Privacy Policy
FIXCLIN TECH S.R.L. ยท v3.0 ยท Effective date: 27 May 2025
This Privacy Policy explains how FIXCLIN TECH S.R.L. collects, uses, and protects personal data when you use the FixClin platform as a Client or Service Provider.
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1. Who we are
FIXCLIN TECH S.R.L. ("FixClin", "we", "us", "our") is the data controller for personal data collected through the FixClin Platform. We are incorporated in the Republic of Moldova and operate in Moldova and Romania.
Registered Address: mun. Chisinau, str. Nucarilor 11, ap. 39, Republic of Moldova
This Privacy Policy applies to all Users of the Platform โ both Clients and Service Providers โ and complies with:
- EU General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679)
- Moldovan Law No. 133/2011 on the Protection of Personal Data (currently in force)
- Moldovan Law No. 195/2024 on Personal Data Protection โ FixClin is actively preparing for compliance ahead of the August 2026 effective date
- EU Digital Services Act (DSA) (Regulation (EU) 2022/2065)
- Romanian Law No. 190/2018 implementing the GDPR
2. What data we collect
2.1 Data you provide directly
- Full name, email address, phone number, and home or business address.
- National identity number or business registration number (Service Providers only, for internal identity verification by the FixClin team).
- Profile photo, trade description, and service categories (Service Providers).
- Copies of trade licences, certificates, or insurance documents (Service Providers).
- Payment method details โ processed by a PCI-DSS compliant processor designated by FixClin. FixClin does not store full card numbers.
- Reviews, ratings, and messages sent through the Platform.
2.2 Data collected automatically
Data in Section 2.2 is collected via cookies and tracking technologies. The legal basis, categories, and opt-out options are set out in our Cookie Policy at fixclin.com/cookies.
- Device identifiers, IP address, browser type, and operating system.
- Usage data: pages viewed, features accessed, search queries, and time spent on the Platform.
- Approximate location data for geo-fenced search results โ only when you explicitly grant permission.
- Log files and error reports for Platform performance and security monitoring.
2.3 Data we receive from third parties
- Payment status from the designated payment processor.
- App store data if you download the Platform via Apple App Store or Google Play.
3. Legal basis for processing
We process personal data only when we have a valid legal basis under GDPR Article 6:
- Contract performance (Art. 6(1)(b)): To register your account, process subscriptions, facilitate bookings, and provide Platform features.
- Legal obligation (Art. 6(1)(c)): To comply with Moldovan and EU tax, anti-money laundering, and data retention laws.
- Legitimate interests (Art. 6(1)(f)): To prevent fraud, improve the Platform, send service-related notifications, and ensure Platform security, provided your interests do not override ours.
- Consent (Art. 6(1)(a)): For non-essential marketing communications and optional cookies. You may withdraw consent at any time without affecting prior lawful processing.
4. How we use your data
4.1 Platform operations
- Creating and managing your account.
- Verifying Service Provider identity and qualifications, conducted internally by the FixClin team prior to profile activation.
- Processing subscription payments and issuing transaction confirmations.
- Facilitating connections between Clients and Service Providers.
- Displaying profiles and search results to Clients.
4.2 Safety and trust
- Identity and credential verification of Service Providers.
- Fraud prevention, detection, and investigation.
- Enforcing Platform Terms and Conditions.
- Responding to disputes and complaints.
4.3 Communications
- Transactional notifications including booking confirmations, subscription receipts, and security alerts.
- Service updates and platform announcements.
- Marketing communications only with your explicit prior consent, which you may withdraw at any time via your account settings or by contacting support@fixclin.com
4.4 Platform improvement
- Aggregated and anonymised analytics to improve user experience.
- Product development using anonymised data only. No individual User is identified in this process.
5. Data sharing
We do not sell your personal data. We share data only in the following limited circumstances:
5.1 Between Platform Users
When a Client books a Service Provider, limited profile information including name, photo, trade category, rating, and phone number is shared to facilitate the service. Client contact details are shared with the confirmed Service Provider for job execution purposes only and must not be used for any other purpose.
5.2 Third-party processors
All third-party processors are or will be bound by Data Processing Agreements under GDPR Article 28 before any personal data is transferred to them.
- Cloud infrastructure: Amazon Web Services (AWS) hosted in EU region where possible, with EU Standard Contractual Clauses in place.
- Payment processing: PCI-DSS compliant processor designated by FixClin, bound by a Data Processing Agreement under GDPR Article 28.
- Email and SMS delivery: Provider to be confirmed prior to launch, bound by a Data Processing Agreement before any personal data is transferred.
- Analytics: Aggregated and anonymised data only.
5.3 Legal and regulatory requirements
We may disclose data to law enforcement, courts, or regulators where required by Moldovan or EU law, or to protect the rights, safety, and property of FixClin, Users, or the public.
5.4 Business transfers
In the event of a merger, acquisition, or sale of FixClin assets, personal data may be transferred to the successor entity subject to the same protections as this Policy. Users will be notified in advance of any such transfer.
6. International data transfers
FixClin operates primarily in Moldova and Romania. If data is transferred outside the European Economic Area, we ensure adequate safeguards are in place, including EU Standard Contractual Clauses approved by the European Commission or adequacy decisions where applicable. You may request details of applicable transfer mechanisms by contacting support@fixclin.com
7. Data retention
We retain personal data only for as long as necessary for the purposes described in this Policy, or as required by law:
When data is no longer needed, it is securely deleted or anonymised.
- Active account data: Retained for the duration of your account plus 2 years after closure.
- Transaction and subscription records: 5 years, as required by Moldovan and Romanian tax law.
- Review and rating data: Retained while the relevant Service Provider account remains active.
- Marketing consent records: Until you withdraw consent, plus 2 years for compliance evidence.
- Log files and security data: Up to 12 months.
8. Your rights under GDPR
If you are located in the EU/EEA, or your data is processed in connection with EU activities, you have the following rights. We will respond to all verified requests within 30 calendar days, extendable by 60 days for complex requests with prior notification:
- Right of Access (Art. 15): Request a copy of all personal data we hold about you.
- Right to Rectification (Art. 16): Request correction of inaccurate or incomplete data.
- Right to Erasure (Art. 17): Request deletion of your data where it is no longer necessary or where you withdraw consent.
- Right to Restriction of Processing (Art. 18): Request that we restrict processing of your data in certain circumstances.
- Right to Data Portability (Art. 20): Request your data in a structured, machine-readable format where processing is based on consent or contract.
- Right to Object (Art. 21): Object to processing based on legitimate interests, including profiling for direct marketing purposes.
- Right to Withdraw Consent: Where processing is based on consent, withdraw it at any time without affecting prior lawful processing.
- Right to Lodge a Complaint: Romania โ ANSPDCP (www.dataprotection.ro) / Moldova โ National Centre for Personal Data Protection (www.datepersonale.md).
Exercising your rights
To exercise any right, contact dpo@fixclin.com. We may require identity verification before processing your request.
9. Cookies and tracking
We use cookies and similar tracking technologies on the Platform. The full Cookie Policy is available at fixclin.com/cookies.
We do not use dark patterns or deceptive design to obtain cookie consent.
- Essential cookies: Required for Platform functionality. Cannot be disabled.
- Analytics cookies: Disabled by default. Require your explicit consent.
- Marketing cookies: Disabled by default. Require your explicit consent.
10. Children's privacy
The Platform is not directed at persons under 18 years of age. We do not knowingly collect personal data from minors. If you believe a minor has registered on the Platform, please contact support@fixclin.com immediately and we will delete the account and all associated data without undue delay.
11. Data security
We implement appropriate technical and organisational measures to protect your personal data, including encryption in transit (TLS/HTTPS), access controls, regular security testing, and incident response procedures. In the event of a personal data breach, we will notify you and the relevant supervisory authority within 72 hours as required by GDPR Art. 33-34.
No data transmission over the internet is entirely secure. You transmit data at your own risk, and we take all reasonable precautions to protect it.
12. Joint controller notice (GDPR Art. 26)
The Court of Justice of the EU (Case C-492/23, December 2025) confirmed that online marketplace operators qualify as joint data controllers with respect to user-generated content published on their platforms. FIXCLIN TECH S.R.L. acknowledges this responsibility and has implemented technical and organisational measures to prevent unlawful processing of personal data in Service Provider listings and User-generated content.
Service Providers are independently responsible for ensuring that any personal data they process in connection with their clients complies with GDPR and applicable Moldovan and Romanian law.
13. Changes to this Policy
We may update this Privacy Policy from time to time to reflect changes in our practices or applicable law. Material changes will be communicated by email to registered Users at least 14 days before they take effect. Continued use of the Platform after the effective date constitutes acceptance.
14. Contact us
We aim to respond to all enquiries within 5 working days and all formal data subject requests within 30 calendar days.
Company address
mun. Chisinau, str. Nucarilor 11, ap. 39, Republic of Moldova