Privacy Policy

INTERNATIONAL TIBECOM & CO TRUST S.R.L., Romanian legal person, with headquarter in Brasov, CUI: RO 31960241 NR. BRAŞOV TRADE REGISTER: J8 / 1002/2013, as a data operator, please read this document carefully explaining how we process and protect your personal data.

Objective of the Information Note.

This notice applies to the processing of personal data of:

Our contractual partners such as suppliers, sellers, customers (“Business Partners”);

Visitors and users of our sites

If you do not fall into the above categories, please contact us at and we will provide you with an Information Notice for your situation.

What data do we collect about you?

We collect and process your personal data when interacting with us (for example, the information you provide by completing the form on our web site, by e-mail or in any other way). This includes information you provide when you access to use our website, participate in discussion forums or other social communication activities on our website. The information you provide may include the name, address, e-mail address and telephone number, personal description and photo, age, date of birth and gender, as well as other information as appropriate.

We will not collect or process sensitive personal data related to you (eg information about racial or ethnic origin, political opinions, religious confession or philosophical beliefs, health, sexual life, or sexual orientation.) If you voluntarily provide us with data (including sensitive personal data) through your interaction with our websites or by contacting us by phone, e-mail or in any other way, by your own will and not at our request, we will delete such personal data from our systems.

Every time you visit our website, we automatically collect the following data:

– technical data, for example, this may include the Internet Protocol (IP) Address used to connect your computer to the Internet, connection information, browser type and version, time zone setting, browser plug-ins types and versions, system and operating platform, device type and brand of mobile device; these data may be collected and processed on our behalf through third-party cookies, and you may find more information about this at

– information about your visit, for example this may include Complete Uniform Resource Locators (URL), sequence of clicks to, through and from our websites (including date and time), information or products you have viewed or searched for (including top read articles, top access categories, pagan response times, download errors, duration of visits to specific pages (including the average time spent on certain pages, viewing certain content or videos) an app and the number of views in such apps, the average number of articles viewed on our Websites, page interaction information (such as scrolling, mouse clicks and crossings), methods used to navigate the page, data about User behavior and any phone number used to call or any email address used to contact our customer service representatives.

In some cases, we obtain your personal data (such as your name, address, email address and phone number, personal description and photo, age, date of birth, and sex) from third parties such as business partners, technical, payment and delivery service subcontractors, advertisers, analytical service providers, market research service providers, credit information agencies. When you visit and register with one of our online platforms, we may obtain your personal data from a third-party social communication provider if you volunteer to register through that third-party social communication platform.

If we obtain your personal data from a third party, we will provide you with all relevant processing information as soon as possible but in any case no later than one month after receiving your personal data, including the categories of personal data undergoing processing, the purpose of the processing and its legal basis.

How we use personal data

General aspects

We may process your personal data if we have to execute a contract that we have concluded with you; whether we have to comply with a legal obligation (for example, the applicable laws on labor relations, accounting, auditing, monitoring of equal opportunities); when it is necessary for our legitimate interests (or those of a third party) and for your interests (for example, for detecting and preventing fraud or for ensuring IT security and networks), unless your fundamental rights prevail over of these interests; if it is necessary to protect your vital interests (or the vital interests of others); and / or where it is necessary for the public interest or for official purposes.

We process your personal information for a variety of technical, administrative, and operational reasons, such as ensuring that content is presented in the most efficient way for you and your computer; to improve our Websites, including its functionality; for the administration of our Websites; for internal operations, including for refresher purposes, data analysis, testing, research, statistics and research; for advertising and marketing, including for specific marketing purposes, so as to provide content, including personalized content, that may be of greater interest to you; as well as as part of our efforts to keep our Websites safe.

In some cases, we will process your personal data only with your consent. In these cases, we will separately request your consent, in a transparent manner, when providing your personal data. You will then be able to withdraw your consent at any time via the email address However, withdrawal of consent will not affect the legality of any processing that occurred prior to its withdrawal.

If we require personal data to comply with legal or contractual obligations, the provision of such personal data by you is required. This means that if such personal data is not provided, we will not be able to manage contractual relationships or comply with our obligations. In all other cases, the provision of personal data is optional and you are not required to provide it.

We may also process your personal data, such as your identification, contact details, and residence address, for the purposes of the possible exercise of our rights or claims against you in the future. This processing is based on our legitimate interest, and we need to exercise our rights in case of possible litigation.

Most often, we will use your personal information in the following situations:

Commercial Partners:

For the purpose of providing services, delivering goods and making payments based on relevant contracts, we may process your personal data, such as identification data, business contact details, bank details, and tax identification code, for persons registered in VAT purposes. This processing is based on (i) the execution of a contract to which you, as a Business Partner, are a party, (ii) legal obligations imposed on us, and (iii) our legitimate interest.

In some cases, we process personal data such as the names and contact details of employees or contractors of the Trading Partners for the purposes of communications relating to the execution of a particular contract with the Trading Partners. This processing is based on (i) the performance of a contract to which the Trading Partners are a party, (ii) the legal obligations imposed on us, and (iii) our legitimate interest.

Being a Commercial Partner, we can provide you with communications about our new products and services. If you no longer wish to receive these communications, you may opt-out by sending us an email to

Users and customers:

For the purpose of providing services, delivering goods and making payments based on relevant contracts (including subscriptions), we may process your personal data, such as identification data, contact details, banking data. This processing is based on the execution of a contract to which Users (especially subscribers) are party to or a legal obligation imposed on us.

We will not share your personal data with third parties for marketing purposes without your explicit consent to that effect.

We may also use your personal data to measure or understand the program’s preferred content and to provide content relevant to you; to let you participate in the interactive features of our service when you choose to do so; to measure or understand the effectiveness of advertising we offer you and others and to provide you with relevant advertising; and to make suggestions and recommendations to you and other Users of our Websites about products or services that may be of interest to you or them.

How and to whom we disclose your personal data

We do not sell your personal data to third parties.

Within the Company, only a limited number of staff members, such as Sales, Legal, News and IT departments, have access to your personal data according to the need-to-know principle. These staff members are subject to confidentiality obligations with respect to personal data. Appropriate technical and organizational measures are taken for the protection of personal data. Company staff members have the right to manage personal data only on Company’s instructions and, if necessary, on service responsibilities.

Personal data may be communicated to governmental authorities and / or law enforcement agencies if required by applicable law or if necessary for the exercise of our rights, including conditions of use, or for the protection of our legitimate interests (including legitimate interests of third parties) in accordance with the applicable laws.

Your personal data may also be disclosed to third parties, including:

(i) service providers providing administrative, professional, and technical support to the Company for IT, security and commercial resources support;

(ii) business partners, suppliers, and subcontractors for the execution of all the agreements we make with you (including subscriptions to our services);

(iii) advertisers and advertisers who request your information to select and deliver advertising relevant to you. We do not disclose identifiable information to advertisers, but we will provide aggregate information about our users. We can also use aggregated information to help advertisers reach the type of audience they are targeting. We may use the personal information we have collected from you to respect the wishes of the advertisers by displaying their advertising messages to the target audience;

(iv) analytics and search engine providers that help us improve and optimize our Websites.

The company may also disclose personal data to external consultants (eg lawyers, accountants, auditors) if necessary.

The Company wishes to carry out an appropriate prior assessment of the selection of third party service providers and requires these service providers to maintain adequate technical and organizational security measures to protect personal data and process personal data only in accordance with the Company’s instructions. Service providers will be entitled to use subcontractors to provide services to the Company, provided that the subcontractor respects the same data protection obligations as service providers.

Storing your personal data and transferring abroad

Your personal data that we collect is stored in the European Union (“EU”) and in the European Economic Area (“EEA”). However, information collected by third parties through cookies will generally serve traffic from a data center closest to where the traffic originates. This means that such information, including ad traffic, can be managed by servers located in the EEA and can be transferred outside the EEA. For more information, see the Cookies Policy

In addition, your personal data can be transferred and stored in a non-EU and EEA location. When your personal data is transferred from your own country to another country, the laws and rules that protect your personal data in the country to which your information is transferred may be different (or may offer less protection) than those in the country where you work.

We intend not to transfer your personal data outside the EEA if there are no adequate safeguards, including: (i) a decision on the appropriateness of the European Commission regarding the country or countries of destination; (ii) “confidentiality shield” certification; (iii) appropriate corporate governance rules; (iv) an approved Code of Conduct, together with the binding and enforceable commitments of the data controller or person authorized by the data controller in the country outside the EU and EEA; (v) an approved certification mechanism, together with the binding and enforceable commitment of the data controller or the person empowered by the data controller in a non-EU and EEA country to apply the appropriate safeguards; or (vi) EU standard contractual clauses approved by the European Commission.



You can ask us to confirm that your personal data is processed by us or not, to provide you with a copy of your personal data and / or to correct it. Under certain circumstances, you have the right to ask us to delete your personal data or, under the right of portability, to ask us to transfer part of your personal data to you or to other entities. You also have the right to oppose processing of your personal data (for example, the use of processing for direct marketing purposes or certain decisions taken only through automated processing (including profile creation) If we process your personal data because we have a legitimate interest in doing so (as explained above), you have the right to withdraw this consent without any adverse effects on you. you also have the right to oppose such processing You may also restrict the processing of your personal data under certain circumstances Please note that your rights described above may be limited in some situations and subject to the laws and regulations applicable on p personal data rotation, for example, your right to oppose the processing of your personal data may be limited if we can demonstrate that we have compelling legitimate reasons to process your personal data that overrides your interests. You will need to prove your identity and provide us with further details to help us respond to your request. We will not charge a fee to meet your request unless this is permitted by law and, if such a fee is levied, it will be reasonable and proportionate to your request. If you wish to exercise these rights, please contact us through the contact persons listed below. We hope that we can answer all your questions about how we process your personal data. However, you also have the right to file a complaint with the data protection supervisors. You can file a complaint in the Member State where you live, where you are working or where the alleged data protection violation occurred.

How long do we keep your personal data

We intend to retain your personal data only for as long as is necessary in accordance with our Data Retention Policy for a period not exceeding the period required to meet the purposes set forth in this Information Note and / or required by applicable law, in accordance with the applicable legal minimum retention periods and / or as necessary to exercise our legitimate rights (and the legitimate rights of others). For example, if you are a Commercial Partner, we will retain your personal information while exercising your contractual relationship with you. If we have a continuing commercial relationship with you as a Commercial Partner (for example, if we can use the same personal data in separate contractual relationships with you), we will continue to keep this personal data until termination our business relationship and the minimum retention period required by law, subject to our Data Retention Policy. If you would like more information about how long we keep your personal data, please contact us at Please be aware that we may process any of your personally-identifiable personal data without first notifying you.

If we process your personal data under your consent, such personal data will be processed only for the period of your consent, unless you withdraw or limit your consent before the expiration of that period. In such cases, we will cease processing the relevant personal data for the relevant purposes, subject to any legal obligation to process such personal data and / or our need to process such personal data for the purposes of our legitimate rights (including the legitimate rights of others).


Data security

We keep your data on our servers and servers hosted by third parties. We use appropriate technical and organizational measures to protect your personal data and prevent unauthorized access. We have entered into contractual relationships with third parties providing hosting services and these contracts include obligations on the organizational and technical security of personal data. All payment transactions will be encrypted (for example, using the TLS protocol). You are responsible for maintaining the confidentiality of all means of authentication (eg passwords) used by you to access parts of our Websites. Data transmission over the Internet is not completely secure. While we will do our best to protect your data, we can not guarantee the security of your data transmitted to our Websites; any transmission is at your own risk. Once we receive your data, we will use strict procedures and security features to try to prevent unauthorized access.

Privacy of minors

The Company does not knowingly collect personal identification data on its Web sites from people under the age of 16. If a parent or guardian is aware that his children have provided the Company with their personal data, they must immediately inform the Company. If the Company discovers that a person under the age of 16 has provided personal data, the Company will destroy this information from its servers immediately, unless its parent’s tutor gives explicit consent to the processing of to the company’s personal data of the child for the specified purposes.

Cookies and social communication widgets

Our websites use cookies to distinguish you from other users of our Web sites. This helps us give you a good experience when browsing our Websites and also enables us to improve our Website. This processing is based on your consent expressed on our Websites or the settings in your browser. For detailed information about the cookie files we use, how long we use them and the purposes for which we use them, see our Cookies Policy

Our websites can include social communication features, such as Facebook, Twitter, Instagram, LinkedIn or Youtube buttons. These features can collect information about you, such as the IP address and websites you visit, and set a cookie to allow it to function properly. The processing of this information through interactions with these features is governed by the privacy notice / privacy policy of the company providing it (see the section on your rights above).


Links to other websites

A Website may provide links to websites that the Company does not control. Once you click on a third-party link, you will be directed to the third-party website. If you visit any of these linked websites, you need to review their privacy policies. We are not responsible for the policies and practices of other companies. Our company does not control and assumes no responsibility for the content, privacy policies and notices or practices of third-party websites or services.

Delete data

If you wish to delete all existing data on you can do so by writing to the



If you have any questions or concerns regarding the processing of your personal data or if you wish to exercise your right, you can contact us at

Please do not disclose sensitive personal data (eg information about racial or ethnic origin, political opinions, religious or other beliefs, health or membership of a trade union), social security numbers or information related to the criminal record when you contact us.


We may update this Information Note from time to time and we will notify you of any change by posting the new version on our web sites listed in Section 1 above. If you have provided us with your contact information and authorized us to contact you, we will notify you if we modify this notice substantially.

Please refer to this Periodic Notice for any changes.

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