Privacy policy

This privacy policy sets out how we collect, use, store, and protect ("process") any personal information you provide to us when using the Onchat.ai website (hereinafter referred to as Onchat). By continuing to use Onchat, you accept this policy. The Onchat.ai website is owned and operated by Soldigo SRL, headquartered at Str. Piata Libertatii, Nr. 10, registered with the Trade Registry under no. J19/60/2023, having VAT number: 47568261 (hereinafter referred to as the Owner, operator, administrator, company).

Certain personal information is essential for the operation of Onchat and for providing services to you. If you do not wish to allow us to process your data, you will not be able to use our services.

Useful contact details and a summary of the control you have over your personal data can be found at the end of this policy.

Compliance

In processing personal data, we will comply with the relevant legislation in force in Romania. We may amend this policy from time to time by updating it as we improve our service to you and as relevant data protection legislation comes into effect. Your personal information will be kept in accordance with our evolving policy. We will not diminish your rights under this policy without your explicit consent.

Principles of processing personal data

Personal data collected will be:

• processed lawfully, fairly, and transparently to the data subject ("lawfulness, fairness, and transparency")
• collected for specified, explicit, and legitimate purposes and not further processed in a manner incompatible with those purposes ("purpose limitation")
• adequate, relevant, and limited to what is necessary in relation to the purposes for which they are processed ("data minimization")
• accurate and, where necessary, kept up to date ("accuracy")
• kept in a form that permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed ("storage limitation")
• processed in a manner that ensures appropriate security of personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction, or damage, by taking appropriate technical or organizational measures ("integrity and confidentiality")

What does personal data mean?

According to the definition of EU Regulation 2016/679 on the protection of individuals with regard to the processing of personal data and on the free movement of such data:

• "personal data" means any information relating to an identified or identifiable natural person ("data subject"); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or one or more specific factors specific to his physical, physiological, genetic, mental, economic, cultural, or social identity.
• "data controller" means according to Article 4 of the General Data Protection Regulation, the natural or legal person, alone or jointly with others, who determines the purposes and means of processing personal data; where the purposes and means of processing are determined by Union law or by the law of a Member State, the controller or the specific criteria for its designation may be provided for by Union law or by the law of a Member State. "data processor" means a natural or legal person who processes personal data on behalf of the controller.

International transfers

Soldigo SRL (Onchat) is a company registered in Romania. In order to provide our services, we may transfer your personal data outside the European Economic Area (EEA), European Economic Area (EEA), and to/from Romania. We may do this to record your service needs, process your orders, record your preferences, manage your account with us, and fulfill our regulatory obligations. To protect your data, we only make these transfers to territories that the relevant authorities of the European Union consider to provide "adequate" protection and/or we have valid contractual agreements in place to protect your data.

Age Limit

Please note that this website is not intended for use or registration by individuals aged 18 years or younger.

Data Controller and Data Processor

We collect data related to three groups:

• I. Visitors to our website whom we describe our services to ("Visitor").
• II. Our customers who have registered for our services ("Client").
• III. Individuals who view information or purchase products through our customers' websites ("Buyers").

Therefore, we are data controllers for the following types of data:

• If you only analyze our services, we will normally collect data indirectly, but we can also do this directly if you interact with us on social media platforms, for example.
• If you are our Client, we will collect both indirect and direct data.

If you are a Buyer, we will collect data only to the extent necessary to provide services to our clients, and our Client remains the Data Controller who is responsible for the decision to use your data by us. If you have any questions regarding personal data held by one of our clients, you should directly contact the client with whom you have interacted. Legal Basis for Data Processing

We are obligated to process your personal data in a lawful, fair, and transparent manner.

Consent - if you are a Visitor, you will consent to our cookie policy to continue viewing our site. We detail below the extent of the indirect use of data, which is anonymized and not designed to individually identify you.

Contract - if you request information regarding entering into a contract with us or if you are a Client, we process the data necessary to respond to your request and provide you with the service. Our service includes information about managing the online business through the newsletter as part of this Service.

Legitimate Interest - if we are required to retain information for legal purposes, for example, if you have been a Client, we do so within our legitimate business activities as a legal entity.

Indirect/Anonymous Tracking of Data

Onchat indirectly/anonymously tracks certain personal data when you visit our website.

Cookies

You can choose to accept or decline cookies on our website.

A cookie is a small file that is placed on your device when you visit a website. The file is added, and the cookie helps analyze web traffic or informs you when you visit a particular site. Cookies help us provide you with a better website, tailoring the site's operations to your needs and responding to you as an individual user, identifying, for example, pages you find useful or not useful. Such a cookie does not give us access to your computer or any information about you, other than the data you choose to share with us.

We use traffic log cookies to identify which pages are being used. This helps us analyze data about web page traffic and improve our website to tailor it to customer needs. We only use this information for statistical analysis purposes and it does not identify you as an individual.

By browsing our website, Onchat tracks your usage to provide you with a better user experience regarding your browsing habits. This helps us analyze data about traffic on social networks and improve Onchat to tailor it to the needs of our customers.

Google Analytics

Our website uses Google Analytics, an analytics service provided by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Google Analytics allows us to analyze the usage of our website and application.

Information about your visit collected by Google Analytics is typically transferred to a Google server in the USA and stored there. Google will use the information collected on behalf of the application operator to evaluate users' use of the application, to compile reports on user activity within the application, and to provide other services related to the use of the application to the application operator.

We will not collect any personally identifiable information about you through Google Analytics. You can find more information about the data that can be collected through Google Mobile App Analytics at http://support.google.com/analytics/bin/answer.py?hl=en&answer=2568871.

By using the site, the user explicitly consents to the collection of their information through Google Analytics.

Onchat collects the following types of information:

• Identification of your previous and current use of the Onchat platform.
• Technical information from your device to enable interaction with our system.
• Information about your visits, including page response times, pages visited, navigation methods, and other similar information.

Direct Collection of Information

Some personal data may be processed by us when you have requested a product or service from us, either as part of a purchase agreement from us or simply by requesting further contact from Onchat.

Risk and Personal Data

Please note that transmitting information over the internet is not completely secure, and we cannot guarantee the security of your data during transit. Any data sent is at your own risk. Please do not include sensitive personal data transmitted over the internet. Onchat may collect the following information:

• Your name
• Contact information, including postal address, email address, and telephone number
• Demographic information, such as location
• Other information relevant to your business or proposed business, price preferences
• Interest in customer satisfaction surveys and/or offers we have made

Data Compilation

For the online store to function and optimize, it's essential to retain and connect data to identify and understand how your business operates. Whether you are a sole proprietor or a partnership firm, this data will constitute your personal data. It will include business profile information, your name and similar information, demographic information, pricing points, business relationships, and the like.

Recommendations

We would greatly appreciate it if you could provide recommendations regarding the wonderful experiences you have had with us. We will review these recommendations before including them in our marketing materials, including on our website, and will only use your first name or a fictitious name, if you prefer.

Customer Experiences

We may retain and record data to highlight the appreciation shown by customers and their experiences. This is done for internal purposes, to allow us to verify that we continue to provide excellent service. If the recording is initiated by us, we will anonymize it, using only the first name.

If the recording is initiated as a result of a request or complaint from you, we will only retain essential information related to the issue at hand and, in this case, for a period of up to 3 months, unless you request otherwise. After 3 months, we may retain information that confirms the request or complaint for training purposes, but the information will be anonymized.

What We Do with the Information We Collect

We collect various types of information from you. Processing anonymous data either stored on your device and not accessed by us (e.g., cookies) or informs our statistical analysis of site and page usage (e.g., traffic cookies, Google Analytics).

Processing personal information involves several different actions, depending on the reason for which you provided us with the information:

Storage

The information we hold about you may be stored outside the European Economic Area for processing your data.

Initially, your personal information is securely stored by Onchat or our third-party provider. Typically, they will not view or use your personal information unless there is an issue related to the use or security of your data. They may be involved in sending newsletters to you, originating from Onchat.

We keep your data secure. Under normal circumstances, information regarding inquiries or contracts with us is retained for a maximum period of 6 years.

Anonymous Tracking

• To personalize Onchat according to your preferences and tastes.
• To improve how we display information about our products and services on our website, for your benefit and in line with your device.
• For the administration of our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical purposes, and surveys.
• To enable you to participate in the interactive features of our service when you choose to do so.
• As part of our efforts to keep our website safe and secure.
• To measure or understand the effectiveness of the ads we serve to you and others and to provide you with relevant advertising.
• To make suggestions and recommendations to both you and other users of our site regarding services that may interest you or them.

Initial Response

We need your personal information to provide you with the initial response you requested.

Further Processing

Once the information is received by us, it is centrally stored. Personal information allows us to:

• Operate the Onchat customer service and respond to your request.
• Maintain internal records to track your request at convenient times for you. This may mean that the local dealer i) will attempt to contact you multiple times to fulfill your contact requests and ii) will retain your data for up to 3 months to respond to any follow-ups discussed with you.

Providing Your Data to Third Parties

If we need to share your data for the purpose of providing the services you requested, we will implement contractual and practical systems to securely protect your personal information. Furthermore, we will notify third parties of any preferences you have indicated regarding the use of your personal data.

Subsequent Marketing

• Depending on your consent, we may periodically use your contact details to send you promotional emails or text messages about new products, special offers, or other information we consider interesting, using the contact details you provided.
• Depending on your consent to be contacted, we may use your contact details for market research purposes.
• Depending on your consent, we may provide your contact details to third parties for their use in related marketing messages.

Your contact details will be retained by us.

Request for Information Deletion

If you have consented to receive marketing messages in the future, we will keep this information for more than 3 months until you indicate that you no longer wish to receive messages from us. If you contact us to indicate that you no longer wish to receive messages from us, we may retain this indication centrally.

Contracts with You

Typically, we will not use information obtained through our website to finalize contracts with you. Such information will be kept in separate records. If this personal information is used to enter into contracts with you, it will be transferred and verified for accuracy in this process. If such data is used to assist in purchases made with you, this information may be retained as part of our accounting records, kept by us for compliance purposes. Only sufficient data for this purpose will be retained, this data will be kept securely, separately, and only for tax compliance purposes.

Business Purchase or Sale

Please note that if the business were to be sold or transferred, or if we were to acquire another business, your data would be transferred along with it, but only as part of the business being sold or transferred. Your personal information may be disclosed to a potential buyer or seller of such a business.

External Websites and Social Media
When you log in or log out of Onchat using external sites, please carefully check whether the external site is controlled by us (generally, our social media spaces on platforms such as Facebook, Twitter, or LinkedIn) or is used by third parties. We cannot control the information practices of other companies and organizations that may display ads, links, or offer our products or services. We cannot take responsibility and cannot control these internet spaces that are not controlled by us, and this policy does not apply to these spaces.

Links to Other Websites

Similarly, our site may contain links that allow you to easily visit other websites of interest. However, after using these links to leave our site, you should be aware that we have no control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information you provide while visiting such sites, and these sites are not governed by this privacy statement. You should exercise caution and review the applicable privacy statement of the website in question.

Please also note that third-party cookies may be downloaded to your device as a result of using this website. For example, if you share information from this website to your social media account, your account may require the use of such cookies to allow this transfer to take place. These cookies are not under our control, and we disclaim any responsibility for the actions of third-party cookies.

Posting Comments and Social Media

Please note that if you choose to post comments on this website or through our social media accounts that contain personal data, we cannot accept responsibility for the use or misuse of this data by other individuals who have access to these posts, and we suggest you carefully consider before posting such data. Please note that we may review tracking data generated by social media providers, such as Facebook, to measure the utility of our social media presence for you.

Collecting Data from Social Networks

We use technology to help us identify when you have interacted with us through social networks or to send you personalized marketing messages related to the products we offer during your experience on social networks. The use of this technology involves retaining your contact details and preferences. We do not categorize this information based on what the law describes as "sensitive personal data."

Integration with Facebook

Onchat integrates various connections with the social network Facebook, headquartered at 1601 South California Avenue, Palo Alto, CA 94304, USA. These are used to share activities on Facebook and to obtain information about Onchat users from Facebook. An overview of Facebook integrations and social plugins can be found here: http://developers.facebook.com/docs/plugins/.

When users activate the connection with Facebook in their settings, the integration with Facebook establishes a connection between the user's device and the Facebook server. Thus, Onchat receives information about the user.

When users invite friends through Facebook, the integration with Facebook establishes a connection between the user's device and the Facebook server. This allows the user to obtain information about their friends through Onchat, as the Onchat provider does not receive any information in this regard.

When users share their information on Facebook and when they invite friends through Facebook, the integration with Facebook establishes a connection between the user's device and the Facebook server. Thus, the user links the information from Onchat to their Facebook account. This allows Facebook to correlate the use of Onchat by a user with their corresponding Facebook account. Onchat, as the provider of Onchat, is not aware of how Facebook will subsequently use the data. Users can find more information on this issue in Facebook's privacy policy at: http://www.facebook.com/about/privacy/.

Users must actively enable the connection with Facebook in their settings in order to share information on Facebook and invite friends through Facebook. If users do not want Facebook to obtain information about their use of Onchat or if they do not want Onchat to obtain information about them through Facebook, they should leave the integration with Facebook disabled, as it is set by default. Once activated, users can deactivate the connection with Facebook again in their settings at any time.

By activating the connection with Facebook in their settings, the user explicitly consents to the exchange of information described in this section. Any data resulting from the use of Facebook will be located outside the European Economic Area (EEA) and will be subject to transfers between the EEA and other locations.

Your Rights Regarding Personal Data
In accordance with the provisions of EU Regulation 2016/679 on the protection of individuals with regard to the processing of personal data and on the free movement of such data, you have the following rights:

1. Right to be informed (Art. 12-13): - You have the right to be informed about the details of your information that we collect and process, including the categories of data collected, purpose, recipients, transfer.
2. Right to rectify data (Art. 16): - You have the right to request the rectification of any information that is inaccurate or erroneous.
3. Data portability (Art. 20): - You have the right to receive your personal data that you have provided to us, and where technically feasible, to request that we transmit your personal data (which you have provided to us) to another organization. You have the right to receive your personal data in a structured, commonly used, and machine-readable format. Your right to receive your personal data must not adversely affect the rights and freedoms of others. This may occur if a transfer of your personal data to another organization also involves the transfer of personal data of others (who have not consented to such transfer).
4. Right of access to data (Art.15): You have the right to request access to your data collected and processed by our association.
5. Right to restrict processing (Art.18): You have the right to request the restriction of processing certain data, to the extent that you:
   • challenge the accuracy of the data, for a period that allows us to verify the accuracy of the data;
   • processing is illegal, and you object to the deletion of personal data, requesting instead the restriction of their use;
   • the operator no longer needs the personal data for the purposes of processing, but you request it for the establishment, exercise, or defense of a right in court
   • or you have objected to processing (other than direct marketing), for the time during which it is verified whether the legitimate interests of the operator prevail over those of the data subject.
6. Right to be forgotten (Art.17): You can benefit without undue delay, ("the right to be forgotten"), if one of the following reasons applies:
   • they are no longer necessary for the purposes for which they were collected or processed;
   • if consent is withdrawn and there is no other legal basis for processing;
   • if the data subject objects to the processing and there are no legitimate reasons prevailing;
   • if personal data have been processed unlawfully;
   • if personal data must be deleted to comply with a legal obligation;
   • personal data have been collected in connection with the provision of information society services referred to in Art. 8 para. (1) of the GDPR
   • According to legal provisions, to fulfill this request, the conditions are as follows: we process your personal data, and if the personal data are no longer necessary for the purposes for which they were collected, except where the data are necessary: for exercising the right to freedom of expression and information; to comply with a legal obligation we have, for archival purposes in the public interest, scientific or historical research purposes, or for statistical purposes; or for the establishment, exercise, or defense of a legal claim.
7. Right to object: Where processing is not based on your consent but on our legitimate interests or those of a third party, you may object at any time to the processing of your personal data for reasons related to your particular situation. In this case, we will no longer process your personal data, unless (i) we can demonstrate compelling legitimate grounds for the processing that override your interests, rights, and freedoms, or (ii) or if the purpose is to establish, exercise, or defend a legal claim. If you object to processing, please specify whether you also want your personal data to be deleted; otherwise, we will only restrict it. You can always object to the processing of your personal data for direct marketing purposes based on our legitimate interest, whatever your reason. If marketing was based on your consent, you can withdraw your consent.
8. ight to object to profiling (Art. 21): you have the right not to be subject to a decision based solely on automated processing. To benefit from any of the above rights, you can send us your request to the email address: info@Onchat.ai. You also have the right to file a complaint with our company at the address Str. Piata Libertatii 10/A/30, 535100 Miercurea Ciuc, Harghita, Romania. and/or by letter sent to our company's headquarters identified in the preamble of the Privacy Policy, or to the National Authority for the Supervision of Personal Data Processing, if necessary and/or if you consider that any processing of your personal data violates in any way the legislation in force.
9. Right to lodge a complaint: If you are unhappy with the way your personal data is processed, or if you believe that the data protection legislation has been infringed in any way, you can address a complaint to our company at the address mentioned in this Privacy Policy, or you can file the complaint with the National Authority for the Supervision of Personal Data Processing, address B-dul G-ral. Gheorghe Magheru 28-30, Sector 1, postal code 010336, Bucharest, Romania phone number +40.318.059.211 +40.318.059.212, fax +40.318.059.602 e-mail: anspdcp@dataprotection.ro

We respect these rights as described above; however, we reserve the right to continue processing your data or to refuse your requests in accordance with relevant legislation.

Privacy Policy

By providing detailed information on the data we collect and process in this Privacy Policy.

Cookies

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can modify your browser settings to decline cookies if you prefer. Consent

You have control over the information you provide to us, either through:

• consent obtained as a result of browsing our website, or
• explicit consent by completing a contact form, either to request further information about our services, or
• explicit consent for further processing for the purpose of sending marketing materials regarding our services, or
• by contacting us regarding personal information, as described below

Consent for the specific purpose for which you provide your data will be inferred from the situation in which you provide this information. If you choose to withdraw your consent for the processing of your personal information at any time, you should inform us in writing using our contact details below.

Data Requests

You can request details about the personal information we hold about you in accordance with the relevant data protection legislation in force at the time (a "Subject Access Request"). If you would like a copy of the information we hold about you, please email us. We reserve the right to charge you a fee or refuse your request if it is clearly unfounded or excessive, especially if it is repetitive.

Data Correction, Complaints, and Deletion

If you believe that the information we process about you:

• is incorrect or incomplete (for example, because you have noticed that your name is misspelled or that someone else has received a call intended for you), or
• is being misused (for example, an unknown company has contacted you using the information you provided without your consent), or
• should no longer be processed by us (for example, because you no longer wish to be contacted)

please email us as soon as possible. We will promptly correct or delete any information found to be incorrect or no longer needed and address your concern or complaint.

These objection rights are subject to our right to assess whether we are authorized or obliged to continue processing, in which case we will inform you of our reasons. For example, where we are required to keep historical records for legal reasons.

Please address any concerns to us first at our contact email address info@Onchat.ai.

If you wish to escalate the issue, please contact us in writing, detailing your concerns, to allow us to provide you with an efficient response.

Automated Decision Making

We do not make automated decisions using your personal data.

Legal Disclosure by Us

Please note that, by this, you consent and, in any case, we may be obliged to disclose your data to legal authorities for the purpose of crime prevention or regulatory purposes or to a court, as required by law. In certain circumstances, we may not be authorized to inform you that we have made such a disclosure.

Contact Details
Onchat is the trading name of Soldigo SRL, registered at Str. Piata Libertatii, no. 10/A/30, Harghita County, Romania.

Our contact email address is info@Onchat.ai. Our address and contact for written correspondence is Str. Piata Libertatii, no. 10/A/30, Harghita County, Romania.

Any request for access to personal data should be addressed to the following email address: info@Onchat.ai.