Datenschutzerklärung

Wellness Path Holding S.R.L. ("Wellness Path Holding", "we", "us" or "our") operates this store and website, including all related information, content, features, tools, products and services, in order to provide you, the customer, with a curated shopping experience (the "Services").

Wellness Path Holding is powered by Shopify, which enables us to provide the Services to you.

This Privacy Policy describes how we collect, use, process and disclose your personal information when you visit, use, make a purchase or other transaction using the Services, or otherwise communicate with us.

If there is a conflict between our Terms of Service and this Privacy Policy with respect to the collection, processing or disclosure of personal information, this Privacy Policy controls in relation to such processing.

Please read this Privacy Policy carefully. By using and accessing any of the Services, you acknowledge that you have read this Privacy Policy and understand the collection, use and disclosure of your information as described in this Privacy Policy.

Personal Information We Collect or Process

When we use the term "personal information" or "personal data", we are referring to information that identifies or can reasonably be linked to you or another identifiable individual.

Personal information does not include information that has been collected anonymously or de-identified so that it cannot identify or reasonably be linked to you.

We may collect or process the following categories of personal information, including inferences drawn from this information where applicable, depending on how you interact with the Services, where you live and as permitted or required by applicable law:

• Contact details, including your name, address, billing address, shipping address, phone number and email address.

• Financial and payment information, including payment method, payment confirmation, transaction details and other payment-related information. Payment card information may be processed directly by Shopify, Shopify Payments or other authorised payment service providers.

• Account information, including your username, password, preferences and settings.

• Transaction information, including items you view, place in your cart, add to your wishlist, purchase, return, exchange or cancel, and information about previous transactions.

• Communications with us, including information you provide when contacting customer support or otherwise communicating with us.

• Device information, including information about your device, browser or network connection, IP address and other unique or technical identifiers.

• Usage information, including information regarding your interaction with the Services, including how and when you interact with or navigate the Services.

• Marketing and preference information, including communication preferences and interactions with marketing communications where applicable.

Personal Information Sources

We may collect personal information from the following sources:

• Directly from you, including when you create an account, visit or use the Services, place an order, communicate with us or otherwise provide us with personal information.

• Automatically through the Services, including from your device when you use our Services or visit our website, and through cookies and similar technologies.

• From Shopify and our service providers, including where we engage them to provide technology, payment processing, analytics, customer support, fulfilment, shipping or other services.

• From our business, marketing or advertising partners, where permitted by applicable law.

• From other third parties, where permitted or required by applicable law.

How We Use Your Personal Information

Depending on how you interact with us or which Services you use, we may use personal information for the following purposes:

Provide, Tailor and Improve the Services

We use personal information to provide and operate the Services, including to perform our contract with you, process payments, fulfil orders placed directly with Wellness Path Holding, remember preferences and items you are interested in, send notifications related to your account or transactions, process purchases, returns, exchanges or other transactions, create and manage your account, arrange shipping, facilitate returns and exchanges, enable reviews and improve the customer experience.

This may include using personal information to understand how customers interact with the Services and to provide relevant product recommendations.

Marketing and Advertising

Subject to applicable law and your choices, we may use personal information for marketing and promotional purposes, including sending marketing or promotional communications by email or other permitted channels and measuring or improving advertising and marketing activities.

Where consent is required by applicable law for marketing communications, cookies or similar advertising technologies, we will rely on consent.

You may withdraw your consent or unsubscribe from marketing communications at any time using the mechanisms provided in the relevant communication or through available privacy settings.

Security and Fraud Prevention

We use personal information to authenticate accounts, provide a secure shopping and payment experience, detect, investigate and prevent suspected fraudulent, illegal, unsafe or malicious activity, protect the Services and our customers, and establish, exercise or defend legal claims.

If you create an account, you are responsible for keeping your account credentials secure and should not share your password or other access details with unauthorised persons.

Communicating With You

We use personal information to provide customer support, respond to enquiries, provide effective Services, communicate with you regarding orders or accounts and maintain our business relationship with you.

Legal Reasons

We may use personal information to comply with applicable law or valid legal process, respond to lawful requests from competent public authorities, comply with tax and accounting requirements, investigate or participate in legal proceedings, enforce our contractual rights and investigate potential violations of our terms or policies.

Legal Bases for Processing

Where the General Data Protection Regulation ("GDPR"), UK GDPR or other applicable data protection legislation requires a legal basis for processing, we process personal information only where an appropriate legal basis applies.

Depending on the purpose and circumstances, we may rely on:

• Performance of a contract or steps taken at your request before entering into a contract — including processing and fulfilling orders, processing payments, arranging delivery, managing accounts, handling returns or refunds and providing requested customer support.

• Compliance with a legal obligation — including compliance with tax, accounting, consumer protection, regulatory and other applicable legal requirements.

• Legitimate interests — including operating, maintaining and improving the Services, providing customer support, maintaining security, preventing and detecting fraud, protecting our business and legal rights and understanding how customers use our Services, provided that our legitimate interests are not overridden by your interests, fundamental rights or freedoms.

• Consent — where required by applicable law, including for certain marketing communications, non-essential cookies, advertising technologies or similar processing activities.

Where processing is based on consent, you have the right to withdraw your consent at any time. Withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

Where certain personal information is necessary to enter into or perform a contract with you, failure to provide that information may mean that we are unable to process or fulfil the relevant transaction or provide the requested Service.

Automated Decision-Making and Profiling

We may use automated tools and technologies to support certain aspects of the Services, including security, fraud prevention, analytics, personalisation and product recommendations.

Wellness Path Holding does not currently make decisions based solely on automated processing, including profiling, that produce legal effects concerning you or similarly significantly affect you within the meaning of Article 22 of the GDPR.

Certain service providers, including Shopify, may use automated technologies or machine learning in connection with their services. Where those providers process personal information for their own purposes, their respective privacy policies apply.

How We Disclose Personal Information

In certain circumstances, we may disclose personal information to third parties for legitimate purposes and subject to this Privacy Policy, including:

• With Shopify, vendors and service providers that perform services on our behalf or support our business, including IT management, payment processing, data analytics, customer support, cloud services, fulfilment and shipping.

• With payment service providers and financial institutions where necessary to process authorised transactions.

• With business and marketing partners to provide marketing services or advertising, where permitted by applicable law and subject to applicable consent requirements.

• When you direct, request or otherwise consent to disclosure, such as where information must be provided to a delivery or fulfilment partner or through your use of social media widgets or login integrations.

• With our affiliates or within our corporate group, where applicable and legally permitted.

• With professional advisers, such as legal, accounting or other professional service providers where reasonably necessary.

• In connection with a business transaction, such as a merger, acquisition, restructuring, insolvency or sale of all or part of our business, subject to applicable legal requirements.

• Where required by law, including to respond to valid requests from competent authorities, comply with applicable legal obligations, enforce applicable terms or policies and protect or defend our rights, the Services, our customers or others.

Relationship With Shopify

The Services are hosted by Shopify, which collects and processes personal information about your access to and use of the Services in order to provide, secure and improve the Services.

Information you submit through the Services may be transmitted to and shared with Shopify and relevant service providers, including parties that may be located in countries other than the country in which you reside.

In addition, we may use Shopify features that incorporate information obtained from interactions with our Store, Shopify and other merchants. In circumstances where Shopify determines the purposes and means of such processing, Shopify is responsible for that processing and for responding to applicable requests concerning its use of personal information.

To learn more about how Shopify uses personal information and the rights you may have in connection with Shopify's processing, please review the Shopify Consumer Privacy Policy:

https://www.shopify.com/legal/privacy/app-users

Depending on where you live, you may also exercise certain rights concerning personal information processed by Shopify through the Shopify Privacy Portal:

https://privacy.shopify.com/en

External Retailers and Third-Party Purchases

Certain products displayed through Wellness Path Holding may be available for purchase from independent external retailers.

When you follow a link to an external retailer and complete a transaction on that retailer's website or platform, the transaction is concluded with the relevant retailer and that retailer independently determines how personal information relating to the transaction is collected and processed.

The relevant retailer's own privacy policy and terms apply to information you provide directly to that retailer.

Wellness Path Holding does not control the external retailer's processing of personal information and does not receive complete payment information submitted directly to an independent external retailer unless specifically stated otherwise.

We recommend reviewing the relevant retailer's privacy policy before completing an external transaction.

Third-Party Websites and Links

The Services may provide links to websites or other online platforms operated by third parties.

If you follow links to sites not affiliated with or controlled by us, you should review their privacy and security policies and other applicable terms and conditions.

We do not control and are not responsible for the privacy or security practices of independent third-party websites or platforms.

Information you provide on public or semi-public venues, including information shared on third-party social networking platforms, may be viewable by other users of those platforms.

Our inclusion of a third-party link does not, by itself, imply endorsement of the content, owners or operators of that third-party platform except where expressly stated.

Cookies and Similar Technologies

We and our service providers may use cookies and similar technologies to operate the Services, remember preferences, understand how the Services are used, improve functionality, maintain security and, where permitted, support analytics, marketing and advertising.

Where required by applicable law, non-essential cookies and similar technologies will be used only after obtaining the required consent.

You can review and manage available choices through the Cookie Preferences functionality available on our website.

Withdrawal or refusal of consent for non-essential cookies does not affect the lawfulness of processing that occurred before consent was withdrawn.

Certain cookies may be strictly necessary for the website, checkout, security or other functionality requested by you to operate correctly.

Children's Data

The Services are not intended to be used independently by children who do not have the legal capacity required under applicable law to use the relevant Services or enter into transactions.

We do not knowingly collect personal information from children where doing so would be prohibited by applicable law.

If you are the parent or legal guardian of a child who has provided personal information to us unlawfully, you may contact us using the contact details below to request that we investigate and, where appropriate, delete that information.

Security and Retention of Your Information

We use reasonable technical and organisational measures designed to protect personal information against unauthorised access, loss, misuse, alteration or disclosure.

Please be aware that no security measures are perfect or impenetrable, and no method of electronic transmission or storage can be guaranteed to be completely secure.

We recommend that you do not use unsecured channels to communicate sensitive or confidential information to us.

How long we retain personal information depends on different factors, including whether we need the information to maintain your account, provide the Services, perform contractual obligations, comply with legal, tax or accounting obligations, resolve disputes, prevent fraud or establish, exercise or defend legal claims.

We retain personal information only for as long as reasonably necessary for the relevant purposes or as required by applicable law.

When personal information is no longer required, we will delete, anonymise or otherwise handle it in accordance with applicable law.

Your Rights and Choices

Depending on where you live, you may have some or all of the rights listed below in relation to your personal information.

These rights are not absolute, may apply only in certain circumstances and may be subject to exceptions provided by applicable law.

• Right to Access / Know. You may have the right to request access to personal information that we hold about you and, where applicable, receive a copy of that information.

• Right to Delete / Erasure. You may have the right to request deletion of personal information we maintain about you in circumstances provided by applicable law.

• Right to Correct / Rectification. You may have the right to request correction of inaccurate or incomplete personal information.

• Right to Restriction of Processing. You may have the right to request that we restrict processing of personal information in certain circumstances.

• Right to Object. You may have the right to object to certain processing based on legitimate interests and, where applicable, to object at any time to processing for direct marketing purposes.

• Right to Portability. You may have the right to receive certain personal information in a structured, commonly used and machine-readable format and, where applicable, request that it be transmitted to another controller.

• Withdrawal of Consent. Where we rely on consent to process personal information, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing based on consent before its withdrawal.

• Managing Communication Preferences. We may send promotional emails where permitted by applicable law. You may opt out at any time by using the unsubscribe mechanism displayed in our emails. If you opt out, we may still send non-promotional communications concerning your account, orders, transactions, security or legal matters.

• Right to Lodge a Complaint. You may have the right to lodge a complaint with a competent data protection supervisory authority.

If you reside in the United Kingdom or European Economic Area, these rights apply subject to the conditions, exceptions and limitations provided by applicable data protection law.

You may exercise applicable rights by contacting us using the contact details provided below or through any privacy functionality made available through the Services.

To learn more about how Shopify uses personal information and rights relating to information processed by Shopify, you may visit:

https://privacy.shopify.com/en

We will not discriminate against you for exercising applicable data protection rights.

We may need to verify your identity before processing certain requests, as permitted or required by applicable law.

Where permitted by applicable law, you may designate an authorised agent or representative to submit a request on your behalf. Before accepting such a request, we may require evidence that the representative has been authorised to act on your behalf and may also need to verify your identity directly.

We will respond to valid requests within the timeframes required by applicable law.

Complaints

If you have complaints about how we process your personal information, please contact us using the contact details provided below.

Depending on where you live, you may have the right to appeal our decision or lodge a complaint with your local data protection supervisory authority.

For the European Economic Area, you can find a list of the competent data protection supervisory authorities through the European Data Protection Board:

https://edpb.europa.eu/about-edpb/about-edpb/members

In Romania, the competent supervisory authority is the National Supervisory Authority for Personal Data Processing (ANSPDCP — Autoritatea Națională de Supraveghere a Prelucrării Datelor cu Caracter Personal).

Nothing in this section limits your right to lodge a complaint directly with a competent supervisory authority where applicable law provides that right.

International Transfers

We may transfer, store or process personal information outside the country in which you live, including where Shopify or other service providers operate internationally.

Where personal information protected by the GDPR is transferred outside the European Economic Area to a country that has not been recognised as providing an adequate level of protection, we will rely on an appropriate transfer mechanism where required, such as the European Commission's Standard Contractual Clauses or another transfer mechanism permitted by applicable law.

Where personal information protected by the UK GDPR is transferred outside the United Kingdom, we will rely on an applicable UK transfer mechanism where required.

Where an applicable adequacy decision exists, personal information may be transferred in reliance on that decision.

Where applicable, you may contact us using the details below for further information regarding safeguards used for international transfers of your personal information.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time, including to reflect changes to our practices, Services, technology or for operational, legal or regulatory reasons.

We will publish the revised Privacy Policy on this website and update the "Last updated" date.

Where required by applicable law, we will provide additional notice or obtain consent before implementing changes that require such notice or consent.

Contact and Data Controller

For purposes of applicable data protection law, Wellness Path Holding S.R.L. is the data controller of personal information where it determines the purposes and means of processing.

If you have questions about our privacy practices or this Privacy Policy, would like to exercise any of the rights available to you, or wish to make a privacy-related complaint, please contact us:

WELLNESS PATH HOLDING S.R.L.

Email: office@wptholding.com
Telephone: +40 743 989 936
Registered address: Comuna Ștefăneștii de Jos, Sat Ștefăneștii de Jos, Str. Fericirii nr. 2, bl. N18D1, Ap. 4, Camera nr. 1, Județul Ilfov, Romania
EUID: ROONRC.J2025101289004
Trade Register No.: J2025101289004
VAT / Tax Identification No.: RO53201196