Privacy Policy

1. Introduction

Thank you for your interest in our company, our products, and/or our services. When you enter into any kind of relationship with us, you entrust us with your information. This information presented in this document (hereinafter referred to as the 'Privacy Policy') is important. We recommend that you read it carefully. The purpose of this Privacy Policy is to explain what data we process (collect, use, share), why we process it, how we process it, your rights under the GDPR, and how you can exercise these rights. When collecting this information, we act as a controller and, by law, are required to provide you with this information. The protection and confidentiality of personal data is very important to us. Being fully aware that personal information belongs to you, we do everything possible to store it safely and process it carefully. We do not provide information to third parties without informing you in accordance with legal provisions. By visiting our website, purchasing our products and/or services, or interacting with us through any means and/or through any communication channel (email, phone, social networks, etc.), you agree to this Privacy Policy and consent to the use of your data for advertising or marketing purposes, as described below in the sections dedicated to Marketing and Advertising. If you do not agree with what is described in this Privacy Policy, please do not use our services or products.

2. Other Services

This Privacy Policy does not cover third-party applications and websites that you may access through links on our site. This is beyond our control. We encourage you to review the Privacy Policy on any site and/or application before providing personal data.

3. Who are we?

DIGITAL NOMADS HUB S.R.L. (hereinafter referred to as Digital Nomads) is responsible for processing your personal data that we collect directly from you or from other sources. According to the law, our company is a personal data controller. To ensure your data is processed safely, we have made every effort to implement reasonable and appropriate technical and organizational measures to protect your personal information.

4. Who are you?

According to the law, you, the natural person benefiting from our products and/or services, the representative or contact person of a company, the website visitor, or the person in any kind of relationship with our company, are a 'data subject', meaning an identified or identifiable natural person. To be fully transparent about data processing and to enable you to easily exercise your rights at any time, we have implemented measures to facilitate information; please see Sections 7, 10, and 11 of this document.

5. Our Commitment

The protection of your personal information is very important to us. That is why we are committed to complying with European and national legislation regarding the protection of personal data, especially Regulation (EU) 679/2016, also known as the GDPR, and the following principles:

• Lawfulness, fairness, and transparency We process your data lawfully and fairly. We are always transparent about the information we use, and you are properly informed.
• Control is yours Within the limits of the law, we offer you the ability to review, modify, delete the personal data you have shared with us, and exercise your other rights. For more information, see Sections 7, 10, and 11 of this document.
• Data integrity and purpose limitation We use data only for the purposes described at the time of collection or for new purposes compatible with the initial ones. In all cases, our purposes are compatible with the law. We take reasonable steps to ensure that personal data is accurate, complete, and up-to-date.
• Security We have implemented reasonable security and encryption measures to best protect your personal information. However, please note that no website, application, or internet connection is completely secure.

6. Changes

We may change this Privacy Policy at any time. All updates and changes to this Policy are effective immediately after notification, which we will make by posting on the site and/or email notification.

7. Questions and requests

If you have any questions or concerns regarding the processing of your data or if you want to exercise your legal rights regarding the data we hold or if you have concerns about how we handle any privacy matter, you can write to us at the email address: client@digital-nomads.dev

8. Your Information

8.1. What kind of information do we collect about you?

When you browse our website, send us a request via email, or contact us for any other purpose and through any other communication channel, you may provide us with the following personal data, which we collect directly from you or from other sources, such as:

• Your first and last name
• Your email address
• Your phone number

Most of the information we collect comes directly from you (for example, by filling out a form on the website). Most of the information is as described above, but there may be situations where we collect data from third parties (i.e., partners, advertising platforms), such as information about purchases and interests.

In addition to the information mentioned above, we may collect the following information, depending on the circumstances:

• How you interact with our website/websites or advertisements (e.g., information about how and when you access our site or which device you use to access the site);
• Information provided when filling out forms or questionnaires;
• The content of messages sent via messaging systems and email;
• Interactions between you and us on social media (e.g., likes, shares, comments);
• Information we collect about you from other companies in the group or third parties that have obtained your consent or have other legal rights to share this information with us (including partners/platforms for publishing or advertising and data aggregators who have obtained the respective rights).

We may collect data through cookies or similar technologies, such as:

• Your IP address
• Your internet browser
• Your location
• The web pages you access on our site

8.2. Why do we collect this information?

We collect personal information for the following purposes:

• To respond to your inquiries and requests and provide customer support services;
• For marketing purposes, but only if we have your prior consent or when there is a legal exception to obtaining consent;
• To offer and improve the services and products we provide;
• To diagnose or fix technical problems;
• To defend against cyberattacks;
• To comply with the law, such as complying with tax legislation that requires us to keep accounting records for 10 years;
• To establish or defend a right in court;
• For analytical and research purposes;
• To conduct promotions and contests;
• To prevent crimes, fraud, or deception;

8.3. What is the legal basis for processing?

We may use the following legal grounds, depending on the specific case:

• Consent for the processing of personal data; However, note that if you are our customer, we may send promotional messages (direct marketing) about similar goods and services without needing consent, under Article 12(3) of Law No. 506/2014. In all cases, you can object to direct marketing and/or withdraw your consent at any time by following the unsubscribe instructions in each email or by sending a written request to the email address client@digital-nomads.dev
• Processing is necessary for the conclusion or execution of a contract between you and us;
• Processing is necessary for our legitimate interests or those of another party, unless your interests, rights, or freedoms prevail. If we use legitimate interest, we conduct a legitimate interest analysis (balancing test) through which we weigh our interest against your interests. If our interests prevail, we will use legitimate interest. If your interests prevail, we will not use legitimate interest, and if we fail to identify another proper legal basis, we will not carry out the processing activity in question.
• Processing is necessary for the fulfillment of legal obligations (such as complying with tax laws requiring us to keep accounting records for 10 years or providing certain information to authorized public bodies);
• In some situations, processing may be necessary to protect your vital interests or those of another natural person; Note that obtaining consent is not mandatory, and we will only obtain your consent in situations where we fail to use another legal basis.

8.4. How long do we store the data?

We store your personal data only for the period necessary to fulfill the purposes, but no more than 5 years from the termination of the contract or the last interaction with us.
After the expiration of the period, personal data will be destroyed or deleted from IT systems or transformed into anonymous data for use in scientific, historical, or statistical research.
Note that in certain expressly regulated situations, we store data for the period required by law.

8.5. How do we share your information with others?

We may disclose your data, in compliance with applicable law, to business partners or other third parties. We make every reasonable effort to ensure that these third parties have implemented appropriate protection and security measures. We have contractual clauses with these third parties to ensure that your data is protected. In these situations, we ensure that any transfer is legitimate, based on your consent or another legal basis.

For example, we may provide your data to other companies, such as IT or telecommunications service providers, accounting, legal services, and other third parties with whom we have a contractual relationship. These third parties are carefully selected to ensure that your data is processed only for the purposes we indicate.

We may also share your data with business partners as part of a joint effort to provide a product or service.

Although unlikely, we may sell the business or part of the business in the future, which will include the transfer of your data.

We may transmit your data to other parties with your consent or as per your instructions, such as when you exercise a portability request.

We may also provide your personal information to the prosecutor's office, police, courts, and other authorized state bodies, based on and within the limits of legal provisions and as a result of expressly formulated requests.

We will ensure, within reasonable limits, that your data does not leave the European Economic Area. However, if we transfer data to countries outside the EEA, we will ensure, in all cases, that the transfers are legitimate, based on your explicit consent or another legal basis.

9. Marketing

To the extent we have obtained your prior consent or you are already a customer of the company, we may use direct marketing technologies and targeted advertising, using the information collected about you regarding interests, preferences, purchases, age, location, etc. For example, we may send emails, display ads within our website or on social media, or place ads on third-party sites, in applications, or on other internet-connected devices.

9.1. What kind of data do we collect for marketing?

To carry out direct marketing or targeted advertising, we may use the following information:

• Information collected through cookies and other similar technologies (location, device, browser, age, etc.);
• Your purchases, how you have interacted with our goods and services, and the feedback we have received from you;
• Age, country, region, gender;
• Other information obtained from our third-party marketing partners, information they have obtained with your consent.

9.2. Marketing Partners

Our marketing partners, such as Facebook, Google, and/or other agencies, help us deliver marketing to you based on information collected directly from you and with your consent. In some cases, we share information we have collected from you. We ensure, in all cases, that these transfers are legal as explained in section 8.5.

Our partners may place ads regarding our services and products, based on the data previously collected from you (interests, preferences) on other websites and/or services. Additionally, our marketing partners may use the information collected about you to improve their services and/or algorithms (including AI-based algorithms).

This privacy policy does not include information about how our partners process your data, but we encourage you to read our marketing partners' privacy policy for more information. You can consult this list of our marketing partners, along with links to the Privacy Policy.

9.3. How can you opt out of direct marketing?

You can object to direct marketing and/or withdraw your consent at any time by following the unsubscribe instructions in each email ('unsubscribe') or by sending a request to the email address client@digital-nomads.dev To disable interest-based advertising, please refer to our Cookie Policy.

10. What are your rights?

Your rights under the GDPR Regulation are as follows:

• Right to withdraw consent
  You can withdraw your consent to the processing of your data at any time by sending a request to the email address client@digital-nomads.dev. However, please note that if we have identified another legal basis for processing your data, we will continue to process your data based on that legal basis. We have the legal ability to use one or more legal grounds for processing your data.
• Right to be informed about the processing of your data
• Right of access to data
  You have the right to obtain confirmation from us whether personal data concerning you is being processed and, if so, access to that data and the information provided in Article 15(1) of the GDPR.
• Right to rectify inaccurate or incomplete data
  You have the right to obtain from us, without undue delay, the rectification of inaccurate personal data concerning you.
• Right to erasure ('right to be forgotten')
  In the situations provided for in Article 17 of the GDPR, you have the right to request and obtain the deletion of personal data.
• Right to restrict processing
  In the cases provided for in Article 18 of the GDPR, you have the right to request and obtain the restriction of processing.
• Right to transmit the data we hold about you to another controller ('right to data portability')
  In the cases provided for in Article 20 of the GDPR, you have the right to request and obtain data portability.
• Right to object to data processing
  In the cases provided for in Article 21 of the GDPR, you have the right to object to the processing of your data.
• Right not to be subject to a decision based solely on automated processing, including profiling, with legal or similarly significant effects on you.
• Right to address the courts to defend your rights and interests.
• Right to lodge a complaint with a Supervisory Authority.

Please note that:

• You can withdraw your consent for direct marketing at any time by following the unsubscribe instructions in each email/sms or other electronic message.
• If you want to exercise your rights, you can do so by sending a written, signed, and dated request to the email address: client@digital-nomads.dev
• The rights listed above are not absolute. There are exceptions, so each request received will be analyzed to determine whether it is well-founded or not. If the request is well-founded, we will facilitate the exercise of your rights. If the request is unfounded, we will reject it, but we will inform you of the reasons for the refusal and your rights to lodge a complaint with the Supervisory Authority and to address the courts.
• We will attempt to respond to your request within one month. However, the term may be extended depending on various aspects, such as the complexity of the request, the large number of requests received, or the inability to identify you in a timely manner.
• If, despite our efforts, we cannot identify you, and you do not provide us with additional information to enable us to identify you, we are not obliged to process the request.

11. Questions, requests, and exercising rights

If you have any questions or concerns regarding the processing of your information or if you want to exercise your legal rights or have any other privacy concerns, you can write to us at the email address client@digital-nomads.dev.