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PRIVACY

Privacy Policy

Last updated: [[DATE - last updated / DATA ultimei actualizarii]]

1. Who we are (the data controller)

This Privacy Policy explains how [[COMPANY LEGAL NAME / DENUMIRE SOCIETATE]] ("Concept 360", "we", "us", "the company") processes personal data when you visit concept360.ro or contact us.

Data controller:

  • Name: [[COMPANY LEGAL NAME / DENUMIRE SOCIETATE]]
  • Registered address: [[ADDRESS / ADRESA SEDIU SOCIAL]]
  • Commerce Register no.: [[J__/__/____]]
  • Fiscal code (CUI): [[CUI]]
  • VAT number: [[VAT / cod TVA]]
  • Email: hq@concept360.ro
  • Phone: +40 743 922 934

2. What data we collect, why, and on what legal basis

We are a B2B video-production studio. The site has no online store, no user accounts, and no login. We collect a limited amount of data, as follows:

a) Contact data (when you email hq@concept360.ro, call us, or, in future, submit a contact form): name, email address, phone number, company name, and the content of your message.

  • Purpose: to respond to your enquiry, send a quote, and carry out pre-contractual and contractual steps.
  • Legal basis: Article 6(1)(b) GDPR (pre-contractual steps taken at your request and performance of a contract) where the individual contracts in their own name (sole trader, freelancer or individual client); and/or Article 6(1)(f) GDPR (our legitimate interest in responding to business enquiries and managing the commercial relationship) for representatives, employees or contact persons of business clients or prospects.
  • Provision of data: providing this data is voluntary; if you choose not to provide it, we cannot respond to your enquiries or send you quotes.

b) Embedded YouTube video content (on play): the site displays videos through a "facade" mechanism - the page loads only a locally hosted preview image, and YouTube content loads only when you press play on a video. Before that action, no content is loaded from Google/YouTube and no data is sent to them. Once you start playback, your browser connects to Google/YouTube servers (youtube-nocookie.com), which may receive your IP address and may set cookies or store data in localStorage.

  • Purpose: to display our video content.
  • Legal basis: Article 6(1)(a) GDPR - your consent, expressed through your explicit action of starting playback of a video.
  • Provision of data: playback is optional; if you do not start a video, no data is sent to Google/YouTube and the rest of the site works normally.

c) Server logs: like most websites, our hosting provider automatically records technical data such as IP address, browser type, pages accessed, and date and time of access.

  • Purpose: operation, security and stability of the site, and prevention of abuse.
  • Legal basis: Article 6(1)(f) GDPR (our legitimate interest in running a secure, functional website).
  • Provision of data: these logs are technically necessary to deliver and secure the site; they are generated automatically when you access the site and cannot be avoided if you use it.

3. Cookies and embedded content

The site sets no cookies and uses no analytics or tracking tools. The only situation in which cookies can appear is video playback: once you start a YouTube video, Google may set its own cookies, as described in section 4. If you do not start a video, no cookie is set.

4. Embedded YouTube videos

Embedded videos are provided by YouTube, a service of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Before you start playback, no data is sent to Google. Once you start a video, Google may receive your IP address and may set cookies/local data, in accordance with its privacy policy (policies.google.com/privacy). At that point, Google may process the data as an independent controller under its own terms and privacy policy; we do not control Google's downstream processing. YouTube content loads only upon your explicit action.

5. Third parties and recipients

We do not sell your data. We may disclose it to:

  • Google LLC / YouTube - only once you start playback of an embedded video.
  • Our web hosting provider - [[HOSTING PROVIDER - name + address / denumire + adresa]], which operates the site's servers (server logs).
  • Our email provider - to receive and manage correspondence.
  • Public authorities - where required by law.

6. International transfers

Some of our providers, such as Google LLC, are based in the United States. Where data is transferred outside the EEA, we rely on an adequacy decision (including, where applicable, the EU-US Data Privacy Framework for certified US recipients such as Google LLC) or on appropriate safeguards such as the European Commission's Standard Contractual Clauses, where these are in place. The applicable mechanism depends on the provider and is verified for each. Our hosting and email providers may store data inside or outside the European Union. You may request information about these safeguards.

7. Retention

  • Contact enquiries and correspondence: kept for up to [[RETENTION PERIOD for contact enquiries, e.g. 3 years / PERIOADA de pastrare a solicitarilor de contact, ex. 3 ani]] from your last contact, after which we delete or anonymise them, unless a legal obligation (for example, accounting or tax) requires longer retention.
  • Server logs: kept for a limited period in line with our hosting provider's practices, for security purposes.

8. Your rights

As a data subject, you have the following rights under the GDPR:

  • right of access;
  • right to rectification;
  • right to erasure ("right to be forgotten");
  • right to restriction of processing;
  • right to data portability, to the extent that processing is based on consent or on a contract and is carried out by automated means;
  • right to object to processing based on legitimate interest;
  • right to withdraw consent at any time, without affecting the lawfulness of processing before withdrawal.

Automated decision-making and profiling: we do not use your personal data for automated decision-making or profiling.

9. How to exercise your rights

Contact us at hq@concept360.ro. We will respond without undue delay and in any case within one month of receiving your request, in accordance with Article 12 GDPR (this period may be extended as permitted by law, with notice to you).

10. Right to lodge a complaint

If you believe our processing of your data infringes the law, you have the right to lodge a complaint with the Romanian National Supervisory Authority for Personal Data Processing (ANSPDCP):

  • Address: 28-30 G-ral. Gheorghe Magheru Blvd, Sector 1, postal code 010336, Bucharest
  • Email: anspdcp@dataprotection.ro
  • Website: www.dataprotection.ro

The right to lodge a complaint may also be exercised with the supervisory authority in your country of residence, place of work, or place of the alleged infringement, not only with ANSPDCP.

11. California residents (CCPA/CPRA)

The company likely does not currently meet the applicability thresholds of the California Consumer Privacy Act (CCPA), as amended by the CPRA. This is subject to change and should be verified by a lawyer. As a courtesy, if you are a California resident you may email us at hq@concept360.ro to exercise any applicable rights (for example, the right to know what personal information is collected, the right to request deletion, and the right to correct). We do not "sell" personal information and do not "share" it for cross-context behavioural advertising within the meaning of the CCPA/CPRA; loading YouTube embeds only upon the visitor's explicit action avoids such sharing.

Note: Visitors from other regions may have rights under the laws applicable in their own jurisdiction.

12. Data security

We apply appropriate technical and organisational measures to protect personal data; however, no internet transmission or hosting can be guaranteed completely secure.

13. Children and sensitive data

The site is not directed at children. Please do not send special-category (sensitive) data, such as data concerning health, ethnic origin, beliefs and the like, via our general contact channels unless it is necessary.

14. Changes to this policy

We may update this policy from time to time. We will post the revised version on this page with a new last-updated date. We encourage you to review it periodically.

15. Contact

For any question about this policy: hq@concept360.ro.