Privacy Policy

Privacy Policy

3. PROTECTION OF PERSONAL DATA

Smart Infra SRL informs the visitor/registered user, and the visitor/registered user acknowledges that he/she is aware of the following:

3.1 General
Individuals accessing the website www.shop.smart-infra.ro (users) may browse the web pages and use its services and content either as regular visitors or as registered users, and the processing of their personal data as a result of their access is governed by this policy. For certain individual services (e.g. product purchase advice, answers to product-related questions, etc.), the specific personal data processing conditions indicated at the time of ordering the service additionally apply.

The company named Smart Infra SRL is responsible for the processing of personal data of the registered visitor/user and controls the processing of his/her data on the web pages of the site. www.shop.smart-infra.ro . The processing of personal data is carried out in accordance with the provisions of the General Data Protection Regulation (GDPR 2016/679), in accordance with the applicable Romanian legislation for the protection of personal data, as well as for the protection of personal data and privacy in the electronic communications sector (Law No 365 of 7 June 2002 on electronic commerce) and with the decisions of the Authority for the Protection of Personal Data ( ANSPDCP). For the processing of your data, as described below, Smart Infra SRL relies on the following legal grounds:

Implementation of the contract (Article 6.1.b of the GDPR): to achieve the purpose of the performance of the distance selling contract or to take action at the user's request prior to the conclusion of the contract and, in particular, to enable the user to complete his orders on the www.shop.smart-infra.ro , it is necessary to process the personal data provided by him when registering and entering his order in the order form, as well as to record and monitor his transactions. The purpose of this processing of basic data is for each user to complete the order in question, to communicate and send information messages on the order processing stages, to provide clarifications relating to the order and, in general, to analyse and provide information on the orders he has placed, to deliver the order to the place of his choice, to confirm and identify him if necessary and to inform him of the stock existing on the website. www.shop.smart-infra.ro  depending on the product and shop. Also, facilitating access to registered users by creating a user account with completed billing and shipping information, information about their purchases, managing their communication with Smart Infra SRL and, starting in July 2021, goals include rewarding them with points and privileges for their purchases if they are also members of the Smart Infra SRL customer loyalty program and make purchases through the www.shop.smart-infra.ro.

Legitimate interests (Article 6.1.f GDPR): some form of processing of personal data is necessary to improve the services of Smart Infra SRL, to detect fraud or abuse, to cooperate with judicial and control authorities. Also, for the periodic information of the visitor and/or registered user by telephone communication, mail, e-mail, mobile phone message (SMS) or any other appropriate means of communication lawfully obtained in the context of the use of https://shop.smart-infra.ro, for the products and services of Smart Infra SRL in the context of their commercial relationship.

Law No 365 of 7 June 2002 on electronic commerce) and if the user does not object to this communication. Such information may include information about products and/or offers and/or competitions that it organises, communication for the purposes of surveys to improve the products and services offered to users and other promotional activities and for similar purposes. Smart Infra SRL may also communicate with the visitor and/or registered user through messaging services such as Viber, WhatsApp, etc., for the purpose of better information and control of related costs. Registered users also have the option, as of July 2021, to choose the communication channels that Smart Infra SRL can use to inform them via their personal account on www.shop.smart-infra.ro. Changes to these preferences have an implementation deadline of up to 30 days for technical reasons. Finally, Smart Infra SRL considers that its legitimate interests include the appearance and promotion of itself and its shops, as well as its products and services in electronic social networks (social media) and other services , also providing the opportunity for other users of these networks to participate in promotional activities and to declare that they like our page and post comments about our products.

Legal obligation (Article 6.1.c GDPR): some user data is retained to comply with Smart Infra SRL's legal obligations, such as for tax and accounting purposes.

Consent - consensus: Fill in the e-mail address of the visitor or registered user in the special field of the site www.shop.smart-infra.ro constitutes affirmative evidence of consent to receive information/promotional messages. 

3.2 Processing and type of personal data - Rights of registered visitors/users.

α) Processing of personal data: in the case of an online order, Smart Infra SRL will process the user's personal data declared by the user during the creation of the account and/or his/her order in the data registration form, in order to complete the specific order through the online shop. Each user of the site www.shop.smart-infra.ro has the choice of 2 ways to complete an online order and declare his/her personal data:

1. As a simple visitor: In this case, your personal data will be kept in Smart Infra SRL's archives for ninety (90) days from the delivery or completion of the respective order, and their processing will relate exclusively to the execution of the distance selling contract. However, the information proving the completion of the transaction will be kept for tax purposes (billing document) and his contact details will be used by Smart Infra SRL for commercial advertising purposes, unless the user has declared that he does not wish to receive such communications.

2. As a registered user of the e-shop. Once a year, Smart Infra SRL will ask the registered user to confirm the veracity of the data he/she keeps and to update it if there are any changes. The registered user can modify or rectify his data at any time by logging into his account at www.shop.smart-infra.ro (login) with his username and password.

b) Type of personal data and purpose of processing

In particular, the personal data that each user must provide (either as a visitor or as a registered user) in order to carry out any transaction through the online shop (www.shop.smart-infra.ro) of Smart Infra SRL and to place orders for its products are as follows:

• -full name of the person
• delivery address of the products
• the billing address of the order (if different from the delivery address)
• Full invoicing details such as name, profession, tax administration to which it belongs and a tax identification number (if a commercial tax invoice has been chosen).
• -mobile and landline telephone number
• his e-mail address.

In addition to the above, Smart Infra SRL also collects and stores the following personal data for registered users only:

• order history
• date of last access
• products that are in your shopping basket or favourites list
• participation in promotions

In the event that the delivery of products or services to a third party other than the visitor or registered user is requested, the latter acknowledges that he/she will be fully responsible for informing and giving full consent to the person, whom he/she designates as the recipient, for the disclosure of his/her personal data to Smart Infra SRL for the sole purpose of delivering those products and assumes full responsibility for any claims of that person against Smart Infra SRL.

The credit card details used by the visitor or registered user are not stored on Smart Infra SRL's storage channels during the transaction, but are recorded directly in a secure environment of the partner company that handled the card transactions.

The visitor and registered user is also informed that for Smart Infra SRL communications with him, in the context of the Law no. 365 of 7 June 2002 on electronic commerce, it processes the contact data provided by the user. Also, when the registered user is sent notifications by SMS/viber/email etc. for changes in the conditions of use of the portal www.shop.smart-infra.ro  with a hyperlink, it is possible to record the IP address of the user's electronic device (mobile phone, tablet, computer, etc.) to prove that the registered user has received the notification.

The purpose of the basic data processing is the execution of the contract and the completion of the specific order, communicating with the visitor/registered user and sending information messages about the order processing steps, providing clarifications related to the order and in general information about the purchases made, delivering the order to the place chosen by the visitor/registered user, confirming and identifying the visitor/registered user in any necessary case and informing about the status of the order. The visitor/registered user is informed that the provision of the above mandatory personal data and processing data is required and is a precondition for the correct execution of the order and delivery of the products and services. For this reason, his/her consent is not required for this specific processing.

Each registered visitor/user who uses www.shop.smart-infra.ro is informed that his personal data concerning the receipt, execution and delivery of an order, as well as questions concerning purchases, products and services of Smart Infra SRL and orders placed on www.shop.smart-infra.ro , will be processed for the purpose of serving users - customers both by competent employees of Smart Infra SRL and by third party recipients and/or processors on behalf of Smart Infra SRL, in the context of fulfilling an order. These third party recipients are transport companies, individual or group forwarding companies, internet and e-commerce service providers and customer service call centres, with whom Smart Infra SRL cooperates and who are subject to the specific strict conditions for processing personal data agreed with Smart Infra SRL as data controller. Smart Infra SRL requires its employees, the operators who maintain its website, as well as its third party partners to take all necessary technical and organisational measures (including policies and procedures to prevent the disclosure of personal data of registered visitors/users - customers that they process and hold and to implement procedures for the management and processing of personal data in a lawful and GDPR-compliant manner.

No further processing or transmission of information on registered visitors/users of Smart Infra SRL and its online shop (√) will be carried out unless there is prior information and full consent, where required.

c) Data recipients: For the data necessary to fulfil each of the above processing purposes and in the context of the responsibilities of each recipient, the recipients of the data of registered visitors/users are or may be:

i. Competent employees of Smart Infra SRL

Tax authorities and banking authorities in the event of an audit

iii. The company currently providing CRM services and processing the data of the registered customer-users as operator on behalf of Smart Infra SRL in accordance with the instructions and orders of Smart Infra SRL or any other company that in the future provides Smart Infra SRL with the same services instead of Smart Infra SRL in cooperation with the aforementioned company.

iv) External partners providing internet, warehousing and order management services, call centre services, delivery (courier) or groupage services, product assembly services and sales data analysis services, to whom the data necessary to perform the tasks are transmitted within strict restrictions and procedures. These companies use the data provided to them under the terms of use of www.shop.smart-infra.ro exclusively in accordance with Smart Infra SRL instructions

d) Rights of the data subject: each visitor/registered user, as a data subject, may at any time exercise his/her rights under the General Data Protection Regulation 679/2016 EU, in particular Articles 12-23, and under national law in particular:

i) the right to information and access to the data processed by Smart Infra SRL,

(ii) the right to restrict the processing of his/her data;

(iii) the right to rectification or erasure (right to be forgotten) of some or all personal data,

(iv) the right to object, i.e. to object to the processing of his/her personal data; and

(v) the right to portability of his/her data.

The above rights can be exercised by any registered visitor/user:

• by sending a request to contact@smart-infra.ro
• by sending a request to contact@smart-infra.ro

In addition, registered users: 

On right of access and rectification/completion of personal data, the company offers registered users on www.shop.smart-infra.ro  the possibility to view, rectify/complete personal data via your personal account on www.shop.smart-infra.ro  in the "Account details" and "Delivery addresses" section.

With regard to the right of portability of personal data, the company offers registered users the possibility to obtain their personal data and/or transfer them to another controller by submitting a written request to contact@smart-infra.ro.

Each registered user is informed that they have the right to withdraw their consent to any processing of data to which they have given their consent on www.shop.smart-infra.rofrom his personal account on www.shop.smart-infra.ro  in the "Personal data settings" section or by sending an e-mail.

e) The period of storage of personal data: site user data www.shop.smart-infra.ro will be kept and processed by Smart Infra SRL until the completion of the respective order, with the exception of data required to be kept for tax purposes.

User data registered on www.shop.smart-infra.ro  will be kept and processed by Smart Infra SRL until the member requests the deletion of his/her account or, for any processing of his/her data based on his/her consent, until the member declares the withdrawal of consent for the purpose of providing Smart Infra SRL services However, some personal data relating to transactions with Smart Infra SRL, as well as the member's information, consent and withdrawal of consent to the processing of his/her data will remain as information for the registered user-customer, in order to ensure proof of the lawfulness of the processing of his/her data by Smart Infra SRL and the protection of the legal rights of the parties.

f) Data in special categories: The member is informed that Smart Infra SRL does not collect or request the disclosure of sensitive personal data (special category data) for the purpose www.shop.smart-infra.ro

(g) Obligation of transparency: For any further information regarding his/her data and their processing and protection, each data subject may contact the Data Protection Officer of Smart Infra SRL (Data Protection Officer) at the following e-mail address contact@smart-infra.roIf the data subject considers that he/she is not satisfied with the response or with the general manner in which his/her data is collected, processed and handled, he/she shall be informed that he/she has the right to lodge a complaint with the competent supervisory authority (National Supervisory Authority for Personal Data Processing, B-dul G-ral. Gheorghe Magheru 28-30, Sector 1, postal code 010336, Bucharest, Romania, anspdcp[at]dataprotection.ro, dpo[at]dataprotection.ro, +40.318.059.211, +40.318.059.212)

h) Technical and organisational protective measures: Smart Infra SRL, the persons authorised by it and its employees/assistants are contractually obliged to implement technical and organisational measures to protect personal data as far as possible against accidental or unlawful destruction or loss, alteration, unlawful disclosure or access and unlawful processing in general (including remote access) and to ensure that the availability and accessibility of personal data can be restored. These measures shall aim to ensure a level of security commensurate with the risk to which the data concerned may be exposed, taking into account the nature and sensitivity of the data, developments in technology, the cost of implementation, and the nature, scope, context and purposes of any specific processing, while putting in place procedures for regular testing, evaluation and assessment of the effectiveness of such technical and organisational measures. In any event, Smart Infra SRL, the persons it appoints on behalf of or on its behalf and its employees/assistants are under a contractual obligation to keep personal data confidential and not to disclose or allow access to them to a third party without prior notification to the person concerned, except in cases expressly provided for by law.

Smart Infra SRL declares that the personal data of the visitor/registered user will not be used for purposes other than those mentioned in this policy without his/her prior notification and, if applicable, consent.