By this Privacy Policy, ARFAM ACTIVITATE SI RECREERE PENTRU FAMILIE S.R.L. (hereinafter referred to as the Company) undertakes to protect your privacy. Please contact us if you have any questions or concerns regarding the use of your personal data and we will be happy to assist you. 

By using this Website, you agree to the processing of your personal data as described in this Privacy Policy.

This Privacy Policy is an integral part of the procedures and rules that the Company has implemented in order to comply with the requirements of the REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation). By accessing and browsing our Website, it also means that you have become aware of the content of our Privacy Policy, while agreeing to the processing of personal data as per the below stipulations.

The Company may amend this Privacy Policy whenever necessary. If amendments are made, they will be updated via the Website so that you may effectively become aware of the new privacy regulations. If you continue to use the functionalities provided by ARFAM ACTIVITATE SI RECREERE PENTRU FAMILIE S.R.L. by accessing the Website, you agree with such, unless your express consent is required. 

A. Who are we?

The https://www.marsupi.ro Website (hereinafter referred to as the Website) is owned and managed by ARFAM ACTIVITATE SI RECREERE PENTRU FAMILIE S.R.L.

Trade Register No.:  J12/236/1991
Tax Identification Number: RO 200378
Registered office: Mun. Cluj-Napoca, B-dul Constantin Brâncuși, nr. 138/A, jud. Cluj
E-mail: hello@marsupi.ro
Tel./Fax: +40721723978

B. What is personal data?

“Personal data” is any information through which you can be identified. These include data such as name, identification number, telephone number, email address, postal address, username, location data, an online identifier, one or more elements specific to your physical, physiological, genetic, mental, economic, cultural or social identity, personal preferences and browsing habits, the content generated, the IP address of your computer, the MAC address of your device, as well as the information included in the cookies, as regulated by the General Data Protection Regulation in order to protect all EU citizens from confidentiality and data breach. 

C. What is the scope of this Privacy Policy?

This Privacy Policy shall apply to your personal data collected or processed through websites, mobile applications and other services and products you interact with and that belong to ARFAM ACTIVITATE SI RECREERE PENTRU FAMILIE S.R.L. This Privacy Policy shall not apply to the websites of other entities, mobile applications and other services and products that do not display or include a link to this Privacy Policy or that have their own privacy policy. 

The personal data provided by users of the Website may be processed by the Company depending on the type of data provided by the user, as well as the interactions between the user and the Company through the Website.

D. What data do we process and what are their sources?

The data that the Company may process as a result of the interaction with the user through our Website originate from the following sources:

• The data resulting from the user’s browsing the web page, collected through cookies and similar technologies.
• The data provided by the user upon contacting the Company through the contact details provided in Chapter A of this Privacy Policy, such as:
• Identification and contact details, i.e. first name and surname, email address, postal address or home address, telephone number;
• Other types of data: favourite products, hobbies, interests, lifestyle information, consumer feedback, and information you provide to us about your experience in using the products and services (e.g., comments and suggestions, testimonials or other information about the website products, consumer-generated content, or any content (e.g., photos, videos) that you create and distribute through our contact details.

If the user of our Website provides other types of data in the interactions with the Company, these data shall be processed by the Company only if their processing is necessary to achieve the 

intended purpose. Otherwise, the data shall be destroyed without being previously saved by us. 

E. Legal grounds for the processing of your data

The Company shall process the personal data provided by users of its Website in accordance with the following legal grounds, depending on the type of data provided by the user, as well as the interactions between the user and the Company:

• Processing your data for “Browsing the Website. Use of cookies” purposes shall be made exclusively on the basis of the consentrequested from the user. 
• The processing of your data for “Contact & Information” purposes shall be based on the management and handling of the relationship between the user and the Company, in other words, on the legitimate interest of the Company in managing your application, maintaining contact between the parties and, where appropriate, providing the service/information requested by the user, the performance of a legal obligation, for example, with regard to the settlement of requests for the exercise of users’ rights regarding the processing of their data, as well as, if necessary, the agreement to be requested from the user.  

F. What assurances do we need when you provide your personal data?

The user gives assurances that the data provided are real, accurate, complete and up to date and shall be responsible for any direct or indirect damage that may result from the breach of such obligation.

If the user provides data belonging to a third party, s/he shall give assurances that s/he has informed that third party of all aspects covered by this Privacy Policy and that s/he has obtained the related consent to provide us with his/her data for the purpose of such processing. All of this shall take place before the data is provided to a third party through our Website. 

The Company informs you that in order to provide your personal data in any way through our Website, you must be over 16 years of age. The user who provides data to the Company through this Website represents and warrants that s/he is over 16 years of age and is fully responsible for such declaration. The use of the systems as well as the results of the processing is prohibited for children who have not reached this age, unless their parents/legal guardians give their consent in this regard. If, despite our reasonable prevention efforts, such processing still takes place, we shall stop it once we notice that the users have not reached the above-mentioned age. 

G. Measures to protect personal data

In response to our concern to ensure the security and confidentiality of your data, the necessary levels of security for the protection of personal data have been adopted and the technical means available to prevent the loss, misuse, alteration, unauthorised access and theft of personal data provided through the Website have been deployed. In any case, you must keep in mind that internet security measures are not infallible. 

H. Your rights regarding personal data

You have the right to obtain a confirmation that your personal data are being processed or not.
Similarly, you have the following rights regarding your personal data:

• To access your personal data: You have the right to access your data to know which of the personal data we process concerns you and what are the conditions under which they are processed.
• To request the rectification or deletion of your data: Under certain circumstances, you have the right to rectify the personal data that you consider inaccurate and that concern you, and which are subject to processing by the Company, as well as the right to request the deletion of data when, amongst other reasons, the data are no longer necessary for the purposes for which they were collected.
• To request the restriction of the processing of your data: Under certain circumstances, you have the right to request that we restrict the processing of your data, in which case we inform you that we will retain the data in connection with which you requested the restriction of processing only for the exercise or defence of a right in court.
• To data portability: Under certain circumstances, you will have the right to receive personal data about you, and which you have provided to us, in a structured format that is commonly used and can be read automatically, as well as for the Company to transmit to another operator.
• To object to the processing of your data: Under certain circumstances and for reasons related to your particular situation, you have the right to object to the processing of your data, in which case the processing shall cease, unless we must continue to do so for legitimate reasons or for the exercise or defence of a right in court.
• Not to be subject to a decision based solely on automated processing, including profiling, that gives rise to legal effects concerning the data subject or similarly affects him/her in a significant way.
• To lodge a complaint with the Data Protection Authority (ANSPDCP) and to bring a case to the competent courts.
• We would also like to remind you that you have the right to withdraw your consent for the processing of your data; this will not affect the lawfulness of the consent-based processing performed prior to the withdrawal.

The Company would like to inform you that you may exercise your personal data rights through any of the following channels:

• By a letter addressed to ARFAM ACTIVITATE SI RECREERE PENTRU FAMILIE S.R.L., with the official address for communication and correspondence in Mun. Cluj-Napoca, B-dul Constantin Brâncuși, nr. 138/A, jud. Cluj.  . Please include the “Data protection” mention.
• By a request addressed to ARFAM ACTIVITATE SI RECREERE PENTRU FAMILIE S.R.L. at the email address hello@marsupi.ro.

In both cases and under the legal provisions, the Company may request the provision of additional information necessary to confirm the identity of the data subject in case of reasonable doubts about the identity of the requesting natural person.

The Company shall provide the requested information within a maximum of one month from the receipt of the application. This period may be extended by a further two months if necessary, depending on the complexity of the applications and their amount. 

The Company would like to inform you that you can lodge a complaint with the competent data protection authority. However, we encourage you to first submit your complaint to the Company so that it can be settled amicably. 

Supervisory authority:

Autoritatea Națională de Supraveghere a Prelucrării Datelor cu Caracter Personal (National 

Authority for the Supervision of Personal Data Processing)

B-dul G-ral. Gheorghe Magheru 28-30
Sector 1, postal code 010336
Bucharest, Romania
Tel: +40.318.059.211 ; +40.318.059.212
Fax: +40.318.059.602
E-mail: anspdcp@dataprotection.ro
www.dataprotection.ro

I. Management and handling of applications and requests from users

The personal data of the users who contact the Company through any of the contact channels provided on the Website will be processed in order to maintain contact between the parties, for the management of the users of the Website, the provision of support services for customers or users, and the management and resolution of such applications and requests. We will process your personal data when you provide us with feedback on our products and services. Such personal data shall be processed for the above purpose only on the basis of your consent by also taking into account our legitimate interest in helping us understand the needs and expectations of customers regarding our products and services. Accordingly, it is your choice whether or not to provide us with personal data (such as forename and surname, email, telephone number or the like).

J. Recipients of your data

The data collected by the Company through this web page may be communicated to the following recipients in Romania, depending on the legal grounds of the communication and only if necessary:

• Public authorities or institutions (e.g., where the communication is necessary for the management of complaints, for the fulfilment of legal and fiscal obligations resulting from the organisation of promotional campaigns and competitions or when the Company is required by law to provide information to authorities or institutions with competence in carrying out inspections and controls on the activity and assets of the Company, or to the courts for the protection of the rights and assets of the Company).
• Companies that provide hosting services to the Company’s platforms and companies that provide technical maintenance of the Website.
• Financial or legal auditors, potential third party acquirers, to the extent that the Company’s business would be transferred (in whole or in part) and the data of the data subjects would be part of the assets that are the subject of such a transaction.

With respect to the other purposes of the data processing detailed in this Privacy Policy, the Company shall inform users that these purposes do not involve the communication of their data to third parties by the Company.

K. Retention time of your data

The Company shall keep your personal data for as long as is necessary to provide the requested service and/or to achieve the processing purpose.
Subsequently, your data shall be deleted.