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Privacy Policy

Last updated: October 2026

1. Who we are

This website is operated by DIGITAL LEADERSHIP SRL, a company registered in Romania, with its registered office at Dezmir, Apahida Commune, Viorelelor Street, no. 17A, Cluj County, Romania, Tax ID (CUI) 38585123, Trade Registry No. J2017006715126 (hereinafter referred to as "GENERATIVA", "we", "our"). Contact email: contact@generativa.ro Website: https://generativa.ro

2. What personal data we collect

We collect the following categories of personal data:
  • Through the contact form: Full name, email address, phone number (optional), company name, industry, service of interest, message.
  • Through the quote request form in the price calculator: full name, email address, phone number, company name, an optional message, together with the indicative configuration selected in the calculator.
  • Through browsing: Browser type, operating system, pages visited, session duration, traffic source. Some of this data is collected anonymously via a cookie-free analytics service. Additionally, we use analytics and marketing services (Google Analytics 4, Google Ads, Meta Pixel, TikTok Pixel) that may collect technical and usage data through cookies, only with your prior consent. Meta Conversions API and TikTok Events API (data sent from our server only with marketing consent, with your email and phone number hashed, as well as your IP address, browser user agent and click identifiers _fbp, _fbc, _ttp, ttclid).
  • Through direct communication: Data you voluntarily provide via email, phone or other communication channels.

3. Legal bases for data processing

We process your personal data based on the following legal grounds, in accordance with Art. 6 of the General Data Protection Regulation (GDPR):
  • Consent (Art. 6(1)(a) GDPR): for sending marketing communications and using non-essential cookies.
  • Legitimate interest (Art. 6(1)(f) GDPR): for improving our services, analysing website traffic and preventing fraud.
  • Performance of a contract or pre-contractual measures (Art. 6(1)(b) GDPR): to respond to your inquiries through the contact form and to provide requested services.
  • Legal obligation (Art. 6(1)(c) GDPR): to fulfill tax and accounting obligations.

4. How we use your data

Your personal data is used to:
  • Respond to messages and inquiries sent through the contact form.
  • Prepare our reply to quote requests submitted through the price calculator.
  • Provide information about our services.
  • Improve the browsing experience on the website.
  • Analyse traffic and visitor behaviour (anonymised data).
  • Comply with applicable legal obligations.

5. Who we share your data with

We do not sell, rent or share your personal data with third parties for marketing purposes.
  • Website hosting and cloud infrastructure providers (EU servers).
  • Backend service hosting providers (EU servers).
  • Transactional email delivery providers (for confirmations and notifications; EU servers).
  • Cloud database providers (EU servers).
  • Privacy-focused website traffic analytics provider (cookie-free, fully anonymised data, EU servers).
  • Google LLC (Google Analytics 4, Google Ads): for traffic analysis on the website and Google Ads campaign measurement. Data processed: technical browsing data, analytics and marketing cookies. Processing based on your consent. Data transfer to the US covered by the EU-US Data Privacy Framework.
  • Meta Platforms, Inc. (Meta Pixel): for measuring advertising campaign effectiveness. Data processed: browsing data, marketing cookies. Meta acts as an independent data controller. Processing based on your consent. Data transfer to the US covered by the EU-US Data Privacy Framework.
  • TikTok Technology Limited (TikTok Pixel): for measuring TikTok advertising campaign effectiveness. Data processed: browsing data, marketing cookies. Processing based on your consent. Transfers outside the EU/EEA are covered by Standard Contractual Clauses (SCCs).
  • Public authorities: only when legally required.

All our service providers are carefully selected and contractually obligated to comply with GDPR and ensure an adequate level of data protection.

6. Data transfers outside the EU/EEA

Your data is primarily stored and processed on servers in the European Union. Google services (Analytics, Ads) and Meta (Pixel) may involve data transfers to the US, covered by the EU-US Data Privacy Framework (European Commission Adequacy Decision of July 10, 2023). The TikTok Pixel service (TikTok Technology Limited, Ireland) may involve transfers outside the EU/EEA, covered by Standard Contractual Clauses (SCCs). These services are activated only with your consent. For any other transfers outside the EU/EEA, we ensure adequate safeguards are in place in accordance with GDPR, including Standard Contractual Clauses (SCCs).

7. How long we retain data

We retain your personal data only for as long as necessary for the purposes for which it was collected:
  • Contact form data: maximum 12 months from the last interaction, unless a contractual relationship is established.
  • Quote request form data: maximum 24 months from the submission of the request, if no service contract is concluded.
  • Traffic analytics data (cookie-free service): data is anonymised at collection and statistically aggregated. Aggregated data retention: indefinite.
  • Analytics cookies (Google Analytics): cookie duration is maximum 14 months. Aggregated data is retained according to platform settings.
  • Marketing cookies (Meta Pixel): cookie duration is maximum 90 days.
  • Marketing cookies (TikTok Pixel): cookie duration is maximum 13 months.
  • Marketing cookies (Google Ads): cookie duration is maximum 90 days.
  • Accounting/tax data: 10 years in accordance with Romanian legislation (Law 82/1991, the Accounting Law).

8. Your rights under GDPR

Under the General Data Protection Regulation (GDPR), you have the following rights:
  • Right of access: you can request a copy of your personal data.
  • Right to rectification: you can request correction of inaccurate data.
  • Right to erasure ("right to be forgotten"): you can request deletion of your data under certain conditions.
  • Right to restriction of processing: you can limit how we process your data.
  • Right to data portability: you can receive your data in a structured, commonly used format.
  • Right to object: you can object to the processing of your data in certain situations.
  • Right not to be subject to automated decision-making, including profiling.

To exercise any of these rights, contact us at contact@generativa.ro. We will respond within 30 days.

9. Data security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, destruction or alteration. These include: • Encryption in transit for all communications. • Encryption at rest for sensitive data. • Role-based data access restrictions. • Regular security audits. • Hosting in European Union data centres.

10. Complaints

If you believe that the processing of your personal data violates GDPR, you have the right to file a complaint with: The National Supervisory Authority for Personal Data Processing (ANSPDCP) Address: B-dul G-ral. Gheorghe Magheru 28-30, Sector 1, postal code 010336, Bucharest, Romania Website: www.dataprotection.ro Email: anspdcp@dataprotection.ro

11. Changes to this policy

We reserve the right to update this Privacy Policy to reflect changes in our practices or applicable legislation. Any changes will be published on this page with the update date. We recommend periodically checking this page.

12. Contact

For any questions regarding privacy or personal data protection: DIGITAL LEADERSHIP SRL Address: Dezmir, Apahida Commune, Viorelelor Street, no. 17A, Cluj County, Romania Email: contact@generativa.ro Tax ID (CUI): 38585123 | Trade Registry: J2017006715126

Cookie Policy

What are cookies

Cookies are small text files stored on your device when you visit a website. They are widely used to make websites work more efficiently and to provide information to site owners.

What cookies we use

We use the following categories of cookies:
  • Strictly necessary cookies: essential for the website to function. The only cookie in this category is generativa_cookie_consent, which stores your choice for 12 months. These cannot be turned off.
  • Cookie-free traffic analytics: we use a privacy-focused analytics service (pages visited, visit duration, traffic sources). It sets no cookies and collects no personal data, so it needs no consent and keeps running whichever option you pick in the banner.
  • Analytics cookies (Google Analytics 4): _ga, _ga_* - traffic statistics and key actions (e.g. submitting a form), with no personal data in the events. Loaded only if you turn on the "Analytics" category. Duration: max. 14 months. Provider: Google.
  • Marketing cookies (Meta Pixel): _fbp, _fbc - measuring the effectiveness of our Meta (Facebook, Instagram) campaigns. Loaded only if you turn on the "Marketing" category. Duration: max. 90 days. Provider: Meta Platforms Ireland.
  • Marketing cookies (TikTok Pixel): _ttp, _tt_enable_cookie, ttclid, ttcsid, ttcsid_* - measuring TikTok advertising campaign effectiveness. Loaded only if you turn on the "Marketing" category. Duration: max. 13 months. Provider: TikTok Technology Limited.
  • Marketing cookies (Google Ads): _gcl_au, _gcl_aw - linking clicks on Google ads to actions on the site (conversion measurement). Loaded only if you turn on the "Marketing" category. Duration: max. 90 days. Provider: Google.
  • Preference cookie: gen_internal, which marks team devices as internal traffic (12 months).

How to control cookies

On your first visit we ask for consent through the banner. You get three options at the same level: accept all, keep only the necessary cookies, or pick categories under "Customise". The Google (Analytics, Ads), Meta and TikTok scripts load only after you turn on the respective category; until then, no connection to these providers takes place. Your choice is stored for 12 months, after which we ask again. If we add new purposes, we ask for your consent again. You can: • Change your choice any time from "Cookie settings" in the footer of every page. The panel opens with your current options selected, so withdrawing consent takes as few clicks as giving it. • Block or delete cookies from your browser settings. • Opt out of Google Analytics: https://tools.google.com/dlpage/gaoptout When you submit a form and have accepted marketing, we also send Meta and TikTok a confirmation from our server (Conversions API and Events API respectively), with your email address and phone number in irreversibly hashed form (SHA-256), as well as your IP address, browser user agent and click identifiers (_fbp, _fbc, _ttp, ttclid), so we can measure our campaigns accurately. Without marketing consent, we send nothing. Choices made on the previous banners are no longer valid; on your first visit after 9 September 2026 we ask again, per category.

Third-party cookies

The third-party services using cookies are Google Analytics 4 and Google Ads (Google LLC), Meta Pixel (Meta Platforms Ireland) and TikTok Pixel (TikTok Technology Limited) - all enabled only with your consent. For EU users, Google Analytics data is collected on EU servers, with the IP address removed before logging; further processing by Google is carried out under the Google Ads Data Processing Terms (standard contractual clauses / EU-US Data Privacy Framework). Google's policy: https://policies.google.com/privacy Meta's policy: https://www.facebook.com/privacy/policy/ TikTok's policy: https://www.tiktok.com/legal/page/eea/privacy-policy/en Additionally, we use a cookieless analytics service that collects no personally identifiable data.

Cookie Policy updates

This policy may be updated periodically. Last update: September 9, 2026.