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Privacy Policy

1. About Coral Club

Coral Club Distribution LTD, located at Agapinos Street 52, 2nd Floor, Office/Apartment 1, 8049 Paphos, Cyprus (herein the “Controller”), acts as the controller of personal data in accordance with its business objectives, procedures, and commercial activities. The Controller complies with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (the “Regulation”) and assumes all obligations applicable to a personal data controller.

Definitions. For the purposes of this Policy, the terms listed below are defined as follows:

- Personal Data — any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person;

- Processing — any operation or set of operations performed on Personal Data, whether automated or not, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;

- Storage — the retention of collected Personal Data on any medium;

- Personal Data File — any organized set of Personal Data accessible according to specific criteria, whether centralized, decentralized, or dispersed functionally or geographically;

- Controller — a private legal entity that determines the purposes and means of the processing of Personal Data;

- Authorized Processor — a natural or legal person, public or private, including state authorities, institutions, and their territorial units, which processes Personal Data on behalf of the Controller;

- Third Party — any natural or legal person, public or private, including state authorities, institutions, and their territorial units, other than the Data Subject, the Controller, or the Authorized Processor, and any person acting under the direct authority of the Controller or Authorized Processor and authorized to process data;

- Recipient — any natural or legal person, public or private, including state authorities, institutions, and their territorial units, to whom Personal Data are disclosed, regardless of whether they are a Third Party; public authorities to whom data are transferred in the context of specific investigative powers are not considered Recipients;

- Anonymous Data — data that, by their origin or specific processing method, cannot be linked to an identified or identifiable natural person.

- “Privacy Shield” — refers to the principles established by the European Commission’s Decision of 12 July 2016, enabling the transfer of Personal Data between an EU Member State and a company headquartered in the United States of America.

Coral Club is committed to safeguarding Personal Data. Therefore, the Company collects and processes Personal Data only to the extent necessary to provide its products, services, websites, and mobile applications (collectively referred to as “Services”).

The types of Personal Data collected include full name, address, phone number, and email address. — Special categories of Personal Data may include personal identification codes and the series and number of identity documents. Processing Duration and Data Location Personal Data will be processed for as long as necessary to deliver our products and services. Personal Data will be stored in an identifiable form for no longer than is necessary to achieve the purposes for which they were collected. Personal Data may be retained for longer periods if processed solely for archiving purposes in the public interest, or for scientific, historical, or statistical purposes in accordance with Article 89(1) of the Regulation, provided appropriate technical and organizational measures are implemented to safeguard the rights and freedoms of the Data Subject (“storage limitation”). The Controller processes the above Personal Data at the following locations:

- Workplace at 5 Vrâncioaia Street, Basement Floor, District 1, Bucharest;

- Workplace at 109 Zizinului Street, Brașov

The Controller processes Personal Data on the basis of contractual necessity or the Data Subject’s consent. The purpose of processing is to provide the Services. This Privacy Policy is designed to inform you about the Personal Data we collect, how we use it, and the rights available to you to access, update, or manage your data.The Company ensures that all authorized personnel (including subcontractors and employees) process Personal Data under strict confidentiality obligations and in accordance with applicable legal requirements. If you have questions regarding our practices or any of your rights outlined below, please contact our Data Protection Officer and team at our Bucharest office via email: mailto:ro.dataprotection@coral-club.com. This mailbox is actively monitored to ensure a responsive and reliable experience. Additionally, we have established a Privacy Center, where you will find answers to frequently asked questions, quick links to your account settings, instructions for exercising your rights, and definitions of key terms used in this Privacy Policy.

2. What Data Do We Collect?

We collect only the data necessary to provide you with our Services effectively. Most of the data you consider personal is collected directly from you when you:

- create an account on our website or purchase any of our products or Services (e.g., billing information including name, address, credit card details, identity document information);

- contact our customer support team (e.g., phone number);

- complete a feedback form, subscribe to our newsletter, or request additional information from us (e.g., email address);

- participate in contests, surveys, or other activities we conduct, where information about you may be required.

In all cases, we also collect additional information during the provision of Services to ensure optimal performance. These collection methods may not always be obvious to you; therefore, we detail below the specific methods we use (which may evolve over time) and how they function:

Account Information is collected in connection with your use of our Services, including your member number, purchased products, dates of product upgrades or expiration, information requests, support interactions, notes explaining your request, and our response.

The User of the Services remains the owner of the processed Personal Data.

Cookies and Similar Technologies on our websites and mobile applications enable us to track your navigation behavior, referral sources, purchased items, device type, and collect various data, including analytics, on how you interact with our Services. This allows us to offer you more relevant product recommendations, improve navigation on our websites and apps, and analyze and enhance the performance of our Services. We may also collect location data (via IP address) to personalize our Services. For more information on how to manage the technologies we use, please visit our https://ro.coral-club.com/userguide/privacy.php#1.

Usage Information is automatically collected when you use or interact with our Services, including metadata, logs, cookies/device identifiers, and location data. This includes specific details about your interactions with features, content, and links (including third-party elements such as social plugins) within the Services, your IP address, browser type and settings, date and duration of Service usage, browser and plugin settings, language preferences, cookie data, device information (including device type, operating system, device settings, app identifiers, unique device identifiers, and error reports). Some of this data may be used or combined to approximate your location.

3. How Do We Use Your Information?

We strictly adhere to the principles of data minimization and purpose limitation. Therefore, collected data is used exclusively for the following purposes:

- (1) for purposes for which you have provided consent;

- (2) to provide you with the products or Services you have purchased or are using;

- (3) to comply with applicable law and for other lawful purposes.

These purposes include: Providing, improving, updating, and developing the Services offered to you. We collect various data regarding your purchases, usage, and/or interactions with our products or Services. We use this information to:

- Improve and optimize the functionality and performance of our Services (including websites and mobile applications);

- Diagnose issues and identify security risks, errors, or necessary enhancements to our Services;

- Detect and prevent fraud and abuse targeting our Services or systems;

- Collect aggregated statistical data regarding Service usage;

- Understand and analyze how you use our Services and identify the most relevant products and services for you.

Often, a significant portion of collected data is aggregated to generate statistical insights about customer interactions with our Services and is not tied to any individual Personal Data. Where such data is linked or closely associated with Personal Data, we process it accordingly.

Consistent with the above, the Controller (including subcontractors) undertakes to comply with the following principles, namely:

- Data will be processed lawfully, fairly, and transparently;

- Personal Data will be collected only for specified, explicit, and legitimate purposes;

- Personal Data will be adequate, relevant, and limited to what is necessary for the purposes for which they are processed;

- Data will be retained in identifiable form for no longer than is necessary to achieve the purposes for which they are processed;

- Processing will be conducted in a manner that ensures appropriate security of the data, including protection against unauthorized or unlawful processing, loss, destruction, or damage, with regular review and updating of safeguards;

- Active record-keeping of all Personal Data processing activities will be maintained.

Sharing Data with Trusted Third Parties. We may disclose your Personal Data to affiliated companies within our corporate group, third parties with whom we have partnership agreements to integrate their services into our Services, and external service providers, to the extent necessary to deliver our Services, including:

- Processing payments via credit cards;

- Advertising services;

- Organizing contests and surveys;

- Analyzing our Services and customer demographics;

- Maintaining customer relationships via email or conducting surveys;

- Customer relationship management.

We share your Personal Data with third parties only when necessary to deliver the Services and only after obtaining your consent. These third parties are contractually obligated to adhere to strict data handling conditions and may not use, disclose, or store your data for any purpose other than those for which they were engaged (or without your prior consent).

Communication with You. We may contact you directly or through a third-party service provider regarding purchased or subscribed Services to provide transactional or service-related information. We may also contact you to inform you of additional services we believe may be of interest to you, provided you have given consent or where permitted under legitimate interests. Consent for such communications is not a condition of purchasing our products or services. Possible communication channels include:

- Email;

- Text messages (SMS);

- Phone calls;

- Automated voice calls or text messages.

You may update your communication preferences or opt out of marketing messages from us or our partners via your Account Settings.

If we collect information from you in connection with a joint offer, it will be clearly indicated at the point of collection which company is collecting the data and which Privacy Policy applies. The policy will also describe your available choices regarding the use and/or joint sharing of your Personal Data with the co-branding partner, along with instructions for exercising those choices.

If you use a service that allows you to import contacts (e.g., marketing tools for sending emails on your behalf), we use those contacts and other Personal Data solely to deliver the requested service. If you believe someone has provided us with your Personal Data and you wish for it to be deleted from our database, please contact us at mailto:ro.dataprotection@coral-club.com.

International Data Transfers. If you use our Services from a country different from where our servers are located, your Personal Data may be transferred across national borders. Additionally, if you contact us via phone or chat, we may assist you through our international support centers located in countries other than your country of residence. In such cases, your Personal Data will be processed in accordance with this Privacy Policy.

Compliance with Legal Requests, Regulatory Authorities, and Law Enforcement. We cooperate with governments, agencies, institutions, and private parties to comply with laws and ensure their enforcement. We may disclose your information to governmental or private entities if, in our sole discretion, we believe it is necessary or appropriate to respond to subpoenas, court orders, to protect our rights or property or the rights of third parties, to ensure public or personal safety, or to prevent or investigate activities we deem unlawful or unethical.

To the extent permitted by law, we will make reasonable efforts to notify you if we receive a legal request to disclose your Personal Data in connection with a judicial proceeding.

Website Analytics. We use various web analytics tools provided by partners such as Google Analytics, Mixpanel, and Singular to collect information about your interaction with our website or mobile applications, including the pages you visit, the site you came from, time spent on our pages, your operating system and web browser, and network and IP address information. Data collected via these tools is used to improve our Services. These tools store persistent cookies in your browser to identify you during subsequent visits to our site. Each cookie may be used only by its respective service provider (e.g., Google for Google Analytics). The information collected via cookies may be transmitted to and stored on the partner’s servers in a country different from your own. Although the collected information does not include Personal Data such as name, address, or payment details, it is used and shared by these service providers in accordance with their individual Privacy Policies. You may manage the technologies we use via settings available on our https://ro.coral-club.com/userguide/privacy.php#1 page, through “cookie banners” displayed upon your first visit to a website (depending on the URL), or via your browser settings or other methods.

Targeted Advertising. Targeted ads or interest-based offers may be displayed based on your activity on our web pages and other websites, as well as on products you currently own. These offers appear as banners distinct from the products shown during navigation. Additionally, we partner with third parties to manage advertising on our websites and other sites. Our partners may use various technologies, such as cookies, to collect information about your activities and display ads based on your interests and browsing history, as well as to measure ad effectiveness. If you do not wish to receive interest-based advertising, please click https://ro.coral-club.com/unsubscribe.php. If you are located in the European Union, please click https://ro.coral-club.com/unsubscribe.php. Note that you will still receive general, non-targeted advertising.

Other Websites. Our website and mobile applications may contain links to other websites. We are not responsible for the privacy policies or content of these external sites and encourage you to review the privacy statements of each website you visit.

On the website, each User has access to information regarding products purchased within the last six months, to enable high-quality assistance and consultation. Access to this information can be enabled via the “Online Office” feature through appropriate settings. With consent to display personal order information, the User grants other Users within their upline structure access to the following data:

- Order number,

- Order date,

- Reporting month in which the order was placed,

- Order type,

- Country where the order was placed,

- Bonus points,

- Order value in local currency,

- Order contents: product code and name, quantity, bonus points, and price per product.

The User independently decides whether to grant other Users access to their data. Upon activating access to order information, the data becomes accessible to other Users. It is important to understand that once consent is granted in the “Online Office,” the User assumes full responsibility for sharing data with third parties. The website administration is not liable for actions taken by other Users.

4. How You Can Access, Update, or Delete Your Data

To access, view, update, delete, or export your Personal Data (if applicable), or to modify your subscription preferences, simply log in to your account and navigate to “Account Settings.” For further information and instructions on accessing, modifying, or deleting your data, please visit our Privacy Center.

If you request the deletion of your Personal Data that is necessary for purchasing products or services, the request will be fulfilled only to the extent that it does not impede the continued provision of services, our lawful business operations, or compliance with legal or contractual obligations for record-keeping. Additionally, you are responsible for notifying the Controller of any inaccurate, corrected, or updated Personal Data by sending a notification to: mailto:ro.dataprotection@coral-club.com

If, for any reason, you are unable to access the “Account Settings” option or the Privacy Center, you may contact us by any of the methods listed under “Contact Us” below.

5. How We Protect and Store Your Data

We adhere to industry-standard security measures to protect collected Personal Data during transmission, receipt, and storage, including encryption where appropriate.

We retain Personal Data for as long as necessary to provide the Services you requested, and thereafter for purposes justified by legal and legitimate business interests. Retention periods may include:

- Periods required by law, contract, or other applicable regulatory requirements;

- Periods necessary for record-keeping, authorization, protection, or enforcement of our rights under law or contract;

- Periods necessary to ensure accurate and complete documentation of administrative and financial operations.

If you have questions regarding the security or storage of your Personal Data, please contact us at mailto:ro.dataprotection@coral-club.com.

Each registered User has access to enhanced information regarding purchased products. When this feature is activated, it leverages the experience of other Users regarding purchased products. By subscribing to enhanced information, the User consents to the sharing of data regarding their purchased products.

If the User explicitly consents by selecting the appropriate setting in their personal account settings to access enhanced product information, access to the User’s data may be granted to other Users. The following data may be shared:

- Contact details: email address, mobile phone number,

- Number of days until status change,

- List of Coral Club events the member has registered for,

- Instant messaging platforms for quick communication: Skype, Telegram, WhatsApp, Viber,

- Purchase list for the current month, purchase history for the last six months.

By using the enhanced product information resource, Users may share their opinions on specific products. It is important to understand that such opinions are purely individual and subjective; therefore, when using a product, we strongly recommend you follow the instructions provided on the packaging.

After using a purchased product, the User may share their impressions with others.

The provided feature is solely a platform for Users to exchange opinions on specific products. Please note that Users are neither employees nor partners of the Company. Once consent is granted for access to this resource, the Company assumes no liability for how other Users may use the data. Any communication with website administrators relates exclusively to access to the enhanced information feature.

If you do not wish for the data used in the enhanced product information feature to be accessible to other Users, decline this option. In this case, do not use the platform — review your consent in the “Online Office” and make the appropriate changes.

6. “Do Not Track” Notices

Some browsers allow you to automatically notify websites you visit not to track you via a “Do Not Track” setting. Industry-wide standards for processing such signals have not yet been established. Like many other websites and web services, we currently do not respond to “Do Not Track” signals received from visitors’ browsers. For additional information about “Do Not Track,” please visit http://www.allaboutdnt.com/.

7. Age Restrictions

Our Services may only be purchased by individuals who are 18 years of age or older. The Services are not intended for, nor directed at, minors (individuals under 18). If you know or have reason to believe that a minor has provided you with their Personal Data, please contact us immediately.

8. Data Protection Authority

If you reside in the European Economic Area (EEA) and believe we are processing your Personal Data under the General Data Protection Regulation (GDPR), you may submit inquiries or complaints to the National Authority for Supervision of Personal Data Processing (NASPDP):

- 28-30 General George Magheru Boulevard, District 1, Bucharest, Email: mailto:anspdcp@dataprotection.ro or Phone: tel:+40318059211, Phone: tel:+40318059212.

9. Contact Us

If you have questions or concerns regarding our Privacy Policy, practices, or Services, you may contact our Data Protection Officer via email: mailto:ro.dataprotection@coral-club.com. You may also contact us by the following means:

- Phone: tel:+40314107114,

- Email: mailto:ro.dataprotection@coral-club.com.

We respond to all inquiries within 30 days.

10. Additional Information

We use cookies on our websites to collect and store small fragments of data as small text files on your device, to enhance your navigation experience according to your preferences. Our cookies do not store any Personal Data. We use them solely to identify your device and collect navigation data (e.g., previously visited pages on our site, your IP address).

A “cookie” is a small text file stored on the user’s computer for reporting purposes. This file is used when you request access to a website to identify you and facilitate easier navigation.

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