FINE FASHION SERVICES srl, with registered office in Strada Ștefan cel Mare 27, Vânători-Neamț, county of Neamț, registered with the Trade Register under No. J27/198/2022, with sole registration number 45651459 (the “Company” or “The Fine Line“) has prepared this personal data processing policy (the “Policy”) to inform you of the conditions under which we collect, process, use and protect your personal data.

For the purposes of this Policy, personal data shall mean any information about an identified or identifiable person, such as name, surname, address, telephone number (“Personal Data“).

Data privacy is one of our fundamental commitments and we therefore ensure that the processing of personal data takes place in full compliance with the principles set out in applicable legislation, including but not limited to the General Data Protection Regulation 679/2016(“GDPR”).

The purpose of this Policy is to inform you, as a data subject, about how The Fine Line, as a controller of Personal Data, acts in relation to users of the www.thefineline.ro website (“Website“).

Please read this Policy carefully, as by accepting it, you agree to all of the terms set out below.

You are not required to provide us with the personal data mentioned in this document, but we will not be able to provide the services you request. If you do not agree with these terms of use, please do not continue to use our services.

The provisions of this Policy are for information purposes only and do not affect the rights recognised by the relevant legislation.

The personal data that we will process is data obtained directly from you (at the time of registration on the Website) or resulting from the provision of services by The Fine Line, such as:

• data provided when creating your account — when you give us information such as name; surname; gender; date of birth/age; address; clothing preferences; size; etc.;
• data entered in the “My Account” section — where you can fill in your bank card details, etc.;
• data entered when placing an order — when you provide us with data such as: desired service, first and last name, billing details, payment method, phone number, bank card details, etc.
• data entered when subscribing to the newsletter, such as: e-mail address, first name; last name; gender; date of birth/age; address; clothing preferences.

The Fine Line offers the possibility to register on the Website via your Facebook or Google account. In this case, you will be directed to the Facebook Inc/Google LLC pages on the Facebook and Google privacy policies available at the following links:

facebook.com/about/privacy or policies.google.com/privacy

On the Website, we offer the possibility to subscribe to The Fine Line newsletter. To ensure that no errors have occurred when entering the email address, we can use the so-called Double Out procedure (DOI): Once you have entered your email address in the registration field and consented to receive our newsletter, we will send you a confirmation link to the specified address. Once you click on this confirmation link, your email address will be included in our mailing list for newsletter delivery. The legal basis for processing this data is Article 6 (1) (a) GDPR.

You can withdraw your consent at any time with effect for the future by sending a message to contact@thefineline.ro or via the unsubscribe option at the end of each newsletter.

We use the data collected for the following purposes:

To conduct the contractual relationship, take and process orders and transactions made in connection with The Fine Line’s services or to resolve your complaints

Duration of processing: the data will be stored for 3 years, calculated from the date of the order.

Analyses and statistics on the use of our services, optimisation of The Fine Line services to improve customer satisfaction, products and services, identification of potential problems with our services.

Duration of processing: your data will be stored for a period of up to 3 years calculated from the date you cease to be a user.

Direct marketing and other commercial communications, offering discounts, promotions, product or service launches.

Duration of processing: the data will be stored for up to 3 years from the date of termination of user status or immediately in the case of a request for exclusion from commercial and marketing communications.

Preventing and combating fraud, complying with The Fine Line’s legal obligations, protecting certain rights in court, preventing attempted fraud.

Duration of processing: the data will be stored for a period of up to 3 years from the date of termination of user status or, if the law requires a longer duration, for the duration provided for by the relevant rules.

The Fine Line may delete your personal data when it considers that it is no longer necessary for the purposes for which it was collected.

In any case, you have the right to withdraw your consent to processing or to object to processing and, if there are no compelling legitimate grounds for processing that prevail, we will stop processing the data.

The Fine Line processes your personal data pursuant to Article 6(1)(b) of the GDPR — processing for pre-contractual and contractual purposes, respectively Article 6 para. (1)(c) of the GDPR — processing for compliance with legal obligations incumbent on the controller (The Fine Line).

As we obtain most of the information directly from you, it is processed under Article 6(1)(a) of the GDPR — processing on the basis of the data subject’s consent.

Mainly, we process personal data in order to be able to conclude a contract at your request. We also process data for the fulfilment of our archiving obligations, obligations to communicate to public authorities or for the preservation and exercise of legal rights. At the same time, there are cases where we process data on the basis of our legitimate interest and to facilitate access to our services.

You have the following rights in relation to the processing of personal data:

Right of access: You have the right to obtain confirmation from us that your data is processed by us, as well as information about the specific processing, such as: the purposes of the processing, the categories of personal data processed, the recipients of the personal data, the period for which the personal data is stored, whether we transfer the personal data abroad and how we protect it;

The right to rectification: You have the possibility to request rectification of your personal data if you identify that they are erroneous or incomplete;

The right to erasure (“right to be forgotten“): In certain cases, you have the possibility to request the deletion of personal data, i.e. when they are no longer necessary for the purposes for which they were collected, if you withdraw your consent to the processing (and there is no other legal reason for the processing) or if you object to the processing;

Right to data portability: You have the right to obtain the transfer of the data we process or control to another controller;

Right to object: in certain situations, you have the right to object to the processing of personal data by us.

Right to revoke consent: To the extent that you have consented to the processing of personal data, you may withdraw your consent at any time, without affecting the lawfulness of the processing based on consent prior to the withdrawal of consent.

The right not to be subject to automated individual decisions: you have the right not to be subject to a decision based solely on automated processing, including profiling. Such a right may not be exercised where the decision:(i) is necessary for the conclusion of a contract or the performance of a contract between you and The Fine Line; (ii) is necessary for taking appropriate measures to protect your rights, freedoms and legitimate interests; or (iii) is based on your explicit consent.

The right to lodge a complaint with the supervisory authority: you have the right to lodge a complaint with the National Supervisory Authority for Personal Data Processing (“ANSPDCP”) about any violation of your rights with regard to the processing of your personal data.
The contact details of ANSPDCP are:

Gheorghe Magheru 28-30, District 1, 010336, Bucharest, Romania
anspdcp@dataprotection.ro

The full list of data protection authorities in the European Union: https://edpb.europa.eu/about-edpb/board/members_en

Certain rights can be exercised directly from the Website and by sending an e-mail to contact@thefineline.ro. In order to ensure that the person contacting us regarding your personal data is you, we reserve the right to verify your identity prior to issuing any response regarding your personal data, precisely in order to ensure the confidentiality of all data.

We make every effort to respond to your requests within 30 days of receipt. This period may be extended by a further 60 days if necessary, taking into account the complexity and number of applications, in which case we will inform you of any extension and the reasons for the delay

The Fine Line currently discloses your personal data to:

• service providers (acting either as controllers or as processors of The Fine Line) that The Fine Line contacts for administrative services, marketing and other service providers (e.g. IT service providers, data storage services, etc.);
• accountants, auditors, lawyers and other external professional staff who will be bound by legal or contractual obligations of confidentiality;
• public authorities if disclosure is necessary to comply with an obligation under applicable law.

We take all necessary precautions, given the nature of personal data and the risks related to data processing, to maintain data security and in particular to prevent misrepresentation, damage or unauthorised access by third parties (physical protection of the location, authentication procedures with personal access, secured by confidential identifiers and passwords, a log-in log, encryption or anonymisation of personal data, storage in secure environments. However, despite our best efforts, we cannot always guarantee the effectiveness of the security measures implemented and therefore cannot guarantee the security of personal data at all times.

This Policy became effective on July 1, 2022. We may update or amend this Personal Data Processing Policy as necessary and will notify you of any such changes. However, we recommend that you review this page from time to time if you wish to be informed about how your data is collected and protected.

To request more details on the measures taken to protect your personal information in the above cases, you can contact us at any time at contact@thefineline.ro