Privacy Policy
Privacy Policy · Personal Data Protection
Version 2.0 • October 2026
Applicable legal framework
Law No. 195/2024 on personal data protection (Republic of Moldova, in force since 23 August 2026)
Policy version: 2026-10
Supervisory authority: CNPDCP — National Center for Personal Data Protection
Data controller — who we are
The applexium.com website is run by SCALELAW SOLUTIONS SRL (IDNO 1025600064372), which acts as the controller of the personal data collected through it:
| Name | SCALELAW SOLUTIONS SRL |
|---|---|
| Brand | Applexium |
| IDNO | 1025600064372 |
| Registered office | MD-2069, mun. Chișinău, Calea Ieșilor 67, of. 9 |
| Office address (correspondence) | str. Mihai Viteazul 2a, Chișinău, Republic of Moldova |
| Administrator | Mircea Ursu |
| Email (including data protection) | info@applexium.com |
| Phone | +373 78 76 87 65 |
This policy applies only to www.applexium.com. Applexium's products (Legalia, Emmi, Precedentia) have their own privacy policies.
What we process, why, and on what legal basis
| Situation | Data | Purpose | Legal basis (Law 195/2024) |
|---|---|---|---|
| Contact form (applexium.com/en/contacts) | Full name, email, company name (optional), message; proof of consent: policy version, consent text, language, date and time | Replying to your request and, if you wish, pre-contractual discussions | Consent — Art. 6(1)(a); later, if you initiate a contract — Art. 6(1)(b) |
| Emmi virtual assistant (the on-site chat, opened only when you choose to) | The messages you write and, if you start a voice conversation, your voice; any personal data you choose to include; if “visitor memory” is enabled — a pseudonymous identifier and summaries of previous conversations | Automated answers to your questions about Applexium and its services | Steps taken at your request before entering into a contract — Art. 6(1)(b); legitimate interest in answering visitors — Art. 6(1)(f) |
| Direct correspondence (email, phone) | Contact details and the content of the communication | Replying, pre-contractual or contractual relationship | Art. 6(1)(b) and (f) |
| Technical delivery of the site | IP address, browser type, requested page, date and time (the hosting provider's server logs) | Serving pages, security, abuse prevention | Legitimate interest — Art. 6(1)(f) |
We use no traffic analytics or advertising tools and build no visitor profiles. We send no marketing communications. We make no decisions based solely on automated processing that produce legal effects for you; the Emmi assistant's answers are informational only.
Providing your data is not a legal or contractual requirement. Without your name, email and message, however, we cannot reply to a request sent through the form; the company name is optional.
The site is not directed at children. Persons under 14 may contact us only with the consent of their legal representative (Art. 8 of Law 195/2024).
Consent and how to withdraw it
For the contact form we ask for your consent through a separate checkbox that is never pre-ticked. Together with your message we keep proof of that consent (policy version, consent text, date and time) so that we can demonstrate it under Art. 7(1).
You can withdraw your consent at any time, as easily as you gave it: an email to info@applexium.com is enough. Withdrawal does not affect the lawfulness of processing carried out before it.
Recipients of your data
We do not sell or rent data. We share it only with the providers that help us run the site, acting as processors:
| Recipient | Role | Country |
|---|---|---|
| Formspree, Inc. | Receives messages sent through the contact form and forwards them to us by email | USA |
| Hostinger International Ltd. | Email service for info@applexium.com | Cyprus (EU) |
| GitHub, Inc. (GitHub Pages) | Website hosting and technical server logs | USA |
| Hetzner Online GmbH — hosting of the Emmi platform (an Applexium product) | The on-site virtual assistant | Germany (EU) |
| Anthropic, PBC | Emmi: generating the assistant's answers | USA |
| OpenAI, L.L.C. | Emmi: knowledge-base search | USA |
| Soniox, Inc. (with Deepgram, Inc. and Groq, Inc. as fallback) | Emmi: speech recognition (voice conversations only) | USA |
| ElevenLabs | Emmi: text-to-speech for answers (voice conversations only) | USA |
We disclose data to public authorities only where the law requires us to.
Transfers outside the Republic of Moldova
Some of the recipients above process data in the European Union (Hetzner, Hostinger) or the USA (Formspree, GitHub and, for the Emmi assistant, Anthropic, OpenAI, Soniox, Deepgram, Groq, ElevenLabs). Transfers are made only to countries ensuring an adequate level of protection or on the basis of the appropriate safeguards provided for in Art. 46 of Law 195/2024 (for example, the standard contractual clauses included in the providers' data processing agreements). You can request information about these safeguards at info@applexium.com.
How long we keep data
- Contact form messages and the proof of consent: no longer than 24 months from receipt, or less if the request does not lead to a contractual relationship;
- Conversations with the Emmi assistant: as long as needed to answer your request; if “visitor memory” is enabled, the pseudonymous identifier and summaries of earlier conversations are kept so the conversation can continue on later visits;
- Technical server logs: kept by the hosting provider under its own policy; we do not access them or link them to your identity;
- Data in contracts or accounting documents: for the periods required by the laws of the Republic of Moldova.
When the period ends, the data is deleted or irreversibly anonymised.
Your rights
Under Law No. 195/2024 you have the right:
- of access to your data and to receive a copy (Art. 15);
- to rectification of inaccurate or incomplete data (Art. 16);
- to erasure (“right to be forgotten”) (Art. 17);
- to restriction of processing (Art. 18);
- to data portability (Art. 20);
- to object to processing based on legitimate interest (Art. 21);
- to withdraw your consent at any time, without affecting earlier processing.
To exercise these rights, write to info@applexium.com. We reply within one month of receipt; for complex requests this may be extended by two further months, in which case we will let you know.
You also have the right to lodge a complaint with the supervisory authority:
CNPDCP — National Center for Personal Data Protection
Address: 48 Serghei Lazo St., MD-2004, Chișinău, Republic of Moldova
Email: centru@datepersonale.md · Phone: (022) 820 801
Website: https://datepersonale.md
Data security
SCALELAW SOLUTIONS SRL applies appropriate technical and organisational measures to protect data against unauthorised access, loss or disclosure, including:
- transmitting data only over encrypted connections (HTTPS / TLS);
- restricting access to authorised staff;
- internal security and confidentiality policies.
In the event of a personal data breach we will notify the CNPDCP and, where required, the people affected, within the legal deadlines.
Cookies
The site uses no analytics or advertising cookies. Details about what is stored in your browser are in the Cookie Policy.
Changes to this policy
We update this policy when the law or the way we process data changes. Every version is dated (current version: 2026-10). If a change affects processing based on consent, we will ask for your consent again.
Contact
For any question or request about your personal data:
Email: info@applexium.com
Phone: +373 78 76 87 65
Registered office: MD-2069, mun. Chișinău, Calea Ieșilor 67, of. 9
Office address (correspondence): str. Mihai Viteazul 2a, Chișinău, Republic of Moldova
© 2026 SCALELAW SOLUTIONS SRL — Applexium. All rights reserved.