1. Who processes your data
The website enverde.md is administered by SCALELAW SOLUTIONS SRL (IDNO 1025600064372), which acts as the controller (operator) of personal data within the meaning of Law No. 195/2024 of the Republic of Moldova on personal data protection.
- Registered office: MD-2069, Chișinău, 67 Calea Ieșilor, office 9, Republic of Moldova
- Office address (for correspondence): 2a Mihai Viteazul St., Chișinău, Republic of Moldova
- Email for personal-data requests: [email protected]
- Phone: +373 78 76 87 65
- Enverde site contact: [email protected]
2. What we collect and why
Callback request (the “We’ll call you back” form)
Data: the name and phone number you enter, the page language, date and time of the request, IP address, country derived from the IP, browser identifier (User-Agent), and the proof of consent: the text you ticked, the version of this policy and the moment you ticked it.
Purpose: to call you back about your request (for example, to assess a plot) and to be able to demonstrate that you consented.
Legal basis: your consent (art. 6(1)(a) of Law No. 195/2024), given by ticking the box next to the form. If we then conclude a contract, the data needed to perform it are processed under art. 6(1)(b).
Is it mandatory? There is no legal or contractual obligation to give us these data, but without a name, phone number and consent we cannot call you.
Emails
If you write to [email protected] or [email protected], we process your address, name and the content of your message to reply (art. 6(1)(b) — steps at your request before a contract — or (f) — our legitimate interest in answering correspondence).
The chat assistant on the site
The AI assistant in the corner of the page only starts when you open it. Your written or spoken messages (and your name and phone, if you leave them there) are processed to answer you and pass your request to the team — basis: art. 6(1)(b) (steps at your request) and, for contact details left in the chat, your consent.
The assistant is Emmi (app.emmi-agent.com), SCALELAW SOLUTIONS SRL / Applexium’s own product, hosted on Hetzner servers in Germany. To generate answers, Emmi uses AI providers to which the conversation text is transferred in the USA: Anthropic (generating replies) and OpenAI (knowledge-base search). In voice mode, speech is transcribed by Soniox (with Deepgram and Groq as fallback) and the spoken reply is synthesised by ElevenLabs.
“Visitor memory” may be enabled: a pseudonymous identifier stored in your browser and a summary of past conversations, so the assistant can pick up where you left off on a later visit. You can ask for their erasure at [email protected] or clear the identifier in your browser. Please do not write anything in the chat you would not want to share.
Technical data
Every visit is automatically logged by the hosting infrastructure (IP address, date and time, requested page, browser) to deliver the page and protect against attacks — legitimate interest (art. 6(1)(f)).
3. Who receives your data
We do not sell or rent data. They are only received by providers that make the service work, acting as processors:
- Cloudflare, Inc. (USA) — site hosting, form processing, network protection and forwarding of email sent to [email protected];
- Mailjet (Sinch group, European Union) — delivering the callback request to the team by email;
- Google LLC (USA) — the mailbox where requests and correspondence arrive; Google Fonts, from which your browser downloads the site’s fonts (it sees your IP address);
- Hetzner Online GmbH (Germany) — hosting of the Emmi assistant; Anthropic, OpenAI, Soniox, Deepgram, Groq, ElevenLabs (USA) — the assistant’s AI providers (see above), only if you use it;
- public authorities, only where the law requires it.
The TikTok link on the page is a plain link: nothing is loaded from TikTok unless you follow it.
4. Transfers outside the Republic of Moldova
Some of the providers above process data on servers in the European Union and the United States. Data are only transferred to providers offering appropriate safeguards under Chapter V of Law No. 195/2024 (for example, standard contractual clauses).
5. How long we keep data
- Callback requests and the proof of consent: at most 12 months from the last contact if no contract follows; if one does, for the term of the contract and the retention periods required by law.
- If you withdraw consent or ask for erasure, we delete the data without undue delay, keeping only the record of the withdrawal.
- Technical access data: as long as the hosting provider keeps them for security, usually a few days.
6. Your rights
Under Law No. 195/2024 you have the right:
- of access to your data (art. 15) and to receive a copy;
- to rectification of inaccurate data (art. 16);
- to erasure (art. 17);
- to restriction of processing (art. 18);
- to data portability (art. 20);
- to object to processing based on legitimate interest (art. 21);
- to withdraw your consent at any time, as easily as you gave it: write to [email protected] or call +373 78 76 87 65. Withdrawal does not affect the lawfulness of processing carried out before it.
We reply within 30 days. If you believe your rights have been infringed, you may lodge a complaint with the National Center for Personal Data Protection of the Republic of Moldova (datepersonale.md).
We do not make decisions based solely on automated processing that produce legal effects concerning you.
7. Cookies and local storage
This site uses no analytics, advertising or tracking cookies. We only use strictly necessary storage:
enverde.cookie-notice(localStorage, 12 months) — remembers that you have seen the cookie notice;- the chat assistant’s session storage (sessionStorage, until you close the tab) — whether the chat window was open;
- if you open the chat and “visitor memory” is on: Emmi’s pseudonymous identifier, stored in your browser under app.emmi-agent.com;
- Cloudflare may set technical security cookies needed to protect the site.
As there are no optional trackers, we do not ask for a separate cookie consent. You can clear local storage at any time in your browser settings.
8. Children
Enverde’s services are aimed at landowners and businesses. We do not knowingly collect data from persons under 14; for them, consent must be given by a legal representative.
9. Security and changes
The site is served over HTTPS only, and requests are accessible only to the people handling them. When we change this policy, we update the version and date above.
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