Privacy and personal data protection policy
For us, the privacy and security of personal data is one of the company's main concerns. In this context, we have implemented measures that comply with the obligations imposed by Regulation 679/2016 (GDPR). As such, we want to assure you of the highest standards of security and transparency regarding the personal data we process in our day-to-day business. As the processing of your personal data is important in our business of providing website creation, implementation and management services we guarantee that it will be processed in compliance with the principle of transparency and security of personal data. This privacy policy aims to understand what data we collect, why we collect it and what we do with it. We have formulated this policy in the simplest possible language so that it is clear and understandable to you. The controller of personal data in relation to you is the company Authorised Natural Person registered under number F12/149/2023 and CUI 47517420. 

Categories of data we process
1. If you are a simple visitor to https://www.pinkleadtech.com we will only process data consisting of cookies. 
2. If you are a natural person customer or a representative of a legal person customer who contacts us via the https://www.pinkleadtech.com website, we will process your personal data consisting of: name, surname, telephone number, e-mail address, city, country, as well as any other data provided as a result of filling in the online form in the contact form section or by e-mail.
3. If we enter into a contract or agreement with you, regardless of its category, we will process your data consisting of your name, surname, telephone number, e-mail address, city, country, as well as any other data contained in the contract signed by the parties or billing information at the time of signing the agreement between the parties.

Purpose of data processing
We use the information we collect from you in order to communicate the requested information, provide contracted services and conclude contracts necessary for recurring business. We will process your data differently depending on which category you fall into: 
a) you only use the contact form or send an email to one of the contact addresses. To the extent that you use the contact form or send us an email, your data may be used to be able to provide you with the requested information about our services and to be passed on to our collaborators in order to provide you with contractual conditions. We process your personal data on the basis of your consent only if you have given your consent - for the communication of newsletters, services, news, etc. We may also process your data in order to comply with legal obligations imposed on us;
b) you enter into a service contract with us. To the extent that you sign a contract, we will use your personal data for the purpose of providing the agreed services. The processing of your data insofar as you are our customer will be carried out for the following purposes:
- Management of negotiations, pre-contractual phases and for the fulfilment of obligations under the contract and the provision of services.
- For the purpose of communicating with you, in order to keep you constantly informed about the status of the requested service and the degree of fulfilment Management and administration of the contractual or pre-contractual relationship between you and us;
- For the fulfilment of our obligations arising from the services provided under the contract concluded between us;
- For the purpose of communicating them to be contacted by our employees or collaborators, solely for the purpose of providing the contracted services.
- For any other purpose ancillary to the above, or for any other purpose for which personal data has been provided to us, in compliance with the relevant legislation.

c) We are obliged to always ask for your consent before using the information for a purpose other than that set out in this document.

Update your personal information
If the personal information you have provided to us is incorrect or changes, such as: you have changed your phone number, name, email address, or if you wish to delete any request made to us or you know that we have incorrect information about you, please contact us by email at: hello@pinkleadtech.com  to update/change your information.
To the extent that any alteration of data occurs due to incorrect, incomplete or insufficient data being provided, we will not be liable.

Disclosure of personal data
Information provided by you is not normally disclosed to third parties, except to collaborators we work with, especially on the design, web development and IT side. If there are situations where we are legally obliged to disclose your data then it will be passed on strictly for the purpose of fulfilling this obligation. Where the transfer may be necessary for the performance of a commercial/contractual relationship, the data will only be transferred following the conclusion of an agreement with the third party containing a data processing agreement.

Retention period of your personal data
Insofar as you are a customer, certain data such as: name, surname, home address, business address, telephone, e-mail, telephone number, other contact data or data inserted in invoices we keep for a period of 10 years, based on Article 25 of Law 82/1991 of the applicable Romanian legislation.To the extent that you are a customer or just a visitor to the site, cookie data is processed for the purpose of analysing how to improve our site, for a period not exceeding 2 years. You can always delete cookie data via your web browser settings. For more details please see the Cookie Privacy Policy available on the website.

Your rights in relation to the processing of personal data:
If you have given your consent to processing activities, you may withdraw your consent at any time. This withdrawal will only take effect for the future and will not affect the lawfulness of the processing prior to the withdrawal. Withdrawal of consent may not operate where the processing of your data is carried out on the basis of a legal obligation incumbent on us.To the extent that your consent is withdrawn, we will prohibit the processing of your personal data and will take all steps to delete all records containing such data. In accordance with the legal provisions, you have the following rights:

- Right of access- the right to obtain from us, upon request and free of charge, confirmation as to whether or not data concerning you is being processed by the company and the right of access to such data, unless such requests are repetitive or made in bad faith;
- Right to information - the right to be informed of the identity of the controller, the purpose for which the data is processed, the recipients or categories of recipients of the data, the existence of the rights provided for in the GDPR and the conditions under which they can be exercised
- The right to rectification - you can ask for inaccurate personal data to be rectified.
- Right to erasure of data ("right to be forgotten") - you can obtain erasure of data if the processing was unlawful or in other cases provided for by law;
- Right to restriction of processing - you can request restriction of processing if you contest the accuracy of the data and in other cases provided for by law;
- Right to object - the right to object at any time, on justified and legitimate grounds related to the data being processed, unless otherwise provided for by law;
- The right to data portability - you can receive, under certain conditions, the personal data you have provided to us, in a machine-readable format or you can request that those data be transferred to another controller
- The right to lodge a complaint - you can lodge a complaint about the way personal data is processed with the competent National Supervisory Authority for Personal Data Processing or you can apply to the courts.
- The right not to be subject to automated decisions or further profiling related to automated decisions - the right to request and obtain the withdrawal, annulment or review of any decision which produces legal effects, taken solely on the basis of the processing of personal data, carried out by automated means, intended to evaluate certain aspects of one's personality, such as professional competence, credibility, conduct or other such aspects;

To exercise any of your rights please contact us using the following contact details if you wish to exercise the above rights:
E-mail: hello@pinkleadtech.com 

We undertake to consider for resolution any request or complaint or petition received and to respond within a reasonable time so that the relevant legal provisions are respected. We work with the relevant regulatory authorities, including the national data protection authorities of the Member States of the European Union, to resolve any complaints about the transfer of personal data that we cannot resolve directly with our users.

The deadlines for responding to requests for these rights will be as follows:
- Right to be informed: at the time the data are collected, i.e. no more than one month - if personal data are not provided by the data subject
- Right of access: no longer than one month
- Right to rectification: no later than one month
- Right to erasure: without undue delay, no longer than one month 
- Right to restrict processing: without undue delay, maximum two weeks
- Right to portability: maximum one month
- Right to object: in principle at the time of receipt of the objection, but no more than 5 working daysRight not to be subject to automated decisions or additional profiling related to automated decisions: No time limit as there is no real ability to be restricted in relation to the specifics of the activity

Security of personal data
We follow the highest standards to protect the data processed, both during transmission to us and afterwards. To this end we have adopted technical security policies and procedures to protect personal data against loss, unauthorised use, destruction, alteration, unauthorised modification, unauthorised disclosure or access and any other form of unlawful processing of personal data in our possession.In order to ensure security, we mention, in general terms, the methods of security: 
Access to personal data is limited and authorized only to persons who have the legal right to use it, who are responsible for ensuring the confidentiality of the data, such as our administrator, accountant and lawyer. Access to areas or premises storing personal data is secured by physical means to which only persons designated by the company have access (key secure areas) or electronic means, i.e. password and username protection. We avoid as far as possible storage on physical media.We use techniques for the security of your electronically stored data 
Data held for one client will be kept separate from another client's data
No employee who comes into contact with personal data or documents containing such data has the possibility to disclose such data to third parties, having specific contractual clauses with them.Minimum security measures to be applied by all company representatives, employees and collaborators Prohibition to disclose the password to other persons, i.e. prohibition to use the account for business purposes by more than one person;
Prohibition to save the password both in physical and electronic format;

If you believe that your personal data has been compromised, please contact us in writing by e-mail: hello@pinkleadtech.com 

In the event of a breach of the security system, we will inform both you and the competent authorities about the occurrence of the breach in accordance with the legislation in force, within 72 hours at the latest, within which time we will communicate to you the relevant information related to the security incidents.

Final provisions
Our privacy policy applies to all services offered by us.
Our privacy policy may change from time to time, but we undertake not to reduce your rights under such changes without your explicit consent, unless they would result from the application of another basis for lawful processing.
Any changes to the privacy policy will be published and posted in conspicuous places so that updates can be easily identified and its contents readily available. We will also keep previous versions of this Privacy Policy in our electronic archive for your review at any time upon request.

This Privacy Policy is effective as of 1.01.2023