What is the purpose of this Privacy Policy?

WINCIRQUE respects your privacy and is committed to protecting your personal data. The aim of this Privacy Policy is to give you information on how WINCIRQUE collects and processes your personal data through:

a) your use of WINCIRQUE website, including any data you may provide through WINCIRQUE websites when you make an enquiry or purchase a product or a service;

b) your registration for, purchase of or use of any WINCIRQUE products and/or services;

c) your use of any WINCIRQUE social media channels; and

d) your sending of personal data to WINCIRQUE by any other means.

This Policy will also inform you of what we do with personal data, how we look after personal data and tell you about your privacy rights and how the law protects you.

It is important that you read this Privacy Policy together with any other privacy policy or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy Policy supplements the other notices and is not intended to override them.

This Privacy Policy contains the following information: 1. WHO WE ARE? 2. IMPORTANT INFORMATION ABOUT THIS POLICY 3. YOUR PERSONAL DATA 4. HOW IS YOUR PERSONAL DATA COLLECTED? 5. HOW WE USE YOUR PERSONAL DATA 6. DATA RETENTION

1. Who we are

WINCIRQUE responsible for your personal data so when we mention “WINCIRQUE”, “we”, “us” or “our” in this Privacy Policy, we are referring to WINCIRQUE SRL.

This Policy shall apply to any WINCIRQUE website including any subdomains that may be made available by us from time to time; including websites with the ending wincirque.com and all WINCIRQUE social media channels (“Website(s)”).

Contact details

If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact us using the following details: [email protected].

WINCIRQUE SRL

CUI 48882571

J40/18470/2023

Address : Bucureşti, Sector 2, Str. Vaselor, Nr.48, Parter, Camera 14, Ap.1

2. Important information about this Policy

Changes to the Privacy Policy and your duty to inform us of changes

This Privacy Policy sets out your rights under the the EU general data protection regulation 2016/679 (GDPR) and any other national or european regulations concerning data protection (hereinafter referred as the “Law”).

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

We may update this Privacy Policy from time to time without prior notice to you or other recipients.

You can exercise your rights of opposition, access, correction and cancellation of your personal data under the terms provided by Law. These rights may be exercised in writing by letter enclosing a copy of your identity document and addressed to WINCIRQUE at the address indicated at the of this document or by email to the following address: [email protected]. You have the right to make a complaint at any time to The National Supervisory Authority For Personal Data Processing (ANSPDCP). We would, however, appreciate the chance to deal with your concerns before you approach The National Supervisory Authority For Personal Data Processing so please contact us in the first instance. The personal data collected on completing this form is confidential and secured.

Personal data to which WINCIRQUE has access will be stored phisically and/or electronically in a file owned by WINCIRQUE for the following purposes: (i) managing the maintenance of the relationship established with WINCIRQUE, (ii) performing the management, administration, provision, expansion and improvement of the content, information and services offered by WINCIRQUE, and (iii) the delivery of all communications. A more detailed description of purposes is presented below.

Any processing or transfer or your data is supervised according to the requirements of the GDPR, by standard protection clauses adopted by the Romanian Law 190/2018. By virtue of this Policy, you are hereby informed, and you accept that WINCIRQUE, with the aforementioned purposes and for storage and security purposes, will transfer your personal data to third parties located in some other EU or non-EU countries. In compliance with current regulations regarding protection of personal data, WINCIRQUE undertakes to comply with the secrecy and confidentiality obligation in this regard and has adopted, for this purpose, the security levels provided in the applicable privacy regulations, installing the necessary technical means and undertaking all measures at its disposal to prevent the alteration, loss, processing, theft or unauthorized access to the same. If you reject the terms of this Privacy Policy If you do not agree to your personal data being used in accordance with this Privacy Policy, please do not submit your personal data to us through the Website or any other means.

Third-party links

The Website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy policies. When you leave our Website, we encourage you to read the privacy policy of every website you visit.

3. Your personal data

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Contact Data includes billing address, delivery address, postal address, e-mail address and telephone numbers.

Financial Data includes bank account, billing information, invoicing details and payment card details. Identity Data includes first name, last name, date of birth and gender.

Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.

Profile Data includes your usernames and passwords (for WINCIRQUE platforms), purchases or orders made by you, your interests, preferences, feedback, survey responses and enquiries submitted to WINCIRQUE.

Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.

Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us, including records of any discount codes used.

Usage Data includes information about your visit to a Website, including the Uniform Resource Locators (URL) clickstream to, through and from the Websites (including date and time), products and/or services you viewed or searched for, page response times, download errors, lengths of visits to certain pages, page interaction information (such as scrolling, clicks and mouse-overs) and methods used to browse away from the page.

We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel/restrict a product or service you have with us, but we will notify you if this is the case at the time.

4. How is your personal data collected?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your personal data by filling in forms or by corresponding with us by post, e-mail or otherwise. This includes personal data you provide when you:

1. submit an online query or request a call back;
2. purchase goods or services from us;
3. speak with one of our teams;
4. create an account on our Website;
5. subscribe to a service or publication;
6. request marketing to be sent to you;
7. enter a competition, promotion or complete a survey; or
8. give us feedback.

Third parties. We may receive personal data about you from various third parties as set out below:

• analytics providers such as Google; advertising networks; and search information providers;

• providers of technical, payment and delivery services.

5. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• where we need to perform the contract we are about to enter into or have entered into with you.

• where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

• where we need to comply with a legal or regulatory obligation.

• where we have your consent.

Purposes for which we will use your personal data

We have set out below ways we plan to use your personal data, and which legal basis we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us at [email protected] if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity for using your personal data

• To respond to enquiries or requests for information

• To register you as a new Client when purchasing products or services from WINCIRQUE

• To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy

(b) Asking you to provide feedback or take a survey Less commonly, we may also process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else's interests) and you are not capable of giving your consent.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We will only send marketing where you have agreed to receive marketing from us. Promotional offers from us

We may use your personal data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, Services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased goods or Services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any company outside the WINCIRQUE group of companies for marketing purposes.

Opting out

You can ask us to stop sending you marketing messages at any time by contacting us.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of you entering into a contract with us.

6. Retention of personal data

We may keep your personal data for a period of maximum 3 years after completion or termination of any relationship between you and WINCIRQUE, for the purpose of settling any requests, complaints or actions of you against WINCIRQUE in regards to performing our contractual obligations.

You may request the deletion or destruction of such data before the abovementioned term, from the moment of which you will waive any right to file a request, complaint or action against WINCIRQUE in regards to our contractual obligations.

Other provisions:

Cookies Policy

Each time that you access the Website, it collects the following information about the visit carried out: domain, directory areas, source, pages visited.

Authorization

The delivery of personal data by any means and/or access to the Website constitutes your express authorization for WINCIRQUE to carry out the processing described in the preceding paragraphs and your approval and acceptance of all declarations and representations contained therein.

For additional information please consult our TERMS AND CONDITIONS.