Controller

Data Modulator Inc. S.R.L.

Bucharest, Romania

1) What Data We Process

• Data you provide to us (e.g., contact details, newsletter sign-up, application data).
• Technical data from your device that is necessary to provide the site (e.g., connection logs).
• No additional personal data is collected unless you choose to provide it.

2) Purposes

• Contract performance and responding to inquiries.
• Newsletter delivery (with consent or permissible direct marketing for similar products/services; opt-out anytime).
• Running video conferences or webinars you join.
• Handling applications for open roles.

3) Legal Bases

• Performance of a contract or pre-contractual steps (Art. 6(1)(b) GDPR).
• Consent (Art. 6(1)(a) GDPR) for optional features like the newsletter; you can withdraw consent anytime.
• Legitimate interests (Art. 6(1)(f) GDPR) for security, service improvement, and similar direct marketing, unless you object.
• Legal obligations (Art. 6(1)(c) GDPR) for retention and disclosures.

4) Recipients

• Public authorities where legally required.
• External processors/service providers (e.g., hosting, newsletter delivery, conferencing).
• Other third parties with your consent or where allowed by overriding interests.

5) International Transfers

Processors outside the EU/EEA may be used. Safeguards such as Standard Contractual Clauses apply to protect your data.

6) Retention

• Customer and contract data: generally 10 years per statutory retention.
• Applicant data: usually deleted within 4 months after a decision unless you consent to longer storage.
• Technical logs: deleted when no longer needed for their purpose.
• Newsletter data: stored until you unsubscribe or withdraw consent.

7) Newsletter Details

We store your email (and optional data you provide) to send the newsletter. You can unsubscribe at any time via the link in each email or by contacting us. If we received your email through a sale of goods or services, we may send similar offers; you can opt out at any time at no cost beyond basic rates.

8) Cookies

We use our own cookies to improve usability; no personal data is stored in them. You can block cookies via your browser settings.

9) Website Visitor Identification

We use Dealfront (Leadfeeder), a GDPR-compliant website analytics service provided by Dealfront GmbH, to identify which companies visit our website. This service uses IP address resolution to determine the company associated with a website visit. It does not identify individual persons.

The data processed includes: IP address (resolved to company name), pages viewed, visit duration, and approximate geographic location. This data is processed under GDPR Article 6(1)(f) — legitimate interest in understanding which businesses are interested in our services.

No personal data (names, email addresses, or individual browsing profiles) is collected through this service. For more information, see Dealfront's privacy policy at dealfront.com/privacy.

10) Video Conferences / Webinars

Data processed: name, email, optional audio/video, chat questions, and technical data needed to connect. Purpose: delivering video conferences/webinars. Recipients: processors/hosts (including outside the EU, e.g., USA) under Standard Contractual Clauses. Recordings only with prior documented consent. Technical data is deleted when no longer required.

11) Your Rights

You have rights to access, rectification, erasure, restriction, data portability, and objection to processing, as well as the right to withdraw consent. You may complain to a data protection supervisory authority.

12) Contact

For privacy requests, reach out to DM Growth.

13) Updates

We may update this notice; material changes will be highlighted on this page. Please review it periodically for the latest version.