---
title: "Privacy Policy - Personal Data Protection"
description: "SPORT SPIRIT Privacy Policy: personal data processing, user rights, security measures and compliance with Moldova data protection laws."
url: "https://sportspirit.md/en/page/privacy-policy"
type: "website"
locale: "en"
---
# Privacy & Security Policy

# PERSONAL DATA PROCESSING POLICY


SPORT SPIRIT S.R.L.


Last updated: 23 August 2026



## 1. Personal Data Controller


This Policy describes how SPORT SPIRIT S.R.L. (hereinafter referred to as the “Company” or “SPORT SPIRIT”), acting as a data controller, processes the personal data of individuals who use the website, online store, loyalty program or other services of the Company, as well as the personal data of representatives, contact persons and end users of clients or partners that are legal entities.


The Company processes personal data in accordance with Law No. 195/2024 on Personal Data Protection, as well as other applicable laws and regulations of the Republic of Moldova.


Data controller identification details: SPORT SPIRIT S.R.L.
IDNO: 1023600005058, registered office: 6 Dimitrie Cantemir St., Chișinău Municipality


For any questions regarding the processing of personal data or the exercise of data protection rights, data subjects may contact: e-mail [info@sportspirit.md](mailto:info@sportspirit.md), telephone +373 76022025, postal address: 6 Dimitrie Cantemir St., Chișinău Municipality



## 2. Categories of Personal Data Processed


Depending on the services used and the data subject’s relationship with SPORT SPIRIT S.R.L., the Company may process the following categories of data:


· identification and contact data: first name, last name, telephone number, e-mail address, delivery address, locality and other necessary contact details;


· order and purchase data: orders placed, products purchased, order value and history, delivery method and order status;


· payment and transaction data: payment method and status, transaction identifiers and data required for refunds. Full bank card details are processed by payment service providers where SPORT SPIRIT S.R.L. does not collect or store such data directly;


· return, exchange, warranty and complaint data: information required to handle requests, confirm purchases and enable consumers to exercise their rights;


· customer account and loyalty program data: account details, activity history, points/discounts, benefits granted, user preferences and settings;


· customer communication data: the content of requests, complaints, reviews and correspondence by telephone, e-mail, online forms or other channels. Telephone calls are recorded only where such recording is actually used and the individual has been informed in advance;


· technical data and online identifiers: IP address, cookie identifiers, information about the device, browser and operating system, technical logs and other information required for the operation and security of the website;


· marketing and service usage data: communication preferences, interactions with the website, products viewed and other data used for campaigns and analytics, solely on the basis of the applicable legal basis.



## 3. Children’s Data


SPORT SPIRIT S.R.L. does not seek to intentionally collect children’s personal data for marketing purposes. Where information society services are offered directly to a child and the processing is based on consent, the special conditions provided for by Law No. 195/2024 shall apply, including the rules concerning the age of 14 and, where applicable, obtaining or authorising consent by the holder of parental responsibility.


The Company collects only personal data that is adequate, relevant and limited to what is necessary in relation to the stated purposes.



## 4. Purposes and Legal Bases for Processing


SPORT SPIRIT S.R.L. processes personal data only for specified, explicit and legitimate purposes, in compliance with the principles of lawfulness, fairness, transparency, data minimisation, accuracy, storage limitation, integrity and confidentiality.


The main purposes and legal bases are as follows:





Purpose of processing
Legal basis





Creation and administration of the customer account; processing and fulfilment of orders; delivery of products; operational communications concerning orders
performance of a contract and taking steps prior to entering into a contract



Processing payments, refunds, tax and accounting documents; compliance with obligations towards public authorities
performance of a contract and/or compliance with legal obligations



Returns, exchanges, warranties, complaints and customer support
performance of a contract, compliance with legal obligations and, where applicable, legitimate interests relating to the establishment, exercise or defence of legal claims



Administration of the loyalty program, points/discounts and related benefits
performance of the terms and conditions of the loyalty program; separate commercial communications are based on the legal basis applicable to marketing



Sending commercial communications by e-mail and SMS
valid consent of the data subject where required by law; the right to withdraw consent/unsubscribe may be exercised at any time



Traffic analysis, online marketing, non-essential cookies and similar technologies
consent, where required under applicable legislation



Website and systems security, prevention of fraud and incidents, protection of assets and defence of the Company’s rights
the Company’s legitimate interests, following an assessment of the balance between such interests and the rights of the data subject




Where processing is based on consent, such consent must be freely given, specific, informed and unambiguous. Consent may be withdrawn at any time, without affecting the lawfulness of processing carried out before its withdrawal.



## 5. Loyalty Program


As part of the loyalty program, SPORT SPIRIT S.R.L. may process the data necessary to identify the member, keep records of participation, provide benefits, administer points/discounts and communicate information strictly related to the operation of the program.


Participation in the loyalty program does not, in itself, constitute consent to receive commercial communications. Marketing by e-mail, SMS or other electronic means is carried out separately, on the basis of the applicable legal basis and with an easy option to unsubscribe.



## 6. Commercial Communications


Where the data subject has validly given consent, SPORT SPIRIT S.R.L. may send information by e-mail, SMS, push notifications or other electronic means concerning promotions, discounts, new products and collections, campaigns, competitions, offers, loyalty program benefits and other commercial information.


Consent to e-mail marketing and SMS marketing is obtained separately from acceptance of the terms and conditions of sale and is not a condition for placing an order.


The data subject may unsubscribe at any time, free of charge. E-mail messages will include a functional unsubscribe mechanism, while SMS messages or other electronic communications will provide a simple means of opting out. Strictly operational communications concerning orders, delivery, returns or other contractual obligations do not constitute marketing communications.



## 7. Data Recipients and Processors


SPORT SPIRIT S.R.L. may disclose personal data only to the extent necessary to achieve the stated purposes and in compliance with applicable legal requirements:


· delivery and courier service providers, including FUN COURIER, for the purpose of dispatching and delivering orders; the data normally disclosed may include first name, last name, telephone number, delivery address and information required to identify the shipment;


· payment service providers, financial institutions or payment processors;


· providers of IT, hosting, maintenance, security and information system administration services;


· providers of SMS, e-mail or electronic notification services, to the extent that such services are actually used by SPORT SPIRIT S.R.L.;


· providers of CRM solutions and/or loyalty platforms, where used;


· providers of legal, accounting and audit services or other professional advisers, to the extent necessary for the provision of their services;


· public authorities, courts and other competent institutions where disclosure is required by law or necessary for the defence of a legal right.


Where a service provider processes personal data on behalf of SPORT SPIRIT S.R.L., the relationship with that provider shall be governed by a contract or other appropriate legal instrument specifying the subject matter, duration, nature and purpose of the processing, the types of data, categories of data subjects, obligations of the parties and security requirements.


SPORT SPIRIT S.R.L. does not make customer data available to third parties for their own marketing purposes, except where a separate legal basis exists and the data subject has been duly informed.



## 8. International Data Transfers


Where the use of certain technical services, platforms, hosting, analytics, CRM, marketing or communication solutions involves the transfer of or access to personal data from outside the Republic of Moldova, SPORT SPIRIT S.R.L. will carry out such transfers only on the basis of a mechanism permitted under Law No. 195/2024 and subject to appropriate safeguards.


Additional information regarding recipients, destination countries and applicable safeguards may be requested using the contact details provided in Section 1.



## 9. Retention Periods


Personal data is retained only for as long as necessary to fulfil the purposes for which it was collected, taking into account legal obligations, limitation periods, the need to resolve complaints and the defence of SPORT SPIRIT S.R.L.’s rights.


· data relating to orders, contracts and tax/accounting documents – for the periods prescribed by applicable accounting, tax and archiving legislation;


· customer account data – for the duration of the account and, after its closure, only to the extent that the retention of certain data is required by law or necessary for the defence of a legal right;


· loyalty program data – for the duration of participation in the program and thereafter only for the period justified by legal obligations or the defence of legal rights;


· data used for commercial communications – until consent is withdrawn/unsubscription occurs or until the expiry of the inactivity period established by internal rules; evidence of the opt-out may be retained on a suppression list in order to prevent further messages from being sent;


· data relating to complaints, returns, exchanges and customer communications – for the period necessary to resolve the relevant matter and thereafter for as long as required by legal obligations or applicable limitation periods.


Specific retention periods are established by SPORT SPIRIT S.R.L.’s internal data retention procedures. Upon expiry of the applicable retention period, the data is deleted, securely destroyed or anonymised.



## 10. Rights of Data Subjects


Under Law No. 195/2024 and to the extent applicable to the specific circumstances, the data subject may exercise the following rights:


· the right to information;


· the right of access to personal data;


· the right to rectification;


· the right to erasure;


· the right to restriction of processing;


· the right to data portability;


· the right to object, including the right to object at any time to processing for direct marketing purposes;


· the right to withdraw consent where processing is based on consent;


· rights applicable in relation to automated individual decision-making, where SPORT SPIRIT S.R.L. uses such processes;


· the right to lodge a complaint with the National Centre for Personal Data Protection (NCPDP/CNPDCP) and the right to bring proceedings before the competent court.


Requests should be submitted using the contact details provided in Section 1. Where there are reasonable doubts concerning the identity of the person making the request, SPORT SPIRIT S.R.L. may request additional information strictly necessary to verify the person’s identity.


SPORT SPIRIT S.R.L. responds to requests without undue delay and within the time limits established by Law No. 195/2024. Where the law permits an extension of the applicable time limit, the data subject will be informed within the initial period and provided with the reasons for the extension.



## 11. Cookies and Similar Technologies


The website may use cookies and similar technologies for operation, security, analytics and marketing purposes. Strictly necessary cookies may be used without consent where permitted by law. Non-essential cookies, including analytics and marketing cookies, are activated only under the conditions and on the legal basis provided for by applicable legislation.


Detailed information regarding the types of cookies, providers, duration and options available to users is provided in the Cookie Policy and through the preference management mechanism available on the website.



## 12. Data Security


SPORT SPIRIT S.R.L. implements technical and organisational measures appropriate to the risks associated with the processing of personal data in order to prevent unauthorised access, loss, destruction, alteration, disclosure or any other form of data compromise.


Security measures are periodically reviewed and adapted according to the nature, scope, context and purposes of the processing, as well as developments in risks and technical solutions.



## 13. Amendments to the Policy


SPORT SPIRIT S.R.L. may update this Policy where there are changes to legislation, internal processes, services, service providers or processing methods. The updated version will be published on the website and will indicate the date of the latest revision.


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Date of last update: 23 August 2026.