Last updated: October 25, 2023
This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You.
We use Your Personal data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.
1. Introduction
Welcome to Reway Vision, operated by Reway Vision S.R.L. (“we,” “our,” or “us”). We are dedicated to safeguarding your privacy and ensuring the security of your personal information. This Privacy Policy outlines how we collect, use, disclose, and protect your data when you visit our website at reway.vision (“the Website”) and engage with our services. Please take a moment to read this Privacy Policy carefully to understand our data handling practices.
As a personal data controller, Reway Vision is responsible for the processing of your personal data that it collects directly or from other sources. We would like to specify that, to ensure the protection and secure processing of your data, Reway Vision has made every effort to implement reasonable and appropriate technical and organizational measures.
If you have any questions or require additional information about our Privacy Policy, please do not hesitate to contact us at: contact@reway.vision
Company Information:
Company Name: Reway Vision S.R.L.
Registered Address: Bucureşti Sectorul 6, Strada SG. CONSTANTIN MOISE, Nr. 5D, Bloc 2, Scara 2, Ap. B5
CUI (Fiscal Code): 48573193
EUID (European Unique Identifier): ROONRC.J40/14220/2023
Email Address: contact@reway.vision
Phone Number: +40 (756) 481 649
2. Interpretation and Definitions
Interpretation
The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.
Definitions
For the purposes of this Privacy Policy:
- Company (referred to as either “the Company”, “We”, “Us” or “Our” in this Agreement) refers to Reway Vision S.R.L.
- Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.
- Country refers to: Romania
- Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.
- Personal Data is any information that relates to an identified or identifiable individual.
- Data Breach signifies a security incident resulting in the unintentional or illegal destruction, misplacement, modification, unauthorized exposure, or entry into personal data. This underscores that a breach encompasses more than just the loss of personal data.
- Service refers to the Website.
- Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.
- Third-party Social Media Service refers to any website or any social network website through which a User can log in or create an account to use the Service.
- Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
- Website refers to reway.vision, accessible from https://reway.vision
- You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.
- Consent represents any freely given, specific, informed, and unambiguous expression of the data subject’s will, by which they accept, through a statement or an unequivocal action, that personal data concerning them shall be processed.
- The controller is an individual or legal entity, public authority, agency, or another entity that, either independently or in collaboration with others, establishes the goals and methods for handling personal data. In cases where the European Union or Member State law dictates the purposes and methods of such data processing, the controller’s role or the specific criteria for their appointment may be outlined in accordance with Union or Member State regulations.
- Regulation GDPR / GDPR represents Regulation (EU) 2016/679 adopted by the European Parliament and the Council of the European Union on April 27, 2016, regarding the protection of individuals concerning the processing of personal data and the free movement of such data and repealing Directive 95/46/EC, also known as the General Data Protection Regulation.
3. Collecting Your Personal Data
Types of Data Collected
Personal Data
Personal data refers to information associated with an individual that can be utilized to identify that person. This information includes, but is not limited to, details such as a person’s name, email address, phone number, social media usernames, location data, or job titles.
While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:
Usage Data
Usage Data is collected automatically when using the Service.
Usage Data may include information such as Your Device’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.
We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.
Tracking Technologies and Cookies
We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze Our Service. The technologies We use may include:
- Cookies or Browser Cookies. A cookie is a small file placed on Your Device. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Service. Unless you have adjusted Your browser setting so that it will refuse Cookies, our Service may use Cookies.
- Web Beacons. Certain sections of our Service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).
Cookies can be “Persistent” or “Session” Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser.
We use both Session and Persistent Cookies for the purposes set out below:
- Necessary / Essential Cookies
- Marketing Cookies
- Preference Cookies
- Statistics Cookies
For more information about the cookies we use and your choices regarding cookies, please visit our Cookies Policy or the Cookies section of our Privacy Policy.
4. Use of Your Personal Data
The Company may use Personal Data for the following purposes:
- To provide and maintain our Service, including to monitor the usage of our Service.
- For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.
- To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application’s push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
- To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.
- To manage Your requests: To attend and manage Your requests to Us.
- For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred.
- Processing for Invoicing: Reway Vision will use the information you provide in the order placement section for the purchase and payment of the desired product or by sending a message or email later in which you communicate the data of the paying company. The personal data provided will be used exclusively for the purpose of processing your request and for sending you the invoice for the purchased product.
- Payment Processor: For making payments on our website, Reway Vision uses external payment processing providers. In connection with payment processing in this context, we do not process or retain personal data such as credit/debit card information used for payment. This information will be provided directly by you to the payment processor Stripe or through your PayPal account, and the use of this data is governed by the data protection policies of the respective providers, which can be accessed here and here.
- For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience.
We may share Your personal information in the following situations:
- With Service Providers: We may share Your personal information with Service Providers to monitor and analyze the use of our Service, to contact You.
- For business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.
- With Affiliates: We may share Your information with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.
- With business partners: We may share Your information with Our business partners to offer You certain products, services or promotions.
- With other users: when You share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside. If You interact with other users or register through a Third-Party Social Media Service, Your contacts on the Third-Party Social Media Service may see Your name, profile, pictures and description of Your activity. Similarly, other users will be able to view descriptions of Your activity, communicate with You and view Your profile.
- With Your consent: We may disclose Your personal information for any other purpose with Your consent.
Our Legal Basis
- In accordance with Article 6(1)(a) of the GDPR, personal data may be processed if the data subject has given consent for the processing of their personal data for one or more specific purposes.
- In accordance with Article 6(1)(b) of the GDPR, personal data may be processed for the purpose of entering into or performing a contract. In order to provide our products or to enter into potential future collaboration contracts, we need to process your personal data, such as name, first name, email address, home address or residence, personal identification number, ID card or identity card series and number.
- In accordance with Article 6(1)(c) of the GDPR, personal data may be processed to fulfill legal obligations, including those of a fiscal nature. To meet certain obligations imposed by tax authorities in connection with billing, refunding certain amounts, paying affiliate marketing fees, or reporting certain information to authorities, Reway Vision may request and process a series of personal data, such as name, first name, home address or residence, personal identification number, ID card or identity card series and number.
5. Retention of Your Personal Data
In accordance with Article 5(2) of the GDPR, the Company, acting as the Controller, adheres to GDPR principles, which state that the “Controller shall be responsible for, and be able to demonstrate, compliance with the principles.” This entails processing Personal Data in a fair and lawful manner, acquiring it only for specific and lawful purposes, ensuring it remains adequate and up-to-date, retaining it for no longer than necessary, and safeguarding it appropriately.
The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.
6. Disclosure of Your Personal Data
Consent
Your Personal Data may be processed only if you have unambiguously given your consent or, the processing is necessary for the performance of the Company Services you request or, for compliance with legal obligations as in the case of Anti Money Laundering and Terrorist Financing Regulations (AML/TF) or, pursuant the public interest or, requested in the exercise of official authority vested in Reway Vision or a third party with whom the Personal Data is disclosed except where such interest is overridden by the interest to protect the fundamental rights and freedoms that arise from the right of privacy.
As an individual you may exercise your right to access your Personal Data held about you by Reway Vision by contacting us. Reway Vision is not legally obligated to appoint a data protection officer. Consequently, any requests regarding your personal data should be directed to the contact details mentioned below.
Business Transactions
If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.
Law enforcement
Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
Other legal requirements
The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:
- Comply with a legal obligation
- Protect and defend the rights or property of the Company
- Prevent or investigate possible wrongdoing in connection with the Service
- Protect the personal safety of Users of the Service or the public
- Protect against legal liability
Transfer of Your Personal Data
Your information, including Personal Data, is processed at the Company’s operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.
Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.
The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.
The Company does not transfer Personal Data outside of the European Economic Area (EEA) unless the receiving country or territory ensures an “adequate” level of protection.
7. What Rights Do You Have, and How Can You Efficiently Exercise Them?
The Right to Access
You are entitled to confirm whether we are processing personal data about you and, if so, to access your personal data and gain insights into how they are being processed.
The Right to Object
You can object to the processing of your personal data when it’s required for tasks in the public interest or for our legitimate interests. Moreover, you can object at any time if your personal data is being processed for direct marketing purposes.
The Right to Rectify
You have the right to request the prompt correction of any inaccurate personal data we hold about you. We will communicate these corrections to anyone to whom we have shared your data, unless this is exceptionally challenging or requires disproportionate (provable) efforts.
The Right to Data Portability
You have the right to receive a portion of your personal data, which you’ve supplied to us, in a structured, widely accepted, machine-readable format. Additionally, you have the right to transmit this data to another data controller, without obstacles from us, wherever it’s technically feasible.
The Right to Avoid Automated Decisions
At Reway Vision, we respect your right not to be subjected to decisions solely driven by automated processing, including profiling, that result in legal consequences or have a significant impact on you. We want to assure you that we do not employ applications, algorithms, artificial intelligence, or automated processes without human intervention to make decisions with legal effects.
The Right to Limit Data Processing
You have the right to request us to restrict the processing of your data under certain circumstances. These circumstances include if you are contesting the accuracy of your personal data, and you need time for us to verify it; if the processing is deemed unlawful, and you request the restriction of use instead of deletion; if we no longer require your data for the intended purposes but you need it for legal claims; or if you’ve objected to the processing pending a review of whether our legitimate interests outweigh yours as the data subject.
Right to Erasure (Right to be Forgotten)
Upon your request, the Company will honor your right to have your Personal Data deleted. The Company will act reasonably and take all necessary steps, including technical measures, to inform third-party data Processors about this request, unless retaining your Personal Data is necessary to fulfill legal obligations or court orders.
8. Children’s Privacy
The website may not be used by anyone under the age of 18 in any way.
Our Service does not address anyone under the age of 18. We do not knowingly collect personally identifiable information from anyone under the age of 18. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 18 without verification of parental consent, We take steps to remove that information from Our servers.
9. Security Measures at Reway Vision to Safeguard Your Personal Data
At Reway Vision, we prioritize the protection of your personal data and have established a comprehensive framework of technical and organizational security measures. Our commitment to safeguarding your privacy and data security includes taking the following precautions:
- Controlled Access: Access to our data systems is restricted to individuals designated by Reway Vision. They are required to use individual accounts and regularly updated passwords for system entry.
- Data Compliance: Our employees, collaborators, and service providers who interact with personal data are bound by principles and policies adhering to data processing. They are well-informed and are legally obligated to comply with GDPR regulations, either through signed Data Processing Agreements or as required by law.
- Limited Access for Authorized Purposes: Our employees and collaborators access personal data solely for the performance of their professional responsibilities and strictly in line with the stated purpose of data collection.
- Enhanced IT Security: Computers with access to our data systems are protected with password authentication and are equipped with the latest antivirus, antispam, and firewall security updates to bolster your data’s security.
- Restricted Printing: Personal data is printed only by authorized users when necessary to carry out our business activities or fulfill our legal obligations.
We urge you to exercise caution when determining which personal data you choose to share. The internet and email systems are not impervious to vulnerabilities, and unforeseen technical errors can potentially impact your personal data. Your privacy and data security are of utmost importance to us, and we remain steadfast in our commitment to protecting your information.
10. Links to Other Websites
Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party’s site. We strongly advise You to review the Privacy Policy of every site You visit.
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
11. Changes to this Privacy Policy
We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.
We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the “Last updated” date at the top of this Privacy Policy.
You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.
12. Contact Us
If you have any questions about this Privacy Policy, You can contact us: