1. Data controller
This policy describes how ProComm Systems SRL processes personal data obtained through the website, contact forms, commercial communications and interactions with prospective clients, clients, partners or their representatives.
2. Data we process
Depending on your interaction with the website or the company, we may process the following categories of data:
- Identification and contact data: name, company, role, email address, phone number, city and messages sent through the form or email.
- Commercial and contractual data: information necessary for quoting, negotiation, service delivery, invoicing, payments, support and maintenance.
- Technical data: IP address, access date and time, browser/device identifiers, pages visited, traffic source, technical and security logs.
- Communication-derived data: request content, correspondence history, feedback, complaints or support requests.
We do not ordinarily seek to collect special categories of data under Article 9 GDPR. Please do not send such data through website forms unless there is a legal obligation or justified contractual necessity.
3. Purposes and legal grounds for processing
| Purpose | Data used | GDPR basis |
|---|
| Responding to inquiries and quote requests | Form data, email, phone, company, message content | Art. 6(1)(b)/(f) |
| Conclusion and performance of contracts | Contact, commercial, billing and project data | Art. 6(1)(b) |
| Compliance with legal obligations | Data required by tax, accounting rules or authorities | Art. 6(1)(c) |
| Website security and abuse prevention | IP, technical logs, traffic, security events | Art. 6(1)(f) |
| Traffic analysis and website improvement | Statistics, online identifiers, page interactions | Art. 6(1)(a) or (f) |
When we rely on legitimate interest, we assess the impact on data subject rights in advance and limit processing to what is necessary, proportionate and reasonable for our activity.
4. Recipients, processors and international transfers
We may disclose data strictly to the extent necessary to the following recipient categories:
- hosting, IT infrastructure, maintenance, email and security providers;
- traffic and performance analytics providers, including Google Analytics if enabled on the site;
- professional consultants, accountants, auditors, lawyers or other relevant service providers;
- public authorities, institutions or courts when required by law or necessary for protecting our rights.
We do not sell personal data. If a provider involves transfers outside the EEA, such transfers take place only with appropriate safeguards, such as standard contractual clauses, supplementary technical measures and adequate risk assessments.
5. Retention periods
We keep data only as long as necessary for the purposes for which it was collected or to comply with applicable legal obligations.
- Contact requests and quotes: up to 24 months after the last interaction, if no contract is concluded.
- Contract and billing data: throughout the contract and afterwards according to legal retention periods.
- Technical and security logs: for periods proportionate to monitoring and security needs.
- Data used for consent-based marketing or analytics: until consent is withdrawn.
After the applicable periods expire, data may be deleted, anonymised or securely archived.
6. Data subject rights
Under GDPR and national legislation, you benefit from the following rights:
- right of access
- right to rectification
- right to erasure where legally applicable
- right to restriction of processing
- right to data portability
- right to object to processing based on legitimate interest
- right to withdraw consent
- right to lodge a complaint with the Romanian supervisory authority
To exercise your rights, please write to [email protected].
7. Cookies and analytics tools
The site may use cookies and similar technologies for technical operation, security, traffic measurement and improving user experience.
If Google Analytics is enabled, certain interaction data may be collected for statistical purposes. Consent configuration should be aligned with this policy.
8. Security, minors and contact details
Security
We apply reasonable technical and organisational measures to protect data against unauthorised access, loss, disclosure, destruction or accidental alteration.
Minors
Our website and services are not directly intended for minors.
Changes
We may update this policy periodically to reflect legal, operational or technical changes.
Contact
For any privacy or data protection request, you can contact us at [email protected], phone +40 720 934 142.