Privacy Policy

This Privacy Policy describes how Xuzaco Suyoni ("we", "us", "our"), operating at Calea Floreasca 169A, Bucharest, Romania, collects and processes personal data when you visit xuzaco-suyoni.info or contact us. We operate in compliance with Regulation (EU) 2016/679 (the General Data Protection Regulation, "GDPR") and Law no. 190/2018 on measures implementing GDPR in Romania.

Who we are

• Controller: Xuzaco Suyoni
• Address: Calea Floreasca 169A, Bucharest, Romania
• Email: [email protected]
• Phone: +40 800 672 671

Data we collect and why

• Contact enquiries. When you submit our contact form or email us, we collect your name, email address, and the content of your message. Legal basis: Article 6(1)(b) GDPR (steps prior to entering into a contract) and Article 6(1)(f) GDPR (our legitimate interest in responding to enquiries).
• Mailing list. When you subscribe to cohort notifications, we collect your email address. Legal basis: Article 6(1)(a) GDPR (your consent). You may withdraw consent at any time by emailing us.
• Website analytics. If you accept analytics cookies, we collect anonymised data about page visits, device type, and navigation paths. Legal basis: Article 6(1)(a) GDPR (your consent via the cookie banner).
• Necessary cookies. We set strictly necessary cookies to maintain session state and store your cookie preferences. Legal basis: Article 6(1)(f) GDPR (legitimate interest in operating a functional website). These do not require your consent.

How long we keep your data

• Contact form enquiries: retained for up to 24 months from the date of receipt, or until the matter is resolved, whichever comes first.
• Mailing list subscriptions: retained until you withdraw consent.
• Analytics data: retained in anonymised form for up to 26 months.
• Cookie preference records: retained for 12 months, after which consent is re-requested.

Who we share your data with

We do not sell or rent personal data. We may share data with:

• Hosting and infrastructure providers acting as data processors under Article 28 GDPR agreements.
• Analytics service providers, only if you have consented to analytics cookies.
• Competent public authorities, only where required by applicable Romanian or EU law.

No transfers of personal data to third countries outside the European Economic Area are made unless adequate safeguards exist under Chapter V GDPR (e.g., Standard Contractual Clauses).

Your rights under GDPR

You have the following rights, exercisable by contacting us at [email protected]:

• Access (Art. 15): request a copy of personal data we hold about you.
• Rectification (Art. 16): correct inaccurate or incomplete data.
• Erasure (Art. 17): request deletion where no legal basis remains for retention.
• Restriction (Art. 18): request that we limit processing in certain circumstances.
• Portability (Art. 20): receive your data in a structured, machine-readable format where processing is automated and based on consent or contract.
• Objection (Art. 21): object to processing based on legitimate interests.
• Withdraw consent: at any time where processing is based on consent, without affecting the lawfulness of prior processing.

You also have the right to lodge a complaint with the Romanian supervisory authority: Autoritatea Nationala de Supraveghere a Prelucrarii Datelor cu Caracter Personal (ANSPDCP), www.dataprotection.ro.

Security

We implement appropriate technical and organisational measures to protect personal data against unauthorised access, disclosure, alteration, or destruction, in accordance with Article 32 GDPR. No method of transmission over the internet is entirely secure; we take all reasonable steps to protect data.

Changes to this policy

We may update this Privacy Policy to reflect changes in law or our practices. The date at the top of this page indicates when it was last revised. Continued use of the website after an update constitutes acknowledgement of the revised policy.