We consider ensuring the right to the protection of personal data as a fundamental commitment of Transformtheday, therefore we will dedicate all the necessary resources and efforts to process your data in full accordance with Regulation (EU) 2016/679 ("General Data Protection Regulation" or " GDPR"), as well as with any other applicable legislation. Since one of the essential principles of this legal framework is transparency, we have prepared this document through which we want to inform you about how we collect, use, transfer and protect your personal data when you interact with us in relation to products and services ours, including through our website or through the applications available on the mobile phone.

We reserve the right to periodically update and modify this Privacy Policy, to reflect any changes in the way 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, which is why we ask you to periodically check the content of this Privacy Policy.

Who we are and how you can contact us

Transformtheday is the commercial name of POLISEMANIC IDEAS SRL, based in Bucharest, Sector 1, Romania, registered at the Trade Registry Office under number J40/17662/2017, CUI: 38373058. (hereinafter "Transformtheday" or "we"). In the sense of the data protection legislation, we are the operator when we process your personal data.

As we are always open to your opinions, as well as to provide you with any additional information you may need regarding the processing of your data, we encourage you to contact Transformtheday's Data Protection Officer at the e-mail address myioana@transformtheday.ai or by post or courier to the address Municipality of Bucharest, Sector 1, Intr. Straulesti, No. 15c, Et. 4, Ap. 404 - with the mention: to the attention of the Transformtheday Data Protection Manager.

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 us. With the example title, we receive information from you as follows:

• When you create an account on Transformtheday, you send us your email address, phone number, name and surname;
• Within your personal page (My Account) in the Transformtheday platform, you can add additional information, such as: nickname, landline number, date of birth, education level, delivery address, alternative e-mail address, bank card details, etc.
• When you place an order, you provide us with information such as the desired product, delivery address, billing details, payment method, phone number, etc.

We may also collect and subsequently process certain information regarding your behavior while visiting our website or using the smartphone application, in order to personalize your online experience and provide you with offers adapted to your profile. we invite you to find out more details in this regard by consulting the section regarding the purposes of processing below.

On our website and in the smartphone application we can store and collect information in cookies and similar technologies, according to the Cookies Policy.

We do not collect or otherwise process sensitive data, included by the General Data Protection Regulation in special categories of personal data. Also, we do not want to collect or process data of minors who have not reached the age of 16.

What are the purposes and grounds of the processing

We will use your personal data for the following purposes:

1. To provide Transformtheday services for your benefit

This general purpose may include, as the case may be, the following:

• Account creation and administration within the Transformtheday platform;
• Order processing, including their receipt, validation, shipping and invoicing;
• Solving cancellations or problems of any kind related to an order, goods or services purchased;
• Returning products according to legal provisions;
• Reimbursement of the counter value of the products according to the legal provisions;

The processing of your data for these purposes is in most cases necessary for the conclusion and execution of a contract between Transformtheday and you. Also, certain processing subsumed for these purposes is required by applicable legislation, including fiscal and accounting legislation.

2. To improve our services

We always want to offer you the best online shopping experience. For this, we can collect and use certain information about your behavior as Buyers, we can invite you to complete satisfaction questionnaires following the completion of an order or we can carry out, directly or with the help of partners, studies and market research.

We base these activities on our legitimate interest to carry out commercial activities, always taking care that your fundamental rights and freedoms are not affected.

3. For Marketing

We want to keep you informed about the best offers for the products that interest you. In this sense, we can send you, through electronic communication channels (e-mail/SMS/mobile push/webpush/etc.) general and thematic newsletters, information about products similar to or complementary to those you have purchased or you have shown interest in purchasing them, as well as other similar commercial communications, and we can display personalized recommendations on the website and in the smartphone application. In order to provide you with information of interest to you, we may use certain data regarding your buyer behavior (e.g. products viewed / added to wishlist / purchased) to create a profile for you. We always make sure that these processes are carried out with respect for your rights and freedoms, and that the decisions taken based on them do not have legal effects on you and do not similarly affect you to a significant extent.

In most cases, we base our marketing communications on your prior consent, expressed by ticking the box "I want to receive the weekly newsletter with Transformtheday news and exclusive campaigns". You can change your mind and withdraw your consent at any time, by:

• Changing the settings in the customer account in the "Personal Data" section;
• Accessing the unsubscribe link displayed within the messages you receive from us;
• Contacting Transformtheday using the contact details provided above.

In certain situations, we may base our marketing activities on our legitimate interest to promote and develop our commercial activity. In any situation where we use information about you for a legitimate interest of ours, we take care and take all the necessary measures so that your fundamental rights and freedoms are not affected. However, you can request us at any time, through the means described above, to stop the processing of your personal data for marketing purposes, and we will comply with your request as soon as possible.

4. To defend our legitimate interests

There may be situations in which 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 Transformtheday platform against cyber attacks:
• Measures to prevent and detect fraud attempts, including the transmission of information to the competent public authorities;
• Measures to manage various other risks.

The general basis of these types of processing is our legitimate interest to defend our commercial activity, it being understood that we ensure that all the 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 protection of goods and valuables 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 on the Transformtheday platform. You can request us to delete certain information or close your account at any time, and we will comply with these requests, subject to keeping certain information including after closing the account, in situations where the applicable legislation or our legitimate interests require it.

If you do not have an account on the Transformtheday platform, the general rule is to keep the information related to the orders made for a period of [3] years from the moment the order was completed. Similar to the previous situation, it is possible to keep certain data even after the expiration of this period, in accordance with the applicable legislation or with our legitimate interests.

To whom we transmit your personal data

As the case may be, 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 Transformtheday;
• 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 can 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 parties under private law is carried out in accordance with the 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 on the territory of Romania.

However, from time to time, it is possible to transfer certain of your personal data to entities located outside Romania. These entities can be located in the European Union or outside the Union, including in countries that the European Commission has not recognized an adequate level of personal data protection.

We will always take steps 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, as the case may be, 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 within the EU to the United States of America.

You can contact us at any time, using the contact details set out above, to find out more information about the countries to which we transfer your data, as well as the guarantees we have put in place regarding these transfers.

How 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, according to industry standards.

We keep your personal data on secure servers, using the latest encryption algorithms and ensuring storage redundancy.

To make payments, we use the services of the PayU/Mobilpay payment processor. Any payment information is encrypted, using SSL technology.

Despite the measures taken to protect your personal data, we draw your attention to the fact that the transmission of information over the Internet, in general, or through other public networks, is not completely secure, there is a risk that the data will be seen and used by third parties unauthorized. We cannot be responsible for such vulnerabilities of systems that are not under our control.

What rights you have

The General Data Protection Regulation recognizes a series of rights regarding your personal data. You may request access to your data, correct any inaccuracies in our records, and/or object to the processing of your personal data. Additionally, you can exercise your right to file a complaint with the competent supervisory authority or seek legal redress. Where applicable, you may also benefit from the right to request the deletion of your personal data, the right to restrict data processing, and the right to data portability.

More information about each of these rights can be obtained by consulting the table presented below.

To be able to exercise your rights, you can contact us using the contact details set out above. Please note the following aspects if you wish to exercise these rights:

Identity. We take seriously the confidentiality of all records containing personal data. For this reason, please send us your requests regarding such records using the email address associated with the Transformtheday 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 to exercise 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 about any fees applied before resolving your request.

Response time. We aim to respond to any valid requests within a maximum of one month, unless this is particularly complicated or if you have made several requests, in which case we will respond within a maximum of two months. We will let you know if we need more than a month. We might ask you if you can tell us exactly what you want to receive or what exactly worries you. This will help us act faster 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.

The rights concerned and their description

Access

You can ask us:

• to confirm whether we are processing your personal data;
• to provide you with a copy of this data;
• to provide you with other information about your personal data, such as the data we have, 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 information.

Correction

You can ask us to rectify or complete your inaccurate or incomplete personal data. It is possible to try to check the accuracy of the data before rectifying them.

Data deletion

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 data processing is based on consent); or
• exercise a legal right to object; or
• they were processed illegally; or
• we have a legal obligation in this regard.

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
• for establishing, exercising or defending a right in court.

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

Keep in mind that, before exercising this right, you download from your Transformtheday account and save all the documents related to the orders made from Transformtheday, regardless of whether the 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 deletion, you will lose all these documents and Transformtheday will be unable to make them available to you because the process of deleting the data, respectively the Transformtheday account, with all the data and the related documents, is an irreversible process.

Restriction of data processing

You can ask us to restrict the processing of personal data, but only if:

• their accuracy is contested (see rectification section), to allow us to verify their accuracy; or
• the processing is illegal, but you do not want the data to be deleted; or
• they are no longer necessary for the purposes for which they were collected, but you need them to establish, exercise or defend a right in court; 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
• to establish, exercise or ensure the defense of a right in court; or
• to protect the rights of another natural or legal person.

Data portability

You can ask us to provide your personal data in a structured, commonly used and machine-readable format, 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 based on your consent or the conclusion or execution of a contract with you; and

The opposition

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 consider 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 the creation of profiles), without invoking any reason, in which case we will stop this processing as soon as possible.

Automated decision making

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

• produce legal effects with respect to you; or
• affects you in another similar way and to a significant extent.
• This right does not apply if the decision reached following automatic decision-making:
• it is necessary for us to conclude or perform a contract with you;
• is authorized by law and there are adequate guarantees 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 supervisory authority for data protection are as follows:

• Autoritatea Nationala de Supraveghere a Prelucrarii Datelor cu Caracter Personal;
• Municipiul Bucuresti, Sector 1, Intr. Straulesti, Nr.15c, Et.4, Romania;
• Phone: +40 768 722 737 
• E-mail: myioana@transformtheday.ai

Without affecting your right to contact the supervisory authority at any time, please contact us in advance, and we promise you that we will make all the necessary efforts to resolve any problem amicably.

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

• by email to: myioana@transformtheday.ai or
• by post or courier to the address: Bucharest Municipality, Sector 1, Intr. Straulesti, No. 15c, Et. 4, Ap. 404 - with the mention to the attention of the Data Protection Officer of POLISEMANTIC IDEAS SRL.