This Privacy Policy explains what personal data Transylvania Executive Hub (“we”, “us”, or “our”) collects through the Transylvania Executive Hub mobile application for iOS and Android (the “App”), how we use it, who we share it with, and what rights you have. This policy is provided in accordance with Regulation (EU) 2016/679 (GDPR).
1. Data Controller
The data controller is Transylvania Executive Hub,
registered in Romania, with headquarters in Cluj-Napoca, Romania.
Contact:
contact@transylvaniaexecutivehub.ro
Website:
transylvaniaexecutivehub.ro
2. Scope
This policy applies to personal data processed through the App and related member services. It does not apply to third-party websites or services that you may access through links in the App, such as maps applications, LinkedIn profiles, or email clients.
3. Data We Collect
3.1 Account & Profile Data
When you create and complete your member account, we collect the data you provide directly:
- Email address (required for authentication)
- Phone number (required to complete your member profile and appear in the directory)
- First and last name (required for your profile)
- Job title / professional position (optional)
- Profile picture (optional)
- Company name and company logo (optional)
- LinkedIn profile link (optional)
- Personal bio (“About me”) and company description (optional)
3.2 App Usage Data
- Events you have registered for or viewed in the App
- In-app settings and preferences you choose
3.3 Technical & Diagnostic Data
- Installed app version and operating system version
- Device type and model
- Error logs and crash reports collected via Google Firebase Crashlytics. These reports may include a pseudonymous user identifier and, when you are signed in, limited account attributes such as user ID, email address, first name, and last name to help us diagnose issues related to your account
- Push notification token generated by your device operating system, when you grant notification permission
- App version and device information sent when checking for over-the-air (OTA) JavaScript bundle updates via Revopush
3.4 Data We Do Not Collect
- We do not request access to your device GPS or store precise location data on our servers
- We do not collect payment card or banking information through the App
- We do not use the App for advertising tracking across other companies’ apps or websites
4. Permissions Requested
The App may request access to the device features listed below. Each permission is optional unless noted otherwise; denying a permission only affects the corresponding feature.
| Permission | Purpose |
|---|---|
| Camera | Taking a profile photo directly within the App |
| Photo Library (iOS) | Selecting a profile photo or company logo from your device |
| Photo selection (Android) | Selecting a profile photo or company logo through the system photo picker. On Android, the App does not request broad access to your entire photo library |
| Push Notifications | Sending alerts about events and community updates when you grant permission in device settings |
| Calendar | Adding events you have registered for to your personal calendar |
The “Getting There” and club office map features open your device’s maps application with an event or office address. The App passes the destination address to the maps app but does not access your live location or store location data on our servers.
5. Purpose and Legal Basis for Processing
| Purpose | GDPR Legal Basis |
|---|---|
| Creating and managing your member account | Performance of a contract (Art. 6(1)(b)) |
| Authentication via one-time passcode (OTP) sent by email or SMS | Performance of a contract (Art. 6(1)(b)) |
| Displaying your profile in the member directory | Performance of a contract / Legitimate interest (Art. 6(1)(b)/(f)) |
| Event registration and attendee management | Performance of a contract (Art. 6(1)(b)) |
| Sending push notifications | Consent (Art. 6(1)(a)) — granted via device settings |
| Error diagnostics and App improvement | Legitimate interest (Art. 6(1)(f)) |
| Delivering over-the-air (OTA) app updates | Legitimate interest (Art. 6(1)(f)) |
| Legal compliance and fraud prevention | Legal obligation (Art. 6(1)(c)) |
6. Who We Share Data With
We do not sell your personal data. Data may be shared only with the following categories of recipients:
- Infrastructure / hosting provider — the servers running the App’s back end, hosted in the European Union (Google Cloud, europe-west4 region) or in countries with an adequate level of protection
- Google Firebase / Crashlytics (Google LLC) — for error and stability reports. Data may be transferred outside the EEA under EU Standard Contractual Clauses. Google’s policy: firebase.google.com/support/privacy
- Revopush — for delivering OTA JavaScript bundle updates to the App. Update checks may include app version and device model. Revopush privacy: revopush.org/privacy
- Other verified members — your public profile data (name, job title, company, photo, LinkedIn, and other profile fields you choose to provide) is visible to other authenticated members of the community
- Public authorities — when required by law
7. International Data Transfers
Where personal data is transferred outside the European Economic Area, we rely on appropriate safeguards such as adequacy decisions or Standard Contractual Clauses, particularly for services provided by Google Firebase.
8. Data Retention
- Account & profile data — for the lifetime of your account and for up to 30 days after deletion (grace period for accidental recovery), after which it is permanently erased
- Error logs (Crashlytics) — up to 90 days, per Firebase’s policy
- Notification data — the push token is invalidated when you uninstall the App or revoke notification permission
9. Tracking and Advertising
We do not use your personal data for cross-app or cross-website tracking for advertising purposes, and we do not sell your data to data brokers. The App does not use the iOS App Tracking Transparency framework because we do not track you across other companies’ apps and websites for advertising.
10. Data Security
We apply appropriate technical and organisational measures to protect your data, including:
- Encrypted transmission of data (HTTPS/TLS)
- Secure storage of authentication tokens and sensitive session data in the device keychain / secure storage
- Role-based access controls on our back-end systems
11. Your Rights (GDPR)
If you are located in the European Economic Area, you have the following rights:
- Access — request a copy of the data we hold about you
- Rectification — correct inaccurate data directly in the App (Profile section) or by contacting us
- Erasure (“right to be forgotten”) — request deletion of your account and associated data (see Section 12)
- Restriction of processing — limit the way we use your data
- Data portability — receive your data in a structured, commonly used, machine-readable format
- Objection — object to processing based on legitimate interest
- Withdrawal of consent — at any time, without affecting the lawfulness of prior processing
To exercise any right, write to us at contact@transylvaniaexecutivehub.ro. We will respond within 30 days. You also have the right to lodge a complaint with the Romanian National Supervisory Authority for Personal Data Processing (ANSPDCP) — www.dataprotection.ro.
12. Account & Data Deletion
You can request complete deletion of your account and associated personal data in two ways:
- From the App: open the Profile tab in the bottom navigation → scroll down and tap Delete Profile. An OTP confirmation code will be sent to your email address or phone number on file. After confirmation, your account and personal data will be deleted within 30 days
- By email: send a request to contact@transylvaniaexecutivehub.ro with the subject “Account Deletion”. We will confirm deletion within 30 days
Data may be retained for a longer period only where required by a legal obligation (for example, invoices or tax requirements).
13. Children
The App is intended exclusively for users aged 18 and over. We do not knowingly collect data from minors. If we become aware that we have received data from a minor, we will delete it immediately.
14. Changes to This Policy
We may update this policy periodically. The updated version will be published at transylvaniaexecutivehub.ro/privacy with a new “Last updated” date. For significant changes, we will notify you via the App or by email at least 15 days before they take effect.
15. Contact
For any questions about this policy or the processing of your data:
Email:
contact@transylvaniaexecutivehub.ro
Website:
transylvaniaexecutivehub.ro
Location: Cluj-Napoca, Romania