Privacy Policy

1. Introduction

Feelter ("we", "us", "our") is committed to protecting your privacy and personal data. This Privacy Policy explains how we collect, use, process, and protect your information when you use our behavioral intelligence services and website.

We are a data controller under the General Data Protection Regulation (GDPR) and other applicable data protection laws. Our registered office is located at Splaiul Unirii 160, Sector 4, Bucharest, Romania.

2. Information We Collect

2.1 Information You Provide Directly

• Account Information: Name, email address, company name, job title, phone number
• Business Information: Industry sector, company size, market focus, business objectives
• Communication Data: Messages, inquiries, feedback, and support requests
• Service Data: Information provided for behavioral analysis projects
• Payment Information: Billing address and payment details (processed securely by third-party providers)

2.2 Information We Collect Automatically

• Usage Data: Pages visited, time spent, click patterns, referral sources
• Device Information: Browser type, operating system, IP address, device identifiers
• Cookies and Tracking: As described in our Cookie Policy
• Location Data: General geographic location based on IP address

2.3 Information from Third Parties

• Publicly Available Data: Business information from public directories and professional networks
• Analytics Providers: Website usage statistics and performance data
• Service Providers: Information from CRM, email marketing, and payment processing partners

3. How We Use Your Information

3.1 Service Provision

• Delivering behavioral intelligence services and analysis
• Providing customer support and technical assistance
• Processing payments and managing accounts
• Communicating about services and projects

3.2 Business Operations

• Improving our services and developing new offerings
• Conducting research and analysis (anonymized)
• Managing business relationships and partnerships
• Complying with legal obligations and regulatory requirements

3.3 Marketing and Communication

• Sending newsletters and service updates (with consent)
• Providing relevant industry insights and thought leadership
• Personalizing website content and user experience
• Conducting market research and customer satisfaction surveys

4. Legal Basis for Processing

We process your personal data based on the following legal grounds:

• Contract Performance: Processing necessary to fulfill our service agreements
• Legitimate Interests: Business operations, service improvement, and fraud prevention
• Consent: Marketing communications and non-essential cookies
• Legal Obligation: Compliance with accounting, tax, and regulatory requirements

5. Data Sharing and Disclosure

5.1 Service Providers

We share data with trusted third-party service providers who assist in:

• Cloud hosting and data storage
• Payment processing and billing
• Email marketing and communication
• Analytics and website optimization
• Customer support and CRM

5.2 Business Transfers

In the event of a merger, acquisition, or sale of assets, your information may be transferred to the new entity, subject to this Privacy Policy.

5.3 Legal Requirements

We may disclose information when required by law, court order, or to:

• Comply with legal obligations
• Protect our rights and property
• Prevent fraud or security threats
• Protect the safety of users or the public

5.4 No Sale of Personal Data

We do not sell, rent, or trade your personal information to third parties for their marketing purposes.

6. International Data Transfers

Your data may be processed in countries outside the European Economic Area (EEA). When we transfer data internationally, we ensure adequate protection through:

• European Commission adequacy decisions
• Standard Contractual Clauses (SCCs)
• Binding Corporate Rules (BCRs)
• Certification schemes and codes of conduct

7. Data Security

We implement comprehensive security measures to protect your data:

7.1 Technical Safeguards

• Encryption in transit and at rest
• Secure access controls and authentication
• Regular security audits and vulnerability assessments
• Intrusion detection and monitoring systems

7.2 Organizational Measures

• Staff training on data protection
• Confidentiality agreements with employees and contractors
• Regular review of data processing activities
• Incident response and breach notification procedures

8. Data Retention

We retain personal data only as long as necessary for the purposes outlined in this policy:

• Account Data: Duration of business relationship plus 7 years for legal compliance
• Project Data: As specified in service agreements, typically 3-5 years
• Marketing Data: Until consent is withdrawn or 3 years of inactivity
• Website Analytics: Anonymized after 26 months
• Support Communications: 3 years from last interaction

9. Your Rights Under GDPR

As a data subject, you have the following rights:

9.1 Access and Portability

• Right of Access: Request information about data we hold about you
• Data Portability: Receive your data in a structured, machine-readable format

9.2 Correction and Deletion

• Rectification: Correct inaccurate or incomplete personal data
• Erasure: Request deletion of your personal data ("right to be forgotten")

9.3 Processing Limitations

• Restriction: Limit how we process your data in certain circumstances
• Objection: Object to processing based on legitimate interests or for marketing
• Withdraw Consent: Revoke consent for consent-based processing

9.4 Supervisory Authority

You have the right to lodge a complaint with a data protection supervisory authority if you believe we have not handled your data appropriately.

10. Cookies and Tracking Technologies

We use cookies and similar technologies to enhance your experience. For detailed information, please see our Cookie Policy.

10.1 Essential Cookies

Required for website functionality and security. These cannot be disabled.

10.2 Analytics Cookies

Help us understand website usage and improve user experience. You can opt out in your browser settings.

10.3 Marketing Cookies

Used for personalized advertising and marketing. Require explicit consent.

11. Children's Privacy

Our services are not intended for children under 16 years of age. We do not knowingly collect personal information from children under 16. If we become aware that we have collected personal data from a child under 16, we will take steps to delete such information.

12. Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes in our practices or applicable laws. We will:

• Post the updated policy on our website
• Send email notification for material changes
• Provide at least 30 days notice for significant changes
• Update the "Last Updated" date at the bottom of this policy

13. Contact Us

For questions about this Privacy Policy or to exercise your data protection rights:

13.1 Contact Information

Email: contact@feelter.io

13.2 Postal Address

Feelter
Splaiul Unirii 160, Sector 4
Bucharest, Romania

13.3 Response Time

We will respond to data protection inquiries within 30 days of receipt. For complex requests, we may extend this period by up to 60 days with notification.

Supervisory Authority Contact

You may contact the relevant data protection authority:

Romanian National Supervisory Authority for Personal Data Processing (ANSPDCP)
Website: dataprotection.ro
Email: anspdcp@dataprotection.ro

Last updated: August 15, 2025