CAMPAIGN REGULATION

“WINTER SALE”

ART. 1 ORGANIZER AND REGULATIONS

1. The organizer of the promotional campaign “WINTER SALE” (hereinafter referred to as the “Campaign” or the “Promotion”) is Sarkkrom Trading S.R.L., headquartered in Bucharest, Sector 1, Calea Floreasca, No. 246C, 34th floor, Units A1 and A, Sky Tower, registered with the Trade Register under No. J40/6719/2007, with the unique registration code 21493505.
2. Participants in this Campaign are required to comply with the terms and conditions of the Official Regulation, as outlined below (hereinafter referred to as the “Official Regulation”).
3. The Official Regulation is prepared and made public in accordance with the applicable Romanian legislation and is available to any requester during the Campaign period through the following means:
• By accessing the campaign link available on the website [ro.tommy.com]
• In participating stores (available in printed format at the checkout)
4. The Organizer reserves the right to modify this Official Regulation during the Campaign, to terminate the Campaign at any time, and/or to change the participation rules, with the obligation to officially notify the public in the same manner as the initial communication. Any such actions will be announced at least 24 (twenty-four) hours in advance.
5. By participating in this Campaign, participants are presumed to have accepted and understood the Regulation and to agree with it. Participants commit to complying with all terms, conditions, and provisions of this Regulation.
6. Online participants understand and accept that use of the website may only be carried out in compliance with the terms and conditions and by being informed about the Privacy Policy.

ART. 2 CAMPAIGN DURATION AND TERRITORY

1. The Campaign will run from 02.01.2026 – 28.02.2026:
   a) In Tommy Hilfiger stores located in: București Mall, Băneasa Shopping City, Palas, Iulius Timișoara, Iulius Cluj, City Park Constanța, Afi Brașov, Afi Cotroceni, Promenada Sibiu, and Promenada Craiova
   b) Online, via the website [ro.tommy.com]
2. After 28.02.2026, Sarkkrom Trading S.R.L. will no longer have any responsibility or obligation in connection with any circumstances that might lead interested persons to believe the Campaign is still ongoing.
3. All products participating in this Campaign must be purchased in accordance with the provisions of this Regulation and subject to availability.
4. During the same period, the Promotion will run simultaneously with other promotions under different conditions, such as:
• Loyalty Program – exclusive to members, subject to different terms and conditions.

ART. 3 RIGHT TO PARTICIPATE IN THE CAMPAIGN

1. The promotional Campaign is addressed to all natural persons who are at least 18 years old by the Campaign start date, including Romanian citizens or foreign citizens residing in Romania with a permanent address/residence in Romania, and who accept the terms and conditions of this Official Regulation (hereinafter referred to as the “Participants”) by making purchases under the Campaign terms.
2. The Organizer reserves the right to eliminate any fraud attempts by restricting participation for individuals attempting to cheat.
3. The campaign is open to the public without restrictions
4. If individuals are identified who have influenced or facilitated fraud by breaching this Regulation, the Organizer has the right to take legal action against them, both civilly and criminally, to recover any damages caused.
5. The Organizer reserves the right to cancel any participation (including any order placed based on benefits obtained through participation in this Campaign) made in violation of this Regulation.
6. Refusal to provide complete or necessary data results in the inability to participate in the Campaign, in accordance with the Regulation.
7. By participating in the Campaign, participants agree that their personal data will be processed by Sarkkrom Trading S.R.L. on its own behalf under the terms of Annex 1 of this Regulation.

ART. 4 PARTICIPATING PRODUCTS

4.1. The Campaign includes selected New Collection Items.

4.2. The Organizer has no liability or obligation toward consumers who purchase Participating Products or place orders that are processed after the Campaign has ended.

4.3. Participating Products in the Promotion:
All products listed in Annex 2, which forms an integral part of this Regulation, are included in the promotion, subject to stock availability and within the promotion period. Any product not included in the category of eligible products specified for each promotional period is excluded

In the event of website malfunctions at ro.tommy.com or system errors, including human error, that result in incorrect or unreasonably low pricing inconsistent with the sale price set by the Organizer for that period, the Organizer reserves the right to cancel the order. Customers who have placed such orders will be notified by phone, email, or SMS. By participating, buyers accept and agree that they will not have any right to oppose or make claims regarding the products subject to these erroneous orders. The Organizer also reserves the right to limit the number of products per purchase.

6. Responsibility

Participation in this promotional campaign implies full, explicit, and unambiguous knowledge and acceptance of this Regulation.

The Organizer is entitled to modify or cancel any or all activities or transactions and take all necessary measures in case of fraud attempts or errors that could lead to unreasonably low or incorrect prices.

The Organizer reserves the right to update the list of eligible products, to add or remove items, or include similar assortments. Any amendments to the Regulation will be communicated to the public in the manner specified herein.

The Organizer is not liable for situations in which, due to website or system malfunctions, online purchases cannot be made during the campaign period or transactions fail due to technical/system errors or human error.

7. Termination of the Promotion

Promotions may be terminated or canceled in whole or in part by unilateral decision of the Organizer, for any reason, including the occurrence of force majeure events or in the event the stock is depleted before the end of the promotional period. Events considered force majeure include, but are not limited to: fires, floods, strikes, blockades, disasters of any kind, and any regulation or administrative decision that may prohibit or change the Regulation terms.

In such cases, the termination or modification will be made public on the website and in participating stores, and the Organizer shall have no further obligations toward customers, including compensation or other similar claims.

ART. 10 – DISPUTES AND GOVERNING LAW

Any disputes arising between the Organizer and the Participants will be resolved amicably, or if not possible, by the competent Romanian courts at the Organizer’s registered office.

The Organizer is entitled to take all necessary action in cases of fraud, abuse, or actions that may affect the image of this Campaign.

ART. 11 – FORCE MAJEURE

For the purposes of this Regulation, Force Majeure means any external event that cannot be controlled, remedied, or foreseen by Sarkkrom Trading SRL, and which prevents it from fulfilling its obligations as per this Regulation, in accordance with Art. 1351 of the Civil Code. If invoking force majeure, the Organizer is required to inform participants within 5 (five) working days of its occurrence, by publishing the announcement on ro.tommy.com.

ART. 12 – MISCELLANEOUS

Any complaints regarding the conduct of the Campaign may be submitted via telephone at the customer support line 0373.760.367 or via the contact form available at ro.tommy.com, and will be considered until the end date of the campaign. After this date, no complaints will be accepted.

Final Provisions

The Promotion Regulation, along with its annexes regarding discounted prices, is made freely available to all interested parties in Tommy Hilfiger stores nationwide and on ro.tommy.com. By participating, customers agree to the content of the Promotion Regulation. The Organizer reserves the right to modify this Regulation at any time during the Promotion by issuing an addendum, which will be communicated to the public as described above.

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

SARKKROM TRADING SRL

ANNEX 1

PERSONAL DATA PROTECTION

The Organizer acts as a data controller under GDPR with regard to the processing of the buyer’s personal data. The processing of personal data collected and used in the context of organizing and carrying out the Campaign will be governed by the rules described in these Terms and Conditions.

Through this Official Regulation, the Organizer and the companies involved in the organization of the Campaign commit to complying with the provisions of the legislation regarding the protection of personal data, namely Regulation (EU) 2016/679 of the European Parliament and of the Council dated April 27, 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC ("GDPR").

Purposes of Personal Data Processing:

Personal data is processed for the following purposes (the specific legal basis of the processing is added in parentheses when detailing the purpose), based on:

• the consent obtained in accordance with art. 6 (1) (a),
• a contract to which the data subject is party, under art. 6 (1) (b) of GDPR, or
• legitimate interests under art. 6 (1) (f) of GDPR:
• organizing and conducting the Campaign;
• sending commercial communications for marketing purposes, such as offers regarding the Organizer's products, invitations to participate in contests, promotional lotteries, surveys or polls, and similar communications (with the buyer's prior consent);
• for the conclusion and execution of a contract concluded between the data subject (the buyer) and SARKKROM TRADING SRL (product purchase);
• participation in the Campaign, resolving complaints and customer requests, including order-related matters such as delivery, invoicing, product returns, resolving potential disputes before courts, debt collection;
• resolving any complaints related to the organization and conduct of the Campaign;
• enforcing the provisions of the Regulation for defense in court and/or other judicial or administrative procedures, including investigation of possible violations, conducting various reports, analyses, and statistical studies regarding marketing campaigns and their success (Organizer’s or Partner’s legitimate interest);
• archiving activities, if required by law (Organizer’s legal obligation).

If the legal basis for processing is the data subject’s consent, the data subject has the right to withdraw that consent at any time. If PARTICIPANTS withdraw their consent for processing personal data for promotional and advertising purposes, the Organizer will cease such processing, without affecting other data processing operations based on other legal grounds.

If the buyer requests an invoice and has a client account (site user), the personal data necessary for issuing the invoice will be automatically retrieved from our records and used strictly for this purpose.
No additional data will be requested, and no separate identification data of the Beneficiaries will be processed.

Source and Recipients of Personal Data:

The Organizer may disclose personal data to:

• its Partners, acting either as controllers or processors, notaries/lawyers appointed to assist with the organization and conduct of the Campaign;
• courier service providers, mobile phone companies;
• public authorities or other categories of recipients, including other Group companies, if disclosure is based on an appropriate legal ground (e.g., legal obligation, consent, or legitimate interest).

Retention Period of Data:

Personal data is retained as long as necessary to fulfill the purposes for which it was collected, in accordance with internal data retention procedures, including applicable archiving rules.

For example, personal data collected for the Campaign will be stored for the duration of the Campaign plus a minimum period of 3 years (which is the statute of limitations for legal actions).
For buyer data related to tax and reporting obligations, the data will be retained for the full archiving period according to financial-accounting regulations.

Data Subject Rights:

Under the law, data subjects have a series of rights. As of GDPR's entry into force, data subjects have the following rights:

1. Right of Access: to obtain confirmation from the Controller as to whether or not their personal data is being processed, and information on the nature of the processing (purpose, categories of data, recipients, retention period, etc.). This right allows a free copy of the personal data, and any additional copies at a cost.
2. Right to Rectification: to request correction of inaccurate personal data or completion of incomplete data.
3. Right to Erasure: to request deletion of personal data when:
• it is no longer needed for the purposes it was collected for;
• the data subject has withdrawn consent and there is no other legal basis for processing;
• processing is unlawful;
• deletion is required under applicable law.
4. Withdrawal of Consent and Right to Object: to withdraw consent at any time for data processed based on consent. They may also object to processing for marketing purposes (including profiling) and to processing based on the Controller's legitimate interest, for reasons related to their particular situation.
5. Restriction of Processing: in the following cases:
• when contesting the accuracy of the data, during the period of verification;
• when processing is unlawful and deletion is opposed, but restriction is requested;
• when the data is no longer needed by the Controller, but the data subject needs it for legal claims;
• when an objection has been filed and a balance of interests is pending.
6. Right to Data Portability: if data is processed by automated means, the data subject can request that it be provided in a structured, commonly used, machine-readable format, and, if technically feasible, to be transferred to another controller.

To exercise the rights mentioned above (points 1–6), data subjects may contact the Controller at:

To the attention of: Data Protection Officer (DPO)
Mailing Address: SKY TOWER, CALEA FLOREASCA no. 246C, 34th Floor, Space A1+A, Sector 1, Bucharest, Postal Code 014476
Email: tommy.contact@sarkkrom.ro

Before responding to such requests, we reserve the right to verify your identity to ensure the request is made by the actual data subject.

Right to File a Complaint with the Supervisory Authority and Legal Action:

Data subjects have the right to lodge a complaint with the data protection supervisory authority if they believe their rights have been violated:

National Authority for the Supervision of Personal Data Processing
Address: Bulevardul General Gheorghe Magheru no. 28-30, Sector 1, Bucharest
Email: anspdcp@dataprotection.ro

They also have the right to take legal action.

LEGAL BASIS

These Terms and Conditions comply with national legislation on the sale of goods and services (Government Ordinance no. 99/2000), and the laws on personal data protection and free movement of such data.

Complaints related to products or services involved in the Campaign after its completion will not be considered if submitted after 14 days from the Campaign’s end and will not be the Organizer’s responsibility.

In case of attempted fraud, system abuse, or any action harming the Organizer’s image, the Organizer reserves the right to take all necessary measures to address the situation.

The Organizer will take all necessary measures to ensure the Campaign runs under normal conditions as outlined above but does not take responsibility for complaints or objections from participants that do not involve a breach of applicable legal provisions.

FINAL PROVISIONS

The Organizer reserves the right to verify and monitor how the Campaign is carried out.

If, for any reason, the Campaign cannot run as planned due to causes beyond the Organizer’s control (fraud, technical problems, or other issues that affect the administration, security, integrity, or proper conduct), the Organizer reserves the right to cancel, suspend, or modify the Campaign.
If the Campaign ends due to force majeure, fraud, or technical difficulties before the scheduled end date, an official announcement will be made at the Campaign location.

SARKKROM TRADING SRL