This privacy commitment explains all aspects related to the processing of personal data and ensures compliance with the principles regarding processing, as well as respect for your rights regarding this data, when you interact with us in relation to our services, as visitors or users of our website, in accordance with the provisions of current European and national legislation, namely the General Data Protection Regulation (EU) 679/2016 (GDPR), Law 190/2018 on the implementation measures of the GDPR, and/or any other decisions that may be issued by the National Supervisory Authority for Personal Data Processing (ANSPDCP) as the supervisory authority for the protection of personal data.
WHO WE ARE?
Inicio SRL, with its headquarters in Bucharest, Sector 5, DUMBRAVA NOUĂ Street, No. 3, unique registration code 48255165 (referred to as “the Company” or “the Operator” or “we”), provides online marketing, web design, graphic design, and advertising services through the inicioagency.com website.
For any processing performed in whole or in part by automated means, as well as processing by means other than automated means of personal data, which is part of a data record system or intended to be part of a data record system, we assure you that your data is:
- Processed in accordance with the principles of lawful, fair, and transparent processing;
- Collected for specified, explicit, and legitimate purposes and not processed in a manner incompatible with these purposes;
- Accurate and up-to-date, if necessary;
- Retained in a form that allows your identification for a period no longer than necessary for the purposes for which the data is processed;
- Processed in a manner that ensures appropriate security, including protection against unauthorized or unlawful processing and against accidental loss, destruction, or damage, using appropriate technical or organizational measures.
WHAT ARE THE CATEGORIES OF DATA SUBJECTS? There are different categories of data subjects, depending on the relationship they have with our Company. We process the data of these data subjects for various processing purposes, always based on a legal basis:
- Visitors to our website (inicioagency.com): These are anonymous individuals who access and browse our website.
- Visitors to our website (inicioagency.com) who may quickly contact us for the purpose of acquiring the services offered by our Company or accessing various services provided by our Company through the use and registration of various requests (e.g., online marketing services, web design, and consultancy) within the contact form or by subscribing to the newsletter.
- Potential clients or business partners of our Company: These are individuals who have the status of an employee, collaborator, representative, or other potential partner, as well as direct or indirect shareholders or ultimate beneficial owners of a potential client/customer, potential supplier/supplier, or other potential partner/business partner of our Company.
WHAT ARE THE PURPOSES FOR PROCESSING YOUR PERSONAL DATA? The main purpose for processing your personal data is to ensure that contractual agreements between us can be properly implemented, allowing contractual relationships to function smoothly and comply with legal requirements.
Our Company processes personal data for the following purposes:
- Providing access to and use of our website (inicioagency.com) by ensuring its proper functioning.
- Operating, protecting, improving, and optimizing our website (inicioagency.com) and the user and customer experience, including conducting analysis, statistics, and research.
- Displaying testimonials on our website (inicioagency.com) from representatives of various clients or business partners.
- Concluding sales contracts for online marketing, web design, consultancy services, and other related services offered by our Company, including order processing and contract invoicing; sending messages regarding the purchased services (such as changes to applicable legislation); addressing various requests/complaints regarding the purchased services.
- Managing the business relationship between us and a potential client/customer, potential supplier/supplier, or other potential business partner, in case you hold the status of an employee, collaborator, representative, or contact person of the respective client, supplier, or business partner.
- Preventing, detecting, or investigating fraud, security breaches, and activities that are or may be prohibited or illegal, as well as defending and exercising our rights in accordance with the law.
- Resolving requests from public authorities or complying with legal requirements (such as specific financial, accounting, tax legislation or anti-money laundering regulations).
- Marketing and advertising.
If we intend to process your personal data for a purpose other than that for which it was collected, we will provide you with information regarding the purpose of the processing and any additional relevant information requested by you before such further processing takes place.
4. WHAT LEGAL BASES DO WE USE FOR PROCESSING YOUR PERSONAL DATA? The legal bases for processing your data are as follows:
- Consent (Art. 6(1)(a) of the GDPR): This applies to displaying testimonials on inicioagency.com from representatives of various clients or business partners, including their names, positions, and companies, which can be used by us for promoting our services.
- Performance of a contract (Art. 6(1)(b) of the GDPR): This applies to purposes related to the conclusion of sales contracts for our services; resolving various requests/complaints regarding the purchased services; sending messages regarding the purchased services (such as changes to applicable legislation).
- Performance of a contract (Art. 6(1)(b) of the GDPR): This applies to the purpose of managing the business relationship between the Controller and a potential client/customer, potential supplier/supplier, or other potential business partner, in case you hold the status of an employee, collaborator, representative, or contact person of the respective client, supplier, or business partner.
- Legitimate interest (Art. 6(1)(f) of the GDPR): This applies to purposes related to providing access to and use of the inicioagency.com website by ensuring its proper functioning; operating, protecting, improving, and optimizing inicioagency.com and the user and customer experience; marketing and advertising; preventing, detecting, or investigating fraud.
- Compliance with legal obligations: This applies to purposes related to security breaches and activities that are or may be prohibited or illegal; defending and exercising our rights; resolving requests from public authorities or complying with legal requirements (such as specific financial, accounting, tax legislation or anti-money laundering regulations).
WHAT TYPES OF DATA DO WE COLLECT? We collect data to operate efficiently and provide you with the best experiences related to our products. You can choose regarding the data we collect. When asked to provide personal data, you can refuse. However, if you choose not to provide data necessary to provide a product, you may not be able to use that product.
For each processing purpose, we require certain personal data from you, as follows:
- Providing access to and use of the inicioagency.com website: We may gather information during your visit to the online store’s website through our data collection tools (Cookies), including internet protocol (IP) address, domain name (URL), access data, client access history (pages viewed, clicked links), HTTP response code, referring web page, bytes used during the visit, viewed page data, or browser type and language.
- Concluding sales contracts for online marketing, web design, and consultancy services: We collect personal data such as name, email address, phone number, address, and banking information (for individual customers) or name, position, email address, and phone number (for representatives/contact persons of legal entities) to process orders, invoices, and messages regarding the purchased services.
- Managing the business relationship between us and potential clients, suppliers, or business partners: We collect personal data such as name, position, email address, phone number, and correspondence address if you hold the status of an employee, collaborator, representative, or contact person of a client, supplier, or business partner.
- Marketing and advertising: We collect personal data such as name, email address, phone number, and data collected from cookies for sending newsletters, personalized marketing campaigns, general and thematic information, information about similar services, offers, and promotions.
- Resolving requests/complaints regarding purchased services: We collect personal data necessary to address your requests. Please note that there are no audio recordings of phone conversations regarding these requests/complaints.
We may obtain your data directly from you or from individuals acting on behalf of a client, supplier, or business partner of the Controller, as well as from public authorities, institutions, publications, and publicly available databases.
We may combine personal information with information about your online transactions and other interactions with us. Additionally, we may combine personal information with information we receive from other sources such as marketing partners, public databases, publicly accessible pages on social platforms, and other third parties.
6. OTHER IMPORTANT INFORMATION
Analysis of communications on our inicioagency.com website
We may examine, scan, or analyze communications on our inicioagency.com website (e.g., through the contact form, email) to prevent fraud, assess risks, comply with regulations, investigate, develop services, conduct research, analyze, and assist customers. For example, as part of our fraud prevention efforts, we scan and analyze messages to mask contact information and references to other websites. In some cases, we may scan, examine, or analyze messages to troubleshoot, improve, and expand service offerings. We use automated methods where possible. However, occasionally, it may be necessary to manually review certain communications, such as fraud investigations and customer support, or evaluate and improve the functionality of these automated tools. We will not examine, scan, or analyze your communications to send third-party marketing messages to you, nor will we sell reviews or analyses of these communications.
These activities are based on our legitimate interest in ensuring compliance with laws and our Terms and Conditions, preventing, detecting, and investigating fraud, security breaches, and activities that are or may be prohibited or illegal, promoting safety, and improving the adequate performance of our services.
Third-party partners and integrations
Our inicioagency.com website may contain links to third-party sites or services, such as integration with third parties, co-branding services, or third-party branded services (“Third-Party Partners”). We do not own or control these Third-Party Partners, and when you interact with them, you may provide information directly to the third-party partner or to us or both. These Third-Party Partners will have their own rules regarding the collection, use, and disclosure of information. We encourage you to review the privacy policies of other websites you access.
Parts of our inicioagency.com website may use third-party services such as Google Analytics, Google Tag Manager, Facebook, LinkedIn, HotJar. The use of these services is subject to their privacy policies, such as the additional terms and conditions of Google Analytics, Google Tag Manager, Facebook, LinkedIn, HotJar.
7. HOW DO WE USE YOUR PERSONAL DATA?
Providing, improving, and developing the inicioagency.com website. We may use personal information to provide, improve, and develop inicioagency.com by:
- Allowing you to access and use inicioagency.com.
- Operating, protecting, improving, and optimizing inicioagency.com and the user and customer experience, including conducting analysis, statistics, and research.
- Providing our own services or third-party services to clients.
- Sending messages regarding purchased services, security alerts.
- Informing, processing orders for the services offered, and resolving various requests/complaints regarding purchased services.
We process this personal information for these purposes based on our legitimate interest in improving inicioagency.com and the customer experience and where necessary for the proper fulfillment of the contract with you.
Creating and maintaining a trusted and safer environment. We may use personal information to create and maintain a trusted and safer environment, such as:
- Detecting and preventing fraud, security breaches, prohibited or illegal activities, spam, abuse, and other harmful activities.
- Conducting security investigations and risk assessments.
- Conducting database and other information source checks, including background or police checks to the extent permitted by applicable laws and with your consent.
- Compliance with legal obligations.
- Resolving disputes with any of our customers and enforcing our agreements with third parties.
- Complying with our Terms and Conditions and other policies.
We process this personal information for these purposes based on our legitimate interest in protecting inicioagency.com, measuring our proper performance of the contract with you, and complying with applicable laws.
Providing, personalizing, measuring, and improving advertising and marketing. We may use personal information to provide, personalize, measure, and improve our advertising and marketing, such as:
- Sending promotional, marketing, advertising, and other information of interest to you based on your preferences (including information about our campaigns and services or those of our partners) and media advertising through social platforms like Facebook, LinkedIn.
- Personalizing, measuring, and improving our advertising.
- Administering surveys, contests, or other promotional activities or sponsorships or managing events sponsored or managed by us or third-party partners.
- Subscribing to email newsletters (this does not affect the frequency of administrative emails we may send related to any purchased service). No fee is charged for sending promotional emails to you.
- Inviting you to local events, promotions, opportunities, experiences within inicioagency.com.
- Displaying testimonials from our clients’ representatives through written statements, video recordings, or podcasts via audio recordings, both on our inicioagency.com website and through social networks and various offline and online media channels.
We process your personal information for the purposes listed in this section based on our legitimate interest in conducting marketing activities to provide you with services that may be of interest to you.
HOW LONG DO WE STORE YOUR PERSONAL DATA? We store your personal data for as long as necessary to provide the purchased services, carry out the requested transactions, or for other essential purposes such as complying with legal obligations, resolving disputes, and implementing our agreements. Since these needs may vary depending on the different types of data and the context of different products, the actual retention periods may vary. The criteria used to determine retention periods include:
- Maintaining and improving the performance of our services, ensuring the safety of our systems, and maintaining proper business and financial records.
- The period for which you have given consent or until you express your intention not to keep them through one of the methods provided in this policy.
- If your data is considered sensitive, it will be stored for a shorter period.
- Situations where the law requires the retention of personal data, maintaining relevant data for an investigation, or data that must be kept in the event of litigation.
The storage periods of your personal data differ depending on the purpose for which they are used, as follows:
- Concluding sales contracts for our services: 10 years, with the mention that personal data included in any accounting documents supporting financial records are archived for 10 years from the closing date of the financial year in which the supporting documents were prepared, in accordance with accounting legislation.
- Defense and exercise of our legal rights and interests: Personal data necessary for this purpose will be retained according to general prescription terms.
- Managing the business relationship between us and potential clients, suppliers, or business partners: During the contract execution period or if there is a legal obligation.
- Marketing and advertising: Until your objections regarding this processing are resolved or until the unsubscribe date from the newsletter service.
- Data processing requiring your consent: Personal data will be processed and retained until the withdrawal of consent, unless the law provides for a different data retention period or data retention is necessary for exercising or defending the rights of the Controller.
- Resolving various requests/complaints regarding purchased services: During the resolution of such requests/complaints or according to general prescription terms for the defense and exercise of our legal rights and interests.
9. WHERE DO WE TRANSFER YOUR PERSONAL DATA?
Your personal data may be processed by other controllers, affiliated controllers, or authorized persons of the Controller, strictly in compliance with personal data protection legislation:
- IT service providers and other companies falling into these categories that the Controller may contract services and products from, and have implemented adequate protection measures as required by law to ensure their compliance with personal data protection obligations. If authorized persons subcontract some activities involving the processing of personal data, the subcontractors will be subject to the same obligations regarding the implementation of security measures, technical and organizational, as provided by the EU General Data Protection Regulation and internal regulations approved for the implementation of the EU General Data Protection Regulation.
- Contracting parties of the Controller that act as associated controllers for the fulfillment of outsourcing services.
- State authorities based on their legal competencies.
- We may share your information with our service providers who manage customer information and perform services on our behalf, such as promotions, customer messaging, surveys, targeting, and retargeting, etc. We have not authorized any of these service providers to perform other operations with your information.
- We may share information about you when we collaborate with another company to provide or offer services, contests, or promotions to our customers.
- We may disclose information about you if necessary or appropriate in good faith to comply with laws or regulations, respond to valid subpoenas, orders, or government requests, or protect the operations, confidentiality, security, property, or rights of the Controller.
- In the unlikely event of a sale or merger of the Company, the personal information of our customers and other information we have collected as described in this policy may be among the transferred assets.
Your data will not be transferred abroad. If your data is transferred to other companies/entities outside the EU/EEA, you will be informed accordingly.
HOW DO I CHOOSE WHICH PROMOTIONS I RECEIVE? Our company only communicates with you if you have expressed or are expressing your agreement (consent) in this regard.
However, there is also the possibility that our company may send you personalized offers if you have used the Contact Form on our website inicioagency.com, based on our legitimate interest for marketing and advertising purposes (Art. 6(1)(f) of the GDPR).
If you prefer not to receive promotional information, such as information about special offers and sales events, you can let us know by contacting our customer service as described in the section titled “How can you contact us?” on our website inicioagency.com or by clicking the unsubscribe links provided in each newsletter sent by us.
- HOW DO WE PROTECT CHILDREN’S DATA?
We explicitly alert visitors and users that all personal data processing refers exclusively to individuals who have reached the age of 16. The use or purchase of services offered through our website inicioagency.com by children under the age of 16 is prohibited. In exceptional situations where personal data of children under 16 is processed, we will immediately cease such processing once we become aware of such situations. The responsibility for the use of our website by children belongs solely to the parents.
12. WHAT HAPPENS IF I USE DIFFERENT DEVICES TO ACCESS THE SITE?
13. WHAT OTHER DATA DO WE COLLECT?
14. HOW ARE MY INFORMATION USED FOR BEHAVIORAL ADVERTISING, AND WHAT ARE MY OPTIONS?
We also work with third-party companies that use tracking technologies (including cookies and pixel tags) on our website to deliver personalized advertising on our behalf and on behalf of other internet advertising agents. These companies may collect information over time about your activities on our website and other websites, as well as your interaction with our advertising and other communications, and use this information to determine which ads you see on third-party websites and applications. These technologies and the information collected about you may also be used to track your activities across multiple devices. For more information about this practice and to understand your options, including how to opt out of receiving these personalized ads, please visit http://www.aboutads.info.
Please note that, even if you opt out of these technologies, they may still collect data, and you will still see ads, but those ads will not be targeted based on information collected through these tracking technologies.
15. WHAT SECURITY MEASURES HAVE WE ADOPTED?
The company has implemented a personal data security policy. We assure you that your data processing is carried out by trained personnel, according to the highest confidentiality standards. We have physical, electronic, contractual, and managerial guarantees to assist you in protecting the security and confidentiality of your personal information.
When you enter your personal information on our website inicioagency.com, we use encryption technology to protect your information as it is transmitted to us.
16. WHAT IS PHISHING?
18. HOW CAN YOU ACCESS OR CHANGE THE INFORMATION YOU HAVE PROVIDED US? You can request to update your personal information by contacting us as described in the section titled “How can you contact us?” below. Please note that any request to update your personal information may take up to 30 days for email requests and up to 6-8 weeks for requests made through traditional postal services.
19. HOW CAN YOU CONTACT US?
20. WHAT RIGHTS DO YOU HAVE? Under personal data protection legislation, you have the following rights:
- Right to information: The right to receive information about the processing of your personal data carried out by us.
- Right of access to data: The right to obtain confirmation of whether or not we process your personal data and, if so, access to the data and information regarding the processing.
- Right to rectification: The right to obtain, without undue delay, the rectification of inaccurate personal data concerning you or the completion of incomplete personal data.
- Right to erasure of data: The right to obtain, without undue delay, the erasure of personal data in the following situations: (1) the personal data is no longer necessary for the purposes for which it was collected or processed; (2) you withdraw your consent for data processing based on consent; (3) you object to the processing of personal data; (4) the personal data has been processed unlawfully; (5) the personal data must be erased to comply with a legal obligation incumbent on the Controller.
- Right to restriction of processing, in any of the following situations: (1) you contest the accuracy of the data; (2) the processing of personal data is unlawful, and you do not want the personal data to be erased but request the restriction of their use; (3) the Controller no longer needs the personal data, but you request it for the establishment, exercise, or defense of legal claims; (4) you object to the processing. In case you have obtained the restriction of processing, you will be subsequently informed by us before lifting the processing restriction.
- Right to data portability: The right to receive the personal data concerning you that you have provided to us in a structured, commonly used, and machine-readable format and to transmit those data to another controller when the processing is based on your consent and is carried out by automated means.
- Right to object: The right to object, on grounds relating to your particular situation, to the processing of personal data based on our legitimate interest.
- Right not to be subject to a decision based solely on automated processing, including profiling (any automated processing that uses personal data to evaluate certain personal aspects of you), which produces legal effects concerning you or similarly affects you to a significant extent.
- Right to withdraw consent at any time and without stating any reason.
For further details regarding the processing activities carried out by us, as well as for the exercise of the rights you benefit from in this context, please contact us through an electronic request via email at firstname.lastname@example.org.
Your request will be analyzed, and you will receive a response within 30 days from the receipt of the request by the Controller. In case of complex or numerous requests, this deadline may be extended by two months.
Similarly, you have the right to address the National Supervisory Authority for Personal Data Processing (ANSPDCP), located at B-dul G-ral. Gheorghe Magheru 28-30, sector 1, postal code 010336, Bucharest, by written request at the institution’s headquarters or by email at email@example.com. You also have the right to seek legal remedies to defend any rights guaranteed by applicable personal data protection legislation that have been violated.