Privacy Policy and Data Protection Notice
version: 15.02.2022
The security of your personal data is very important to Diginet Pro. You can visit our website without providing personal information. Your data is required when using certain services. This document contains information about what data and for what purpose is collected, processed and where it is stored.
1. General Provisions
1.1. We, Diginet Pro SRL, Fiscal Code 1019600052341 (“Company”), E-mail address: [info@diginet.md] (“E-Mail address”), process your personal data in the context of your use of our products (“Products”) or platforms (the “Platform” and together with the Products, the “Services”). We process your personal data confidentially and responsibly.
The processing of your personal data is carried out in accordance with the Law of the RM No. 133 of 08.07.2011 “On the Protection of Personal Data” with amendments and additions.
1.1.1. Also, we also make reasonable efforts to comply with the requirements of the General Data Protection Regulation, GDPR.
1.2. Purpose of the Privacy Policy: The purpose of this Privacy Policy is to inform users of the Diginet Pro Internet Services, based on the website(s) diginet.md, facturare.md, chatbot.md (hereinafter referred to as the “website” or “Services”), Personal Service Account – my.diginet.md (hereinafter “Personal Account”), as well as customers, users, suppliers and other business partners about how Diginet Pro processes personal data.
These websites are owned by Diginet Pro SRL, listed in the Basic Information on this website.
1.2.1. In this Privacy Policy, we have provided you with information about the company, nature, scope, and purposes of collecting, processing and using your personal data.
1.2.2. For some of our products, we will only process data for the purposes and means specified by you. In these cases, we will provide you with separate data processing agreements.
With this in mind, not all aspects of this information may apply to you.
1.3. Definitions:
- “Customer” means a Customer of the Diginet Services(s) who uses the Service for commercial purposes.
- “Customer Personal Data” means personal data, reports, addresses and other files, folders or documents in electronic form that the Customer stores within the Services.
- “Customer’s Employee” means an employee, agent or representative of the Customer who uses the Website’s Personal Account to access the Services.
- “User” means the end User of the Service Client, including, but not limited to, authorized Users of the Service Client.
- “User Personal Data” means any data that relates to or may be associated with a User, such as name, telephone number, postal address or e-mail address.
- “Open Area” or “External Interface” means an area of the Site that can be accessed by both Clients and Users, and Site Visitors, without the need to enter a personal account.
- “Restricted Area” or “Personal Account” means a restricted area of the Site or Personal Account, which can only be accessed by Service Clients and Registered Users. Login and password are required to access the Personal Account.
- “Visitor” means a person other than the Client or User who uses the Public Area of the Site but does not have access to the restricted area of the Site or Service.
1.4. Personal Data Processor: The Company (Diginet Pro) is a “Personal Data Processor” (Processor) in accordance with Article 3, Chapter 1, of the Law of the Republic of Moldova No. 133 of 08.07.2011 “On the Protection of Personal Data”, as amended and supplemented.
We act on behalf of, for the purposes and in the legitimate interests of the Controller (Client) for the processing of personal data and at his direction;
1.4.1. According to paragraph. 8 Art. 4, GDPR we are also a Processor who processes personal data on behalf of and on behalf of the Controller.
1.5. How to contact us: For personal data protection issues, you can contact us by e-mail: dataprotection@diginet.md or by our postal address with the subject line “Personal data protection”.
1.6. Company address:
Diginet Pro SRL
str. Nicolae Titulescu 1,
Chisinau, MD-2002, Republic of Moldova
1.7. Diginet Pro Internet Services do not transfer personal data to third parties, including for marketing purposes or to generate income from the use of personal data.
1.8. These Terms and Conditions have been translated from Romanian into English and Russian. In case of discrepancies between the Romanian version and the translation (Russian or English), the Romanian version shall prevail.
2. Data We Process
2.1. Purpose of personal data processing
Diginet Pro processes personal data solely for the purpose of providing its Services.
- 2.1.1. The facturare.md service processes personal data solely for the purpose of providing its Services – preparing invoices for payment, sending them to payers and further processing payments.
The processing of personal data is initiated either at the request of the Client (Seller of the Goods or Service Provider) or the Payer (Buyer) in order to make a payment by selecting a product or service, a payment method and a payment service provider, indicating the invoice identifier for payment and the Payer. - 2.1.2. Web telephony services – We offer the following Web telephony services:
- Callback Online
Widget of Callback service from the seller’s website in online mode. - Call from browser of website – WebCall
Button and widget to the site to call the manager directly from the browser. - Call with One-Time Password
Delivery of a One-Time Password as a voice message over the phone call - Voice Bot
Using the Diginet Pro voice bot to automate calls.
- Callback Online
The call is initiated either by a visitor to the online seller’s website (using a special call widget), or when the online seller’s manager accesses the customer’s card in CRM or another management system.
2.2. General information:
We process such personal data that you, as a user of the SERVICE, provide to us when visiting the open area of the site, when registering in the Personal Account and when using the SERVICE (“Data”).
2.3. Visitors to the public part of the site
If you visit the public part of the website, we only process the personal data that your browser transmits to our server.
We collect the following data, which is necessary for us to properly display the site and ensure the necessary stability and security:
- hostname and IP address of the device;
- date and time of the server request, time zone;
- client request (including file requests), http response code;
- the requested site and the amount of data transferred;
- Referrer URL – referring (previously visited) page;
- browser, operating system, interface, language, and browser software version.
2.4.Personal account – Registration data of the Client (User) of the Service:
All Personal Data for the Personal Account of the User and the Client of the SERVICE is collected directly from you, as from the subject of personal data.
We collect and process the following information:
2.4.1. When registering a Client (User) in the Service
- IP address;
- registration data: registration date, login (email) and password signature (hash) (i.e. not the password itself);
- personal information: full name; E-mail address; address, postal code, city, region, country;
- company information: company name, website, fiscal code, VAT code;
- information about company managers: Last name, first name, E-mail, phone number;
2.4.2. Each time the Client (User) enters the Personal Account of the Service
- IP address;
- date and time of entry into the personal account.
2.4.3. Information that is available to us when you pay for the Diginet Pro Services:
- your IP address;
- your email;
- your mobile phone number;
- date of payment, account number for payment (account identifier), currency, amount.
2.5. factutare.md Service – the Data on invoices for payment issued by your Buyers (Payers) (see clause 2.1.1)
(invoices for payment issued by the Client (User of the Service) for payment by their Buyers (Payers))
The data processed when using the Service is processed by us as a Processor, at the initiative and instruction of the Controller, see Art. 3, Chapter 1, of the Law of the Republic of Moldova No. 133 of 08.07.2011 “On the Protection of Personal Data” with amendments and additions.
2.5.1. Personal information about your Buyer / Payer:
- surname and name;
- E-mail address;
- address, postal code, city, region, country;
- payer’s mobile phone number (optional)
2.5.2. Invoice Information for Your Buyers (Billing Information)
- Account number for payment
- Date of transfer of goods or materials, provision of works or provision of services
(optional, may or may not be included at the request of the Seller) - Date of invoice sending
- Contact and name of organization/seller
- Name and Surname of the buyer/payer
(optional, may or may not be included at the request of the Seller) - e-mail of the Buyer (Payer)
- Buyer’s (Payer’s) mobile phone number (optional, at will)
- link to the document “Terms and Conditions of Sale of Goods or Provision of Services”
(according to the requirements of the Seller)
(required when paying online with a bank card via the website) - A string detailing each product or service
(as entered by the Seller of the product or the Service Provider) - The cost per unit of goods, materials, works, or services
- Tax rates
- Total amount payable (or outstanding) in currency
- Personal note
- In case of the successful payment by credit card on the website of the Seller (Merchant),
the first six (6) digits and the last four (4) digits of the Payer’s bank card number are also available.
(in the settings of the Merchant account, it is possible to choose whether or not to store this information)
2.6. Web telephony services (see clause 2.1.2):
2.6.1. Usage Information
May include Call Detail Record (“CDR”) and other call records of Customers and End Users.
CDRs may include Personal Data, including (i) the identity of the End User who initiates the voice or video call and (ii) the identity of the person who receives such voice or video call. Unless required by applicable law, we do not share information about calls, call duration, numbers dialed, or call content with any third party.
2.6.2. SIP and Account Information
The SIP account information consists of the SIP credentials that you enter to forward calls using the Diginet Pro Web Telephony Services.
The Skype account information consists of the Skype ID that you enter to route calls using Diginet Pro services.
Unless required by applicable law, this information is not provided to third parties.
3. Why we process your data
3.1. Target:
Data Processing has the following purposes (“Purposes”):
- provide and improve the SERVICE;
- managing relations with Clients (Users) of the SERVICE, including newsletters;
- security and stability of the SERVICE.
3.2. Legality of processing:
The legality of processing (according to Art. 5, Law of the Republic of Moldova No. 133 of 08.07.2011 “On the protection of personal data”) arises from:
- 3.2.1. your consent when we have requested your explicit consent (clause 1 of Article 5 of the Law of the Republic of Moldova No. 133 of 08.07.2011 “On the Protection of Personal Data”); and
- 3.2.2. the need to fulfill the contract, as your data is necessary for the satisfactory provision of the SERVICE; and
- 3.2.3. the processing is necessary for the purposes of the legitimate interests pursued by the Controller (en. Controller) or by a third party, pursuant to paragraph f), Art. 6 Lawfulness of processing, GDPR
3.3. Legitimate interests:
in accordance with 3.2.3 consist of monitoring, analyzing and improving the SERVICE, providing you with any assistance to protect the security, integrity, performance and functionality of the SERVICE.
4. How we use and share your personal information
4.1. Use of Data: We use the Data that you, as a user of the product, have provided to us only for the Purposes specified in clause 3.1.
4.2. Transfer of Data: We transfer Data to third parties only if it is (i) necessary for the Purposes, for example, when we use service providers, (ii) at the request of a national authority, (iii) by court order, or (iv) if you have given consent in advance .
4.3. Service providers:
For some parts of our Services, we use third party Service providers or to process data such as:
- 4.3.1. Accepting payments:
- Moldovan banks Internet acquirers for accepting online payments by bank cards through the website;
- banks of Moldova acquirers for accepting online payments by bank cards through POS terminals;
- State Payment System – Mpay.gov.md – accepting cash in payment terminals of Payment systems, in authorized banks of Moldova or the Post of Moldova;
- Payment systems, holders of the license of the National Bank of Moldova – accepting cash in payment terminals and electronic money;
- The factura.md service is the acceptance of cash in authorized banks of Moldova or the Post of Moldova;
- Accounting for the receipt of cash (for the purpose of accounting for invoices paid at the Seller’s office);
- Accounting for the acceptance of non-cash payments (for the purpose of accounting for invoices paid by bank transfer to the Seller’s settlement account).
- 4.3.2. Sending SMS alerts (SMS notifications of a non-advertising nature):
5. Storage And Data Safety
5.1. Data retention period: We store your Data for as long as you are a registered User of the SERVICE.
In addition, we only retain Data if required to do so by law (due to warranties, terms or periods of retention) or otherwise.
5.2. Deletion of data: Data will be deleted if you (a) withdraw your consent to storage, (b) the Data is no longer necessary to fulfill a user contract for the Product, or (c) the storage is or becomes legally unacceptable. The deletion request does not affect the data if the storage is legally necessary, for example for accounting purposes.
5.3. Security measures: In order to avoid unauthorized access to data and in general to protect data, we apply the following security measures: encrypted transmission, encrypted storage, authorization concept, data backup concept and physical security measures for servers. These security measures are constantly reviewed in line with the latest technological developments.
6. Information About Rights
Our company would like to make sure that you are fully aware of all your data protection rights.
In order to exercise the rights defined in sections 6.1 to 6.9, you can either use the possibilities of the Personal Account of the Service, or please send a request by e-mail dataprotection@diginet.md or to the postal address indicated in clause 1.5.
If you make a request, we have one month to respond to you.
Each user is entitled to the following:
6.1. Right to be informed: You have the right to be informed – confirmation that your personal data is being collected or not. If collected, who is the Controller and who is the Processor (if any), the purposes of the processing and the categories of personal data collected. As well as additional information:
- a) recipients or categories of recipients of personal data;
- b) the existence of rights to access, amend your personal data and object, including the conditions for exercising these rights;
- c) whether responses to data-collection questions are mandatory or voluntary, and the possible consequences of not responding.
6.1.1) In Section 2 of this document, we set out the Purposes of data processing and inform you what data we collect when you visit each of the services in the public and private parts of the site;
6.1.2) clause 3.2 specifies the legality of the processing of personal data;
6.1.3) in paragraphs 2.3 – 2.6 sets out the categories of personal data collected.
6.2. Right of Access: You have the right to receive from us, upon request:
- a) confirmation of whether or not the data relating to you has been processed, as well as information about the purposes of processing, the categories of data used, the recipients or categories of recipients to whom the data is disclosed;
- b) communication of personal data that is the subject of processing, as well as information about their origin and the duration of their storage;
- c) information about the principles of operation of the mechanism used in any automated processing of data relating to you as a subject of personal data;
- d) information about the legal consequences for you as the subject of personal data resulting from the processing of data;
- f) information about the procedure for making changes to your personal data.
6.3. Withdrawal of Consent: You can withdraw your consent to further processing of your personal data at any time.
6.3.1. Upon receipt of your further processing consent, we will stop processing your personal data without undue delay and will inform you of this, while continuing to store it.
6.3.2. Your withdrawal of consent does not affect the lawfulness of data processing based on consent prior to withdrawal.
6.4. Right to Correction: You have the right to request that our company correct any information that you believe is inaccurate.
You also have the right to require Our Company to complete information that You believe is incomplete.
6.4.1. If the data processed by us is incorrect or incomplete, we will correct it without undue delay and inform you of this correction.
6.5. Right to deletion: If you decide that you do not want us to further process your data, send a request by E-mail dataprotection@diginet.md or on paper to the postal address specified in clause 1.5.
We will delete your data and inform you about this process. If mandatory legal provisions prevent such removal, we will notify you without undue delay.
6.6. Right to restriction of processing: You have the right to request that our company restrict the processing of your personal data if one of the following conditions applies:
- the accuracy of the personal data is disputed by you. The duration of the restriction of processing – for a period allowing us to check the accuracy of personal data and correct them;
- You are of the opinion that the processing is unlawful but you object to the deletion of personal data;
- Your personal data is no longer needed for the purposes of the processing, but is required by you to establish, exercise or defend legal claims;
- You objected to the processing of personal data in accordance with clause 6.8.
6.7. Right to data portability: you have the right to (i) receive your data in a structured, commonly used and machine-readable format and (ii) transfer that data to another Controller (en. Controller) or Processor (en. Processor) without any interference with our sides.
6.8. Right to object: you have the right to object to the processing of your personal data at any time, unless otherwise provided by law.
(i) If the objection is justified, the processing carried out by us can no longer affect your data.
(ii) You have the right to object at any time to the processing of personal data concerning you for direct marketing purposes.
Before disclosing your personal data to third parties, we will inform you of the right to object to such use, including how you can object or how to avoid sharing your personal data.
6.9. The right not to be affected by a private decision You have the right to demand the total or partial annulment of any private decision that gives rise to legal consequences in relation to your rights and freedoms and is based solely on automated processing of personal data intended to assess some of your personal aspects, such as professional competence, reliability, behavior, etc.
6.9.1. You may be affected by a private decision if (i) the decision is authorized by law to secure your legitimate interests (ii) the decision is made in the course of entering into or performing a contract, provided that you have expressed your consent to enter into or perform such contract.
6.10. Right to file a complaint: You have the right to file a complaint with the National Center for Personal Data Protection (NCPD) of the Republic of Moldova if you believe that the processing of personal data in the Diginet SERVICE violates applicable law, including the Law of the Republic of Moldova no. data” with amendments and additions.
6.11. If you rightly believe that you have suffered damage as a result of illegal processing of personal data, your rights or interests have been violated, then you have the right to apply to the court of the Republic of Moldova with a claim for compensation for material and moral damage.
7. Deleting your data
7.1. We erase or anonymize your personal data as soon as it is no longer needed for the purposes for which we collected it or used it in accordance with the sections above. If the data needs to be stored for legal reasons, it will be blocked. This means that it will no longer be available for further processing.
7.2. If you require further information on our deletion and retention periods, please contact us as Processor referred to in Section 2 providing your relevant contact details.
8. Changes of purpose
8.1. Your personal data will only be processed for purposes other than those described above, if this is required by law or if you have given your consent to change the purpose of the data processing.
8.2. In the event of further processing for purposes other than those for which we originally collected the data, we will notify you of those other purposes before the data is further processed and provide you with all other information that is relevant thereto.
9. Automated processing of Personal Data
9.1. We do not use any automated processing systems to make specific decisions, including profiling.
10. Cookies
10.1. What are Cookies Files ‘cookies’ is small text files that are placed on the user’s computer, smartphone and/or stored by the browser. If the respective server of our Website is again accessed by the user of the Website/Product, the user’s browser sends the afore received cookie back to the server. The server can evaluate the information received in this manner in various ways. Cookies can, for example, be used in order to manage advertisements on the Website or to facilitate navigation on a webpage.
10.2. Disabling of Cookies: The user can disable the installation of cookies by entering the corresponding settings in his/her browser software (e.g. in Internet Explorer, Mozilla Firefox, Opera, or Safari). However, in this case the user may jeopardize his/her use of the complete range of functions on the Website.
10.3. Cookie Policy: Please see our Cookie Policy for more information.
11. Use of web analytics
This Site uses Google Analytics and Yandex.Metrica.
11.1. Use of Google Analytics
- This system uses cookies to collect data on the Site for analysis. Google uses this data to create reports on visits to this Site, on their activity, and to assess user behavior on the Site. Google may transfer information to third parties if this is not illegal or they have an agreement with Google. Google does not associate your IP address with any other information held by Google.
- You can:
- to prevent Google from tracking cookies that are generated when you visit this Site (including your IP address), to process these data and transmit them to Google by downloading and installing a special browser plug-in.
- block the storage of cookies by selecting the appropriate settings in your browser.
- You can find more information on the use and protection of data on the website or here.
- You can view the following documents from Google: Terms of Service, Privacy Policy, or get information about Google’s use of data.
11.2. Using Yandex.Metrica
- This site uses Yandex.Metrica tools to analyze statistics on the use of this website. Yandex.Metrica generates statistical and other information about the use of the website through cookies stored on users’ computers. The information generated in relation to our website is used to generate reports on website usage.
- Yandex stores and uses such information for a period of time established by the internal regulations of the services, depending on the type of cookie file. Yandex Privacy Policy.
12. Changes To This Privacy Policy
12.1. If the Company decides to change this Privacy Policy, it will post those changes directly in the Services. Should the changes be material to you, especially concerning your right to data protection, you need to confirm them.