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Privacy Policy

PRIVACY POLICY REGARDING THE PROCESSING OF PERSONAL DATA

This English text is a translation of the Romanian version. The Romanian version is the reference version and prevails in case of any inconsistency.

1. INTRODUCTION

This policy regarding the processing of personal data provides you with the legal information about how Fcube Data Lab S.R.L. processes your personal data when you access and use the Promoscore mobile application, as well as the rights you have in relation to this processing.

In this policy, except where terms are defined below or where the context requires otherwise, capitalized terms have the meaning set out in the Terms and Conditions.

2. WHO IS THE CONTROLLER OF YOUR PERSONAL DATA?

Fcube Data Lab S.R.L., a Romanian limited liability company with its registered office in Bucharest, Sector 2, 1 Thomas Masaryk Street, Building 1, Entrance A, Floor 2, Apartment 5, Office 2, registered with the Bucharest Trade Registry under no. J2025059084009, having European unique identifier ROONRC. J2025059084009 and tax identification code RO52291263, e-mail: support@promoscore.io, is the controller of your personal data and controls how your personal data is processed.

3. WHAT CATEGORIES OF PERSONAL DATA DO WE PROCESS?

The Company processes the following categories of personal data:

Personal data that we obtain directly from you

  • To sign in to our Promoscore application, you must provide certain personal data directly, such as your e-mail address or the credentials associated with your social media accounts. Providing this data is mandatory in order to create and use your Promoscore account.
  • To benefit from the prices, offers and promotions available in stores near you, it is necessary to provide your location (for example, city, street or area). If you do not provide this personal data, you will not be able to benefit from these Services.
  • If, when opening your Promoscore account, you choose to answer our preliminary questions, we will process personal data such as your date of birth, gender and number of people in your household (usually the number of adults, children and pets). You may choose to provide this information if you want to benefit from personalized shopping budget recommendations and simulations.
  • If you upload cards or vouchers to the application that contain certain personal data, such as first name and last name, or the unique code assigned to the card or voucher generated by the issuing store, we will also process this personal data. You may choose to provide this information if you want to store these instruments in your Promoscore wallet, use them for direct purchases from the issuing stores and include the related benefits in your shopping list.
  • If you upload receipts to the application that contain certain personal data, such as first name, last name and delivery address, we will also process this personal data. You may choose to provide this information if you want to store these instruments in your Promoscore wallet and use them to simulate and update your shopping budget and monitor your expenses.

Personal data generated by us

  • Data resulting from your navigation in the Promoscore application, collected through cookies and similar technologies in accordance with the Cookie Policy, such as location data (country/region) and the identification number of the equipment you use to browse the Promoscore application.
  • Personal data, such as simulations and updates of your shopping budget, generated by us based on the information received from you.

Information we obtain from third parties

  • In order to provide the Promoscore application and to promote it, we work with third-party operators that provide application distribution platforms and promotion services on social media platforms. When you download the Promoscore application, these third-party operators collect certain personal data in accordance with their own policies, which is then disclosed to us in aggregated form. This sharing of information is necessary for us to verify and monitor how the contractual relationship with these operators is carried out and does not contain personal data.

4. FOR WHAT PURPOSES DO WE PROCESS YOUR PERSONAL DATA AND WHAT IS THE LEGAL BASIS FOR THE PROCESSING?

We process your personal data, to the extent permitted or required by applicable law and depending on the options you use or access within the Promoscore application, as follows:

Providing the Services

We process your personal data for the performance of the contract concluded with you as a result of opening your Promoscore user account. The Services can be provided only if you open a Promoscore user account.

Managing your user account within the Promoscore application

When you create a user account within the Promoscore application, we will process your personal data based on our legitimate interest in ensuring your access to and use of your user account.

Communicating with you

We process your personal data based on our legitimate interest in responding to your requests relating to our Services or to your complaints. Communicating with you is also necessary in order to comply with our legal obligations in relation to consumers and data subjects.

Complying with our legal obligations

We process your personal data in order to comply with our legal obligations relating to record keeping and archiving, tax, accounting or anti-fraud justifications, and internal reporting/audit, as applicable.

Establishing, exercising or defending our rights in court

In certain circumstances (for example, disputes, complaints and litigation), we may process your personal data in order to exercise or defend, before a court or administrative authority, our rights and interests, which may arise from the contract concluded with you as a result of opening your Promoscore user account or from the law.

Operation and security of our IT systems

When you use or access our Promoscore application, our IT systems automatically collect certain data (such as the IP address provided by your internet service provider, the date and time of system access/sign-in, the operating system used and the browser type used), which is used to prevent and investigate potential abuse/fraud in the use of our IT systems and to ensure the long-term viability of our IT systems. The processing of this personal data is based on our legitimate interest in ensuring the viability of our IT systems and preventing and investigating fraudulent and abusive use of our systems.

Analysis and statistics regarding the use of the Promoscore application

We may process your personal data collected through cookies and similar technologies in order to carry out analyses and statistics about how you use or interact with the Promoscore application. We consider that we have a legitimate interest in carrying out such processing of your personal data so that we can better understand how to improve the functioning and optimization of the application.

Anonymized statistics and reports

We may process your personal data to generate anonymized statistics and reports that contribute both to improving personalized recommendations for users and to creating consumer behavior analyses that may be used by brands and retailers. The legal basis for processing this data is our legitimate interest in optimizing the application’s features and providing aggregated reports to commercial partners, while respecting the principle of data anonymization so that the individual identity of users cannot be identified or directly associated with the processed data.

Promoting the Promoscore application and our Services

We may process your personal data to promote the Promoscore application and our Services and to communicate offers, news and promotions to you by electronic means (e-mail) only based on your prior and explicit consent. In these cases, you may withdraw your consent at any time by sending a request to support@promoscore.io or by pressing the unsubscribe button available in the application or in the commercial communication. Withdrawal of your consent will not affect the lawfulness of processing carried out before the withdrawal.

When we request your personal data in order to comply with our legal or contractual obligations, providing this personal data is mandatory; without it, concluding a contract with you will not be possible. Also, you will not be able to benefit from certain functionalities of the Promoscore application if you choose not to provide the personal data necessary to access those functionalities.

5. TO WHOM DO WE DISCLOSE YOUR PERSONAL DATA?

In the course of our activity, we may transmit your personal data to:

  • Providers of cookies and similar technologies
  • Our affiliates (companies in the Promoscore group) and consultants (for example, auditors, lawyers, accountants, etc.)
  • Providers of platforms for the sale of applications/software
  • Our partners that help us manage the application or provide data storage services
  • Public authorities, under the conditions provided by law (for example, when laws require disclosure or when we have a legitimate interest in making the disclosure)
  • Potential buyers of our business or of the Promoscore application, or any other buyer, when the Company is subject to an acquisition and/or restructuring process, in compliance with legal provisions

We may also transfer your personal data outside the country.

Some recipients located outside the European Economic Area are certified under the EU-US Privacy Shield framework, and others are located in countries for which the European Commission has issued adequacy decisions. In each case, the transfer is recognized as providing an adequate level of protection for personal data from the perspective of European data protection law.

We may enter into data transfer agreements based on Standard Contractual Clauses (European Commission Decision 2010/87/EU and/or European Commission Decision 2004/915/EC), in accordance with Article 46(5) of Regulation (EU) No. 679/2016 (“GDPR”), or use other appropriate means, thereby ensuring that all other recipients located outside the European Economic Area provide an adequate level of protection for your personal data and that appropriate technical and organizational security measures exist to protect your personal data against accidental or unlawful destruction, accidental loss or alteration, unauthorized disclosure or access, and all other unlawful forms of processing.

Our current partner to whom we transfer personal data and whose servers are located in third countries is Google LLC, 1600 Amphitheatre Parkway, Mountain View, California 94043, USA (provider of cookies and similar technologies for analytics services). Data may be transferred to servers in the USA and other servers in third countries. Associated safeguards for data transfers: EU-US Privacy Shield.

The list of our partners to whom we transfer personal data may be updated periodically. You may ask us to provide a complete list of the countries outside the European Economic Area to which your personal data may be transferred, as well as details regarding the measures adopted for such transfers, at support@promoscore.io.

6. HOW DO WE ENSURE THE CONFIDENTIALITY, SECURITY AND INTEGRITY OF YOUR PERSONAL DATA?

The Company has implemented appropriate technical and organizational measures to preserve the confidentiality, integrity and security of your personal data. Your personal data may be stored on our technological systems or in printed format.

7. HOW LONG DO WE KEEP YOUR PERSONAL DATA?

As a rule, personal data processed for the purposes mentioned in this policy is kept for as long as you have a user account within the Promoscore application.

In certain situations, after the contractual relationship with the user ends, some personal data relating to user accounts may be kept for an additional period equal to the limitation period for civil liability in connection with the Services we provide to users. This information will be kept in a secure environment and used only for these purposes.

Personal data of persons registered in our marketing database will also be kept until those data subjects exercise their right to withdraw consent or, respectively, their right to object.

Data relating to cookies and similar technologies will be kept according to the specific periods set for such technologies, with a storage period that may vary from the browsing session period to up to 2 years.

Afterwards, upon expiry of these periods or upon the exercise of one of your rights in accordance with the law, we will remove/delete your personal data from our systems and records and/or take measures to anonymize it so that you can no longer be identified based on it.

8. WHAT ARE YOUR RIGHTS UNDER THE GDPR?

Under the GDPR, you have the following rights:

Right of access

You have the right to ask us to confirm whether your personal data is processed by us. You also have the right to obtain a copy of the personal data we process.

Right to rectification

You have the right to ask us to rectify your inaccurate personal data. You may also correct, complete or modify the personal data you provided to us through your user account.

Right to erasure (“right to be forgotten”)

You have the right to ask us to erase your personal data, in which case we will erase that data without undue delay, unless we have legitimate grounds to continue processing it.

Right to restriction

You have the right to ask us to restrict the processing of your personal data in the following situations: (i) when you have submitted a request for rectification or objection, for the period during which we resolve your request; (ii) when we find that the processing of your personal data is unlawful and you do not agree that we delete the data processed in this way; and (iii) when, although we no longer need your personal data, you request it from us in order to establish, exercise or defend a right in court. If we accept your request to restrict processing, the relevant data will be marked as restricted and any subsequent processing by us of your personal data, except storage, will take place only based on your express consent or on grounds relating to the protection of our rights in court, the protection of another person or reasons of public interest.

Right to object

You have the right to object to the processing of your personal data on grounds relating to your particular situation when we process your personal data based on a legitimate interest or for marketing purposes. If you submit an objection request, we will stop processing your personal data for the relevant purposes, unless we have compelling legitimate grounds that justify continued processing and override your interests, rights and freedoms.

Right to portability

When we process your personal data based on your consent or for the performance of a contract concluded with you, you have the right to request the portability of the personal data we process and the direct transmission of that data to another entity indicated by you, in a structured, commonly used and machine-readable format.

You may exercise the rights mentioned above by sending a written request to: Fcube Data Lab S.R.L., Bucharest, Sector 2, 1 Thomas Masaryk Street, Building 1, Entrance A, Floor 2, Apartment 5, Office 2, or by e-mail to support@promoscore.io. If you have not received a response to your request within 30 days or you are not satisfied with the way we handled your request, you have the right to lodge a complaint with the National Supervisory Authority for Personal Data Processing, located at 28-30 B-dul G-ral. Gheorghe Magheru, Sector 1, postal code 010336, Bucharest, Romania, https://www.dataprotection.ro/.

Mobile platforms have permission systems for certain types of device data and notifications, such as phone contacts and location services, as well as push notifications. You may change your device settings either to give your consent or to object to the collection of the relevant information or the display of the relevant notifications. Of course, if you do this, certain Services provided through the Promoscore application may lose their full functionality.

This Policy regarding the processing of personal data, including the Cookie Policy, enters into force on 10.11.2025 and may be updated from time to time. Any update will become applicable from the moment the new version is published in the Promoscore application.