- Order and delivery details
- Name, phone number, full address, floor, intercom code, notes for the courier. The legal basis is performance of the contract or steps taken at the request of the person before the contract, so the legal side is straightforward. The difficult part is the principle of data minimisation: the data must be adequate, relevant and limited to what is necessary in relation to the purpose. The intercom code has a purpose that ends on the day of delivery; the order number has a purpose that lasts longer. A single table, in which all fields have the same lifespan, treats the two the same because no one separated them, not because the law would require that.Keep: Determined by purpose, with planned terms by categories that are expressly included in the record of processing activities. The specific term imposed by accounting and archiving obligations for the documents accompanying the order remains unverified in this dossier — we were unable to open those texts on the day of verification.SourceLaw 195/2024, art. 6 para. (1) lit. b), art. 5 para. (1) lit. c) and e), art. 30 para. (1) lit. c) and f)
- Customer account and order history
- Authentication data, saved addresses, the list of previous orders. It is the set that makes it possible to repeat an order and, at the same time, the one that feeds recommendations. The distinction that matters: keeping the history so that that customer can consult it is a continuation of the relationship with them; using the same history to assess preferences, behaviour or economic situation is profiling by the law’s definition, so a different purpose, with its own notice. The compatibility of a new purpose is assessed by explicit criteria, including the link with the initial purpose, the context of the relationship and the possible consequences for the person.Keep: As long as the account is active and as long as the contractual relationship requires. The criteria for determining the period must be communicated to the person at the time of collection if the exact period cannot be indicated.SourceLaw 195/2024, art. 4 (the definition of “profiling”), art. 6 para. (5), art. 13 para. (2) lit. a), art. 5 para. (1) lit. b)
- Abandoned cart
- An email address or phone number, the selected products, the moment of interruption, sometimes a session identifier linking the row to subsequent visits. It is not an order and it is not an account; it is a standalone processing operation, with its own purpose, which must be described in the record with its real purpose. When the basis is legitimate interest, the information at the time of collection must say what legitimate interests are being pursued — that is, the shop is obliged to write, in words, why it keeps the address of someone who did not buy.Keep: Short and explicit, by the nature of the purpose: recovery of a purchase intent has a window of days, not years. The term is decided and written down; the right to object may end it at any time, and from that moment the data are no longer processed for that purpose.SourceLaw 195/2024, art. 6 para. (1) lit. f), art. 13 para. (1) lit. c) and d), art. 21 para. (1)–(3), art. 30 para. (1) lit. b) and f)
- Online identifiers and tracking tags
- Cookies, device identifiers, remarketing pixels, synchronised audience lists with advertising platforms. The law’s definition expressly includes the online identifier among the elements by which a person becomes identifiable, so the discussion “these are not personal data, they are just cookies” ends at the level of definition. What is added: each platform to which the list is sent is a recipient, and the recipients or categories of recipients are communicated to the person at the time of collection, together with the intention to transfer to another state and the safeguards on which the transfer relies.Keep: Determined by the declared marketing purpose and limited by withdrawal of consent, which must be as easy as giving it. The categories of recipients and transfers are included in the record of processing activities.SourceLaw 195/2024, art. 4 (the definition of “personal data”), art. 7 para. (3), art. 13 para. (1) lit. e) and f), art. 30 para. (1) lit. d) and e); Law 284/2004, art. 10 para. (2) lit. f)
- The conversation thread with the customer
- The messages through which size is negotiated, a photo of the defective product is sent, the address is dictated, it is explained for whom the gift is. The content is largely the same as the order, but with one important difference: it is a free field, and free fields collect data that nobody asked for, including, occasionally, health reasons for a return. The place is not the shop’s; it is the infrastructure of a channel provider, often in another state — so the provider is a processor and requires a written contract with the subject, duration, nature, purpose, type of data and categories of data subjects, and the storage location falls under the transfer regime.Keep: Undefined in practice, because the threads remain in the application. Exactly for this reason, the term must be decided explicitly and written into the record, not left to the application’s implicit behaviour.SourceLegea 195/2024, art. 28 alin. (3), art. 44 alin. (2), art. 9 alin. (1), art. 30 alin. (1) lit. f)
- The cancellation and refund file
- The revocation statement or completed standard form, the acknowledgement of receipt sent on a durable medium, proof of dispatch of the goods, and sometimes a bank account for reimbursement when the initial payment cannot be reversed. The law requires reimbursement to be made in the same currency and using the same means of payment as those used by the consumer, except where they have expressly agreed to another method — so an IBAN collected implicitly, without that agreement, is a collection that was not necessary. The burden of proof regarding the exercise of the right of revocation lies with the consumer, which makes the acknowledgement of receipt not just a courtesy, but a piece of the dossier.Keep: Related to the period during which the mutual obligations from revocation may be challenged. Processing necessary for the establishment, exercise or defence of a right in proceedings is an express limit to the right to erasure, so the term is justified by that purpose, not by habit.SourceCodul civil nr. 1107/2002, art. 1057 alin. (2), art. 1054 alin. (4), art. 1062 alin. (2); Legea 195/2024, art. 5 alin. (1) lit. c), art. 17 alin. (3) lit. e)