This Privacy Policy explains how CRM LEGACY S.R.L. ("CRM LEGACY", "SOLARA", "we", "us" or "our") collects, uses, stores and protects your personal data when you visit reservesolara.com (the "Website"), join our Reserve List, contact us, or place a reservation or order. We are committed to protecting your privacy and to handling your personal data in accordance with Regulation (EU) 2016/679 (the "GDPR") and Romanian Law no. 190/2018.
By using the Website or providing us with your personal data, you confirm that you have read and understood this Policy.
1. Who we are (the data controller)
The controller responsible for your personal data is:
- CRM LEGACY S.R.L.
- Registered office: Bulevardul Aviatorilor 18, camera 2, Bucharest, Romania
- Sole registration code (CUI): RO55120918 · Trade Register no.: J2026042826006
- Email: contact@reservesolara.com
For any question about this Policy or about how we handle your personal data, contact us at contact@reservesolara.com.
2. What personal data we collect
We collect the following categories of personal data:
- Identity and contact details — your name, email address and, where you provide it, your telephone number (for example, when you join the Reserve List or contact us).
- Reservation and order details — where reservations or orders are open, the products you reserve or buy, your billing and delivery address, and your order history.
- Payment information — where payments are taken, they are processed by our third-party payment providers. We do not store your full card details on our own systems.
- Communications — the content of messages you send us and our correspondence with you.
- Technical and usage data — information collected automatically when you use the Website, such as your IP address, device and browser type, and how you interact with the Website, gathered through cookies and similar technologies (see Section 5).
We only collect data that is necessary for the purposes described in this Policy. Where a field is marked as required, we need that information to provide the relevant service; anything else you share is optional.
3. How we use your data, and our legal basis
We process your personal data for the following purposes and on the following legal bases under Article 6 of the GDPR:
- Reserve List and marketing — to manage the Reserve List and send you news, launch announcements and offers about our coffee releases by email and, where you have given a number, by SMS. Legal basis: your consent (Art. 6(1)(a)). You may withdraw consent at any time (see Section 9).
- Reservations and orders — to process and fulfil your reservations and orders, take payment, arrange delivery and provide customer support. Legal basis: performance of a contract with you, or steps taken at your request before entering into one (Art. 6(1)(b)).
- Legal compliance — to meet our accounting, tax and consumer-protection obligations. Legal basis: compliance with a legal obligation (Art. 6(1)(c)).
- Running and protecting our business — to operate, secure and improve the Website, prevent fraud and misuse, understand how the Website is used, and respond to your enquiries. Legal basis: our legitimate interests (Art. 6(1)(f)), balanced against your rights. Where the law requires it, we rely on your consent for non-essential cookies (see Section 5).
4. Marketing communications
Where you have joined the Reserve List or otherwise consented, we will send you information about our releases and offers. Every marketing email contains an unsubscribe link, and you can opt out of email or SMS marketing at any time by contacting us at contact@reservesolara.com. Withdrawing consent does not affect the lawfulness of processing carried out before you withdrew it.
5. Cookies and similar technologies
The Website uses cookies and similar technologies to make it work, to remember your preferences, and to measure how it is used. Strictly necessary cookies are essential for the Website to function. Analytics and marketing cookies are used only where you have given consent through our cookie banner, and you can change your choices at any time. A separate Cookie Policy, where published, provides further detail.
6. Who we share your data with
We do not sell your personal data. We share it only with:
- Service providers acting on our behalf (processors) — including our website hosting provider, email and SMS platform, payment providers, delivery and courier partners, and analytics providers. They act only on our instructions and under a data-processing agreement.
- Advisers and authorities — professional advisers, and public authorities or courts where we are required to share data by law or to establish, exercise or defend legal claims.
7. International transfers
Some of our service providers may be located outside the European Economic Area (EEA). Where your personal data is transferred outside the EEA, we ensure an adequate level of protection, for example by relying on an adequacy decision of the European Commission, or on Standard Contractual Clauses approved by the European Commission, together with any additional safeguards required. You can request more information about these safeguards by contacting us.
8. How long we keep your data
We keep your personal data only for as long as necessary for the purposes set out in this Policy:
- Reserve List and marketing data — until you unsubscribe or withdraw your consent, or after an extended period of inactivity, after which it is deleted.
- Reservation and order data — for the duration of our relationship and afterwards as required by law. Accounting and tax records are kept for the period required by Romanian law (currently up to 10 years).
- Enquiries and correspondence — for as long as needed to handle your request and for a reasonable period afterwards.
When personal data is no longer needed, we securely delete or anonymise it.
9. Your rights
Under the GDPR, you have the right to access your personal data; to have inaccurate data corrected; to have your data erased; to restrict or object to processing; to receive your data in a portable format; and, where processing is based on consent, to withdraw that consent at any time. You also have the right not to be subject to a decision based solely on automated processing (see Section 10).
To exercise any of these rights, contact us at contact@reservesolara.com. We will respond within one month, as required by the GDPR, and we may need to verify your identity before acting on your request.
10. Automated decision-making
We do not make decisions producing legal or similarly significant effects about you based solely on automated processing, and we do not carry out that kind of profiling.
11. How we protect your data
We use appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, alteration or disclosure. No method of transmission or storage is completely secure, but we work to safeguard your data and keep our measures under review.
12. Children
The Website and our services are intended for people aged 16 and over. We do not knowingly collect personal data from children under 16. If you believe a child has given us their personal data, please contact us and we will delete it.
13. Complaints and the supervisory authority
If you have a concern about how we handle your personal data, please contact us first at contact@reservesolara.com so we can try to resolve it. You also have the right to lodge a complaint with the Romanian supervisory authority:
- National Supervisory Authority for Personal Data Processing (ANSPDCP)
- B-dul General Gheorghe Magheru 28-30, Sector 1, 010336 Bucharest, Romania
- www.dataprotection.ro · anspdcp@dataprotection.ro
14. Changes to this Policy
We may update this Policy from time to time to reflect changes in our practices or in the law. The current version is always available on the Website, and the date at the top shows when it was last updated. We will notify you of material changes where the law requires it.
15. Contact us
CRM LEGACY S.R.L.
Bulevardul Aviatorilor 18, camera 2, Bucharest, Romania
Email: contact@reservesolara.com