1. WHO WE ARE

We are ALMAZ DESIGN MANAGEMENT SRL ("we", "us", "our") and we are committed to protecting your privacy.

Operator: ALMAZ DESIGN MANAGEMENT S.R.L. ("ALMAZ"), company based in Romania, Bucharest 49-57 Grigore Gafencu Street, GF, space no. 2, sector 1, registered with the Office of the Register of Commerce Bucharest with J40/14813/2013,CUI (RO)32538696 uses the Website almazclothing.com and processes personal data in accordance with the provisions of EU Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to processing of personal data and on the free movement of such data and repealing Directive 95/46/EC ('Regulation')

This privacy policy provides you with information about how we collect and use personal data, the reasons why we collect that information and how we can use and share it.

THE WEBSITE AND SERVICES PROVIDED BY ALMAZ ARE NOT INTENDED FOR USE BY MINORS.

If you have any questions about this privacy policy, including any request to exercise your legal rights, you can contact the ALMAZ data protection officer at the e-mail address: privacy@almazclothing.com.

2. WHAT CATEGORIES OF PERSONAL DATA WE COLLECT AND HOW

When you interact with us, whether you're using our website or communicating through other communication channels, we may collect the following information about you:

2.1 information you provide to us: you can provide us with information about yourself. If you sign up for an account on our website, place an order for products, fill in any online forms (such as registration forms, competitions and surveys), choose to receive our newsletters and offers participate in a competition or promotion, participate in social media functions with our website or correspond with us (via email, phone, instant chat, social media or otherwise).

Based on what you provide, this information may include: your name, address or location, phone number and email address, date of birth, gender, purchase information, shopping preferences, images, and financial information (including your card details. even if we do not keep them, our payment processors do so).

If you register an account on our website, you can choose to give us your photo and choose an alias (your nickname). Using your account, you can invite your friends to shop on our website (including via email, Facebook or Twitter). Although they will be notified that we have received their details from you, please make sure that you have the permission of your friends. before sharing your contact details with us and just sending emails to people you know and who you know agree to this.

2.2 information we receive from other operators: we may receive information about you. from other sources, such as from other accounts of yours, or other websites, including our partners, social media providers such as Facebook and Twitter, advertising networks and analytics partners and payment and delivery service providers.

By logging in to our mobile apps through the Facebook or Twitter platform or by signing in to your Microsoft account from our website to your accounts, by Facebook or Twitter, you grant us permission to obtain certain information from this operator. The specific types of information we can get depend on your account settings. or/or our website and will be subject to their privacy policies.

We supplement the data you provide to us with data from data annexation services, such as data from the public or social chart, to help you submit our promotional offers. We will add this data to the information that exists in our customer account to better understand customer interests and to provide more relevant product recommendations and advertising, to increase our customer's security when we also use our website to comply with our legal obligations, such as sanctions laws. This information may relate to the size of the household, family income or profession. This information may be associated with your personal information. such as your name, email, mailing address, home address or phone number.

ALMAZ does not collect or otherwise process sensitive data included by the Regulation in special categories of personal data. We also do not collect or process data of minors who have not reached the age of 18.

How do we collect your data:

Information that our IT systems collect about you: every time you visit the site, certain information will be created and recorded automatically by our computer systems. This information includes:

1. cookies: You can see more details about cookies in section 5. Cookies can help you improve your browsing experience on our website and facilitate interaction with us. For example: storing your location or language preferences can help you not to return information on your return to our website. It will also help that the products you want to order do not disappear as you browse between the pages on our website. We also use cookies to provide you with personalized advertising;

2. Device information: Information provided by your device depending on the type of device you're using (whether it's a computer, Mac, iPhone, Android or otherwise) and settings on your device, but includes the type of device you have (such as an iPhone 6S or Samsung Galaxy S7), the IP address of the browser, mobile network provider (for mobile devices), pages you've visited, time zone, and location of your country, blocking or downloading error reports.

3. Information we collect directly in our store: ALMAZ always looks for new opportunities to improve your shopping experience. When you visit the ALMAZ store, you may have the opportunity to use pioneering technology to improve your in-store experience. You can also give us information about yourself., in the store if you make a purchase using a credit or debit card, fill out a survey or questionnaire, participate in a competition or a promotion, give us feedback or have other types of interactions with us in the store. If you're using a WiFi-compatible device in the store, certain information may be provided by your device, which will be different depending on your device and settings. The information that can be provided is the type of device you have, the identifier address/access media control address (MAC), the proximity of the device to the access point, the location of the device, and, where applicable, when and for how long the device is connected to the Wi-Fi network. You can stop providing information by turning off Wi-Fi on your device.

3. PURPOSES AND BASIS OF PROCESSING

We will use your personal data. personal data for the following purposes:

1. For the provision of the services you require: processing your personal data necessary for the conclusion and performance of a contract between ALMAZ and you.

2. For the execution of obligations imposed by applicable law, including tax and accounting legislation.

3. To improve ALMAZ services

4. For marketing

5. To defend our legitimate interests

To provide you with the requested services, including to allow you to order and receive ordered products using our website, to manage your account and optimize your experience, we must use the information we collect.

We also use information for marketing and advertising purposes. If you've told us that you want to receive marketing communications or when you've made a purchase using our services, we and our partners will use your information (including name, email address, and address) to occasionally send you updates, news, and offers via email, mail or other media. We may use your information (including additional information received from partners that we attach to our existing customer information as described below) to adapt these messages. You can unsubscribe from our email marketing communications by changing your account profile management preferences. or following the instructions for opting out the promotional emails that are sent to you.

We use third-party service providers to serve ads that are most relevant to you using different devices, our and others' websites and mobile apps. In addition to information about your surfing on our website or about using our mobile app, our service providers may also use information about your interactions with other websites or apps to target ads for products available from ALMAZ or our partners. For information about opting out of target advertising and controlling the use of cookies, see the cookie section of this Privacy Policy.

We also conduct research, analysis and surveys on the use of our website and customer opinions. We're tracking your expenses on ALMAZ website so you can offer our exclusive loyalty programs, such as VIP client.

Finally, we use your personal information to confirm your identity and perform credit checks or anti-fraud checks to ensure your and our financial security.

Please scroll down to find out the detailed purposes for requesting your information, what specific information is collected and the legal basis that allows us to collect this data:

1. For the creation and administration of the ALMAZ customer account, order processing, including their taking over, validation, dispatch and invoicing, to solve problems of any kind relating to an order, goods or services purchased, for the return of products according to the legal provisions and reimbursement of the value of the products according to the legal provisions, for the provision of support services, we collect: name, email, password and other additional details that you want to add them to your account, such as your phone number, delivery addresses, and gender. The legal basis of the processing is the conclusion and execution of a contract with you.

2. For payment of orders we collect: information containing the credit/debit card number, the name of the holder and CVV. This information is not stored by ALMAZ but is transferred only to our authorised payment service providers. The legal basis is the execution of a contract with you.

3. To monitor the quality of our customer service, we collect: name, email address, password and addresses and contact history with us. The legal basis are legitimate interests in the course of our business.

4. To manage, maintain, and optimize our website and our services, we collect: your device information. (e.g. device IP address and device type), cookies, and navigation information. The legal basis are legitimate interests in the course of our business.

5. To carry out fraud and credit checks and if we can do business with you, we collect your name; e-mail; addresses; credit/debit card details; browsing history; shopping history; date of birth; sex; device information (such as IP address and device type), any national identifiers (such as driving licence or identity cards) and any information available to the public (such as profiles or social media news). The legal basis is the legitimate interests of protecting ALMAZ and its customers from fraudulent activities, and we ensure that all the measures we take guarantee a balance between our interests and your rights and freedoms. Fundamental. In certain cases, we also base our processing on legal provisions such as the obligation to ensure the security of property and values provided for by the legislation applicable in this matter.

6. To send you marketing communications and personalized offers and to manage our loyalty programs, we collect your name; e-mail address; phone number; addresses; date of birth; shopping history; browsing history and behavior; information about the device; Shopping preferences cookies; internal identifiers; Country. The legal basis is the consent expressed and the legitimate interests of the direct electronic marketing of products and services similar to those you have acquired using our website provided for in Article 12 of Law 506/2004. You may withdraw your consent at any time by: change the settings in your customer account in the "My subscriptions" section or access the unsubscribe link displayed in the messages you receive from us; OR by contacting ALMAZ using the contact details described above

7. Conducting research, analysis and inquiries regarding the use of our website, we collect: IP address; device information. The legal basis are our legitimate interests in managing our business and improving our website and your experience and this processing will not affect your interests.

8. Targeted advertising and advertising of our products and services and our partners, we collect: email address, cookie identifiers, and device information. The legal basis is mainly represented by your consent but sometimes also by our legitimate interest in carrying out the activity.

In all situations where we ground our marketing activities on our legitimate interest in promoting and developing our business, we take care and take all necessary measures to ensure that your rights are safeguard and are not prejudiced. You can always, by the means described above, stop us processing your data for marketing purposes, and we will comply with your request.

9. To produce aggregated statistical reports, we use your order history, provided that the result of such reports does not identify you. The legal basis is our legitimate interests in carrying out our work and improving our website.

4. TO WHOM YOUR PERSONAL DATA IS SHARED WITH

To provide our website and services, we work with a number of carefully selected third-party partners. To do this, we may share your information with these third parties suppliers and partners in the following limited circumstances:

A. third-party service providers for the performance of the business or for the performance of the contract with you. To work properly, we rely on a number of carefully selected suppliers to provide us with services and products. We must allow these companies to use your information but only to the extent necessary to provide the services and benefit from their products.

Below you can find the types of third parties we use:

• Carrier companies, which we use to deliver your orders. For delivery they must have access to your personal information, including the name and address of delivery. These providers operate globally, with many local companies that can be engaged according to the shipping address;

• The payment service providers we use to process your information, including your credit/debit card details, so that we can collect payment from you. They are based in the European Union, the United States and China and are employed based on your location;

• Analysis and search engine providers such as: Google and Hotjar that we use to help us improve and optimize the website. These suppliers are based in the United States and Europe.

• IT/technology providers we use to support, maintain and provide our technology and IT infrastructure that support our website and store your information. This includes the Linux CentOS we use to host your information and is based in Romania.

• Advertisers for marketing purposes: we can provide your information to our advertising and social media partners (including Facebook and Twitter, where you have a user account) where they require data to select and provide relevant ads about our products and services and to our partners and others;

• Legal provisions compliance: on occasion, we may be obliged to link with various regulators and law enforcement agencies in a number of different countries, either as a result of the law, a court order or another legal process. Although we dispute applications where appropriate, in some cases, we may have to share your information with regulatory authorities or law enforcement agencies. If we consider it appropriate and provided that they are not prohibited by law or by court order, we will try to notify you of these legal requests;

B. aggregated information with third parties: we may aggregate your information with other customers' information, creating a data set of information about the use of our website, purchasing products and other general information, grouped about our customers based on our legitimate interest in understanding the use of the service and demand for our product. Although this dataset is aggregated and anonymized, which means that it cannot identify an individual, provide valuable information on the use of our website and therefore we can share it with selected third parties. These parties may include providers of plugins or similar technologies to help measure traffic, our partners and other suppliers that enable our products and investors to be stored better.

5. TRANSFER OF Personal data

We store and process your personal data on the territory of Romania.

6. COOKIES

For purposes such as displaying custom content, we use cookies or similar technologies. By pressing Accept or browsing this website, you agree to allow the collection of information through cookies or similar technologies. Learn more about cookies in the Cookies section of the Privacy Policy, including the possibility of withdrawing the agreement.

This policy respects the general legal framework on the protection of personal data, explains cookies and details how our users can manage their preferences.

Is it a cookie?

An internet cookie (known as a cookie) is a small file that consists of numbers and letters and which, when you visit a site, is saved in the browser used by you (e.g. Internet Explorer, Chrome, Mozilla, Safari) and stored on your computer, phone, tablet, or any other device through which you access that site. Cookies do not contain software, viruses or spyware and will not access the information on the user's hard drive on whose equipment was installed. Although cookies are stored in the memory of the internet user's device, they cannot access any other information in that device. We use technology like "cookies" to collect information and store your preferences online.

We use the following categories of cookies on our Website:

 • CATEGORY 1: STRICTLY NECESSARY COOKIES These cookies are essential in order to enable you to move around the website and use its features. Without these cookies, services you have asked for such as remembering your login details or shopping basket items cannot be provided.

 • CATEGORY 2: PERFORMANCE COOKIES These cookies collect anonymous information on how you use our Website. For example, we use Google Analytics cookies to help us understand how customers arrive at our site, browse or use our site and highlight areas where we can improve areas such as navigation, shopping experience and marketing campaigns. The data stored by these cookies does not show personal details from which your individual identity can be established. You may opt-in to these cookies using your browser settings.

 • CATEGORY 3: FUNCTIONALITY COOKIES These cookies remember choices you make such as the country you visit our website from, language and search parameters such as size, colour or product line. These can then be used to provide you with an experience more appropriate to your selections and to make the visits more tailored and pleasant. The information these cookies collect may be anonymised and they cannot track your browsing activity on other websites. You may opt into these cookies using your browser settings. 

• CATEGORY 4: TARGETING COOKIES OR ADVERTISING COOKIES These cookies collect information about your browsing habits in order to make advertising more relevant to you and your interests. They are also used to limit the number of times you see an advert as well as help measure the effectiveness of an advertising campaign. The cookies are usually placed by third party advertising networks. They remember the websites you visit, and that information is shared with other parties such as advertisers. For example, we use third party companies to provide you with more personalised adverts when visiting other websites. You may opt-in to these cookies using your browser settings.

 • CATEGORY 5: SOCIAL MEDIA COOKIES These cookies allow you to share what you’ve been doing on the website on social media such as Facebook and Twitter. Please refer to the respective privacy policies for how their cookies work. If you want to delete any cookies that are already on your computer, please refer to the help and support area on your Internet browser for instructions on how to locate the file or directory that stores cookies. Information on deleting or controlling cookies is available at www.AboutCookies.org. Please note that by deleting our cookies or disabling future cookies you may not be able to access certain areas or features of our Website.

You can withdraw your consent to these cookies at any time through the following options:

• Google Analytics cookies across all websites, please visit Google Analytics Opt-out Browser Add-on;

• other third-party cookies relating to behavioural advertising, please go to www.youronlinechoices.eu.

• any other type of cookies, you can clean the cookies through your browser settings.

Accessing and continuing to browse www.almazclothing.com is considered acceptance of this Cookie Policy. If you do not agree to the use of cookies or any provisions of this Policy, you may block any cookies in your browser settings except technical cookies. This will not restrict your access to our website.

If you need more information about using and setting cookie preferences, you can contact us at e-mail: privacy@almazclothing.com.

You can also find more information about cookies on the www.allaboutcookies.org or www.youronlinechoices.com/rowebsite.

Please note that refusing cookies does not mean you will no longer receive online advertising. It does mean that the company or companies from which you opted out will no longer deliver adverts tailored to your web preferences and usage patterns, so you may see a greater number of adverts that are irrelevant to you and your preferences.

7. Security

It is very important for us to keep your data. personal data. We take a number of reasonable steps to try to protect the personal information you provide, including:

• using a Transport Layer Secure (TLS) to encrypt the personal data that you send us during the order process (including any financial information such as credit or debit card details);

• requiring you to establish a unique username and password to access your account on our Website;

• not keeping details of your credit or debit card that would enable any third party to transact using that credit or debit card (such as your CVV number); and

• regularly monitoring our servers and IT systems for possible vulnerabilities and attacks. Unfortunately, despite this, the transmission of information via the Internet is not completely secure. We cannot guarantee the security of your personal data transmitted to or through our Website, and any such transmission is at your own risk. In particular, please keep in mind that if you voluntarily disclose personal information through other means of communication than the Website in a non-protected environment (such as through email, sms, online messages) then that information can be collected and used by others outside of our or your control. 

8. HOW LONG DO WE KEEP YOU DATA

We keep your data as long as you have your microsoft account active. with us and subsequently for a period of 5 years, in which you may have questions or complaints about our services, or for a longer retention period in the case of data for which we are obliged to comply with them in accordance with the applicable legal requirements.

In some circumstances you may ask us to delete your data as below screenshot shown.

Once you have completed the use of our services, we may store your information in an aggregated and anonymised format.

9. YOUR RIGHTS

The Regulation provides for your rights. Please note the following points if you wish to exercise these rights:

1. To maintain the confidentiality of all records containing personal data, please send us your requests, using the email address registered on your ALMAZ account. Otherwise, we reserve the right to verify your identity by requesting additional information aimed at confirming your identity. When you have appointed someone else to make the request on your behalf, that person and/or organization must present us with a valid written authorization issued by you.

2. We will not charge a fee to exercise any right to you in respect of your personal data, unless your request is not legitimate, repetitive or excessive, in which case we will charge a reasonable amount in such circumstances. We will inform you of any fees applied before you resolve your request.

3. We would like to respond to any valid requests within a maximum of one month, unless this is particularly complicated or if you have made several requests, in which case we are going to respond within a maximum of two months. We'll let you know if we need more than a month. We may ask you if you can tell us exactly what you want to receive or what you are worried about. This will help us act faster and shorten the response time to your request.

Rights of the data subject:

1. Right of access- you can ask us to: confirm that 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 have, what we use, to whom we disclose it, if we transfer them abroad and how we protect them, 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. You can also request a written copy of your personal information. If you need more than one copy of the data we have about you, we may charge a reasonable administration fee.

2. Right of rectification- you may request that we correct or complete your inaccurate or incomplete personal data. We may try to verify the accuracy of the data before correcting them. Please note that while assessing whether the personal data we hold about you is not valid are inaccurate or incomplete, you may exercise the right to restrict the processing of applicable data as described below.

3. Withdrawal of consent- you may withdraw your consent at any time by changing your preferences from "My Account" or by unsubscribing to the bottom of each received email or by writing by email as shown below.

4. Right to delete data- you have the right to request that we delete your personal data. This is possible to the extent and only if: they are no longer necessary for the purposes for which they were collected; or you have withdrawn your consent (if the processing is based on consent); or exercise a legal right to object; or data have been illegally processed; or we have a legal obligation to do so. Please keep in mind that erasure of personal data is not possible where the processing of your personal is necessary: in order to comply with a legal obligation or for the establishment, exercise or defence of a right in court, or for other circumstances in which we are not obliged to comply with your request.

Please consider and save all documents related to orders made from ALMAZ before requesting the deletion of your personal data, regardless of whether the invoicing was made to you or to another natural or legal person (such as: invoices, warranty certificates). If you do not do this before exercising your right to delete, you will lose all these documents and ALMAZ will be unable to provide them, as appropriate, because the process of deleting the data, respectively the ALMAZ account , with all the data and documents related thereto, is an irreversible process.

5. Right to restrict data processing- in the event of a dispute regarding the correctness of the processing of your personal data, you may request restriction of the processing but only if: (1) the accuracy of the data processed by us is contested (by application for rectification) in order to enable us to verify their accuracy; or (2) processing is illegal (according to a court decision), but you do not want the data to be deleted; or (3) they are no longer necessary for the purposes for which they were collected, but you need them to establish, exercise or defend a right in court; or (4) you have exercised your right of opposition to processing - for the verification period if our rights prevail. We specify that we will continue to use your personal data following a request for restriction, if: we have your valid consent expressed; or to establish, exercise or defend a right in court; or to protect our or other natural or legal rights.

6. Data portability: You can ask us to provide you with personal data in a structured, commonly used and readable format, or you can request that it be "ported" directly to another data controller you indicate to us. We may only comply with your request if: processing is based on your consent. or on the conclusion or performance of a contract with you; processing is done automatic.

7. Opposition: You can object at any time to the processing of your personal data under our legitimate interest, if you consider that your rights and freedoms are not observed and fundamental rights prevail over this interest. You may always object to the processing of your personal data for direct marketing purposes (including profiling), without invoking any reason, in which case we will cease this processing as soon as possible. You can do this by changing your preferences in "My Account" or by selecting "unsubscribe" at the bottom of every marketing email we send you. Please note that you will still receive emails related to the orders you make through our website or updates to our Terms and Conditions and privacy policy.

8. Automatic decision-making: You may ask not to be the subject of a decision based solely on automatic processing, but only when that decision: produces legal effects with respect to you; or otherwise affects you similarly and to a significant extent.

This right does not apply if the decision reached following automatic decision-making: we are required to conclude or conduct a contract with you; is authorised by law and there are adequate safeguards for your rights and freedoms; or based on your explicit consent.

To exercise any of your rights, please contact us at the address indicated in section 11.

10. ACCESSING LINKS TO THIRD-PARTY WEBSITES

Our website may contain links to and from other websites, from advertisers or collaborators. If you access a link to any of these websites, please note that this Privacy Policy does not apply to those websites and that ALMAZ does not process personal data in common with such websites.

We cannot guarantee the security of these sites and are not responsible for the privacy policies or practices of these websites, so please check their policies before sending personal data on those websites.

11. COMPLAINTS

If you have any questions or concerns about this Privacy Policy, please contact us:

• by sending us an email to: privacy@almazclothing.com or

• by writing to the data protection officer at: Bucharest str. Grigore Gafencu 49-57 ground floor commercial space no. 2, sector 1,

Supervisory Authority: also if your request has not been resolved or you are still dissatisfied, you may submit a complaint to the National Supervisory Authority for Processing of Personal Data (http://www.dataprotection.ro/)

12. UPDATES TO THIS POLICY

We reserve the right to update and periodically modify this Privacy Policy so that it reflects any changes to how we process your personal data or any changes to the legal requirements Mandatory.

In the event of a change, the Privacy Policy will be displayed on our website in the modified version. Please check the contents of this Privacy Policy periodically.