Privacy Policy

1. PREAMBLE AND COMMITMENT

PRIME DASH DEVELOPMENT SA ("PRIME DASH", "we", "us", or "our") considers the protection of personal data a fundamental commitment. We dedicate all necessary resources to process your data in full compliance with Regulation (EU) 2016/679 (GDPR) and applicable Romanian legislation.

In the spirit of transparency, this policy details how we collect, use, transfer, and protect your personal data when you interact with our products, services, website, or mobile applications. We reserve the right to update this policy to reflect changes in legal requirements or our processing activities. The latest version will always be available on our website.

2. WHO WE ARE (DATA CONTROLLER)

PRIME DASH is the data controller regarding your personal data.

• Trade Name: PRIME DASH DEVELOPMENT SA
• Registered Office: Oradea, str. Tudor Vladimirescu, no. 17, Bihor county, Romania
• Fiscal Identification (CUI): RO 41599013
• Trade Registry Number: J05 / 2146/2019
• Legal Representative: Rus Cătălin
• General Email: contact@primedash.com

Data Protection Officer (DPO):

For any concerns regarding your data privacy, you may contact our DPO directly at: dpo@primedash.com.

3. CATEGORIES OF PERSONAL DATA PROCESSED

We primarily process data belonging to representatives of legal entities using our services. Note: The Prime Dash platform is B2B (Business-to-Business). Financial data, reports, and graphs regarding the legal entity (company) you represent are not considered personal data under GDPR.

We collect data directly from you in the following ways:

A. Data you provide directly

• Contact Forms: Name, surname, and email address when you send us a message.
• Service Usage: Name and surname of the legal representative, email address.
• Contractual Relationship: Name, surname, email of the legal representative, and IP address.

B. Data collected automatically

• Technical Data: When using our website or app, we may collect information via cookies (see Section 10), IP addresses, and device information.

C. Exclusions

• Payment Data: We do not store full card details. Online payments are processed by an authorized third-party payment processor responsible for transaction validation.
• Sensitive Data: We do not collect special categories of personal data (e.g., health, religion, ethnicity).
• Minors: We do not knowingly collect data from minors under the age of 16.

4. PURPOSES AND LEGAL GROUNDS FOR PROCESSING

We process your data for the specific purposes listed below:

Purpose

Legal Basis (GDPR)

1. Providing Services: Account creation, subscription administration, invoicing, giving access to the platform, and identity validation.

Art. 6(1)(b) - Contractual Necessity: Processing is required to execute the contract between you and PRIME DASH.

Art. 6(1)(c) - Legal Obligation: Compliance with fiscal and accounting laws.

2. Service Improvement: Analyzing user behavior, satisfaction questionnaires, and market research to improve the user experience.

Art. 6(1)(f) - Legitimate Interest: Our interest in developing our commercial activity without harming your rights.

3. Marketing: Sending newsletters, offers, or information on complementary products via email/SMS/push notifications.

Art. 6(1)(a) - Consent: Given at account creation.

Art. 6(1)(f) - Legitimate Interest: In specific existing client relationships. You may withdraw consent or unsubscribe at any time.

4. Security & Defense: Protecting against cyber attacks, fraud prevention, risk management, and defending legal rights.

Art. 6(1)(f) - Legitimate Interest: Protecting our business and users.

Art. 6(1)(c) - Legal Obligation: Cooperating with authorities.

5. DATA RETENTION

We retain your personal data for a period of 3 years from the date of your last interaction with us (e.g., sending a contact form, requesting an offer, or communicating via email).

• Upon expiration of this retention period, or if the data is no longer necessary for the purpose for which it was collected, it will be securely deleted, destroyed, or anonymized so that it cannot be reconstituted.

6. DATA RECIPIENTS

To provide our services, we may transmit your data to:

• Companies within the PRIME DASH group.
• Service Providers: Payment processors, marketing/telemarketing agencies, market research firms, and IT/Cloud service providers.
• Public Authorities: Only when required by law or to defend a legitimate interest.

We ensure all third-party partners are bound by confidentiality agreements and process data in compliance with GDPR.

7. INTERNATIONAL DATA TRANSFERS

We currently store and process data primarily within the European Union (EU).

However, if we transfer data to service providers (e.g., servers/partners) in the United States or other non-EU countries, we ensure appropriate safeguards are in place.

• Note on US Transfers: Transfers are protected by Standard Contractual Clauses (SCCs) approved by the European Commission or, where applicable, the EU-US Data Privacy Framework, ensuring a level of protection equivalent to that in the EU.

8. DATA SECURITY

We implement industry-standard technical and organizational measures to protect your data, including:

• Encryption: Data transmission is encrypted using HTTPS with TLS 1.2.
• Secure Storage: Usage of dedicated, secure servers with redundancy.
• Access Control: Strict limitations on who can access your data internally.

Disclaimer: While we take every measure to protect your data, transmission over the Internet is never 100% secure. We cannot guarantee the security of data transmitted to our site; any transmission is at your own risk.

9. YOUR RIGHTS (GDPR)

Under GDPR, you have the following rights regarding your personal data:

1. Right of Access: To confirm if we process your data and receive a copy of it.
2. Right to Rectification: To correct inaccurate or incomplete data.
3. Right to Erasure ("Right to be Forgotten"): To ask us to delete data if it is no longer needed, consent is withdrawn, or processing was unlawful.
4. Right to Restriction: To suspend processing in specific cases (e.g., while verifying data accuracy).
5. Right to Data Portability: To receive your data in a structured format or transfer it to another controller.
6. Right to Object: To oppose processing based on legitimate interest or for direct marketing.

How to exercise rights:

Please submit your written request to dpo@primedash.com. We will respond within one month (extendable to two months for complex requests). Identification may be required to protect your privacy.

Complaints:

If you believe your rights have been violated, you may file a complaint with the National Supervisory Authority for Personal Data Processing (ANSPDCP):

• Address: B-dul G-ral. Gheorghe Magheru 28-30, Sector 1, Bucharest, 010336
• Email: anspdcp@dataprotection.ro

10. COOKIE POLICY

What are Cookies?

Cookies are small text files stored on your device when you access the internet. They are "passive" (they do not contain viruses or spyware) and help websites function efficiently or recognize your device.

How We Use Cookies

We use cookies to:

• Keep you logged in and retain preferences (e.g., language, currency).
• Analyze site traffic and performance to improve services.
• Deliver relevant advertising (if consented).

Types of Cookies Used

1. Strictly Necessary: Essential for the site to work (e.g., logging in, security). These cannot be disabled.
2. Functional: Remember your choices (language, username) for a better experience.
3. Analytics/Statistics: Anonymous data regarding how visitors use the site.
4. Marketing/Tracking & Social Plugins:
   
   • Used by third parties (e.g., Facebook, LinkedIn, Google) to build a profile of your interests and show relevant ads.
   • Social Plugins: We use plugins (e.g., Share buttons). These are disabled by default. If you click to activate them, data may be transferred to the respective social network.

Managing Cookies

You can manage your preferences via the Cookie Consent Bar at the bottom of our website. Additionally, you can block or delete cookies through your browser settings (Chrome, Firefox, Safari, etc.). Please note that disabling necessary cookies may render parts of the PRIME PAY platform unusable.

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