Privacy Policy
This policy explains what personal data INCOGNICODE SRL collects through incognicode.com and through our work with clients, why we collect it, and what rights you have under the EU General Data Protection Regulation (Regulation (EU) 2016/679, "GDPR") and Romanian data protection law.
Who we are
The data controller is INCOGNICODE SRL, a Romanian limited liability company registered with the Trade Register under no. J40/15154/2015, tax code (CIF) RO35322165, with its registered office at Str. Sergent David Ilie nr. 2, Mansardă, Camera 1, Sector 4, București, Romania.
For any privacy question or request, email hi@incognicode.com. We have not appointed a Data Protection Officer because the law does not require one for our activity.
What data we collect
Website visits. We use Google Analytics 4 to count visits and see which pages people read. Google Analytics collects your IP address (which Google does not store or log for EU users), approximate location (country and city), device and browser type, pages visited, referring site, and time spent on the site. It sets cookies to tell new visitors from returning ones. See our Cookie Policy for details.
Emails you send us. When you write to hi@incognicode.com, we receive your name, email address, and anything you choose to include in the message.
Client and supplier contacts. When we work with a company, we process the names, job titles, business email addresses, and phone numbers of the people we deal with there, plus the data needed for contracts and invoices.
We do not knowingly collect special categories of data (health, religion, political views and so on), and the website is not intended for children.
Why we use it and on what legal basis
| Purpose | Legal basis (GDPR art. 6) |
|---|---|
| Measuring website traffic | Your consent, art. 6(1)(a) |
| Replying to your messages and preparing offers | Steps taken at your request before a contract, art. 6(1)(b), or our legitimate interest in answering business enquiries, art. 6(1)(f) |
| Delivering services under a contract | Performance of a contract, art. 6(1)(b), or our legitimate interest in managing the relationship with the client company you work for, art. 6(1)(f) |
| Invoicing, accounting, and tax records | Legal obligation, art. 6(1)(c) |
| Defending or enforcing legal claims | Legitimate interest, art. 6(1)(f) |
Who we share it with
We do not sell personal data. We share it only with:
- Google Ireland Limited and Google LLC, for website analytics;
- our hosting and email providers, who store data on our behalf;
- our accountant, for invoicing and tax compliance;
- public authorities, when the law requires it.
Each provider processes data only on our instructions and under a data processing agreement.
Transfers outside the EU
Google LLC may process analytics data in the United States. Google is certified under the EU-U.S. Data Privacy Framework, which the European Commission recognised as providing adequate protection on 10 July 2023. Where another provider transfers data outside the European Economic Area, we rely on the European Commission's Standard Contractual Clauses.
How long we keep it
- Analytics data: up to 14 months, then Google deletes it automatically.
- Emails that did not lead to a contract: up to 2 years after the last message.
- Contract correspondence and contact details: for the duration of the contract and 3 years after it ends, the general limitation period under the Romanian Civil Code.
- Invoices and accounting documents: for the period required by Romanian accounting law (Law no. 82/1991).
Your rights
You have the right to:
- access the data we hold about you and get a copy of it;
- have inaccurate data corrected;
- have your data deleted, where we no longer have a reason to keep it;
- restrict how we use your data;
- receive your data in a portable format;
- object to processing based on our legitimate interest;
- withdraw your consent at any time, without affecting processing that happened before.
To use any of these rights, email hi@incognicode.com. We will reply within one month. We may ask you to confirm your identity first.
You can also complain to the Romanian supervisory authority: Autoritatea Națională de Supraveghere a Prelucrării Datelor cu Caracter Personal (ANSPDCP), B-dul G-ral. Gheorghe Magheru nr. 28-30, Sector 1, București, www.dataprotection.ro.
Security
The website is served over HTTPS. Access to client and contact data is limited to the people at INCOGNICODE who need it for their work, and the accounts that hold it are protected with strong passwords and two-factor authentication.
Changes to this policy
We will post any changes on this page and update the date at the top. If a change affects how we use data you already gave us, we will tell you by email where we have your address.