reviews on our site, we process your name, surname, email address, duration of product use, ratings given for products or services, and the content of your review. Gender and age are optional, and you can share your opinions without providing this information. The purpose of processing your personal data is to manage and publish your reviews on our website or platform.
8.3. Managing Marketing Communications
We place great importance on the marketing messages we send you. Our marketing communications may include information about products, services, offers, discounts, events on our site, collecting feedback, or requesting opinions and reviews about our products and services.
8.4. Customer Service
To assist you with resolving any issues that may arise and to answer your questions, you can contact us via various channels such as phone, email, Facebook Messenger, Instagram, WhatsApp, etc.
To manage phone calls and messages, as well as to gather your opinions about our products and services, we will process certain data about you. Depending on the nature of your request, this data may be shared with other internal departments or partners.
For this purpose, we may process the necessary data to manage your call or message: name, surname, email address, phone number, and the content of the call or message, such as the delivery address or order number. We may also process your data by recording phone conversations to improve the quality of our services and for evidentiary purposes. Additionally, we may have access to your profile image from the public accounts you use to contact us (e.g., Facebook, Instagram). You are not required to provide us with your personal data, but without it, we may not be able to handle your request.
8.5. Statistical Purposes
In certain situations, we may use your personal data collected for the purposes outlined above for statistical or scientific research purposes. Statistical information is not considered personal data because it does not allow the identification of individuals.
The statistical information obtained (e.g., in the form of charts) will contain anonymous data. This means we will not be able to associate the statistical information with you or any other individual. Since the statistical information obtained does not contain personal data, it may be stored for an indefinite period.
Please note that processing your data for statistical purposes does not mean we will no longer be able to identify you in connection with other activities involving the processing of your data. We will continue to process your personal data according to the purposes outlined above. For example, we will still retain information about you if you have a customer account on www.pellegrinoaida.com or if you have submitted a product review.
8.5.Processing of Data on Social Media
This Privacy Policy applies to our website/platform, official Facebook, Instagram, TikTok pages, and other official pages managed by us.
We inform you that we are the administrators of the official pages and communities of Aida Pellegrino, Aida Pellegrino – Femininity Mentor, @pellegrino_aida, and we are responsible for your personal data processed through these pages. At the same time, Facebook is responsible for certain aspects of your personal data, such as the transfer of data to other countries.
In some cases, we share responsibilities with Facebook regarding your data and act as joint controllers (e.g., statistical data provided to us by Facebook, collected as a result of your interactions with our pages).
8.5.1. What Personal Data Do We Process?
a) When visiting our pages (Aida Pellegrino, Aida Pellegrino – Femininity Mentor, @pellegrino_aida), we may process the following data:
- If you like, share, or comment on our posts, we can access your public profile (name, surname, photos, and other public profile details), as well as the content of your comment.
- If you send us a private message, we can access your public profile and the content of the message you sent. For example, we may request your phone number or email address in private to manage your request or validate contest winners.
- If you are tagged by a friend in a post for a contest/raffle organized on one of our pages, we will have access to your name, surname, and public profile.
b) Content Sharing
Typically, Instagram Stories published on our page are automatically shared on our official Facebook page. Additionally, we may share content from partner pages (e.g., influencers or companies) or from followers’ pages on our own pages. For example, we might share a Story in which we are tagged by an influencer or follower, share a post by an influencer or partner where you commented, were tagged, or where your image/voice appears, or repost/share one of your posts where your image/voice and public profile appear.
c) General Statistics
When Facebook/Instagram users interact with our pages, Facebook provides us with general statistics about user actions. For example, the number of page views, clicks on a post, or interactions with page content (likes, shares, comments, etc.). These statistics are anonymized, and we cannot identify you based on this data.
d) Personalized Advertising Campaigns.
When customizing advertising campaigns on Facebook/Instagram, we define interest categories that may include you. Facebook uses predefined categories of individuals and shows our ads to people within the indicated category.
We process your data for the purpose of promoting our brand, products, services, or certain public events or charitable actions in which we participate as an organizer or partner, to respond to public or private messages, to analyze statistics about our page audience, and to customize the audience of posts or advertising campaigns.
We mention that providing this data is not mandatory; however, Facebook or other social media providers operate uniformly for all pages and users. Therefore, if you interact with our pages, we will automatically have access to certain data about you, as described above.
| 9. Retention Period for Personal Data |
User data on the website www.pellegrinoaida.com will be retained and processed by us until the completion of the respective order, except for data required to be retained for tax purposes.
Data of registered users on the website www.pellegrinoaida.com will be retained and processed by us until the user requests the deletion of their account or, for any data processing based on their consent, until they withdraw their consent for the provision of services by Reconnection SRL. However, certain personal data related to transactions with Reconnection SRL, as well as information regarding the user’s consent and withdrawal of consent, will remain as records for the registered user-client to ensure proof of the legality of data processing by Reconnection SRL and to protect the legal rights of the parties.
Please note that we do not collect any Special Categories of Personal Data about you (this includes data about racial or ethnic origin, political opinions, religious or philosophical beliefs, union membership, or the processing of genetic data, biometric data for unique identification, data concerning health, sexual life, or sexual orientation, or information about criminal convictions and offenses).
| 10. What Happens If You Don’t Provide Us With Your Data |
When we ask you to provide personal data to grant you access to certain functionalities or services on the website, we will mark some fields as mandatory because this information is necessary for us to provide the service or grant access to the respective functionality.
Please note that if you choose not to provide this information, you may not be able to complete your registration as a user or benefit from these services or functionalities.
We inform you that we will use your personal data only for the purposes for which we collected it unless we reasonably consider that we need to use it for another reason that is compatible with the original purpose.
Please be aware that we may process your personal data without informing you or obtaining your consent, in accordance with the rules outlined above, where the law permits us to do so.
| 11. Legal Grounds for Processing Personal Data |
The legal grounds for processing your personal data are generally as follows:
♦ Your consent for the processing of personal data;
♦ Processing is necessary for the conclusion or performance of a contract between you and us;
♦ Processing is necessary for the purposes of our legitimate interests or those of another party.
| 12. Disclosure of Personal Data and Data Transfers |
We inform you that we may disclose your data, in compliance with applicable laws, to business partners or other third parties. We continually make reasonable efforts to ensure these third parties have implemented appropriate protection and security measures. We have contractual clauses with these third parties to ensure your data is protected. In such cases, we will ensure that any transfer is lawful under applicable legislation.
Additionally, we may transfer data to other parties with your consent or as per your instructions, such as in cases where you request data portability or to authorized state authorities based on and within the limits of legal provisions and following explicit requests.
The transfer of personal data to a third country can only occur if the destination country provides an adequate level of protection.
Data transfer to a country whose legislation does not provide a level of protection at least equivalent to that offered by the General Data Protection Regulation (GDPR) is possible only if there are sufficient guarantees regarding the protection of the fundamental rights of the data subjects. These guarantees will be established by us through contracts with the providers/service suppliers to whom your personal data will be transferred.
Whenever we transfer your personal data outside the EEA (European Economic Area), we will ensure a similar level of protection through one of the following safeguard mechanisms:
- We will transfer your personal data to countries that the European Commission has determined provide an adequate level of safety for personal data.
- When working with certain service providers, we may use specific contract models provided and approved by the European Commission, which offer personal data the same protection as within Europe.
| 13. Data Security |
We understand the importance of personal data security and take necessary measures to protect our clients and others whose data we process from unauthorized access, as well as unauthorized alteration, disclosure, or destruction of the data we handle in our operations.
We have implemented the following technical and organizational measures for the security of personal data: e le prelucrăm în activitatea curentă.
| Data Minimization | We ensure that the personal data we process is limited to what is necessary, appropriate, and relevant for the purposes stated in this Policy. |
| Restricting Data Access | We strive to limit access to the personal data we process as much as possible, granting access only to the minimum necessary: employees, collaborators, and other individuals who need to access this data to process it and fulfill a service. Our partners and collaborators are subject to strict confidentiality obligations (either contractual or legal). |
| Specific Technical Measures | We use technologies to ensure the security of our clients, always striving to implement the most effective solutions for data protection. Additionally, we perform regular data backups to enable recovery in case of an incident and have periodic audit procedures in place regarding the security of the equipment used. However, no website, application, or internet connection is completely secure and impervious to breaches. |
| Ensuring the Accuracy of Your Data | Sometimes, we may ask you to confirm the accuracy or update your data to ensure it reflects the current reality. |
| Staff Training | We continuously train and test our employees and collaborators on legislation and best practices in the field of personal data processing. |
| Data Anonymization | Where possible, we strive to anonymize or pseudonymize the personal data we process so that the individuals to whom the data refers can no longer be identified. |
However, despite our continuous efforts to ensure the security of the data you entrust to us, unfortunate events such as incidents or security breaches may occur. In such cases, we will strictly follow the security incident reporting and notification procedure and take all necessary measures to restore the situation to normal as quickly as possible.
| 14. Your Rights – Questions, Requests, and Exercising Your Rights |
For any additional information regarding your data, as well as its processing and protection, you can contact the Data Protection Officer at Reconnection SRL via email at contact@pellegrinoaida.com or by phone at +974 50106378.
Your rights under the GDPR include the following:
| The right to be informed about the processing of your data | |
| Right of access to data | You have the right to obtain confirmation from us as to whether or not personal data concerning you is being processed and, if so, access to that data and the information provided under Article 15(1) of the GDPR. |
| The right to rectify inaccurate or incomplete data | You have the right to obtain from us, without undue delay, the rectification of inaccurate personal data concerning you. |
| The right to erasure (“right to be forgotten”) | In the situations outlined in Article 17 of the GDPR, you have the right to request and obtain the deletion of your personal data. |
| The right to restrict processing | In the cases outlined in Article 18 of the GDPR, you have the right to request and obtain the restriction of processing. |
| The right to transfer your data to another controller (“right to data portability”) | The right to transfer the data we hold about you to another controller (“right to data portability”). |
| The right to object to data processing | In the cases outlined in Article 21 of the GDPR, you have the right to object to the processing of your data. |
| The right not to be subject to a decision based solely on automated processing, including profiling, with legal or similarly significant effects on you | |
| The right to seek legal recourse to protect your rights and interests |
Please note that the rights listed above are not absolute. There are exceptions, so each request received will be analyzed to determine whether it is justified. If the request is justified, we will facilitate the exercise of your rights. If the request is unjustified, we will reject it, but we will inform you of the reasons for the refusal and your rights to file a complaint with the Supervisory Authority and to seek legal recourse.
We will also strive to respond to your request within 30 (thirty) days. However, this timeframe may be extended depending on various factors, such as the complexity of the request, the high volume of requests received, or difficulties in identifying you in a timely manner. If, despite our best efforts, we are unable to identify you and you do not provide additional information to assist in your identification, we are not obligated to process your request.
| 15. Changes/Modifications/Updates to the Privacy Policy |
We may occasionally update the Privacy Policy and will notify you via the website or email about the latest version. All updates and changes to this document take effect immediately upon notification, which we will provide through a notice on the website and/or via email. Even if you do not receive a notification, we encourage you to periodically access and review the Privacy Policy to stay informed about the latest versions.
Privacy Policy updated on 17.11.2024.
