terms and conditions

Data Controller’s Contact Information
PROMOCRAT MEDIA SRL, with its registered office in Bucharest, 142 Mihai Eminescu street, sector 2, registered with the National Office of the Trade Register Bucharest under number J40/261/2012, unique registration code RO29534830.

Place of business: 142 Mihai Eminescu street, block 1, floor 1, apt. 1, sector 2, Bucharest, 020083.

Purpose of Processing Your Personal Data
Our purposes for processing your personal data are real, current, and legitimate.

www.promocrat.com does not process personal data for secondary purposes that are incompatible with the primary purposes for which your personal data was initially collected.

We also do not process data without:

Your initial consent
Having a legitimate interest in doing so
A legal basis
Before collecting your personal data, we inform you of:

The main purpose for which we collect this data
If we have a secondary purpose, what it is.
Before collecting and processing your data, we ask for your consent to do so.

What types of data we collect and process:

2.1. Your email is collected for the following purposes:

to download the agency’s portfolio in PDF format
to send you news if you subscribed to our newsletter
2.2. Your name is collected for:

communication through the newsletter
2.4. Your organization’s legal details (if any) are collected for:

identifying you by the agency and to carry out a business audit if you have explicitly requested this
2.5. Your phone number is collected for:

identifying you by the agency to confirm a certain request sent via email or through the contact form on the website
2.6. Your ID from strictly necessary cookies is collected for:

making marketing communications to you
2.7. www.promocrat.com does not process your banking data.

“Responsibility for processing your personal data

The processing of your personal data is the responsibility of www.promocrat.com

We have the following responsibilities:

  • Determining the purpose for which your data is processed

  • Determining how your personal data is processed

  • Assuming responsibility for the proper management of the personal data you provide us with, in accordance with the terms and GDPR procedure manual.

Within Promocrat Media SRL, there is a person responsible for data protection, whom you can address at the following contact coordinates:

Cosmin Gabriel Cucos, 0758 52 62 48, dpo@promocrat.ro or financiar@promocrat.ro, Strada Mihai Eminescu, nr. 142, block 1, floor 1, ap. 1, sector 2, Bucharest, working hours 8:30 – 17:30.

  1. How we collect your contact data

www.promocrat.com collects personal data directly from you through the following ways:

  • electronically, using the contact form from the website pages

  • by phone

  • by email

  • www.promocrat.comonly collects strictly necessary personal data for operational purposes.

When you provide your personal data in order to make a purchase on www.promocrat.com providing this data is:

  • allowed and voluntary. Personal data is provided freely: name, email, phone, address. Providing this data is free by your agreement and you can opt not to provide it, but without some of this information, the products ordered cannot be delivered to you.

  • allowed and mandatory. These are data that you are required to provide us with: billing data. If you are a legal entity, without providing these details, you cannot purchase our products and services.

  • Providing mandatory personal data is a legal requirement, for example, in the case of invoices, these documents cannot be issued without a buyer, and it is impossible, if you do not provide us with the data, to make a commercial transaction with you.”

5. The legal basis for the collection of your personal data

www.promocrat.com processes “non-sensitive” personal data.

The legal basis for processing your “non-sensitive” or ordinary personal data is:

–       your consent. Requesting the consent we ask you to process your data justifies the processing of your personal data.

–       a contract to which you are a party, in the case of legal entities. As a result of the need to comply with a legal obligation to which we have committed ourselves and we are obliged by law to comply with it.

Your personal data are processed based on interests that are: real, legitimate and present.

The processing of your personal data is necessary in order to fulfill the legitimate interests that we pursue.

However, our legitimate interests may be overridden by your fundamental interests and rights.

www.promocrat.com Adequately protects your rights and freedoms, as well as your interests, based on the GDPR procedure manual.


6. The situations in which www.promocrat.com collects personal data.

www.promocrat.com collects personal data of its customers and website users.

Promocrat Media SRL processes your personal data in trade and marketing activities, in commercial activities, in the following situations:

–       Sale of services

–       Online marketing activities.

– Fiscal bills

–       Transactional emails. The emails through which we send you information about your request.

–       For marketing purposes, with the partners we work with: Google, Facebook, Hotjar, Email Marketing Automation and other online promotion networks, based on the terms and conditions of these platforms. The transmission of data to these service providers is done only with your consent and for marketing purposes, being transmitted automatically, through pseudonymization and encryption. These aspects will be dealt with automatically in point 7.


Your personal data are provided directly and freely, as a user of the website.


7. Automatic profiling and automation processes

www.promocrat.com can automatically process your data. This type of processing is done automatically and can represent, but is not limited to:

An analysis of your consumption characteristics and behavior
A prediction about your future behavior
It is done only by computer means, without the intervention of the human factor
It can be considered a profiling, but a fully automated one

Your personal data is used to make decisions about your future experience in the current experience. This is done on the basis of automatic decisions that realize the automated profiling of you, by means of a computer

The basis on which we perform this profiling is that if a user accesses a section of www.promocrat.com, then he is interested in that section, and we, through a completely automatic process, will come to his aid with personalized content, based on the analysis mentioned above.

These decisions have no impact on your rights as a person or your legal status. This type of fully automatic actions do not have a significant impact on your behavior and choices, their purpose being to help you choose the best decision.

The legal basis for data processing in this fully automatic profiling process is justified by our legitimate interest in carrying out our activity in optimal parameters or by the legitimate interest of a third party, such as Google or Facebook, who will deliver the information that is yours more relevant when you carry out a search process or express your intention to find a certain type of service.

In automated decision-making and automated profiling, only non-sensitive personal data is processed.


8. Storage of your personal data

Your personal data is not stored for a longer period than that which justifies our legal and economic activity. We do not store your personal data without a real basis or need for their use. Only those data are stored that are indispensable in carrying out our economic activity and honoring our commitment in relation to you.

Periodically, we analyze the stored data to identify if their purpose is current. If the purpose of keeping these data is not justified, they are deleted.

We also delete your personal data at the moment you send us this request, with the exception of those data whose provision and processing is required by a certain legal provision, where we will apply the term provided by law, for example, in the case of invoices, data storage is mandatory for a period of 5 years


9. Disclosure of personal data

Your data are disclosed to certain third parties, partners with the help of which we carry out our activity: e.g. the courier companies we worked with. This is done based on your consent.

The partners to whom we disclose your personal data are:

Google Ireland Ltd. – online marketing services

Facebook Ireland Ltd. – online marketing services

Mailchimp – newsletter marketing services

Hotjar.inc – user behavior monitoring services

Klaviyo – CRM

Just Ideas SRL – Accounting service

If your data will be disclosed, at the request of another recipient, then you will be notified of the moment of data disclosure, as well as of the identity of the person to whom this disclosure is made.


10. Transfer of personal data outside the EU

Your personal data are not transferred outside the EU.


11. Security of your personal data

www.promocrat.com has taken all the measures at its disposal to ensure adequate security of your personal data, through the following actions:

–       Adequate technical equipment

– SSL certificate and data security algorithms within the www.promocrat.com platform

–       Organizational and procedural measures specially created for this purpose limiting unauthorized and illegal processing

–       Prevention of accidental or illegal loss.

–       Prevention of accidental or illegal destruction.

For this purpose, we have implemented the following measures:

11.1. Security breach analysis

11.2. Documentation of security incidents

11.3. Identification of personal data that is incidentally impacted by Security

11.4. Actions necessary to remedy the security incident.

11.5. Limiting the consequences of Security incidents

11.6. Recovery of personal data

11.7. The return to the initial, normal state of personal data.

If a security or data loss accident is identified, it is immediately reported to the management of our company. At the same time, our personal data protection officer will identify if this incident has adverse effects on you and, if necessary, will inform the relevant staff in your organization or you. At the same time, we will analyze the need for the Supervisory Authority in relation to this incident.

At the same time, our DPO will take all measures to limit:

– accidental or illegal destruction of personal data,

–       accidental or illegal loss of control over personal data

–       access to personal data by unauthorized persons

–       accidental or illegal modification of your data

– Unauthorized transmission of personal data

Your information in case of a computer breach will be made:

–       if this unforeseen event is a significant one and has consequences on your security or integrity, physical or legal

–       in a time interval as fast as possible.


We do not have the obligation to notify you following an event or incident that concerned your personal data if:

–       we have taken all measures to encrypt and secure your data, so that it is impossible for any third party in our organization to access them.

–       There is no longer a risk for you, following the occurrence of the event.


12. Your rights

As a user of www.promocrat.com you have the following rights:

The right of access and information.

You have the right to be informed at any time if we use and process your personal data.

You have the right to be provided with confirmation that your data is being processed by us, if this happens, under the following conditions: the requested data includes only the data that concern you.

you have the right to have access to your personal data if you request this from us and if we process these data for you.

You have the right to receive a copy or archive of your personal data if you request this from us and, after confirming that we are processing your data, you also request a copy of them.

You have the right to modify, rectify or update your personal data. And we are obliged to rectify your data if: we are processing your personal data, they are not complete or accurate and you have requested an update or correction of them.

You have the right to delete your personal data.

We are obliged to delete your personal data without undue delay, if

–       we process your personal data, and

–       request the deletion of your personal data, and

–       your personal data are not necessary for us in matters that are regulated by law. For example, the data on the invoices cannot be deleted, because these documents must be archived for 5 years

–       there is no legal basis for data processing

–       we do not have your processing consent or you have withdrawn this consent

–       you find that your data is used for purposes you do not want, for example, marketing.

– The processing of your data is illegal

You have the right to obtain restrictions regarding the processing of your personal data, if: the data are not anonymous, include only information that concerns you or include other data that can be clearly linked to you.

We are obliged to restrict the processing of your data if:

–       you request this from us

–       we do not need your data in relations with third parties

–       request the data for a legal complaint or criminal complaint

– object that your data are necessary to carry out the www.promocrat.com activity, i.e. there is no legitimate basis for their processing

We are obliged to notify you about the restriction of the processing of your personal data.

Following the restriction of your personal data, we have the right to

–       their storage

– Their processing, based on your consent

–       Their processing in order to make a legal complaint

–       Their processing in order to make a criminal complaint

–       Their processing in the exercise of a public interest of the EU or a member state

If you obtain a restriction regarding the processing of your personal data, we must inform you before the restriction is lifted.

If your data is processed for digital marketing or other marketing purposes, you have the right to object to the processing of your data for this purpose, if the data processing includes personal data concerning you and includes pseudonyms or other data associations that can be clearly linked to you.

Following your objection, we are obliged to stop processing your data in this regard.

Communication regarding the exercise of your right regarding the processing of personal data is done in writing, to us, at the contact address yourstory@promocrat.ro

For your identification, you need to send us a valid identity document, CI, driver’s license or passport, which contains: identification number, country, validity period, full name, address, date of birth.

These elements aim to identify you as the initiator of the request and the owner of the personal data that we process. Any other elements apart from these can be hidden.

We will not accept other means of ensuring your identity.

To make the request, you need to have a valid email address.

After submitting the request, you will receive a reply to the email address from which the email was sent to us.

You will be informed, by the person we designated responsible for the protection and management of your personal data, ensuring that your request is analyzed and resolved.

The response time for resolving a request regarding your rights in relation to your personal data is 14 days

You have the right to file a complaint with a competent supervisory authority in your domicile, provided that it is in the EU or in the place where the abuse of your personal data took place.

The supervisory authority to which you submitted the complaint will inform you about the resolution of the complaint.

You have the right to start a judicial challenge procedure in the EU and in the EEA against a personal data operator, an intermediary or an authority through the EU.

Any changes to the privacy policy will be announced.

Previous versions of the privacy policy are not made available to the public and cannot be accessed.
For express requests, you can contact us at DPO@promocrat.ro