PRIVACY POLICY

OUR PRIVACY PRINCIPLES

We have 5 Privacy Promises that explain how we use and care for your information. We:

1. ALWAYS use your personal data in accordance with data protection law.
2. ALWAYS inform you about what information we collect, what we do with it, who we share it with, and who to contact if you have any concerns.
3. ALWAYS provide options to say "STOP" if you do not wish to receive marketing communications.
4. ALWAYS take measures to protect your information and ensure that no unauthorized person has access to it.
5. ALWAYS respond to questions about your personal data without delay.

OUR PRIVACY POLICY

We are committed to safeguarding your privacy rights and ensuring that your personal data is protected.

This Privacy Policy explains the types of personal data we collect and how we process and protect that information in connection with the services we offer. This includes information collected offline in our stores or through our customer services, and online through our websites, applications (including mobile applications), and third-party platforms ("Sites").

1. WHO IS RESPONSIBLE FOR WHAT HAPPENS TO YOUR DATA?

support@instaflex.blog
Strada Muncitorilor 18, Cluj-Napoca 400424, Romania

2. HOW CAN I CONTACT THE DATA PROTECTION OFFICER?

If you have any questions about how we process your personal data, you can contact our Data Protection Officer via email at info@abcloudgroup.com.

3. WHAT IS PERSONAL DATA?

Personal Data refers to information that can identify you directly or indirectly ("Personal Data"). This typically includes information such as your name, address, email, and phone number, but may also include other information such as your IP address, shopping habits, and information about your lifestyle or preferences, such as your hobbies and interests.

4. WHAT HAPPENS WHEN YOU PROVIDE US WITH YOUR PERSONAL DATA OR WHEN WE RECEIVE YOUR PERSONAL DATA IN OTHER WAYS?

We collect your Personal Data directly in various ways, for example when you provide us with your information to register as a customer on our Sites, register for sweepstakes or competitions, subscribe to our newsletter, receive information or mailings, use our applications, purchase a product or service from us, complete a survey, make a comment or inquiry, or contact our Customer Service Team.

When you provide us with your Personal Data, we will process it in accordance with this Privacy Policy. If you do not want us to process your Personal Data in this way, please do not provide us with your personal information.

We may also receive your Personal Data from other sources, including information from commercially available sources such as public databases and data aggregators, as well as information from third parties. If you do not want us to receive your Personal Data from other sources, please communicate your preferences directly to the relevant sources.

We process your Personal Data to provide you with our services, as explained below. In certain cases, we only process your Personal Data if you have given us permission to do so, for example in most cases where we process your Personal Data for marketing purposes, use cookies or location data, or when we process your sensitive personal information. In other cases, we may rely on other legal grounds to process your personal data, such as fulfilling our contract with you or legitimate interests, such as fraud prevention.

You can always opt out of receiving marketing communications without this affecting your loyalty benefits.

When we process your Personal Data based on your consent, we will request your consent explicitly and only for a specific purpose. We will also ask you to provide additional consent if we need to use your Personal Data for purposes not covered by this Privacy Policy.

5. FOR WHAT PURPOSES DO WE PROCESS YOUR PERSONAL DATA?

5.1 WE PROCESS THE FOLLOWING CATEGORIES OF PERSONAL DATA FOR THE FOLLOWING PURPOSES:

• Browsing our sites
• Purchase/Acceptance of a Service
• Customer Service
• Product and service suggestions that may interest you.
• Contests and sweepstakes
• Online purchases

WHAT PERSONAL DATA MAY WE COLLECT?

Information about the type of browser you use when visiting our sites, your IP and device address, hyperlinks you have clicked, websites you visited before arriving at our sites, and information collected by cookies or similar tracking devices. Your username, profile picture, gender, networks, and any other information you choose to share when using third-party sites (such as when you use the "Like" feature on Facebook).

WHAT IS THE PURPOSE OF THE PROCESSING?

We (and third-party service providers acting on our behalf) use cookies and similar technologies to process data about you when you visit our Sites. We would like to know if you have visited us before and your preferences to offer you a personalized experience on our Sites.

See Section 5.2 below for more information about cookies.

HOW LONG DO WE STORE YOUR PERSONAL DATA?

Please refer to the cookie consent tool to find out the storage periods for each cookie.

WHAT IS OUR LEGAL BASIS FOR PROCESSING?

Your consent when you click "accept and continue" in our Cookie Consent Tool on our Sites. In some cases, and where permitted by law, we will infer from your actions that you accept Cookies. Please note that we need to process certain basic browsing data to provide essential Site functionality, such as secure login or remembering where you are in an order.

5.2 COOKIES AND SIMILAR TECHNOLOGIES

We use cookies and similar technologies ("Cookies") to improve our products and your experience on our Sites by collecting information about how you use our Sites. Some of the Cookies we use are necessary to enable basic site functionality, for example to provide secure login or remember where you are in an order, but we also use Cookies that allow us to analyze site usage (so we can measure and improve performance), and advertising Cookies that are used by advertising companies to display ads relevant to your interests.

We may also tailor our Sites and our products to your interests and needs by collecting information about your device and linking it to your Personal Data to ensure our Sites offer the best web experience for you.

Where we use Google Analytics, we have configured the service to anonymize your IP address as soon as data is received by the Analytics Collection Network, before any storage or processing takes place.

You can view more information about the cookies we use and adjust your preferences through the Cookie Consent Tool on our sites. However, please note that without cookies you may not be able to use all features of our sites or online services.

6. WITH WHOM DO WE SHARE YOUR PERSONAL DATA?

6.1 OUR SERVICE PROVIDERS

We share your Personal Data with the following data processors (i.e., service providers who help us perform the tasks mentioned above):

• Trusted third parties who help us process and analyze your Personal Data, to support us in suggesting products and services that may interest you, in accordance with Section 5.1 mentioned above.
• If you place an order for a product or service with us, trusted third parties may be involved to enable payment and delivery of the products and services you have requested. Unless you have given your consent, such trusted third parties are not authorized by us to use your Personal Data in any other way and will be required to implement appropriate technical and organizational measures to protect your Personal Data.

These processors are bound by us to comply with strict requirements under applicable data protection laws, to handle your Personal Data solely on our behalf, and to meet high standards of information security.

6.2 OTHER RECIPIENTS

We share your Personal Data with the following third parties who process your Personal Data for their own purposes (i.e., these third parties are not processors; rather, they use your Personal Data because they have their own interest or because you have given your consent):

Law enforcement or other agencies if we are required to do so by law, or by a warrant, subpoena, or court order to disclose your Personal Data.

Please note that we never share your Personal Data with social media platforms. When we participate in audience building or customer matching activities with social media platforms such as Facebook or Google, your Personal Data is always anonymized before transfer. If there is any change in the future and we need to share your Personal Data with a social media platform, we will request your consent.

6.3 SHARING INFORMATION ABOUT YOUR SITE USAGE

With your consent, we will share information about site usage with trusted third parties (e.g., advertisers, advertising agencies, advertising networks, data exchanges, etc.) in order to offer you personalized content that may be of interest to you based on your previous activity on our site. These trusted third parties may set and access their own cookies, web beacons, and similar tracking technologies on your device to help us offer you personalized content and advertising when you visit our relevant sites. See Section 5.2 for more information about cookies and how to opt out.

Please note that even if you choose to opt out, you may still receive advertisements from us that are not personalized based on your site usage information.

7. HOW LONG DO WE PROCESS YOUR PERSONAL DATA?

We will store your Personal Data only until the purposes mentioned for which we have collected or received your Personal Data are fulfilled, and once our legal obligations to retain records have expired, as described in Section 5.1.

8. WHAT ARE YOUR RIGHTS?

If certain requirements are met, you have the right to:

• Obtain confirmation from us as to whether or not we process your Personal Data and, if so, access to your Personal Data;
• Rectification of inaccurate personal data;
• Erasure of Personal Data;
• Object to the processing of Personal Data;
• Restriction of the processing of Personal Data;
• Data portability: receive the Personal Data you have provided to us in a structured, commonly used, and machine-readable format, and transfer it to another data controller.

You can learn more about these rights in the GDPR, which grants the following rights to individuals:

1. The right to be informed
2. The right of access
3. The right to rectification
4. The right to erasure
5. The right to restrict processing
6. The right to data portability
7. The right to object
8. Rights in relation to automated decision-making and profiling.

To exercise your rights, please contact the Data Protection Officer (see Section 1 for contact details) or contact our Customer Service team using the details provided below.

Please note that you do not need to contact our Data Protection Officer to exercise your rights to stop receiving marketing communications from us. You can opt out of such communications by accessing the Marketing Preferences in your 'My Account' if you have an account with us, directly from the communications we send you, or by contacting our Customer Service Team or sending an email.

9. CAN YOU WITHDRAW YOUR CONSENT FOR THE PROCESSING OF PERSONAL DATA?

When your consent is the legal basis for the processing of your Personal Data, you may withdraw your consent for:

• Marketing communications: by accessing your account in Marketing Preferences or using the unsubscribe link in any of our marketing communications.
• Use of Cookies: through our Cookie Consent Tool at the bottom of our Sites.
• Other purposes: by sending us an email or contacting our Customer Service as indicated in Section 8.

Please note that withdrawing your consent will not affect the lawfulness of processing carried out before the withdrawal.

10. CAN YOU FILE A COMPLAINT WITH DATA PROTECTION AUTHORITIES?

If you believe that the processing of Personal Data by us violates data protection laws, you may file a complaint with the Information Commissioner.

11. HOW DO WE PROTECT YOUR PERSONAL DATA?

We maintain appropriate technical and organizational measures to protect the Personal Data you provide to us against destruction, loss, alteration, unauthorized disclosure, or accidental or unlawful access to your Personal Data.

12. CAN WE CHANGE OUR PRIVACY POLICY?

We may change this Privacy Policy from time to time by posting the updated version of the Privacy Policy here. We recommend that you visit this section frequently to stay informed.