Privacy Policy

1. Who is responsible for your data

AI Fluent is operated by Florin Cusmereanu, a sole trader based in Romania, EU. Florin Cusmereanu is the data controller for the personal data described here.

Contact for any privacy question or request: florin@aifluent.ai.

No Data Protection Officer is appointed. GDPR Article 37 requires one only for public authorities, for organisations whose core activity is large-scale systematic monitoring, and for organisations processing special-category data at large scale. None of these apply. Privacy requests go to the address above and are handled by Florin directly.

2. What we collect and why

Contact form

Name, email address, company, and the message you write. Used to answer your enquiry and follow up on it. Lawful basis: legitimate interest in responding to people who contact us about our services (GDPR Article 6(1)(f)).

Assessment tools (AIMS, PACE, ACTS, ORBIT)

Your answers, the score they produce, and the email address you enter to receive the report. Used to generate and send your report. Lawful basis: performance of a request you made (GDPR Article 6(1)(b)).

Newsletter

Your email address. Used to send the newsletter. Lawful basis: consent (GDPR Article 6(1)(a)). Subscribing is separate from receiving an assessment report. You get the report either way.

Booking a call

Handled by Google Calendar Appointment Scheduling. The details you enter go to Google and to us. Lawful basis: performance of a request you made.

How you found us

On your first visit your browser stores, locally, the campaign parameters in the link you arrived through, the site that referred you, and the first page you landed on. It stays on your device and is sent to us only if you later submit one of our forms, attached to that submission. It is not a cookie, it identifies no one on its own, and clearing your browser storage removes it. Lawful basis: legitimate interest in knowing which channels bring people here (GDPR Article 6(1)(f)).

Booking-button clicks

When you click a “Book a discovery call” button we record which button it was, the time, and a one-way hash of your IP address. No cookie is set and no new identifier is created. If you have already given us your email through one of the tools, the click is linked to that record. Lawful basis: legitimate interest in knowing which parts of the site lead to conversations (GDPR Article 6(1)(f)).

Analytics

Google Analytics 4, loaded through Google Tag Manager. Collects page views, events, approximate location at city level, device and browser type. Lawful basis: consent (GDPR Article 6(1)(a)). Nothing is collected until you allow analytics in the cookie banner. See the Cookie Policy.

Technical logs

Our hosting and rate-limiting providers record IP addresses and request metadata to keep the site available and to block abuse. Lawful basis: legitimate interest in security and availability (GDPR Article 6(1)(f)).

We do not sell personal data. We do not profile you, and no decision about you is made by automated means.

3. How long we keep it

Where no statutory period applies, these periods are our own choice, set to the shortest span that still lets us run the business. You can ask for earlier deletion at any time.

4. Who processes data on our behalf

Each acts as a processor under a data processing agreement and may only use the data to provide its service to us.

5. Transfers outside the EEA

Some of the processors above are established in the United States, so your data can be processed outside the European Economic Area. Those transfers rely on the EU-US Data Privacy Framework where the recipient is certified under it, and otherwise on the European Commission's Standard Contractual Clauses. You can ask us which mechanism applies to a specific processor and we will tell you.

6. Your rights

Under the GDPR you have the right to:

• access the personal data we hold about you, and get a copy
• have inaccurate or incomplete data corrected
• have your data erased, unless we are required to keep it
• restrict how we process your data while a dispute is resolved
• receive your data in a structured, machine-readable format, and have it sent to another provider
• object to processing based on legitimate interest, and to object to direct marketing at any time
• withdraw consent at any time, where consent is the basis we rely on

To use any of these, email florin@aifluent.ai. We reply within 1 month. If the request is complex we may extend by up to 2 further months and will tell you inside the first month if that happens. Exercising these rights is free.

Withdrawing consent does not affect processing that already happened lawfully before you withdrew it. To withdraw newsletter consent, use the unsubscribe link in any newsletter email or write to us. To withdraw analytics consent, see the Cookie Policy.

7. Complaints

If you think we have handled your data badly, tell us first at florin@aifluent.ai and we will try to fix it.

You also have the right to complain to a supervisory authority. In Romania that is the Autoritatea Naţională de Supraveghere a Prelucrării Datelor cu Caracter Personal (ANSPDCP), dataprotection.ro. You can also complain to the supervisory authority in the EU country where you live or work, or where you believe the problem occurred.

8. Security

Data is stored with the processors listed above. Assessment reports are held in private storage, not public buckets. Access to production data is kept to the minimum number of people needed to run the site. No system is perfectly secure, and we do not claim otherwise.

9. Changes

This is version 1.0. A lawyer-revised version replaces it after launch. When we make a material change we update the version and effective date at the top of this page, and tell newsletter subscribers.