01The data controller
The controller of your personal data, within the meaning of Regulation (EU) 2016/679 (the “GDPR”), is:
- Name: INSPIRING RESEARCH & INVENTIVE SOLUTIONS S.R.L.
- Unique registration code (CUI): 48657227
- Trade Register number: J2023015414400 (EUID ROONRC.J2023015414400)
- Registered office: Str. Lt. Radu Beller, nr. 3-5, Sector 1, București
- Contact email, including for personal data: [email protected]
In this policy, the controller is referred to as “we”, and the theposting.ai service as “the Service”. Capitalised terms have the meaning given to them in the Terms and Conditions.
For any question about your personal data, you can write to us at [email protected].
02Who this policy applies to
This policy applies to visitors of the public website (the home page, pricing, the legal pages, sign-in and sign-up) and to users who create an account and use the application.
If you use the Service on behalf of a company, we process your data as the account user and as the company’s contact person.
This policy does not apply to third-party websites and services you reach through the Service, such as social networks, their sign-in pages or the Stripe payment page. These have their own privacy policies.
03What data we process
We only process the data we need to provide the Service. Specifically:
- Account data
- – the name, email address and mobile phone number entered at sign-up (or added after sign-in, for accounts created before the phone number was required), the password (stored only as a salted hash, never in plain text), the account role, the account creation date, the date of the last sign-in and the date of your last activity in the application (updated at most once an hour). We also keep whether and when you confirmed your email address, and the language of the site when you signed up (used for the emails we send you; for accounts created before we started recording it, the language at the first sign-in after that). If you delete your account, we also record the date of deletion and the reason you give, if any (optional), and, if you sign up again, the link between the new account and the deleted one.
- Sign-in sessions
- – when you sign in, a cookie containing a random identifier is saved in your browser, while our database keeps only its cryptographic fingerprint (hash), together with the expiry date.
- Sign-in security and one-time links
- – when we email you a link to confirm your email address (valid for 48 hours) or to reset your password (valid for 60 minutes, single use; a new link cancels the previous ones), our database keeps only a cryptographic fingerprint (hash) of the link’s code, the address it was sent to, and when it expires and when it was used. To protect accounts against password guessing and abuse, we count failed sign-in attempts and requests for these emails per email address (stored only as a hash, never in plain text) and per IP address; after 5 failed attempts for an address (or 30 from the same IP address), sign-in is temporarily locked (for 15 minutes, longer if it happens again). We record that a lock occurred (its scope, per email address or per IP address, and its duration and, if the address belongs to an account, the account identifier), without the email address or the IP address.
- Your content
- – the uploaded images or video (the file, its type, size and original file name; for a video also its duration, dimensions and a few still frames taken from it in your browser), the edited copies of your photos and the edit settings, the photos picked automatically for a post, the instruction (brief), the chosen tone, the selected networks, the generated drafts and your edits, the instructions for regeneration and the additional fields required by some networks (for example the title, the subreddit, the Pinterest board or the Google Business location). Original files are kept and passed on as you upload them, including their metadata (for example a photo’s EXIF data, which may include where it was taken); edited copies no longer contain this metadata.
- Connected social accounts
- – the network, the username, the display name and the account identifier at the Zernio publishing service, as well as your Zernio profile identifier. Accounts are connected through the network’s sign-in page or, for Bluesky, through an app password that we pass on to Zernio without storing it. We do not receive or store the passwords of your social accounts. Your Zernio profile is created with the name and email address of your theposting.ai account, so that we can identify it.
- Registry of connected social accounts
- – for every social media account connected through theposting.ai: the network, the account’s identifier on that network and its username, the date it was first connected and which theposting.ai account connected it first (the account identifier and a one-way hash of its email address), and when it was last seen. We use it only to apply the free-plan rule that an account already used on theposting.ai by someone else cannot be connected again on Free.
- Custom offer requests
- – the name, email, phone number, optional company, needs and message you send through the custom offer form, plus a one-way hash of your IP address used to limit spam.
- Post history and scheduling
- – the status of each draft on each network (draft, approved, scheduled, publishing, published or failed), the approval, scheduling and publishing dates, the link and identifier of the published post and the error messages received from the networks.
- Time zone
- – the time zone detected in your browser, used to display and schedule publishing times correctly.
- Usage and plan
- – a record of the actions that count towards the plan limits (posts created, regenerations, publications), the chosen plan, the trial period, the free plan period, the subscription status, monthly packs and extra social accounts, remaining credits from one-time packs, and any packs, credits or offers granted by our team.
- Billing and payment data
- – your Stripe customer identifier, the subscription (the plan, billing period, price, currency, status, and start, renewal and cancellation dates) and the payments (the amount, currency, status, period covered). We keep the billing details you enter at checkout or on your account page (individual or company; the name or company name, the tax ID and trade register number of a company, the address and, optionally, an email address for invoices); those entered on the payment page are also kept by Stripe. We issue the invoices ourselves; they contain the seller’s and buyer’s details, the items, the amounts, the VAT and, for payments in euro, the BNR exchange rate. You enter your card details directly on the Stripe page; we do not receive or store them. Before every payment we also keep proof of the confirmation in which you requested that the service start immediately and acknowledged losing the right of withdrawal (the date and time, what you bought, the version of the Terms and the language it was shown in), together with the payment records.
- Log of administrative actions
- – when a theposting.ai administrator changes something in your account (for example changes the plan, extends the trial period, deactivates or restores the account or changes the role), we record the action, the administrator who performed it, the date and the details of the change.
- Correspondence
- – the messages you send us by email and our replies.
- Technical data
- – the application records technical errors in the server logs; these may contain internal identifiers (for example of a post or an account), but not the content of your posts. For security and operational purposes, our network provider (Cloudflare) and the hosting infrastructure may record data about requests, such as the IP address, the date and time, the page accessed and the browser type.
- Visit statistics
- – for each page viewed on the website or in the application: the page address (without its parameters), the date and time, where the visit came from (the referring site and any utm_source, utm_medium and utm_campaign tags of the link), the country (derived from the IP address by our network provider), the device type (computer, phone or tablet), the browser and its language. To count unique visitors without cookies we use a code valid for a single day, calculated from a random key that changes every day, the IP address and the browser type; the IP address itself is not stored, and once the key has changed the code can no longer be linked to a device. When you create an account, we save with it the source of that day’s first visit (for example Google, Facebook or a campaign name) and the first page you viewed.
- Google Analytics (only with your consent)
- – only if you accept the “Analytics” category, Google Analytics 4 (provided by Google Ireland Limited and loaded through Google Tag Manager) collects, through the _ga and _ga_GVPYW6ZXZ7 cookies: a random browser identifier, the pages viewed, the date, time and length of the visit, the referring site and campaign tags, the approximate country and city (derived from the IP address, which Google Analytics 4 does not store), the device type, operating system, browser and language, and events such as creating an account or starting and completing a payment (the plan and the amount). We do not send Google your name, email address, phone number or card details. Google Signals and ad personalisation are turned off, and neither Google Tag Manager nor Google Analytics is loaded on the administration pages. When it loads, Google Tag Manager receives, like any web resource, your IP address and technical browser data. The data may be transferred to the USA under the EU-U.S. Data Privacy Framework and is kept for 14 months. The legal basis is your consent (Art. 6(1)(a) GDPR), which you can withdraw at any time from “Cookie settings”.
We do not use advertising pixels or other third-party advertising tools, we do not build marketing profiles of you and we do not buy data about you from third parties. We measure traffic primarily ourselves, in aggregate and without cookies (“Visit statistics”); Google Analytics runs only if you give your consent.
We do not ask you for special categories of data (for example data about health, religion or political opinions). If the images, videos or texts you upload contain such data, or data about other people, you are responsible for having a legal basis to use them, as provided in the Terms and Conditions.
04Purposes and legal bases of processing
For each purpose we use only the data needed and rely on one of the legal bases provided in Art. 6 GDPR:
| Purpose | Data used | Legal basis |
|---|---|---|
| Creating and managing the account, signing in | Account data, sessions | Performance of the contract (Art. 6(1)(b) GDPR) |
| Generating drafts with AI, editing and regenerating them, picking photos automatically, editing photos | Your content | Performance of the contract |
| Connecting social accounts, publishing and scheduling posts, suggesting publishing times | Connected accounts, approved content, history and scheduling, time zone | Performance of the contract |
| Applying plan limits, the trial period, the subscription, extra packs and collecting payments | Usage and plan, billing and payment data | Performance of the contract |
| Issuing invoices and keeping accounting records | Billing and payment data | Legal obligation (Art. 6(1)(c) GDPR), under tax and accounting law |
| Sending transactional emails about your account: confirming the email address, password reset, notice that the password was changed, a welcome message after confirmation, and invoices after a payment | Account data (name, email address, language), one-time links, invoices (the invoice PDF is attached) | Performance of the contract (Art. 6(1)(b) GDPR); for invoices also the legal obligation (Art. 6(1)(c) GDPR) |
| Security of the Service, prevention of abuse and fraud, diagnosing errors | Technical data, sessions, sign-in security data (failed-attempt counters, locks) | Our legitimate interest in protecting the Service and its users (Art. 6(1)(f) GDPR) |
| Identifying the account and preventing abuse of the free plan (one account per person, per email address and per phone number; the free plan once per social account; no new trial period or free plan period when you sign up again after deleting your account) | Account data (email, phone number, including those of deleted accounts), the trial and free plan end dates of deleted accounts, registry of connected social accounts | Our legitimate interest in offering the free plan fairly and preventing repeated free sign-ups (Art. 6(1)(f) GDPR) |
| Keeping a deleted (deactivated) account so that it can be restored at your request | Account data, your content, post history and scheduling, usage and plan | Our legitimate interest, and yours, in being able to restore the account if you change your mind (Art. 6(1)(f) GDPR); you can ask for permanent erasure at any time (see section 10) |
| Answering custom offer requests | Custom offer requests | Steps taken at your request before entering into a contract (Art. 6(1)(b) GDPR) |
| Account administration by our team and the record of these actions | Account data, log of administrative actions | Legitimate interest in administering the Service properly and being able to show what changes were made |
| Replying to your messages and communications about your account (for example changes to the terms or prices) | Account data, correspondence | Performance of the contract; legitimate interest for messages not related to the contract |
| Establishing, exercising or defending legal claims | The data relevant to the situation in question | Legitimate interest |
| Measuring website traffic in aggregate (visitors, pages viewed, traffic sources, signups by source, including the source saved when an account is created) to improve the website and how we present it | Visit statistics | Our legitimate interest in understanding, in aggregate, how the website is used (Art. 6(1)(f) GDPR); nothing is stored on or read from your device |
| Analysing how the website and the application are used with Google Analytics 4 (pages visited, traffic sources, signups and payments, in aggregate) | The data described under “Google Analytics” | Consent (Art. 6(1)(a) GDPR and Art. 4(5) of Law no. 506/2004), which you can withdraw at any time from “Cookie settings” |
| Other cookies that are not strictly necessary | As described in the Cookie Policy | Consent (Art. 6(1)(a) GDPR and Law no. 506/2004) |
Creating and managing the account, signing in
- Data used
- Account data, sessions
- Legal basis
- Performance of the contract (Art. 6(1)(b) GDPR)
Generating drafts with AI, editing and regenerating them, picking photos automatically, editing photos
- Data used
- Your content
- Legal basis
- Performance of the contract
Connecting social accounts, publishing and scheduling posts, suggesting publishing times
- Data used
- Connected accounts, approved content, history and scheduling, time zone
- Legal basis
- Performance of the contract
Applying plan limits, the trial period, the subscription, extra packs and collecting payments
- Data used
- Usage and plan, billing and payment data
- Legal basis
- Performance of the contract
Issuing invoices and keeping accounting records
- Data used
- Billing and payment data
- Legal basis
- Legal obligation (Art. 6(1)(c) GDPR), under tax and accounting law
Sending transactional emails about your account: confirming the email address, password reset, notice that the password was changed, a welcome message after confirmation, and invoices after a payment
- Data used
- Account data (name, email address, language), one-time links, invoices (the invoice PDF is attached)
- Legal basis
- Performance of the contract (Art. 6(1)(b) GDPR); for invoices also the legal obligation (Art. 6(1)(c) GDPR)
Security of the Service, prevention of abuse and fraud, diagnosing errors
- Data used
- Technical data, sessions, sign-in security data (failed-attempt counters, locks)
- Legal basis
- Our legitimate interest in protecting the Service and its users (Art. 6(1)(f) GDPR)
Identifying the account and preventing abuse of the free plan (one account per person, per email address and per phone number; the free plan once per social account; no new trial period or free plan period when you sign up again after deleting your account)
- Data used
- Account data (email, phone number, including those of deleted accounts), the trial and free plan end dates of deleted accounts, registry of connected social accounts
- Legal basis
- Our legitimate interest in offering the free plan fairly and preventing repeated free sign-ups (Art. 6(1)(f) GDPR)
Keeping a deleted (deactivated) account so that it can be restored at your request
- Data used
- Account data, your content, post history and scheduling, usage and plan
- Legal basis
- Our legitimate interest, and yours, in being able to restore the account if you change your mind (Art. 6(1)(f) GDPR); you can ask for permanent erasure at any time (see section 10)
Answering custom offer requests
- Data used
- Custom offer requests
- Legal basis
- Steps taken at your request before entering into a contract (Art. 6(1)(b) GDPR)
Account administration by our team and the record of these actions
- Data used
- Account data, log of administrative actions
- Legal basis
- Legitimate interest in administering the Service properly and being able to show what changes were made
Replying to your messages and communications about your account (for example changes to the terms or prices)
- Data used
- Account data, correspondence
- Legal basis
- Performance of the contract; legitimate interest for messages not related to the contract
Establishing, exercising or defending legal claims
- Data used
- The data relevant to the situation in question
- Legal basis
- Legitimate interest
Measuring website traffic in aggregate (visitors, pages viewed, traffic sources, signups by source, including the source saved when an account is created) to improve the website and how we present it
- Data used
- Visit statistics
- Legal basis
- Our legitimate interest in understanding, in aggregate, how the website is used (Art. 6(1)(f) GDPR); nothing is stored on or read from your device
Analysing how the website and the application are used with Google Analytics 4 (pages visited, traffic sources, signups and payments, in aggregate)
- Data used
- The data described under “Google Analytics”
- Legal basis
- Consent (Art. 6(1)(a) GDPR and Art. 4(5) of Law no. 506/2004), which you can withdraw at any time from “Cookie settings”
Other cookies that are not strictly necessary
- Data used
- As described in the Cookie Policy
- Legal basis
- Consent (Art. 6(1)(a) GDPR and Law no. 506/2004)
When we rely on legitimate interest, we make sure that it does not override your interests, rights and freedoms, and you can object to the processing (see section 10).
Your account data and content are necessary to use the Service: without them we cannot create your account or generate or publish your posts.
We only send you service (transactional) emails related to your account, listed above, which you cannot unsubscribe from while you have an account, because they are part of the Service. We do not send you newsletters or marketing messages. If we do so in the future, we will ask for your consent where the law requires it.
05Artificial intelligence
To generate drafts, we send to OpenRouter, a service that provides intermediated access to artificial intelligence models, the uploaded images (as encoded files) or, for a video, the still frames taken from it and its duration (never the video file itself), the instruction, the tone, the network the draft is written for and, on regeneration, the current draft and your instructions. For publishing time suggestions, we send the instruction, the drafts, the chosen networks and the time zone. When you upload more photos than a post can take, we send small previews of the photos and the instruction, so that the model can pick the right photos and their order.
OpenRouter passes the request on to the provider of the model used (an AI model developer, which may be based in the USA or in another country), which processes it to produce the response. We do not send them the name, email address or payment data associated with your account.
We do not use your content to train our own artificial intelligence models. How OpenRouter and the model providers retain or use the data they receive is governed by their terms and policies. Where available, we aim to use settings that limit data retention and the use of data for model training.
Photo editing (filters, adjustments, auto enhance) does not use artificial intelligence: it is algorithmic processing carried out on our servers, and photos are not sent to third parties for editing.
Please do not include in images, videos or instructions any information you do not wish to share with these providers, for example sensitive personal data or data about other people without their consent.
06Who we share data with
We do not sell or rent your personal data. We share it only to the extent necessary, with:
- Zernio
- – the service through which social accounts are connected and posts are published or scheduled. It receives the approved content (the text, the images or the video with its cover frame, and the network-specific fields), the scheduled time, the data needed to connect the accounts, and the name, email address and identifier of your theposting.ai account, used for your Zernio profile. Zernio acts on our behalf, as a service provider (processor).
- OpenRouter and the AI model providers
- – receive the data described in section 5, in order to generate drafts and publishing time suggestions.
- Stripe
- – processes payments, manages subscriptions and payment methods and provides the subscription management portal. When the customer profile is created, we send it your name, email address and user identifier, while you enter your card details and billing address directly with Stripe. We issue the tax invoices ourselves. For some processing, such as fraud prevention or its own legal obligations, Stripe may act as an independent controller, under its own privacy policy.
- Google Ireland Limited
- – the provider of Google Analytics 4 and of Google Tag Manager, which loads it (Gordon House, Barrow Street, Dublin 4, Ireland), only if you have accepted the “Analytics” category. It acts as a processor under Google’s data processing terms; the data may also be processed by Google LLC (USA) and its sub-processors (see section 7).
- The hosting provider
- – Hetzner Online GmbH, which hosts the application servers and the database, in Germany.
- Cloudflare
- – Cloudflare, Inc. stores, in private storage (Cloudflare R2), the uploaded images and videos, the extracted frames and the edited copies of photos. In addition, every request to the website passes through Cloudflare (delivery network, attack protection and HTTPS encryption), so Cloudflare processes the IP address and technical data of requests and tells us the country a visit comes from. Cloudflare acts as a processor, under its data processing terms.
- Resend
- – the service through which we send transactional emails (the email address confirmation and password reset links, the notice that your password was changed, the welcome message and invoices). It receives your email address and the content of each email, which may include your name, a one-time link and, for invoice emails, the invoice as a PDF, and it records delivery data (for example whether the email was delivered or bounced). Resend acts on our behalf, as a processor, under its data processing terms.
- Social networks
- – when you publish, the post and its images or video reach the networks you have chosen (for example X, LinkedIn, Facebook or Instagram), where they become visible according to your account settings. The networks process this data as independent controllers, under their own policies.
- Advisers and authorities
- – our accountant and advisers, to the extent necessary for tax and accounting obligations or for defending our rights, as well as public authorities, where the law requires us to.
- Successors
- – in the event of a reorganisation, merger or sale of the business, data may be transferred to the new controller, which will have to comply with this policy or inform you of any changes.
We share with providers acting on our behalf only the data needed for the service they provide, under contracts that require them to protect it and to use it only in accordance with our instructions.
07Transfers outside the European Economic Area
Some of our providers (for example Stripe, Cloudflare, Google, Resend, OpenRouter, the AI model providers and, where applicable, Zernio) are based or process data outside the European Economic Area (EEA), in particular in the United States of America.
Where data is transferred to a country for which the European Commission has not adopted an adequacy decision, the transfer is based on the safeguards provided by the GDPR, usually the standard contractual clauses adopted by the European Commission. For recipients in the USA certified under the EU-U.S. Data Privacy Framework, the transfer may rely on the adequacy decision for that framework.
These safeguards are those offered by the providers through their contracts and data processing documents. You can request information about the safeguards applicable to a specific transfer at [email protected].
When you publish on a social network, the data is sent to that network at your request, in order to perform the service you have requested.
08How long we keep data
| Data | Retention period |
|---|---|
| Account data, connected accounts, time zone, usage and plan, billing details from your account page, signup source | For as long as the account is active. After you delete the account, it is deactivated and this data is kept, inaccessible to you, for as long as the account can be restored, until you ask us to erase it permanently (we may also delete or anonymise deactivated accounts at a later date); permanent erasure is carried out within 30 days of your request |
| Images, videos (including extracted frames and edited copies), instructions, drafts and post history | Until you delete them; if you delete the account, they are kept deactivated together with the account data, as above, and are erased within 30 days of a request for permanent erasure |
| Sign-in sessions | Until you sign out or until they expire (30 days); expired sessions are deleted periodically, and all sessions are deleted when you delete the account |
| One-time links (email confirmation, password reset) | Valid until used or until they expire (48 hours / 60 minutes); kept at most until the account is permanently erased, with expired links deleted progressively, typically 7 days after they expire |
| Sign-in attempt counters and locks | Up to 2 days after the last attempt (a lock lasts at most 24 hours) |
| Invoices and accounting records (invoices, payments) | 10 years from the end of the financial year in which they were prepared, under Accounting Law no. 82/1991; kept after the account is deleted and after permanent erasure (then without the link to your account), with the buyer details shown on the invoice. The proof of the right-of-withdrawal confirmations is kept together with the payment records |
| Log of administrative actions | For as long as the account exists, including while it is deactivated; when the account is permanently erased, the records about it are deleted too |
| Registry of connected social accounts | For as long as the Service is offered, as it is needed to prevent abuse of the free plan; after the account is permanently erased only the network, the social account identifier and username, the dates and the hash of the email address are kept (no name, email or phone number) |
| Custom offer requests | Until the request is answered and then for 3 years at most |
| Correspondence | For as long as needed to resolve the request and then for 3 years at most, for any clarifications or claims |
| Emails sent through Resend (delivery records) | According to Resend’s retention periods for sending logs; we do not keep copies of the emails, other than the invoices themselves |
| Technical server logs | 90 days at most |
| Visit statistics | 25 months at most, then deleted automatically (the daily visitor code can no longer be linked to a device once its day is over) |
| Google Analytics | Event-level data: 14 months at most, then deleted automatically by Google. The _ga and _ga_GVPYW6ZXZ7 cookies expire after 2 years at most and are deleted when you withdraw your consent |
| Cookies | According to the durations in the Cookie Policy |
Account data, connected accounts, time zone, usage and plan, billing details from your account page, signup source
- Retention period
- For as long as the account is active. After you delete the account, it is deactivated and this data is kept, inaccessible to you, for as long as the account can be restored, until you ask us to erase it permanently (we may also delete or anonymise deactivated accounts at a later date); permanent erasure is carried out within 30 days of your request
Images, videos (including extracted frames and edited copies), instructions, drafts and post history
- Retention period
- Until you delete them; if you delete the account, they are kept deactivated together with the account data, as above, and are erased within 30 days of a request for permanent erasure
Sign-in sessions
- Retention period
- Until you sign out or until they expire (30 days); expired sessions are deleted periodically, and all sessions are deleted when you delete the account
One-time links (email confirmation, password reset)
- Retention period
- Valid until used or until they expire (48 hours / 60 minutes); kept at most until the account is permanently erased, with expired links deleted progressively, typically 7 days after they expire
Sign-in attempt counters and locks
- Retention period
- Up to 2 days after the last attempt (a lock lasts at most 24 hours)
Invoices and accounting records (invoices, payments)
- Retention period
- 10 years from the end of the financial year in which they were prepared, under Accounting Law no. 82/1991; kept after the account is deleted and after permanent erasure (then without the link to your account), with the buyer details shown on the invoice. The proof of the right-of-withdrawal confirmations is kept together with the payment records
Log of administrative actions
- Retention period
- For as long as the account exists, including while it is deactivated; when the account is permanently erased, the records about it are deleted too
Registry of connected social accounts
- Retention period
- For as long as the Service is offered, as it is needed to prevent abuse of the free plan; after the account is permanently erased only the network, the social account identifier and username, the dates and the hash of the email address are kept (no name, email or phone number)
Custom offer requests
- Retention period
- Until the request is answered and then for 3 years at most
Correspondence
- Retention period
- For as long as needed to resolve the request and then for 3 years at most, for any clarifications or claims
Emails sent through Resend (delivery records)
- Retention period
- According to Resend’s retention periods for sending logs; we do not keep copies of the emails, other than the invoices themselves
Technical server logs
- Retention period
- 90 days at most
Visit statistics
- Retention period
- 25 months at most, then deleted automatically (the daily visitor code can no longer be linked to a device once its day is over)
Google Analytics
- Retention period
- Event-level data: 14 months at most, then deleted automatically by Google. The _ga and _ga_GVPYW6ZXZ7 cookies expire after 2 years at most and are deleted when you withdraw your consent
Cookies
- Retention period
- According to the durations in the Cookie Policy
Backups may retain deleted data for a short period, until they are overwritten in their normal cycle; during this time we do not use them for any other purpose.
We may keep certain data for longer only if the law requires us to or if it is necessary for establishing, exercising or defending legal claims, and only for as long as necessary.
Posts already published on social networks are not automatically deleted together with your account; you can delete them directly on each network. Data kept by Zernio, Stripe or the social networks is also subject to the periods they set.
09Data security
We use technical and organisational measures appropriate to the risks, including:
- communication between your browser and the Service is encrypted (HTTPS);
- passwords are stored only as a salted hash (bcrypt), and sessions only as a cryptographic fingerprint;
- the session cookie cannot be read by scripts on the page (HttpOnly);
- sign-in attempts are limited (temporary lock after repeated failures), and the answers to sign-in and password reset requests do not reveal whether an account exists for an email address;
- password reset and email confirmation links are single-use, expire and are stored only as a cryptographic fingerprint; after a password reset you are signed out on all devices and we notify you by email;
- each user has access only to their own posts and media, and uploaded images and videos are stored privately and are not public: they are shown only through the application, after your account is checked;
- communication with our providers (Stripe, Zernio, OpenRouter, Cloudflare, Resend) is encrypted;
- administration features are available only to administrator accounts, and their actions are recorded;
- social accounts are connected through the networks’ official mechanisms, without us receiving their passwords;
- card details are processed exclusively by Stripe.
No system is completely secure. If we become aware of a personal data breach that may affect your rights, we will notify ANSPDCP (Romania’s National Supervisory Authority for Personal Data Processing) and, where the law requires it, inform you without undue delay.
You also contribute to security: use a unique, strong password and let us know if you suspect unauthorised access to your account.
10Your rights
Under the GDPR, you have the following rights:
- Right of access
- – you can find out whether we process data about you and receive a copy of it, together with the information in this policy.
- Right to rectification
- – you can ask for inaccurate data to be corrected or incomplete data to be completed.
- Right to erasure
- – you can ask for your data to be deleted, for example when it is no longer necessary or you withdraw your consent, except for data the law requires us to keep (such as invoices). For your account, this means its permanent erasure, described below.
- Right to restriction
- – you can ask us to restrict processing, for example while we verify the accuracy of the data or an objection you have raised.
- Right to data portability
- – you can receive the data you have provided to us and that we process by automated means on the basis of the contract or consent, in a structured, commonly used and machine-readable format, or ask for it to be transmitted to another controller, where technically feasible.
- Right to object
- – you can object at any time, on grounds relating to your particular situation, to processing based on our legitimate interest. We will stop the processing unless we have compelling legitimate grounds or the data is necessary for defending legal claims.
- Right to withdraw consent
- – where processing is based on consent (for example cookies that are not strictly necessary), you can withdraw it at any time, as easily as you gave it, without affecting the lawfulness of processing carried out before the withdrawal. For cookies, use the “Cookie settings” link in the page footer.
- Rights relating to automated decisions
- – you have the right not to be subject to a decision based solely on automated processing which produces legal effects concerning you or similarly significantly affects you (see section 14).
You can do many of these things directly in the application: you can edit or delete posts, download your photos and videos, disconnect social accounts, update your billing details and manage your subscription from the billing page. You can also delete your account yourself, from the Account page.
Deleting your account. You can delete your account from the Account page (by confirming with the account’s email address) or by writing to us. Deletion deactivates the account immediately: you are signed out on all devices, scheduled publications are cancelled, your social accounts are disconnected from Zernio and any subscription is cancelled. Your data is not erased at that point: account data, images and videos, drafts and post history are kept, inaccessible to you, so that the account can be restored at your request and to prevent abuse of the free offer (see sections 4 and 8).
Signing up again. If you sign up again with the same email address or phone number, a new, empty account is created. We use the email address and phone number to find the deleted account and carry over to the new account the end dates of its trial period and free plan period, so that deleting an account and signing up again does not give a new free trial or a new free plan period. The legal basis is our legitimate interest in preventing abuse of the free offer (Art. 6(1)(f) GDPR).
Restoring the account. To have a deleted account restored, write to us at [email protected] from that account’s email address. If you have signed up again in the meantime, the previous content is moved into the new account, while the billing records stay attached to the old account, for accounting.
Permanent erasure. You can ask for the permanent erasure of your account and data at any time, before or after deleting the account, by writing to us at [email protected] from the account’s email address. We carry it out within 30 days of the request; after that the account can no longer be restored. Only the following are kept after permanent erasure: invoices and accounting records, for 10 years (Accounting Law no. 82/1991), without the link to your account; the proof of the right-of-withdrawal confirmations, with the billing records; backups, until they are overwritten in their normal cycle; and the registry of connected social accounts, which keeps only a hash of the email address (see section 8).
11How to exercise your rights
Send us a request at [email protected], preferably from the email address associated with your account, and specify which right you wish to exercise.
We will reply without undue delay and within one month of receiving the request at the latest. This period may be extended by two further months for complex or numerous requests, in which case we will inform you within the first month.
Exercising your rights is free of charge. If requests are manifestly unfounded or excessive, in particular because of their repetitive character, we may charge a reasonable fee or refuse to act on them, explaining the reason to you.
To protect your data, we may ask you for additional information to confirm your identity before acting on the request.
12Complaints to the supervisory authority
If you believe that the processing of your data infringes the law, you have the right to lodge a complaint with the National Supervisory Authority for Personal Data Processing (ANSPDCP), www.dataprotection.ro, or with the supervisory authority in the Member State of your habitual residence, place of work or place of the alleged infringement.
We encourage you to write to us first at [email protected], so that we can try to resolve the situation together. You may also bring the matter before the competent court.
13Minors
The Service is intended for people aged at least 18, in accordance with the Terms and Conditions. We do not knowingly collect data about minors.
If you become aware that a minor has provided us with personal data, write to us at [email protected] and we will delete it.
If you upload images or videos showing minors, you are responsible for having the consent of their parents or legal representatives, as provided in the Terms and Conditions.
14Automated decisions
Drafts and publishing time suggestions are generated automatically, with the help of artificial intelligence, but they are only proposals. You review them and can edit or reject them, and nothing is published without your explicit approval.
We do not make decisions based solely on automated processing, including profiling, which produce legal effects concerning you or similarly significantly affect you, within the meaning of Art. 22 GDPR.
Plan limits (for example the number of posts per month) are applied automatically, according to the plan you have chosen and the conditions shown at purchase.
16Changes to this policy
We may update this policy when the Service, our providers or the law change. The date of the last update is shown at the top of the document.
If the changes are significant, we will inform you in advance, by email or through a notification in the Service.
This policy is available in Romanian, English and Italian. The Romanian version is the reference version.
17Contact
For any question about this policy or about your personal data, you can contact us:
- Email: [email protected]
- Postal address: INSPIRING RESEARCH & INVENTIVE SOLUTIONS S.R.L., Str. Lt. Radu Beller, nr. 3-5, Sector 1, București
We will reply as soon as possible.