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Privacy Policy

Last updated: July 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. J12/6715/2017 (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 order form: Full name, email address, phone number, company name, industry, estimated daily interaction volume, selected plan, billing cycle (monthly/annual), additional details (optional). This data is necessary for processing service requests under Art. 6(1)(b) GDPR (pre-contractual measures).
  • 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, Meta Pixel, TikTok Pixel) that may collect technical and usage data through cookies, only with your prior consent.
  • 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, analyzing 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.
  • Process service requests submitted through the order form (identifying the requested plan, contacting to discuss terms).
  • Provide information about our services.
  • Improve the browsing experience on the website.
  • Analyze traffic and visitor behavior (anonymized 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).
  • Cloud database providers (EU servers).
  • Privacy-focused website traffic analytics provider (cookie-free, fully anonymized data, EU servers).
  • Google LLC (Google Analytics 4, Google Tag Manager): for traffic analysis and website script management. Data processed: technical browsing data, analytics 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, loaded via Google Tag Manager): 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, Tag Manager) 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.
  • Order form data: maximum 24 months from the submission of the request, if no service contract is concluded. If a contract is concluded, the data is retained for the duration of the contract plus 5 years for legal and fiscal compliance.
  • Traffic analytics data (cookie-free service): data is anonymized 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.
  • 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 organizational measures to protect your personal data against unauthorized 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 centers.

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: J12/6715/2017

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 (e.g. your cookie preference). Cannot be disabled.
  • Cookie-free traffic analytics: we use a privacy-focused analytics service (pages visited, visit duration, traffic sources). It uses no cookies and collects no personal data - no consent required.
  • Functional cookies: remember your preferences (selected language, display preferences). Duration: max. 12 months.
  • Analytics cookies (Google Analytics 4): _ga, _ga_* - traffic statistics and key actions (e.g. submitting a form), with no personal data. Enabled only with your consent. Duration: max. 14 months. Provider: Google.
  • Marketing cookies (TikTok Pixel): _ttp, _tt_enable_cookie - measuring TikTok advertising campaign effectiveness. Enabled only with your consent. Duration: max. 13 months. Provider: TikTok.

How to control cookies

On your first visit we ask for consent via the banner. The analytics and marketing scripts (Google Analytics, and Google Tag Manager with TikTok Pixel) load only after you accept - until then, no connection to Google or TikTok takes place. You can: • Accept or reject non-essential cookies from the banner. • Block or delete cookies from your browser settings. • Opt out of Google Analytics: https://tools.google.com/dlpage/gaoptout

Third-party cookies

The third-party services using cookies are Google Analytics 4 (Google LLC) and TikTok Pixel (TikTok Technology Limited, loaded via Google Tag Manager) - both enabled only with your consent. For EU users, Google Analytics data is collected on EU servers and the IP address is dropped before logging. Google's policy: https://policies.google.com/privacy 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: July 29, 2026.