Who is responsible for your data?
The data controller is Direct Softworks SRL (Romania). For any question, email [email protected].
What data we collect
When you contact us, you give us:
- Name, so we know who we are talking to.
- Email address, so we can reply.
- Phone number (if you share it), so we can call you back.
- Your message and selected services, so we can prepare a useful reply.
- If you start our contact form and leave without sending it, whatever you had already typed - see "Enquiries you start but don't send" below, which explains exactly what that means and how to have it deleted.
If you allow the optional cookie categories, we also collect data while you browse: anonymised page views (our own analytics), and - if you accept marketing cookies - your IP address, browser and device details, and the pages you visit, which the Apollo.io tracker uses to identify the company you are visiting from. Both are off unless you switch them on.
Enquiries you start but don't send
Our contact form asks for your email address on its first screen, then asks five more questions. If you give us the address and then leave without sending the form, we keep what you had typed - the address, and whichever of the later answers you had already given - so that we can follow up on the enquiry you started. This happens whether or not you accepted any cookies, because it is not a cookie: nothing is placed on your device, and the record is kept on our own server against the address you typed. Here is exactly what that does and does not mean:
- It is only kept once you have moved past the email screen with a valid address. We do not record what you type while you type it, so an address you began and then corrected never reaches us at all.
- We use it to reply to you about that enquiry. We do not add you to a newsletter, a mailing list or an outreach sequence - that would be marketing you never asked for, and we do not do it.
- We do not share it with anyone. It is not sent to Apollo.io or to any other third party, and it never leaves the EU.
- No IP address is stored with it. The country we see comes from Cloudflare, derived from your IP address without us reading or keeping it.
- It is deleted automatically after 180 days, and straight away if you ask us to.
Our legal basis is legitimate interest (GDPR Art. 6(1)(f)): you had begun sending us a business enquiry, and replying to it is the thing you were in the middle of asking for. Because it is a legitimate interest and not consent, you can object at any time under Art. 21(1) - email [email protected] and we will delete the record, and you do not have to give a reason. If you would rather we never had it in the first place, don't enter your email address until you're ready to send the form.
Why we collect this data
We use your data to reply, schedule a call, and prepare a proposal if we work together.
We never sell or rent your personal data. We do use one third-party marketing tool, Apollo.io, and only with your consent: it tells us which companies visit our site so we can decide who to reach out to. Everything else stays with us and our hosting and email providers.
Our legal basis for each use
Under the GDPR we rely on:
- Consent (Art. 6(1)(a)) for all optional cookies and tracking, including our analytics beacon and the Apollo.io visitor tracker. Nothing in these categories runs before you agree, and you can withdraw at any time.
- Steps taken at your request before a contract (Art. 6(1)(b)) when we handle your enquiry, quote, or project.
- Legitimate interest (Art. 6(1)(f)) in keeping the site secure and preventing abuse of our forms.
- Legitimate interest (Art. 6(1)(f)) in replying to an enquiry you began sending us through our contact form and did not finish. You can object to this at any time and we will delete the record - see "Enquiries you start but don't send" above.
- Legal obligation (Art. 6(1)(c)) where accounting or tax law requires us to keep records.
How long we keep your data
We keep emails and contact messages for up to 12 months so we can follow up and keep context. After that, messages may be archived or deleted during normal inbox clean up. Detailed analytics rows - individual visits, page views and clicks - are deleted after 400 days. What survives that is a daily table of counts only (how many visits, from which country, to which page), which contains nothing about any individual and is kept indefinitely so year-on-year comparisons remain possible. An unfinished contact-form enquiry - the email address and answers described under "Enquiries you start but don't send" - is deleted after 180 days, or immediately on request. The random key used to hash anonymous visitor identifiers is deleted after two days. Your cookie choice is stored for 365 days, after which we ask again. Data held inside Apollo.io is kept according to Apollo's own retention policy for as long as our account is active, and we delete records there on request.
Transfers outside the EU
If you accept marketing cookies, the Apollo.io tracker transfers the data described above to the United States, where Apollo.io, Inc. processes it. That transfer is governed by Apollo's Data Processing Addendum, which forms part of the Apollo terms of service we are bound by as a subscriber, and which incorporates the European Commission's Standard Contractual Clauses. Apollo also states that it complies with the EU-U.S. Data Privacy Framework. If you would rather no data about you left the EU, choose "Essential only" or switch marketing cookies off - every part of this site works exactly the same either way.
Your rights under GDPR
As an EU resident, you have the right to:
- Access, ask what personal data we hold about you.
- Correction, ask us to correct inaccurate data.
- Deletion, ask us to delete your personal data (when possible).
- Portability, ask for a copy of your data in a common format.
- Objection, object to certain types of processing (if it applies).
- Withdrawal of consent, at any time, for anything we do on the basis of consent - including the Apollo.io tracker. Withdrawing does not affect what was lawful before you withdrew.
- Complaint, lodge one with the Romanian supervisory authority (ANSPDCP, dataprotection.ro) if you think we have got this wrong.
To use these rights, email [email protected]. To withdraw cookie consent, use "Cookie settings" at the bottom of any page.
Contact for privacy questions
For any question about this privacy policy or your personal data, contact Direct Softworks SRL at [email protected].