GDPR – Privacy Policy

Data protection notice of Royal Expert Design SRL

Royal Expert Design SRL (hereinafter “RED”, “We” or “Us”) welcomes you to our internet pages and mobile applications (together also referred to as “online offers”). We thank you for your interest in our company and our products.

1. RED respects your privacy

The protection of your privacy throughout the course of processing personal data as well as the security of all business data are important concerns to us. We process personal data that was gathered during your visit of our online offers confidentially and only in accordance with statutory regulations.

Data protection and information security are included in our corporate policy.

2. Controller

Royal Expert Design SRL is the controller responsible for the processing of your data; exceptions are outlined in this data protection notice.

Our contact details are as follows:

Royal Expert Design SRL, Islaz 29 street, Sector 1, Bucharest, Romania 011555,

Register of Commerce no. J40/15965/2008, Fiscal Code: RO24483832,

E-mail: contact@redmetal.eu, Phone: +4 0720 057 100.

3. Collection, processing and usage of personal data

3.1 Processed data categories

Communication data (e.g. name, telephone number, e-mail address, address, IP address) are processed.

3.2 Principles

Personal data consists of all information related to an identified or identifiable natural person, this includes, e.g. names, addresses, phone numbers, email addresses, contractual master data, contract accounting, and payment data, which is an expression of a person’s identity.

We collect, process, and use personal data (including IP addresses) only when there is either a statutory legal basis to do so or if you have given your consent to the processing or use of personal data concerning this matter, e.g. by means of registration.

3.3 Processing purposes and legal basis

We as well as the service providers commissioned by us, process your personal data for the following processing purposes:

3.3.1 Provision of these online offers

Legal basis: Predominantly, legitimate interest on our part in direct marketing as long as this occurs in accordance with data protection and competition law.

3.3.2 In reply to user inquiries in the framework of a contact form

Legal basis: Predominantly, legitimate interest in direct marketing on our part and in the enhancement of our products and services, as long as this is carried out in compliance with data protection regulations and competition law regulations resp. contractual performance resp. consent.

3.3.3 In reply to user inquiries in the framework of a live chat

Legal basis: Predominantly, legitimate interest in direct marketing on our part and in the enhancement of our products and services, as long as this is carried out in compliance with data protection regulations and competition law regulations resp. contractual performance resp. consent.

3.3.4 Resolving service disruptions as well as for security reasons

Legal basis: Fulfillment of our legal obligations within the scope of data security and predominantly, legitimate interest in resolving service disruptions as well as in the protection of our offers.

3.3.5 Self-promotion and promotion by others as well as market research and reach analysis done within the scope statutorily permitted or based on consent

Legal basis: Consent or predominantly, legitimate interest on our part in direct marketing if in accordance with data protection and competition law.

3.3.6 Safeguarding and defending our rights

Legal basis: Justified interest on our part in the assertion and defense of our rights.

3.4 Log files

Each time you use the internet, your browser is transmitting certain information which we store in so-called log files.

We store log files to determine service disruptions and for security reasons (e.g., to investigate attack attempts) for a short period of time and delete them afterwards. Log files which need to be maintained for evidence purposes are excluded from deletion until the respective incident is resolved and may, on a case-by-case basis, be passed on to investigating authorities.

Log files are also used for analysis purposes (without the IP address or without the complete IP address) see module 3.3.5 “Self-promotion and promotion by others as well as market research and reach analysis done within the scope statutorily permitted or based on consent”

In log files, the following information is saved:

IP address (internet protocol address) of the terminal device used to access the online offer;
Internet address of the website from which the online offer is accessed (so-called URL of origin or referrer URL);
Name of the service provider which was used to access the online offer;
Name of the files or information accessed;
Date and time as well as duration of recalling the data;
Amount of data transferred;
Operating system and information on the internet browser used, including add-ons installed (e.g., Flash Player);
http status code (e.g., “Request successful” or “File requested not found”).

3.5 Data transfer

3.5.1 Data transfer to other controllers

Principally, your personal data is forwarded to other controllers only if required for the fulfillment of a contractual obligation, or if we ourselves, or a third party, have a legitimate interest in the data transfer, or if you have given your consent. Particulars on the legal basis and the recipients or categories of recipients can be found in the section “Processing purposes and legal basis” (see no. 3.3).

Additionally, data may be transferred to other controllers when we are obliged to do so due to statutory regulations or enforceable administrative or judicial orders.

3.5.2 Service providers

We involve external service providers with tasks such as marketing services, programming, data hosting, and hotline services. We have chosen those service providers carefully and monitor them on a regular basis, especially regarding their diligent handling of and protection of the data that they store. All service providers are obliged to maintain confidentiality and to comply with the statutory provisions.

3.5.3 Transfer to recipients outside the EEA

We might transfer personal data to recipients located outside the EEA into so-called third countries. In such cases, prior to the transfer we ensure that either the data recipient provides an appropriate level of data protection or that you have consented to the transfer. You are entitled to receive an overview of third country recipients and a copy of the specifically agreed-provisions securing an appropriate level of data protection. For this purpose, please use the statements made in the “Operator” section (see no. 2).

3.6 Duration of storage; retention periods

Principally, we store your data for as long as it is necessary to render our online offers and connected services or for as long as we have a legitimate interest in storing the data (e.g. we might still have a legitimate interest in postal mail marketing). In all other cases we delete your personal data with the exception of data we are obliged to store for the fulfillment of legal obligations (e.g. due to retention periods under the tax and commercial codes we are obliged to have documents such as contracts and invoices available for a certain period of time).

4. Usage of cookies

In the context of our online service, cookies and tracking mechanisms may be used. Cookies are small text files that may be stored on your device when visiting our online service. Tracking is possible using different technologies. In particular, we process information using pixel technology and/or during log file analysis.

4.1 Categories

We distinguish between cookies that are mandatorily required for the technical functions of the online service and such cookies and tracking mechanisms that are not mandatorily required for the technical function of the online service.

It is generally possible to use the online service without any cookies that serve non-technical purposes.

4.1.1 Technically required cookies

By technically required cookies we mean cookies without those the technical provision of the online service cannot be ensured. These include e.g. cookies that store data to ensure smooth reproduction of video or audio footage.

Such cookies will be deleted when you leave the website.

4.1.2 Cookies and tracking mechanisms that are technically not required

We use marketing cookies and tracking mechanisms. We only use such cookies and tracking mechanisms if you have given us your prior consent in each case. With the exception of the cookie that saves the current status of your privacy settings (selection cookie). This cookie is set based on legitimate interest.

General

By using marketing cookies and tracking mechanisms we and our partners are able to show you offerings based on your interests, resulting from an analysis of your user behaviour:

Statistics: By using statistical tools, we measure e.g. the number of your page views.
Conversion tracking: Our conversion tracking partners place a cookie on your computer (“conversion cookie”) if you accessed our website via an advertisement of the respective partner. Normally these cookies are no longer valid after 30 days. If you visit certain pages of our website and the cookie has not yet expired, we and the relevant conversion partner can recognize that a certain user clicked on the advertisement and thereby was redirected to our website. The information obtained by means of the conversion cookie serves the purpose of compiling conversion statistics and recording the total number of users who clicked on the respective advertisement and were redirected to a website with a conversion tracking tag.
Social plugins: Some of the pages of our online service involve content and services of other providers (e.g. Facebook, Twitter) which also may use cookies and active modules. For more details regarding social plugins please refer to the section on “social plugins” (see no. 7).

Please note that using the tools might include transfer of your data to recipients outside of the EEA where there is no adequate level of data protection pursuant to the GDPR (e.g. the USA). For more details in this respect please refer to the following description of the individual marketing tools:

Name: Google Analytics
Provider: Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA
Function: Analysis of user behavior (page retrievals, number of visitors and visits, downloads), creation of pseudonymous user profiles based on cross-device information of logged-in Google users (cross-device tracking), enrichment of pseudonymous user data with target group-specific information provided by Google, retargeting, UX testing, conversion tracking, and retargeting in conjunction with Google Ads
Name: Google Tag Manager
Provider: Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA
Function: Administration of website tags via a user interface, integration of program codes on our websites
Name: Google Ads
Provider: Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA
Function: Placement of advertisements, remarketing, conversion tracking
Further information is available at: https://adssettings.google.com/authenticated

4.2 Management of cookies and tracking mechanisms

You can manage your cookie and tracking mechanism settings in the browser and/or our privacy settings.

Note: The settings you have made refer only to the browser used in each case.

4.2.1 Deactivation of all cookies

If you wish to deactivate all cookies, please deactivate cookies in your browser settings. Please note that this may affect the functionality of the website.

4.2.2 Management of your settings with regard to cookies and tracking mechanisms not required technically

When visiting our websites, you will be asked in a cookie layer whether you consent to our using of any marketing cookies or tracking mechanisms, respectively.

In our privacy settings, you may withdraw the consent with effect for the future or grant your consent at a later point in time.

5. Google

5.1 Google Maps

This page uses the map service Google Maps via an API. The provider is Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.

For the use of the functions of Google Maps it is necessary to store your IP address. This information is usually transmitted to a server of Google LLC in the USA and saved there. The provider of this page does not have any influence on this transmission of data.

The use of Google Maps is in the interest of an appealing presentation of our online offers and an easy retrievability of the places listed by us on the website. This represents a predominant legitimate interest on our part within the meaning of article 6 section 1, lit. f, GDPR.

Please see the privacy policy of Google for more information on the handling of user data: https://www.google.de/intl/de/policies/privacy/.

5.2 Google web fonts

This site uses so-called web fonts of the provider Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA for the uniform display of fonts. When you access a page, your browser loads the required web fonts into your browser cache to display texts and fonts correctly.

For this purpose, the browser you are using has to connect to the servers of Google. This informs Google that our website was accessed via your IP address. The use of Google web fonts is in the interest of a uniform and appealing presentation of our online offers. This represents a predominant legitimate interest on our part within the meaning of article 6 section 1, lit. f, GDPR.

Your computer will use a standard font if your browser does not support web fonts.

For more information about Google web fonts please see https://developers.google.com/fonts/faq and the privacy policy of Google: https://www.google.de/intl/de/policies/privacy/.

6. Social plugins

In our online offer, we use so-called social plugins of different social networks; these will be described individually in this section.

On application of the plugins, your Internet browser will establish a direct connection to the servers of the respective social network. Hereby the relevant provider obtains the information that your Internet browser has called up the corresponding page of our online offer, even if you do not possess a user account with the provider or are not currently logged in with the provider. Log files (including the IP address) are directly transmitted from your Internet browser to a server of the relevant provider where they are stored if necessary. The headquarters of the provider or his/her server could be located outside the EU or the EEA (e.g. in the USA).

The plugins represent independent extensions of the providers of social networks. Therefore, we have no influence on the extent of the data collected and stored by the social network providers via the plugins.

The purpose and extent of the collection, the further processing of the data by the social network as well as your associated rights and setting options for the protection of your private sphere can be taken from the data protection notes of the respective social network.

You should not use the respective plugins if you do not want social network providers to obtain data concerning this online offer or to continue to use this data.

6.1 Social plugins with 2-click solution

With a so-called 2-click solution, we protect you from having your visits to our websites recorded and evaluated by social network providers as standard. When you access a page of our internet offer, which contains such plugins, these are initially deactivated. The plugins are not activated until you click the provided button.

6.2 Facebook plugins

Facebook is provided under www.facebook.com by Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA, and under www.facebook.de by Facebook Ireland Limited, Hanover Reach, 5–7 Hanover Quay, Dublin 2, Ireland (“Facebook”). You will find an overview of the plugins from Facebook and their appearance here: http://developers.facebook.com/plugin; you will find information on data protection at Facebook here: http://www.facebook.com/policy.php.

6.3 Twitter plugins

Twitter is provided by Twitter Inc., 1355 Market St, Suite 900, San Francisco, CA 94103, USA (“Twitter”). You will find an overview of the plugins from Twitter and their appearance here: https://twitter.com/about/resources/buttons; you will find information on data protection at Twitter here: https://twitter.com/privacy.

6.4 LinkedIn plugins

LinkedIn is provided by LinkedIn Corporation, 2029 Stierlin Court, Mountain View, CA 94043, USA (“LinkedIn”). You will find an overview of the plugins from LinkedIn and their appearance here: https://developer.linkedin.com/plugins; you will find information on data protection at LinkedIn here: https://www.linkedin.com/legal/privacy-policy.

7. YouTube

This online offer uses the video platform YouTube, which is provided by YouTube, LLC, 901 Cherry Ave. San Bruno, CA 94066, USA (“YouTube”). YouTube is a platform which allows the playback of audio and video files.

If you access a corresponding page of our offer, the embedded YouTube player will establish a connection to YouTube so that the video or audio file can be transmitted and played. In the process, data are also transmitted to YouTube as the responsible body. We are not responsible for the processing of this data by YouTube.

Further information concerning the extent and purpose of the collected data, on the further processing and utilization of your data by YouTube, on your rights and on your selectable data protection options can be found in the privacy policy of YouTube.

8. External links

Our online offers may contain links to internet pages of third parties, in particular providers who are not related to us. Upon clicking on the link, we have no influence on the collecting, processing, and use of personal data possibly transmitted by clicking on the link to the third party (such as the IP address or the URL of the site on which the link is located) as the conduct of third parties is naturally beyond our control. We do not assume responsibility for the processing of personal data by third parties.

9. Security

Our employees and the companies providing services on our behalf, are obliged to confidentiality and to compliance with the applicable data protection laws. We take all necessary technical and organizational measures to ensure an appropriate level of security and to protect your data that are administrated by us especially from the risks of unintended or unlawful destruction, manipulation, loss, change, or unauthorized disclosure or unauthorized access. Our security measures are, pursuant to technological progress, constantly being improved.

10. User rights

To enforce your rights, please use the details provided in the “Controller” section (see no. 2). In doing so, please ensure that an unambiguous identification of your person is possible.

10.1 Right to information and access

You have the right to obtain confirmation from us about whether or not your personal data is being processed, and, if this is the case, access to your personal data.

10.2 Right to correction and deletion

You have the right to obtain the rectification of inaccurate personal data. As far as statutory requirements are fulfilled, you have the right to obtain the completion or deletion of your data.

This does not apply to data which is necessary for billing or accounting purposes or which is subject to a statutory retention period. If access to such data is not required, however, its processing is restricted (see the following).

10.3 Restriction of processing

As far as statutory requirements are fulfilled you have the right to demand for restriction of the processing of your data.

10.4 Data portability

As far as statutory requirements are fulfilled you may request to receive data that you have provided to us in a structured, commonly used and machine-readable format or – if technically feasible – that we transfer those data to a third party.

10.5 Right of objection

10.5.1 Objection to data processing based on the legal basis of “legitimate interest”

In addition, you have the right to object to the processing of your personal data at any time, insofar as this is based on “legitimate interest”. We will then terminate the processing of your data, unless we demonstrate compelling legitimate grounds according to legal requirements which override your rights.

10.5.2 Objection to direct marketing

Additionally, you may object to the processing of your personal data for direct marketing purposes at any time. Please take into account that due to organizational reasons, there might be an overlap between your objection and the usage of your data within the scope of a campaign which is already running.

10.6 Withdrawal of consent

In case you consented to the processing of your data, you have the right to revoke this consent at any time with effect for the future. The lawfulness of data processing prior to your withdrawal remains unchanged.

10.7 Right to lodge complaint with supervisory authority

You have the right to submit an appeal to a data protection supervisory authority. For this purpose, you can refer to the data protection supervisory authority, which is competent for your place of residence of federal state or to the data protection supervisory authority which is competent for our group. The data protection supervisory authority responsible for us is:

Autoritatea Naţională de Supraveghere a Prelucrării Datelor cu Caracter Personal
B-dul. G-ral. Gheorghe Magheru 28-30, Sector 1, Bucureşti 010336, România
Contact:
+40.318.059.211
+40.318.059.212

anspdcp@dataprotection.ro
http://dataprotection.ro

11. Children

This online offer is not directed at children under an age of 16 years.

12. Change of the data protection notice

We reserve the right to change our security and data protection measures. In such cases, we will amend our data protection notice accordingly. Please, therefore, notice the current version of our data protection notice, as this is subject to changes.

13. Contact

If you wish to contact us, please find us at the address stated in the “Controller” section (see no. 2).

To assert your rights, to notify data protection incidents, for suggestions and complaints regarding the processing of your personal data we recommend that you contact our data protection officer:

Data Protection Officer
Royal Expert Design SRL
Islaz 29 street, Sector 1, Bucharest 011555 ROMANIA

or

e-mail to: dpo@redmetal.eu

Date of last revision: 21.12.2020

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