Privacy Policy

1. Data Controller

ThinkFLOW Systems (thinkflowhub@gmail.com, Bucharest, Romania) is the data controller for personal data collected through thinkflow.ro and related subdomains.

You can contact our data protection representative at: thinkflowhub@gmail.com.

2. What We Collect

We collect: name and email address (via contact forms and newsletter signup), IP address and browser user agent (via server logs), cookie identifiers for affiliate tracking, and usage data (pages visited, time on site).

We do not collect sensitive personal data (health, religion, political affiliation).

3. Legal Basis (GDPR Art. 6)

We process your data based on: your consent (contact form submissions, newsletter signup, cookie consent — Art. 6(1)(a)), contract performance (service delivery — Art. 6(1)(b)), and legitimate interests (analytics, affiliate tracking, site security — Art. 6(1)(f)).

4. How We Use Your Data

To respond to inquiries and deliver services, to send newsletters (only with explicit consent), to improve our website and content, to track affiliate referrals and commissions, and to comply with legal obligations.

5. Cookies

We use only essential cookies for site functionality. Affiliate referral links use URL parameters (not cookies) for tracking. We do not use tracking cookies or third-party analytics cookies without your explicit consent. You can disable cookies in your browser settings.

When we implement analytics, you will be asked for consent via a cookie banner before any non-essential cookies are placed.

6. Data Sharing and International Transfers

We share data with: Vercel Inc. (US — hosting and server logs, covered by EU-US Data Privacy Framework), and email service providers for transactional emails. We do not sell personal data to third parties.

For transfers to the US, we rely on the EU-US Data Privacy Framework or Standard Contractual Clauses as applicable. A copy of the relevant safeguards is available on request.

7. Data Retention

We retain personal data for 24 months after the last contact. Newsletter subscription data is retained until you unsubscribe. Affiliate tracking data is retained for the duration of the affiliate program relationship. You may request earlier deletion at any time.

8. Your Rights (GDPR)

Under GDPR, you have the following rights:

• Right of access (Art. 15) — request a copy of your data
• Right to rectification (Art. 16) — correct inaccurate data
• Right to erasure (Art. 17) — right to be forgotten
• Right to restrict processing (Art. 18)
• Right to data portability (Art. 20)
• Right to object (Art. 21) — including objection to direct marketing
• Right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal

To exercise these rights, contact us at thinkflowhub@gmail.com. We will respond within 30 days.

9. Right to Lodge a Complaint

If you believe your data protection rights have been violated, you have the right to lodge a complaint with the Romanian National Supervisory Authority for Personal Data Processing (ANSPDCP — Autoritatea Nationala de Supraveghere a Prelucrarii Datelor cu Caracter Personal):

Website: www.dataprotection.ro
Address: B-dul G-ral. Gheorghe Magheru, nr. 28-30, Sector 1, Bucuresti
Email: anspdcp@dataprotection.ro

10. CCPA Rights

California residents have the right to: know what personal data is collected, request deletion, and opt out of the sale of personal data. We do not sell personal data.

11. Security

We implement AES-256 encryption for stored data, TLS/HTTPS for all data in transit, and restricted access to personal data on a need-to-know basis. We conduct periodic security reviews.

12. Changes to This Policy

We will notify you of material changes to this policy via email (if we have your contact information) or a prominent notice on our website at least 30 days before changes take effect.

13. Contact

For privacy-related inquiries: thinkflowhub@gmail.com, Bucharest, Romania.