Privacy Policy

Version of 9 October 2026

1. Who processes your data

We are three independent developers from Moldova who work together. There is no separate company behind the site: the three of us are joint controllers of your data, and each of us is registered separately as an activitate independentă — the Moldovan legal form for a self-employed individual:

• Nicu Emilian, IDNO 1026023009384
• Nicu Andrei, IDNO 1026023002972
• Mladin Dumitru, IDNO 1026023009395

Joint responsibility means this: we decide together why and how the enquiries from the site are processed — and we answer for that decision together as well. You may exercise your rights in relation to any one of us, but the simplest way is to write to the shared address [email protected]: all three of us receive the message and we handle the request jointly. The same address is the place for any questions about this policy.

We have no office you could walk into — we work remotely, so the only address for reaching us is the email one. The full registered address of any of us we will provide on request sent to that same address.

We are registered in Moldova, outside the European Union, and we have not appointed a representative in the EU. The site receives only what you write in the form yourself — a name, an email address, the text of your message and a site address, if you give one; there are few such enquiries, none of them involve special categories of data, and the processing does not create a noticeable risk for you. Should that change, we will appoint a representative and name them here.

2. What data we receive

When you write to us through the form

Your name, email address, the text of the message and the site address, if you gave one — what you entered yourself. Stored alongside them are the date of sending, the page you wrote from, the language of the page and a technical record of your consent.

We do not store your IP address in the clear: it is turned into an irreversible hash and used only to limit the number of submissions from one address and to cut off automated mailings.

When you are simply reading the site

The server records the usual technical details of the request — they are needed for the site to work and for a failure to be traced. No separate visitor profile is built from them.

Everything to do with measuring traffic and recording behaviour is described on the cookie page and is switched on only with your consent.

3. Why, and on what legal basis

• To answer your enquiry — because you approached us yourself. Basis: steps prior to entering into a contract, and our legitimate interest in replying to those who write.
• To keep the form from being used by automated mailings — legitimate interest: without this the form stops working for people.
• To measure traffic and analyse behaviour on the site — only on the basis of your consent, which you give in the cookie bar and can take back at any moment.

4. Who we share data with

We do not sell your data and do not pass it to third parties for their own purposes. But for the site to work, part of the data goes through services we use:

• Telegram (Telegram Messenger Inc.) — enquiries from the form reach us there as a notification. The name, the address, the message text and the site address, if given, pass through the service.
• Google (reCAPTCHA) — tells a human from a program when the form is submitted. Google receives technical data about your browser and your interaction with the page.
• Google (Analytics) — traffic measurement. It is loaded only after your consent in the cookie bar. Advertising signals are switched off: your data is not used to personalise ads.
• Microsoft (Clarity) — session recordings and heatmaps. It is loaded only after your consent in the cookie bar; before that no request is made to Microsoft. Form fields are masked in the recordings.
• Cloudflare — the site is served through their network, so requests pass through their servers.
• Our server — Moldtelecom S.A., Moldova. The enquiries from the form and the technical logs are kept there.

Traffic-measurement services are listed separately, on the cookie page: some of them work always, because they do not identify you, others only after consent.

5. Transfers outside your country

We ourselves are in Moldova, and so is the site’s server: an enquiry from the form comes straight to us and is kept there. This does not count as a transfer outside the EEA within the meaning of Chapter V of the GDPR — you disclose the data directly to us, not to someone in the Union who would then pass it on (European Data Protection Board, Guidelines 05/2021).

The services that the data passes through are located outside the EEA, and each has its own legal ground:

• Telegram — the data of people in the EEA and the UK is kept by the company in data centres in the Netherlands, that is, inside the Union. It has appointed a representative in the EU: the European Data Protection Office, Brussels.
• Google (reCAPTCHA, Analytics) — certification under the EU-U.S. Data Privacy Framework and, where the framework does not apply, the European Commission’s standard contractual clauses.
• Microsoft (Clarity) — certification under the EU-U.S. Data Privacy Framework and standard contractual clauses. For people in the EEA, Microsoft’s controller is its Irish entity, Microsoft Ireland Operations Limited.
• Cloudflare — standard contractual clauses and, for transfers to the United States, certification under the EU-U.S. Data Privacy Framework as well.

6. How long we keep it

• Enquiries from the form — we keep them for as long as a conversation about work is still possible, and delete them at your request. If a contract has grown out of the correspondence, the period is determined by the contract and by accounting requirements.
• The record of your consent — as long as the submission itself: without it we could not show that consent was given.
• The server’s technical logs — about a month: they are rotated once a week, and nothing older than five weeks stays on the server.

7. Your rights

If you are in the European Economic Area or in the United Kingdom, you have the right to:

• find out what data of yours we hold and receive a copy of it;
• correct inaccurate data;
• demand erasure;
• restrict the processing or object to it;
• receive your data in a machine-readable form and pass it on to someone else;
• withdraw consent — this does not make unlawful what was done before the withdrawal;
• lodge a complaint with the data protection supervisory authority in your country.

To exercise any of them, write to [email protected]. We reply within a month.

8. Changes

If the policy changes, we will update the date at the top of the page. Substantial changes affecting data already collected are not applied retroactively.

Related documents: consent to data processing and the cookie notice.