PRIVACY POLICY

In short : We process your information to provide improve and administer our services communicate with you for security and fraud prevention, and to comply with law we may also process your information for other purposes with your consent.

We process your personal information for a variety of reasons, depending on how you interact with our services, including:

• To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log into your account as well as keep your account in working order.
• To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service.
• To respond to user inquiries/ offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.
• To save or protect an individual’s vital interest. We may process your information when necessary to save or protect an individual’s vital interest, such as to prevent harm.

In short: We only process your personal information when we believe it is necessary, and we have a valid legal reason (i.e. legal basis) to do so under applicable law, like with your consent, to comply with laws to provide you with services to enter into our fulfil our contractual obligations, to protect your rights, or fulfil our legitimate business interests.

The General Data Protection Regulation (GDPR) and (Romanian?) GDPR require us to explain the valid legal basis we rely on in order to process your personal information. As such, we may rely on the following legal basis to process your personal information :

• Consent. We may process your information if you have given us permission (i.e. consent) to use your personal information for a specific purpose. You can withdraw your consent at any time. Learn more about withdrawing your consent.
• Performance of a Contract. We may process your personal information when we believe it is necessary to fulfil our contractual obligations to you, including providing our Services, or at your request prior to entering into a contract with you.
• Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement, body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
• Vital interests. We may process your information where we believe it is necessary to protect your vital interests, or the vital interests of the third-party, such as situations involving potential threats to the safety of any person.

In legal terms, we are generally the ‘data controller’ under European data protection laws of the personal information described in this privacy notice, since we determine the means, and/or purposes of the data processing we perform. This privacy notices does not apply to the personal information we process as a ‘data processor’ on behalf of our customers. In those situations, the customer that we provide services to, with whom we have entered into a data processing agreement is the ‘data controller’ responsible for your personal information, and we merely process your information on their behalf in accordance with your instructions. If you want to know more about our customers privacy practices, you should read their privacy policies and direct any questions you have to them.

In short: We may share information in specifications described in this section and/or with the following third parties.

We may need to share your personal information in the following situations:

• Business Transfers. We may share or transfer your information in connection with, or during negotiations on any merger sale of company, assets, financing, or acquisition of all or a portion of our business to another company.
• When we use Google analytics. We may share your information with Google Analytics to track and analyse the use of the Services. The Google Analytics Advertising Features that we may use include Google Analytics Demographics, and Interest Reporting. To opt out of being tracked by Google Analytics across the Services visit http://tools.google.com/dlpage/gaoptout. You can out of Google Analytics Advertising Features through Ads Settings, and Ad Settings for mobile apps. Other opt out means include http://optout.networkadvertising.org and http://www.networkadvertising.org/mobile-choice .For more information on the privacy practices of Google, please visit the Google Privacy & Terms page.
• Offer Wall. Our application(s) made display a third-party hosted ‘offer wall’. Such an offer wall allows third-party advertisers to offer virtual currency, gifts, or other items to users in return for the acceptance and completion of an advertisement offer. Such an offer wall may appear in our application(s) and be displayed to you based on certain data, such as your geographic area or demographic information. When you click on an offer wall, you will be brought to an external website belonging to other persons and will leave our application(s). A unique identifier, such as your user ID, will be shared with the offer wall provider in order to prevent fraud and properly credit your account with the relevant reward.

In Short: We are not responsible for the safety of any information that you share with third parties that we may link to or who advertise on our Services, but are not affiliated with our Services.

The Services, including our wall offer, may link to third-party websites, online services or mobile applications, and/or contain advertisements from third parties that are not affiliated with us and which may link to other websites services or applications. Accordingly, we do not make any guarantee regarding any such third parties, and we will not be liable for any loss or damage caused by the use of such third-party website services or applications. The inclusion of a link towards a third-party website, service or application does not imply an endorsement by us. We cannot guarantee the safety and privacy of data you provide to any third parties. Any data of collected by third parties is not covered by this privacy notice. We are not responsible for the content or privacy and security practices and policies of any third-party, including other websites, services or applications that may be linked to or from the Services. You should review the policies of such third parties and contact them directly to respond to your questions.

In short: If you choose to register or log into our Services using a social media account, we may have access to certain information about you.

Our Services offer you the ability to register and login using your third-party social media account details (like your Facebook or Twitter logins). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile information we receive may vary depending on the social media provider concerned, but will often include your name, email address, friends list, and profile picture, as well as other information you choose to make public on such a social media platform.

We will use the information we receive only for the purposes that are described in this privacy notice or that are otherwise made clear to you on the relevant Services. Please note that we do not control and are not responsible for, other uses of your personal information by your third-party social media provider. We recommend that you review their privacy notice to understand how they collect, use, and share your personal information, and how you can set your privacy preferences on their sites and apps.

In short: we keep your information for as long as necessary to fulfil the purposes outlined in this privacy notice, unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law, such as tax, accounting, or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than the period of time in which users have an account with us.

When we have no ongoing legitimate business and need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

In short: We aim to protect your personal information through our system of organizational and technical security measures.

We have implemented appropriate and reasonable, technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, super criminals, or other unauthorized third parties will not be able to defeat, our security and improperly collect, access, steel, or modify your information. Although we will do our best to protect your personal information, transmission of personal information from our services is at your own risk. You should only access the services within a secure environment.

In short: In some regions, such as the European economic area (EEA), United Kingdom (UK), and Switzerland, you have rights that allow you greater access to control over your personal information. You may review change or terminate your account at any time.

In some regions (like the EEA, UK, and Switzerland), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information,(ii) to request rectification or erasure, (iii) to restrict the processing of your personal information, (iv) if applicable to data portability and (v) not to be subject to automated decision making. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us using the contact details provided in the section ‘How can you contact us about this notice?’ below.

We will consider and act upon any request in accordance with applicable data protection laws.

If you are located in the EEA or UK, and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority.

If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

Withdrawing your consent: If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section ‘How can you contact us about this notice’ below.

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Account information 

If you would have any time like to review or change the information in your account to terminate your account, you can:

• Contact us using the contact information provided.
• Log into your account settings and update your user account.

Upon your request to terminate your account, we will deactivate your account and information from our active databases . However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.

If you have questions or comments about your privacy rights, you may email us at office@sinica.ro.

Most with browsers and some mobile operating systems and mobile applications include a do not track Do-Not-Track (‘DNT’) feature or setting you activate the signal your privacy preference not to have data about your online browsing activities, monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DND browser, signals, or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this privacy notice from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of
such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

If you have questions or comments about this notice, you may contact our Data, Protection Officer (DPO), Dumitru Rasvan Andrei, by email at rasvan.dumitru@sinica.ro, by phone at +40721961911, or contact us at:

Sinica Group SRL

Dumitru Rasvan Andrei

61-63 Ion Ionescu De La Brad Blvd. 1^st Sector, Bucharest,

Tel: +40 (722) 661 651

Bucharest, 013811

Romania

If you are a resident in the European Economic Area or Switzerland, we are the ‘data controller’ of your personal information . We have appointed Dumitru Rasvan Andrei to be our representative in the EA and Switzerland. You can contact them directly regarding our processing of your information by email at rasvan.dumitru@sinica.ro, by visiting http://www.carmem.ro/contact or https://sinica.ro/contact , by phone at +40721961911, or by post to:

Bulevardul Ion Ionescu De La Brad 61-63,

Sectorul 1, Bucuresti 013812,

Romania

Based on the applicable law of your country, you may have the right to request access to the personal information we collect from you change that information, or delete it. To request a review or delete your personal information please visit http://carmem.ro/account_delete/