Privacy Policy
1. The Controller
Prime Complex Solutions S.R.L., a company of Romanian nationality, carrying on business under the trading name Prime Axis, with registered office at Str. Nerva Traian 27-33, birou 6, sc. B, et. 1, sector 3, Bucuresti, Romania, registered with the Trade Register under no. J2025080524002, fiscal identification code RO52741279 (hereinafter "the Company"), is the controller of the personal data to which this policy refers.
Any matter concerning the processing of personal data, including the exercise of the rights provided at section 9, is addressed to: contact@primeaxis.ro.
A data protection officer has not been designated, the situations and conditions provided at Articles 37 to 39 of the General Data Protection Regulation, to which Article 10 of Law no. 190/2018 refers, not being met.
2. Scope and applicable legislation
This policy describes the processing of personal data carried out by the Company in connection with the website primeaxis.ro, as well as with the enquiries and engagements arising from it.
The processing is governed by Regulation (EU) 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (the "Regulation"), by Law no. 190/2018 on measures for the implementation of the Regulation, and by Law no. 506/2004 on the processing of personal data and the protection of privacy in the electronic communications sector.
The website has an informational function. It does not permit the conclusion of transactions, the processing of payments, or the creation of user accounts.
3. Categories of personal data processed
3.1 Data communicated through the contact form: surname and forename, electronic mail address, telephone number, the category selected, and the content of the message. The completion of any field is not a condition of submission of the form.
3.2 Data communicated through other channels of correspondence, namely electronic mail, telephone, and messaging applications.
3.3 Technical data processed by the hosting provider for the purpose of delivering and securing the website, as well as, subject to consent, aggregated statistical data concerning use of the website. Cookies are the subject of a separate policy.
3.4 Data necessary for the performance of an engagement. The categories concerned are determined by the nature of the matter and are indicated in the written note transmitted before the commencement of work.
4. Purposes of the processing and legal bases
4.1 Dealing with enquiries received and establishing the extent to which the Company is able to act. Legal basis: Article 6(1)(b) of the Regulation, steps taken at the request of the data subject prior to the conclusion of a contract; as regards correspondence which does not concern a prospective engagement, Article 6(1)(f) of the Regulation, the legitimate interest of the Company in responding to communications addressed to it.
4.2 Performance of the engagement and communication with the client in the course of it. Legal basis: Article 6(1)(b) of the Regulation.
4.3 Operation, maintenance, and security of the website. Legal basis: Article 6(1)(f) of the Regulation, the legitimate interest of the Company in maintaining a functional and secure website.
4.4 Analysis of aggregated statistical data concerning use of the website. Legal basis: Article 6(1)(a) of the Regulation, the consent of the data subject.
4.5 Fulfilment of accounting, fiscal, and other obligations provided by law. Legal basis: Article 6(1)(c) of the Regulation.
4.6 Establishment, exercise, or defence of a right before the courts. Legal basis: Article 6(1)(f) of the Regulation.
Where the processing is founded on legitimate interest, the Company has assessed that interest by reference to the rights and freedoms of the data subject and processes only the data necessary for the purpose pursued. The right to object is provided at section 9.
5. Identification data
To the extent that the performance of an engagement or the fulfilment of a legal obligation so requires, the Company processes identification data, including the personal numeric code and the particulars of identity or travel documents. That processing is founded exclusively on Article 6(1)(b) or Article 6(1)(c) of the Regulation. Processing of a national identification number for the purposes of the legitimate interests pursued by the Company does not take place.
The Company applies appropriate technical and organisational measures for observance of the principle of data minimisation and of the principle of integrity and confidentiality, as well as storage periods established according to the nature of the data and the purpose of the processing.
6. Recipients
6.1 Wix.com Ltd., in its capacity as processor, for the hosting of the website and the provision of its statistical function.
6.2 The professionals and specialists involved in a particular matter, to the extent that their intervention is necessary for its performance and limited to the data required for that purpose.
6.3 Public authorities and other third parties, where disclosure is required by law or is necessary for the performance of the engagement.
Personal data is not disclosed to advertising networks, marketing platforms, or third-party analytics services, and is not processed for the purpose of creating profiles.
7. Transfers outside the European Economic Area
The hosting provider may process data on servers situated outside the European Economic Area. Such transfers are carried out on the basis of an adequacy decision of the European Commission or, in the absence of such a decision, on the basis of standard contractual clauses adopted by the Commission. Further information is available on request, at the address indicated at section 1.
8. Storage periods
8.1 Enquiries not followed by an engagement: 12 months from the date of the last correspondence.
8.2 Engagements: for the duration of the matter and, thereafter, for the periods provided by the applicable accounting, fiscal, and civil legislation.
8.3 Statistical data: for the retention period applied by the hosting provider, or until the withdrawal of consent.
Upon expiry of the applicable period, the data is deleted.
9. Rights of the data subject
The data subject has the right:
a) to obtain confirmation as to whether or not data concerning him or her is processed, and access to that data, pursuant to Article 15 of the Regulation;
b) to obtain the rectification of inaccurate data, pursuant to Article 16 of the Regulation;
c) to obtain the erasure of data, in the situations provided at Article 17 of the Regulation;
d) to obtain the restriction of processing, in the situations provided at Article 18 of the Regulation;
e) to receive the data in a structured, commonly used, and machine-readable format, pursuant to Article 20 of the Regulation;
f) to object to processing founded on legitimate interest, pursuant to Article 21 of the Regulation;
g) to withdraw consent at any time, pursuant to Article 7(3) of the Regulation, without affecting the lawfulness of processing carried out prior to the withdrawal.
Requests are addressed to contact@primeaxis.ro. The Company responds within one month of receipt of the request. That period may be extended by no more than two months where the request is complex, the data subject being informed of the extension and of the reasons for it, pursuant to Article 12(3) of the Regulation.
10. Automated decision-making
The Company does not carry out automated decision-making, including profiling, producing legal effects concerning the data subject or similarly significantly affecting him or her, within the meaning of Article 22 of the Regulation.
11. Complaints
Complaints concerning the processing of personal data may be addressed to the Company at contact@primeaxis.ro.
The data subject also has the right to lodge a complaint with the supervisory authority:
Autoritatea Nationala de Supraveghere a Prelucrarii Datelor cu Caracter Personal (ANSPDCP)
B-dul G-ral. Gheorghe Magheru 28-30, sector 1, 010336 Bucuresti
anspdcp@dataprotection.ro
www.dataprotection.ro
The data subject has the right to an effective judicial remedy, pursuant to Articles 78 and 79 of the Regulation.
12. Amendments
Amendments to this policy are published on this page, the date indicated above being updated accordingly. Where an amendment significantly affects the processing of data already collected, the Company undertakes reasonable steps to inform the data subjects concerned.