Privacy Policy

Consent and Minimum Age

By continuing to use the Website, you declare and confirm that you are at least 18 years old, have fully read and understood the Privacy Policy, the Cookie Policy, and consent to the processing and use of your personal data ("Personal Data"), in accordance with the aforementioned policies.

The parent or legal guardian is obliged to read the Privacy Policy, Cookie Policy and give their unvitiated, express and freely given consent to the processing of their personal data (as well as the minor's), in accordance with the provisions indicated in the Privacy Policy. We reserve the right to verify the existence of consent from the parent or legal guardian, using reasonable measures. The mentioned persons are responsible for the protection of the minor's personal data.

If one of the parents or the legal guardian of the minor believes that the minor's personal data has reached us without the necessary consent, the parent or legal guardian has the right to exercise one of the rights mentioned in the Privacy Policy.

Policy Updates

We reserve the right to periodically review and update the Privacy Policy to reflect any changes in our operations and how we process your personal data, or any changes related to legal requirements. In the event of any such changes, we will display the updated version of the Privacy Policy on the Website.

Data Controller for Personal Data Processing

For the purposes described below, SLAVENA LUX SRL acts as a personal data operator, unless otherwise explicitly provided in the Privacy Policy.

To exercise your rights regarding the Privacy Policy, please contact us using the following contact details:

Principles of Personal Data Protection

To ensure that the processing of your personal data complies with applicable personal data protection legislation, we base our processing operations on the following basic principles:

• Personal data collection will only be carried out for specified, explicit, and legitimate purposes.
• Data will not be processed by third parties in a manner incompatible with these purposes.
• Personal data will be accurate and up-to-date (if necessary).
• Personal data processing will be done in a legal, fair, and transparent manner.
• All personal data will be kept confidential and stored in a highly secure manner.
• Personal data will not be transferred to third parties, including outside the Republic of Moldova, unless this is necessary for effective response to your feedback.
• Individuals whose data is processed have the right to information, access, rectification, objection, processing restriction, erasure, data portability, challenge, non-submission to an automated individual decision, justice.

Sources of Personal Data Collection

We collect your personal data:

• Directly from You: if you contact us using the feedback form placed on the Website, in order to accept your feedback (comments, suggestions, etc.)
• Indirectly from You: at the stage of accessing the Website through automated collection of data about your device, usage data, session data, and traffic data to ensure the correct functionality of the Website and your interaction with its content.

We do not process your personal data beyond what is necessary for providing our services, in accordance with the provisions of the Privacy Policy below.

Basis, Categories, and Purpose of Personal Data Collection

Personal data means any information that can be linked to an identified or identifiable natural person, and which can directly or indirectly lead to the identification of the data subject.

Your personal data may be collected directly from you or automatically, if it refers to your device, traffic, session, and Website usage.

Your personal data is collected and processed only with your unvitiated, express, and freely given consent at the stage of submitting your feedback.

Processed Personal Data

The personal data processed by us include:

Purposes of Processing

The following are the purposes for which we collect your personal data:

• To receive/respond to your feedback: Name, Surname, Email, Phone (mobile or landline), Feedback (comments, suggestions, etc.)
• To ensure correct Website functionality: Usage and/or session data, Traffic data, Data about the device used

Specific Details of Messages Sent by Us and Direct Marketing Activities

We may send you messages in response to feedback received from you, using SMS and/or your email provided via the feedback form. In this regard, our messages will not be direct marketing in nature and will not be sent for the purpose of sending promotional offers. In any other case, we will not use your personal data for the purpose of sending promotional offers.

Place of Processing and Cross-border Transfer of Personal Data

Currently, we store and process your personal data in the territory of the Republic of Moldova on servers belonging to us and/or our partners. We do not perform cross-border transfer of your personal data.

Storage and Processing Period of Personal Data

Your personal data is processed for the period necessary to achieve the purposes for which it was collected.

Thus, the personal data processing period is:

• For receiving and responding to your feedback: 30 days from the moment your feedback is received
• To ensure correct Website functionality: from the moment of accessing the Website until the moment you close the Website
• For fulfilling the prescriptions of competent public authorities: for the period necessary to fulfill the prescriptions
• For realizing a legitimate interest of the operator: for the period necessary to realize such a legitimate interest of the operator

After the expiration of the mentioned terms, personal data is kept in archived form according to current legislation. In exceptional cases, provided by current legislation, we may keep your personal data for a longer period if we are obliged to execute a legal and/or prescribed requirement by competent public authorities, as well as to realize our legitimate interest.

Disclosure of Personal Data

Your personal data will not be disclosed to unauthorized third parties.

However, in accordance with applicable legislation, we may disclose your personal data to the following third parties:

• your legal representatives
• central/local public authorities, if disclosure is due to a legal obligation (e.g., criminal investigation bodies, state tax service, etc.)
• our contractual partners (e.g., partners to whom your feedback partially refers)
• providers of legal representation services (e.g., lawyers, legal consulting firms)

In this regard, we implement appropriate technical and organizational measures necessary for the legal, compliant, and secure disclosure of your personal data to third parties, and we ensure that your personal data is subsequently processed in strict compliance with the purposes for which it was transmitted to third parties.

Protection and Security of Personal Data

We are committed to ensuring the security of personal data by implementing appropriate technical and organizational measures for processing data in electronic format. The transmission of your personal data is done using state-of-the-art encryption algorithms, and we store it on secure servers, while ensuring data redundancy.

Your Rights Regarding Personal Data Processing

In accordance with Articles 12-18 of Law on Personal Data Protection No. 133 of 08.07.2011, you are a data subject and have the following rights:

• Right to be informed: you can obtain information about data processing
• Right of access: you can access copies of any data that has been collected or obtained by the data controller and/or processor
• Right to rectification: you can request the rectification of inaccurate data, the personal data controller being obliged to correct them
• Right to objection: you can object to how data is managed and request the cessation of further actions
• Right to restriction of processing: you can request the cessation of data processing in a certain way or the complete cessation of further processing
• Right to erasure: you can request the data to be erased as soon as possible by the data controller or by the person empowered
• Right to data portability: you can request access to collected data in a digital format compatible with a variety of devices
• Right to complain: you can address the CNPDCP (National Center for Personal Data Protection) regarding non-compliant data processing by the data controller or processor
• Right to access to justice: you can notify the court for the reparation of any material and/or moral damages caused by the processing of your data