Privacy policy

Updated on October 23, 2023

The Website (from now on "Website" or "Site") is owned by Traction Keys SRL, a legal entity with a registered office in Bucharest, Romania, registered with the Trade Register Office under number J40/17044/2022, with TIN 46749278 (from now on "Company"), processes your personal data. 

Personal data within the meaning of this document means any information relating to an identified or identifiable natural person - a person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, identification number, location data, online identifiers, or to one or more factors specific to his or her physical, physiological, genetic, mental, economic, cultural or social identity.

​This document aims to inform you about the technical and organizational measures we take and your rights regarding processing personal data. We undertake to use our best efforts to process this data in compliance with the applicable law and in accordance with the provisions of Regulation (EU) 2016/679 on the protection of individuals concerning the processing of personal data ("General Data Protection Regulation" or "GDPR").


​Through the website, we collect and process the following categories of personal data in the following situations:

  • The IP address of the device you are using, the type of internet browser you are using, and the date and time you access the website when you access it;
  • Information in the form of cookies and similar technologies when visiting the website;
  • Information such as first and last name, and e-mail address, when you choose to provide it to us;


We gather personal data that you furnish to us, encompassing details such as your name, address, contact information, passwords, security data, and payment information.

This personal information is voluntarily supplied by you when you express an interest in acquiring information about our company or our products and services, engage in activities on our Services, or make contact with us through various means.

The specific personal information we collect is contingent upon the nature of your interactions with us and our Services, the preferences you exercise, and the products and features you utilize. The categories of personal information we may gather encompass:

  • Publicly Accessible Personal Information: This category includes email addresses and similar data.
  • Credentials: We collect passwords, password hints, and analogous security information for authentication and account access.
  • It is essential that all personal information provided to us remains truthful, complete, and accurate. You are obligated to promptly inform us of any modifications to such personal data.



We process your data in accordance with the General Data Protection Regulation exclusively for the following purposes:

  • To provide you with the Website, with all its functionalities and its full content;
  • To improve your experience in using the Website;
  • To promote the content of the Website;
  • In order to fulfill our contractual obligations to you, undertaken through the Website;
  • To prevent and detect security threats, fraud, or other criminal activity;
  • To create and manage your account as appropriate
  • To inform you about orders placed on the Website, as appropriate;
  • To ensure that you can subscribe to the Newsletter as appropriate;


The collection and processing of your data will always be carried out in accordance with the applicable legislation in force, based on one or more of the following grounds:

We have your consent to process your data - Your consent is a legal basis for collecting, storing, and using your personal data. Where, under applicable law, the processing of certain special categories of personal data requires your express prior consent, we will only process data with your express prior consent;

Our legal obligations require data processing - The collection and processing of personal data may be necessary for the fulfillment of legal obligations imposed on us, for example, in relation to the protection against criminal activities and fraud or for the fulfillment of tax obligations.

We have a contractual obligation to you - The processing of your data will be necessary if we enter into, amend and/or perform a contract with you via the Website.

There is a legitimate interest justifying the processing. In certain situations, the processing of your personal data may be necessary to satisfy either a public interest or a private interest of ours or third parties. When data processing is carried out in our legitimate interest, it will always be done with respect for your interests and/or fundamental rights and freedoms.

The processing is necessary to protect the vital interests of you or another natural person.

In cases where applicable legal provisions require your prior explicit consent for processing special categories of personal data, we will process such data only based on your prior explicit consent.


We make every effort to keep your personal data secure. To this end, we have implemented all appropriate technical and organizational measures in accordance with our internal procedures and the legislation in force regarding the storage, transmission, and access of personal data.


Your personal data is kept only as long as necessary in accordance with the purposes set out in this Privacy Policy and the storage periods required by applicable legal provisions.

You may at any time request and obtain, at your discretion, the deletion of your personal data.​


In certain situations, we will transmit your personal data to our collaborators, maintaining control over them and using appropriate technical and organizational protection measures. We make every effort to ensure the integrity and security of your data also when it is transmitted to third parties/persons.

We may handle or share the data we possess based on the following legal grounds:

  • Consent: Your data may be processed if you have provided explicit consent for a specific purpose.
  • Legitimate Interests: Data processing may occur when reasonably necessary to pursue our legitimate business interests.
  • Performance of a Contract: If we have a contractual agreement with you, we may process your personal information to fulfill the terms of that contract.
  • Legal Obligations: We may disclose your information when compelled by applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as responding to a court order or subpoena. This includes cooperating with public authorities to meet national security or law enforcement requirements.
  • Vital Interests: Your information may be disclosed when we believe it is crucial to investigate, prevent, or take action in situations involving potential policy violations, suspected fraud, threats to individual safety, illegal activities, or as evidence in litigation we are involved in.

In more specific terms, we may need to process your data or share your personal information in the following scenarios:

Business Transfers: Information sharing or transfer might occur in connection with, or during discussions of, a merger, sale of company assets, financing, or acquisition of all or part of our business by another entity.

Your personal data will only be transmitted at your request or with your consent unless required by law.​


Subscribing to the Newsletter can be done by registering your e-mail address, accepting the Terms and Conditions in advance, and agreeing to receive the newsletter.

At any time, you have the right to unsubscribe directly by means of the e-mail message you receive for this purpose.


The right to be informed

You have the right to know what data we process, how it is processed, the purpose and legal basis of its processing, and any other information concerning the processing of your personal data.

Right of access

You have the right to obtain confirmation from us that we are processing your personal data and the right to access it.

Right to rectification/completion of data

At your request, you have the right to have your personal data rectified or completed, as appropriate, whenever you consider them to be incorrect or incomplete.

The right to delete your data

 At any time, you have the right to request and obtain the deletion of your personal data without undue delay ("right to be forgotten"). 

​Right to data transfer/portability

At your express request, the data processed by us may be transferred either to you or to another controller indicated by you.

​The right to oppose

You have the right to object to the processing of your personal data at any time and for any reason you consider appropriate. If you agree to exercise your right to object, we will immediately stop processing your data.

​The right not to be subject to an individual decision taken by us

​The right to report violations of your rights to the authorities.

​Any violation of your rights can be reported to the National Authority for the Supervision of Personal Data Processing (ANPC).


​For any reported irregularities, questions, or uncertainties, as well as to exercise any of the rights listed above, please do not hesitate to contact us by sending a request either to our e-mail address,, or by post or courier to Clucerului 55, Bucharest.