GDPR

1. general information

The protection of your personal data is important to SC NATURAL PLUS COMERT SRL , so we pay particular attention to protecting the confidentiality of Visitors who access the website www.naturalplus.ro, as well as those whose personal data has been provided to us by a third party or to whom we have had access from another source, in accordance with Regulation (EU) 2016/679 adopted by the European Parliament and the Council of the European Union on April 27, 2016, on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC.

In this regard, please carefully read the terms of the following Privacy Policy regarding the protection and processing of personal data, to understand how your information will be treated.

This Policy is an informational note and explains the online practices of SC NATURAL PLUS COMERT SRL , regarding the application of the GDPR provisions, as well as the rights you enjoy regarding how your information is used through the Site SC NATURAL PLUS COMERT SRL .

Processing of personal data carried out by SC NATURAL PLUS COMERT SRL , will always be carried out in accordance with the provisions of the GDPR, as well as with the regulations on the protection of personal data specific to each country in which it operates SC NATURAL PLUS COMERT SRL .

Through this Personal Data Protection Policy, SC NATURAL PLUS COMERT SRL , wishes to inform Visitors about the nature of the personal data it collects, uses and processes, as well as the purposes of the processing. In addition, visitors to the site are informed through this Policy about the rights they benefit from.

We note that, in connection with SC NATURAL PLUS COMERT SRL , This Policy is valid and applies both in connection with the website and in connection with social media pages associated with our brand and name, including, but not limited to, Instagram (https://www. instagram.com/naturalplus/), Facebook (https://www.facebook.com/ naturalplus /).

As a result of visiting our Site, obtaining products or interacting with SC NATURAL PLUS COMERT SRL by any method or means of communication, such as e-mail, telephone or social networks, each data subject confirms that he or she agrees with this Privacy Policy. If you do not agree and do not want to accept the information, situations and/or conditions described in the Policy, please leave the Site and do not access the products provided.

1. Definitions

In this Privacy Policy, unless expressly provided otherwise, the expressions mentioned below shall have the following meanings:

1. Personal data controller

We inform you that the ownership of the domain and the owner of our virtual store, www.naturalplus.ro, corresponds to the authorized person Bucsa Mariana (Contact Person), Romanian legal entity, with registered office in Str.Nichita Stănescu 8, Dej 405200. Reg.com.: JJ12/317/1994 , CIF:5179064 email: claudiu@naturalplus.ro

As a personal data controller, SC NATURAL PLUS COMERT SRL is responsible for the processing of your personal data, which it collects directly or from other sources. We would like to point out that in order to ensure the protection and secure processing of your data, SC NATURAL PLUS COMERT SRL has made every effort to implement reasonable and appropriate technical and organizational measures.

1. Data Protection Officer (DPO)

SC NATURAL PLUS COMERT SRL, has no legal obligation to appoint a data protection officer. Consequently, any request regarding your personal data should be addressed to the contact details mentioned above.

If you have any concerns, questions, comments or complaints regarding this Policy or the use of personal data we process or you wish to exercise any of your rights, you can always send us your request to the e-mail address: claudiu@naturaplus.ro

1. What personal data do we process about you?

Depending on the products and features you wish to access or purchase, we will need to collect, use, store and/or transfer certain personal data.

Your personal data that will be processed are the following:

• identification data , such as first and last name, username, date of birth, gender, country, etc.;
• contacts , such as home address, billing address, email address, phone number;
• financial and commercial data , such as payment or card or bank account information, bank card details, information about products purchased, details of payments from and to the person concerned;
• technical data , such as IP (internet protocol) address, login details, browser type and version, location and time zone settings, browser plug-ins and their versions, operating system, operating platform and other technologies on the devices you use to access this Site and your user account;
• profile data , such as username, password, orders placed, history of products purchased, answers given to various questions or surveys;
• statistical and marketing data , such as information regarding the use of the Site and the products provided, preferences regarding the receipt of marketing materials and preferred means of communication;
• aggregated data , such as the collection, use and sharing of certain statistical or demographic data. Aggregated data may come from personal data, but is not considered “personal data” within the meaning of the law, as this information does not directly or indirectly reveal your identity. In the exceptional situation where aggregated data is combined or correlated with personal data in such a way that direct or indirect identification is possible, the resulting combined data will be treated by SC NATURAL PLUS COMERT SRL as personal data, which will be used in the manner described in this Policy. .

If you do not wish to provide us with information regarding your personal data, we draw your attention to the possibility that you may not be able to access certain functions, purchase the products provided, subscribe, create and/or access your user account, we may not be able to conclude contracts or collaborations necessary later or we may not be able to respond to your requests.

SC NATURAL PLUS COMERT SRL may hold personal data of the data subjects both as a result of direct interaction and by obtaining them indirectly or through technology.

For example, SC NATURAL PLUS COMERT SRL will receive personal data about you in the following situations:

• to order;
• creating a user account;
• news subscription;
• sending an email or a private message on social media;
• commenting on social platforms, tagging us in posts or sharing our content.

1. Principles regarding data processing

SC NATURAL PLUS COMERT SRL is committed to respecting the principles of personal data protection provided by the GDPR, to ensure that all data is:

• processed fairly, legally and transparently;
• collected for specified, explicit and legitimate purposes;
• adequate, relevant and limited in relation to the purposes for which they are processed;
• correct and up-to-date;
• kept in a form which does not permit identification of data subjects for longer than is necessary in relation to the purpose of the processing;
• processed in accordance with the rights of the data subject, in a manner that ensures adequate security of the processing, so that the data are intact, confidential and available.

1. Legal basis and purposes of processing personal data

• In accordance with art. 6 par. (1) letter b) of the GDPR, personal data may be processed for the purpose of concluding or executing the contract. In order to be able to offer you our products or to conclude any subsequent collaboration contracts, we must process personal data belonging to you, such as your name, surname, e-mail address, home address or residence, personal identification number, series and number of your ID card or passport.
• In accordance with art. 6 par. (1) letter c) of the GDPR, personal data may be processed for the purpose of fulfilling legal obligations, including those of a fiscal nature. For the fulfillment of certain obligations imposed by the fiscal authorities in connection with invoicing, reimbursement of certain amounts, payment of marketing affiliate commissions or reporting certain information to the authorities, SC NATURAL PLUS COMERT SRL may request and process a series of personal data, such as name, surname, home address or residence, personal identification number, series and number of the ID card or passport.
• In accordance with art. 6 para. (1) letter a) of the GDPR, personal data may be processed if the data subject has given consent to the processing of his or her personal data for one or more specific purposes.

NATURAL PLUS relies on consent only for direct marketing purposes, in which case it is expressly requested. As such, in certain cases, personal data will be used for the purpose of a) the potential transmission of newsletters or other marketing, informational or commercial messages; b) possible participation in various contests or promotions.

• In accordance with art. 6 par. (1) lett. f) of the GDPR, personal data may be processed for the purposes of the legitimate interests pursued by the controller or by a third party for the purpose of carrying out the object of activity. Such a situation will also take into account the analysis of your interest, as well as the fact that fundamental rights and freedoms are not affected. The legitimate interest may be represented by Bucsa Mariana (contact person) ensuring the correct functionality of the Site, as well as a permanent improvement of the experience of Site visitors.

Processing the form to purchase a product from the front page of the Site or from the "Shop" section and processing the form to access the free e-book

Natural Plus will use the information you provide in the appropriate section to place an order to purchase a product or in the appropriate section to obtain a free e-book, available on the site, solely for the purpose of processing your request.

By providing any personal data through the website www.naturalplus.ro, you understand and agree that your data will be processed in accordance with the provisions of this Data Protection Policy belonging to Natural Plus .

Natural Plus undertakes not to process the personal data provided for a purpose other than that for which they were transmitted, unless it is reasonably necessary to use them for another purpose, compatible with that of the initial processing or if there is your express consent to use them for other purposes.

Processing for billing purposes

Natural Plus will use the information you provide in the order placement section to purchase and pay for the desired product or by sending a subsequent message or email through which you communicate the data of the paying company, the personal data provided being used exclusively for the purpose of processing your request and to send you the invoice for the purchased product.

Payment processor

To implement payments on our website, Natural Plus uses external payment processing providers. In connection with the processing of payments in this context, we do not process or retain personal data or information such as credit/debit card details used to make the payment. This information will be provided directly by you to the payment processor Netopia Payments or through your Paypal account, and the use of this data is governed by the providers' data protection policies, which can be consulted here and here.

Processing for the purpose of registration as a User

To access the digital products "Game Changer Video Course" and "Smart Money - online academy subscription", the User must create an account. In this case, Natural Plus will use the information you provide in the appropriate account creation and authentication section, such as contact details and identification data, to register you as a User and subsequently allow you to access your account.

As a User, you have the possibility to request the deletion of your account and the processed personal data by sending a request to Natural Plus , through the agreed and presented communication methods.

Processing for the purpose of sending the Newsletter

If you have agreed to subscribe to the newsletter Natural Plus, we state that your personal data will be collected, processed and used for the purpose of sending you various information from our area of ​​activity, information about possible campaigns and/or marketing messages. .

We mention that Natural Plus reserves the right to select the subscribers to whom it will send newsletters, as well as the right to remove from the database any member who has previously expressed their consent. The exercise of these rights can be carried out without any further commitment on the part of Natural Plus and without any prior notice to that effect.

Processing to respond to requests

If you contact us by sending a request, notification, question or message of any kind, Natural Plus will collect and process the personal data you have communicated and may request the provision of additional personal data in order to respond to the request and to resolve the possible situation or problem presented.

Contacting Natural Plus through any of the methods provided, through mediated or direct communications, including through the use of social platforms, you understand and express your consent that your personal data will be processed in accordance with the provisions of this Privacy Policy.

Processing for the purpose of resolving legal requests

Natural Plus may collect, process and transmit information regarding your personal data to regulatory authorities, law enforcement agencies or other entities in the following situations:

• in response to a legal request, where it can be considered, in good faith, that the law requires this fact;
• when it is believed in good faith that it is necessary to detect, prevent and respond to fraud, unauthorized or improper use of any of our materials, any violation of our terms and conditions or policies, or other harmful or illegal activities, to protect us (including our rights, property or materials), you and/or others, including as part of investigations or inquiries initiated by regulatory authorities.

The personal data information we receive from or about you may be accessed, processed and stored for a longer period of time if it is subject to a legal request or obligation, a government investigation or other types of investigations regarding possible violations of our terms and conditions or policies, or in other cases to prevent possible harm.

1. Disclosure of personal data to third parties

Personal data processed through the Site Natural Plus may be disclosed and/or transferred to third parties only if there is your express consent to do so, except in situations where there is a legal/contractual obligation to do so. Natural Plus  to do this.

As an example, Natural Plus may provide personal data to various bodies of the judicial system, such as prosecutors, police, courts or other competent state bodies, based on and within the limits of legal provisions and following an express request.

Please note that in order to process your requests when placing an order and purchasing a product or accessing the free eBook section of the Site, we may, in certain circumstances, be required to disclose your personal data. to partners with whom we Natural Plus collaborates with and/or other third party service providers Natural Plus .

For example, Natural Plus may transmit the collected personal data to various partners, such as IT (cloud, hosting) or telecommunications service providers, advertising agencies, accounting and human resources services, integrated solution providers or legal services.

However, Natural Plus  has adopted appropriate technical and organizational measures to ensure the security of data transfer, as well as the processing of your data in accordance with GDPR requirements by the aforementioned entities.

Natural Plus ensures, within reasonable limits, that the personal data collected will not be transmitted outside the European Economic Area. However, in the event that there is a transfer of data to third countries in the EEA, Natural Plus it will ensure that transfers are legitimate and that they will be based on the express consent of the person concerned or on another legally accepted basis.

Information controlled by Natural Plus may be transferred, transmitted or stored and processed in the EEA or in countries other than your country of residence, for the purposes described in this Policy. In such cases, we note that we use standard contractual clauses approved by the European Commission and rely on adequacy decisions issued by the European Commission in respect of certain countries, as applicable, with respect to data transfers from the EEA to the United States and other countries.

1. Data processing by third parties, other websites and sponsors

The website www.naturalplus.ro may contain, at some point, access links to other websites whose data processing policies may be different from those of Natural Plus .

Please consider and review the privacy policies of other sites, Natural Plus assumes no responsibility for the information transmitted or collected by these third parties.

Also, in situations where you interact with Natural Plus through social networks, please note that other third parties may also have access to the personal data provided, such as Facebook or Instagram.

1. Automatic data processing. Cookies

The website www.naturalplus.ro uses cookie identifiers.

Aspects related to the use of cookie identifiers are governed by the Cookie Policy, which is an integral part of this policy and the Site Terms and Conditions and supplements it. Please read the entire content of the Cookie Policy carefully.

As a data subject, you have the option to exercise your right to disable cookies, as stated in the section on your rights.

1. Data storage

Natural Plus may retain the processed data for different periods of time, necessary to fulfill the stated purposes or considered reasonable, in accordance with the purposes indicated above.

Other legal obligations, lawsuits and/or investigations Natural Plus may also require us to retain certain personal data you have provided to us.

In general, we retain your personal data only for the period necessary to fulfill the purpose for which you provided it to us, to meet your needs, to respond to your requests, or to comply with our legal obligations.

At this time, we refer to the following criteria for determining the duration of data storage:

• If you have provided us with information to obtain products provided by Natural Plus , by placing an order, we will collect and process personal data for the purpose of honoring the order, as well as fulfilling contractual and/or legal obligations. Such personal data stored in our databases will be deleted from records within a maximum period of 5 (five) years from the date of the last order, with the exception of personal data necessary from a financial and accounting point of view, which will be processed and stored. for the period established by law.
• If you have provided us with information to create and access your user account to access the digital products "Game Changer Video Course" and "Smart Money - online academy subscription", we will collect and process personal data in order to recognize and allow access to the account. Taking into account the permanent possibility of accessing the account and watching the video courses, granted for an unlimited period, such personal data will be processed and stored in our databases until you cancel the monthly or annual subscription or until you decide that you no longer want to have an account and send us a request to delete your personal data.
• If you have provided us with information for the conclusion of any subsequent contracts or collaboration agreements, we will collect and process personal data for the purpose of concluding and executing the contract, as well as for the fulfillment of contractual and/or legal obligations. These personal data will be processed and stored for the period necessary to fulfill the object of the contract and fulfill any legal obligations arising from it. For example, in the case of financial and accounting supporting documents, the retention period provided by law is 10 (ten) years from the end of the financial year during which they were drawn up.
• If you have expressed your option to subscribe to the newsletter Natural Plus , we will collect and process your personal data to send you various information from our area of ​​activity, information regarding possible campaigns and/or marketing messages. Such data will be processed and stored until you decide to unsubscribe, using one of the options offered for this purpose.
• If you contact us with certain questions or requests, we will collect and process personal data to respond to your request. Such personal data will be processed and stored for the period necessary to process the request and resolve it, but no longer than 5 (five) years from the last correspondence sent.
• In the case of cookies used, they are stored on your computer for as long as necessary to achieve the purposes they serve (e.g. cookies for the account authentication session) and for a determined period in accordance with the usual regulations and guidelines. To find out more about the use of cookies, please read the Cookie Policy on our website.

1. Rights of data subjects

Data subjects have the following rights, in accordance with the GDPR, with respect to the personal data they Natural Plus processes them:

• Right of access to processed data : you have the right to access the personal data we hold about you. The first provision of information will be free of charge. If you require additional copies of information already provided, we may charge a reasonable fee, taking into account the administrative costs of providing the information. Manifestly unfounded, excessive or repeated requests may not be answered.
• Right to data rectification : you have the right to request that your data be rectified if it is inaccurate or outdated and/or completed if it is incomplete.
• Right to erasure ("right to be forgotten") : In certain circumstances, you have the right to obtain the deletion or destruction of your data. This is not an absolute right, as sometimes we may need to retain your data for legal or regulatory reasons.
• Right to restriction of processing : You have the right to request the restriction of the processing of your data. This means that the processing of your data is limited so that we can keep the data but not use or process it. This right applies in specific circumstances set out in the General Data Protection Regulation, namely:
• the accuracy of the data is contested by the data subject (you), for a period that allows the controller ( Natural Plus ) to verify their correctness;
• the processing is unlawful and the data subject (you) opposes the erasure of the data and requests the restriction of their use;
• the operator ( Natural Plus ) no longer needs the data for processing, but they are required by the data subject (you) to establish, exercise or defend legal claims;
• the data subject (you) has objected to the processing on legitimate grounds of the controller ( Natural Plus ), based on the verification that the legitimate reasons of the controller ( Natural Plus ) exceed those of the data subject (you).
• Right to data portability : you have the right to move, copy or transfer the data that interests you from our database to another. This only applies to data that you have provided, where the processing is based on your consent or on the basis of a contract and is implemented by easily accessible automated means.
• Right to object : you may object at any time to the processing of your data when such processing is based on a legitimate interest.
• Right to withdraw consent at any time : you may withdraw your consent to the processing of your data where such processing is based on consent. Withdrawing consent does not affect the lawfulness of processing based on consent prior to its withdrawal.
• Right to lodge a complaint with the competent supervisory authority : you have the right to lodge a complaint with the data protection authority in your country of residence or domicile to challenge the data protection practices offered by Natural Plus . In Romania, this body is represented by the National Supervisory Authority for the Processing of Personal Data (ANSPDCP), which is headquartered in Bucharest, bld. G-ral. Gheorghe Magheru no. 28-30, Sector 1, postal code 010336 and has the following contact details: telephone +40.318.059.211 or +40.318.059.212, e-mail address anspdcp@dataprotection.ro.
• The right to object to our processing of your data when we are carrying out actions in the public interest or in our legitimate interests or those of a third party : you can object at any time to the processing of your data when such processing is based on a legitimate interest.
• The right to object to the processing of your data for direct marketing purposes (right to unsubscribe) : you have the possibility, permanently and completely, to unsubscribe from our newsletter or to ask us to stop sending you marketing messages, either by accessing the unsubscribe link included in the emails, or by sending to Natural Plus  an email requesting deletion from the database.
• The right to disable cookies : you have the possibility, partially or completely, to disable cookies. Internet browser settings are usually programmed by default to accept cookies, but you can easily change them by accessing and changing your browser settings. For more details, visit the Cookie Policy.

You can exercise any of these rights in relation to the personal data you Natural Plus processes them by sending a simple request to Natural Plus , at the contact details provided. In such a situation, we may very well ask you for proof of your identity.

We would like to point out that the rights listed above are not absolute. In certain situations, there may be exceptions, so each request received will be analyzed to decide whether it is justified or not. If the request is well-founded, it will be resolved according to the request. If the request is unfounded, we will reject it and, if applicable, we will tell you the reasons for the rejection, as well as the rights you still have.

Natural Plus will take all measures to respond to requests within a maximum of 30 (thirty) days. However, in certain situations and taking into account various circumstances, this deadline may be extended, depending on the complexity of the request, the large number of requests received, the impossibility of identifying the applicant within the optimal period or the expectation of responses from other bodies. .

In the event of unsubscribing from marketing messages, please note that this unsubscription does not apply to personal data that you have provided to us for another purpose, for example when you requested a product from Natural Plus.

1. Processing security

Natural Plus has adopted technical and organizational data processing measures, updated in accordance with the requirements of the GDPR, in order to protect your personal data against any unauthorized access, improper use or disclosure, unauthorized modification, destruction or accidental loss. All employees and collaborators Natural Plus , as well as any third parties acting on behalf of and on behalf of Natural Plus , are required to respect the confidentiality of your information, in accordance with the provisions of this Data Protection Policy.

To guarantee the protection offered to the personal data we process, Natural Plus implemented measures such as adopting dedicated data processing policies and protecting systems from possible unauthorized access, proceeded to minimize and limit the data it processes. , proceeded to restrict access to the processed data, used technologies to ensure data security and trained staff and collaborators on applicable legislation.

However, we draw your attention to the fact that unwanted events may also occur, which may lead to various incidents or security breaches. In such situations, we will follow the procedure for reporting and notifying security incidents and will take all necessary measures to reduce the effects of the incident and return the situation to its previous state of normality.

1. Disclaimer

Website Natural Plus may contain links to other sites and/or other web pages that are not the property of SC NATURAL PLUS COMERT SRL assumes no responsibility for the content of these sites and, therefore, cannot be held responsible for the content, advertising, goods, services, software, information or other materials available on or through these sites. SC NATURAL PLUS COMERT SRL will not be responsible for the loss of personal data, for any negative effects on visitors' personal data or for other moral and/or patrimonial damages caused by access to the respective sites.

As such, SC NATURAL PLUS COMERT SRL encourages and advises you to read and familiarize yourself with the existing Privacy Policies of any website and/or application you access before providing personal data.

1. Update of the Policy on the protection and processing of personal data

Please note that this Policy may be subject to periodic content changes, by updating the Site www.naturalplus.ro. Therefore, it is necessary to check this page for any updates.

Please do not continue to use the website www.naturalplus.ro if you do not agree to such changes.

The terms of this Policy are interpreted in accordance with applicable law.