Privacy Policy

1. PRIVACY POLICY REGARDING THE PROCESSING OF PERSONAL DATA

  • We consider ensuring the right to personal data protection as a fundamental commitment of the company GODDESS INTERNATIONAL S.R.L., therefore we will dedicate all necessary resources and efforts to process your data in full compliance with Regulation (EU) 2016/679 ("General Data Protection Regulation" or "GDPR"), as well as with any other applicable legislation in Romania. Since one of the essential principles of this legal framework is transparency, we have prepared this document through which we want to inform you about how we collect, use, transfer, and protect your personal data when you interact with us in connection with our products and services, including through our website or mobile applications.
  • We reserve the right to periodically update and modify this Privacy Policy to reflect any changes in how we process your personal data or any changes in legal requirements. In the event of any such changes, we will display the modified version of the Privacy Policy on our website, which is why we ask you to periodically check the content of this Privacy Policy.

2. WHO ARE WE AND HOW CAN YOU CONTACT US?

  • MYGRACE – the trade name for GODDESS INTERNATIONAL S.R.L., a Romanian legal entity, with its registered office in Bucharest, Sector 4, Drumul Jilavei Street, No. 52, registered with the Trade Register under order number J2022001538401, CIF RO45551581. For the purpose of data protection legislation, we are the operator when processing your personal data.

3. WHAT CATEGORIES OF PERSONAL DATA DO WE PROCESS?

  • In general, we collect personal data directly from you, so you have control over the type of information you provide to us. For example, we receive information from you in the following situations:
    • when you create a MYGRACE account, you send us: email address, first and last name, residential address, delivery address (if different from residential address), postal code, phone number, email address;
    • on your personal page (My Account) on the MYGRACE platform, you can add additional information, such as: phone number, date of birth, delivery addresses (if you have multiple preferred delivery addresses, alternative email address, etc.);
    • when you place an order, you provide us with information such as: desired product, first and last name, delivery address, billing details, payment method, phone number, etc.
  • We may also collect and subsequently process certain information about your behavior while visiting our website or using the smartphone application, to personalize your online experience and provide you with offers tailored to your profile. We invite you to find out more details in this regard by consulting the section below regarding the purposes of processing.
  • On our website and in the smartphone application, we may store and collect information in cookies and similar technologies, according to the Cookie Policy.
  • We do not collect and do not otherwise process sensitive data, included by the General Data Protection Regulation in special categories of personal data. Also, we do not wish to collect or process data of minors under the age of 16.

4. WHAT ARE THE PURPOSES AND GROUNDS FOR PROCESSING?

  • We will use your personal data for the following purposes:
    • For taking orders and delivering ordered products

    This general purpose may include, as appropriate, the following:

    • creating and managing the account within the MYGRACE platform;
    • processing orders, including taking, validating, shipping, and invoicing them;
    • resolving cancellations or problems of any nature related to an order, purchased goods or services;
    • returning products in accordance with legal provisions;
    • reimbursing the value of products in accordance with legal provisions;
    • providing support services, including answering your questions regarding your orders or MYGRACE goods and services.
  • Also, certain processing subsumed to these purposes are imposed by applicable legislation, including tax and accounting legislation.

 

  • For improving our services
  • We constantly strive to offer you the best online shopping experience. For this, we may collect and use certain information related to your Buyer behavior, we may invite you to complete satisfaction questionnaires after completing an order, or we may conduct, directly or with the help of partners, market studies and research.
  • We base these activities on our legitimate interest in conducting commercial activities, always ensuring that your fundamental rights and freedoms are not affected.

     

    • For marketing purposes
  • We want to keep you informed about the best offers for products/services that interest you. In this regard, we may send you any type of message (such as: email/SMS/mobile-push/web-push, etc.) containing general and thematic information, information about products similar or complementary to those you have purchased, information about offers or promotions, information regarding products added to the "Account/My Cart" section or "Account/Favorites" section or that you have shown interest in purchasing, as well as other commercial communications, such as market research and opinion polls, and we may display personalized recommendations on the website and in the smartphone application. To provide you with information of interest to you, we may use certain data about your buyer behavior (e.g., products viewed / added to the favorites section / purchased) to create a profile for you. We always ensure that this processing is carried out in compliance with your rights and freedoms and that decisions based on it do not have legal effects on you and do not significantly affect you in a similar way.
  • In most cases, we base our marketing communications on your prior consent. You can change your mind and withdraw your consent at any time, by:
    • accessing the unsubscribe link displayed in the messages you receive from us;
    • contacting MYGRACE using the contact details described on the contact page.
  • In certain situations, we may base our marketing activities on our legitimate interest to promote and develop our commercial activity. In any situation where we use information about you for our legitimate interest, we take care and take all necessary measures to ensure that your fundamental rights and freedoms are not affected. However, you can always ask us, by the means described above, to stop processing your personal data for marketing purposes, and we will comply with your request.
    • For defending our legitimate interests
  • There may be situations where we will use or transmit information to protect our rights and commercial activity. These may include:
    • measures to protect the website and MYGRACE platform users from cyber attacks;
    • measures to prevent and detect fraud attempts, including transmitting information to competent public authorities;
    • measures to manage other risks.
  • The general basis for these types of processing is our legitimate interest in defending our commercial activity, it being understood that we ensure that all measures we take guarantee a balance between our interests and your fundamental rights and freedoms.
  • Also, in certain cases, we base our processing on legal provisions, such as the obligation to ensure the security of goods and values provided by applicable legislation in this matter.

5. HOW LONG DO WE RETAIN YOUR PERSONAL DATA?

  • As a general rule, we will store your personal data for as long as you have an account on the MYGRACE platform. You can ask us at any time to delete certain information or close the account, and we will comply with these requests, subject to retaining certain information even after closing the account, in situations where applicable legislation or our legitimate interests require it.

6. TO WHOM DO WE TRANSMIT YOUR PERSONAL DATA?

  • As appropriate, we may transmit or grant access to certain of your personal data to the following categories of recipients:
    • companies within the same group of companies as MYGRACE;
    • courier service providers;
    • payment/banking service providers;
    • marketing / telemarketing service providers;
    • market research service providers;
    • insurance companies;
    • IT service providers;
    • other companies with whom we may develop joint programs for offering our goods and services on the market.
  • If we have a legal obligation or if it is necessary to defend a legitimate interest, we may also disclose certain personal data to public authorities.
  • We ensure that access to your data by third-party private legal entities is carried out in accordance with legal provisions regarding data protection and information confidentiality, based on contracts concluded with them.

7. TO WHICH COUNTRIES DO WE TRANSFER YOUR PERSONAL DATA?

  • Currently, we store and process your personal data in Romania.
  • However, we may transfer certain of your personal data to entities located in the European Union or outside the Union, including to countries that the European Commission has not recognized as having an adequate level of personal data protection.
  • We will always take measures to ensure that any international transfer of personal data is carefully managed to protect your rights and interests. Transfers to service providers and other third parties will always be protected by contractual commitments and, where appropriate, by other safeguards, such as: standard contractual clauses issued by the European Commission or certification schemes, such as the Privacy Shield for the protection of personal data transferred from within the EU to the United States of America.
  • You can contact us at any time, using the contact details provided above, to find out more information about the countries to which we transfer your data.

8. HOW DO WE PROTECT THE SECURITY OF YOUR PERSONAL DATA?

  • We are committed to ensuring the security of personal data by implementing appropriate technical and organizational measures, in accordance with industry standards.
  • The transmission of your personal data is done using state-of-the-art encryption algorithms, and the data is stored on secure servers, while ensuring data redundancy.
  • Despite the measures taken to protect your personal data, we draw your attention to the fact that the transmission of information via the Internet, in general, or through other public networks, is not completely secure, there being a risk that data may be seen and used by unauthorized third parties. We cannot be held responsible for such vulnerabilities of systems that are not under our control.

9. WHAT ARE YOUR RIGHTS?

  • The General Data Protection Regulation recognizes a series of rights regarding your personal data. You can request access to your data, correction of any errors in our files, and/or you can object to the processing of your personal data. You can also exercise your right to complain to the competent supervisory authority or to address the courts. As appropriate, you may also benefit from the right to request the erasure of your personal data, the right to restriction of processing of your data, and the right to data portability.
  • More information about each of these rights can be obtained by consulting the section presented below.
    Rights concerned Description
    Right of access to processed data

    You can ask us to:

    ·         confirm whether we process your personal data;

    ·         provide you with a copy of this data;

    ·         provide you with other information about your personal data, such as the data we hold, what we use it for, to whom we disclose it, whether we transfer it abroad and how we protect it, how long we keep it, what rights you have, how you can make a complaint, where we obtained your data, to the extent that the information has not already been provided to you through this information.
    Right to rectification You can ask us to rectify or complete your inaccurate or incomplete personal data. We may try to verify the accuracy of the data before rectifying it.
    Right to erasure (right to be forgotten)

    You can ask us to erase your personal data, but only if:

    ·         they are no longer necessary for the purposes for which they were collected; or

    ·         you have withdrawn your consent (where data processing was based on consent); or

    ·         you exercise a legal right to object; or

    ·         they have been unlawfully processed; or

    ·         we have a legal obligation to do so.

    We are not obligated to comply with your request for erasure of personal data if the processing of personal data is necessary:

    ·         for compliance with a legal obligation; or

    ·         for the establishment, exercise, or defense of a legal claim.

    There are certain other circumstances where we are not obligated to comply with your request for erasure of data, although these two are the most probable circumstances in which we might refuse such a request.
    Right to restriction of processing

    You can ask us to restrict the processing of personal data, but only if:

    ·         their accuracy is contested (see the rectification section), to allow us to verify their accuracy; or

    ·         the processing is unlawful, but you do not want the data to be erased; or

    ·         they are no longer necessary for the purposes for which they were collected, but you need them to establish, exercise, or defend a legal claim; or

    ·         you have exercised your right to object, and the verification of whether our rights prevail is ongoing.

    We may continue to use your personal data following a request for restriction, if:

    ·         we have your consent; or

    ·         for the establishment, exercise, or defense of a legal claim; or

    ·         to protect the rights of GODDESS INTERNATIONAL or another natural or legal person.
    Right to data portability

    You can ask us to provide you with your personal data in a structured, commonly used, and machine-readable format, or you can request that it be "ported" directly to another data controller, but in each case only if:

    ·         the processing is based on your consent or on the conclusion or performance of a contract with you;

    and

    ·         the processing is carried out by automated means.
    Right to object You may object at any time, for reasons related to your particular situation, to the processing of your personal data based on our legitimate interest, if you consider that your fundamental rights and freedoms outweigh this interest. You may also object at any time to the processing of data for direct marketing purposes (including profiling), without invoking any reason, in which case we will cease this processing as soon as possible.
    Right not to be subject to a decision based solely on automated processing

    You may request not to be subject to a decision based solely on automated processing, but only when that decision:

    ·         produces legal effects concerning you; or

    ·         significantly affects you in a similar manner.

    This right does not apply if the decision reached through automated decision-making:

    ·         is necessary for us to enter into or perform a contract with you;

    ·         is authorized by law and there are adequate safeguards for your rights and freedoms; or

    ·         is based on your explicit consent.
    Right to withdraw consent We address this issue of consent withdrawal in the context where personal data is processed solely based on previously expressed consent, which can be withdrawn at any time. Withdrawing consent leads to the automatic deletion of personal data, except in situations where data processing cannot cease due to the company's legitimate reasons (for example, for court proceedings).
    Right to lodge a complaint with the National Supervisory Authority for Personal Data Processing

    You have the right to lodge a complaint with the supervisory authority regarding the processing of your personal data. In Romania, the contact details of the data protection supervisory authority are as follows: National Supervisory Authority for Personal Data Processing at Bulevardul General Gheorghe Magheru, no. 28-30, Sector 1, postal code 010336, Bucharest, Romania; Phone: +40.318.059.211 or +40.318.059.212; Email: anspdcp@dataprotection.ro.

    Without affecting your right to contact the supervisory authority at any time, please contact us beforehand and we promise to make every effort to resolve any issue amicably.
  • To exercise your rights, you can contact us using the contact details provided above. Please note the following if you wish to exercise these rights:
    • We take the confidentiality of all records containing personal data seriously. For this reason, please send us your requests regarding such records using the email address associated with your MYGRACE account. Otherwise, we reserve the right to verify your identity by requesting additional information aimed at confirming your identity.
    • We will not charge a fee for exercising any right regarding your personal data, unless your request for access to information is unfounded, repetitive, or excessive, in which case we will charge a reasonable amount in such circumstances. We will inform you of any fees applied before processing your request.
    • Response time. We aim to respond to all valid requests within a maximum of one month, unless this is particularly complex or if you have made multiple requests, in which case we will respond within a maximum of two months. We will notify you if we need more than one month. We may ask you if you can tell us exactly what you want to receive or what concerns you. This will help us act faster and shorten the response time to your request.
    • Third-party rights. We are not obliged to comply with a request if it would adversely affect the rights and freedoms of other data subjects.

10. CONTACT DPO (Data Protection Officer)

  • We remind you that you can contact the MYGRACE Data Protection Officer at any time by sending your request through any of the following methods:
  • by email at: protectia.datelor@mygrace.ro or
  • by post or courier at: Bucharest, Sector 3, Splaiul Unirii, no. 313, building M, 2nd floor, MYGRACE - with the mention "for the attention of the Data Protection Officer within MYGRACE".