1. Who we are
Coltan Holding (hereinafter referred to as "Coltan Holding", "we", "us", "our"), operated by Tudor Coltan – Cabinet de Avocat, CIF 33847320, having its registered office at Bd. Mircea Eliade nr. 16B, "One Mircea Eliade" complex, T2, Ap. 9-3, Sector 1, Bucharest, Romania, is the data controller responsible for the personal data processed in connection with the website coltanholding.com (hereinafter referred to as the "Website").
This Privacy Policy explains what personal data we collect, why we collect it, how we use it, and the rights you have under Regulation (EU) 2016/679 (hereinafter referred to as "GDPR") and applicable Romanian law.
2. Scope of this Policy
This Policy applies to personal data we process:
- when you browse the Website and, where you consent, through analytics cookies;
- when you submit an enquiry or booking request through our contact/booking form;
- when you communicate with us through the live chat widget (hereinafter referred to as "Airo Inbox") embedded on the Website.
For details on the specific cookies we use, please see our Cookie Policy.
3. Personal data we collect
3.1 Data you provide directly
- Contact / booking form: full name, email address, organisation (optional), selected area of interest, and the content of your message, together with any other information you choose to include (e.g. phone number, preferred date/time for a consultation).
- Live chat (Airo Inbox): the content of the messages you exchange with us through the chat widget. Because the chat is free-text, we do not control in advance what you choose to type; it may include your name, contact details, or other information you voluntarily provide. We only process what you actually submit through the chat.
3.2 Data collected automatically
- Usage/analytics data, collected only after you give consent through the cookie banner: pages visited, referral source, approximate location at city/country level, device and browser type, and session duration, via Google Analytics (GA4).
We do not knowingly collect special categories of personal data (e.g. data concerning health, religion, or political opinions) through the Website, and we ask that you do not include such information in the contact form or chat.
4. Purposes and legal basis for processing
| Purpose | Legal basis (GDPR Art. 6) |
|---|---|
| Responding to enquiries submitted via the contact form and scheduling consultations | Art. 6(1)(b) – steps taken at your request prior to entering into a contract, or Art. 6(1)(f) – our legitimate interest in handling business enquiries where no contract is contemplated |
| Operating the live chat and responding to messages | Art. 6(1)(f) – legitimate interest in communicating with visitors who initiate contact |
| Website analytics (Google Analytics) | Art. 6(1)(a) – your consent, given via the cookie banner |
| Complying with legal, accounting, and tax obligations | Art. 6(1)(c) – compliance with a legal obligation |
5. Recipients of personal data
We do not sell, rent, or trade your personal data. We may share personal data, to the extent strictly necessary, with the following categories of recipients:
- our analytics provider, Google LLC / Google Ireland Limited, as provider of Google Analytics (GA4);
- our live chat / messaging service provider, which processes messages exchanged through the chat widget on our behalf;
- our website hosting provider, which stores the technical infrastructure of the Website;
- professional advisers (e.g. accountants, IT providers) bound by confidentiality obligations, where necessary for the operation of our business;
- public authorities, where required by law.
6. International data transfers
Where a service provider processes personal data outside the European Economic Area (for example, Google), the transfer is carried out on the basis of an adequacy decision or appropriate safeguards, such as the European Commission's Standard Contractual Clauses.
7. Data retention
- Contact / booking enquiries: retained only for as long as necessary to respond to and resolve your enquiry. Once your enquiry has been dealt with and no further follow-up is expected, the data is deleted, unless a client relationship is subsequently established, in which case the statutory retention periods applicable to accounting and legal records under Romanian law apply instead.
- Live chat conversations: retained only for as long as necessary to handle and respond to the conversation, and deleted once it has been resolved and no further follow-up is expected.
- Analytics data: retained for 14 months within Google Analytics, in line with Google's default retention setting.
We do not retain personal data collected through the form or chat for longer than necessary for the purpose for which it was provided, unless a longer period is required or permitted by law.
8. Your rights under the GDPR
In relation to your personal data, you have the right to:
- Access — obtain confirmation of, and access to, the personal data we hold about you.
- Rectification — request correction of inaccurate or incomplete data.
- Erasure — request deletion of your data ("right to be forgotten"), where applicable.
- Restriction — request that we limit the processing of your data in certain circumstances.
- Objection — object to processing based on our legitimate interest.
- Data portability — receive your data in a structured, commonly used format, where technically feasible.
- Withdraw consent — withdraw consent at any time (e.g. via the cookie banner), without affecting the lawfulness of processing carried out before withdrawal.
- Lodge a complaint — with the Romanian National Supervisory Authority for Personal Data Processing (ANSPDCP), www.dataprotection.ro, or with the supervisory authority of your habitual residence.
To exercise any of these rights, please contact us using the details in Section 13 below.
9. Cookies
The Website uses cookies, including analytics and functional cookies placed only with your consent.
Full details are available in our Cookie Policy.
10. Security
We implement appropriate technical and organisational measures to protect personal data against unauthorised access, alteration, disclosure, or loss, including transmission of the Website over HTTPS. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.
11. Children
The Website is not directed at, and we do not knowingly collect personal data from, individuals under the age of 16. If you believe a child has provided us with personal data, please contact us so that we can take appropriate action.
12. Changes to this Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices or for legal or operational reasons. The "Last updated" date at the top of this page indicates when it was last revised.
13. Contact
For any privacy-related questions or to exercise your rights, please contact us at [email protected], or by post at:
Tudor Coltan – Cabinet de Avocat (CIF 33847320)Bd. Mircea Eliade nr. 16B, "One Mircea Eliade" complex, T2, Ap. 9-3
Sector 1, Bucharest, Romania