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Privacy Policy

Your privacy is critically important to us.

Last updated: 13 October 2026

This Privacy Policy explains how S.C. Asperitas Solutions S.A.
processes personal data when you visit asperitas-solutions.com (the
“website”) or contact us through it. It is provided under Article 13 of
Regulation (EU) 2016/679 (the “GDPR”).

1. Who we are

The controller of your personal data is:

S.C. ASPERITAS SOLUTIONS S.A. (“Asperitas
Solutions”, “we”, “us”) Aleea Cioplea nr. 14, parter, cam. 1, 500473
Brașov, Romania Trade Register no.: J2017000985084 (formerly
J8/985/2017) VAT / CUI: RO37465749 Email: contact@asperitas-solutions.com
Phone: +40 726 329 199

For any question about this policy or to exercise your rights, write
to contact@asperitas-solutions.com.

We have not appointed a Data Protection Officer.

2. Scope

This policy covers the website and enquiries made through it or by
email or phone before any contract.

We provide B2B software services (IPTV, Android TV and AI solutions).
Personal data we process for or on behalf of clients during a project is
governed by the relevant client contract and, where applicable, a data
processing agreement, not by this policy.

Data Purpose Legal basis
Contact form and email/phone enquiries: name, email
address, message content, and any other details you choose to include;
phone number if you call us		 Answering your enquiry and, where relevant, preparing an offer or
discussing a possible project		 Steps taken at your request before entering into a contract (Art.
6(1)(b) GDPR); where the enquiry is not about a possible contract, our
legitimate interest in answering messages sent to us (Art. 6(1)(f))
Server logs: IP address, date and time of the
request, page requested, referring page, browser and operating system,
response code		 Operating the website, ensuring its security and investigating
misuse or errors		 Our legitimate interest in running a secure website (Art.
6(1)(f))
Consent records: your cookie choices, stored by the
Complianz consent banner on our server and in your browser		 Remembering and documenting your consent choices Our legitimate interest in respecting and being able to demonstrate
your choices, as required by Art. 7(1) GDPR (Art. 6(1)(f))
Analytics data (Google Analytics 4, only after you accept
statistics cookies): pages viewed, visit duration, approximate
location, device and browser information, IP address (processed by
Google), online identifiers stored in cookies		 Understanding how the website is used so we can improve it Your consent (Art. 6(1)(a)), which you can withdraw at any time
Embedded YouTube videos (only after marketing
consent): once a video is unblocked, your browser connects to
YouTube, which receives your IP address and device and browser
information and may set cookies or similar identifiers		 Showing videos about our solutions Your consent to marketing cookies (Art. 6(1)(a)), which you can
withdraw at any time
Business correspondence that leads to or relates to
a contract		 Managing the business relationship, accounting and tax
compliance		 Performance of a contract (Art. 6(1)(b)) and legal obligations (Art.
6(1)(c))
Data needed for legal claims Establishing, exercising or defending legal claims Our legitimate interest (Art. 6(1)(f))

Where we rely on legitimate interests, we have balanced them against
your rights. You can ask us for more information about this
assessment.

We do not send newsletters or marketing messages, and we do not use
your data for that purpose.

Google Analytics 4. We use Google Analytics 4
(measurement ID G-SKKEEEDV5D) to produce statistics on how the website
is used. Google Analytics is fully blocked by the Complianz consent
banner and loads only after you accept statistics cookies. We do not use
Google Consent Mode, so no data is sent to Google before you accept, or
at all if you refuse. We have turned off Google Signals and the sharing
of Analytics data with Google for its own products and services. You can
withdraw your consent at any time using the “Manage consent” button
(section 8).

Fonts. The website’s fonts are served from our own
server, so loading them does not send your data to Google.

Please do not send us special categories of data (for example health
data) or unnecessary data about other people in your messages.

4. Is providing data
mandatory?

  • Enquiries: name, email address and message are
    needed to reply. Without them we cannot answer.
  • Server logs: collected automatically; they are
    needed to deliver the website securely.
  • Analytics and videos: entirely optional. If you do
    not consent, you can still use the website; Google Analytics does not
    load unless you accept statistics cookies, and the videos do not load
    unless you accept marketing cookies.

5. Who receives your data

Your data is accessed by authorised Asperitas Solutions staff. We
also use the following service providers, who act as our processors
under a contract (Art. 28 GDPR) unless stated otherwise:

  • Easyhost S.R.L. (Bd. Dimitrie Pompeiu nr. 8,
    Clădirea FEPER HPE, et. 5, cam. 503, biroul 27, Sector 2, 023255
    Bucharest, Romania; CUI RO18542039) – website hosting on servers in
    Bucharest, Romania (server logs).
  • Google Workspace – business email, including
    delivery of contact-form messages. Provided by Google Cloud EMEA
    Limited, Velasco, Clanwilliam Place, Dublin 2, Ireland, with processing
    also by Google LLC, USA.
  • Google Analytics 4 – website statistics, only after
    you accept statistics cookies. Provided by Google Ireland Limited
    (Gordon House, Barrow Street, Dublin 4, Ireland), which acts as our
    processor; data may also be processed by Google LLC, USA (see section
    6).
  • YouTube (Google Ireland Limited, with processing
    also by Google LLC, USA) – embedded videos. We use standard YouTube
    embeds, which the consent banner blocks until you accept marketing
    cookies. Once unblocked, YouTube sets cookies and receives your IP
    address and device data, and Google may use them for its own purposes,
    including advertising; for that processing Google acts as an independent
    controller and its privacy policy applies: https://policies.google.com/privacy.
  • Complianz – we use the free Complianz plugin, set
    to EU opt-in mode, for the consent banner. It runs on our own website;
    consent choices are stored on our server and in your browser. No consent
    data is sent to Complianz or to cookiedatabase.org, because the plugin’s
    cookie scan and sync features are not activated.
  • Professional advisers (for example accountants or lawyers) and
    public authorities, where required by law or needed to protect our
    rights.

We do not sell your personal data.

External links. The website links to other websites,
including pages about the EU-funded project SMIS 150887 and our social
media profiles. We do not share your data with these sites when you view
our pages. If you follow a link, the other site’s own privacy policy
applies.

6. Transfers
outside the European Economic Area

Google LLC may process data in the United States, including data from
Google Workspace, Google Analytics and YouTube. Such transfers are based
on:

  • the European Commission’s adequacy decision for the EU-U.S. Data
    Privacy Framework, under which Google LLC is certified; and/or
  • the European Commission’s Standard Contractual Clauses included in
    Google’s data processing terms.

You can ask us for more information about these safeguards at contact@asperitas-solutions.com.

7. How long we keep data

Data Retention
Contact messages, enquiries and related correspondence that do not
lead to a contract		 12 months after the last contact
Server logs For the period set by the hosting provider, normally no longer than
30 days
Google Analytics 4 data Event data: 2 months; user data: 14 months (settings of our Google
Analytics property). The Google Analytics cookies in your browser last
up to 2 years unless you delete them
Consent records 6 months, after which we ask for your choices again
Accounting records and related business correspondence, where a
contract follows		 10 years, as required by Romanian accounting law (Law No.
82/1991)
Data needed for legal claims Until the claim is resolved and limitation periods have expired

After these periods, data is deleted or anonymised.

8. Your rights

Under the GDPR you have the right to:

  • access your personal data and receive a copy (Art.
    15);
  • rectification of inaccurate or incomplete data
    (Art. 16);
  • erasure of your data where the legal conditions are
    met (Art. 17);
  • restriction of processing (Art. 18);
  • data portability for data you provided to us, where
    processing is based on consent or contract and carried out by automated
    means (Art. 20);
  • object at any time, on grounds relating to your
    particular situation, to processing based on our legitimate interests
    (Art. 21);
  • withdraw your consent at any time, without
    affecting the lawfulness of processing before withdrawal. You can change
    your cookie choices at any time using the floating “Manage consent”
    button at the bottom of every page of the website.

To exercise your rights, email contact@asperitas-solutions.com.
We will reply without undue delay and within one month at the latest;
this can be extended by two further months for complex requests, in
which case we will tell you. We may ask for information to confirm your
identity.

9. Right to complain

If you believe our processing of your data breaches the GDPR, you can
lodge a complaint with a supervisory authority, in particular in the EU
country where you live, work or where the alleged breach occurred. In
Romania this is:

Autoritatea Națională de Supraveghere a Prelucrării Datelor
cu Caracter Personal (ANSPDCP) B-dul G-ral. Gheorghe Magheru
28-30, Sector 1, 010336 Bucharest, Romania Phone: +40 318 059 211 Email:
anspdcp@dataprotection.ro
Website: https://www.dataprotection.ro

We would appreciate the chance to resolve your concern first, so
please feel free to contact us beforehand.

10. Automated decision-making

We do not make decisions based solely on automated processing,
including profiling, that produce legal effects concerning you or
similarly significantly affect you (Art. 22 GDPR).

11. Children

The website is aimed at businesses and is not directed at children.
We do not knowingly collect data from anyone under 16. If you believe a
child has sent us personal data, contact us and we will delete it.

12. Security

We use technical and organisational measures appropriate to the risk
to protect personal data, including encrypted connections (HTTPS) to the
website and access to data limited to authorised staff. No method of
transmission or storage is completely secure, but we work to protect
your data and to keep our measures up to date.

13. Cookies

If you accept statistics cookies, Google Analytics sets the cookies
_ga (distinguishes visitors) and
_ga_SKKEEEDV5D (the _ga_<ID> cookie,
which keeps the session state), each lasting up to 2 years. For details
of all the cookies and similar technologies used on the website and how
to manage your preferences, see our Cookie
Policy.

14. Changes to this policy

We may update this policy, for example when we add new website
features or the law changes. The current version is always published on
this page with its “Last updated” date. If we make significant changes,
we will highlight them on the website.