We consider ensuring the right to the protection of personal data a commitment of Digital Native Marketing SRL, therefore we will devote the necessary resources and effort to process your data in full accordance with Regulation (EU) 2016/679 (“General Data Protection Regulation” or “GDPR”), as well as with any other legislation applicable on the territory of Romania.

As one of the essential principles of this legal framework is transparency, we have prepared this document to inform you about how we collect, use, transfer and protect your personal data when you interact with us in relation to our products and services including through our website or mobile phone applications.

We reserve the right to periodically update and amend this Privacy Policy, without prior notice, to reflect any changes in the way we process your personal data or any changes in legal requirements. In case of any such change, we will display on our website the modified version of the Privacy Policy, which is why we ask you to periodically check the content of this Privacy Policy.

This document is intended to inform you about the processing of your personal data, in the context of the use of the website www.digitalantive.ro.(the “Site”)

Categories of personal data processed

1. If you are a customer or user of this Website, SC Digital Native Marketing SRL may process your personal data, such as name and surname, telephone, e-mail address, billing address, delivery address, data regarding to the way you use the Site, for example your behavior/preferences/habits, as well as any other categories of data that you provide directly in the context of creating a user account, in the context of placing an order through the Site or in any other way resulting from the use of the Site.

If you use your Facebook or Google account to create a user account on the Site, SC Digital Native Marketing SRL processes the following public profile data displayed by the respective applications: username, e-mail address.2. If you are a visitor to the Site SC Digital Native Marketing SRL will process your personal data that you provide directly in the context of using the Site, such as the data that you provide in the contact section, in the extent to which you contact us in this way

.Who we are and how you can contact us

The website www.digitalnative.ro is the property of SC. Digital Native Marketing SRL.Digital Native – is the commercial name of Digital Native Marketing SRL, a legal entity of Romanian nationality, with its registered office in Romania, Bucharest City, Str. Neagoe-Voda 12-16, Bl. 9/2, sc. B, Apartment 31, Room 1, Int. 31, Sector 1, having order number in the Trade Register J40/3623/2021, unique fiscal registration code 43824383.

Accessing this site or any part of this site implies tacit agreement with the terms and conditions presented on the site as well as with the cookie policy and the privacy policy. Acceptance of the terms and conditions as well as of all the policies present on the site is considered tacit, complete and without reservations.As we are always open to your opinions, as well as to provide you with any additional information you may need regarding the processing of your data, we encourage you to contact us at – hello@digitalnative.ro

What categories of personal data we process

We generally collect your personal data directly from you, so you have control over the type of information you give us. By way of example, we receive information from you as follows:

• When you create an account on the platform located at digitalnative.ro or the subdomains of this address, you send us: e-mail address, name and surname;
• Within your personal page (My Account) on the DigitalNative platform you can add additional information, such as: nickname, mobile phone number, landline number, delivery addresses, alternative email address, etc.;

We may also collect and further process certain information about your behavior while visiting our website or using our smartphone app, in order 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 regarding the purposes of processing below.

On our website and smartphone application we may store and collect information in cookies and similar technologies, according to the Cookie Policy.We do not collect or otherwise process sensitive data, included by the General Data Protection Regulation in special categories of personal data. We also do not wish to collect or process data of minors under the age of 18.

What are the purposes and grounds of the processing

We will use your personal data for the provision of digitalnative.ro services for your benefit.

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

• Creating and managing the account within the digitalnative.ro platform;
• Order processing, including their receipt, validation, dispatch and invoicing;
• Solving cancellations or problems of any nature related to an order, goods or services purchased;
• Returning the products according to the legal provisions;
• Reimbursement of the consideration for products and services according to legal provisions;
• Providing support services, including providing answers to your questions regarding your orders or digitalnative.ro services through the dedicated platform.

The processing of your data for these purposes is in most cases necessary for the conclusion and performance of a contract between DigitalNative and you. Also, certain processing subsumed for these purposes is required by applicable law, including tax and accounting law.

To improve our services

We always want to offer you an online experience of the highest quality by using the online platform located at digitalnative.ro or on its subdomains. For this, we may collect and use certain information related to your Shopping behavior, we may invite you to complete satisfaction surveys following the completion of an order, or we may conduct, directly or with the help of partners, studies and market research.We base these activities on our legitimate interest in carrying out commercial activities, always taking care that your fundamental rights and freedoms are not affected.

For marketing purpose

We want to keep you informed about the best offers of Digital Native Marketing for the products / services that interest you. In this regard, we may send you any type of message (such as: e-mail / SMS / telephone / mobile push /webpush / etc.) containing general and thematic information, information regarding products similar to or complementary to those we you have purchased them, information about offers or promotions, information about products added to the “Account/My Basket” section or the “Account/Favorites” section or you have shown interest in purchasing them, as well as other commercial communications such as surveys market and opinion polls, and we may display personalized recommendations on the website and smartphone app.

In order to provide you with information of interest to you, we may use certain data regarding your purchasing behavior (e.g. products viewed / added to wishlist / purchased) to create a profile for you. We always ensure that this processing is carried out with respect for your rights and freedoms and that the decisions made on the basis of them do not have legal effects on you and do not similarly affect you to a significant extent.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:

• Changing the settings regarding the subscriptions made
• Accessing the unsubscribe link displayed in the messages you receive from us; or by contacting DigitalNative using the contact details described above.

In certain situations, we may base our marketing activities on our legitimate interest in promoting and developing our business. 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.

How long we keep your personal data

As a general rule, we will store your personal data as long as you have an account on the DigitalNative.ro platform or for a period of 2 years from the conclusion of the contractual commitments. You may request that we delete certain information or close your account at any time, and we will comply with such requests, subject to the retention of certain information including after account closure, where applicable law or our legitimate interests require it.

To whom we transmit your personal dataAs appropriate, we may transmit or provide access to certain of your personal data to the following categories of recipients:

• companies within the same group of companies as DigitalNative.ro
• courier service providers;
• payment/banking service providers;
• marketing / telemarketing service providers;
• IT service providers;
• other companies with whom we can develop joint programs for offering our goods and services on the market.
• to DigitalNative.ro Employees and Collaborators for the purpose of realizing the object of the contract between you and Digital Native.If we are under 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 legal entities under private law is carried out in accordance with the legal provisions on data protection and information confidentiality, based on contracts concluded with them.

To which countries we transfer your personal data

Currently, we store and process your personal data only on the territory of Romania. However, we may transfer certain of your personal data to entities located in the European Union or outside the Union, including countries that have not been recognized by the European Commission as having an adequate level of personal data protection.

We will always take steps to ensure that any international transfer of personal data is handled carefully to protect your rights and interests. Transfers to service providers and other third parties will always be protected by contractual commitments and, where applicable, 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 set out above to find out more about the countries to which we transfer your data and the safeguards we have put in place in relation to those transfers.

How we protect the security of your personal data

We are committed to ensuring the security of personal data by implementing dedicated technical and organizational measures.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.Despite the measures taken to protect your personal data, we draw your attention to the fact that the transmission of information over the Internet in general or through other public networks is not completely secure, there is a risk that the data will be seen and used by third parties unauthorized parties. We cannot be responsible for such vulnerabilities of systems that are not under our control.

What rights do you have?

The General Data Protection Regulation recognizes a number of rights in relation to your personal data. You can request access to your data, correct any mistakes in our files and/or object to the processing of your personal data. You can also exercise your right to complain to the competent supervisory authority or go to court. If applicable, you may also benefit from the right to request the deletion of your personal data, the right to restrict the processing of your data and the right to data portability.In order to exercise your rights, you can contact us using the contact details set out above.

Please note the following points if you wish to exercise these rights:

Identity

We take the privacy of all records containing personal data seriously. For this reason, please submit your requests regarding such records to us using the email address associated with your DigitalNative account. Otherwise, we reserve the right to verify your identity by requesting additional information aimed at confirming your identity.Response timeWe aim to respond to any valid requests within a maximum of 30 days, unless this is particularly complicated or you have made multiple requests, in which case we will respond within a maximum of two months. We will let you know if we need more than a month. We may ask if you can tell us exactly what you want to receive or what you are concerned about. This will help us act faster and shorten the response time to your request.

Third Party Rights.

We must not comply with a request if it would adversely affect the rights and freedoms of other data subjects.

Entitled rights access

You can ask us:to confirm whether we are processing your personal data;to provide you with a copy of this data; to provide you with other information about your personal data, such as what data we have, what we use it for, who we disclose it to, 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 by this notice.

Rectification

You can ask us to correct or complete your inaccurate or incomplete personal data. We may attempt to verify the accuracy of the data before rectifying it.

Delete data

You can ask us to delete your personal data, but only if:they are no longer necessary for the purposes for which they were collected; oryou have withdrawn your consent (if the data processing was based on consent); orexercise a legal right to object; orthey have been processed illegally or we have a legal obligation to do so.

We are not obliged to comply with your request to delete your personal data where the processing of your personal data is necessary:to comply with a legal obligation or to establish, exercise or defend a right in court.There are certain other circumstances in which we are not obliged to comply with your data deletion request, although these two are the most likely circumstances in which we may refuse your request

Please bear in mind that, before exercising this right, you download from your DigitalNative account and save all documents related to the orders made from Digital Native, regardless of whether the invoice was made to you or to another natural or legal person (such as : invoices, warranty certificates, necessary documentation, etc.). If you do not do this before exercising your right of deletion, you will lose all these documents and DigitalNative will be unable to make them available to you, as the case may be, because the process of deleting the data, respectively the DigitalNative account , with all the data and documents related to it, is an irreversible process.

Restriction of data processing

You can ask us to restrict the processing of your personal data, but only if:their accuracy is disputed (see rectification section), to enable us to verify their accuracy; or the processing is illegal, but you do not want the data to be deleted; or 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 you have exercised your right to object and checking whether our rights prevail is ongoing. We may continue to use your personal data following a restriction request if: we have your consent; or to as certain, exercise or ensure the defense of a right in court; or to protect the rights of DigitalNative or another natural or legal person.

Data portability

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

the processing is based on your consent or the conclusion or performance of a contract with you; and the processing is done by automatic means.

Opposition

You can object at any time, for reasons related to your particular situation, to the processing of your personal data on the basis of our legitimate interest, if you consider that your fundamental rights and freedoms prevail over this interest.You can also object to the processing of your data for direct marketing purposes (including profiling) at any time without giving any reason, in which case we will stop this processing as soon as possible.

Automated decision making

You can ask not to be the subject of a decision based solely on automated processing, but only where that decision:produce legal effects with respect to you; oraffects you in another similar and significant way.This right does not apply if the decision reached by automated decision-making:it 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.

Claims

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 supervisory authority for data protection are as follows:The National Supervisory Authority for the Processing of Personal Data G-ral Blvd. Gheorghe Magheru no. 28-30, Sector 1, postal code 010336, Bucharest, Romania Telephone: +40.318.059.211 or +40.318.059.212; E-mail: anspdcp@dataprotection.ro

Without prejudice to your right to contact the supervisory authority at any time, please contact us in advance, and we promise to make every effort to resolve any problem amicably.