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Privacy Policy

1. Introduction

1.1. This website (transylvanian.software) (Site) is owned and operated by QuickWeb Info SRL (Transylvanian Software, TS, we or us), a company organized under the laws of Romania, with a registered address at Bucharest, Romania.

1.2. We are committed to protecting your privacy, keeping your information secure and managing it in accordance with our legal responsibilities under the applicable privacy and data protection laws, including the Privacy Act 1988 (Cth) and General Data Protection Regulation (EU 2016/679) (GDPR) (collectively, Privacy Laws).

1.3. Our Site provides a range of products and services for you to use. When providing our Services to you, we collect information (including Personal Information) about you.

1.4. This Privacy Policy outlines how and when we collect, process, use, share, store, disclose, alter and destroy your Personal Information and applies to all Personal Information we collect through our Site and through other channels as described below.

1.5. For the purpose of this Privacy Policy, Transylvanian Software is a Data Controller. A Data Controller means the natural person or the legal entity which, alone or jointly with others, determines the purposes and means of the processing of Personal Information.

1.6. By accessing or using the Site or any of our products or services, you indicate that:

  • you have read and understood this Privacy Policy; and

  • you agree that your access to, or use of, the Site or any of our Services indicates your consent to this Privacy Policy.

1.7. For the purposes of this Privacy Policy, when we refer to you we mean any past, current or prospective customer of Transylvanian Software, including any visitor to one of our Sites.

2. Types of personal information we collect

2.1. Personal Information (or Personal Data under the GDPR) means any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;

2.2. Transylvanian Software collects and uses Personal Information from customers, authorized users or visitors of the Site, purchasers of our Services, and any other individual who interacts with us.

2.3. Transylvanian Software collects and uses different types of Personal Information depending on the type of dealing you have with us, which may include:

  • your name, address, telephone number, email address, job title and occupation;

  • business details (such as the Customer’s business name, address, telephone number and email address);

  • information about the IT Services you order or enquire about, including how the products or services are used;

  • information relating to your Site account, including your username and password;

  • your financial information (such as credit card and bank account details), method of payment and any additional information required for user authentication processes; and

  • any other information relating to you that you provide to us, including the information you provide by email or telephone, or through surveys, competition forms, at special events and other promotional activities;

  • information regarding your access and use of our Site, including location information, IP address, mobile or device system used, IT Services you viewed or searched for, length of visits to certain pages, page interaction information, types of web browsers used to access the Site and any third party websites you access;

2.4. Sensitive Information (or Sensitive Personal Data under the GDPR) means Personal Information concerning an individual's racial or ethnic origin, political opinions, religious or philosophical beliefs, or a trade-union membership, sexual orientation or practices, health or biometric information or criminal record.

2.5. Transylvanian Software does not intend to collect your Sensitive Information. However, some of our products or services are automated and we may not recognize that you have accidentally provided us with Sensitive Information.

2.6. We also do not knowingly seek or collect Personal Information or Sensitive Information from Children (see below).

2.7. If you have accidentally sent us Sensitive Information, please contact us using the details below.

3. Method of collection

3.1. Transylvanian Software collects your Personal Information in several ways, including:

  • through your use, or orders, of our IT Services (and our records of these);

  • automatically when you visit the Site or submit information through the Site, contact us by email, telephone or other device, or complete any forms or documents or request information about our IT Services;

  • when you submit a request for customer support;

  • when you participate in our surveys, competitions, promotions, questionnaires or other promotional activities;

  • from third parties (for example, the name of the person who referred you to us, the names and contact information for people you refer to us);

  • when you post, publish or submit comments, reviews, or testimonials about our Transylvanian Software and our IT Services on our Site, on social media (including blogs, chat groups, bulletin boards or forums) or other marketing channels; 

  • from publicly available sources of information.

3.2. The Personal Information we collect will track and enhance your use of the Site, and assist us in providing a better service to you.

3.3. Transylvanian Software will only collect Personal Information that is necessary for one or more of our functions or for a purpose outlined in this policy or otherwise disclosed to you. By providing your Personal Information to us, you acknowledge that you are authorized to provide such information to us.

3.4. Except where Personal Information is collected by automatic means, when we collect Personal Information directly from you, we will take reasonable steps to notify you (using a collection notice) at, before, or as soon as practicable after, the time of collection.

3.5. When we collect your Personal Information from your authorized representative, we will take reasonable steps to make sure you are aware of the collection.

3.6. If you provide us with Personal Information about another individual (as their authorized representative), we rely on you to:

  • inform them that you are providing their Personal Information to us; and

  • advise them that they can contact us for further information.

3.7. You must take reasonable steps to ensure the individual is aware of, and consents to, the matters outlined in this Privacy Policy, including that their Personal Information is being collected, the purposes for which that information is being collected, the intended recipients of that information, the individual's right to access that information, and who we are and how to contact us.

3.8. Upon our request, you must also assist us with any requests by the individual to access or update the Personal Information you have collected from them and provided to us.

4. Legal basis for processing personal information (EU Only)

Transylvanian Software relies on several legal bases under the GDPR to collect, process, store, use and disclose the Personal Information of individuals residing in the European Union (EU), including:

4.1. where you have freely and expressly consented to the collection, use, storage, processing and disclosure of your personal information for a specific purpose. The provision of Personal Information to us is voluntary. However, if you do not provide your Personal Information to us, we may not be able to provide you with access to, and use of our Site. You may withdraw your consent at any time by contacting us using the details below;

4.2. where the collection, use, storage, processing and disclosure of your Personal Information is necessary for the performance of a contract to which you are a party. For example, when collection and use is necessary to fulfil our obligations to provide you with access to, and use of our  Site;

4.3. for our legitimate business interests, including, but not limited to:

  • providing, operating and improving our Site;

  • marketing new promotions, deals, offers, competitions, products, services provided by us or our Authorized Affiliates that we consider may interest or benefit you;

  • managing, analyzing, understanding and developing our relationship with you; and

  • responding to your queries or complaints;

4.4. where there is a legal obligation to collect, use, store, process or disclose your Personal Information. For example, we may be obliged to disclose your Personal Information by reason of any applicable law, regulation or court order and/or to protect our interests and legal rights.

5. How we use your Personal Information

5.1. Transylvanian Software only uses, processes and discloses your Personal Information for the purposes for which it is collected. We do not sell your Personal Information to any third party. In particular, we use and process your Personal Information to:

  • provide you with our Services, or the Site;

  • improve, develop and manage our Services and the Site;

  • operate, maintain, test and upgrade our systems and Site;

  • notify you of opportunities we think you might be interested in, including new Services, other related product or service offerings and updates relating to suspicious and malicious activity;

  • manage your Site account (for example, managing your subscription or other registration to provide you with IT Services, providing information related to your purchase, use, payments and invoices, and contacting you about your purchase);

5.2. Transylvanian Software may also use and process your Personal Information:

  • to customize the advertising and content on our Site, or on any of our social media channels;

  • to provide information that we think may interest or benefit you, including information about our Services, the Site, offers, competitions, promotions, events and surveys

  • to charge and bill you for accessing and using our Services;

  • to verify your identity

  • to perform research and analysis about our Services and the Site;

  • to comply with regulatory or other legal requirements,

  • for any purpose to which you have consented and

  • for any other purpose notified to you at the time of collection.

5.3. With your consent, Transylvanian Software may provide your Personal Information to:

  • our employees, related entities, business partners, third party contractors, suppliers and agents from time to time for the purpose of delivering, providing and administering our Site; and

  • third party service providers who process or use your Personal Information for the purpose of performing functions on our behalf, but may not process or use such information for any other purpose. Examples of these third-party service providers include, but are not limited to, such as marketing and analysis organizations, financial and credit card institutions or third party payment processors to process payments, hosting companies, web developers, internet service providers, customer service providers, customer support specialists, fulfilment companies, external business advisors (including auditors and lawyers), our insurer, and research and data analysis firms, (collectively, Authorised Affiliates).

  • When we disclose your Personal Information to any of our Authorized Affiliates, we will ensure that they undertake to protect your privacy. These Authorized Affiliates are not permitted to use the information for any purpose other than the purpose for which they have been given access.

  • Our Authorized Affiliates may also provide us with Personal Information collected from you. If you disclose Personal Information to an Authorized Affiliate, we rely on you to provide the Authorized Affiliate with consent for us to collect, store, use, process and disclose your Personal Information.

  • We may also disclose any Personal Information we consider necessary to comply with any applicable law, regulation, legal process, governmental request or industry code or standard.

5.4. We use third party payment processors to process payments made to us. In connection with the processing of such payments, we do not collect, process, use, share, store or disclose any Personal Information or payment information (such as credit card and bank account details). Rather, all such information is provided directly to our third party processor, Stripe, Braintree, and Chargify, whose use of your Personal Information is governed by their privacy policy, which may be viewed at:

https://stripe.com/privacy

https://www.braintreepayments.com/legal/data-protection-addendum

https://help.chargify.com/my-account/gdpr.html

6. Overseas disclosure

6.1. Our Authorized Affiliates may be located in or outside Romania, including in the United States of America and other countries from time to time, whose laws are not recognized by the European Commission as providing an adequate level of protection to Personal Information.

6.2. Where Transylvanian Software do transfer your Personal Information to our overseas Authorized Affiliate, we take steps reasonably necessary to ensure that:

  • there is a legal basis for the transfer of your Personal Information; and

  • your Personal Information is treated securely (including, using reasonable endeavors to ensure that each overseas Authorized Affiliate receiving your Personal Information are bound by Standard Contractual Clauses approved by the European Commission, which can be found at http://ec.europa.eu/justice/data-protection/international-transfers/transfer/index_en.htm )

6.3. By accessing or using our Site, or providing your Personal Information to us, you explicitly and freely consent to the transfer of your Personal Information to our overseas Authorized Affiliates

6.4. If you do not wish to receive information from any of our Authorized Affiliates, please let us know using the details below.

7. Disclaimer

7.1. Transylvanian Software will not disclose your Personal Information to any third party (other than our Authorized Affiliates) without your written consent, unless:

  • we are otherwise required by the relevant Privacy Laws;

  • we are permitted to under this Privacy Policy; or

  • such disclosure is, in our opinion, reasonably necessary to protect our rights or property, avoid injury to any person or ensure the proper functioning of the Site.

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7.2. This Privacy Policy only covers the use and Personal Information we collect from you. The use of your Personal Information by any third party is governed by their privacy policies and is not within our control.

8. Storage and security

8.1. Transylvanian Software takes reasonable steps in the circumstances to keep your personal information safe. We use a combination of technical, administrative, and physical controls to protect and maintain the security of your Personal Information.

8.2. Our officers, employees, agents and third-party contractors are expected to observe the confidentiality of your Personal Information.

8.3. Wherever possible, we procure that Authorized Affiliates who have access to your Personal Information take reasonable steps to:

  • protect and maintain the security of your Personal Information; and

  • comply with the relevant Privacy Laws when your accessing and using your Personal Information.

9. No guarantee and destruction of Personal Information

9.1. The transmission of information via the internet is not completely secure. While we do our best to protect your personal information, we cannot guarantee the security of any Personal Information transmitted through the Site or via any social media channels.

9.2. You provide your Personal Information to us at your own risk and we are not responsible for any unauthorized access to, and disclosure of, your Personal Information.

9.3. Transylvanian Software will destroy or de-identify Personal Information where it is no longer required, unless we are required to retain the information for legal, business or tax purposes or as otherwise authorized by law.

10. Suspected data security

10.1. Transylvanian Software has a comprehensive data breach notification policy and response plan (Response Plan), which outlines the steps our personnel are required to take in the event of a data breach. This allows us to identify and deal with a data breach quickly to mitigate any harm that may result.

10.2. As part of the Response Plan, Transylvanian Software will notify you as soon as practicable if we:

  • discover or suspect that your Personal Information has been lost, accessed by, or disclosed to, any unauthorized person or in any unauthorized manner;

  • believe that you are likely to suffer serious harm as a result; and

  • are unable to prevent the likely risk of harm.

10.3. If you would like more information about our Response Plan, please contact us using the details below.

11. Direct marketing

11.1. At the time of accessing, or using, our Site or otherwise from time to time, we may seek your express consent, by requesting that you tick the appropriate check box when providing us with your personal information, for us to send you marketing or promotional materials and other information.

11.2. Where we have obtained your prior consent or are otherwise permitted under the GDPR, we may, from time to time, use your Personal Information to send you information about the promotions, deals, competitions or other products or services we offer, and any other information that we consider may be relevant to you.

11.3. These communications may continue, even after you stop using our Services. We may send this information to you via the communication channels specified at the time you provide your consent.

11.4. These communication channels may include mail, email, SMS telephone, social media or by customizing online content and displaying advertising on our Site or social media channels. You can opt out of receiving these communications by:

  • contacting us using the details below; or

  • using the unsubscribe function in the email or SMS

11.5. You may re-subscribe at any time by re-registering on, or via, the Site.

12. Third party websites

12.1. Links to other websites or social media platforms from the pages on this Site are for your information and convenience only. In providing a link we do not endorse, and accept no responsibility for any material on any website or social media platform that is linked from, or that links to this Site. Such websites or social media platforms may be controlled or produced by third parties.

12.2. You must make your own decision to use such websites or social media platforms and to accept their terms of use and privacy and other policies. We have no control over its use and you should exercise caution when deciding to disclose your Personal Information.

13. Cookies

13.1. Transylvanian Software may collect information when you access and use our Site by utilizing features and technologies of your internet browser, including cookies, embedded web links and similar technologies. A cookie is a piece of data that enables us to track and target your preferences.

13.2. Please see our Cookie Policy for more information regarding the use of cookies and other technologies described in this section.

14. Your rights in relation to privacy (EU only)

14.1. Under the GDPR, you have a number of important rights. Subject to certain exceptions, you have the right to:

  • fair and transparent processing of your Personal Information and processing in accordance with the GDPR;

  • require us to rectify or correct any Personal Information we hold about you that is inaccurate or incomplete;

  • require us to erase your Personal Information in certain situations;

  • obtain a copy of your Personal Information in a commonly used electronic format so that you can manage and move it, or request we send it to a third party;

  • object or withdraw your consent at any time to the collection, use, processing or disclosure of your Personal Information (including for direct marketing purposes), but this does not:

    1. apply where we have other legal justifications to continue to collect, use, process or disclosure your Personal Information; or

    2. affect the lawfulness of any collection, use, processing or disclosure that occurred before you withdraw your consent;

  • object to decisions being made by automated means which produce legal effects concerning you or significantly affecting you; or

  • otherwise restrict our collection, use, processing or disclosure of your Personal Information in certain circumstances.

14.2. You can exercise any of these rights by contacting us using the details below.

15. Access rights (EU)

15.1. Transylvanian Software will use our reasonable endeavors to keep your Personal Information accurate, up-to-date and complete.

15.2. You have the right to access any Personal Information we hold about you, subject to some exceptions provided by relevant Privacy Laws.

15.3. You can access, or request that we correct, your Personal Information by writing to us using the details below. We may require proof of identity.

15.4. If we do not allow you to access any part of your Personal Information, we will tell you why in writing.

15.5. Transylvanian Software will not charge you for requesting access to your Personal Information but may charge you for our reasonable costs in supplying you with access to this information.

15.6. Transylvanian Software will endeavor to respond to your request for access or correction within 1 month from your request.

16. Children's policy

16.1. Transylvanian Software does not knowingly seek, collect or process Personal Information from or about persons under the age of 18 years of age (Children) without the consent of a parent or guardian.

16.2. If we become aware that any Personal Information relating to a Child has been provided without the consent of a parent or guardian, we will use reasonable endeavors to:

  • delete the Personal Information from all relevant files as soon as possible; or

  • ensure, where deletion is not possible, that the Personal Information is not used further for any purpose or disclosed further to any Authorized Affiliate.

16.3. Any parent or guardian with queries regarding our collection, use, processing or disclosure of Personal Information relating to their Child should contact us using the details below.

17. Changes to the policy

17.1. Transylvanian Software may amend this Privacy Policy from time to time at our sole discretion.

17.2. Any revised Privacy Policy will be posted on our Site and effective from the time of posting.

Your continued use of our Site following the posting of any revised Privacy Policy indicates your acceptance of the changes to the policy.

You should regularly check and read the Privacy Policy.

18. Complaint

18.1. If you have any issues about this policy or the way we handle your personal information, please contact us using the details below and provide full details of your complaint and any supporting documentation.

18.2. At all times, privacy complaints:

  • will be treated seriously;

  • will be dealt with promptly;

  • will be dealt with in a confidential manner; and

  • will not affect your existing obligations or your commercial arrangements with us.

18.3. Our Privacy Officer will endeavor to:

  • respond to you within 21 business days; and

  • investigate and attempt to resolve your concerns within 30 business days or any longer period necessary and notified to you by our Privacy Officer.

18.4. If you are dissatisfied with the outcome of your complaint, you may refer the complaint to the lead supervisory authority in the relevant EU member state. The supervisory authority in Romania is The National Supervisory Authority For Personal Data Processing who may be contacted at anspdcp@dataprotection.ro ,Tel. +40.318.059.211 or any other channels as updated at https://dataprotection.ro.

19. Contact us

You can contact us using the following details: