Privacy Policy

1. General Information

FIXLY TECHNOLOGY SRL ("FIXLY", "we", "us", "our") respects the privacy of our customers and the protection of their personal data. This privacy policy explains how we collect, use and protect your personal information.

Data controller: FIXLY TECHNOLOGY SRL
Address: Calea Națională 37A, Botoșani, Botoșani, Romania
Phone: 0769777332
Email: support@fixlygsm.ro

2. Data We Collect

In accordance with the General Data Protection Regulation (GDPR) and applicable Romanian law, we collect and process the following categories of personal data:

2.1 Identification and Contact Data

• First and last name (required to provide our services)
• Email address (for communication and confirmations)
• Phone number (for contact and SMS notifications)
• Home address (for delivery and invoicing)
• Personal numeric code (CNP): optional, collected only if you choose to provide it for invoicing records (our invoicing system does not require it to issue the document)
• Date of birth (for age verification where necessary)

2.2 Device and Service Data

• Device model and serial number
• IMEI number (for legitimacy checks)
• Detailed description of the reported issue
• Complete history of repairs carried out
• Photos of the device (before and after repair)
• Diagnostic logs and tests performed
• Device warranty information

2.3 Financial and Payment Data

• Payment card information (processed securely by authorised payment processors)
• Complete transaction and payment history
• Invoices, receipts and accounting documents
• Information about your preferred payment methods
• Details of vouchers and discounts used

2.4 Behavioural and Preference Data

• Browsing history on the Site (via cookies)
• Service and communication preferences
• Feedback and ratings you provide
• Interactions with technical support
• Data about your use of mobile apps

2.5 Technical and Security Data

• IP address and browser information
• Data about the device used to access the Site
• Security and access logs
• Location information (where necessary)
• Site performance data and errors encountered

3. Purposes of Processing

We process your personal data for the following purposes:

• Providing repair services
• Processing orders and payments
• Communicating with you
• Complying with legal obligations
• Improving our services
• Marketing and commercial communications (with your consent)

4. Legal Basis

We process your personal data on the basis of:

• Performance of a contract: To provide our services
• Legal obligations: For tax and accounting reporting
• Legitimate interests: To improve our services
• Consent: For marketing and commercial communications

5. Sub-processors and Data Sharing

We do not sell your personal data. We share it with the following sub-processors, with whom we have concluded data processing agreements:

5a. International Data Transfers

Google LLC and Vercel Inc. are companies established in the United States of America. Your data processed through their services may be transferred to the USA. These transfers take place on the basis of the Standard Contractual Clauses (SCCs) adopted by the European Commission in Decision (EU) 2021/914, which ensure an adequate level of protection in line with the requirements of Chapter V of the GDPR (Art. 44-49).

Our other sub-processors are established in Romania or in European Union member states, so no additional safeguards are required for transfers.

6. Data Security

We implement technical and organisational security measures to protect your personal data:

• Encryption of data in transit and at rest
• Restricted access to data
• Access monitoring and auditing
• Staff training on data protection
• Regular, secure backups

7. Data Retention

We retain your personal data for:

• Customer data: 5 years from the last interaction
• Payment data: 10 years (as required by tax law)
• Marketing data: Until consent is withdrawn
• Repair data: 3 years for warranty purposes

8. Your Rights

Under the GDPR, as a data subject you have the following rights:

• Right to be informed: To know how we process your data
• Right of access: To obtain a copy of your data
• Right to rectification: To have inaccurate data corrected
• Right to erasure: To have your data deleted under certain conditions
• Right to restriction: To restrict processing
• Right to data portability: To receive your data in a structured format
• Right to object: To object to processing
• Right to withdraw consent: For marketing

You can exercise your right of access (a copy of your data) and your right to erasure directly from your account, under Settings → Privacy & Data (Setări → Confidențialitate & Date), or you can contact us as described in section 11 below. We respond within 30 days at most.

9. Cookies

We use cookies to operate the Site and to analyse how it is used. Non-essential cookies (analytics, advertising) are enabled only with your explicit consent, in accordance with Law no. 506/2004 (Romanian law on privacy in electronic communications) and the GDPR.

With your consent to analytics, Google Analytics 4 and Vercel Analytics record page views, clicks, scroll depth and active time on page, form starts and submissions, repair request steps and orders from the parts shop. For parts orders we send the products, order value, currency, chosen payment method and order number. We do not send the values you enter in form fields, your contact details or delivery addresses to analytics services. The purchase event is recorded once the order has been created successfully; with cash on delivery or bank transfer, payment may be collected later.

On your first visit you will see a banner where you can accept, reject or customise each category of cookies. You can change your preferences at any time. Full details of every cookie we use are available in our Cookie Policy.

9a. Personal Data Breach Notification

In the event of a security incident affecting your personal data, we undertake to:

• Notify the ANSPDCP within 72 hours of becoming aware of the breach, in accordance with Art. 33 GDPR
• Inform you directly and without undue delay if the breach is likely to result in a high risk to your rights and freedoms, in accordance with Art. 34 GDPR
• The notification will include: the nature of the breach, the data affected, the likely consequences and the measures taken

9b. Right to Object (Art. 21 GDPR)

You have the right to object at any time to the processing of your personal data carried out on the basis of our legitimate interest (Art. 6(1)(f) GDPR), including profiling. You can contact us at support@fixlygsm.ro. We will stop the processing unless we demonstrate compelling legitimate grounds that override your rights.

10. Changes

We reserve the right to amend this privacy policy. Changes will be published on the Site, and we will notify you by email of any significant changes.

11. Contact and Complaints

For questions about this policy or to exercise your rights, you can contact us at:

• Email: support@fixlygsm.ro
• Phone: 0769777332
• Address: Calea Națională 37A, Botoșani, Botoșani

You have the right to lodge a complaint with the Romanian supervisory authority, the Autoritatea Națională de Supraveghere a Prelucrării Datelor cu Caracter Personal (ANSPDCP).