1. General provisions

This Privacy Policy describes how personal data of users of heritage.md (the “Website”) is collected, used, stored and protected.

The personal data controller is S.R.L. “HERITAGE EDU PLUS”, IDNO 1021600033813, registered in the Republic of Moldova.

Contact details:

Address: 45/A Dacia Blvd., Chișinău, MD-2062, Republic of Moldova
Phone: +373 620 222 10
E-mail: info@heritage.md
Website: heritage.md

Personal data is processed in accordance with the applicable personal data protection legislation of the Republic of Moldova.

2. Personal data that may be collected

Depending on how a user interacts with the Website, the following categories of data may be processed:

• first and last name;

• telephone number;

• e-mail address;

• messages, questions and enquiries submitted through Website forms;

• information provided in connection with applications, enquiries and the admission process;

• information required for online payments;

• technical information about the device and browser;

• IP address;

• information about actions performed on the Website;

• pages visited, traffic source and duration of visits;

• cookies and similar technology data.

The Website requests only the personal data necessary for the relevant processing purpose.

3. Purposes of processing

Personal data may be used to:

• process user enquiries and messages;

• communicate with users;

• provide information about educational services and school activities;

• process enquiries and applications related to admission and education;

• arrange and confirm payments;

• ensure the operation and security of the Website;

• analyse Website traffic and usage;

• improve Website content, structure and functionality;

• measure the effectiveness of advertising campaigns;

• comply with applicable legal obligations in the Republic of Moldova.

4. Contact form

The Website contains a contact form through which a user may provide their first and last name, telephone number, e-mail address and the text of a message or question.

This information is used to process the enquiry and communicate with the user.

Before submitting the form, the user confirms their consent to the processing of their personal data in accordance with the applicable terms.

5. Online payments

The Website may provide the possibility to pay for educational and other services online.

Information required to complete a payment may be transferred to a bank, payment system or other payment service provider involved in processing the transaction.

Bank card information required directly for the transaction is processed by the relevant payment service provider. The Website should not store the complete bank card number, CVV/CVC code or other card authentication information where such information is processed directly by the payment provider.

Information concerning the fact of payment, amount, purpose and transaction status may be processed by the controller for accounting and payment confirmation purposes.

6. Google Tag Manager

The Website uses Google Tag Manager to manage technical and analytical tags.

Google Tag Manager is used to load and manage connected services. The specific scope of data processing depends on the services activated through it and the user’s consent settings.

7. Google Analytics

The Website uses Google Analytics to obtain statistical information about Website traffic and usage.

Google Analytics may process technical information about the device and browser, approximate location information, IP address and information concerning the user’s interaction with Website pages.

Analytics technologies and cookies that are not strictly necessary for the operation of the Website should be used in accordance with the user’s choices in the cookie settings.

8. Google Ads

The Website may use Google Ads technologies to measure advertising campaign performance and track conversions.

Depending on the configuration, information concerning Website visits, interactions with advertisements and certain actions performed on the Website may be processed.

Advertising cookies and similar technologies are used after obtaining the appropriate user consent where such consent is required by applicable law.

9. Meta Pixel

The Website uses Meta Pixel (Facebook Pixel) to analyse advertising effectiveness and actions taken by users after interacting with advertising materials on Meta platforms.

Meta Pixel may transmit information to Meta concerning pages visited, actions performed, technical characteristics of the user’s device and browser and other identifiers used by the advertising platform.

Meta Pixel and related advertising cookies should be activated after obtaining the appropriate user consent where such consent is required.

10. Cookies

The Website may use:

• necessary cookies – for the technical operation and essential functions of the Website;

• functional cookies – to remember user preferences;

• analytics cookies – to analyse Website traffic and usage;

• advertising cookies – to measure advertising performance and operate marketing tools.

Users may accept or reject optional cookie categories through the consent management mechanism available on the Website.

Refusing analytics or advertising cookies should not prevent the user from accessing the essential functions of the Website.

11. Disclosure to third parties

To operate the Website and provide services, personal data may be transferred or made available to technical, analytics, advertising, hosting and payment service providers.

Depending on the functions actually used, these recipients may include:

• Google;

• Meta Platforms;

• banks and payment service providers;

• hosting and technical infrastructure providers;

• other service providers required for the operation of the Website.

Data is disclosed only to the extent necessary for the relevant processing purpose.

Some service providers may process data outside the Republic of Moldova. Where this occurs, transfers are carried out in accordance with applicable personal data protection requirements.

12. Data retention

Personal data is retained only for as long as necessary for the purposes for which it was collected or for the period required by applicable law.

Enquiry data may be retained for the period necessary to respond to the user, maintain subsequent communication and protect the controller’s legitimate interests.

Payment and accounting information is retained for the periods required under applicable legislation.

13. User rights

Subject to the conditions and limitations established by applicable law, users have the right to:

• receive information about the processing of their personal data;

• request access to their personal data;

• request correction of inaccurate or incomplete data;

• request deletion of their data;

• request restriction of processing;

• object to processing where provided by law;

• withdraw previously given consent;

• exercise the right to data portability where applicable;

• lodge a complaint with the competent personal data protection authority.

Withdrawal of consent does not affect the lawfulness of processing carried out before consent was withdrawn.

14. Data security

The controller applies reasonable technical and organisational measures to protect personal data against unauthorised access, alteration, disclosure, loss or destruction.

Access to personal data is provided only to persons who require it to perform their relevant duties.

15. Children’s personal data

As Heritage provides educational services to children, personal data relating to minors may be processed as part of admission and educational processes.

Such information should be processed only for specific educational, administrative and legal purposes and in accordance with the special requirements applicable to the protection of children’s personal data.

Where applicable law requires the consent of a parent or legal representative, the relevant processing is carried out after such consent has been obtained.

16. Changes to this Privacy Policy

This Privacy Policy may be updated periodically due to changes in legislation, Website functionality or the services used.

The current version of the Policy is published on the Website.

17. Contact details

For questions concerning personal data processing or the exercise of data protection rights, users may contact:

S.R.L. “HERITAGE EDU PLUS”
IDNO: 1021600033813
Address: 45/A Dacia Blvd., Chișinău, MD-2062, Republic of Moldova
Phone: +373 620 222 10
E-mail: info@heritage.md