PRIVACY POLICY ON THE PROTECTION AND PROCESSING OF PERSONAL DATA

The information provided below gives you an overview of our approach to processing your personal data and of your rights under the provisions of data protection legislation.

Controller's details

Categories of personal data

For the purposes of Processing mentioned in point II below, we process your personal data provided through our website — hereinafter referred to as "Personal Data" — as follows:

First name, last name, date of birth, mobile phone number, e-mail address (hereinafter "Personal Data");
Order number, type of products ordered, payment information (hereinafter "Order Data");
The content of the comment submitted and its subject, the content of documents attached and sent to Linella, information submitted by customers as part of surveys (hereinafter "Communication Data");
Information regarding your use of the user account and the Site, such as the date and time you accessed the Website, including your public IP address, public Device ID, and similar data about you (hereinafter "Monitoring Data"). Moldretail Group SRL collects Personal Data in the following ways: directly from you (provided on the site, by e-mail, on social networks, or through other means of communication), from traffic reports recorded by the servers hosting the site, from social networks, as well as through cookies or from third-party partners who provide us with data for the purpose of delivering products to you (e.g. online sales platforms).

Purposes of Processing

We process your personal data to the extent permitted or required by applicable law for the following purposes:

These activities may include:

to supply the goods and services offered by Linella, including the actions specific to this activity, including enabling optimal use of the Site and obtaining statistical information for the purpose of improving Linella's services or conducting surveys about Linella's products and services (hereinafter "Purposes related to the provision of services and the operation of the Site");
for the secure administration of Moldretail Group SRL's information system and for the purpose of preventing criminal activity (hereinafter "Purposes related to security and fraud prevention");
to enable customers to create an account on our Site, place orders online, and purchase products from the Linella online store. We use the information you provide us to manage the account created on our Site. You can manage your account, take advantage of special offers, shop more easily, and manage your personal settings (hereinafter "Purposes related to the online supermarket");
to enable customers to submit suggestions and complaints regarding the services offered by Linella (hereinafter "Purposes related to customer suggestions and complaints");
to enable suppliers to offer their opinions and comments regarding Linella's activity, or to propose collaboration ideas or submit offers to Linella (hereinafter "Purposes related to suppliers");
to enable contacting and managing the contracting of Linella's potential expansion partners (hereinafter "Purposes related to expansion partners");
to carry out marketing activities (hereinafter "Purposes related to marketing");
Using your personal data to send you news about our products and services when you purchase a product from the online supermarket or when you set up a user account. You can unsubscribe from these marketing communications at any time, quickly and easily. You only need to (i) click the "Unsubscribe" link included in each newsletter, on the web page that then opens.
Based on the information you provide us, you may be shown personalized offers on the Site (including on social networks). These may be offers you can benefit from directly on the Site, offers from third parties, or products we believe may interest you.
When you take part in other promotional activities (raffles, contests), you may be asked to provide relevant information that will be used to administer these promotions or to award the prizes granted.
Use of your phone number by Linella or one of its authorized representatives to contact you for the purpose of improving our services or those of our subcontractors/partners (e.g. in the case of surveys regarding your interaction with the representatives/agents of Moldretail Group SRL)
Use of your purchase history on the website www.linella.md to display relevant offers on the website www.linella.md, when you browse the site using your personal account on www.linella.md.
In order to be able to grant you personalized offers under the Loyalty Program, should you enroll in this program in accordance with chapter 17 of the Terms and Conditions ("Purposes related to the loyalty program"), we use your purchase history made with the loyalty card, in Linella stores and on the website www.linella.md. We will use the Personal Data, as provided by you to Linella, for the purposes mentioned in this Policy.

Legal basis for the Processing of your personal data

In general, the processing of Personal Data is necessary for carrying out the activity specific to the purposes of Processing.

In general, you are required to provide your Personal Data on a mandatory basis, except for limited situations where we inform you that certain information is optional. If you do not provide the data requested as mandatory, the process may be delayed or even become impossible. Please note that, in the case of the Loyalty Program, if you do not provide us with the personal data, or do not give your consent for profiling, we will not be able to offer you personalized offers or benefits.

In order to process your Personal Data, Linella relies on various legal grounds, as follows:

Consent:
1. We may rely on your consent to use your personal information for certain direct marketing purposes, consent being the legal basis for the collection, processing, and use of your Personal Data, as permitted by applicable law. You may withdraw your consent at any time by contacting us at the addresses provided at the end of this Privacy Policy or by accessing the Personalization page.
2. In addition, based on your consent, we keep a record of your purchase history in order to be able to display, once you have logged into your account, recommendations or offers relevant to you based on this history, and to carry out analyses enabling us to allocate/propose personalized recommendations, offers, or benefits within the Loyalty Program for cards validated online or physically in Linella stores. If you withdraw your consent to profiling using the Communication Preferences page, you will still benefit from all offers on the site (generally applicable), but these will no longer be displayed based on their relevance to you, and you will only be able to use the card in standard mode.

At the initial stage of the loyalty program, the data collected from you will have limited relevance for profiling purposes. As we collect more data on your purchase history, the relevance of the personalized offers or benefits we offer you will also improve.

Performance of a contract or steps taken with a view to concluding a contract:

Processing is necessary for the performance of the contract to which the data subject is a party, or in order to take steps at your request prior to entering into a contract between you and Linella (e.g., in the case of expansion partners, this refers to the collaboration agreement; in the case of customers, to the sale-purchase agreement; in the case of suppliers, to the supply agreement). For example, if you use our services to place an order online, we will use your Personal Data to fulfil our obligation to complete and manage that order in accordance with the contract we have with you. In addition, the Processing of your Personal Data may be necessary to take steps prior to the conclusion of a possible contract, where you are a potential partner and wish to contact us regarding possible business collaboration;

Legitimate interests:

We may use the information for our legitimate interests, such as providing the most suitable content on the Site, marketing, improving and promoting our products and services, as well as the content on our Site, and for administrative and fraud-detection purposes.

Legal obligations:

The processing of data is necessary for compliance with our legal obligations, such as obligations under accounting and tax legislation, or requests from public authorities.

PERSONAL DATA

Purposes of processing	Categories of Personal Data involved	Legal basis
Purposes related to the provision of services and the operation of the Site	Personal Data Communication Data	Consent of the data subject; Performance of a contract; Based on a legal obligation; or Based on legitimate interest.
Purposes related to security and fraud prevention	Personal Data Order Data Monitoring Data	Based on a legal obligation; or Based on legitimate interest. Performance of a contract; Based on a legal obligation; or
Purposes related to the online supermarket	Personal Data Order Data Monitoring Data	Based on a legal obligation; or Based on legitimate interest. Performance of a contract; Based on a legal obligation; or
Purposes related to customer suggestions and complaints	Personal Data Order Data Monitoring Data	Based on a legal obligation; or Based on legitimate interest. Performance of a contract; Based on a legal obligation; or
Purposes related to suppliers	Personal Data Order Data Monitoring Data	Based on a legal obligation; or Based on legitimate interest. Performance of a contract; Based on a legal obligation; or
Purposes related to expansion partners	Personal Data Order Data Monitoring Data	Based on a legal obligation; or Based on legitimate interest. Performance of a contract; Based on a legal obligation; or
Purposes related to marketing	Personal Data Order Data Monitoring Data	Based on a legal obligation; or Based on legitimate interest. Performance of a contract; Based on a legal obligation; or
Purposes related to the loyalty program, including the provision of	Personal Data Order Data Monitoring Data	Based on a legal obligation; or Based on legitimate interest. Performance of a contract; Based on a legal obligation; or

Retention periods

Personal Data processed for the purposes mentioned herein will be kept only as long as necessary, for the duration of your account and thereafter, during a transitional period (for example, to receive a response to your request, for the delivery of goods, or the issuance of invoices), or for any other longer period during which Linella has a legal obligation to archive Personal Data.

If legal proceedings are initiated, Personal Data may be kept until the end of such proceedings, including any appeal periods, and will then be deleted or archived in accordance with the provisions of applicable law.

In principle, we will keep your Personal Data for the period required or permitted by applicable law. Thereafter, we will remove/delete your Personal Data from our systems and records and/or take measures to anonymize it so that you can no longer be identified on its basis. In all cases, Personal Data contained in contracts, correspondence, and other identified documents may be subject to legal retention requirements, which generally require retention for up to 10 years. Any other Personal Data will generally be deleted within 6 months from the deletion of your user account or from its collection through the Site, except for Order Data, which may be kept for up to 3 years from the date of the transaction, or, as the case may be, for a period necessary to comply with legal obligations (including if we are required to do so by a court decision), or if necessary for reasons of security, fraud prevention, disputes, or abuse.

Security procedures

In accordance with European data protection legislation, we use reasonable procedures to prevent unauthorized access and inappropriate use of Personal Data.

We use appropriate systems and procedures to protect and secure the Personal Data you send us. We also use security procedures as well as technical and physical restrictions on accessing and using Personal Data on our servers. Only authorized personnel may access personal data while at work.

Your rights

If you have given your consent regarding certain Processing activities, you may withdraw that consent at any time, with effect for the future. Such withdrawal will not affect the lawfulness of Processing carried out prior to the withdrawal of consent.

Under the conditions provided by applicable law (GDPR), you have the following rights:

Right of access: You have the right to be informed, upon request, whether your Personal Data is being processed, and if so, to request access to it. This information includes, among other things, the purposes of Processing, the categories of Personal Data concerned, and the recipients or categories of recipients to whom your Personal Data has been or will be disclosed. You have the right to obtain a copy of the Personal Data being processed. For additional copies, we may charge a reasonable fee based on administrative costs.
Right to rectification: You have the right to obtain from us the rectification of inaccurate Personal Data concerning you. Depending on the purposes of Processing, you also have the right to have incomplete Personal Data completed, including by means of providing a supplementary statement.
Right to erasure ("right to be forgotten"): You have the right to request that we erase your Personal Data, by contacting Customer Relations by phone or by sending an e-mail to relatiiclienti@linella.md.
Right to restriction of processing: You have the right to request the restriction of the Processing of your Personal Data. In this case, the data in question will be marked and may only be processed by us for certain purposes.
Right to data portability: You have the right to receive the Personal Data you have provided to us in a structured, commonly used, and machine-readable format, and you have the right to transmit that data to another entity without objection from us.
Right to object: You have the right to object, on grounds relating to your particular situation, at any time, to the Processing of your Personal Data by us, and we may be required to no longer process your Personal Data. If you have the right to object and you exercise it, we will no longer process your Personal Data for that purpose. Exercising this right does not involve any cost. This right may be overridden in particular if the Processing of your Personal Data is necessary for formalities related to the conclusion of a contract or for the performance of a contract already concluded.

The rights mentioned above shall be exercised by submitting a request in writing, dated and signed, addressed to Linella at the postal address sos. Muncesti 121, Chisinau — for the attention of the Data Protection Officer. In the request, you may indicate whether you wish the information to be communicated to a specific address, which may also be an e-mail address, or through a courier service ensuring that delivery is made only to you personally. Please note that, before responding to any such request, we reserve the right to verify your identity, in order to ensure that the request genuinely comes from you.

Linella will provide the requested information within 30 days from the date of receipt of the request, in accordance with the manner of communication you have expressed.

Please note that the rights mentioned above may be limited under applicable national data protection legislation. Moldretail Group SRL, as data controller, remains the central point of contact for the exercise of these rights.

You also have the right to lodge a complaint with the National Authority for the Supervision of Personal Data Processing.

How do we process children's personal data?

The services offered by the website www.linella.md are not intended for minors.

Cookies

This section regarding Cookies applies to all users of this Site. By the term "cookies" we mean cookie files and similar technologies through which information may be collected automatically.

Cookies are used to provide you with a better browsing experience and services tailored to Customers' needs: improving navigation, including by identifying any errors that occur while users visit/use the site; anonymous statistics on how the Site is used; anticipating possible future services/products to be offered to users.

Cookies provide us with information about how this Site is used, so that we can improve the efficiency and accessibility of the Site for users.

The full list of third-party cookies is set out in the following table:

No.	Name (key)	Use and purpose	Retention period
1	s_cc	Adobe cookie that determines whether cookies are enabled in the browser	Session
2	s_fid	Adobe cookie that identifies the visitor. This cookie is associated with the analytics service provided by the Site Catalyst product suite. It is a cookie introduced in 2013 as a fallback visitor identifier, in case the s_vi cookie normally used for this purpose is blocked. It contains a unique, randomly generated ID.	5 years
3	s_ppn	Adobe cookie that stores information about the name of the previous page	Session
4	s_sq	Adobe cookie that stores information about the previous link clicked on the site	Session
5	s_vi_...	Stores the Adobe Analytics session ID called VisitorID. This ID is not the same as Mega Image's.	2 years

Disabling and refusing to accept cookies may make this website difficult to visit, resulting in limitations on your ability to use it.

Users can configure their browser to reject cookie files, or to accept cookies only from a specific website.

All modern browsers offer the option to change cookie settings. These settings can usually be found in the "options" section or "preferences" menu of your browser.

You also have the option of disabling cookies (except those strictly necessary for the operation of this website) as follows:

Types of cookies and their purpose:
Registration cookies
When you register on this site, cookies are generated that remember the registration.
Performance cookies:
This type of cookie stores the preferences of the user of this website, so that resetting preferences on a subsequent visit to the website is no longer necessary.
User analysis cookies
These cookies tell us whether a particular user of the website has visited/used this website before. These cookies are used for statistical purposes only.
Geotargeting cookies
These cookies are used by software that determines the country of origin of the website user. The same advertisements will be received regardless of the selected language.
Advertising cookies
These cookies allow us to find out whether you have viewed an online advertisement, its type, and the time elapsed since it was viewed. These cookies are anonymous and do not store data about users.
In addition to the cookies set by Mega Image, necessary for the proper functioning of the site, we use cookies set through certain third parties. Third-party cookie providers must also comply with data protection rules and the privacy policy available on this website.
Chrome
Firefox
Internet Explorer
Safari

Photographs, video recordings, and content submitted by you

At events, store openings, prize draws, and in stores, we take photographs and video recordings which we publish on the website, on Facebook, Instagram, YouTube, and TikTok, on Telegram channels, on television, and on local portals.

What we do	What data we use	Legal basis	How long we keep the data
Deliberate filming or photographing of identifiable persons, in close-up, and public distribution of the material	Image, voice, first and last name or an abbreviated form thereof, locality, statements	Your consent, requested before filming, Art. 6(1)(a); for persons under 18, the consent of their legal representative	For the duration of the material's use and 3 years from its withdrawal from our channels. Consents: same period. Unpublished materials: 6 months from the event
General images from stores and events, in which persons appear incidentally and not in close-up	Image, to the extent the person is visible	Legitimate interest in documenting and publicly communicating our activity, Art. 6(1)(f). Persons who are not the subject of the material are blurred during editing	For the duration of the material's use and 3 years from its withdrawal from our channels. Consents: same period. Unpublished materials: 6 months from the event
Registration for events and record of attendance; documentation of prize draws and publication of winners	Registration lists; minutes of the prize draws; names of winners	Performance of a contract, Art. 6(1)(b)	Registration lists: 1 year from the event. Prize draw documentation: 3 years
Use in our communications of photographs and video materials you send us, including in social media contests	Profile identifier, displayed name, materials submitted, contest participation	Your consent and the license granted, Art. 6(1)(a); for running the contest, performance of a contract, Art. 6(1)(b)	Unused materials: 1 year from submission. Materials used: for the duration of the license and 3 years from last use. Contest records: 3 years from completion

You may withdraw your consent at any time, by contacting us at our contact address; in that case we will remove the material from our channels and request its removal by any third parties who have taken it over, to the extent of our ability to do so.

10. Final provisions

Please address any questions to Linella at the postal address sos. Muncesti 121, Chisinau.

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