Bro and Sis

Cookie and Similar Technologies Usage Policy

This policy refers to the cookies and similar technologies used, where applicable, on the websites and applications operated by S.C. Barbarella Tech SRL, with its registered office in Chiajna, str. Rezervelor 66B/93, Ilfov, Romania, under the BROandSIS brand, hereinafter referred to as BROandSIS.

The proper protection of personal data is an important objective for us. Our goal is to be as clear and transparent as possible regarding our approach in this matter. For any questions, please contact us at contact@broandsis.tv.

What Are Cookies?

A cookie is a small file made up of letters and numbers that is stored on the computer, mobile device, or other equipment of a user accessing the internet. The cookie is installed at the request issued by the user’s terminal to a server of BROandSIS or to a third-party server.

What Are Cookies Used For?

These files primarily enable the recognition of the user’s terminal and the presentation of content in a relevant manner, tailored to the user’s preferences. Cookies provide users with a pleasant browsing experience and support our efforts to offer services tailored to users, such as online privacy preferences, shopping cart, or relevant advertising. They are also used to prepare aggregated anonymous statistics that help us understand how users interact with our web pages, allowing us to improve their structure and content without allowing the personal identification of the user

What Cookies Do We Use?

We use two types of cookies: session cookies and persistent cookies. Session cookies are temporary files that remain on the user’s device until the session ends or the application is closed. Persistent cookies remain on the user’s device for a period defined by the cookie’s parameters or until manually deleted by the user.

How Are Cookies Used on This Site?

A visit to this site may place the following types of cookies:

– Strictly necessary cookies for the site’s functionality

– Analytical cookies

– Advertising cookies

Strictly necessary cookies and/or similar technologies are essential for the proper functioning of the site, being set on your device when you access the site or following actions taken on the site, as applicable. You can set your browser to block these cookies; however, in this case, certain sections of the site may not function correctly.

Do Cookies Contain Personal Data?

Cookies or similar technologies, by themselves, do not require personal information to be used and, in many cases, do not personally identify internet users. However, there are situations where personal data may be collected through the use of cookies to facilitate certain functionalities for the user or to provide the user with an experience tailored to their preferences. Such data is encrypted in a way that prevents unauthorized access.

What Are Similar Technologies?

There are other technologies that can be used for the same purposes as cookies. The www.broandsis.tv website uses a similar technology called Local Storage, which allows information to be stored on the terminal (computer, mobile phone, etc.).

Blocking Cookies

Most browsers are set by default to accept cookies, but you have the option to change the settings to block some or all cookies.

If you choose to block cookies, some functionalities of the site will be disabled, which may cause certain malfunctions or errors while using our site. For example, blocking cookies may prevent you from:

– Logging into your account

– Making online purchases

– Downloading content online

If you agree with these limitations and wish to block cookies, follow the instructions below: Choose your browser from the list below to see the steps you need to follow after opening your browser.

Google Chrome:

1. Click on the Settings icon (top right corner).
2. Click on “Settings.”
3. Go to “Privacy and security,” then “Site settings.”
4. Click on “Cookies and other site data.”
5. Choose your desired settings.

Mozilla Firefox:

1. Click on the menu icon and select “Options” from the list.
2. Click on the “Privacy & Security” tab.
3. Click on “Cookies and Site Data.”
4. Choose your desired settings.

Safari:

1. Select “Preferences.”
2. Click on “Privacy.”
3. Choose your desired settings.

Internet Explorer:

1. Select “Tools” from the main toolbar, then “Internet Options.”
2. Click on the “Privacy” tab.
3. Choose your desired settings.
4. Click “OK” to close.

The settings above are specific to each browser, and our company is not responsible for how they operate.

Managing Cookie Preferences

In general, a web browser application allows cookies and/or similar technologies to be stored on the device by default. These are stored for the periods described in the table in Section 12 below. These settings can be changed so that automatic cookie management is blocked by the web browser, or the user is notified each time cookies are sent to their device. Detailed information about the options and methods for managing cookies can be found in the settings area of the application (web browser). Limiting the use of cookies may affect certain functionalities of the website.

Why Are Cookies Important for the Internet?

Cookies and/or similar technologies are central to the efficient functioning of the Internet, helping to create a user-friendly browsing experience tailored to each user’s preferences and interests. Refusing or disabling cookies may make some websites or parts of websites unusable.

Disabling cookies does not mean you will stop receiving online advertising in compliance with the law— it only means that the advertising will no longer be able to take into account your preferences and interests, as indicated by your browsing behavior. Examples of important uses for cookies (which do not require user authentication through an account) include:

• Content and Services Tailored to User Preferences: Categories of products and services.

• Offers Tailored to User Interests: Promotions based on user interests.
• Password Retention: Remembering login credentials.
• Child Protection Data for Internet Content: Options such as family mode and safe search functions.
• Limiting Ad Frequency: Reducing the number of times a particular ad is shown to a user on a site.
• Providing Relevant Advertising: Ads that are pertinent to the user.
• Measuring, Optimizing, and Adapting Analytics Features: Such as confirming traffic levels on a website, the type of content viewed, and how a user arrives at a website (e.g., through search engines, directly, from other websites, etc.). Websites use these analyses to improve their services for the benefit of users.

Security and Privacy Aspects

In general, browsers have built-in privacy settings that provide various levels of cookie acceptance, expiration periods, and automatic deletion after the user has visited a certain site.

Other security aspects related to cookies:

• Customizing browser settings regarding cookies to reflect a comfort level of cookie usage security that suits you.
• If you are the only person using the computer, you may choose to set long expiration terms for storing browsing history and personal access data.
• If you share computer access, you might consider configuring the browser to delete individual browsing data each time you close the browser. This is an option to access sites that place cookies and remove any visit information upon closing the browsing session.

Links and Additional Useful Information

If you want to learn more about cookies and their uses, we recommend the following links:

– Microsoft Cookie Guide

– All About Cookies

BROandSIS uses third-party services to provide functionalities, for analytics, and for advertising. These third parties may set and use cookies and/or similar technologies on BROandSIS-operated websites and applications, as well as on websites and applications not operated by BROandSIS. For more details, please refer to the privacy policies, user preference management guides, and opt-out options provided by the companies managing these services, as applicable.

2. Intellectual Property Rights

The content, as described in the preamble, including but not limited to logos, stylized representations, trademarks, static images, dynamic images, text, and/or multimedia content presented on the site, is the exclusive property of BROandSIS, with all rights directly or indirectly obtained (through usage and/or publishing licenses) reserved by BROandSIS.

The Client/Buyer is not permitted to copy, distribute, publish, transfer to third parties, modify and/or otherwise alter, use, link to, display, or include any content in any context other than the original intended BROandSIS, to include any content outside the site, to remove any copyright marks indicating BROandSIS’s ownership of the content, or to participate in the transfer, sale, or distribution of materials created by reproducing, modifying, or altering the content, except with the express written consent of BROandSIS.

Any content accessed by the Client/Buyer by any means is subject to this Document, unless the content is accompanied by a specific and valid usage agreement between BROandSIS and the Client/Buyer, and without any implied or express warranty from BROandSIS regarding that content.

The Client/Buyer may copy, transfer, and/or use the content only for personal or non-commercial purposes, provided that such use does not conflict with the provisions of this Document.

If BROandSIS grants the Client/Buyer the right to use certain content accessed through this agreement, in the manner described in a separate usage agreement, this right extends only to the specific content mentioned in the agreement, only for the duration of that content’s existence or the period specified in the agreement, according to the stated conditions, if any, and does not constitute a contractual obligation on the part of BROandSIS to the respective Client/Buyer or any third party who has/obtains access to this transferred content by any means and who might be adversely affected in any way by this content, during or after the expiration of the usage agreement.

No content transmitted to the Client or Buyer, by any means of communication (electronic, telephone, etc.) or obtained through access, viewing, and/or visualization, constitutes a contractual obligation on the part of BROandSIS and/or the employee/representative of BROandSIS who facilitated the content transfer, if any, regarding that content.

Any use of the content for purposes other than those expressly permitted by this Document or by the accompanying usage agreement, if any, is prohibited.

3. Advertising:
4. Newsletters from BROandSIS are sent through specialized partners approved by BROandSIS. This ensures the confidentiality and security of the information.
5. Opting out of receiving newsletters does not imply withdrawing consent given for this Document.
6. Personal Data Processing:
7. In accordance with the requirements of Law no. 677/2001 for the protection of individuals with regard to the processing of personal data and the free movement of such data, as amended and supplemented, BROandSIS is obligated to manage personal data provided by you securely and only for the specified purposes.
8. The purposes of data collection are:

– Sending newsletters and/or periodic alerts via electronic mail (email, SMS)

– Market research, tracking, and monitoring of sales and customer behavior.

3. By completing the data in the account creation and/or order form, the Buyer unconditionally declares and agrees that their personal data may be included in BROandSIS’s database and expressly consents to all such personal data being stored, used, and processed for the purposes specified in point 2 above.

4. By reading this Document, you acknowledge that your rights under the law are guaranteed, including the right to information, the right to access data, the right to intervention, the right to object, the right not to be subject to an individual decision, and the right to seek justice in case of violation of the rights guaranteed by Law 677/2001 for the protection of individuals with regard to the processing of personal data and the free movement of such data.

5. Based on a written, dated, signed request sent to the address: contact@broandsis.tv, you can exercise, free of charge, once per year, the right to confirm whether or not your personal data is being processed.

6. Based on a written, dated, signed request sent to the address: contact@broandsis.tv, you can exercise the right to intervention on the data, as applicable:

1. Rectification, updating, blocking, or deletion of data whose processing is not in accordance with Law 677/2001 for the protection of individuals with regard to the processing of personal data and the free movement of such data, especially incomplete or inaccurate data;

1. Transformation of data into anonymous data if the processing is not in accordance with Law 677/2001 for the protection of individuals with regard to the processing of personal data and the free movement of such data;

1. Notification to third parties to whom the data has been disclosed, if such notification is not impossible or does not involve disproportionate effort compared to the legitimate interest that could be affected.

7. Additionally, BROandSIS may provide customers’ personal data to other companies with which it has partnership relationships, but only under a confidentiality commitment from these companies and only for the purposes mentioned in point 2, ensuring that this data is kept secure and that the provision of such personal information complies with current legislation. This may include: courier service providers, marketing service providers, payment/banking service providers, telemarketing or other services provided by companies with which we may develop joint market offering programs for our goods and services, and insurers.

8. The Buyer’s personal information may also be provided to the General Prosecutor’s Office, Police, courts, and other state authorities, based on and within the limits of legal provisions and as a result of express requests.

5. Privacy Policy Regarding the Processing of Personal Data

We consider ensuring the right to personal data protection a fundamental commitment for BROandSIS. Therefore, we will dedicate all necessary resources and efforts to process your data in full compliance with Regulation (EU) 2016/679 (“General Data Protection Regulation” or “GDPR”), as well as with any other applicable legislation in Romania. Given that one of the core principles of this legal framework is transparency, we have prepared this document to inform you about how we collect, use, transfer, and protect your personal data when you interact with us regarding our products and services, including through our website or mobile applications.

We reserve the right to periodically update and modify this Privacy Policy to reflect any changes in how we process your personal data or any changes in legal requirements. In the event of such changes, we will display the modified version of the Privacy Policy on our website. Please check the content of this Privacy Policy periodically.

Categories of Personal Data We Process

In general, we collect your personal data directly from you, allowing you to control the type of information you provide. Additionally, we may collect and subsequently process certain information regarding your behavior while visiting our website or using our mobile application to personalize your online experience and offer tailored promotions based on your profile. For more details on this, please refer to the section below on the purposes of processing.

On our website and within the mobile application, we may store and collect information through cookies and similar technologies, in accordance with our Cookie Policy.

We do not collect or otherwise process sensitive data, as defined by the General Data Protection Regulation (GDPR) under special categories of personal data.

Purposes and Legal Grounds for Processing

1.To Improve Our Services: We continuously aim to provide you with the best experience. To achieve this, we may collect and use certain information related to your buying behavior, invite you to complete satisfaction surveys after you have placed an order, or conduct market studies and research either directly or with the help of partners.

We base these activities on our legitimate interest in conducting commercial activities, always ensuring that your fundamental rights and freedoms are not compromised.

2. For Marketing: We want to keep you informed about the best offers for products/services that interest you. To this end, we may send you various types of messages (such as email, SMS, phone calls, mobile push notifications, web push notifications, etc.) containing general and targeted information, details about similar or complementary products to those you have purchased/downloaded, information about offers or promotions, updates about products or other commercial communications such as market research and opinion surveys. We may also provide personalized recommendations on our website and mobile application.

To offer you relevant information, we may use certain data about your buying behavior (e.g., products viewed/added to wishlist/purchased) to create a profile. We ensure that such processing respects your rights and freedoms, and that decisions based on this profiling do not have legal effects on you or significantly affect you.

In most cases, we base our marketing communications on your prior consent. You can change your mind and withdraw your consent at any time by:

   – Modifying the settings in your client account under the “Preferences” section;

   – Accessing the unsubscribe link included in the messages you receive from us;

   – Or by contacting BROandSIS using the contact details provided above.

 In certain situations, we may rely on our legitimate interest in promoting and developing our commercial activity for marketing activities. Whenever we use information about you for our legitimate interest, we take all necessary measures to ensure that your fundamental rights and freedoms are not affected. However, you can always request, through the means described above, that we stop processing your personal data for marketing purposes, and we will comply with your request.

3.To Defend Our Legitimate Interests: There may be situations where we use or transmit information to protect our rights and business activities. These situations may include:

      – Measures to protect our website and the users of the BROandSIS platform from cyberattacks;

      – Measures to prevent and detect fraud attempts, including transmitting information to competent public authorities;

      – Measures to manage various other risks.

The general basis for these types of processing is our legitimate interest in defending our commercial activities. We ensure that all measures we take balance our interests with your fundamental rights and freedoms. Additionally, in certain cases, we base our processing on legal requirements, such as the obligation to safeguard assets and values as provided by applicable legislation.

How Long We Retain Your Personal Data

As a general rule, we will retain your personal data for as long as you have an account on the BROandSIS platform. You can request at any time the deletion of certain information or the closure of your account, and we will comply with these requests, subject to retaining certain information even after account closure if required by applicable law or our legitimate interests.

Who We Share Your Personal Data With

As applicable, we may share or provide access to certain personal data of yours with the following categories of recipients:

– Companies within the same corporate group as BROandSIS;

– 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 may develop joint market offering programs for our goods and services.

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-party private entities is conducted in accordance with legal data protection and information confidentiality provisions, based on contracts concluded with these entities.

Where We Transfer Your Personal Data

As a general rule, your personal data is stored and processed within the European Union (EU) and the European Economic Area (EEA).

If your personal data is transferred outside the EU or the EEA, such transfers will be made (a) based on a decision by the European Commission determining that the third country provides an adequate level of protection, (b) under binding corporate rules, or (c) based on standard contractual clauses adopted by the European Commission. Additionally, if we identify that any of these measures are not sufficient to ensure an adequate level of protection, we will implement additional technical and/or organizational security measures on a case-by-case basis, in accordance with the recommendations of the European Commission.

How We Protect Your Personal Data

We are committed to ensuring the security of your personal data by implementing appropriate technical and organizational measures in accordance with industry standards. The transmission of your personal data is conducted using state-of-the-art encryption algorithms, and we store it on secure servers, ensuring data redundancy.

For processing payments, we use the services of the payment processor PayU. Any payment information is encrypted using HTTPS with TLS 1.2 encryption technology.

Despite the measures we take to protect your personal data, please be aware that transmitting information over the Internet or through other public networks is not completely secure. There is a risk that data may be intercepted and used by unauthorized third parties. We cannot be held responsible for such vulnerabilities in systems not under our control.

Your Rights

The General Data Protection Regulation (GDPR) recognizes a number of rights related to your personal data. You can request access to your data, correct any inaccuracies in our files, and/or object to the processing of your personal data. Additionally, you have the right to lodge a complaint with the competent supervisory authority or to seek judicial remedies. Depending on the circumstances, you may also have the right to request the deletion of your personal data, the right to restrict the processing of your data, and the right to data portability.

More information about each of these rights can be obtained by referring to the table provided below. To exercise your rights, you can contact us using the contact details provided above. Please note the following points if you wish to exercise these rights:

Identity

We take the privacy of all records containing personal data very seriously. For this reason, please send your requests regarding such records using the email address associated with your BROandSIS account. Otherwise, we reserve the right to verify your identity by requesting additional information to confirm your identity.

Fees

We will not charge a fee for exercising any right regarding your personal data, unless your request for information is unfounded, repetitive, or excessive, in which case we will charge a reasonable amount under such circumstances. We will inform you of any applicable fees before processing your request.

Response Time

We aim to respond to any valid requests within one month, unless the request is particularly complex or you have made multiple requests, in which case we will respond within two months. We will inform you if we need more than one month. We may ask you to specify exactly what you want to receive or what concerns you. This will help us act more quickly and shorten the response time to your request.

Third-Party Rights

We are not obligated to comply with a request if it would negatively affect the rights and freedoms of other data subjects.

Right of Access

You may request:

– Confirmation of whether we are processing your personal data;

– A copy of these data;

– Additional information about your personal data, such as: the data we hold, the purposes for which we use it, to whom we disclose it, whether we transfer it abroad and how we protect it, how long we keep it, what rights you have, how you can make a complaint, and where we obtained your data, to the extent that this information has not already been provided to you through this notice.

Data Rectification

You may request that we rectify or complete any inaccurate or incomplete personal data. We may attempt to verify the accuracy of the data before making any rectifications.

Data Erasure

You may request that we delete your personal data, but only if:

      – The data are no longer necessary for the purposes for which they were collected; or

      – You have withdrawn your consent (if the data processing was based on consent); or

      – You exercise a legal right to object; or

      – The data have been processed unlawfully; or

      – We have a legal obligation to do so.

We are not obligated to comply with your request for deletion of your personal data if the processing of your personal data is necessary:

    – To comply with a legal obligation; or

    – For the establishment, exercise, or defense of legal claims.

Restriction of Data Processing

You may request that we restrict the processing of your personal data, but only if:

– The accuracy of the data is contested (see the rectification section), to allow us to verify its accuracy; or

– The processing is unlawful, but you do not want the data to be deleted; or

– The data are no longer necessary for the purposes for which they were collected, but you need them to establish, exercise, or defend a legal claim; or

– You have exercised your right to object, and the verification of whether our rights override yours is ongoing.

We may continue to use your personal data following a restriction request if:

– We have your consent; or

– To establish, exercise, or defend a legal claim; or

– To protect the rights of BROandSIS or another individual or legal entity.

Data Portability

You may request that we provide your personal data in a structured, commonly used, and machine-readable format, or that we “port” it directly to another data controller, but only if:

– The processing is based on your consent or the performance of a contract with you; and

– The processing is carried out by automated means.

Objection

You may object at any time, on grounds relating to your particular situation, to the processing of your personal data based on our legitimate interest if you believe that your fundamental rights and freedoms outweigh this interest.

You may also object at any time to the processing of your data for direct marketing purposes (including profiling) without providing any reason, in which case we will cease this processing as soon as possible.

Automated Decision-Making

You may request not to be subject to a decision based solely on automated processing, but only when the decision:

– Produces legal effects concerning you; or

– Affects you similarly and to a significant extent.

This right does not apply if the decision resulting from automated decision-making:

– Is necessary for entering into or performing a contract with you;

– Is authorized by law and there are adequate safeguards for your rights and freedoms; or

– Is based on your explicit consent.

6. Complaints

You have the right to lodge a complaint with the supervisory authority regarding the processing of your personal data. In Romania, the contact details for the data protection supervisory authority are as follows:

National Authority for the Supervision of Personal Data Processing:

– B-dul G-ral. Gheorghe Magheru nr. 28-30, sector 1, postal code 010336, Bucharest, Romania

– Phone: +40.318.059.211 or +40.318.059.212;

– Email: anspdcp@dataprotection.ro.

Without affecting your right to contact the supervisory authority at any time, please contact us first. We promise to make every effort to resolve any issues amicably.

Please note that you can contact BROandSIS at any time by sending your request through any of the following methods:

– By email to: contact@broandsis.tv