GDPR

Personal Data Processing Policy

The purpose of this document is to inform the users of the website www.azur.ro about the processing of personal data by AZUR SA, as Operator, registered at the Trade Register under no. J35/9/1991, tax number 1807689 and with registered office at Bld. Constructorilor no. 1-3, Timișoara, Timiș, Romania.

Personal data processing is carried out in accordance with Regulation No 679/2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing Directive No 95/46/EC (hereinafter “GDPR”), being applicable in all Member States of the European Union.

AZUR SA is aware of the importance of protecting information collected about you, in particular information that is capable of identifying you as an individual (“personal information”). This document governs how we collect information (through the document called “interest form”, by creating a user account on the www.azur.ro website and by subscribing to the newsletter).

1 How we collect personal data

1.1 Directly - we process personal data that you have voluntarily provided to us:

• When you contact us by filling in the contact form

1.2 Indirectly - we may process data that you have not volunteered:

• When you visit the website or interact in any way with it

2 Categories of personal data processed

2.1 If you are a customer of the website, AZUR SA will process your personal data such as, but not limited to:

• Surname and first name

• Phone number

• E-mail

• Data relating to how you use the website (e.g., your behavior/preferences/habits within www.azur-metalworking.ro)

2.2 If you are a visitor to the www.azur-metalworking.ro website, AZUR SA will process the personal data you provide:

• Directly in the context of using the website, such as the data you provide in the contact/questions/complaints section, to the extent that you contact us in this way

• Indirectly, data such as: IP address, browser used, browsing duration, search history, operating system used, language and pages viewed, full URLs, sequence of clicks to, through and from our website, information or products viewed/searched, duration of visits to particular pages, information on page interaction (e.g., scrolling, clicks, mouse-overs), data on user behavior

3 Basis of processing and purpose

Legal obligation: We may process personal data in order to fulfill our legal obligations as a professional.

3.1 If you are a customer of the www.azur-metalworking.ro website, AZUR SA will process your personal data as follows:

3.1.1 For the fulfillment of the legal obligations incumbent on AZUR SA in the context of the services provided through the azur.ro website, including tax obligations, as well as archiving obligations.

Basis: The processing of your data for this purpose is necessary on the basis of legal obligations. Providing your data for this purpose is necessary. Refusal to provide data may result in AZUR SA being unable to comply with its legal obligations and thus unable to provide you with services through the website.

3.1.2 In order to carry out the contractual relationship between you and AZUR SA, i.e., to take over, validate, dispatch and invoice the order placed on the website, inform you of the status of the order, organize the return of ordered products, etc.

Basis: The processing of your data for this purpose is based on the contract concluded between you and AZUR SA, as defined in the Terms and Conditions. The provision of your personal data is necessary for the performance of this contract. Refusal to provide your data may result in the impossibility of the contractual relationship between you and AZUR SA.

3.1.3 For marketing activities, i.e., for the transmission, via remote communication means (e-mail, SMS, whatsapp), of commercial communications regarding the products and services offered by AZUR SA, via the azur.ro website.

Basis: The processing of your data for this purpose is based on your consent, if you choose to provide it by: subscribing to the newsletter, creating an account, completing an order on the site.

3.1.4 To unsubscribe from receiving such commercial communications you can use the option at the end of each e-mail/SMS containing commercial communications.

Providing your data for this purpose is voluntary. Refusal to provide consent to the processing of your data for this purpose will have no negative consequences for you.

3.1.5 For the purpose of carrying out various analyses, reporting on the functioning of the site, profiling consumer preferences, mainly in order to improve the experience offered on the site.

Basis: The processing of your data for this purpose is based on AZUR SA’s legitimate interest to continuously improve the customer experience on the site. Providing your data for this purpose is voluntary. Refusal to provide data for this purpose will have no negative consequences for you.

3.2 If you are a visitor to the azur.ro website, AZUR SA will process your personal data as follows:

3.2.1 For marketing activities, i.e., for the transmission, via remote communication means (e-mail, SMS, whatsapp), of commercial communications regarding the products and services offered by AZUR SA, via the azur.ro website.

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

3.2.2 You can express your consent to the processing of your data for this purpose by completing and ticking the appropriate box on the newsletter subscription form available on the website.

3.2.3 To unsubscribe from receiving such commercial communications you can use the option at the end of each e-mail/SMS or whatsapp message containing commercial communications.

Providing your data for this purpose is voluntary. Refusing to provide consent to the processing of your data for this purpose will have no negative consequences for you.

3.2.4 To resolve complaints, grievances and to monitor traffic and improve your experience on the azur.ro website.

Basis: The processing of your data for this purpose is based on the legitimate interest of AZUR SA to ensure the proper functioning of the azur.ro website, as well as to continuously improve the experience of visitors to the website, including by resolving various comments, questions or complaints.

Providing your data for this purpose is voluntary. Refusal to provide data for this purpose will have no negative consequences for you.

4 Disclosure of personal data

We do not disclose your personal data to third parties!

4.1 In addition to the Operator AZUR SA, in certain situations, data may be accessible to third parties such as service providers, transport operators, hosting providers, IT companies, partners who provide us with marketing services, storage, appointed, if necessary, as processors by the Operator.

The companies that have access to your data to be able to carry out the commercial transaction are:

• AZUR SA - administrator of the AZUR.RO website

They are bound by contract to maintain the confidentiality of the data and to use it exclusively for the purpose for which it was provided.

4.2 We may also disclose your personal data to central/local public authorities in the following cases (the list is made by way of example, without limiting ourselves to these instances):

• Where disclosure of personal data is required by law: public authorities, auditors or institutions with powers to carry out inspections and controls on our business, who ask us to provide information, by virtue of legal obligations, to comply with a legal requirement or to protect our rights and assets

• For site administration purposes

• To maintain, customize and improve the site and the services provided through it

• In cases where this communication is necessary for the awarding of prizes or other facilities to data subjects obtained as a result of their participation in various promotional campaigns organized by AZUR SA through the azur.ro website

• For conducting data analysis, testing and research, monitoring usage trends and activity, developing security features and authenticating site users

• For the transmission of commercial marketing communications, under the conditions and within the limits laid down by law

4.3 These third parties in turn have similar obligations to our obligations with regard to the protection of personal data, either they themselves are personal data controllers or they are processors who process data on behalf of AZUR SA.

4.4 In order to facilitate our global operations and in accordance with applicable law, we may transfer or, where appropriate, allow access to our partners in multiple countries, including the United States of America, as set out in the Cookie Policy.

4.5 All personal data processing activities relate exclusively to persons who are over 18 years of age, i.e., representatives of legal entities or persons acting on behalf of and for the account of the legal entity.

4.6 If you do not provide us with the personal data requested, you will not be able to transmit your request/order to us and we will not be able to respond to you.

5 Rights you have in relation to your personal data

5.1 The right to request a copy of the personal data we hold.

5.2 Right to information - the right to receive details of the processing activities carried out by AZUR SA as described in this document.

5.3 Right of access to data - to ask us to rectify any personal data that is inaccurate or no longer up to date: the right to obtain confirmation from AZUR SA regarding the processing of personal data, as well as details of the processing activities, such as how the data is processed, the purpose for which the processing is carried out, the recipients or categories of recipients of the data, etc.

5.4 The right to data portability, if the processing is based on your consent, a contract or automated means of decision making, the right to ask us to provide personal data obtained directly from you and, if possible, to transmit those data directly to another controller.

5.5 The right to withdraw your consent to processing, where the processing is based on consent, without however affecting the lawfulness of the processing activities carried out up to that point.

5.6 The right to erasure of data, to request that personal data be deleted when no longer needed without undue delay (“right to be forgotten”) - applies under certain conditions. It is possible that, following the request for erasure of data, AZUR SA may anonymize these data (thus depriving them of their personal nature) and continue processing for statistical purposes under these conditions.

5.7 Right to restrict processing under certain conditions.

5.8 Right to object - in relation to processing activities, may be exercised by submitting a request as indicated below.

At any time, for reasons relating to the data subject’s particular situation, data relating to him or her may be processed on the basis of the legitimate interest of AZUR SA or on the basis of the public interest, unless AZUR SA can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of data subjects or for the establishment, exercise or defense of legal claims.

At any time, free of charge and without any justification, that data concerning him or her are processed for direct marketing purposes.

5.9 Right not to be subject to an automated individual decision - the right not to be subject to a decision taken solely on the basis of automated processing activities, including profiling, which produces legal effects concerning the data subject or otherwise significantly affects him or her.

5.10 The right in the event of a dispute as to the fairness of the processing of personal data, the right to restrict processing.

5.11 The right to lodge a complaint with the supervisory authority: the National Supervisory Authority for Personal Data Processing at Blvd. G-ral. Gheorghe Magheru, no. 28-30, 1^st District, zip code 010336, Bucharest, Romania or by e-mail at anspdcp@dataprotection.ro.

The above rights can be exercised at any time. To exercise these rights, we encourage you to send us a request in writing, dated and signed, or in electronic format to the following address: office@azur.ro.

6 Duration for which we process your data

6.1 AZUR SA will process your personal data for as long as is necessary to achieve the processing purposes mentioned above.

6.2 If you are a customer, we will process your data for the entire duration of the contractual relationship and subsequently in accordance with the legal obligations incumbent on AZUR SA (for example, in the case of financial-accounting supporting documents for which the retention period laid down by law is 10 years from the end of the financial year in which they were drawn up).

6.3 If you are a customer and you exercise the option to delete your user account by clicking on the “Delete account” button in the “My account” section, AZUR SA will interpret this action as your option to unsubscribe from receiving commercial communications informing you about the products and services offered through the azur.ro website.

In this regard, if you choose to delete your user account, we will no longer send you such e-mails and/or SMS.

However, we would like to inform you that deleting your account will not automatically result in the deletion of your personal data.

6.4 If you wish to stop the processing of your personal data or if you wish to have your data deleted, you can exercise your rights as detailed below.

If you request the deletion of your account, but there is at least one active order on that account, the request for deletion of the account can only be registered after the delivery of the products and the completion of the last active order.

If you withdraw your consent to the processing of data for marketing purposes, AZUR SA will cease processing your personal data for this purpose, without however affecting the processing carried out by AZUR SA on the basis of the consent expressed by you prior to your withdrawal.

6.5 Data submitted via the account created on the website: 5 years from the date on which the account has no further activity.

6.6 Data collected unintentionally via the site: 3 years from the date of collection.

6.7 Once the processing period indicated above expires and we no longer have legal or legitimate grounds to process your personal data, it will be deleted in accordance with the controller’s internal procedures.

7 Changes in personal data processing policy

We reserve the right to amend this personal data processing policy in accordance with the legislation in force, which shall prevail over the provisions of this document from the time of publication in the Official Gazette. In case of major changes in the future, you will be notified by e-mail (if possible) or by posting a specific message on the website.

If you have any queries, you can contact us by e-mail: office@azur.ro or by phone/whatsapp: 0723/727984.