Privacy Policy
We consider ensuring the right to personal data protection a fundamental commitment of Cigar Master, therefore we will dedicate all necessary resources and efforts to process your data in full compliance with Regulation (EU) 2016/679 ("General Data Protection Regulation" or "GDPR"), as well as with any other applicable legislation in Romania. Since transparency is one of the essential principles of this legal framework, we have prepared this document to inform you about how we collect, use, transfer, and protect your personal data when you interact with us regarding our products and services, including through our website or other mobile applications.
We reserve the right to update and modify this Privacy Policy periodically to reflect any changes in how we process your personal data or any changes in legal requirements. In case of any such modification, we will display the modified version of the Privacy Policy on our website, so please check the content of this Privacy Policy regularly.
Who we are and how you can contact us
Cigar Master is the trade name of ..............................., a legal entity of Romanian nationality, having its registered office in..................., with registration number in the Trade Register ..........., unique tax registration code ............... (hereinafter "Cigar Master" or "we"). For data protection legislation purposes, we are a controller when processing your personal data.
As we are always open to hearing your opinions and providing you with any additional information you may need regarding the processing of your data, we encourage you to contact the Cigar Master Data Protection Officer at the email address gdpr@cigarmaster.ro.
What categories of personal data do we process
In general, we collect your personal data directly from you, so you have control over the type of information you provide to us. For example, we receive information from you as follows:
When you create a Cigar Master account, you provide us with: email address, first name, and last name;
On your personal page (My Account) within the Cigar Master platform, you have the option to add additional information, such as: photo, gender, nickname, mobile phone number, landline phone number, date of birth, education level, delivery addresses, alternative email address, bank card details, etc.;
When you place an order, you provide us with information such as: desired product, first name and last name, delivery address, billing details, payment method, phone number, bank card details, etc.
We may also collect and subsequently process certain information regarding your behavior while visiting our website or using the smartphone application, 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 on processing purposes below.
On our website and in the smartphone application, we may store and collect information in cookies and similar technologies, in accordance with 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 for processing
We will use your personal data for the following purposes:
To provide Cigar Master services for your benefit.
This general purpose may include, as appropriate, the following:
a) Creating and administering your account within the Cigar Master platform;
b) Processing orders, including their receipt, validation, shipment, and invoicing;
c) Resolving cancellations or issues of any nature related to an order, or purchased goods or services;
d) Returning products in accordance with legal provisions;
e) Refunding the value of products in accordance with legal provisions;
f) Providing support services, including answering your questions about your orders or Cigar Master goods and services.
Processing your data for these purposes is in most cases necessary for the conclusion and execution of a contract between Cigar Master and you. Also, certain processing subsumed to these purposes is required by applicable law, including tax and accounting legislation.
For improving our services
We constantly want to offer you the best online shopping experience. For this, we may collect and use certain information related to your Buyer behavior, we may invite you to complete satisfaction questionnaires after completing an order, or we may conduct, directly or with the help of partners, market studies and research.
We base these activities on our legitimate interest in conducting commercial activities, always ensuring that your fundamental rights and freedoms are not affected.
For marketing
We want to keep you informed about the best offers for the products/services you are interested in. To this end, we may send you any type of message (such as: email/SMS/phone/mobile push/webpush/etc.) containing general and thematic information, information about similar or complementary products to those you have purchased, information about offers or promotions, information related to products added to the “Account/My Cart” or “Account/Favorites” sections or that you have shown interest in purchasing, as well as other commercial communications such as market research and opinion polls, and we may display personalized recommendations on the website. To provide you with information of interest to you, we may use certain data about your buyer behavior (e.g., products viewed / added to wishlist / purchased) to create a profile for you. We always ensure that these processing operations are carried out with respect for your rights and freedoms and that decisions based on them do not have legal effects on you and do not significantly affect you in a similar way.
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 in your customer account in the "Subscribe / Unsubscribe Newsletter" section;
– Accessing the unsubscribe link displayed in the messages you receive from us; or by
– Contacting Cigar Master using the contact details described above.
In certain situations, we may base our marketing activities on our legitimate interest in promoting and developing our commercial activity. In any situation where we use information about you for our legitimate interest, we take care and all necessary measures to ensure that your fundamental rights and freedoms are not affected. However, you can always ask us, by the means described above, to stop processing your personal data for marketing purposes, and we will comply with your request.
For the defense of our legitimate interests
There may be situations where we will use or transmit information to protect our rights and commercial activity. These may include:
– Measures to protect the website and users of the Cigar Master platform against cyber attacks:
– Measures to prevent and detect fraud attempts, including transmitting information to competent public authorities;
– Measures to manage various other risks.
The general basis for these types of processing is our legitimate interest in defending our commercial activity, it being understood that we ensure that all measures we take guarantee a balance between our interests and your fundamental rights and freedoms.
Also, in certain cases, we base our processing on legal provisions such as the obligation to ensure the security of goods and assets provided by applicable legislation in this matter.
How long do we keep your personal data
As a general rule, we will store your personal data as long as you have an account on the Cigar Master platform. You can ask us at any time to delete certain information or close your account, and we will comply with these requests, subject to retaining certain information even after the account is closed, in situations where applicable law or our legitimate interests require it.
To whom do we transmit your personal data
As appropriate, we may transmit or provide access to certain personal data of yours to the following categories of recipients:
– companies within the same group of companies as Cigar Master;
– courier service providers;
– payment/banking service providers;
– marketing / telemarketing service providers;
– market research service providers;
– IT service providers;
– other companies with which we may develop joint programs for offering our goods and services on the market.
If we have 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 private legal entities is carried out in accordance with data protection and information confidentiality provisions, based on contracts concluded with them.
In which countries do we transfer your personal data
Currently, we store and process your personal data in Romania.
However, we may transfer some of your personal data to entities located in the European Union or outside the Union, including to countries that the European Commission has not recognized as having an adequate level of personal data protection.
We will always take measures to ensure that any international transfer of personal data is carefully managed to protect your rights and interests. Transfers to service providers and other third parties will always be protected by contractual commitments and, where appropriate, by 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 provided above, to find out more information about the countries to which we transfer your data, as well as the safeguards we have implemented regarding these transfers.
How do we protect the security of your personal data
We are committed to ensuring the security of personal data by implementing appropriate technical and organizational measures, in accordance with industry standards.
The transmission of your personal data is done using state-of-the-art encryption algorithms, and we store them on secure servers, while ensuring data redundancy.
For payments, we use the services of the payment processor ........ Any payment information is encrypted using HTTPS technology with TSL 1.2 encryption.
Despite the measures taken to protect your personal data, we draw your attention to the fact that transmitting information via the Internet, in general, or through other public networks, is not completely secure, and there is a risk that data may be seen and used by unauthorized third parties. We cannot be held responsible for such vulnerabilities of systems that are not under our control.
What rights do you have
The General Data Protection Regulation recognizes a series of rights concerning your personal data. You can request access to your data, correct any errors 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 to appeal to the courts. Where 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.
More information about each of these rights can be obtained by consulting the information presented below.
To exercise your rights, you can contact us using the contact details provided above. Please note the following if you wish to exercise these rights:
Identity
We take the confidentiality of all records containing personal data seriously. For this reason, please send us your requests regarding such records using the email address associated with your Cigar Master account. Otherwise, we reserve the right to verify your identity by requesting additional information aimed at confirming your identity.
Fees
We will not charge a fee for exercising any right regarding your personal data, unless your request for access to information is unfounded, repetitive, or excessive, in which case we will charge a reasonable amount in such circumstances. We will inform you of any fees applied before processing your request.
Response duration
We aim to respond to all valid requests within a maximum of one month, unless this is particularly complex or if you have made several requests, in which case we will respond within a maximum of two months. We will notify you if we need more than one month. We may ask you if you can tell us exactly what you want to receive or what your concern is. This will help us act faster and shorten the response time to your request.
Third-party rights
We are not obliged to comply with a request if it would negatively affect the rights and freedoms of other data subjects.
Affected rights
Access
You can ask us to:
- confirm whether 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 hold, what we use it for, to whom we disclose it, if 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 through this notice.
Rectification
- You can ask us to rectify or complete your inaccurate or incomplete personal data.
We may try to verify the accuracy of the data before rectifying it.
Erasure
You can ask us to erase your personal data, but only if:
- they are no longer necessary for the purposes for which they were collected; or
- you have withdrawn your consent (where data processing was based on consent); or
- you exercise a legal right to object; or
- they have been unlawfully processed; or
- we have a legal obligation to do so.
We are not obliged to comply with your request for the erasure of your personal data if the processing of your personal data is necessary:
- for compliance with a legal obligation; or
- for the establishment, exercise or defense of legal claims.
There are certain other circumstances where we are not obliged to comply with your request for data erasure, although these two are the most likely circumstances in which we might refuse this request.
Please note that before exercising this right, you should download from your Cigar Master account and save all documents related to orders placed with Cigar Master, regardless of whether invoicing was done to you or to another natural or legal person (such as: invoices, warranty certificates). If you do not take this step before exercising your right to erasure, you will lose all these documents and Cigar Master will be unable to provide them to you, as applicable, because the process of deleting data, respectively the Cigar Master account, with all related data and documents, is an irreversible process.
Restriction of processing
You can ask us to restrict the processing of personal data, but only if:
- their accuracy is contested (see the rectification section), to allow us to verify their accuracy; or
- the processing is unlawful, but you do not want the data to be erased; or
- they are no longer necessary for the purposes for which they were collected, but you need them for the establishment, exercise or defense of legal claims; or
- you have exercised your right to object, and the verification of whether our rights prevail is ongoing.
We may continue to use your personal data following a restriction request if:
- we have your consent; or
- for the establishment, exercise or defense of legal claims; or
- to protect the rights of Cigar Master or another natural or legal person.
Data portability
You may ask us to provide you with 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 on the conclusion or performance of a contract with you; and
- the processing is carried out by automated means.
Objection
You may object at any time, on grounds relating to your particular situation, to the processing of your personal data based on our legitimate interest, if you consider that your fundamental rights and freedoms override this interest.
You may also object at any time to the processing of your data for direct marketing purposes (including profiling), without giving any reason, in which case we will stop such processing as soon as possible.
Automated decision-making - You may request not to be subject to a decision based solely on automated processing, but only when that decision:
- produces legal effects concerning you; or
- similarly and significantly affects you in other ways.
This right does not apply where the decision reached following automated decision-making:
- is necessary for us to enter into or perform a contract with you;
- is authorised by law and there are adequate safeguards for your rights and freedoms; or
- is based on your explicit consent.
Complaints
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:
National Supervisory Authority for Personal Data Processing
B-dul G-ral. Gheorghe Magheru no. 28-30, Sector 1, postcode 010336, Bucharest, Romania
Phone: +40.318.059.211 or +40.318.059.212;
Email: anspdcp@dataprotection.ro
Without affecting your right to contact the supervisory authority at any time, please contact us first, and we promise to make every effort to resolve any issue amicably.
We remind you that you can contact the Cigar Master Data Protection Officer at any time by sending your request through any of the following methods:
– by e-mail to: gdpr@cigarmaster.ro
