Principles of personal data processing

PELEK Distribution s.r.o.,

with its registered office at: Vlkova 532/8, 13000 Prague, Czech Republic,

ID: 26719941, email: info@pelek.ro, tel.: +420 705 724 353 (hereinafter referred to as “Controller ")

for the sale of goods through an online store operated by pelek.ro called PELEK Distribution s.r.o.

The protection of personal data is very important to us. The purpose of this document is to familiarize you with all the information related to the processing of your Personal Data if you use the Online Store on the online store pelek.ro;. We recommend that you read this Privacy Policy. If you have any further questions regarding the processing of your personal data, please contact us by email at info@pelek.ro.

Definition. For greater clarity and ease of reference, terms that are frequently repeated in this policy are listed in this personal data processing policy:

— Online Store: an online store operated by an administrator named PELEK Distribution s.r.o. through the online store pelek.ro;

— GDPR: Regulation (EU) 2016/679 of the European Parliament and of the Council;

— Personal Data: any information about the User on the basis of which they can be identified directly or indirectly;

— User: the natural person to whom the Personal Data relates, most often will be a customer or prospective customer, also referred to as “you”;

— Processor: carries out personal data processing activities on the basis of a contract or another mandate for the controller;

1. Basic information

Your personal data is collected through the online store pelek.ro; and/or directly by us. In both cases, we may act as the data controller. If your personal data is processed on the online store pelek.ro, please read the Personal Data Processing Policy.

We process the following personal data about you:

— first and last name, contact details (in particular, email address and telephone number), address;

— billing information and bank details (data required for accounting);

— information you provide to us as part of our communication (in particular, your questions and answers to your questions, and communication with you).

We do not process special categories of personal data.

2. The purposes for which we process personal data and the reason for processing

2.1 Execution of the contractual relationship and related legal obligations. The reason for processing Personal Data is the performance of the purchase contract and the related obligations (delivery of goods, accounting, handling complaints, or if you exercise your right to return the goods within the statutory period). We will process your first and last name, contact information (residential address and delivery address, email address, and telephone number), or other billing information. Personal data are processed for the duration of the contractual relationship and thereafter 4 years after its conclusion (here, we are interested in retaining certain Personal Data related to the purchase contract for the purpose of protecting our interests). We are legally required to archive accounting and tax documents. The retention period for this data may be up to 10 years from the end of the tax period in which the service was provided. If necessary for delivery and payment, the Personal Data collected by us will be transferred to an authorized transport company or an authorized credit institution.

2.2 Card payment. If you provide us with your payment card details, we do not have access to the full details. We only know that you are paying by card, and the card data are processed by the recipients of these data, who will process the payment for us.

2.3 Order fulfillment. To process your order, we also cooperate with other service providers (carriers and others) who help us fulfill the contracts concluded. We transfer your data to these partners only for the purpose of fulfilling our obligations under the purchase contract.

2.4 Communications with customer support, complaints, or other inquiries. If you have contacted us, we process your personal data on the basis of your consent for the purpose of handling your inquiry or complaint. We may process the following Personal Data about you: first name, last name, telephone number, email address, information about your order. Closed requests and complaints submitted to customer support are deleted regularly, but no later than 4 years after the inquiry or complaint has been resolved.

2.5 Review. Our customers’ reviews are important to us. We will publish reviews if you give us your consent to do so (submit a review for a specific product or service). We may process the following Personal Data about you: first name, last name, email address, order details. With your express consent, we will also process photographs and Personal Data included in the review text. Reviews are included in the withdrawal of your consent, but for a period of no more than 5 years.

2.6 Customer reviews. You may share your shopping experience and rate individual products. We may use other Processors to evaluate your feedback regarding the individual goods purchased.

2.7 Legal obligations. We may transfer personal data to third parties other than the Processors listed below if required by law or in response to legal requirements from public authorities or at the request of a court in legal disputes.

2.8 Age restrictions. For goods with age restrictions, we verify that you have reached the required minimum age in accordance with applicable legal regulations. For this purpose, we use an identification service that enables us to verify your age.

2.9 Digital products. If it is necessary to update goods with digital elements or digital products, we process the data you provided when placing the order.

3. Communication

3.1 Emails we may send. As part of the sale of our goods or services, we may send customers emails relating to:

3.1.1 delivery notification, delivery date update

3.1.2 tax documents, invoices

3.1.3 provision of a return label.

4. Processors

Your personal data may be transferred to our business partners (Processors) or other third parties if required by law.

We use only verified Processors with whom we have a written contract and who provide us with at least the same guarantees that we provide to you. These are only Processors originating from the European Union or from countries that have been declared and recognized as safe, or from countries with which we have concluded standard contractual clauses in accordance with Article 46 of the GDPR and which provide a comparable level of protection for your personal data as under the GDPR and Czech legal regulations. All of our Processors are bound by confidentiality obligations and may not use the Personal Data provided for purposes other than those for which we made it available to them in accordance with these principles.

— Carriers (see section 2.1 Performance of the contractual relationship and related legal obligations):

Czech Post, PPL, DPD, WEDO, Zasilkovna, Balikovna, GLS

— Order processing (see section 2.1 Fulfillment of the contractual relationship and related legal obligations): Pelek.ro, BaseLinker

— Accounting (see section 2.1 Performance of the contractual relationship and related legal obligations):

A BRA

  1. What are your rights?

Where to contact us? Write to us at info@pelek.ro or at our registered office address.

When will we finish? We will respond to you within no more than one month. If providing the information would jeopardize the privacy of other individuals or would be disproportionate to the risks or costs of providing it, we may be unable to comply with your request. In the case of a repeated request, the controller shall have the right to charge a reasonable fee for a copy of the personal data.

— Right of access. Confirmation of whether we process your personal data. Information about the purposes of processing, the categories of personal data, the recipients to whom they are made available, the processing period, the existence

the right to request that the controller exercise one of the rights listed below. This is provided that the rights and freedoms of other persons will not be adversely affected.

— The right to rectification. Request the correction of inaccurate personal data.

— The right to erasure. If there is no other reason to continue processing this data, we will delete or fully anonymize the data you requested.

— The right to restriction of processing. If you believe that we are processing the data incorrectly - regardless of whether this concerns the purposes or the scope of the processing, please let us know.

— The right to be notified of the rectification, erasure, or restriction of processing. If you contact us with a request, we will inform you of the outcome, unless this is impossible (for example, the email address from which you wrote to us no longer works).

— The right to data portability. At your request, we can provide the data you have provided to us in a structured, machine-readable format to another controller.

— The right to object. If we process your data based on a legitimate interest (for example, sending a newsletter). It is up to us to prove our legitimate interest; if you are right, we will stop this processing.

— The right to withdraw consent. If you have changed your mind, please write to us. Processing related to marketing and commercial purposes may be withdrawn at any time.

— automated individual decision-making, including profiling. You have the right not to be subject to any decision based solely on automated processing, including profiling, which would have legal effects on you or similarly significantly affect you. We respect your rights, so we do not conduct profiling.

6. Conclusion

Please also read the Personal Data Protection Statement on the online store pelek.ro. In this document, you will find more information about when the online store pelek.ro is the controller of personal data and how it manages your data.

This personal data processing policy may be amended only in writing. If you have any questions about our privacy policy, please contact us by email at info@pelek.ro.

If you are not satisfied, you may submit an initiative or complaint at any time to the Office for Personal Data Protection, located at Plk. Sochora 727/27, 170 00 Prague 7 - Holešovice (more about https://www.uoou.cz).

This privacy policy is effective as of 01.01.2024