Privacy Policy

The controller within the meaning of the General Data Protection Regulation (GDPR) is:

Web Solution Jog690 S.R.L.
Strada Ion Slavici, Nr. 13, Cam. Nr. 1, Scara B, Ap. 18
300539 Timisoara, Romania
Represented by: Johann Göschelbauer
Email: office@jog690.eu

We generally only process our users' personal data to the extent necessary to provide a functioning website along with our content and services, or where a legal basis permits it. Legal bases include, in particular, the performance of contractual or pre-contractual measures (Art. 6(1)(b) GDPR), our legitimate interest in a secure and functioning online offering (Art. 6(1)(f) GDPR), and your consent (Art. 6(1)(a) GDPR), where such consent has been obtained.

Data is generally transmitted between your browser and our servers in encrypted form via SSL/TLS (indicated by "https://" in your browser's address bar).

Retention period

Unless a more specific retention period is stated in this Privacy Policy, we retain your personal data only for as long as necessary for the respective processing purpose. If you assert a legitimate right to erasure or withdraw a consent you have given, your data will be deleted, unless statutory retention obligations apply (e.g. under commercial or tax law); in that case, deletion takes place once those obligations no longer apply.

Transfers to third countries

Some of the services we use (including Google Analytics, Google Ads, Meta Pixel, and Cloudflare) may transfer personal data to countries outside the EU/EEA, in particular the United States. We only use such services where the respective provider is certified under the EU-U.S. Data Privacy Framework or has agreed appropriate safeguards, such as the Standard Contractual Clauses approved by the European Commission (Art. 46 GDPR). Details of individual transfers are provided in the relevant sections of this Privacy Policy.

Recipients of personal data

In the course of our business activities, we work with external service providers (e.g. hosting, security, and analytics providers) to whom personal data may be transferred in this context. Data is only shared where necessary to fulfil a contract, where we are legally obligated to do so, where there is a legitimate interest in the disclosure, or where another legal basis permits it. We have a data processing agreement in place with all processors we use, in accordance with Art. 28 GDPR.

These websites are hosted on servers operated by Hetzner Online GmbH, Industriestr. 25, 91710 Nuremberg, Germany. The server location is Nuremberg, Germany — within the European Union. We have a data processing agreement with Hetzner in accordance with Art. 28 GDPR.

The use of Hetzner is based on our legitimate interest in a secure, fast, and efficient provision of our online offering through a professional provider (Art. 6(1)(f) GDPR).

We use the Cloudflare service provided by Cloudflare, Inc., 101 Townsend St., San Francisco, CA 94107, USA. Cloudflare acts as a Content Delivery Network (CDN) and security proxy, delivering our website faster and protecting it against attacks (e.g. DDoS). This necessarily involves processing the IP addresses of website visitors.

This processing is based on our legitimate interest in a secure and performant delivery of our online offering (Art. 6(1)(f) GDPR). Since Cloudflare may also transfer data to the USA, we base such transfers on the Standard Contractual Clauses approved by the European Commission and/or the EU-U.S. Data Privacy Framework, to the extent Cloudflare has joined it. Further information can be found in Cloudflare's privacy policy.

We additionally use Cloudflare R2 to store automated backups of our website (including the database). These backups may contain personal data generated through use of the website (e.g. contact inquiries). Storage serves the purpose of data security and recoverability in the event of a disruption, based on our legitimate interest in a functioning and resilient online offering (Art. 6(1)(f) GDPR). Backups are rotated regularly and are not retained indefinitely.

To protect our contact form against automated spam and bot access, we also use Cloudflare Turnstile. This analyzes technical characteristics of your device and your interaction (including IP address and browser signals) to distinguish between human users and automated access, without requiring you to solve a traditional CAPTCHA. No content is evaluated for advertising purposes. The legal basis is our legitimate interest in a functioning contact form free of spam and abuse (Art. 6(1)(f) GDPR).

Our hosting provider automatically collects and stores information in what are known as server log files, which your browser automatically transmits to us. This includes:

• IP address of the accessing device
• Date and time of access
• Name and URL of the file accessed
• Website from which access occurred (referrer URL)
• Browser used and, where applicable, your device's operating system

This data is used exclusively to ensure smooth operation of the website, to improve our offering, and to safeguard the security of our IT systems (Art. 6(1)(f) GDPR). It is not combined with other data sources and is generally deleted automatically after a short period.

To protect our website against unauthorized access, brute-force attacks, and other security threats, we use the Wordfence security plugin provided by Defiant Inc. Wordfence processes IP addresses and access patterns in order to detect suspicious behavior and, where necessary, block it automatically.

This processing is based on our legitimate interest in the security and integrity of our website and the data processed on it (Art. 6(1)(f) GDPR in conjunction with Recital 49 GDPR).

Our website uses cookies. Cookies are small text files stored on your device that cause no damage to it. They are either stored temporarily for the duration of your visit (session cookies, which are automatically deleted once you leave the website) or permanently (persistent cookies, which remain on your device until a set expiry date or until you delete them manually).

Cookies may be set by us directly (first-party cookies) or originate from third-party providers whose services we integrate (third-party cookies, e.g. from Google or Meta, where such services are used in accordance with §8–§10).

Technically necessary cookies, which are essential for operating the website, are used on the basis of Art. 6(1)(f) GDPR.

For all cookies and technologies that are not strictly necessary (e.g. analytics and marketing tools), we obtain your consent via a cookie consent banner before they are used (Art. 6(1)(a) GDPR). You may withdraw or adjust your consent at any time, with future effect, via the cookie settings.

You can also configure your browser to notify you when cookies are set, to allow cookies only on a case-by-case basis, to reject cookies generally, or to automatically delete cookies when you close your browser. Disabling cookies may limit the functionality of this website.

The following sections (§8–§10) describe services that are activated only after you have given consent and are not necessarily used simultaneously across all of our websites.

Where you have given consent, we use Google Analytics 4 on this website, a web analytics service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Google Analytics uses cookies or comparable technologies that enable an analysis of your use of our website (e.g. pages visited, time spent, visitor origin).

The IP address transmitted by your browser as part of Google Analytics is not combined with other Google data. Data processing takes place via Google Consent Mode, meaning tracking cookies are only actively loaded once you have given your consent. Data may be transferred to the USA; Google is certified under the EU-U.S. Data Privacy Framework.

The legal basis is your consent under Art. 6(1)(a) GDPR, which you may withdraw at any time.

Where we run Google Ads advertising campaigns from time to time, we use conversion tracking provided by Google Ireland Limited on the relevant pages. After clicking on one of our Google ads, a cookie is set on your device, which allows us to determine whether a specific action (e.g. submitting the contact form) took place on our website.

The information collected in this way is anonymous to us and does not allow any conclusions to be drawn about your identity. Data is not shared with third parties outside the Google group of companies. Processing only takes place if you have consented to the relevant category in the cookie banner (Art. 6(1)(a) GDPR).

Where we run advertising campaigns via Meta (Facebook/Instagram) from time to time, we use the so-called "Meta Pixel" provided by Meta Platforms Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland, on the relevant pages. This allows Meta to identify visitors to our website as a target audience for displaying advertisements (Facebook ads).

We use the Meta Pixel to ensure our Facebook ads are shown only to users who have shown interest in our services, and to measure the effectiveness of our advertising. Data may be transferred to Meta in the USA. Processing takes place only with your consent via the cookie banner (Art. 6(1)(a) GDPR).

This website uses so-called Google Fonts for a consistent display of typefaces. These fonts are hosted locally on our own server. As a result, no connection to Google's servers is made when you visit this website, and no personal data is transmitted to Google.

If you send us an inquiry via the contact form, the details you provide in the inquiry form — including the contact information you enter (name, company, phone number, email address) — along with your message, are stored by us for the purpose of processing your inquiry and in case of follow-up questions.

Submission takes place via an encrypted SMTP connection to an email inbox hosted by Infomaniak Network SA, Rue Eugène-Marziano 25, 1227 Geneva, Switzerland. Data transfers to Switzerland are covered by an adequacy decision of the European Commission under Art. 45 GDPR, confirming an adequate level of data protection.

Inquiries by email or phone

If you contact us directly by email or phone instead, we store and process your inquiry, including any personal data arising from it (e.g. name, contact details, content of the inquiry), for the purpose of handling your request. We do not share this data with third parties without your consent.

The legal basis for processing data entered in the contact form, as well as inquiries submitted by email or phone, is our legitimate interest in responding to your inquiry (Art. 6(1)(f) GDPR) or, where the inquiry is aimed at concluding a contract or serves to carry out pre-contractual measures, Art. 6(1)(b) GDPR. The data is deleted once it is no longer required for the purpose for which it was collected, at the latest once the correspondence has concluded, unless statutory retention obligations apply.

You have the following rights with regard to your personal data:

• Right of access (Art. 15 GDPR)
• Right to rectification of inaccurate data (Art. 16 GDPR)
• Right to erasure (Art. 17 GDPR)
• Right to restriction of processing (Art. 18 GDPR)
• Right to data portability (Art. 20 GDPR)
• Right to object to processing (Art. 21 GDPR)
• Right to withdraw consent given, with future effect (Art. 7(3) GDPR)

Withdrawing your consent

Many data processing operations are only possible with your express consent. You may withdraw any consent already given at any time. The lawfulness of data processing carried out prior to withdrawal remains unaffected.

Right to data portability

You have the right to receive data that we process automatically on the basis of your consent or in performance of a contract, either yourself or transferred to a third party, in a common, machine-readable format. Where you request the direct transfer of data to another controller, this will only take place to the extent technically feasible.

Right to restriction of processing

You have the right to request the restriction of processing of your personal data. This right applies, in particular, in the following cases:

• If you dispute the accuracy of data we hold about you, for the duration it takes to verify that data
• If the processing of your data was or is unlawful, but you request restriction instead of erasure
• If we no longer need the data, but you need it to establish, exercise, or defend legal claims
• If you have objected to processing under Art. 21(1) GDPR, pending verification of whether our grounds override yours

If you have restricted the processing of your data, such data — other than being stored — may only be processed with your consent, or for the establishment, exercise, or defense of legal claims, for the protection of the rights of another natural or legal person, or for reasons of important public interest.

Right to object (Art. 21 GDPR)

To exercise these rights, please contact us using the details provided in §1.

Objection to promotional emails

We hereby expressly object to the use of contact details published as part of our legal notice obligation (phone number, email address) for sending unsolicited advertising and information materials. We expressly reserve the right to take legal action in the event of unsolicited promotional information being sent, for example via spam emails.

Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a data protection supervisory authority, in particular in the Member State of your habitual residence, place of work, or the place of the alleged infringement, if you consider that the processing of personal data relating to you infringes the GDPR.

The supervisory authority responsible at the controller's registered seat is the Romanian data protection authority:
Autoritatea Naţională de Supraveghere a Prelucrării Datelor cu Caracter Personal (ANSPDCP), B-dul G-ral. Gheorghe Magheru 28-30, Sector 1, 010336 Bucharest, Romania.

We reserve the right to update this Privacy Policy in order to ensure it always complies with current legal requirements, or to reflect changes to our services in the Privacy Policy, for example when introducing new services. The new Privacy Policy will then apply to your next visit.