1/ Who We Are
This Privacy Policy explains how ATHENE CONSULTANCY S.R.L. (“ATHENE CONSULTANCY”, “we”, “us” or “our”) processes personal data when you visit our website, contact us, apply for a position or engage with us in connection with our services.
The controller responsible for your personal data is:
ATHENE CONSULTANCY S.R.L.
Registered office: Municipiul Satu Mare, Str. Miron Costin, Nr. 15A, Județ Satu Mare, Romania
Trade Register number: J2026048992006
Unique Registration Code (CUI): 55398109
EUID: ROONRC.J2026048992006
Email: athene@atheneworld.com
Telephone: +40 723 240 825
For the purposes of applicable data protection legislation, including Regulation (EU) 2016/679 (the General Data Protection Regulation or “GDPR”) and Romanian Law No. 190/2018, ATHENE CONSULTANCY S.R.L. is the data controller for the personal data described in this Privacy Policy.
2/ What Personal Data We Collect
We aim to collect only personal data that is necessary for the purposes described in this Privacy Policy.
Website visitors
When you visit our website, our hosting and security infrastructure may automatically process certain technical information necessary to deliver, maintain and secure the website. This may include:
- IP address;
- browser and device information;
- requested pages or resources;
- date and time of requests; and
- technical information contained in server logs.
Our website does not use advertising trackers, behavioural advertising or analytics tools.
When you contact us
If you contact us by email or another communication method we make available, we may process:
- your name;
- your email address and other contact details;
- the contents of your message; and
- any other personal data that you voluntarily provide.
Please do not send sensitive or unnecessary personal information unless it is relevant to your enquiry.
Clients and prospective clients
If you are an existing or prospective client, we may process contact, identification and business information that you provide to us, together with information necessary to discuss, establish or perform a business relationship with you.
Job applicants
If you apply for a position with ATHENE CONSULTANCY, we may process information contained in your application and CV, including your name, contact details, employment history, education, qualifications, skills, professional experience and other information that you choose to provide.
We process recruitment information only to assess applications, communicate with candidates, arrange interviews and, where applicable, take steps towards entering into an employment or other working relationship.
Please do not provide sensitive personal data that is not relevant to your application.
3/ How and Why We Use Personal Data
We process personal data only where we have a lawful basis to do so.
Website operation and security
We process technical information, including IP addresses and server logs, where necessary to operate, maintain and secure our website and to prevent or investigate misuse.
Legal basis: Article 6(1)(f) GDPR — our legitimate interest in operating a reliable and secure website.
Responding to enquiries
We process information provided when you contact us so that we can respond to your enquiry, provide information you request and, where appropriate, take steps at your request before entering into a contract.
Legal basis: Article 6(1)(b) GDPR where processing is necessary to take steps at your request before entering into a contract, and/or Article 6(1)(f) GDPR where we have a legitimate interest in responding to and managing business enquiries.
Providing our services
Where you engage us as a client, we process personal data necessary to provide our services, administer our relationship with you and perform our contractual obligations.
Legal basis: Article 6(1)(b) GDPR — processing necessary for the performance of a contract.
Recruitment
Where you apply for a position with us, we process application and recruitment information to assess your suitability, communicate with you during the recruitment process and take steps at your request before entering into an employment or other working relationship.
Legal basis: Article 6(1)(b) GDPR where processing is necessary to take steps at the request of the applicant before entering into a contract, and/or Article 6(1)(f) GDPR where we have a legitimate interest in managing our recruitment process.
Where processing of particular information is required by applicable law, the relevant legal obligation may also constitute the legal basis under Article 6(1)(c) GDPR.
Legal, tax and accounting obligations
We may process personal data where necessary to comply with applicable legal, tax, accounting, regulatory or other statutory obligations.
Legal basis: Article 6(1)(c) GDPR.
Legal claims and protection of our rights
We may process personal data where necessary to establish, exercise or defend legal claims or to protect our legal rights and legitimate business interests.
Legal basis: Article 6(1)(f) GDPR — our legitimate interest in protecting and enforcing our legal rights.
We do not sell personal data.
We do not use personal data for automated decision-making that produces legal or similarly significant effects.
We do not use personal data for behavioural advertising or automated profiling for advertising purposes.
4/ Who May Receive Personal Data
We may disclose personal data where reasonably necessary for the purposes described in this Privacy Policy.
Recipients or categories of recipients may include:
- website hosting and IT service providers;
- email and communications service providers, including Google Workspace;
- professional advisers, including accountants, auditors and lawyers, where necessary and subject to appropriate confidentiality obligations;
- payment or financial service providers, where relevant;
- recruitment or HR service providers, where applicable;
- public authorities, courts, regulators or law-enforcement bodies where disclosure is required or permitted by law; and
- other service providers where necessary to provide our services and where appropriate data protection arrangements are in place.
Our principal technology providers currently include:
- Vercel Inc., for website hosting and related infrastructure; and
- Google / Google Workspace, for business email and related productivity services.
Where a service provider processes personal data on our behalf, we require appropriate contractual and organisational safeguards in accordance with applicable data protection law.
5/ International Transfers
Some of our service providers may process personal data outside the European Economic Area (“EEA”).
For example, Vercel and Google may process or store personal data in countries outside the EEA.
Where personal data is transferred outside the EEA, we ensure that the transfer is made using a lawful transfer mechanism under Chapter V of the GDPR, such as an adequacy decision, the European Commission's Standard Contractual Clauses or another lawful transfer mechanism, where applicable.
Google's current Data Processing Amendment for Google Workspace provides mechanisms for international transfers of Customer Personal Data, including appropriate contractual safeguards where required. Vercel also provides data-transfer safeguards under its current Data Processing Addendum.
You may contact us using the details in Section 12 if you would like further information about the safeguards applicable to a particular international transfer.
6/ How Long We Keep Personal Data
We retain personal data only for as long as necessary for the purposes for which it was collected, unless a longer period is required or permitted by law.
In particular:
- technical and security logs are retained for a limited period determined by our operational and security requirements and, where applicable, by our hosting provider;
- enquiry correspondence is generally retained for as long as reasonably necessary to handle the enquiry and any resulting relationship, and for a reasonable period afterwards where necessary to establish, exercise or defend legal claims;
- client and business records are retained for the duration of the relevant business relationship and afterwards for the periods required by applicable Romanian tax, accounting, legal or regulatory requirements;
- recruitment and unsuccessful applicant information is normally retained only for as long as reasonably necessary to complete the recruitment process and deal with related legal or administrative matters, unless a longer retention period is required or permitted by law or the applicant has separately agreed to a longer retention period; and
- information relating to successful candidates who become employees or contractors may be retained as part of the relevant employment or contractual records for the periods required by applicable law.
When personal data is no longer required, we will delete it or, where appropriate, anonymise it.
7/ Your Data Protection Rights
Subject to the conditions and limitations provided by applicable law, you may have the right to:
- request access to the personal data we hold about you;
- request correction of inaccurate or incomplete personal data;
- request deletion of your personal data where the legal requirements for erasure are met;
- request restriction of processing in the circumstances provided by law;
- object to processing based on our legitimate interests;
- receive certain personal data in a structured, commonly used and machine-readable format and, where legally applicable, request its transmission to another controller;
- withdraw consent at any time where we rely on consent as the legal basis for processing; and
- lodge a complaint with a competent data protection supervisory authority.
Withdrawal of consent does not affect the lawfulness of processing carried out before consent was withdrawn.
These rights are subject to applicable legal exceptions. For example, we may need to retain certain information where required by tax, accounting, employment or other legal obligations.
To exercise your rights, please contact us using the details in Section 12.
You may lodge a complaint with the supervisory authority in the EU Member State where you normally live, work or where you believe an infringement has occurred.
In Romania, the relevant supervisory authority is:
Autoritatea Națională de Supraveghere a Prelucrării Datelor cu Caracter Personal (ANSPDCP)
Website: www.dataprotection.ro
8/ Security
We implement appropriate technical and organisational measures designed to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access.
Our website is served over an encrypted HTTPS connection.
We use security controls provided by our technology and communications providers, including access controls, authentication and other security measures appropriate to the nature of the personal data processed.
However, no method of transmitting or storing information can be guaranteed to be completely secure. We regularly review our security measures and take reasonable steps to address identified risks.
9/ Cookies and Similar Technologies
Our website does not use non-essential cookies, advertising cookies, analytics cookies or similar tracking technologies.
We also serve website fonts from our own website rather than loading them from third-party font providers.
If this changes, we will update this Privacy Policy and, where required by applicable law, obtain consent before using non-essential cookies or similar technologies.
10/ Children
Our website and services are intended for adults and are not directed at children.
We do not knowingly collect personal data from children through the website. If you believe that a child has provided us with personal data, please contact us so that we can assess and, where appropriate, delete the information.
11/ Changes to This Privacy Policy
We may update this Privacy Policy from time to time, for example where our services, processing activities or applicable legal requirements change.
The latest version will always be published on this page together with the date on which it was last updated.
12/ Contact Us
If you have any questions about this Privacy Policy, our processing of personal data, or wish to exercise your data protection rights, please contact us:
ATHENE CONSULTANCY S.R.L.
Municipiul Satu Mare, Str. Miron Costin, Nr. 15A, Județ Satu Mare, Romania
CUI: 55398109
Trade Register number: J2026048992006
Email: athene@atheneworld.com
Telephone: +40 723 240 825
We will handle requests in accordance with applicable data protection law.