Privacy Policy

This Privacy Policy describes how LPG Distributors SRL (“LPG Distributors SRL,”, “DIS&DIS”, “we” or “us”) collects, uses and shares personal information, such as your name, address, phone number and email address. Use of DIS&DIS’ websites and apps (hereafter referred to as the “Website” or the “Service”) is subject to this Privacy Policy and our Terms of Service. Read them carefully to understand our practices and your options.

LPG Distributors SRL is committed to protecting the privacy and security of our customers and users, respecting the right to the protection of personal data as well as the right to privacy.

The term User/s is used in this policy to refer to all persons over 18 years old who access the Website.

For all our services, the data controller - the company responsible for your privacy - is LPG Distributors SRL a company established and operating in accordance with the laws of Romania, registered at the Trade Register under the no. J35 /1982 /2020, CUI: 42832019. The registered office of the LPG Distributors SRL is in Timisoara, Closca Street 54, room 3, Timis, Romania.

Thus, we take all necessary steps to process your personal data in accordance with the principles set out in the Romanian data protection legislation, including Regulation (EU)  2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC ("GDPR").

Personal data shall mean any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is a person who can be identified, directly or indirectly, in particular by reference to an identification element such as a name, identification number, location data, an online identifier, or to one or more specific elements specific to its physical, physiological, genetic, mental, economic, cultural or social identity.

LPG distributors SRL is the controller of personal data within the meaning of the GDPR, i.e. it determines the means and purposes for processing personal data.

WHAT KIND OF PERSONAL DATA DO WE PROCESS?

LPG distributors SRL collects the information you communicate when you use the “DIS&DIS” site, such as identification data, location data, payment data and more.

The data categories we process are as follows:

- First name, last name and contact details;
- Home address, residence, delivery address,
- Telephone number, and email address;
- Date of birth;

- National identity card or passport data;
- Age and gender;

- Bank information, bank account number;
- Billing data;
- Account ID, client code and account password;
- Social media account;

- Statistical data on the use of the website;

- Data of the user’s browsing;

- Device location data.

We do not collect or otherwise process sensitive data, as defined in the GDPR as special categories of personal data.

On the “CONTACT” page, it is possible to briefly explain the reason for the communication by completing a contact form. Keep in mind that there can be no personal questions except those strictly requested by current legislation. Under no circumstances will be communicated data regarding special categories (such as health data, religion, etc.). In case of doing so, the User exempts LPG Distributors SRL from total liability. In the event that inappropriate inquiries or content are sent, we will proceed to their elimination.

This Website is not directed to minors. We do not collect data on minors under the age of 18. Children underage may not use the services available through the Website without the prior authorization of their parents, guardians or legal representatives, who will be solely responsible for all acts performed through the Website by minors at their charge, including the completion of the forms with the personal data of said minors and the marking, where appropriate, of the opt-in boxes that accompany them.

You can always choose what personal data you want to provide us. However, if you choose not to provide certain personal data if it is necessary for the conclusion of the contract or the use of the services; we will be unable to offer you certain services, for example: if you do not want to give us your name, surname, e-mail address or telephone number, we will not be able to conclude the contract with you and deliver the ordered products.

You can visit our website without providing information about yourself. Each time a website is accessed, the web server automatically saves only the so-called server log file, which contains, for example, the requested file name, IP address, date and time of the call, the amount of data transferred and the requesting provider (access data) and documents the call.

These access data are evaluated exclusively in order to ensure the smooth operation of the site and to improve our offer, as well as to obtain statistical data of the user’s browsing and use of the website.

By providing us with your data through the Website, the User guarantees that they are true, accurate, complete and up-to-date, taking responsibility for any direct or indirect damage or loss that may be caused as a result of the breach of such obligation. If you provide third-party data to us, the User must have their consent and commit to transferring the information contained in this Policy, exempting LPG Distributors SRL from any responsibility in this regard. However, we may carry out the verifications to check if the consent is valid, adopting the appropriate due diligence measures, in accordance with the data protection regulations.

FOR WHAT PURPOSE AND ON WHAT LEGAL GROUNDS DO WE PROCESS YOUR PERSONAL DATA?

Our company processes personal data for the purpose of fulfilling the specific object of activity and the object of the contracts concluded with the clients, as well as for the purpose of fulfilling the legal obligations regarding our activity.

The processing of personal data by the data controller will be carried out exclusively under the incidence of one of the six legal grounds provided in art. 6 of the GDPR:

a) consent;

b) concluding or executing a contract;

c) fulfilment of a legal obligation of the operator;

d) protection of the vital interests of the data subject or of another natural person;

e) fulfilling a task related to the public interest;

f) for the purpose of the legitimate interest of the operator or of a third party.

I.-In order to complete the services requested, DIS&DIS processes your data on the basis of art. 6 par. (1) lit. b) GDPR: “the processing is necessary for the execution of a contract” to which the data subject is a party or to take steps at the request of the data subject before concluding a contract. Required fields are marked as such because in these cases we need data to process the contract or to process your contact, and you cannot send the order or contract without them.

II.- We collect personal data if you voluntarily provide us with your express consent as part of your order, to create the user account, or when you contact us (for example, using the contact form or email),

under the conditions of art. 6 par. (1) letter a) “the data subject has given his / her consent for the processing of his / her personal data for one or more specific purposes”;

III. In cases expressly provided by the legal provisions in force (domestic and international), the data controller processes personal data under the conditions provided by art. 6 par. (1) lit. c) "the processing is necessary in order to fulfil a legal obligation incumbent on the operator".

IV. At the same time, in relation to the state authorities, the operator falls under the incidence of art. 6 par. (1) letter e) "the processing is necessary for the performance of a task that serves a public interest or that results from the exercise of the public authority with which the operator is invested".

V. Last but not least, in well-justified cases, such as civil, criminal actions, the provisions of art. 6 par. (1) lit. f) "the processing is necessary for the purpose of the legitimate interests pursued by the controller or a third party, unless the interests or fundamental rights and freedoms of the data subject prevail, which require the protection of personal data, especially when the data subject is a child."

HOW DO WE USE THE PROCESSED DATA?

I. For the conclusion and execution of the contract:

- Identifying the person accessing the site, by assigning a unique number to the first visit to the site - user/customer ID;

 -For order registration and product delivery we process name, address, phone, e-mail, user/customer ID;

- Identifying the person who contacts us by message: name, user/customer ID

- We process age data, to limit access and orders for people under 18 because we do not have the right to sell products to minors:

- The data are necessary to communicate the status of the order by phone or e-mail;

- Communicating privacy policy updates;

- Participation of clients in promotions, offers

- Bank account data are required for making payments and refunds;

- We keep conversations made by e-mail, instant chat, social media, to provide services and customer support;

II. To fulfil the legal obligations:

- We keep and record in the accounting records the data as a result of orders and financial transactions between customers and DIS&DIS;

- We process the data for reporting to state institutions and paying taxes;

III. Based on the consent of the data subject:

- We will collect personal data, through cookies for marketing purposes and for the elaboration of user profiling;

- For marketing purposes, the data is used to send to users, newsletters about our products, services and promotions, there is always the possibility to unsubscribe from that method of communication;

- Based on the data provided, we use online advertising, and the user may see our banners and ads on other websites and apps, such as Social Media. We manage this through a variety of digital marketing networks and ad exchanges. We also use a range of advertising technologies.

- The banners and ads displayed are based on the information we have about our users (for example, search history and read content) or banners or ads that were previously clicked.

Based on the consent regarding the use of cookies, data are obtained for:

- Product recommendation based on previous accesses

- List of favourite products, to notify customers about offers or reintroduction of products

- History of previous orders,

- Save client account preferences to keep the previously selected language and currency.

- Presentation of advertisements and product recommendations sent to customers and visitors

- Connect your Social Media account to your client account to sign in easily and easily without the need to create a specific account;

- Feedback, answers to surveys and participation in competitions

TO WHOM WE TRANSMIT YOUR PERSONAL DATA?

The recipients of personal data are the controller's proxies, the controller's employees, the accounting department, but also the clients, partners, beneficiaries, suppliers; as well as state institutions.

We do not sell customers' personal data to third parties.

However, we share your data upon request, or on the basis of contracts to the following recipients or categories of recipients, who have access to the data, in order to perform the services you have requested:

- Wine suppliers and sellers;

- Warehouse providers, Warehousing, packaging, ordering, delivery companies;

- Forwarders, Companies that ensure the delivery of purchased goods and services to you;

- Software companies to maintain the website and hosting

- Bank entities, Payment service providers for online payments;

- Marketing providers, marketing agencies, advertising partners and the hosts of their sites;

- Social Media sites (if you choose to link your accounts to us);

- Affiliates who help us reach potential new customers and promote products on their websites;

- Support companies

- The Ministry of Public Finance and its subordinate structures

- Legal authorities and public authorities with powers of supervision and control of economic activity;

- To the holding of the group L&P Global, BV.

- Necessary collaborators to perform the contracted services and provide the product.

- Other entities under public or private law, any other natural or legal person that justifies a legitimate interest, in accordance with the law.

DO WE TRANSFER YOUR PERSONAL DATA OUTSIDE THE EU / EEA?

Based on the services you have selected and your consent to the use of cookies, in certain situations we transfer the data outside the EU. This transfer will only be made on condition that the operator undertakes to comply with the standard contractual clauses issued by the European Commission.   

HOW LONG DO WE RETAIN YOUR PERSONAL DATA?

We will retain your information for as long as you continue to be a customer or user of our services, for the purpose of achieving the purposes detailed in this policy, and for as long as we are required to retain it to ensure that we meet the legal requirements worldwide.

If you no longer wish to be a customer, you may contact our team and request that your account be closed. However, we have a legal obligation to retain some of your personal data even after you have requested that we delete it. . We will keep only what we absolutely need and only to ensure that we can meet our legal or regulatory requirements, resolve disputes, prevent fraud and abuse, or enforce our Terms and Conditions.

We constantly review the need to keep your personal data, and if the processing is no longer necessary and there is no legally binding obligation to keep your personal data, we will delete/destroy your personal information as soon as possible and in a way that cannot be recovered or reconstructed.

If personal information is printed on paper, it will be destroyed in a way that ensures its complete disposal and if it is saved on electronic media, it will be erased by technical means to ensure that the information can no longer be recovered or reconstructed at a later date.

WHAT ARE YOUR RIGHTS?

As a data subject, you have the following rights under the GDPR:

Right of access: You may ask us for (i) a confirmation that personal data is being processed or not, and if so, access to that data and information about such data, and (ii) a copy of your personal data we hold (Article 15 of the GDPR);

Right to rectification: You may inform us of any changes to your personal data or ask us to correct the personal data we have about you. (Article 16 of the GDPR);

Right to erasure ("right to be forgotten"): In certain situations (e.g. (I) the case where the data was collected illegally, (ii) the deadline for storing the data has expired, (iii) you have exercised your right to object or (iv) the processing of data is carried out on consent and you have withdrawn your consent), you may ask us to delete the personal data we have about you. (Article 17 of the GDPR);

Right to restriction of processing: In certain situations (such as if you challenge the accuracy of such data or the lawfulness of processing), you may ask us to restrict the processing of your data for a certain period (Article 18 GDPR);

Right to data portability: Ask us to send your personal data to a third party or directly to you. (Article 20 of the GDPR);

Right to object: In certain situations (such as processing based on legitimate interest), you may ask us to stop processing your data. (Article 21 of the GDPR);

If we use your personal data based on your consent, you may withdraw this consent at any time by sending us an email, REF: Data Protection, to hello@disndis.com. In this situation, your data will no longer be processed by us unless a legal provision requires us to keep and archive it. In any case, we will inform you if such a legal provision exists and expressly indicate it.

Also, in case you do not have electronic means or do not want to use them, you can make a written request that you submit to our headquarters in Timisoara city, Closca Street 54, room 3, Timis, Romania.

IS YOUR DATA SAFE?

We take your personal security seriously, so we take the important security measures necessary to protect against unauthorized access to data or unauthorized alteration, disclosure or destruction of data. This includes internal reviews of data collection, storage and processing practices and security measures, also physical security measures to protect against unauthorized access to systems where we store personal data.

We also ask our service providers and business partners to take all necessary measures to protect against unauthorized access to data or unauthorized alteration, disclosure or destruction of data.

COMMERCIAL AND PROMOTIONAL INFORMATION

If the User has authorized us to do so, we will process the personal data provided with the aim of notifying you of advertisement content and commercial communications of DIS&DIS. In that case, you can revoke your consent at any time by clicking on the link provided in each newsletter or by email to hello@disndis.com, REF: Unsubscribe Newsletters.

We inform you that we may still send you non-marketing emails related to our commercial relationship.

Newsletters and our Website may also contain links to third-party sites. We will store your data for as long as you are subscribed to our newsletter. After you unsubscribe, we will block your data in this context so that you will not receive any more newsletters from us in the future.

SOCIAL NETWORKS

We have set up social media icons on our website. With a simple mouse click, you can access the following social media platforms: Facebook, Instagram and Spotify, where we create our own playlists so you can enjoy while consuming our products. When visiting our website, no personal data is transmitted to the providers. You can recognize the platform provider by the logo. We offer you the opportunity to go directly to DIS&DIS publications on each social network through the icon. We have no influence on the data collected and the data processing procedures on these social networks, nor are we aware of the full scope of the data collection, the purposes of the processing and the retention periods. We also have no information on the erasure of the same.

In the event that the followers of our profiles contact DIS&DIS through said networks or publish images or information in our profile that contains personal data, it will be the sole responsibility of the User and/or follower, being DIS&DIS exempt from all responsibility regarding the content that the User and the follower incorporate in our public profiles. Due to the fact that the profile of DIS&DIS on social networks is public, DIS&DISis not responsible for any direct or indirect action carried out by third parties derived from the publication of the User of their personal data in our profiles. Therefore, we strongly ask you to not share any personal or sensitive information and that you carefully read the Privacy Policies and Terms and Conditions of these social platforms to configure your profile with the degree of privacy you want. Anyone who does not wish to continue to be a follower of DIS&DIS in the social networks in which it is present can stop following said profile as provided in the Terms and Conditions of the corresponding social platform.

Below you can find the addresses of the social media platforms where you can view their privacy statements:

• Facebook Inc, 1601 S California Ave, Palo Alto, California 94304, USA; facebook.com/policy.php.
• Instagram Inc, 1 Hacker Way, Menlo Park, CA 94025, USA; https://help.instagram.com/519522125107875.

Links

In relation to the links to other portals or web pages not managed by DIS&DIS that may appear on the portal for information purposes, DIS&DIS does not exercise any control over them, nor does respond to the information accessed. We ask you to visit these websites directly to obtain information on their Privacy Policy that provides information regarding data protection, security, data collection and provisions regarding the transmission of data. 

DIS&DIS will not be responsible for any action taken by, or the contents of, these websites.

Unless DIS&DIS has authorized it in advance and in writing, you cannot insert a link, hyperlink, framing or similar link on the Website.

LANGUAGE

The Privacy Policy is available in Romanian, Spanish and English language. Should any discrepancy among the Romanian, Spanish and English version arise, the English version shall prevail.

QUESTIONS OR COMPLAINTS

If you have any questions or concerns regarding the processing of your personal data or if you wish to exercise any of the rights mentioned above, you are welcome to contact us by sending an e-mail to the following address: hello@disndis.com, and we will reply you within 30 days of receiving your request.

Also, in case you do not have electronic means or do not want to use them, you can make a written request that you submit to our headquarters in Timisoara city, Closca Street 54, room 3, Timis, Romania.

Any communication will be written as a reference on an envelope or e-mail “Data Protection”.

To the extent that you are not satisfied with the way your request was resolved, you may lodge a complaint with the national data processing Supervisory Authority, if deemed appropriate.  The contact details of the National Authority to oversee the processing of personal data are: B-dul G-ral. 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.

POLICY CHANGES

This privacy policy may change in accordance with changes to data policy law or based on changes to our services or organizational mode from time to time. If we make material changes to this, we will publish a link to the revised policy on our website homepage. If we make significant changes that will impact your rights and freedoms. (for example, when we start processing your personal data for purposes other than those specified above), we will contact you before we start processing this data, for your consent.

If you want a copy of the previous versions of this privacy policy, please send an email to hello@disndis.com

COOKIES

DIS&DIS will only use data storage and retrieval devices (“Cookies”) when the User has given his prior consent for it in accordance with what is indicated in the pop-up window of the user’s browser when accessing the Website for the first time and in the other terms and conditions indicated in the Cookies Policy that every user must know about.