Privacy and data processing policy
Welcome to my website, www.gabrielvip.com!
Thank you for your interest in what we do and the products and/or services we offer. When you enter into a relationship of any kind with us, you entrust us with your information. We know how important the privacy of the data you give us is, so we have prepared this Privacy and Data Processing Policy to tell you a little about how we process your data and what rights you have in relation to us.
The purpose of this policy
The purpose of this Privacy and Data Processing Policy is to explain to you what data I process, why I process it and what I do with it. This Privacy & Personal Data Processing Policy (the "Policy") is intended to inform you about how Smart Media Creators SRL ("Company"), known under the generic brand name "Gabriel VIP" treats the privacy of the data it collects and when you provide it to us through your use of this site, including any data you give us when, for example, you subscribe to our newsletter, participate in one of our ongoing promotions or purchase a product or service.
The www.gabrielvip.com website is not intended for children under the age of 18, we do not and do not intend to knowingly collect data about children. To this end, we take all reasonable steps to verify that the person providing the data to us is not a child as defined above - the responsibility for any information provided to us in circumvention of these provisions rests entirely with the person providing the data to us.
This policy informs you about the information we process about you in relation to us. In collecting this information, we act as a controller and are required by law to provide you with information about us, why and how we use your data and what rights you have over your data. This policy is in addition to our other notices and is not intended to remove them.
It is important that you read this policy along with all data processing & privacy notices that we provide to you on various occasions when we collect or process your personal data so that you are always fully informed of what and how we use this data.
We take your privacy seriously and will never sell lists or email addresses. We are aware that your personal information belongs to you and we do our best to store it securely and process it carefully. We do not provide information to third parties without informing you. This information is important. I hope you will read it carefully.
Who are we?
Below you will find our identification data:
Name: SMART MEDIA CREATORS SRL
Head office: Targoviste, Radu de la Afumati, No 1, Jud. Dambovita
Trade register number: J15/138/17.02.2017
Unique identification code: 37059813
E-mail: hello@gabrielvip.com
To the extent that you have any questions, comments or complaints about us or the personal data we process for you, you can always send us an e-mail at the above address.
Copyright
The company as author, owner, administrator of the gabrielvip.com website (hereinafter referred to individually as "the Site" and collectively as "the Sites"), collects and processes personal data belonging to persons accessing the Site, in accordance with the legal provisions on the processing of personal data and the free movement of such data. Through this policy, we tell you what information we collect about you as a user of the Site (hereinafter referred to as "User"), how we use (process) it, and the choices you have regarding this data.
This policy covers social media profiles, which can be found at the following address:
Instagram: http://instagram.com/iamgabrielvip
Youtube: http://youtube.com/@gabrielvip
TikTok
This policy applies to all devices used to access the gabrielvip.com website, such as, but not limited to, smartphone and tablet devices, laptops, smartwatches, and any other device with an internet connection that allows remote access to the Site. The Company owns all copyrights to all content that the Company posts on the Site, and persons accessing the Site have no rights to the content, including, without limitation, reproduction, copying, distribution, modification, etc.
In case you do not agree with the terms and conditions related to their use (presented in this document in terms of personal data protection, but also in the rest of the documents on the website in terms of confidential information, etc.), please do not use the gabrielvip.com website.
Changes to this policy
This policy became applicable Company-wide on the date indicated at the top of this webpage. To the extent we deem necessary, this policy may be subject to change from time to time. When we make changes, the updated policy will be posted on this page, indicating the date it became applicable. In such a case, it will be at the Company's discretion whether and how to notify individuals of such changes other than by posting them on the website (e-mail, pop-up, slide bar, announcement, etc.).
We encourage you to check for updates and changes to this policy by checking this date when you access the gabrielvip.com website and mobile apps. We will notify you of any changes to this policy that could significantly affect how we use or disclose your personal information before the change becomes effective via a message on this site, when possible.
Links to other sites
The website is part of a whole that includes the pages on social networks, namely Facebook: Instagram: Youtube
This policy does not cover other third party apps and websites that you may reach by accessing links on our website or social media. This is no longer under our control. We encourage you, before providing personal data to them, to review and familiarize yourself with the rules of use of any site and/or application, the privacy and data processing policy, and the security standards used. We are not responsible for the expressions and procedures used by the operators of these websites, and you are solely responsible for submitting personal data to these websites.
Youtube
You'll see me quite active on my YouTube channel where I post educational content, tutorials, reviews, tips & tricks from the video and editing world, professional tips and more.
YouTube has its own data processing policy, which I invite you to read here. When you comment on a video, another user's comment or interact with YouTube's facilities, you agree to its data processing policy.
I'm pretty active on Instagram, where you can leave me comments, tag me or write me messages. We collect your personal data here too, but Instagram also collects it, and it has its own data processing policy, which I invite you to read here.
Commercial partners
www.gabrielvip.com contains affiliate links, meaning, I recommend products and services I’ve used or know well and may receive a commission if you purchase them too (at no additional cost to you).
One of the partners I work with for affiliate products is Amazon Associates - Amazon’s affiliate marketing program (https://affiliate-program.amazon.com).
Amazon Associates has its own
Operating Agreement (https://affiliate-program.amazon.com/help/operating/agreement)
Conditions of Use (https://www.amazon.com/gp/help/customer/display.html?ie=UTF8&nodeId=508088)
Program Policies (https://affiliate-program.amazon.com/help/operating/policies).
Amazon.com also has its own
Conditions of Use (https://www.amazon.com/gp/help/customer/display.html?nodeId=508088&ref_=footer_cou)
Privacy Notice (https://www.amazon.com/gp/help/customer/display.html?nodeId=468496&ref_=footer_privacy)
Consumer Health Data Privacy Disclosure (https://www.amazon.com/gp/help/customer/display.html?ie=UTF8&nodeId=TnACMrGVghHocjL8KB&ref_=footer_consumer_health_data_privacy)
Please note that my partners have their own processing policy, which you will find on their respective websites, and some of the information comes to us as a result of the agreement we have with them.
Although we use these platforms to contact you with useful information or offer you the opportunity to place an order for a product or service, they are governed by their own privacy policy, which we encourage you to read here: Facebook, Instagram, YouTube, WhatsApp.
6. User Conduct
By accessing the Site, you agree to abide by the legal rules in force in Romania when using this Site, to act consistently with good morals and those rules and not to damage in any way the reputation and rights of the Company or other users.
7. Responsibility
All risks that may affect you as a result of using this Site are entirely your responsibility and the company is not liable for them. All disputes arising in connection with the use of the Site shall be settled by the competent court of competent jurisdiction in Romania.
You are also responsible for any comments, reviews or messages submitted through the Site or on related social media pages or on the pages of our business partners that may affect other people or us as a Company. Although we constantly strive to delete or remove such messages or comments, we may not be able to act promptly on all reported issues due to time constraints. Should there be any claims by us or third parties regarding the content posted, we fully reserve the right to fully recover our damages from you.
8. Information about the processing of personal data
8.1 To whom does this policy apply?
According to the law, as a user of the Site you are a beneficiary of our services (including by purchasing physical products). Whether you do so personally, through a representative or as a contact person of a company or person in any kind of relationship with our Company, you are a "data subject", i.e. an identified or identifiable natural person.
In order to be fully transparent about data processing and to allow you to easily exercise your rights at any time, we have implemented measures to facilitate communication between us, the data controller, and you, as the data subject.
8.2 Compliance with legal regulations on personal data protection
In the course of its current activity, the Company processes certain personal data relating to its customers, users, and employees and assumes the role of personal data controller in relation to the processing of such personal data.
When processing personal data, the Company conducts its business in accordance with legal regulations, in particular, Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (hereinafter referred to as the "General Data Protection Regulation" or "GDPR/RGDP").
In accordance with the above-mentioned provisions on the protection of individuals with regard to the processing of personal data and the free movement of such data, the Company processes and manages personal data for the purposes listed below, having implemented technical, organizational and security solutions in line with legal regulations.
During the use of the Site, the Company takes all necessary steps to preserve the confidentiality of personal data submitted by Users through the Site, both directly and indirectly.
This policy describes how the Company and its affiliates collect and use users'/employees' personal data in order to provide the products and services offered.
Examples of operations that fall under this heading include, but are not limited to, the following:
customer support, which involves requesting information or filing complaints, post-sales activities, including customer relations services, informing users/customers about the evaluation of the services provided (feedback);
carrying out competitions organised by the Company via the Website or social networks;
delivery of prizes won or products ordered;
information about services, accounts, programs, contests and sweepstakes;
presentation of special offers, personalized promotions, advertising messages, promotion of products and events, loyalty programs or other marketing purposes;
maintaining, improving and analyzing the website, products and services we offer;
maintaining adequate records for internal administrative purposes, maintaining the functionality of our website and keeping them relevant to customer needs;
providing information on the products marketed;
providing important product safety information;
for specific activities in the Human Resources department, if you are interested in being part of our team and have sent a CV to the Human Resources department via the Website, in the dedicated section or have been redirected to the contact page;
to respond to requests received on the Company's contact address or in the dedicated section of the Site;
Personal data will be kept as long as necessary for the purposes mentioned above or, where applicable, in accordance with legal provisions (such as, for example, in the case of the organization of competitions).
8.3 Personal data controller. Who are we?
As you have seen or are about to see, I ask for certain personal data depending on the stage you are at in the Site. When you browse the gabrielvip.com website and social media platforms, I may collect information about you, both from you directly and from other people/third party service providers.
Please note that there may be situations where, if you choose not to provide us with your personal data, we may not be able to provide you with the services/products you request or respond to a request from you.
In the area of personal data, the company I represent is a personal data controller. As such, we have a number of obligations, including informing you about the data we process, how we do it, what rights you have and how you can exercise those rights.
Below you will find our identification data:
Name: SMART MEDIA CREATORS SRL
Head office: Targoviste, Radu de la Afumati, No 1, Jud. Dambovita
Trade register number: J15/138/17.02.2017
Unique identification code: 37059813
E-mail: hello@gabrielvip.com
To the extent that you have any questions, comments or complaints about us or the personal data we process for you, you can always send us an e-mail at the above address
8.4 What information do we collect?
Personal data or personal information means any information about an individual that can help identify that person. This does not include data where identity has been removed (anonymised data).
Depending on the products, services or functionalities you wish to benefit from, we will need to process certain personal data, which will generally be as follows (this list is indicative and will, where applicable, be detailed):
Identifying information: first name, last name, company name, trade registration number, unique identification code, username or similar identifier, date of birth, gender, language in which you wish to interact with us, country, etc. Certain identifying information will be required in order for us to issue you an invoice or enter into a contract with you.
Contact details: billing address, delivery address, e-mail address, phone number.
Financial data: payment or credit card/bank account information, purchase information. We do not store data about bank card information or other technical data: this is only done through our payment processor we are working with at the time.
Transaction data: details of payments to and from you and other details of products and services you have purchased from us.
Technical data: internet protocol (IP) 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.
Profile data: username, password, orders placed by you, your interests and preferences, feedback provided, survey responses.
Usage data: information about how you use our Site, products and services.
Marketing and communication data: your preferences for receiving marketing materials from us and our third parties and your preferred methods of communication.
Biometric data: Photo-video images from events you attend (workshops, webinars, live social media, conferences, seminars, other events) or when you provide us with photo-video testimonials.
We also collect, use and share Aggregate Data, such as statistical or demographic data, for any purpose. Aggregate Data may be derived from your personal data, but is not considered personal data for purposes of the law because this information does not directly or indirectly reveal your identity.
For example, we might aggregate your Usage Data to calculate the percentage of users accessing a specific site feature. However, if we combine or correlate Aggregated Data with your Personal Data in such a way that we can directly or indirectly identify you, we will treat the resulting combined data as Personal Data that will be used as described in this document.
We DO NOT collect any Special Categories of Personal Data about you (this includes details of your racial or ethnic origin, political opinions, religious or philosophical beliefs or trade union membership and the processing of genetic data, biometric data for your unique identification, health data or data about your sex life or sexual orientation). We also do not collect information about criminal convictions and offences.
You will see that as you use our Site, we collect information about you and the services you use, which falls into three different categories depending on the source, as follows:
Direct interaction (information we collect from you). You will be able to directly provide us with information about yourself (such as Identification Data, Contact Data and Financial Data) by filling out fields on the Site or by mail, email, telephone or other method we provide to you. This includes the personal data you provide to us when:
you want to buy/benefit from one of our products or services;
make an account with us on the Site;
subscribe to our services or publications (including newsletter);
request promotional & marketing material;
enter a competition or promotion, fill in a questionnaire, etc.;
participate in one of our events, including webinars;
give feedback etc.
Automated technologies or interactions. As you use our Site, we may automatically collect Technical Data about the equipment you use, how you browse and various patterns. We will collect this information through the use of cookies, server logs and other similar technologies. Please read our cookie policy for further details here.
Third parties or publicly available information.
We may obtain information about you from other sources, such as public databases, joint marketing partners and other third parties. Examples of information we may receive from other sources include information about your media profiles (including social media networks), marketing leads, search results and links, and paid records (such as sponsored links). We may receive information from you and from partners with whom we have a contractual relationship so that we can deliver that service to you, such as a course or webinar you want to attend.
We may also receive personal data about you from various third parties (or public sources), such as:
Technical data from the following third parties:
analytics providers (such as Google);
advertising networks;
search information providers;
Contact Data, Financial Data and Transaction Data from technical, payment or delivery service providers;
Identification data and Contact data from brokers/intermediaries or data aggregators;
Identification data and contact details from public sources (such as Trade Register, ANAF, etc.).
8.4.1 Information you provide us with
As a customer (user who has purchased a product or service from the Site) - some information we collect is provided by you when you use our services, purchase one of our products, subscribe to our newsletter or contact us on social networking pages, via WhatsApp, email or other means of contact. This may include your first and last name, username, password, email address, postal address, phone number, date of birth, and any other information provided/collected by us. Any information provided by you will be taken into account and you agree that your personal data may be used by the Company for the purposes set out below.
For these situations, the following examples of personal data will be considered:
your first and last name
place of residence
email address
date of birth
phone number
payment details
where applicable, appropriate information about the order placed and
photo-video footage when participating in offline or online events.
In this case, your personal data is processed in accordance with the terms & conditions found on the Site and the related social media pages. If you choose not to provide us with your data, we will not be able to complete your order, respond to your requests, enter you in contests and promotions or allow you to enjoy the full customer experience.
The personal data of customers are processed for the following purposes:
to facilitate the management of the orders of the respective customer;
marketing (for example, as part of the Company's marketing campaigns, to provide information about new products, to deliver the Company's marketing communications, or to provide notifications of prize winnings and other customer-related benefits);
monitoring customer satisfaction.
In the case of contests organized on the Site or via social media pages, personal data is processed for the purpose of handing out prizes to the winners of a contest. Personal data may be used to send you information about products, services, events, etc. that we offer and host, provided that you tick the appropriate box in the Loyalty Program or contest (promotion) registration form or have submitted such data for one of the purposes mentioned above.
As a user - when you use our contact address, WhatsApp number, write to us on one of our social network pages or send us a request via the dedicated section of the Site asking for certain information about the Company, you want to report certain issues, etc. In order to reply to your messages, the Company must process your data.
Attention! Any information and personal data that you transmit in any manner whatsoever to the Company is entirely your responsibility and you are solely responsible for the accuracy of the information and data transmitted to the Company.
8.4.2 Information we automatically collect using technologies
Some information is collected automatically by us, including when you access our Website or otherwise use our services. This information includes:
Shopping information - we may collect information about your transactions on the Site, including what products you purchase, how often you access them, whether you have purchased other products, and any rewards or promotions associated with your purchases.
Device information and general usage - we may collect information about your browser or device. This information may include the type of device you are using, your operating system, browser, internet service provider, your domain name, internet protocol (IP) address, device and mobile ad identifiers, the website that referred you to the Site, the web pages you view (including the date and time you view them), the services or functionality you access or use (including the date and time you access or use them), and the subject of the ads you click on or view. To collect this information, we use cookies, web beacons and/or similar technologies. The purpose of processing this data is for the Company to use it to compile statistics, through the use of Aggregate Data, which analyzes site usage and to customize advertising to Users, to the extent they have agreed to this.
Statistical data & anonymous data
The company may use statistical data or anonymous data resulting from processing for the following purposes:
preparation of reports/analyses;
collecting information for your own purposes;
publishing, promoting, offering services offered by the Company
8.4.4 Communication data. Cookies policy & other tracking technologies.
This section on cookies explains how and why cookies, web beacons, pixels, gifs and other similar technologies (collectively "Cookie and other tracking technologies") may be stored and accessed on your device when you use or visit the Site.
8.4.4.1 What are cookies & other tracking technologies?
A "cookie" is a small text file of information that can be stored on your computer or mobile devices with Internet access (smartphone, tablet or other devices that allow you to connect to the Internet and access a web instance) when you access the Internet. The cookie is installed by a request issued by a web-server to a browser (e.g. Internet Explorer, Chrome) and cannot access information on the user's computer/mobile device. Please note that this technology does not contain software, viruses or spyware.
Other tracking technologies work similarly to cookies and place small data files on your devices or monitor your activity on the Site to allow us to collect information about how you use the Site. This allows the Site to recognize your device from other users of the Sites. The information provided below about cookies also applies to these other tracking technologies. You can find more information at www.allaboutcookies.org and www.youronlinechoices.eu.
8.4.4.2 What do we use cookies for?
Use of cookies - We use cookies and other tracking technologies to make the Site easier to use and to better tailor our offerings to your interests and needs. Cookies are also used to increase the speed of your future activities and experiences on our site. They relate to your online privacy preferences or relevant advertising. We also use cookies to compile anonymous, aggregated statistics that allow us to understand how people use the Site and to help us improve its structure and content, excluding personally identifying the user.
8.4.4.3 What types of cookies do we use?
The company uses two types of cookies: (a) session cookies and (b) persistent cookies.
Session cookies are used temporarily and remain stored on your device until you log out of the site or close the application (web browser).
Persistent cookies remain on your device either for the period defined in the relevant cookie settings or until you delete it. In general, we store cookies and files from other tracking technologies for up to 30 days.
The cookies we use are included in one or more of the following categories:
Strictly necessary: these types of cookies are essential for the provision of services specifically requested by visitors to the website. Without them, the web pages cannot function and cannot provide the requested services.
A detailed overview of the strictly necessary cookies of our website is given below:
Name (Cookie ID): gabriel_vip_session
The domain placing the cookie:
The purpose of the cookie: uniqueness
Lifespan: session
Name (Cookie ID): XSRF-TOKEN
The domain placing the cookie:
The purpose of the cookie: security
Lifespan: session
performance: These cookies collect information about how visitors use a web page, such as which pages are most popular, which page login method is most effective, and whether users receive error messages from web pages. These cookies allow us to provide users with a high quality user experience and also allow us to measure website audience. The information collected by these cookies does not identify users, but is only intended to help improve the way our website works by providing information that allows us to offer a more personalized experience in the future.
Information obtained through the use of cookies may be collected only for the purpose of mediating and performing certain user functions. This data is encrypted in a way that disables access by unauthorized persons.
8.4.4.4 What are third party cookies?
In certain situations, our Site makes use of cookies that are provided by third parties. Please note that we are not responsible for their processing of personal data and we recommend that you read their privacy and cookie policy.
For example, we include in this category cookies provided by third parties such as YouTube (for playing video content), Facebook (for displaying our fan page, events, etc.), Instagram (for displaying your feed and the ability to interact with those posts), etc.
Although they are not mandatory, it is possible that if you choose not to accept these cookies, your experience with the Site may be limited (for example, you may not be able to view entire elements on a page, such as video content).
A detailed overview of the strictly necessary cookies of our website is given below:
Name (Cookie ID): gabriel_vip_session
The domain placing the cookie:
The purpose of the cookie: uniqueness
Lifespan: session
Name (Cookie ID): XSRF-TOKEN
The domain placing the cookie:
The purpose of the cookie: security
Lifespan: session
8.4.4.5 What types of similar tracking technologies do we use?
Our website uses Google Analytics, a web analytics service provided by Google, Inc. ("Google"). Google Analytics uses cookies to help the website analyze how users use the site. The information generated by the cookie about your use of the Website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Google will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser. If you choose to do so you may not be able to use the full functionality of this website.
You can learn more about Google Analytics' privacy policy here.
To disable the Google Analytics option, you can access the following link.
We also use technology provided by Facebook, through Facebook Pixel and Facebook Custom Ads.
Facebook Custom Ads is a set of cookies that tracks your interactions with our Site in order to provide you with personalized advertising on Facebook where you are a registered user of such a service. Your encrypted email address is also shared by us or our third party service providers with Facebook for this purpose.
Facebook Pixel is used to track the conversion rate of Facebook ads and to target users with Facebook ads based on the actions they take on our site.
This pixel records information about a user's browser session, which it sends to Facebook, along with an anonymized version of the Facebook ID and the URL viewed. This allows us to target our Facebook ads to the audience of people who have visited the site.
Users' personal data are processed subject to their consent, which is voluntary and is provided by the User when accessing the Site.
Most Internet browsers are initially set to automatically accept cookies. You can change the settings to block cookies or to be notified when cookies are sent to your computer or mobile device (smartphone, tablet). If you cancel the cookies we use, you will no longer receive personalized information when you visit the Site. If you use multiple devices to view and access the Site (e.g. computer, smartphone, tablet, etc.) you will need to ensure that each browser on each device is set to match your cookie preferences. By going to the "cookie settings" existing in the browsers you use you will find indications explaining how you can change your cookie settings. These settings are usually found in the "options" or "preferences" menu of your browser. For more details you can also use the "help" option of your browser.
Your browser may allow you to delete all cookies after closing it. However, this option results in the deletion of permanent cookies that may store your preferences and custom settings on web pages you visit regularly. However, you can keep the cookies you want, as your browser can allow you to specify which web pages are always or never allowed to use cookies.
You can find further details on how to delete cookies or how to manage cookies on different internet browsers by clicking on the links below:
· Cookie settings in Internet Explorer
· Cookie settings in Firefox
· Cookie settings in Chrome
· Cookie settings in Safari
9. How do we use the information obtained?
The Company collects this information in order to provide you with the Company's products and services, to improve service offerings, and to develop new technologies to help you.
Specifically, we use the information:
in order to be able to deliver your purchased products and services;
to send you regular commercial information;
to keep you up to date with our latest news;
to improve the safety and security of our users and our services;
for the assistance offered to users;
for research and development;
to enable communications to or between users;
in connection with legal proceedings;
in order to conclude or execute a contract between you and our company
to answer your questions and requests;
for marketing purposes, but only if we have your prior consent;
to provide and improve the services and products we offer;
to diagnose or fix technical problems;
to defend against cyber attacks;
for creating and/or maintaining accounts;
to comply with the relevant legislation;
to establish or claim a right in court;
to verify your identity (e.g. when you return to the site and are already logged in);
to personalize your experience on the site;
to personalize the advertising you see on other publishers' websites, while limiting the amount of time you see ads;
to improve the design and style of the site
to inform you about products, services or promotional offers that may be of interest to you if you have chosen to receive these types of communications.
to send you automated messages about your subscription or account registration, for example if you clicked on a password reset link. This could be via email, overlay or push notification.
to publish and reply to a comment you sent to us, on the blog, on the website etc.;
to allow you to share content on the site with others using social media or email;
to administer contests and inform you if you have registered for a promotion;
for compiling customer reviews;
for market research;
to send a product to the address you specify;
to give you access to a service or product you request;
to deal with any request/complaint/complaint or suggestion you send us;
to send you push notifications via the website application;
to be able to use and keep track of affiliate marketing etc.
In short, we will use the data you provide to us (either directly or indirectly) to:
enter into or perform a contract with you;
to achieve our (or a third party's) legitimate interest when it is also in your interest and your fundamental rights and freedoms are not affected;
comply with a legal or statutory obligation.
The Company does not sell or distribute your personal information to third parties for their direct marketing purposes.
9.1 Provision of services and functions
The company uses the information collected to provide, customize, maintain and improve its products and services. This includes using the information to:
creating and updating your account on the Site;
confirmation of your identity and/or the company you represent;
allowing access to your account and viewing the status and transactions made;
performing internal operations necessary to provide our services, including troubleshooting software and operational errors, performing data analysis, testing, studying, monitoring and analyzing usage and activity trends;
specific activities of the Human Resources department, if you are interested in being part of our team and have sent a CV to the Human Resources department via the Website;
9.2 Customer assistance
The company uses the information you provide (such as your history in the app or on the Site, comments or reviews left on social media platforms or sent via email, payment methods, personal data, etc.) to improve the support service offered to users, such as:
investigate and solve your problems;
monitor and improve responses received from customer support;
9.3 Research and development
The company is in a continuous process of improving the services and products offered to customers, through continuous research and development, in order to constantly provide quality services and products.
Therefore, your data is very important to us and we will be able to use it for testing, research, analysis and product development. This allows us to improve the safety and security of our services, to develop new features and products and to facilitate the provision and expansion of our services.
9.4 Messages
The Company may use the information used by you to provide you with messages (via the Platform, email, WhatsApp or social networks) regarding your account status, updates to the Site and social platforms, loyalty, rewards, events, newly introduced services or products and the like, when we think you may be interested.
9.5 Legal procedures
We may use the information you provide to investigate or resolve disputes, complaints or any existing problems with the use of the products or for any other purpose permitted by applicable law. The Company may also transmit the information provided in accordance with requests from the jurisdictional bodies that have jurisdiction over access to this information, such as criminal investigations, court cases or preliminary proceedings, etc.
9.6 Transfer of information obtained
We will only disclose your personal data for the purposes and to the third parties described below.
Tert (designation): https://www.mailerlite.com / MailerLite Limited
Purpose (service provided): Send newsletter
Privacy policy: https://www.mailerlite.com/legal/privacy-policy
Tert (designation):
Purpose (service provided): Issuing invoices, preparing accounting documents
Privacy policy:
Personal data may be shared with any other member company of our group if we consider this to be in our legitimate interest for internal administrative purposes (e.g. data storage) or for auditing and monitoring our internal processes.
We may share personal data with and/or to our group companies if they provide us with products and services, such as IT systems.
9.7 Transfer of personal data abroad
We work with a number of carefully selected partners and service providers to ensure that your data is safe. We consider it important that you are informed about where the data you provide us is transferred.
The transfer of personal data to a third state can only take place if the state to which the transfer is intended ensures an adequate level of protection.
The transfer of data to a state whose legislation does not provide for a level of protection at least equal to that offered by the General Data Protection Regulation is only possible if there are sufficient guarantees regarding the protection of the fundamental rights of data subjects. These guarantees will be established by us through contracts concluded with the providers/service providers to whom your personal data will be transferred.
Some of our service providers may be located outside the European Economic Area (EEA), so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data outside the EEA, we will ensure that a similar level of protection is in place through one of the following safeguards:
we will transfer your personal data to countries where it has been demonstrated by the European Commission to provide an adequate level of security for personal data. For more details, click here.
when we use certain service providers, we will be able to use certain model contracts provided and approved by the European Commission which offer the same protection to personal data as they do in Europe. For more details, click here.
When we use US providers, we will be able to transfer data if they are part of the EU-US Security Shield which obliges them to offer similar conditions of protection for data shared between the EU and the US. For more details, click here.
In the event that the Company is required or not permitted to provide personal data, only data necessary to fulfill the strict purpose of the request will be disclosed.
9.8 Provision of data to third parties
The company may disclose personal data to third parties. The Company only provides partners with personal data that it has already processed, for which technical and organizational measures for data protection have been established and other obligations under the General Data Protection Regulation have been fulfilled. The Company's partners have access to personal data only to the extent necessary for the performance of their tasks.
The Company uses services of companies such as:
https://www.hostinger.com has its own Privacy Policy:
https://www.hostinger.com/legal/privacy-policy and Terms of Service: https://www.hostinger.com/legal/universal-terms-of-service-agreement
https://www.mailerlite.com / has its own:
Under no circumstances does the company provide personal data to third parties against payment.
Categories of recipients to whom personal data collected may be disclosed:
contractual partners of the Company (such as the companies with which we are in partnership, but only under a confidentiality commitment from them, guaranteeing that this data is kept secure and that the provision of this personal information is in accordance with the legislation in force);
Service providers that provide the Company with services related to placing personal data on Company servers, managing loyalty program applications, securing payments for Company purchases and evaluating marketing surveys (e.g., marketing services, newsletter management, payment/banking or other services), including entities that assist the Company in processing data as data processors, insurers, etc.); Personal data of Company employees is provided to the external accounting firm, which compiles the Company's accounting, tax and payroll records;
to the competent authorities (Public Prosecutor's Office, Police, courts and other authorized state bodies), on the basis and within the limits of the legal provisions and following expressly formulated requests, as well as when requested in accordance with the applicable legislation;
other companies in the same group as the Company, its subsidiaries and affiliated companies for management and analysis, decision-making and other business purposes. For example, we may share your information with subsidiaries and affiliated companies to administer our loyalty or reward programs, process orders and requests, and to expand and promote our product and service offerings,
specialists, lawyers, accountants and other professional service providers
We may also transmit personal data to third parties:
if you request or agree to this;
persons who can demonstrate that they have the legal authority to act on your behalf;
where it is in our legitimate interest to do so in order to administer, expand or develop the business;
where we are required to disclose your personal data to comply with a legal obligation, any lawful request from governmental or executive authorities and as may become necessary to meet certain national security or law enforcement requirements or to prevent certain illegal activities;
to respond to any claim, to protect our rights or the rights of a third party, to protect the safety of any person or to prevent any illegal activity; or to protect the rights, property or safety of the Company, its employees, its customers, its suppliers or others. Some of these recipients (including our affiliates) may use your data in countries outside the European Economic Area.
10. Safety and security
We understand how important the confidentiality and security of personal data is and we take the necessary measures to protect our customers and other persons whose data we process from unauthorized access to personal data, as well as from unauthorized alteration, disclosure or destruction of the data we process in the course of our business.
We have implemented the following technical and organisational measures for the security of personal data:
Dedicated policies. We adopt and constantly review our internal personal data processing practices and policies (including physical and electronic security measures) to protect our systems from unauthorized access or other possible security threats. These policies are subject to constant review to ensure that we comply with legal requirements and that systems are functioning properly.
Data minimisation. We ensure that the personal data we process is limited to that which is necessary, appropriate and relevant for the purposes stated in this policy.
Restricting access to data. We try to restrict access to the personal data we process as much as possible to the minimum necessary: employees, collaborators and other persons who need to access this data in order to process it and carry out a service. Our partners and collaborators are subject to strict confidentiality obligations (either by contract or by law).
Specific technical measures. We use technologies to ensure the security of our customers, always trying to implement the best solutions for data protection. We also make regular data back-ups in order to be able to recover them in case of an incident and we have regular audit procedures in place regarding the security of the equipment used. However, no website, no application and no internet connection is completely secure and unreachable (see NASA).
Ensuring the accuracy of your data. Sometimes we may ask you to confirm the accuracy or currency of your data to ensure that it reflects the reality.
Staff training. We constantly train and test our employees and collaborators on legislation and best practices in the field of personal data processing.
Data anonymisation. Where we can, we try as far as possible to anonymise/pseudo-anonymise the personal data we process so that we can no longer identify the individuals to whom it relates.
However, although we constantly strive to ensure the security of the data you entrust to us, we may experience less fortunate events and security incidents/breaches. In these cases, we will strictly follow the procedure for reporting and notifying security incidents and will take all necessary measures to restore the situation to normal as soon as possible.
11. Data retention
The company keeps personal data only for the period of time necessary to achieve the purpose of its processing and does so in accordance with the rules specified below:
in the case of contests organized on the Sites or on social networks, personal data are kept only for the period of time during which you participate in that contest (including the procedure for the delivery of prizes), except for certain financial-fiscal provisions that may require a longer period of time. After this date, we may continue to keep the data obtained, after they have been anonymised, to use them for statistical purposes, research, development, expansion and improvement of the services offered;
Users' personal data are kept for a maximum of two years from the last visit to the Site. After this period, in case of account deletion, the Company may continue to keep the data obtained, after they have been anonymized, in order to use them for statistical purposes, research, development, expansion and improvement of the services offered.
in the case of employees, personal data are kept for a period in accordance with the archiving periods provided by law;
in the case of social media postings, events, conferences, promotional materials of any type (indoor/outdoor/digital/print format), images or photo-video materials of Customers or Users will be retained until expressly requested by the persons appearing in such materials. However, in the event of a request for deletion, the Company reserves the right not to comply with such a request if it considers that its interest prevails over the interest of the consumer/person concerned.
the images recorded by the security cameras (if the events take place at the Company's premises) are kept for a maximum period of thirty days;
keep transaction information and usage statistics in accordance with regulations, tax and insurance requirements and other requirements in force where it operates. After this period, the Company deletes or anonymizes this information in accordance with applicable laws.
Below you will find an overview of our main activities in relation to you and the corresponding retention periods:
Purpose: Registering as a User
Additional information: We will keep your data until the moment you decide you no longer have User status (delete your account).
Purpose: Conclusion and execution of the sales or service contract you enter into with us
Additional information: We will process your data for as long as necessary to manage the purchase of the products or services you purchase, including any returns, complaints, warranties or claims related to the purchase of that product or service.
Purpose: Requests or inquiries made through Customer Service/Support
Additional information: We will process the data for as long as necessary to fulfill the request or application.
Purpose: Marketing
Additional information: We will process the data until you unsubscribe from the newsletter/other marketing methods.
Purpose: Improving services
Additional information: We will process the data on a one-off basis, only for the duration of the respective action (i.e. survey, feedback form, etc.).
Purpose: Employment procedures
Additional information: In case you apply for a position with us, but the recruitment process is not completed, we will keep your personal data for a limited period of time, according to our internal policy for processing personal data on candidates.
If you are an employee of the Company, we will retain your personal data for the statutory period required by law where mandatory and/or for such other period as may be necessary to fulfill our legitimate interests (for example, in relation to the resolution of any disciplinary proceedings or financial liability) in accordance with the employee personal data processing policy provided to us.
In short, we will keep your personal data for as long as necessary to fulfill the purposes for which we have collected it, including for the purposes of meeting any legal, accounting or reporting requirements.
We try as much as possible to establish from the outset the period necessary for storing personal data, but this is not always possible. To determine the appropriate retention period for personal data, we consider the value, nature and sensitivity of personal data, the potential risk of harm caused by unauthorised use or disclosure of your personal data, the purposes for which we process personal data and whether we can achieve those purposes by other means and applicable legal requirements.
By law we must keep basic information about our clients (including contact details, identity, financial and trading data) for 5 years after they are no longer clients for tax purposes.
In certain circumstances, we may anonymize your personal data (so that it can no longer be associated with you) for scientific, historical or statistical research purposes, in which case we may use this information indefinitely without prior notice to you.
Please note that in certain expressly regulated situations, we store data for the period required by law.
12. Storage of data provided
The personal data you provide us with and that we process is processed in the EEA ("European Economic Area") and stored on servers in Europe. However, this data may be processed by non-EEA staff working for us or for one of our business partners or service providers who are covered by the EU-US Privacy Shield.
A full list of third party sub-authorities and details of their privacy policies can be found on our website when they become available.
Some countries outside the EEA may not offer the same level of adequate protection of your rights and freedoms with regard to the processing of personal data; however, by using our services, you consent to your personal data being disclosed by the Company to third parties.
Please contact us if you would like more details about the specific safeguards applied to the transfer of your personal information outside the EEA.
13. Purpose of processing
The company uses the information you provide to give you access to:
our current products and offers;
information on the Company's activity
marketing campaigns run by the Company;
various promotional offers run by the Company on a regular basis or at certain times;
various campaigns that we believe you would at some point be reasonably interested in given your history with the Company;
For the proper performance of these services, the Company may also use the information provided for other purposes such as billing, statistics, research & development, etc. To the extent that the Company considers that the information provided may be used for purposes other than those mentioned above, it will immediately inform users about this.
14. What do we rely on when we process your data?
14.1 Data processing is necessary to provide the services you request
The company must collect and use certain information to provide services. These include:
user profile information for participation in promotions and contests, necessary to create and maintain the account, including to confirm identity and to make or receive payments;
information about Customers or Users (for promotional purposes) in the case of participation in events organized by the Company, where photographs and video recordings may be taken of the participants/people present at the event, regardless of their quality. The Company reserves the right to use such data for further promotion of other events/current promotional activity of the Company to show others how past events have been, with the aim of increasing interest in future events;
information about transactions and cases entered into the platform, which must be generated and maintained in relation to how the user interacts with the products and services they receive;
* information about the use of the Company's services, necessary to maintain, optimize and improve the services.
14.2 Processing is necessary for the legitimate interests of the Company
The Company collects and uses personal information to the extent necessary to fulfill its legitimate interests. This includes the collection and use of information:
to maintain and improve user safety and security;
to prevent, detect and combat fraud that may be related to the use of our services;
to provide customer support services;
to optimise the service offered and develop new services;
for research, development and analysis purposes (including analysing usage trends to improve user experience and offer new services)
to establish the marketing and communication strategy;
to carry out any promotions, contests or campaigns.
14.3 The processing is necessary to fulfil the Company's legal obligations
The company is subject to the applicable law of the jurisdiction in which it operates, and certain personal data will need to be processed in accordance with these regulations (e.g. obligations to maintain financial and accounting records, employment documents, complaint resolution information, etc.).
There may also be situations in which the Company has to transmit your personal data to the competent bodies and authorities when they are requested to do so in order to resolve or prevent disputes.
14.4 Other grounds
The company uses different processing grounds for the data provided by you in order to provide you with the services. These are:
Data element: Name, first name, e-mail address, phone number
Basis of processing: Article 6 para. (1) lit. b GDPR - to fulfill the contract you enter into with us remotely when you create an account on the Site when you want to benefit from one of our products or services.
Data element: Name, surname, transaction, date, location
Basis of processing: Article 6 para. (1) lit. b GDPR - by virtue of your contract with us, either remotely or by location, for the purpose of collecting feedback from you regarding your experience and resolving any complaints you bring to our attention.
Data element: Billing dates
Basis of processing: Article 6 para. (1) lit. b GDPR - in order to comply with a legal obligation under applicable law.
Data element: Delivery details (name, surname, address, telephone)
Basis of processing: To be able to send you the products ordered or the materials included in certain online programs you purchase, as well as the prizes obtained during various promotional campaigns run by us.
Data element: Promotional & marketing activities
Basis of processing: Article 6 para. (1) lit. a) GDPR - consent - in the case of direct marketing, if you do not wish to receive information and newsletters regarding our activity and services offered, you can always withdraw your consent.
Article 6 para. (1) lit. f) GDPR - legitimate interest - to promote our services and products offered for which you can always withdraw your consent.
Data element: Credit card data, exchanges of information between users, etc.
Basis of processing: Article 6 para. (1) lit. f) GDPR - legitimate interest - we may use this and similar data to improve the services offered, complete the transaction process, identify and resolve user problems, etc.
Data element: Images: stills and ambient video; stills and close-up/portrait video (including testimonials)
Basis of processing: Article 6 para. (1) lit. f) GDPR - legitimate interest - we may use this data for marketing activities, advertising on digital channels to promote the Company's brand on social networks and other online platforms.
15. Data belonging to minors
The company does not, in its data processing activities, process personal data of minors under 18 years of age. Special care is taken to ensure that any processing of personal data of minors is carried out in accordance with legal requirements and in strictly defined cases.
The company does not carry out direct marketing promotional activities towards minors. Minors who have not reached the age of 18 are not allowed to request services, nor to communicate on the Company's Website nor to participate in contests, events or campaigns of the Company, unless this is done on behalf of the minor by the legal representative or guardian of the minor in question, according to the law.
Minors under the age of 18 may purchase products or services and request and receive communications from the Company only if they have the consent of their legal representative or guardian, as required by law.
In addition, any person who provides us with personal data through the Sites or other applications or devices covered by this Policy warrants that he or she is of legal age or full legal capacity.
Any collection or processing of personal data of minors will be carried out only under the conditions of the law and taking into account the above.
16. Your rights
Under the GDPR, you have a number of rights regarding your personal data:
Right conferred: Right to withdraw consent
Additional information: It is valid when the processing was based on your consent and there is no other basis for processing. Please note that withdrawal of consent does not affect the processing that has taken place up to this point.
Right conferred: The right to be informed about the processing of your data
Additional information: This is achieved through this policy/information note.
Right conferred: Right of access
Additional information: You have the right to ask us for information about the personal data we process about you. We will try, as far as possible, to provide you with information about your data in a clear, accessible, structured manner. In order to do this, we will need to be sure that the data relates to you, so we will identify you by providing you with a copy of your identity card.
Additional copies can be provided for a fee.
Right conferred: Right of rectification
Additional information: Your data should always be up-to-date and complete. Although we make every effort to ensure that the data provided is always accurate, we will need your help. If you discover that your data is not correct, that changes have occurred or that you would like to add something, you can send us a request asking us to rectify that data, whether we are talking about an update, modification or addition.
Right conferred: The right to erasure/the right "to be forgotten"
Additional information: You can ask us to delete your personal data in the following cases:
personal data are no longer necessary for the purposes for which they were collected or processed;
you withdraw your consent on the basis of which the processing takes place;
you object to processing when the processing of personal data is for direct marketing purposes;
personal data have been unlawfully processed;
personal data must be deleted to comply with a legal obligation.
data have been processed from a minor without the consent of the parents, guardian or legal representative.
Users can request the deletion of their account at any time. Following such a request, the Company will delete the information that no longer needs to be kept and will restrict access or use of any information that still needs to be kept.
Right conferred: Right to restriction of processing
Additional information: You can ask us to restrict the processing of your personal data in the following cases:
you dispute the accuracy of your personal data, but for a period that allows us to verify the accuracy of the data;
the processing is unlawful and you do not agree to the deletion of your personal data, but you ask us to restrict the processing instead;
we no longer need your personal data, but you ask us for them to establish, exercise or defend a right in court;
you object to the processing of your personal data, when the processing of personal data is for direct marketing purposes, for the period of time during which it is verified whether our legitimate rights prevail over your rights.
Right conferred: Right to data portability
Additional information: You can ask us to transmit your personal data that you have provided to us in a structured, commonly used and machine-readable format and you have the right to transmit this data to another controller in the following cases:
processing is based on consent;
processing is carried out by automatic means.
Right conferred: The right to opposition
Additional information: You have the right to object to processing when:
the processing is necessary for the performance of a task carried out in the public interest,
processing is necessary for the purposes of legitimate interests pursued by us or a third party, including profiling on the basis of such provisions.
In such a case, we will no longer process your personal data, unless we demonstrate that we have compelling legitimate grounds for processing which override your interests, rights and freedoms or that the purpose is to establish, exercise or defend a legal claim.
Right conferred: The right to object to automated individual decision-making, including profiling
Additional information: You have the right not to be subject to a decision based solely on automatic processing, including profiling, which produces legal effects concerning you or which similarly affects you to a significant extent.
These rights have certain limitations, namely:
the automatic decision is necessary for the conclusion or execution of a contract between you and us;
the decision is authorized according to legal rules;
we have your explicit consent to do so.
In such a case, you can send us a request for your personal data to undergo manual processing.
Please note that:
You can withdraw your consent to direct marketing at any time by following the unsubscribe instructions in each email/sms or other electronic message.
if you wish to exercise your rights, you may do so by sending a written, signed and dated request to the following e-mail address: or by any other means made available to you by the Company and outlined in this Policy.
the rights listed above are not absolute. There are exceptions, therefore each request received will be examined in order to decide whether it is justified or not. To the extent that the request is justified, we will facilitate the exercise of your rights. If the request is unfounded, we will reject it, but we will inform you of the reasons for the refusal and of your rights to lodge a complaint with the Supervisory Authority and to go to court.
we will try to respond to your request within 30 days. However, the deadline may be extended depending on various aspects, such as the complexity of the request, the large number of requests received or the impossibility of identifying you within a reasonable time.
we may in some cases have to charge a fee for exercising our rights, especially when we consider it to be unjustified. In this case, we will inform you within the legal time limit about the necessity of paying the fee and we will proceed to solve the request only after this fee has been paid.
we may not be able to provide the requested information in some cases because it would involve "mixed data", i.e. personal data belonging to other people that we cannot reasonably and effectively keep confidential. In such a case we will inform you within the legal time limit, including that you may lodge a complaint with the competent authority.
If, despite our best efforts, we are unable to identify you and you do not provide us with additional information to identify you, we are not obliged to comply with your request.
17. Complaints
If you want your personal data to be accessed, updated, rectified or deleted in certain circumstances (for example, when the personal data is no longer needed for the purposes mentioned above), if you want to request the restriction of data processing in certain circumstances (for example, when you dispute the accuracy of the data - for a period that would allow us to verify the accuracy of the data in question); if you wish to lodge a complaint with us, if you wish to object to the processing of your data and wish, at any time, to withdraw your consent to the processing of your personal data that you have previously given, you may notify us at any time by means of a written request, dated and signed, to the following e-mail address: hello@gabroelvip.com.
To exercise these rights, as well as for any additional questions regarding this notice or the Company's use of personal data, please contact us by choosing any of the communication methods described above, also specifying your full name, postal or email address (depending on how you wish to communicate), your telephone number and the purpose of your request.
We will make every effort to resolve your request as soon as possible
You can also lodge a complaint with the personal data supervisory authority. For Romania, contact details are below:
Name: National Supervisory Authority for Personal Data Processing:
Address: B-dul G-ral. Gheorghe Magheru nr. 28-30, Sector 1, postal code 010336, Bucuresti, Romania
Phone: +40.318.059.211 or +40.318.059.212
E-mail: anspdcp@dataprotection.ro
18. Changes to this policy/information notice
We may occasionally update this policy/notice and will notify you via the platform and/or email of the latest version. All updates and changes to this Notice are effective immediately upon notification, which we will make by posting on the Site and/or email notification. Even if you do not receive a notification, we encourage you to periodically access and read this Notice to keep up to date with the latest versions.
This document was last updated on 12.03.2025.
