Privacy statement

1. Who is responsible for your data

The data controller is Archetypal Coherence Matrix (ACM Framework), a service operated by MEDIA KSW Limited Liability Company, IDNO 1016600037745, with its registered office at MD-6812, Chisinau municipality, Bacioi village, 6 Europa Boulevard, Republic of Moldova. For data uploaded to the platform by a brand (for example, the client list for a survey), the brand is the controller, and ACM processes the data on its behalf, under the Data processing agreement.

2. What data we process

• Account: name, email, role and the brands you have access to.
• Brand: name, industry, website, perspectives, decisions and uploaded materials.
• Survey respondents: responses, language and the demographic data they choose; the public survey is anonymous.
• Payment: plan, invoices and payment confirmations.
• Where you came from: when the account is created, once only, the campaign parameters (UTM), the site you came from (without the exact page address), the landing page and the time of the first visit.
• Use of the site: the pages visited and the device, through cookies, only with your consent when they are not necessary.

3. Why and on what legal basis

• To provide the Service to you: performance of the contract.
• To protect and improve it: our legitimate interest.
• For analytics and advertising: your consent, which you can withdraw at any time.
• For invoicing and accounting: legal obligation.

4. How long we keep data

For as long as you have an account and as long as is necessary for the purpose for which we collected the data. A deleted account can be restored for 30 days, after which it is deleted automatically. A deleted brand can be restored for 30 days, after which its data are deleted. Invoices are kept for as long as accounting law requires.

Backups on our server are deleted automatically after 7–30 days. An encrypted backup is also kept off the server (Backblaze B2), where it cannot be deleted from the server. If a backup is ever restored, accounts and brands deleted in the meantime are deleted again.

5. Who we share data with

We do not sell data. We share it only with the partners who help us run the Service (hosting, database, email, analytics, artificial intelligence, password checking), named in the Processors list, and with the authorities when the law requires it.

6. Transfers outside your country

Some partners process data in other countries. We only use partners that offer appropriate safeguards, for example the standard contractual clauses approved by the European Commission.

7. Your rights

You have the right of access, rectification, erasure, restriction, portability and objection, plus the right to withdraw your consent. You exercise them by writing to us at ajutor@acmframework.com; we reply within 30 days at most.

You may lodge a complaint with the National Centre for Personal Data Protection (NCPDP) of the Republic of Moldova or with the data protection authority in your country. pending lawyer confirmation: the competent authority

8. Children

The Service is not intended for children under 16, and we do not knowingly collect their data.

9. Data security

Data travel encrypted, access is limited by role, and every administrative access is logged. No system is perfectly secure; if a breach occurs that affects you, we will notify you without delay.

10. Changes to the statement

When the statement changes, we update the date at the top and, for important changes, we notify you in the platform or by email.

11. Contact

For any questions about your data, write to us at ajutor@acmframework.com.