Privacy policy

Last updated: 5 October 2026

ProMotion Creative respects the privacy of the people it deals with and treats the protection of personal data with the same seriousness we apply to our clients' campaign data. In short: we collect what we need, we explain why, and we don't turn your data into a marketing mystery.

This policy explains how we collect, use, store and protect personal data when you:

• visit the website promotioncreative.ro;
• contact us or request a quote;
• book a consultation;
• apply for a service or programme, including Incubator SIM by PMC;
• become a client, supplier or partner;
• subscribe to our communications;
• apply for a job, internship or collaboration;
• interact with ProMotion Creative or ProMotion Consulting by email, phone, social media or other channels.

1. Who is the data controller?

The data controller is:

PROMOTION PERFORMANCE S.R.L.
Trading name: ProMotion Creative
Consulting division: ProMotion Consulting
Tax ID (CUI): 52722951
Registered office: Str. Someșului nr. 4, ap. 1, Târgu Mureș, Mureș County, Romania
Website: promotioncreative.ro
Email: motion@promotioncreative.ro
Phone: +40 750 160 928

ProMotion Consulting is a division of ProMotion Creative, not a separate controller, unless expressly stated otherwise.

For questions or requests about personal data, you can write to us at the email address above with the subject “Data protection”.

2. What personal data may we collect?

Depending on how you interact with us, we may process the following categories of data:

Identification and contact data

• first and last name;
• email address;
• phone number;
• job title and company;
• town or country.

Professional and company data

• industry;
• company size and structure;
• website and marketing channels;
• marketing or advertising budget;
• turnover or declared revenue range;
• the company's goals, difficulties and needs;
• information about internal marketing, sales or CRM processes;
• other information provided in a form, audit, conversation or consulting session.

Contractual and financial data

• information needed to prepare quotes and contracts;
• billing details;
• history of services and payments;
• commercial and operational correspondence.

We do not collect or store full bank card details. Where online payments are available, they are processed by the payment provider used.

Technical and usage data

• IP address;
• type of device, browser and operating system;
• pages visited and time spent on the site;
• source of the visit;
• cookie or similar identifiers;
• events and interactions with the site;
• technical data needed for the site's security and operation.

Communications data

We may keep messages, requests, replies and relevant notes from conversations by email, phone, forms, video calls or social media.

An audio or video conversation will only be recorded after participants have been informed and, where required, have given their consent.

Recruitment data

If you apply for a role, internship or collaboration, we may process:

• your CV and portfolio;
• your professional experience;
• your professional profiles;
• your answers in the application form;
• materials you send voluntarily;
• notes from interviews.

Please do not send us sensitive data or information that isn't needed for your request.

3. How do we obtain data?

We may receive data:

• directly from you;
• automatically, through your use of the site and the technologies allowed by your cookie preferences;
• from the company or organisation you represent;
• from partners, clients or suppliers, where there is a legal reason;
• from publicly available professional sources, such as company websites, public registers or professional profiles;
• from the platforms through which you communicate with us, within the limits of their settings and policies.

4. Why do we use data, and on what legal basis?

Where we rely on legitimate interest, we assess whether the purpose is proportionate and whether the data subject's rights override our interest.

Where processing is based on consent, you can withdraw it at any time. Withdrawal does not affect the lawfulness of processing carried out before it.

5. Forms, audits and Incubator SIM

Contact, qualification and application forms help us understand whether and how we can contribute to your company's goals.

For the Incubator SIM by PMC programme, we may ask for information about:

• the business model;
• the team and internal resources;
• current marketing and sales activities;
• declared revenue or budgets;
• existing processes, tools and bottlenecks;
• development and scaling goals.

We use this data to assess fit, prepare the initial conversation and, if we start working together, to design and implement the internal marketing system.

We do not use confidential information provided during the assessment to promote other companies, and we do not publish it without separate permission.

6. Cookies, analytics and advertising

The site may use:

• cookies strictly necessary for its operation and security;
• preference cookies;
• traffic analytics technologies;
• conversion measurement technologies;
• advertising and remarketing technologies.

Non-essential cookies and technologies are only activated based on the choices you make through the consent mechanism on the site.

Depending on the active technical configuration, we may use services such as:

• Google Analytics 4;
• Google Tag Manager;
• Google Search Console;
• Meta Pixel and/or Conversions API;
• appointment booking platforms;
• CRM and automation tools;
• video hosting or external content platforms.

You can change or withdraw your cookie choices from the preferences panel on the site. More information about the active technologies, providers and their durations is set out in our Cookie policy.

7. Commercial communications

We may send you newsletters, educational materials, invitations, studies, updates and offers if:

• you have given your consent;
• you are a client, and the law allows communication about similar services;
• another legal basis applies to the situation.

You can unsubscribe at any time using the link in the message or by writing to us at motion@promotioncreative.ro.

Unsubscribing from marketing does not stop administrative messages needed for an active collaboration.

8. Who may we share data with?

We do not sell personal databases.

We may give access to data, strictly to the extent necessary, to the following categories of recipients:

• the site's hosting and maintenance provider;
• email and cloud service providers;
• CRM, project management and automation platforms;
• analytics, advertising and measurement providers;
• booking and video-conferencing platforms;
• payment processors;
• accounting, audit, legal or IT service providers;
• collaborators involved in delivering a project, bound by confidentiality obligations;
• public authorities, where disclosure is required by law;
• potential buyers or investors, in the context of a reorganisation or transaction, with appropriate safeguards.

Providers that process data on our behalf are contractually required to protect it and to use it only according to our instructions.

9. International transfers

Some technology providers may process data outside Romania or the European Economic Area.

In these cases, we use mechanisms recognised by applicable law, such as:

• an adequacy decision issued by the European Commission;
• standard contractual clauses approved by the European Commission;
• other safeguards provided for by the GDPR.

You can ask us for more information about the safeguards that apply.

10. How long do we keep data?

We keep data only as long as it is needed for the purpose for which it was collected, or as long as the law requires.

Typically:

• requests and opportunities that don't lead to a collaboration are kept for at most 24 months from the last interaction;
• client data is kept for the duration of the collaboration and afterwards according to the applicable accounting, tax and limitation periods;
• marketing preferences are kept until consent is withdrawn or you unsubscribe;
• we may keep minimal proof of an unsubscribe to make sure the preference is respected;
• technical and security logs are usually kept for 6 to 12 months, unless an incident justifies a longer period;
• applications are kept for at most 6 months after recruitment ends;
• with separate consent, an application may be kept for up to 24 months for future opportunities;
• data collected through cookies is kept for the durations shown in the consent panel and the Cookie policy.

Data may be kept longer where this is needed to meet a legal obligation, resolve a dispute or protect our rights.

11. How do we protect data?

We apply technical and organisational measures suited to the nature of the data and the risks involved, including, where appropriate:

• access control for accounts and systems;
• multi-factor authentication;
• updates and infrastructure hardening;
• backups;
• limiting access to the people who need the data;
• confidentiality agreements;
• selecting and vetting providers;
• procedures for identifying and handling incidents.

No method of transmission or storage can guarantee absolute security, but we take preventing and handling incidents seriously.

12. What are your rights?

Under the conditions set out in the GDPR, you can request:

• access to your personal data;
• correction of inaccurate or incomplete data;
• erasure of your data;
• restriction of processing;
• data portability;
• to object to processing based on legitimate interest;
• to object to direct marketing, at any time;
• to withdraw your consent;
• information about the safeguards used for international transfers;
• not to be subject to a decision based solely on automated processing, if it produces legal effects or similarly significantly affects you.

To exercise your rights, send a request to motion@promotioncreative.ro with the subject “Data protection”.

We may ask for reasonable information to verify your identity. We will usually reply within one month. For complex or numerous requests, this period may be extended as provided by the GDPR, and you will be informed.

Exercising your rights is normally free of charge. For manifestly unfounded or excessive requests, the law may allow us to charge a reasonable fee or to refuse the request.

13. Automated decisions and profiling

We do not make decisions based solely on automated processing that produce legal effects or similarly significantly affect data subjects.

Subject to your cookie preferences, we may use audience segmentation, conversion measurement or ad optimisation. These activities do not automatically determine whether a client is accepted into or refused from a programme.

14. Children's data

Our services are aimed at companies and professionals and are not designed to collect children's data intentionally.

If we learn that we have received data about a minor without an appropriate basis, we will take steps to delete it.

15. External links and platforms

The site may contain links to external platforms, social networks or services operated by third parties. How these third parties process data is governed by their own privacy policies, over which we have no control.

We recommend reading those policies before sending them personal data.

16. Changes to this policy

We may update this policy when our services, tools, internal processes or the applicable law change.

The updated version will be published on this page, with the date of the last change. If the changes are significant, we may also inform the people affected by other appropriate means.

17. Complaints

If you have a concern, we encourage you to contact us first so we can try to resolve it.

You also have the right to lodge a complaint with:

The National Supervisory Authority for Personal Data Processing (Autoritatea Națională de Supraveghere a Prelucrării Datelor cu Caracter Personal – ANSPDCP), Romania
Website: www.dataprotection.ro

If you live or work in another EU country, you may also complain to the data protection authority there.

This right does not affect your ability to use other administrative or judicial remedies.