Privacy Policy

This Privacy Policy explains how INITWIN collects, uses, stores and protects personal data when you visit our website, contact us, request a quote, subscribe to commercial communications, or use digital services provided by the company.

We take data protection seriously and apply the principles set out in Regulation (EU) 2016/679 on the protection of personal data (GDPR), as well as applicable national law, including Romanian Law no. 190/2018.

This policy applies to the INITWIN website, contact forms, commercial communications, user accounts and, where applicable, the client portal or other digital services operated by INITWIN.

1. Who we are

The controller of personal data is INITWIN, referred to below as "INITWIN", "we", "the company" or "the controller".

For requests relating to personal data, please use the subject line "Data protection" or "GDPR". We will review your request and respond within the time limits set by applicable law.

• Email: contact@initwin.com
• Contact form: https://www.initwin.com/en/contact

Where INITWIN acts as a software provider for a business client and processes data on that client's behalf, our role may be that of processor, not controller. In such cases, processing is governed by the commercial contract and, where required, by a data processing agreement.

2. When this policy applies

This Privacy Policy applies when you:

• access the INITWIN website;
• read articles on the blog;
• complete the contact form;
• request a quote or a commercial discussion;
• communicate with us by email, phone or other channels;
• subscribe to the newsletter or informational materials;
• create an account or use a client portal;
• interact with digital services operated by INITWIN;
• accept cookies or similar technologies on the site.

This policy does not apply to third-party websites we may link to. Those sites are governed by their own privacy policies.

3. What data we may collect

The data we collect depends on how you interact with us.

3.1. Identification and contact data

• first and last name;
• company name;
• job title or role in the company;
• email address;
• phone number;
• billing details, where a contractual relationship exists;
• other information voluntarily provided via form or email.

3.2. Data submitted through forms

• your message;
• type of service requested;
• project information;
• estimated budget, if you provide it;
• desired delivery timeline;
• attached files or documents, where the form allows this;
• history of subsequent communications.

Please do not send sensitive data or special categories of data through general contact forms unless strictly necessary for your request.

3.3. Account and authentication data

• email address associated with the account;
• password, stored securely, not in plain text;
• user role and permissions;
• login history;
• actions performed in the account;
• documents, tickets, projects or communications linked to the account.

3.4. Newsletter and commercial communications data

• email address;
• name, if you provide it;
• subscription date;
• subscription source;
• communication preferences;
• statistics on email opens or link clicks, if we use email marketing tools and where consent is required.

You may unsubscribe at any time using the unsubscribe link in emails or by sending a request to our contact address.

3.5. Technical data

• IP address;
• browser type;
• operating system;
• device used;
• browser language;
• pages accessed;
• date and time of access;
• traffic source;
• security logs;
• cookie identifiers.

This data is used for site operation, security, technical diagnostics, abuse prevention and, if you give consent, traffic analytics.

4. Purposes of data processing

We process personal data for clear and legitimate purposes.

4.1. Responding to enquiries

We use data submitted via forms, email or phone to answer your questions, review a commercial request or prepare a quote.

4.2. Providing services

If you become an INITWIN client, we use the data needed to manage the contractual relationship, project communication, service delivery, support, invoicing and documentation.

4.3. Managing accounts and the client portal

Where a client portal is active, we use data for authentication, access management, and displaying relevant projects, documents, tickets or communications.

4.4. Website and application security

We use technical data, logs and authentication information to protect the site, accounts and our systems against unauthorised access, spam, cyber attacks, fraud or other abusive activity.

4.5. Marketing and commercial communications

With your consent, we may send newsletters, articles, news, invitations or information about INITWIN services. In certain B2B cases, we may send relevant commercial communications based on legitimate interest, with the right to object or unsubscribe.

4.6. Analytics and service improvement

We may use aggregated or statistical data to understand how the site is used, which pages are accessed and how we can improve the user experience.

4.7. Legal obligations

We process certain data to comply with legal obligations regarding accounting, taxation, archiving, responses to authorities or defence of our rights.

5. Legal bases for processing

We process personal data only when we have a valid legal basis.

6. Who we may share data with

Personal data may only be accessed by people or providers who need it for the purposes described in this policy.

We may share data with:

• authorised INITWIN staff;
• hosting and infrastructure providers;
• transactional email providers;
• backup and monitoring providers;
• traffic analytics services, only under permitted conditions;
• IT security providers;
• legal, accounting or tax advisers;
• public authorities, where there is a legal obligation;
• contractual partners, only when necessary to provide services.

We do not sell your personal data to third parties.

When we use providers that process data on our behalf, we ensure contractual obligations regarding confidentiality, security and compliance with applicable data protection law.

7. Transfers outside the European Economic Area

Where possible, we use providers that process data in the European Union or the European Economic Area.

If data is transferred to countries outside the European Economic Area, we ensure appropriate safeguards are in place, such as:

• European Commission adequacy decisions;
• standard contractual clauses;
• mechanisms recognised by applicable law;
• additional technical and organisational measures, where appropriate.

You may request further information about international data transfers using the contact address indicated in this policy.

8. How long we keep data

We keep personal data only as long as necessary for the purposes for which it was collected or as required by law.

Indicative retention periods may include:

• form or email enquiries: up to 24 months from the last interaction, if no contract is concluded;
• contractual data: for the duration of the contract and thereafter as required by law;
• tax and accounting documents: in line with applicable legal time limits;
• user accounts: for the duration of account use and a reasonable period after deactivation;
• newsletter: until unsubscribe or withdrawal of consent;
• technical logs: usually between 30 and 90 days, except where needed for security investigations;
• cookie preferences: as stated in the Cookie Policy.

When retention periods expire, data is deleted, anonymised or securely archived, as appropriate.

9. How we protect data

We apply technical and organisational measures to protect personal data against unauthorised access, loss, alteration, disclosure or accidental destruction.

These measures may include:

• encryption of communications via HTTPS/TLS;
• secure password storage;
• role-based access control;
• protected authentication and sessions;
• regular backups;
• technical monitoring;
• protection against abuse and automated attacks;
• logging of relevant actions;
• limiting internal access to data;
• training for people who may access data;
• security updates and measures applied to infrastructure.

No computer system can guarantee absolute security. If you suspect a security issue or unauthorised access to your data, please contact us as soon as possible.

10. Cookies and similar technologies

The site may use cookies and similar technologies for:

• technical operation of the site;
• storing preferences;
• security;
• traffic analytics;
• improving the user experience;
• communications and marketing, where applicable.

Strictly necessary cookies may be placed without consent because they are required for the site to function. Analytics, marketing or other non-essential cookies are used according to your choices.

You can change your cookie preferences from the banner or settings panel available on the site.

For further details, see the Cookie Policy.

11. Your rights

As a data subject, you have the following rights, subject to applicable law:

• the right of access to your personal data;
• the right to rectification of inaccurate or incomplete data;
• the right to erasure of data, in certain conditions;
• the right to restriction of processing;
• the right to data portability;
• the right to object to certain processing;
• the right to withdraw consent, where processing is based on consent;
• the right not to be subject to a decision based solely on automated processing that produces legal or similarly significant effects;
• the right to lodge a complaint with the National Supervisory Authority for Personal Data Processing. (www.dataprotection.ro).

To exercise your rights, you may contact us at the email address indicated above. contact@initwin.com. To protect your data, we may request additional information to verify your identity before responding to a request.

12. Automated decisions and profiling

On the public website, we do not use your data for decisions based solely on automated processing that produce legal effects on you or similarly significantly affect you.

If we introduce such processing in the future, we will update this policy and provide the information required by applicable law.

13. Children's data

The INITWIN website and services are intended primarily for professionals, companies and people seeking digital or software services.

We do not intentionally collect personal data from minors through the public website. If you learn that a minor has sent us personal data without parental or legal guardian consent, please contact us so we can review the situation and, where appropriate, delete the data.

14. Links to third-party sites

The INITWIN website may contain links to external sites, articles, documentation, social networks, partners or other resources.

We do not control the privacy policies of those sites and are not responsible for how they collect or use personal data. We recommend reviewing their privacy policies before providing data.

15. Processing within software projects

INITWIN develops software solutions, web applications, databases, integrations, reporting systems, dashboards and other digital products for business clients.

Within these projects, INITWIN may process personal data on behalf of the client. In such cases, the client is usually the data controller and INITWIN acts as processor, in accordance with the client's instructions and contractual provisions.

For such projects, details on data categories, purposes, duration, security measures and party responsibilities are set out in the contract and, where required, in a data processing agreement.

16. Changes to this policy

We may update this Privacy Policy when legislative, technical, operational or commercial changes occur.

The updated version will be published on this page and will include the date of the last update. For important changes, we may display a notice on the site or, where appropriate, send information by email.

We recommend checking this page periodically to stay informed about how we protect personal data.

17. Contact

For questions about this Privacy Policy or to exercise your data protection rights, you may contact us using the details above.

• Email: contact@initwin.com
• Contact form: https://www.initwin.com/en/contact

Related documents: Cookie Policy · Terms & Conditions Manage cookie preferences