Privacy Policy

Last updated: 05/03/2026

Welcome to SPECULA.VISION! Your privacy is of utmost importance to us. This Privacy Policy outlines how PAX GLOBAL S.R.L. ("we," "us," or "our") collects, uses, and protects your personal data when you use our platform, SPECULA.VISION and engage with our services. By accessing or using our services, you agree to this document.

1. Data Collection and Processing

SPECULA.VISION collects and processes personal data to deliver services, comply with legal obligations, and enhance your experience. All data processing is conducted in compliance with the General Data Protection Regulation (GDPR), specifically under Article 6(1) a, b, f. We adhere to the principle of "privacy by design", ensuring that data protection considerations are integrated into the development and operation of our services from the outset. We apply measures in accordance to the data minimization principle, and only collect essential personal data.


We process:

  • Account Data: Your name, email address, payment details and contact information provided during registration or subscription.
  • Content Data: Files (images, videos, or other formats) or any form of data uploaded to the platform.
  • Telemetry Data (Technical Data): IP addresses, browser types, device data, activity logs, geolocation, web requests and cookie identifiers (see cookie policy). This data is used for analytics, performance monitoring, internal optimization, and cybersecurity hardening.

Data collected is explicitly provided by users when interacting with the services and is solely used to deliver and optimize the services. We do not sell, rent, or share user data with service providers or third parties for marketing, advertising, reselling, or profiling purposes. Telemetry tools may collect additional non-identifiable information, exclusively for internal analysis and optimization. If, at any time, Users want to stop the processing of private information, they must refrain from using the services, as the processing is an automated process and cannot be turned off per user request.

SPECULA.VISION does not use AI to handle your private information (or any other information) and does not use your data to train AI. All decisions (including the ones impacting our customers) are taken by humans. However, we are unable to provide this guarantee regarding parties which we chose to integrate with, in order to provide the services.


2. Data Transmission, Storage and Security

SPECULA.VISION utilizes dedicated servers located in secure facilities across the European Union to provide the services. User data is stored on these servers. Your data will never leave these servers unless it is required for security or legal purposes or for interaction with other services which are essential for the functionality of SPECULA.VISION


We employ robust encryption protocols, including SSL/TLS for data transmission and AES for secure storage. Data is encrypted in transit and at rest. While every effort is made to protect your data, no system can be completely secure. By using our platform, you acknowledge this inherent risk. We continuously assess and address risks associated with various types of data breaches, including unauthorized access, accidental loss, data corruption, and unauthorized modification, to minimize their potential impact on your personal data.

Below, a subset of measures or topics which are on our radar:

  • Clear Policies
  • Physical Security
  • Strict Access Controls
  • Multi Layered Firewall
  • Incident Response Procedures
  • Dedicated Support Channel
  • Confidentiality Agreements
  • Source Code Analysis
  • Log Processing


Measures for Reducing Data Impact (Log Processing):

To further reduce the impact of data processing, particularly concerning logs:

  • Random Processing: Log processing for prevention purposes is conducted at least once a month and the data subject whose data is processed is chosen randomly.
  • Limited Scope for Remediation: Log processing performed as a result of a technical issue or cyberattack is strictly limited in scope to only the data necessary for remediation or identifying the root cause.
  • Restricted Access to Logs: Access to logs is strictly restricted to authorized personnel.

3. Data Recipients

The recipients of your data include:

  • Hosting service provider (Hetzner Online GmbH)
  • Proxy service provider (Cloudflare Inc.)
  • Mailing service provider (Mailgun, Sinch AB)
  • Accounting service provider (Digital Keez SRL)
  • Banking institution (REVOLUT BANK UAB VILNIUS SUCURSALA BUCURESTI)
  • Business collaborators (as necessary for service delivery)
  • Competent authorities (as required by law)

4. Data Retention Periods

Personal data is retained only as long as necessary to provide services, comply with legal obligations, or resolve disputes. Specific retention periods are as follows:

  • Accounting Operations Data: Stored for a period of 5 years (required by Romanian law).
  • Technical Operations Data (Specific): Stored for a maximum period of 1 year for: User account and associated details, device IP, logs, geolocation, IP address, web requests, cookie identifiers (for login and authorization), and contact data.
  • Other Technical Operations Data: Stored for a determined period according with the type of data.
  • Service Provision, Banking, and Customer Details Data: Stored for a period of 3 years.

When an account is deleted, we permanently remove all associated content and data from our servers, unless legally required or we have a legitimate interest to retain it.


5. International Data Transfer

Data processed may be transferred to other countries to the extent that such transfer is necessary to ensure the availability and provision of the services. We ensure that any such transfers comply with GDPR requirements by only choosing providers with trusted reputation.


6. Your Rights

As a data subject, you have a series of rights under Regulation (EU) 2016/679 (GDPR), designed to give you control over your personal data. We are committed to facilitating the exercise of these rights and responding to requests in a reasonable timeframe, generally within one month of receiving the request.


These rights include:

  • The Right to Information (Articles 13 & 14 GDPR): The right to be informed about the collection and use of your personal data.
  • The Right of Access (Article 15 GDPR): The right to obtain confirmation that your data is being processed and to access that data.
  • The Right to Rectification (Article 16 GDPR): The right to have inaccurate or incomplete personal data corrected without undue delay.
  • The Right to Erasure ("Right to be Forgotten") (Article 17 GDPR): The right to request the deletion or removal of your personal data where there is no compelling reason for its continued processing.
  • The Right to Restriction of Processing (Article 18 GDPR): The right to limit the way we use your data.
  • The Right to Data Portability (Article 20 GDPR): The right to receive your personal data in a structured, commonly used, and machine-readable format and to transmit that data to another controller.
  • The Right to Object (Article 21 GDPR): The right to object to processing based on legitimate interests or the performance of a task in the public interest/exercise of official authority, and direct marketing.
  • The Right Not to Be Subject to Automated Individual Decision-Making (Article 22 GDPR): The right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.

For a detailed list of your rights, refer to the full text of the GDPR legislation.


Should you believe your rights have not been respected or that your data is being processed contrary to GDPR provisions, you have the right to lodge a complaint with the National Supervisory Authority for Personal Data Processing (ANSPDCP) in Romania.


ANSPDCP Contact Details:

Address: B-dul G-ral. Gheorghe Magheru nr. 28-30, Sector 1, 010336, Bucharest, Romania

Phone: +40.31.805.9211 Fax: +40.31.805.9602

Email: [email protected]

Website: www.dataprotection.ro


7. Policy Updates

This Privacy Policy may be updated periodically to reflect changes in our practices or legal requirements. Continued use of our services constitutes acceptance of any revised terms.


8. Contact

If you have any questions, concerns, or wish to exercise your rights regarding your personal data, please contact our Data Protection Officer (DPO) at [email protected]