1. Who we are

SC SPALATORIA TEOREMA SRL SRL ( hereinafter „SPALATORIA TEOREMA SRL”, „we”, „us” or similar ) is a limited liability company duly incorporated and registered in Romania, having its registered office at BDUL. GRIVITEI 91, Brasov, Romania, registered with the Trade Registry under no. J08/729/2018, sole registration code RO39124896.
 We collect and process several categories of personal data from you as a user of the website SPALATORIA TEOREMA SRL iOS app, SPALATORIA TEOREMA SRL Android app, and those other mobile applications containing links to this Privacy Policy that are operated by us but branded with the name, trademarks, or service marks of a partner laundry ( the „Applications”), which, in compliance with European Union data protection law, makes us a data controller for such data.

We take your privacy extremely seriously and this notice of personal data processing describes our policies and practices regarding our collection and use of your personal data – such as what data we collect, why we collect it, and what we do with it, and sets forth your privacy rights.

Please read this Privacy Notice carefully to understand how we handle your personal information.
 Unless otherwise defined in this Privacy Policy

2. How we collect your personal data

Personal Data may be collected or accessed in a number of ways, including:

  1. directly from you (from your form input data on the Website or Applications);

  2. observed by us when you navigate on our Website or Applications (cookies, IP, website navigation, etc.);

2.1 Data provided by you directly

As a visitor, you have to submit your name and your telephone number in order to use the Website or Applications. However, in order to use our service, you will need to share your address so that we can determine what services and laundries are available to you.

In addition, personal data that are specifically and voluntarily provided by visitors may be collected through the Website or Applications, as follows:

  1. Our Website and Applications use forms by which you may create an account, that include fields such as first and last name, email address and password.

    We process this data under the legal basis of performing a contract with users, in order to enable you to easily log into our Website or Applications and place orders. This data will be kept for the duration of existence of the user account, until the user deletes the account.

    When you order through our Website or Applications, we might also ask for your delivery address details, telephone number, payment information, and any preferences (e.g. time preferences) you have for your order.

    We process this data under the legal basis of performing a contract with users, in order to:

    1. ensure orders are processed and delivered to you,

    2. communicate with you regarding orders,

    3. take payment and give refunds,

    4. provide you customer care and support,

    5. prevent and detect fraud, and

    6. keep you informed on our services.

  2. This data is stored for the duration of existence of your account.

  3. Our Website and Applications also gives you the ability to send us a message via the contact form and to submit a complaint via the dedicated section. The data that you input in the contact form is processed based in our legitimate interest to respond to your inquiry and/or to keep a record of your complaint, request, and the like. This data is stored for 3 years after resolution of the complaint.

    Please note that user generated content posted through the Website or Applications, such as service reviews and certain social networking posts (e.g. services items you share) may be viewed by the general public. Accordingly, SPALATORIA TEOREMA SRL cannot ensure the privacy of any personal data included in such user generated content.

    When you participate at surveys, competitions and promotions organized via our Website or Applications, we process your data relevant to such event in order to run the event, confirm users’ registration, draw conclusions of surveys and select winners of competitions. This data is stored for 3 years.

    In addition, we can use any of the data indicated at this point 2.1 under our legitimate interest, for providing you with the best appropriate content for the Website or Applications, emails and newsletters, to improve and promote our products and services and for administrative, fraud detection and legal purposes.

    We do not use your data to send you marketing communications unless you expressly opt in for such communication. Even in such cases we make sure that you have an easy to use option to unsubscribe (withdraw your consent) at any time, either in the communication itself or by contacting us as indicated in Section 8.

2.2 Use of the Website and Applications

The Website and Applications collect certain information automatically and store it in log files. The information may include internet protocol (IP) addresses, browser type, operating system and other usage information about the use of the Website or Applications, including a history of the pages you view. We use this information to help us design our site to better suit our users’ needs. We may also use your IP address to help diagnose problems with our server and to administer our Website and Applications, analyze trends, track visitor movements, and gather broad demographic information that assists us in identifying visitor preferences.


3. How we share information

We will disclose your personal data only for the purposes and to those third parties, as described below. We will take appropriate steps to ensure that your personal data are processed, secured, and transferred according to applicable law.

3.1 Disclosure to SPALATORIA TEOREMA SRL group companies

Your personal information may be shared with any company that is a member of our group, where we consider that it is in our legitimate interests to do so for internal administrative purposes (e.g. storage of data, CRM), or for auditing and monitoring of our internal processes.

We may also share your personal information with our group companies where they provide products and services to us, such as information technology systems.

Access to your personal information is limited to those employees who need to know the personal information, and may include their potential managers and their designees, as well as employees in the marketing, information technology and security departments.

3.2 Disclosure to third parties

We will share the strictly necessary parts of your personal data, on a need-to-know basis with the following categories of third parties:

  1. Partner Laundry and Delivery Providers, to whom SPALATORIA TEOREMA SRL shares orders content, special instructions, first and last name, delivery address, and telephone number, to the extent necessary to process those orders

  2. Companies that provide products and services to us (processors), such as:

    1. media agencies, such as those organizing promotional campaigns and those administering the Website or Applications;

    2. analytics, advertising.

    3. infrastructure agencies (other parties that handle the email newsletter, SMS marketing or other kinds of marketing, client support or sales activities in our name);

    4. information technology systems suppliers and support, including email archiving, telecommunication suppliers, backup and disaster recovery and cyber security services.

  3. companies involved in the operation of our Website or Applications, where they are not providing a service for us.

  4. other parties such as public authorities and institutions, accountants, auditors, lawyers and other outside professional advisors, where their activity requires such knowledge or where we are required by law to make such a disclosure.

We will also disclose your personal information to third parties:

  1. If you request or authorize so;

  2. to persons demonstrating legal authority to act on your behalf;

  3. where it is in our legitimate interests to do so to run, grow and develop our business:

    1. if we sell any business or assets related to the Website or Applications you are subscribing to, we may disclose your personal information to the prospective buyer of such business or assets, in order to ensure that the activity continues as a going concern;

    2. if SPALATORIA TEOREMA SRL or substantially all of its assets are acquired by a third party, in which case personal information held by SPALATORIA TEOREMA SRL will automatically be one of the transferred assets;

  4. if we are under a duty to disclose or share your personal information in order to comply with any legal obligation, any lawful request from government officials and as may be required to meet national security or law enforcement requirements or prevent illegal activity;

  5. to respond to any claims, to protect our rights or the rights of a third party, to protect the safety of any person or to prevent any illegal activity; or

  6. to protect the rights, property or safety of SPALATORIA TEOREMA SRL, our employees, customers, suppliers or other persons.

Some of these recipients (including our affiliates) may use your data in countries which are outside of the European Economic Area. Please see Section 4 below for more detail on this aspect.

3.3 Restrictions on use of personal information by recipients

Any third parties with whom we choose to share your personal information pursuant to the above are limited (by law and by contract) in their ability to use your personal information for the specific purposes identified by us. We will always ensure that any third parties with whom we choose to share your personal information are subject to privacy and security obligations consistent with this Privacy Notice and applicable laws. However, for the avoidance of doubt this cannot be applicable where the disclosure is not our decision.

Save as expressly detailed above, we will never share, sell or rent any of your personal information to any third party without notifying you and, if applicable, obtaining your consent.

4. Transfers of information outside of the European Union

The personal information may be processed by staff operating outside the EEA working for us, other members of our group or third-party data processors for the purposes mentioned above.

If we provide any personal information about you to any such non-EEA members of our group or third-party data processors, we will take appropriate measures to ensure that the recipient protects your personal information adequately in accordance with this Privacy Notice. These measures include:

Further details on the steps we take to protect your personal information in these cases is available from us on request by contacting us (see section 9 below) at any time.

5. Your rights

As a data subject you have specific legal rights relating to the personal data we collect from you. SPALATORIA TEOREMA SRL will respect your individual rights and will deal with your concerns adequately.

  1. Right to withdraw consent: Where you have given consent for the processing of your personal data, you may withdraw your consent at any moment.

  2. Right to rectification: You may obtain from us rectification of personal data concerning you. We make reasonable efforts to keep personal data in our possession or control which are used on an ongoing basis, accurate, complete, current and relevant, based on the most recent information available to us. In appropriate cases, we provide self-service internet portals where users have the possibility to review and rectify their personal data. For instance, you can edit the name, phone number and email address associated with your account through the Settings menu of our Website or Applications.

  3. Right to restriction: You may obtain from us restriction of processing of your personal data, if

  4. Right to access: You may ask from us information regarding personal data that we hold about you, including information as to which categories of personal data we have in our possession or control, what they are being used for, where we collected them, if not from you directly, and to whom they have been disclosed, if applicable.
     We will provide you with a copy of your personal data upon request and, you can download your data regarding your account, your orders and

  5. Right to portability: As of december 1th 2019, you have the right to receive your personal data that you have provided to us, and, where technically feasible, request that we transmit your personal data (that you have provided to us) to another organization.
     These are rights you have if:

  6. You have the right to receive your personal data in a structured, commonly used and machine-readable format.

    Your right to receive your personal data must not adversely affect the rights and the freedoms of other persons. This may be the case if a transmission of your personal data to another organization also involves the transmission of the personal data of other (non-consenting) individuals.

    Your right to have your personal data transmitted from us to another organization is a right you have if such transmission is technically feasible.

  7. Right to erasure: You have the right to request that we delete the personal data we process about you. We must comply with this request if we process your personal data, unless the data is necessary:

  8. Right to object: You may object – at any time – to the processing of your personal data due to your particular situation, provided that the processing is not based on your consent but on our legitimate interests or those of a third party. In this event we shall no longer process your personal data, unless we can demonstrate compelling legitimate grounds and an overriding interest for the processing, or for the establishment, exercise or defense of legal claims. If you object to the processing, please specify whether you also wish the erasure of your personal data, otherwise we will only restrict it.
     You may always object to the processing of your personal data for direct marketing that was based on our legitimate interest, regardless of any reason. If the marketing was based on your consent, you can withdraw consent.

  9. Right to lodge a complaint: You can lodge a complaint to the data protection supervisory authority:

    Name:

    Autoritatea Națională de Supraveghere a Prelucrării Datelor cu Caracter Personal

    Address:

    B-dul G-ral. Gheorghe Magheru 28-30, Sector 1, cod poștal 010336, București, România

    Telephone:

    +40.318.059.211
     +40.318.059.212

    Fax:

    +40.318.059.602

    Email:

    anspdcp@dataprotection.ro


     Please note:

6. Security

SPALATORIA TEOREMA SRL is committed to protecting personal information from loss, misuse, disclosure, alteration, unavailability, unauthorized access and destruction and takes all reasonable precautions to safeguard the confidentiality of personal information, including through use of appropriate organizational and technical measures. Organizational measures include physical access controls to our premises, staff training and locking physical files in filing cabinets. Technical measures include use of encryption, passwords for access to our systems and use of anti-virus software.

In the course of provision of your personal data to us, your personal information may be transferred over the internet. Although we make every effort to protect the personal information which you provide to us, the transmission of information between you and us over the internet is not completely secure. As such, we cannot guarantee the security of your personal information transmitted to us over the internet and that any such transmission is at your own risk. Once we have received your personal information, we will use strict procedures and security features to prevent unauthorized access to it.

7. Changes to our Privacy Notice 

We reserve the right, at our discretion, to modify our privacy practices and update and make changes to this privacy notice at any time. For this reason, we encourage you to refer to this privacy notice on an ongoing basis. This privacy notice is current as of the date which appears at the top of the document. We will treat your personal data in a manner consistent with the privacy notice under which they were collected, unless we have your consent to treat them differently.

8. Contact information

Please direct your questions regarding the subject matter of data protection and any requests in the exercise of your legal rights to the following contact details: office@spalatoriateorema.ro
 BDUL. GRIVITEI 91, Brasov, Romania.

We will investigate and attempt to resolve any request or complaint regarding the use or disclosure of your personal information.

If you are not satisfied with our reply, you may also make a complaint to the National Supervisory Authority for Processing of Personal Data. You can find further information about the process at: http://dataprotection.ro/?page=procedura_de_solutionare_a_plangerilor