- Personal data controller
The operator of personal data obtained from customers or provided by them in the process of authentication and order processing is: S.C. Best Alternative Technologies SRL. You can contact us by e-mail at: office@smarttabbyboo.com.
Throughout this Policy, the Personal Data Controller will be referred to as “SMART TabbyBoo” or the “Company”.
- General
The need to retain personal data varies depending on the type of data being processed within the company. Some data can be deleted immediately, others need to be stored until such time as their future usefulness is no longer a possibility.
There are cases where personal data is stored for a limited period of time, the storage periods being imposed by the legal regulations in force, applicable at national or European Union level.
In other cases, the storage periods must be established by each organization, depending on its activity, taking into account the data processing principles laid down in EU Regulation 679/2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data (known by the acronym “GDPR”). As the company’s determination of personal data processing and retention periods can be a somewhat subjective undertaking, the implementation of a Retention Policy is important to ensure that the rules implemented at the company level regarding data storage are consistently applied throughout the organization.
In any case, the provisions of the GDPR and Law 190/2018 on measures to implement the General Data Protection Regulation will be complied with by the company in the storage of personal data processed.
- Storage policy
The scope of this Policy covers all company data, i.e. data stored in the company’s information systems, data provided by the company in the media, data rented or derived from collaborations and contractual partnerships, regardless of the location (company headquarters or point of work) where such data is processed.
The SMART TabbyBoo Storage Policy is a tool that provides assurance that the requirements of the GDPR, relevant laws and regulations in the field of personal data protection are respected. This Policy, mainly refers to the principle of limiting the retention over time of the personal data processed and which entails storing it only for a period of time necessary for the purposes for which the data is processed. The Personal Data Storage (Retention) Policy is primarily intended as a business-friendly resource that will allocate relevant retention periods in all areas of activity and departments of the company, allowing the carrying out of personal data deletion/removal activities in a consistent and controlled manner.
- Requests regarding the Personal Data Retention Policy
This Policy is applicable to natural persons as customers of SMART TabbyBoo, legal entities as customers, but also to the representatives of our contractual partners, both as Personal Data Controllers in relation with SMART TabbyBoo or as Persons authorized by the Controller, according to the General Data Protection Regulation.
We store and process personal data only in cases where you have voluntarily provided this data to us, such as by filling in a contact form, by subscribing to the company newsletter or by creating an account and placing an order.
To the extent that you have requests or questions regarding the storage periods of your personal data within SMART TabbyBoo, please contact the company, using the e-mail address mentioned above.
- The reasons for long-term storage of personal data in SMART TabbyBoo
The company does not propose to adopt a “save everything” approach. We believe that such a rule is not practical or cost-effective and would place an undue burden on all company staff and in particular on the IT department which would be managing an increasing amount of data. However, certain data needs to be kept on a long-term basis to protect the company’s interests, to save evidence of processing or erasure in accordance with the law and this Policy of the personal data processed, if SMART TabbyBoo deems it necessary, and in general to comply with good business practices. Some of the most important reasons for long-term storage of data within SMART TabbyBoo, are the following:
- Complaints about the quality of the company’s services;
- Litigation;
- Investigating accidents at work;
- Security incident investigation;
- Legal regulations;
- Security of intellectual property.
- Retention (storage) periods
Personal data storage periods are specified in the table below and apply to all record formats, i.e. paper and/or electronic, unless otherwise specified in this Policy.
DEPARTMENT | PROCESSING ACTIVITY | RETENTION PERIOD |
Marketing | Electronic campaign forms | 3 years from the date of completion of the original |
Marketing | Documents evidencing winnings or prizes awarded on the basis of competitions and lottery draws | 10 years from the date of their conclusion |
Marketing | Telephone calls for marketing purposes | 30 days |
Marketing | Information about participating in prize competitions
| 5 years from the date of completion of the competition |
Customer Relations | E-mail received from the customer with a suggestion or complaint | 3 years from the date of receipt in electronic format |
Customer Relations | E-mail received from the client for requests related to the company’s commercial activity | 3 years from the date of receipt in electronic format |
Customer Relations | E-mail received from the customer for inquiries related to personal data processing activities within the company | 3 years from the date of receipt, both in physical and electronic format |
Customer Relations | The Customer Relations Department database which includes any general enquiries from customers | Deleting data every 3 years |
Logistics | AWB (Airway Bill) and documents that accompany the shipment of goods from the warehouse to the customer (delivery order) | 5 years |
Logistics | AWB (Airway Bill) and documents that accompany the shipment of goods from the warehouse to the customer (delivery order
| 5 years |
Business Relations | Contracts concluded by the company with suppliers | 10 years from the date of termination of the contract |
Business Relations | Partnership contracts signed by the company for commercial promotional events organized by the company | 10 years from the date of termination of the contract |
Business Relations | Business cards collected during business meetings | 1 year from the date of last contact |
Business to Business (B2B) | Personal data, such as: name, position and contact details of the representatives of the companies we work with | Until the date of the request for deletion or until the date on which we became aware that the data became inactive |
