We consider ensuring the right to the protection of personal data as a fundamental commitment of Abies Industries Group SRL, and 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 any other applicable legislation. Since 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 regarding our products and services, including through our website.

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 the event of any such changes, we will display the modified version of the Privacy Policy on our website, so please check the content of this Privacy Policy periodically.

Who we are and how you can contact us

Abies Industries Group SRL is the trade name of Abies Industries Group SRL, a Romanian legal entity, with registered office at 5 Bisericii Street, Nehoiu, Buzau County, VAT ID 15668858, Trade Registry J10/698/2003, (hereinafter “Abies Industries Group SRL” or “we”). Under data protection legislation, we are the data controller when processing your personal data.

Since we are always open to your opinions and providing you with any additional information you may need regarding the processing of your data, we encourage you to contact the Data Protection Officer of Abies Industries Group SRL at the email address office@abies-furniture.ro or by mail or courier to 5 Bisericii Street, Nehoiu, Buzau County, with the mention: Attention of the Data Protection Officer of Abies Industries Group SRL.

Categories of personal data we process

In general, we collect your personal data directly from you, giving you control over the type of information you provide. For example, we receive information from you when:

• You create an account on abies-furniture.ro, providing your email address, phone number, name, and surname;
• In your personal page (My Account) on the platform abies-furniture.ro, you have the possibility to add additional information, such as a nickname, landline number, date of birth, delivery address, alternative email address, credit card details, etc.
• When placing an order, you provide information such as the desired product, delivery address, billing details, payment method, phone number, etc.

We may also collect and process certain information about your behavior during your visit to our website to personalize your online experience and provide you with offers tailored to your profile. For more details, please refer to the section on processing purposes below.

On our website, 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, including special categories of personal data, as defined by the General Data Protection Regulation. Also, we do not intend to collect or process the data of minors who have not reached the age of 18.

Purposes and legal basis of processing

We will use your personal data for the following purposes:

1. To provide services by Abies Industries Group SRL for your benefit

This general purpose may include, where applicable, the following:

• Creation and administration of the account within the Abies Industries Group SRL platform;
• Processing orders, including taking, validating, shipping, and invoicing them;
• Handling cancellations or issues of any kind related to an order, purchased goods, or services;
• Return of products according to legal provisions;
• Refund of the value of products according to legal provisions.

Processing your data for these purposes is, in most cases, necessary for the conclusion and execution of a contract between Abies Industries Group SRL and you. Also, certain processing activities related to these purposes are imposed by applicable laws, including tax and accounting legislation.

2. To improve our services

We constantly aim to offer you the best online shopping experience. For this, we may collect and use certain information about your buyer behavior, invite you to complete satisfaction surveys following the completion of an order, or conduct market research directly or with the help of partners.

We base these activities on our legitimate interest in carrying out commercial activities, always ensuring that your fundamental rights and freedoms are not affected.

3. For Marketing

We want to keep you informed about the best offers for products that interest you. In this regard, we may send you, through electronic communication channels (email/SMS/etc.), general and thematic newsletters, information about similar or complementary products to those you have purchased or shown interest in, as well as other similar commercial communications, 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., viewed/added to wishlist/purchased products) to create a profile. We always ensure that these processes 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 affect you in a similar significant way.

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 take all necessary measures to ensure that your fundamental rights and freedoms are not affected. However, you can request at any time, using the means described above, to stop processing your personal data for marketing purposes, and we will respond as soon as possible to your request.

4. 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 Abies Industries Group SRL platform from cyberattacks;
• Measures to prevent and detect fraud attempts, including the transmission of information to competent public authorities;
• Management of various other risks.

The general basis for these types of processing is our legitimate interest in defending our commercial activity, ensuring that all measures we take guarantee a balance between our interests and your fundamental rights.

Also, in certain cases, we base the processing on legal provisions such as the obligation to ensure the protection of goods and values provided by the applicable legislation in this matter.

How long we keep your personal data

As a general rule, we will store your personal data as long as you have an account in the Abies Industries Group SRL platform. You can request the deletion of certain information or the closure of the account at any time, and we will respond to these requests, subject to retaining certain information even after the account is closed, in situations where the applicable legislation or our legitimate interests require it.

If you do not have an account in the Abies Industries Group SRL platform, the general rule is to keep information related to orders placed for a period of 3 years from the completion of the order. Similar to the previous situation, it is possible to retain certain data even after the expiration of this period, in accordance with applicable legislation or our legitimate interests.

To whom 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 Abies Industries Group SRL;
• courier service providers;
• payment/banking service providers;
• marketing/telemarketing service providers;
• market research service providers;
• insurance companies;
• IT service providers;
• other companies with which we may develop joint programs for offering our goods and services on the market.

In case of a legal obligation or if 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 is carried out in accordance with legal provisions regarding data protection and information confidentiality, 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, from time to time, it is possible to transfer certain data of yours to entities located outside Romania. These entities may be located in the European Union or outside the Union, including countries to which the European Commission has not recognized 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 applicable, by other guarantees, 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 the EU to the United States.

You can contact us anytime, using the contact details provided above, to find out more information about the countries to which we transfer your data, as well as the guarantees 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, following industry standards.

Despite the measures taken to protect your personal data, please note that transmitting information over the Internet, in general, or through other public networks, is not completely secure, and there is a risk that data may be viewed and used by unauthorized third parties. We cannot be held responsible for such vulnerabilities in systems that are not under our control.

What rights do you have

The General Data Protection Regulation recognizes a series of rights regarding your personal data. You can request access to your data, correction of any errors in our files, and/or object to the processing of your personal data. Additionally, you can exercise the right to complain to the competent supervisory authority or seek judicial remedies. Depending on the situation, you may also have 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 table presented below. To exercise your rights, you can contact us using the contact details provided above. Please note the following if you want to exercise these rights:

Identity: We take the confidentiality of all records containing personal data seriously. Therefore, please send us your requests regarding such records using the email address associated with the Abies Industries Group SRL account. Otherwise, we reserve the right to verify your identity by requesting additional information to confirm your identity.

Fees: We will not charge a fee to exercise any of your rights regarding your personal data unless your request for information access is unfounded, repetitive, or excessive, in which case we will charge a reasonable fee in such circumstances. We will inform you of any fees applied before resolving your request.

Response time: We aim to respond to any valid requests within a maximum of one month, unless it is exceptionally complicated or if you have made multiple requests, in which case we will respond within a maximum of two months. We will notify you if we need more than a month. We may ask you to specify exactly what you want to receive or what concerns you. This will help us to act more quickly and shorten the response time to your request.

Third-party rights: We do not have to comply with a request if it would negatively affect the rights and freedoms of other data subjects.

Rights affected and their description

Access

You can ask us to:

• confirm if we process your personal data;
• provide you with a copy of this data;
• provide you with other information about your personal data, such as what data we have, how we use it, to whom we disclose it, if we transfer it abroad, 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 in this notice.

Rectification

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

Deletion of 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; or
• you have withdrawn your consent (if the data processing is based on consent); or
• you object to processing; or
• they have been processed unlawfully; or
• we have a legal obligation to do so.

We are not obliged to comply with your request to delete your personal data if the processing of your personal data is necessary:

• to comply with a legal obligation; or
• to establish, exercise, or defend a legal claim.

There are certain other circumstances in which we are not obligated to comply with your data deletion request, although these are the two most likely circumstances in which we may refuse your request.

Please note that, before exercising this right, you should download from your Abies Industries Group SRL account and save all documents related to orders placed with Abies Industries Group SRL, 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 the right to delete, you will lose all these documents, and Abies Industries Group SRL will be unable to provide them to you, as the process of deleting data, including the Abies Industries Group SRL account, with all associated data and documents, 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 contested (see the rectification section), to allow us to verify their accuracy; or
• processing is illegal, but you do not want the data to be deleted; or
• they are no longer needed for the purposes for which they were collected, but you need them to establish, exercise, or defend a legal claim; or
• you have exercised your right to object, and the verification of whether our rights prevail is in progress.

We can continue to use your personal data following a restriction request if:

• we have your consent; or
• to establish, exercise, or defend a legal claim; or
• to protect the rights of another natural or legal person.

Data portability

You can ask us to provide you with your personal data in a structured format, commonly used and machine-readable, or you can request that it be ‘ported’ directly to another data operator, but in each case only if:

• the processing is based on your consent or the conclusion or execution of a contract with you, and
• the processing is done by automated means.

Objection

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

Automated decision making

You can request not to be subject to a decision based solely on automated processing, but only when that decision:

• has legal effects on you; or
• affects you in a similar and significant way.

This right does not apply in cases where the decision reached through automated decision-making:

• is necessary for the conclusion or performance of 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.

Complaints

You have the right to file a complaint with the supervisory authority regarding the processing of your personal data. In Romania, the contact details of the data protection supervisory authority are as follows:

• National Supervisory Authority for Personal Data Processing;
• G-ral. Gheorghe Magheru Blvd. no. 28-30, Sector 1, postal code 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 beforehand, and we promise to make every effort to resolve any issues amicably.

We remind you that you can contact the Abies Industries Group SRL Data Protection Officer at any time by sending your request through any of the following methods:

• by email to the address: office@abies-furniture.ro, or
• by mail or courier to the address: Bisericii Street no. 5, Nehoiu, Buzau County, with the mention ‘Attention: Abies Industries Group SRL Data Protection Officer.’