Who we are
Hi there, we’re Angvlar SRL (CUI: 40331941, REG. COM.: J12/5486/2018), România, Cluj, Cluj-Napoca, 400000 (“Angvlar”) and welcome to our privacy policy. This policy outlines how we handle your personal information if you’re an Angvlar user or visitor to our Sites. It applies across Angvlar’s main website (www.angvlar.com), Angvlar Analytics, Angvlar Conversions, Angvlar Dashboard, Angvlar Drive, Angvlar Drop, Angvlar Forms, Angvlar QR Menu, Angvlar QR, Angvlar Short, Angvlar SMS, Angvlar Social, and everything that our company owns online.
When we say ‘we’, ‘us’, ‘Angvlar’, ‘Angvlar.com’, ‘Angvlar SRL’ or ‘SC Angvlar SRL’, that’s who we are, and we own and run the Sites.
If we say ‘policy’, we’re talking about this privacy policy. If we say user terms, we’re talking about the rules for using each Site. The rules seek consent to them separately to this policy.
The type of personal information we collect
We collect certain personal information about visitors and users of our Sites.
The most common types of information we collect include things like usernames, member names, e-mail addresses, IP addresses, other contact details, survey responses, blogs, photos, payment information such as payment agent details, transactional details, tax information, support queries, forum comments (if applicable), content you direct us to make available on our Sites (such as item descriptions), your actions on our Sites (including any selections or inputs into items) and web and e-mail analytics data. We will also collect personal information from job applications (such as your CV, the application form, cover letter and interview notes).
How we collect personal information
We collect personal information directly when you provide it to us, automatically as you navigate through the Sites, or other people when you use services associated with the Sites.
We collect your personal information when you provide it to us when you complete membership registration and buy or provide items or services on our Sites, subscribe to a newsletter, or e-mail list, submit feedback, enter a contest, fill out a survey, or send us a communication.
Personal information we collect about you from others
Although we generally collect personal information directly from you, we occasionally collect specific categories of personal information about you from other sources. In particular:
a. financial and/or transaction details from payment providers located in România and the UK to process a transaction;
b. third-party service providers located worldwide may provide information about you when you link, connect, or log in to your account with the third-party provider, and they send us information such as your registration and profile from that service. The information varies and is controlled by that service provider or as authorised by you via your privacy settings at that service provider; and
c. other third-party sources and/or partners from România and Germany, whereby we receive additional information about you (to the extent permitted by applicable law), such as demographic data or fraud detection information, and combine it with information we have about you. For example, fraud warnings from service providers like identity verification services. We also receive information about you and your activities on and off our platforms through partnerships or about your experiences and interactions from our partner ad networks.
How we use personal information
We will use your personal information:
a. To fulfil a contract or take steps linked to a contract: in particular, in facilitating and processing transactions on the Sites, like where you purchase a service from us.
b. Where this is necessary for purposes which are in our, or third parties, legitimate interests. These interests include:
i. operating the Sites;
ii. providing you with services described on the Sites;
iii. verifying your identity when you sign in to any of our Sites;
iv. responding to support tickets and helping facilitate the resolution of any disputes;
v. updating you with operational news and information about our Sites and services, e.g. to notify you about changes to our Sites, website disruptions or security updates;
vi. carrying out technical analysis to determine how to improve the Sites and services we provide;
vii. monitoring activity on the Sites, e.g. to identify potential fraudulent activity and to ensure compliance with the user terms that apply to the Sites;
viii. managing our relationship with you, e.g. by responding to your comments or queries submitted to us on the Sites or asking for your feedback or whether you want to participate in a survey;
ix. managing our legal and operational affairs (including managing risks relating to content and fraud matters);
x. training Angvlar STAFF about how to serve our users best;
xi. improving our products and services;
xii. providing general administrative and performance functions and activities;
xiii. verifying your identity; and
xiv. processing your job application to Angvlar.
c. Where you give us consent:
i. providing marketing information about products and services that may interest you; and
ii. customising our services and websites, like advertising on the Site – which involves using cookies or similar technologies – to provide a more personalised experience.
d. For purposes which are required by law.
e. To respond to requests by the government, a court of law, or law enforcement authorities conducting an investigation.
When we disclose your personal information
We will disclose personal information to the following recipients:
a. companies that are in the Angvlar group;
b. our professional advisers (lawyers, accountants, financial advisers etc.), which are located in România;
c. regulators and government authorities in connection with our compliance procedures and obligations;
d. subcontractors and service providers who assist us in connection with the ways we use personal information (as set out above), in particular: hosting providers which are located in România; technical and customer support services which are located in România; recruitment agencies which are located in Romania and the US; security and fraud prevention services; marketing and analytics services which are located in România, Germany, the UK and the US; subscription management services which are located in the US; payment processing services which are located in Romania and the UK; identification verification services; and operational tooling services which are located in România, Germany, the UK and the US. Noting that our subcontractors and service providers may also transfer and access such information from other countries where they operate.
e. a purchaser or prospective purchaser of all or part of our assets or our business, and their professional advisers, in connection with the purchase;
f. a third party to respond to requests relating to a criminal investigation or alleged or suspected illegal activity;
g. a third party to enforce or defend our rights or to address financial or reputational risks;
h. a rights holder concerning an allegation of intellectual property infringement or any other infringement; and
i. other recipients where we are authorised or legally required to do so.
Where we transfer and/or store your personal information
Some of the recipients described in the above section, and to whom we disclose your personal information, are based in places like Germany, the UK and the US. We are based in România, so your data will be processed in România. To secure your information, we only collaborate with service providers and subcontractors that, in our opinion, uphold an adequate level of data security compliance. We do this based on this policy.
How we keep your personal information secure
We store personal information on secure servers that our service providers and we manage, and occasionally hard copy files are kept in secure locations in România, Germany, the UK and the US. The personal information we store or transmit is protected by security and access controls, including username and password authentication, two-factor authentication, and data encryption where appropriate.
How you can access your personal information
Additionally, you have the right to seek access to additional personal data we hold about you and to request corrections of any errors in that data. You may access this by logging into your account and some of our personal information on file. You can also close your account with us for any of our Sites at any time. To make an access or correction request, contact our Data Protection Department using the contact details at the end of this policy.
Marketing Choices regarding your personal information
Where we have your consent to do so (e.g. if you have subscribed to one of our e-mail lists or have indicated that you are interested in receiving offers or information from us), we send you marketing communications by e-mail about products and services that we feel may be of interest to you. You can opt out of such communications if you prefer not to receive them in the future by using the “unsubscribe” facility provided in the communication itself.
You also have choices about cookies, as described below. By modifying your browser preferences, you can accept all cookies, be notified when a cookie is set, or reject all cookies. If you choose to reject cookies, some parts of our Sites may not work correctly in your case.
Cookies (not the type you eat!) and web analytics
For detailed information regarding how we use cookies, check our Cookies Policy. For more general information on cookies, see http://www.allaboutcookies.org.
When you visit our Sites, certain information is recorded, which is generally anonymous and does not reveal your identity. Some of this information could be associated with your account if logged in. We’re talking about the following kinds of details:
a. your IP address or proxy server IP address;
b. the domain name you requested;
c. the name of your internet service provider is sometimes captured depending on the configuration of your ISP connection;
d. the date and time of your visit to the website;
e. the length of your session;
f. the pages which you have accessed;
g. the number of times you access our Site within any month;
h. the file URL you look at and information relating to it;
i. the website which referred you to our Sites;
j. the operating system which your computer uses; and
k. the technical capabilities of your web browser.
Occasionally, we will use third-party advertising companies to serve ads based on prior visits to our Sites. For example, if you visit our Sites, you may later see an advertisement for our products and services when you visit a different Site.
Information about children
Our Sites are not suitable for children under the age of 16 years, so if you are under 16, we ask that you do not use our Sites or give us your personal information (if you are a young tech wiz, please direct your nearest responsible adult to use the Sites for you!). If you are from 16 to 18 years, you can browse the Sites, but you’ll need the supervision of a parent or guardian to become a registered user. Parents or guardians are responsible for monitoring their children’s use of our Sites.
Information you make public or give to others
You can find yourself providing information to others in many ways, like posting a public message on a forum thread, sharing information via social media, or contacting another user via our Sites or directly via e-mail. Before making your information publicly available or giving your information to anyone else:
- Think carefully.
- If you make your personal information available to others, we can’t control or accept responsibility for how they will use or manage that data. If giving information to another user via our Sites, ask them how they will handle your data.
- If you’re sharing information via another website, check the privacy policy for that Site to understand its information management practices, as this privacy policy will not apply.
How you can manage or delete your personal information
We retain your personal information for as long as necessary to provide the services to you and others and to comply with our legal obligations. Suppose you no longer want us to use your personal information or to provide you with the Angvlar services. In that case, you can request that we erase your personal information and close your Angvlar account by contacting our Data Protection Department by submitting a request form through our Data Protection Department Form.
If you want to report a security vulnerability in an Angvlar product, please see our Helpful Hacker Program!
How long we keep your personal information
Please note that if you request the erasure of your personal information, we may retain information from deleted accounts as necessary for our legitimate business interests, to comply with the law, prevent fraud, collect fees, resolve disputes, troubleshoot problems, assist with investigations or requests by government, a court of law, or law enforcement authorities, enforce the terms of service and take other actions permitted by law. Any information we retain will be handled following this Privacy Policy.
When we need to update this policy
We will periodically need to change the latest legal requirements and any changes to our privacy management practices to keep this policy current.
When we change the policy, we’ll notify you about such changes, where required. A copy of the latest version of this policy will always be available on this page.
How you can contact us
If you have any questions about our privacy practices or how we have been managing your personal information, please get in touch with us via the Data Protection Department Form.
If you want to report a security vulnerability in an Angvlar product, please see our Helpful Hacker Program!
We’re glad you made it to the end of the privacy policy because knowing this is the best way to understand how your personal information is used and how to manage it best!
If you’re a user or visitor in the European Economic Area, these rights also apply to you:
For applicable EU data protection law (including the General Data Protection Regulation 2016/679 (the “GDPR”), we are a ‘data controller’ of your personal information.
How you can access your personal information
You are also entitled to ask us to port your personal information (i.e., we will deliver data to you in a machine-readable, organised, and widely utilised format), erase it, or restrict its processing. You also have the right to object to some processing based on our legitimate interests, such as profiling that we perform for direct marketing purposes, where we have asked for your consent to process your data, to withdraw this consent as described below.
In some circumstances, these rights are restricted. For instance, we can show that processing your personal information is required by law. In rare cases, we could keep part of your data even if you revoke your consent.
We must divulge your personal information when obligated by law or by contract.
If such data is provided, we can manage our contractual relationship with you and meet our obligations. In all other cases, the provision of requested personal information is optional.
If you have unresolved concerns, you also have the right to complain to data protection authorities. The relevant data protection authority will be the data protection authority of the country:
- Of your habitual residence.
- Of your place of work.
- In which you consider the alleged infringement has occurred.
*Both personal information and personal data have the same meaning in the context of this Privacy Policy.
Angvlar Privacy Policy v1.2, effective date: 1st of March, 2022