FullyTokenized values the confidentiality of your personal data and is firmly committed to safeguarding the information you share with us. This Privacy Policy has been prepared to provide clarity and transparency regarding how FullyTokenized, in its role as data controller, collects, uses, stores, and protects your personal information when you interact with our Website and the Service. This page on our Privacy Policy informs you of our policies and procedures regarding the collection, use, and disclosure of personal data when you use our Service and the choices you have associated with that data. We use your personal data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this Privacy Policy.
Please take the time to read this Privacy Policy carefully before using our Website or the related Service. All capital terms as defined in our Terms and Conditions carry the same meaning here unless otherwise specified.
For the purposes of this Privacy Policy, the terms "personal data" and "personal information" are used interchangeably. It is also sometimes collectively referred to as handling, collecting, disclosing, protecting or storing your personal information as "processing" such personal information.
Throughout this Privacy Policy, "FullyTokenized", "we", "our", and "us" refer to FullyTokenized as the brand name and MAYWIN SD S.R.L. as the operating limited liability company, incorporated and functioning according to the laws of Romania, with the following details:
Address: Cluj-Napoca, 279 Calea Turzii, No. 3, Cluj County, Romania
Company Registration Number: J12/1538/2024
Company Sole Identification Code: 38691671
E-mail: [email protected]
Information Collection And Its Use
FullyTokenized collects certain non-personally identifiable information typically provided by browsers and servers, such as operating system, browser type, language settings, referring website, as well as the date and time of each visit (the "Usage Data"). This information is used to gain a better understanding of how visitors interact with the Website. Such data may be gathered through analytics tools, which can provide insights such as how a user arrived on the Website, whether they are a returning visitor, the duration of their visit, and the specific pages viewed. In particular, the Website uses Google Analytics.
We may also collect information that could potentially be personally identifiable, such as Internet Protocol (IP) addresses. However, FullyTokenized does not use IP addresses to directly identify individuals and does not disclose this data except in accordance with this Privacy Policy.
To provide access to the Website and deliver our Service, FullyTokenized may need to collect personal data—defined as information relating to an identified or identifiable individual. The type and scope of personal data collected depends on the nature of your interaction with us. In all cases, we only collect what is necessary and proportionate to fulfil the purpose of the interaction, such as delivering our Service. Personally identifiable information may include, but is not limited to:
- First name and last name
- Email address
- Phone number
- Cookies and Usage Data
You are free to withhold certain personal information; however, doing so may limit our ability to provide you with our Service and some or all of its features.
2. More on Cookies and Track Information
We use cookies and similar tracking technologies to track the activity on our Website and Service. A cookie is a small file, typically a string of information of letters and numbers, downloaded to a device when a person accesses certain websites. Cookies are then sent back to the originating website on each subsequent visit. Cookies can allow a website to recognise a person's device.
Other tracking technologies are also used, such as beacons, tags, and scripts, to collect and track information and to improve and analyze our Service. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.
3. Use of Personal Data
FullyTokenized uses the collected personal information for the following purposes:
- To provide and maintain our Service;
- To notify you about changes to our Service;
- To allow you to participate in interactive features of our Service when you choose to do so;
- To manage event registrations and attendance;
We process your personal information to plan and host video-conferences or webinars for which you have registered via Calendly or otherwise, or that you attend, including sending related communications to you. - To provide customer support;
- To gather analysis or valuable information so that we can improve our Website and Service;
- We process your personal information to analyze overall trends and help us improve the user experience on our Website;
- To monitor the usage of our Service;
- To administer surveys and conduct research; and
- To detect, prevent, and address technical issues.
4. Legal Basis for Processing Personal Information Under GDPR
FullyTokenized' legal basis for collecting and using the personal information described in this Privacy Policy depends on the personal information we collect and the specific context in which we collect it.
In line with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, (the "General Data Protection Regulation" or "GDPR"), FullyTokenized' legal basis is:
- The performance of a contract or our legitimate interest in fulfilling your requests and communicating with you;
- The performance of a contract or our legitimate interest to provide and administer our Service;
- The performance of a contract or our legitimate interest in providing the video-conference, webinar, training;
- Our legitimate interest in providing online content to our customers and prospective customers regarding our Service offering and related information;
- Our legitimate interest in providing a relevant and well-functioning Website for the benefit of our Website visitors;
- Our legitimate interest in promoting the safety and security of our Website and in protecting our rights and the rights of others;
- Our legitimate interest for payment purposes and in the management of our business operations;
- Your consent or explicit consent and our legitimate interest in conducting the survey or research based on its stated goals (where no special categories of personal information are in scope);
- Our legitimate interest in protecting against misuse or abuse of our Website or Service, protecting personal property or safety, pursuing remedies available to us and limiting our damages, complying with judicial proceedings, court orders or legal processes, responding to lawful requests, or for auditing purposes.
5. Retention of Data
FullyTokenized will retain your personal data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your personal data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
FullyTokenized will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer periods.
6. Third-Party Providers
To deliver our Service effectively, FullyTokenized may share or transfer personal data with its affiliated companies and third-party contractors. Such disclosures are made only for purposes directly connected to providing the Services, fulfilling the reasons for which the data was originally collected, or the additional purposes outlined in Section 3 above.
In particular, we may rely on third-party providers for services such as data backup, hosting, storage, and security. These providers are permitted to use personal data solely for the purpose of delivering their contracted services to FullyTokenized. Each provider is required to uphold confidentiality, apply appropriate security measures, and process personal data strictly in line with our instructions and applicable data protection laws. Where providers engage their own sub-processors, they must ensure equivalent safeguards are in place.
The following are examples of third parties or categories of third parties with whom we may share your data:
- Affiliated companies connected to FullyTokenized or making use of current or future FullyTokenized services;
- External legal counsel and other professional advisers;
- Accounting and audit firms;
- Technology and infrastructure providers, including:
- Amazon Web Services (AWS)
- Cloudflare
- DocuSign
- GitHub
- Google (Analytics)
- Jira
- Microsoft
- Slack
From time to time, we may also share your data with similar providers offering equivalent or replacement services to those listed above.
7. Security of Data
We are committed to ensuring that your personal data is safeguarded at all times. To this end, we maintain an adequate level of protection and implement appropriate technical and organizational measures designed to prevent accidental or unlawful destruction, loss, alteration, unauthorized disclosure, access, or any other unlawful processing of your data.
We maintain a comprehensive data protection and recovery framework. To enhance security, our servers use Secure Sockets Layer (SSL) encryption, ensuring that information you provide or access during a session cannot be intercepted by unauthorized parties.
That said, because the internet cannot be considered entirely secure, we cannot guarantee that the transmission or storage of your personal information will always be completely free from risks. We therefore encourage you to exercise caution when accessing our Website or sharing information online.
8. Your rights in relation to personal information
Subject to the conditions and limitations set out under applicable law, you may be entitled to exercise some or all of the following rights with respect to the personal information we process about you:
- Right to be informed – to receive clear information about how your personal data is collected and used.
- Right of access – to request a copy of the personal data we hold about you.
- Right to rectification – to ask us to correct or complete inaccurate or incomplete data.
- Right to restriction – to request limits on how we process your personal data.
- Right to data portability – to have your personal data transferred to another organisation, where technically feasible.
- Right to object – to object to certain processing activities, such as direct marketing.
- Right to erasure – to request the deletion of your personal data, subject to legal or regulatory retention obligations.
- Right to lodge a complaint – to raise concerns with a supervisory authority. If you have any questions or complaints about this Privacy Policy or the way that we handle your personal data, we would appreciate the chance to deal with your concerns in the first instance before you approach the relevant authority. Please contact us using the email: [email protected]. You have the right to make a complaint at any time to any relevant authority for data protection issues.
Please note that these rights are not absolute and may only apply under specific circumstances. For example, even if you request erasure of your personal data, we may still need to retain certain records to comply with accounting, and record-keeping purposes or in order that we comply with our legal and regulatory obligations.
To protect your privacy and ensure security, we may verify your identity before responding to a rights request. Verification may include matching information you provide against data we already hold. If we cannot confirm your identity with reasonable certainty, we may need to decline your request.
Exercising your rights will not result in discrimination against you. However, please be aware that in some cases, exercising certain rights (such as restricting processing or requesting erasure) may make it impossible for us to continue providing certain services.
9. Google Analytics
The FullyTokenized Website uses Google Analytics, a web analytics service provided by Google, Inc. ("Google"). Google Analytics uses "cookies", which are text files placed on your computer, to help the FullyTokenized Website analyze how users use our Website. The information generated by the cookie about your use of the Website (including your IP address) will be transmitted to and stored by Google on servers in the United States. In case of activation of the IP anonymization, Google will truncate/anonymize the last octet of the IP address for Member States of the European Union as well as for other parties to the Agreement on the European Economic Area. Only in exceptional cases, the full IP address is sent to and shortened by Google servers in the USA.
Google will use this information for the purpose of evaluating your use of the Website, compiling reports on Website activity to FullyTokenized and providing other services relating to Website activity and internet usage to FullyTokenized. Google will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser. However, please note that if you do this, you may not be able to use the full functionality of this website. Furthermore you can prevent Google’s collection and use of data (cookies and IP address) by downloading and installing the browser plug-in available under
this link.
10. Links to Other Sites
Our Website may include links, integrations, or redirects to external websites, social media platforms, or third-party content over which we have no control. The presence of such links does not imply our endorsement of, or any association with, the operators of those websites, and they fall outside the scope of this Privacy Policy.
If you choose to access a third-party website, you do so at your own discretion. We strongly encourage you to review the privacy policies and practices of those third parties before sharing any personal data with them. We are not responsible or liable for the actions, policies, or data protection standards of third-party operators, and your interactions with them are governed solely by their own terms.
11. Children's Privacy
FullyTokenized recognizes the critical importance of safeguarding children's privacy, particularly in the digital space. Our Website and Service are not intended for, nor directed toward, individuals under the age of majority. Access to and use of our Service is restricted to users who are at least 18 years old. We do not knowingly collect, store, or process personal information from anyone under this age threshold. If we become aware that we have inadvertently gathered such data, we will take prompt steps to delete it from our systems.
12. Changes to This Privacy Policy
FullyTokenized may revise or update this Privacy Policy from time to time at its sole discretion. Any changes will be published on the Website, and your continued use of our Service constitutes acceptance of the updated Privacy Policy.
Please note that any personal information collected by FullyTokenized is governed by the version of the Privacy Policy in effect at the time of collection. We encourage you to review this Privacy Policy periodically to stay informed about how we handle, protect, and process your personal information
13. Governing Law and Dispute Resolution
This Privacy Policy, and any matters arising from or related to it, shall be governed by and interpreted in accordance with the laws of Romania, without regard to its conflict of law rules.
You agree first to try to resolve any dispute informally by contacting us at
[email protected]. If a dispute is not resolved within 30 days of submission, any disputes in connection with this Privacy Policy shall fall under the exclusive jurisdiction of the competent courts of Romania.
13. Contact Us
If you have any questions about this Privacy Policy, please contact us by email:
[email protected]
