PERSONAL DATA PROCESSING POLICY

The purpose of this Policy is to inform you about how STRATEGIC MEDIA TEAM S.R.L. processes personal data when you use the informat.ro website and Application.

Through this Policy, we also inform you about the rights of data subjects in accordance with the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (hereinafter referred to as the GDPR) and the national legislation on the protection and security of personal data, hereinafter collectively referred to as GDPR Legislation.

“Processing” means any operation or set of operations performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.

1. WHO ARE WE?

STRATEGIC MEDIA TEAM S.R.L. is a personal data controller, having its registered office in Bucharest, 71 Buzești Street, 3rd floor, Sector 1, Romania, registered with the Trade Registry Office under no. J40/11526/05.07.2022, Unique Registration Code / VAT no. RO44538282, e-mail address: [email protected].
Within this document, STRATEGIC MEDIA TEAM S.R.L. shall be referred to as “SMT” or the “Controller”.

In accordance with the applicable GDPR Legislation, SMT is obliged to manage personal data securely and only for the specified purposes. SMT processes personal data lawfully, implementing appropriate technical and organizational measures to ensure data integrity and confidentiality, in compliance with GDPR requirements.

2. WHAT PERSONAL DATA DO WE PROCESS? PURPOSES AND LEGAL GROUNDS

In principle, any information that identifies or may identify, directly or indirectly, a natural person is considered personal data. SMT processes the following categories of personal data, as follows:

a) Website operation and improvement

For operating the website, enabling access and use by visitors, and improving the services offered: information automatically transmitted, without user intervention, by the browser of the device used to SMT’s servers (such as the IP address, which is anonymized), as well as data collected through cookies and similar technologies (e.g. pixels), in accordance with the Cookie Policy.

Legal basis: Article 6(1)(a) or (f) GDPR, as applicable.

b) Communication with SMT

For communicating with SMT, including handling requests: first name, last name, phone number, e-mail address, and any other data provided by the data subject in written or verbal communications.

You may contact SMT via the website, telephone, or e-mail.

We may also access social media profiles and process profile data (e.g. username, profile picture, or other information provided to the social network) or your comments when you interact with SMT through such channels (e.g. when you follow or share content on the platforms/applications used).

Legal basis: Article 6(1)(a), (c), or (f) GDPR, as applicable.

c) User account creation and management

For creating, accessing, and managing a user account in the Application and personalizing content: first name, last name, phone number, e-mail address, account password (encrypted), Google or Apple account used for registration, user preferences (e.g. language, preferred news categories), account type (free/paid), subscription details (e.g. payment method, recurrence, value, subscription start/end dates).

When registering or logging in via Google or Apple, you will be redirected to the respective provider and informed about the personal data transmitted to SMT in accordance with their own privacy policies.

Legal basis: Article 6(1)(b) GDPR.

d) Legal obligations

For complying with legal obligations: personal data may be processed, for example, to handle complaints, provide information to competent authorities, or archive documents as required by law.

Legal basis: Article 6(1)(c) GDPR.

e) Legitimate interests

For pursuing SMT’s legitimate interests: administration of SMT’s activity, correspondence, handling complaints, internal records, legal defenses, and document archiving.

Legal basis: Article 6(1)(f) GDPR.

f) Subscriptions and commercial communications

For subscriptions and receiving commercial communications/newsletters (e.g. E-mail Digest): e-mail address and selected language.

Legal basis: Article 6(1)(a) GDPR (consent), in accordance with Law no. 506/2004.

SMT reserves the right to request additional data necessary for carrying out its activity, in compliance with applicable legal provisions.

If you choose not to provide mandatory information, your request may not be completed, and you may not benefit from SMT’s services or website functionalities.

3. WHO ARE THE DATA SUBJECTS?

Within the context of this Policy, data subjects include:
a) visitors/users of the informat.ro website and Application, and social media accounts (e.g. Facebook, Instagram, LinkedIn);
b) persons whose data is provided to SMT by users or other individuals;
c) persons who contact SMT via public channels (e.g. e-mail, phone).

SMT collects personal data either directly from the data subject or indirectly from third parties, including public sources, only where applicable.

If SMT receives personal data about a data subject from another individual or third party, that person is responsible for informing the data subject about such processing.

The website/Application includes social media links but does not use embedded plug-ins. Clicking such links redirects you to the respective platform.
However, certain social media plug-ins may be used to ensure connection with SMT’s official social media pages. SMT does not access or store data collected by these plug-ins.

If you communicate with us via social media platforms, those platform operators process your personal data in accordance with their own privacy policies.

The SMT website also includes an AI-assisted search function that processes only search keywords and does not collect or process personal data. Queries are not linked to user accounts, IP addresses, or other identifiers and are not stored individually. Only aggregated statistics are used. Users are expressly requested not to enter identifying or sensitive data in the search field.

4. HOW LONG DO WE PROCESS PERSONAL DATA?

Personal data is processed for a limited period, depending on the purpose and applicable legal requirements.

Examples:
a) correspondence related to requests is stored for up to 3 years from completion;
b) data processed based on consent is stored for the duration of consent, plus the 3-year limitation period after withdrawal.

After retention periods expire, data is deleted.

5. TO WHOM DO WE DISCLOSE PERSONAL DATA?

Personal data may be disclosed, where applicable, to:

• public authorities and institutions;
• courts of law;
• service providers (IT, hosting, maintenance, legal services, newsletter distribution, analytics).

Subscription payments are handled by Apple Distribution International Ltd. and Google Ireland Limited, acting as independent controllers. SMT receives only limited transaction information.

SMT uses RevenueCat, Inc. as a processor for subscription management.

Analytics tools used include Matomo (anonymous, aggregated data) and Google Analytics.

Website hosting is provided via Amazon Web Services, with data stored in the EU.

Data transfers outside the EU/EEA occur only in compliance with GDPR safeguards.

6. WHAT ARE YOUR RIGHTS AND HOW CAN YOU EXERCISE THEM?

Under Articles 12–22 GDPR, data subjects have the right to:

• access;
• rectification;
• erasure (“right to be forgotten”);
• restriction of processing;
• data portability;
• objection;
• not be subject to automated decision-making;
• withdraw consent at any time;
• lodge a complaint with the national data protection authority or a court.

To exercise these rights, contact:
STRATEGIC MEDIA TEAM S.R.L.,
71 Buzești Street, 3rd floor, Sector 1, Bucharest, Romania
E-mail: [email protected]

SMT will respond within one month, with possible extension in accordance with GDPR