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Privacy Policy
Privacy Policy
How RECOSPORT SRL collects, uses and protects personal data when you use a Recosport online store, place orders or communicate with us.
RO28735800 · J2011001722123
1. Who is the data controller
The controller of personal data processed through Recosport online stores is RECOSPORT SRL, with registered office at Str. Avram Iancu 408H, Ap. 2, Florești, Cluj County, Romania, VAT/CUI RO28735800, Trade Register no. J2011001722123.
- Email for privacy matters and exercising your rights: [email protected]
- Phone: +40 790 871 225 / 0364 264 345
- Contact page: /contactus
Where, for a particular processing activity, a supplier or partner independently determines the purposes and means of processing, that party may act as a separate controller and its own privacy policy will apply to processing carried out on its own behalf.
2. Who and when this policy applies to
This policy applies to individuals who:
- visit or use a Recosport website;
- create an account, add products to a basket, favourites or personal lists;
- place or receive an order, including where a purchase is made for a company, club, institution or other professional customer;
- request a quotation, support, service, warranty, return or withdrawal from a contract;
- subscribe to a newsletter or express marketing preferences;
- submit reviews, questions or other communications to Recosport.
For legal entities, this policy applies to the personal data of representatives, employees, collaborators and contact persons.
3. What personal data we may collect
Depending on how you interact with us, we may process the following categories:
- Identification and contact data: first name, last name, email, phone number, billing/delivery address, city, county/region and country.
- Account data: account identifier, preferences, favourites, viewed products, saved addresses and information associated with authentication. Passwords should be stored in technically protected form, not in plain text.
- Order data: products ordered, quantities, prices, discounts, delivery and payment methods, order status, tracking/AWB data, return history and warranty history.
- B2B billing data: organisation name, tax/VAT identifier, address and, where applicable, representative or contact-person details.
- Payment data: payment method, transaction status, transaction identifier and limited information communicated by the payment processor. Full card details are generally entered and processed within the payment provider's environment and are not intended to be stored by Recosport.
- Communication data: the content of messages sent through forms, email, phone, chat, WhatsApp or other channels you use to contact us.
- Technical and usage data: IP address, date and time of access, URLs accessed, browser, operating system, device, technical identifiers, security logs and information about interaction with the website.
- Marketing preferences and consent: subscription/unsubscription, the date and manner in which consent was expressed, and cookie preferences.
- Reviews: displayed name or alias, rating, review content and, where necessary to verify authenticity, information that the product was ordered.
We do not intentionally collect more data than is necessary for the purposes described in this policy.
4. Where the data comes from
Personal data may come from:
- you directly, when you create an account, place an order, complete a form or contact us;
- payment-service providers, for confirmation or transaction status;
- couriers and logistics providers, for delivery, return or transport-incident status;
- cookie technologies and analytics tools, within the limits of your expressed preferences and applicable law;
- a representative of a company or institution that provides us with the details of a contact person for the performance of a business relationship;
- public sources or public authorities, only where there is an appropriate purpose and legal basis.
If we receive personal data about you from a third party and Article 14 GDPR requires us to inform you, we will provide the legally required information within the applicable period.
5. Why we process personal data and the legal basis
| Purpose | Examples of data | Main legal basis |
|---|---|---|
| Creating and managing an account | Name, email, phone, addresses, account data | Art. 6(1)(b) GDPR performance of a contract / pre-contractual steps |
| Processing and delivering orders | Identification, contact, address, order, AWB/tracking, status | Art. 6(1)(b) contract; where applicable Art. 6(1)(c) legal obligation |
| Invoicing, accounting and tax compliance | Billing, order and transaction data | Art. 6(1)(c) legal obligation |
| Payments and transaction reconciliation | Payment method, status, transaction identifier | Art. 6(1)(b) contract and, where applicable, legal obligations |
| Returns, withdrawal, warranty, service and complaints | Order, contact details, product, correspondence, documents | Art. 6(1)(b) contract; Art. 6(1)(c) legal obligation; Art. 6(1)(f) establishment, exercise or defence of rights |
| Support and operational communications | Name, email, phone, message, request history | Art. 6(1)(b) or Art. 6(1)(f) legitimate interests |
| Website security, fraud and abuse prevention | IP, logs, device, technical activity | Art. 6(1)(f) legitimate interests; where applicable, legal obligation |
| Newsletter and direct marketing | Email, phone, preferences, consent history | Art. 6(1)(a) consent; or the legal exception for existing customers under the applicable electronic-communications rules |
| Analytics, measurement and advertising based on non-essential cookies | Cookie IDs, IP, interactions, events | Art. 6(1)(a) consent together with the applicable electronic-communications rules |
| Establishment, exercise or defence of legal rights | Relevant account, order and correspondence data | Art. 6(1)(f) legitimate interests and, where applicable, legal obligation |
Where legitimate interests are relied upon, we assess the necessity of processing and its impact on your rights and freedoms. You have the right to object to processing in the circumstances provided by Article 21 GDPR.
6. Accounts, orders and delivery
We use the data necessary to create and administer your account, process an order, communicate its status, generate commercial documents and organise delivery.
For delivery, the necessary data may be shared with the selected courier or logistics provider. A courier may also process certain data as an independent controller for its own obligations, including delivery management, proof of delivery, returns and legal compliance.
Communications strictly related to an order, security, invoice, delivery, service or return are not marketing communications and may be sent irrespective of newsletter preference where they are necessary to perform the contract or comply with law.
7. Payments
Depending on the chosen method, payment may be processed by banks or specialised payment providers. They receive the data required to authorise and process the transaction and may, for certain activities, act as independent controllers in accordance with their own legal obligations.
Recosport generally receives only the information necessary to confirm and reconcile payment, such as transaction status, amount, currency and a transaction identifier. We do not ask you to send a full card number, CVV/CVC code or bank authentication codes by email or form.
8. Returns, withdrawal, warranties and complaints
To manage a return, exercise of withdrawal rights, warranty or complaint, we may use identification and contact data, order number, the product concerned, relevant technical reasons, documents or photographs necessary for resolution, and communication history.
The data is used for performance of the contract, compliance with legal obligations and, where necessary, the establishment, exercise or defence of legal rights.
The online withdrawal function and return procedures should collect only the information necessary to identify the contract and resolve the request.
9. Newsletter, direct marketing and commercial preferences
If you subscribed to the newsletter or provided valid consent, we may send commercial communications through the channels you selected. You may withdraw consent at any time, without affecting the lawfulness of processing carried out before withdrawal.
For existing customers, an email address obtained directly in connection with a sale may be used, where permitted by law, for communications concerning our own similar products or services, provided a clear and free opportunity to object is offered both when the address is collected and in every communication.
You can unsubscribe through the link in commercial messages or by emailing [email protected].
12. Special categories of data and children's data
If you voluntarily provide such information in a request and processing is necessary, we will limit its use to the purpose for which it was provided and identify a condition permitted by Article 9 GDPR, for example explicit consent or necessity for the establishment, exercise or defence of legal claims. If there is no lawful condition and no necessity, the data will be minimised or removed.
For information-society services offered directly to a child and based on consent, the rules of Article 8 GDPR concerning the age of 16 and authorisation by the holder of parental responsibility apply where relevant.
13. Who we may disclose data to
We do not sell personal data. Where necessary and proportionate, data may be made available to the following categories of recipients:
- hosting, infrastructure, software-maintenance, security and IT-service providers;
- payment processors, banks and financial-service providers used for a transaction;
- couriers, locker operators and logistics providers;
- invoicing, accounting, ERP and administrative-service providers;
- email, SMS, support and marketing providers, only for permitted purposes;
- analytics and advertising providers, only subject to consent and applicable cookie rules;
- manufacturers, importers or authorised service centres where required for warranty, repair or technical assistance;
- consultants, lawyers, auditors, insurers or other professionals subject to confidentiality obligations;
- public authorities, courts or law-enforcement bodies where disclosure is required or permitted by law.
Where a provider processes personal data exclusively on our behalf, the relationship is governed, where applicable, by the requirements of Article 28 GDPR.
14. Transfers of personal data outside the European Economic Area
Some technology services may involve access to or storage of data outside the European Economic Area. Such a transfer is made only where a mechanism permitted by Chapter V GDPR is available, for example:
- an adequacy decision adopted by the European Commission;
- standard contractual clauses approved by the European Commission and, where necessary, supplementary measures;
- other safeguards or derogations provided by the GDPR, where applicable.
You may request additional information about the safeguards applicable to a relevant transfer using the contact details in this policy.
15. How long we retain personal data
We do not keep personal data longer than necessary. Because retention periods differ by information type and legal obligation, we use the following criteria:
| Category | Retention criterion |
|---|---|
| Customer account | While the account is active or until an erasure request, with separate retention of information that must be maintained for legal reasons or to defend rights. |
| Orders, invoices and accounting records | According to mandatory retention periods under applicable accounting, tax and archiving legislation. |
| Returns, withdrawals, warranties and complaints | For the duration of resolution and afterwards for as long as required by legal obligations and applicable limitation periods. |
| Correspondence and support | For as long as needed to resolve the request and, where a dispute may arise, for the reasonable period necessary to defend rights. |
| Marketing | Until consent is withdrawn or an objection is exercised; we may retain a minimal “do not contact” record in order to honour the preference. |
| Evidence of consent | For as long as necessary to demonstrate compliance and manage any disputes. |
| Cookies and analytics identifiers | According to the durations stated in the Cookie Policy and preference tool and no longer than justified by the purpose. |
| Security logs | For a limited period proportionate to security, incident-prevention and abuse-investigation needs. |
At the end of the relevant period, data is erased, anonymised or archived as permitted or required by law.
16. How we protect personal data
We apply technical and organisational measures appropriate to the risk, including measures concerning access control, confidentiality, integrity and availability of systems, backups, updates, monitoring and incident-management procedures, depending on the nature of the processing.
No transmission over the internet can be guaranteed to be free of all risk. However, responsibility for processing security is not transferred to the user: Recosport and its providers must implement the measures required by law.
In the event of a personal-data breach, we apply the assessment, documentation and notification obligations required by the GDPR, including notification to the supervisory authority and, where required, to affected individuals.
17. Your rights
Subject to the conditions set out in the GDPR, you have the following rights:
Confirmation of processing and a copy of personal data together with the information required by law.
Correction of inaccurate data and completion of incomplete data.
Deletion of personal data in the circumstances provided by Article 17 GDPR.
Restriction of processing in the circumstances provided by Article 18 GDPR.
Receiving personal data in a structured format and transmitting it to another controller where Article 20 applies.
Objecting to processing based on legitimate interests and, at any time, to direct marketing.
At any time for processing based on consent, without retroactive effect.
The rights provided by Article 22 GDPR where a decision is based solely on automated processing and produces legal or similarly significant effects.
Requests can be sent to [email protected]. To protect personal data, we may request reasonable information to verify identity.
We will respond without undue delay and normally within one month of receiving the request. The period may be extended by up to two additional months in the circumstances permitted by the GDPR, with notice given within the first month. Exercising your rights is in principle free of charge, subject to the exceptions for manifestly unfounded or excessive requests.
18. Profiling and solely automated decisions
Content personalisation, advertising segmentation or behaviour analysis may constitute forms of profiling where used, but such activities must be carried out only under an applicable legal basis and, for non-essential technologies, subject to cookie consent.
Recosport does not ordinarily use, through its online stores, decisions based solely on automated processing that produce legal effects or similarly significantly affect you. If such a mechanism is introduced, you will receive the information and safeguards required by Article 22 GDPR, including, where applicable, the possibility of human intervention and contesting the decision.
Payment providers may use their own anti-fraud systems as independent controllers under their own policies and legal obligations.
19. Right to lodge a complaint
If you believe our processing of your personal data infringes applicable data-protection law, we encourage you to contact us first so that we can review and address the issue.
You also have the right to lodge a complaint with the competent supervisory authority. In Romania:
National Supervisory Authority for Personal Data Processing (ANSPDCP)
Bd. G-ral Gheorghe Magheru nr. 28-30, Sector 1, Bucharest, postal code 010336
Phone: +40 31 805 92 11
Email: [email protected]
Website: www.dataprotection.ro
You also have the right to an effective judicial remedy under applicable law.
20. Third-party links and services
The website may contain links, maps, social-media buttons, payment services or other components operated by third parties. When you access a third-party service, the operator of that service may process personal data under its own privacy policy. We recommend reviewing the information provided by that operator.
The presence of a link does not mean that Recosport controls all processing carried out by the relevant provider.
21. Changes to this policy
We may update this policy to reflect legislative, technological or operational changes. The current version and the date of update are published on this page.
If a change materially alters how we use personal data and applicable law requires notice or renewed consent, we will take the appropriate steps before the new processing begins.
22. Data-protection contact
RECOSPORT SRL
Str. Avram Iancu 408H, Ap. 2, Florești, Cluj County, Romania
CUI/VAT RO28735800 · J2011001722123
Email: [email protected]
Phone: +40 790 871 225 / 0364 264 345
