Privacy Policy
Privacy Policy
1. Confidentiality
The confidentiality and protection of your personal data is one of our commitments at BROTORHEADS SRL, a Romanian legal entity, with its registered office located in the municipality of Bucharest, sector 3, Calea Mosilor no. 88, sc.F, ap.82, registered in the Trade Register under no. J2026019899000, with the unique registration code 54336841, hereinafter referred to as BROTORHEADS.
Therefore, we strive to process your personal data in accordance with the principles defined in the data protection legislation applicable in Romania, including Regulation (EU) 2016/679 on the protection of individuals with regard to the processing of personal data and on the free movement of such data ("GDPR"). The terms used in this privacy policy that are not defined shall have the meaning given by the GDPR.
Personal data is any information relating to an identified or identifiable natural person. An identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identification number or to one or more factors specific to our physical, psychological, mental, economic, cultural or social identity.
This privacy and data protection policy concerns the data of our customers, business partners, other persons who contact and visit us, as well as their representatives, potential employees, collaborators, etc. and applies both to data collected through our online store (“Products”), www.brotorheads.com/shop/, hereinafter referred to as the “Website”, and to all other personal data collected by e-mail or through other off-line contacts.
The privacy and data protection policy describes:
• the purposes for which we collect and use your personal data;
• the reasons for processing the data for these purposes;
• the categories of personal data that we process;
• the duration of the processing of this data;
• your rights as data subjects and how you can exercise them;
• to whom we may disclose your personal data, information that we hope to provide you with in a transparent and easy-to-read manner, so that you can understand what we want to communicate to you.
You will also find out how you can contact us if you have any questions regarding your personal data, questions that we will be happy to answer. Please also read our cookie policy, from which you will find out how BROTORHEADS uses cookies and other similar technologies.
2. Purposes, grounds for processing and categories of personal data processed
In the context of your interaction with BROTORHEADS, given that the Website is an online store, we may subject you - as a natural person - to the data processing activities that we carry out. Therefore, we use your personal data in the following cases:
a. If you are a customer or potential customer of BROTORHEADS:
i. Use of the Website and purchase of Products
We use your relevant personal data to prepare and deliver the ordered Products or to send you the requested product offers. In this regard, we will need at least the following personal data: full name, telephone number, e-mail, delivery address. In this case, we rely on the execution of the contract as the basis for the processing of personal data because without the above data we will be unable to deliver the ordered products or send you the requested product offers, and the use of the Website will not achieve its purpose.
ii. Communication with you
We use your contact data, namely name and surname, e-mail, telephone, to communicate with you, in connection with the requests you have, as well as with any other relevant aspects related to the commercial relationship. Also, in this case, we rely on the execution of the contract as the basis for the processing of personal data.
iii. Data processing as an obligation imposed by law, in general, and by our obligations as a product supplier, in particular
We may process some of your personal data in the context of providing the Products based on legal obligations, namely the personal data necessary to prepare invoices for the Products – name and surname, home address, personal identification number or series and number of the identity document. In this case, the reasons for processing these data relate to the legal obligation we have.
iv. Sending offers, news regarding BROTORHEADS services and products
We may also use your contact details to provide you in the form chosen by you (electronically via e-mail, SMS, on paper) - our offers and other information regarding the services and products
iv. Sending offers, news regarding BROTORHEADS services and products
We may also use your contact details to provide you in the form of your choice (electronically via e-mail, SMS, on paper) - our offers and other information regarding Brotorheads services and products, promotions, etc., only if you have expressly requested such a service and, therefore, have previously expressed your explicit consent for such processing of your data. You can withdraw your consent at any time by expressing your option not to receive such information in the following ways:
Email to shop@brotorheads.com
b. If you are the representative or contact person, employee or other collaborator of a customer or potential customer of BROTORHEADS or of a business partner of BROTORHEADS
i. Supply of Products
We use your relevant personal data to prepare and supply the Products requested from us or, in case you are a representative of a supplier of BROTORHEADS, to contact you in order to order Products. We rely in this case on the legitimate interest in the supply of the Products and the execution of the contract.
ii. Communication with you
We use the contact data you provide to communicate with you, in connection with your or our requests, and with any other relevant aspects related to the commercial relationship. Also in this case, we rely on the legitimate interest of providing our products and services in our field of activity and in managing the relationship with our business partners, customers or suppliers, as the basis for the processing of personal data.
iii. Data processing as an obligation imposed by law, in general, and in relation to our obligations as a product supplier, in particular
We may process some of your personal data in the context of providing the Products based on the legal obligations governing the activity of the product suppliers. In this case, the reasons for the processing relate to the legal obligation we have.
iv. Sending promotional offers and packages, news regarding BROTORHEADS services and products
We may also use your contact details to provide you in the form chosen by you (electronically via e-mail, SMS, on paper) - our offers and other information or seasonal news regarding services and products, promotions, etc. BROTORHEADS, but only if you have expressly requested such a service and, therefore, have previously expressed your explicit consent for such processing of your data. You can always withdraw your consent, expressing your option not to receive such information in the following ways:
E-mail to shop@brotorheads.com
In all cases, the data is provided either directly by you or by the customer/partner. The categories of data processed in the context of our relationship with you are the name, surname, e-mail address, telephone, position within the company, as well as other personal data provided to BROTORHEADS, usually by you, as necessary to fulfill the above purposes.
c. If you are a visitor to our physical store
We use your personal data to ensure the security of the premises, goods, our staff and other visitors to our physical store BROTORHEADS. In this case, the data processing is based on the legitimate interest of BROTORHEADS, namely the protection of these spaces, assets and personnel.
The categories of data processed in this context are your name, as well as other personal data that you may provide us directly. Also, in this context, we mention that BROTORHEADS records images from the physical store through internal video surveillance systems (CCTV), without audio recording, images that will be kept for a period of 30 days.
d. Information that we collect automatically. Cookies
Based on your visit to the Website, we automatically collect certain information through cookies. Please review the Cookie Policy using the link at the bottom of the page called "Cookie Settings".
At the same time, in order to profile, monitor and send personalized communications and offers, we may use automated marketing software, dedicated to online stores.
The activities of profiling, monitoring or sending personalized communications and offers do not have any legal effect or other similar significant effect on the users of the Website, the only result being that of receiving discounts and personalized marketing offers. You can opt out of being profiled or receiving commercial communications at any time.
In order to process, monitor the activity on the Website and the interaction with the Website, the following personal data is automatically collected and stored: e-mail, phone number, name, surname, county, city, IP address (including possible location), browser, order ID, discount code, discount value, shipping cost, total order value, individual price of ordered products, product variations, products, device, OS, IP location, timestamps related to page visit, page visit, category visit, brand visit, click on image, mouse over cart, mouse over price, scroll up, scroll down, add to cart, remove from cart, select variation, add to wishlist, comment, help page visit.
e. Information we collect from third parties
We may also receive your personal data through other sources, even if you do not provide it to us directly, from third parties who have the right or legal obligation to share your data with us. These may include business partners and public authorities. When you use or benefit from some of BROTORHEADS services or products, you provide details to our business partners, who direct your details to us.
f. Processing for other purposes
We do not process your personal data for secondary purposes other than those for which it was initially collected, without prior consent, without a legitimate interest or without a legal basis.
g. Information about children
BROTORHEADS does not collect personal data from children as the purchase of Products and Services on the Website is only permitted to persons over 18 years of age.
3. Do we disclose your personal data to third parties?
In certain circumstances, we will share your personal data with third parties:
• Third party service and product providers – we may use service and/or product providers to process your personal data on our behalf. We assure you that we have signed personal data processing agreements and confidentiality clauses with all third-party service providers in order to protect them and we do not allow them to use them for other purposes.
• Competent authorities – in the case of requests based on legal provisions, we provide your data to the competent authorities, when this is strictly necessary to detect fraud, criminal acts and, in general, when legal provisions require us to comply with such a requirement.
• When you expressly request this or expressly authorize us to disclose your data.
• In the case of urgent situations or cases of force majeure.
• If disclosure is necessary to resolve disputes, to ascertain or exercise a right in court.
We assure you that we do not alienate or sell your personal data to any other entity, natural or legal person.
4. How long do we keep personal data?
We limit the storage period of your personal data to what is necessary for the processing purposes that have been made known to you.
We review the need to continue to keep your personal data. Every 2 years we analyze the data collected and processed, in order to filter, sort and maintain the processing only for data for which the purpose of the processing is current. If, following the periodic review, it appears that you have not used the website in the last two years, BROTORHEADS will send you an e-mail to reactivate the commercial relationship. If you do not respond to BROTORHEADS's request, we will proceed to delete both the processed personal data and the user account, if any.
Regardless of your activity on the website, we will delete your personal data immediately, following a request sent by you, with the exception of data whose processing/provision is imposed by a legal provision, in which case the retention period will be that provided for in the applicable mandatory legislation.
At the same time, we may retain personal data in the event of the establishment, exercise or defense of a right in court.
If the retention of your personal data is necessary for purposes specified by law, we may continue to retain this data.
5. How do we ensure the security of personal data? Are they safe?
We want to keep your personal data safe by implementing appropriate technical measures and appropriate organizational measures.
In accordance with applicable law, we have defined and use internal procedures to prevent unauthorized access and inappropriate use of personal data.
We use appropriate systems and procedures to protect and secure personal data, specifically aimed at preventing unauthorized/illegal processing, accidental or unlawful loss, accidental or unlawful destruction.
We have implemented measures to prevent and/or discover security breaches, to document security incidents, data affected by such incidents, to remedy security incidents, and to recover personal data.
We have also implemented measures and procedures to comply with our obligations under applicable law in the event of a security incident, including our obligations to notify the competent supervisory authority and to notify and inform you, as appropriate.
In the case of our employees, contractors, suppliers and BROTORHEADS collaborators, we limit and restrict their access to the personal data we process, to what is strictly necessary, on the one hand, and on the other hand, imposing strict confidentiality obligations.
We have also implemented and are conducting a policy of continuous training of our staff in relation to the processing of personal data.
6. Do we transfer personal data outside the EU or EEA?
We do not transfer your personal data to countries outside the European Economic Area or to international organizations.
7. How can you control your personal data? What are your rights?
As data subjects, the GDPR provides you with a series of rights, including:
a. To access data: you can obtain information regarding the processing of your personal data and a copy of this personal data.
b. To rectify data: if you consider that your personal data is inaccurate or incomplete, you can request the appropriate modification of this personal data.
c. To obtain data erasure: you can request the erasure of your personal data, to the extent provided by law.
d. To restrict processing: you can request the restriction of the processing of your personal data.
e. To object to processing: you can contest the processing of your personal data, for reasons related to your particular situation.
f. Data portability: you have the right to request that the personal data you have provided to us be returned to you or, if possible, transferred to a third party.
We are happy to provide you with all our assistance in exercising these rights.
You can exercise these rights mentioned above and learn more about them by submitting a written request to us, as data controller, at: BROTORHEADS SRL, a Romanian legal entity, with its registered office located in the municipality of Bucharest, sector 3, Cale Mosilor no. 88, sc.F, ap.82, or by e-mail to shop@brotorheads.com . You also have the right to file a complaint with the national supervisory authority for personal data protection (ANSPDCP) [Dataprotection.ro/].
All requests will be treated seriously and will receive a response from BROTORHEADS, even if they are unfounded. The response will be adapted depending on the measures taken, and if the request cannot be fulfilled, the refusal will be motivated.
BROTORHEADS will not charge any fee or other material benefit for the exercise of the rights conferred by the GDPR. The exception will be repetitive or excessive requests, in which case we may charge a reasonable amount, but we will inform you about this before resolving the request.
The response to the requests will be sent within a maximum of 30 days from its receipt. if the complexity or excessive volume of information requires a longer period of time, we will notify you within 30 days, with the actual response being communicated within a maximum of 60 days.
If the request concerns personal data for which BROTORHEADS is the data controller, the request will be sent within 3 working days to the controller responsible for the respective processing. Under no circumstances will BROTORHEADS respond to data subjects in situations where it acts as a data controller, but it will assist in formulating the response if the controller requests it to do so and will take all necessary steps to ensure that the response reaches the data subject.
Do not provide your personal data to BROTORHEADS through other communication channels, except for those mentioned in this policy, namely through the website user account, if applicable, and/or by e-mail to shop@brotorheads.com, regardless of the person or company requesting it on our behalf, including employees or former employees of BROTORHEADS that you have previously known. Personal data transmitted through any other communication channels except those mentioned in the policy to any third party, for any purpose, is not the responsibility of BROTORHEADS, the latter being unable to ensure their security. In this regard, we recommend that you carefully study the privacy policies of such third parties.
8. Who is responsible for the processing of personal data?
BROTORHEADS controls the processing of personal data, being the data controller. For any questions or ambiguities in connection with this policy or in connection with the processing of personal data, please write to us at: shop@brotorheads.com
This privacy policy is in force from 01.04.2026. it may undergo subsequent changes. Any updates enter into force on the date of their publication on the website www.brotorheads.com/shop/ .
By any subsequent changes and updates to this policy, we undertake not to prejudice in any way your rights mentioned in this version. In the event that such changes could have a major direct or indirect impact on your rights in relation to your personal data, we undertake to explicitly inform you of this and to request your consent, if necessary, in accordance with the applicable legal provisions.
In any case, all subsequent changes will be presented on this page, and if they are significant, we will highlight them. Also, all versions of this privacy policy are kept in the BROTORHEADS archive for consultation.
