Privacy Policy

1. Who is responsible

The controller is S.C. FOCUS ON CONSISTENCY S.R.L., CUI 51804514, Nr. Reg. Com. J2025035139004, Bucharest, Romania. No data protection officer is appointed, which is not required at this scale.

For anything to do with your data, write to office@raresstoicescu.ro.

2. What is collected

When you send a message. Your name, email address, phone number if you give one, and the content of your message.

When you complete a campaign form. The answers you give, your phone number, the verification code sent to it and whether it was entered correctly, the consent boxes you ticked with the exact wording shown to you, and the date, time and IP address at which you ticked them.

When you simply visit. If you allow statistics cookies: the pages you open, how long you stay, how far you scroll, where you click, your approximate screen size, browser, operating system, language and IP address, together with a random identifier stored by your browser. If you allow marketing cookies, the third parties named in section 5 also receive data about your visit.

Always. Your cookie decision, the version of the policy you were shown, and the address it was made from — kept as proof that consent was asked for and given.

3. Why, and on what legal basis

To reply to you — because you asked, and because there is a legitimate interest in answering correspondence (Article 6(1)(f), and Article 6(1)(b) where a message concerns a possible engagement).

To verify a phone number — to establish that an enquiry is genuine, on the basis of legitimate interest, and with your agreement to receive the code.

To measure the site and advertising — only with your consent (Article 6(1)(a)), given through the cookie banner and withdrawable at any time.

To keep the site working and free of abuse — session handling, language, and invisible reCAPTCHA on the whole site, on the basis of legitimate interest in a site that functions and is not flooded with automated submissions.

To prove consent — a legal obligation under Article 7(1).

4. Invisible reCAPTCHA

Every page of this site runs Google reCAPTCHA in its invisible form. It looks at how a page is used in order to distinguish people from automated scripts, and it does this without asking you to solve anything. Google receives the information described in its own privacy notice.

This runs on legitimate interest rather than consent, because without it the forms on this site are unusable within days. It is subject to Google's Privacy Policy and Terms of Service.

5. Who else sees your data

The hosting provider, which stores the site and its database on servers in the European Union.

The email provider used to send and receive messages from the forms.

SMSAPI, when a verification code is sent to your phone number.

Meta, TikTok and Google, but only if you allow marketing cookies. Where a form is completed, the same conversion may also be reported to Meta from the server so that a single action is not counted twice; that reporting follows the consent you gave.

Your data is not sold, and it is not shared with anyone for their own marketing.

6. Transfers outside the EU

Meta, TikTok and Google process data outside the European Economic Area, including in the United States, under the standard contractual clauses and the frameworks each of them publishes. If you do not allow marketing cookies, no transfer to them takes place.

7. How long it is kept

Messages and enquiries: three years from the last contact, so that a conversation can be picked up again and any dispute answered.

Verification codes: minutes. They expire on use or shortly after being sent, and the code itself is discarded once the number is verified.

Consent records: three years from the date given, or from withdrawal.

Statistics: twenty-six months, after which visits are no longer identifiable.

Anything not covered above is deleted once the reason for holding it has passed.

8. Your rights

You may ask for a copy of your data, ask for it to be corrected, ask for it to be deleted, ask that its use be restricted, object to processing based on legitimate interest, and ask to receive it in a portable form. Where processing rests on consent, you may withdraw that consent at any time without affecting what was done beforehand.

Requests go to office@raresstoicescu.ro and are answered within one month.

If you believe your data has been mishandled you may complain to the Romanian supervisory authority, ANSPDCP, at dataprotection.ro, or to the authority in the country where you live.

9. Security

The site is served over HTTPS. Access to the administration area is restricted and credentials are stored encrypted. No arrangement is perfect, and no claim is made here that one is; what can reasonably be done at this scale, is done.

10. Children

This site is not directed at children and no data is knowingly collected from anyone under 16. If you believe a child has sent information through this site, write and it will be deleted.

11. Changes

This policy may be updated. The date at the top shows when it last changed. Where a change affects what you have consented to, the cookie banner will ask again rather than assume.