This policy explains which personal data CMDA processes through the cmda.md website, for what purpose and on what legal basis, how long we keep it and what rights you have, in accordance with Law No. 195/2024 on personal data protection.
1. Who the controller is
The cmda.md website was created for and belongs to the Public Institution Municipal Centre for Entrepreneurship Development (CMDA), founded by the Chișinău Municipal Council. The site is administered by SCALELAW SOLUTIONS SRL (IDNO 1025600064372), which acts as the controller of the personal data processed through the site. For any question or request about personal data, contact the controller:
- SCALELAW SOLUTIONS SRL, IDNO 1025600064372
- Registered office: Calea Ieșilor 67, of. 9, MD-2069, Chișinău, Republic of Moldova
- Office address for correspondence: str. Mihai Viteazul 2a, Chișinău
- Email: info@applexium.com
- Phone: +373 78 76 87 65
For questions about CMDA programmes and services: info@cmda.md, +373 (60) 31-41-41, 132 Ștefan cel Mare și Sfânt Blvd., MD-2012, Chișinău.
2. What data we process, why and on what basis
Contact form
- Data: name, email address, phone (optional), request type and message. To be able to prove your consent, we also keep the date and time of consent, the version of this policy, the form language, the IP address and the browser type.
- Purpose: reviewing your request and replying to it.
- Legal basis: your consent (Art. 6(1)(a) of Law No. 195/2024), given by ticking the box below the form. Proof of consent is kept under the obligation set out in Art. 7(1) of the same law.
- Name, email and message are needed to reply to you; phone is optional. Providing the data is not a legal or contractual obligation. If you prefer not to use the form, you can write to info@cmda.md or call us.
Server logs
On every visit the server automatically records the IP address, date and time, the requested page and the browser type. We use these only for the security and operation of the site (Art. 6(1)(c) and Art. 32 of Law No. 195/2024).
Visit statistics
We count visits with Umami, a tool installed on our own server. It uses no cookies, does not store IP addresses and does not let us identify visitors: we only see aggregated data (pages visited, country, device type). The data is not shared with third parties. Legal basis: the legitimate interest in knowing which information on the site is useful to visitors (Art. 6(1)(f) of Law No. 195/2024); the data does not identify you.
The Emmi virtual assistant and Google Maps
These external services load only if you accept them in the cookie banner (consent, Art. 6(1)(a) of Law No. 195/2024). Emmi is SCALELAW SOLUTIONS SRL’s own product (Applexium, emmi-agent.com), hosted on Hetzner servers in Nuremberg, Germany. The assistant receives the messages you type in the chat and, in voice mode, a recording of your voice; to compose answers, the text is sent to the artificial intelligence providers listed in section 4. To recognise you on a later visit, Emmi keeps a pseudonymous identifier in your browser and a summary of earlier conversations. Please do not enter sensitive data in the chat. The Google Maps map on the Contacts page sends your IP address to Google and may set Google cookies; you can also show it just once using the button on the Contacts page.
Applications to programmes
Applications for CMDA programmes are submitted on the separate platform startup.chisinau.md, which has its own personal data rules. This policy covers only the cmda.md website.
3. Cookies and browser storage
Without your consent we use only items strictly necessary for the site to work:
- csrftoken (cookie, 1 year) — protects the contact form against forged submissions;
- django_language (cookie, 1 year) and selectedLanguage (local storage) — remember the chosen language;
- cmda_consent (local storage, 12 months) — remembers your choice in the cookie banner.
Only if you accept the external services: the Emmi assistant keeps a pseudonymous visitor identifier and the chat window state in your browser, and Google Maps may set its own cookies. You can change your choice at any time via “Cookie settings” in the footer of every page.
4. Who receives the data
We do not sell or rent data. It may reach only:
- CMDA — the staff who review requests sent through the contact form;
- Hostinger International Ltd. — hosts the website server (Frankfurt, Germany) and the @cmda.md mailboxes;
- the Emmi service of SCALELAW SOLUTIONS SRL (Hetzner Online GmbH servers, Nuremberg, Germany) and, through it, the artificial intelligence providers: Anthropic PBC (the Claude language model that composes the answers), OpenAI (indexing the question text to search the knowledge base) and, in voice mode only, Deepgram (speech recognition) and ElevenLabs (voice synthesis) — only if you accepted the external services and use the chat;
- Google (Google Maps) — only if you accepted the external services or chose to show the map;
- public authorities, when the law requires it.
5. Transfers abroad
The website server (Frankfurt) and the Emmi service servers (Nuremberg) are located in Germany, a European Union member state where the General Data Protection Regulation (GDPR) applies. If you use the Emmi assistant, the text of your messages (and, in voice mode, your voice recording) is sent to artificial intelligence providers in the United States (Anthropic, OpenAI, Deepgram, ElevenLabs). Google may process data in the USA under its own privacy policy. These transfers happen only after you accept the external services.
6. How long we keep data
- Contact form messages and proof of consent — as long as needed to review the request and for follow-up correspondence, then according to the document retention periods set for the institution by archives legislation. If you withdraw consent, the message is deleted unless the law requires us to keep it.
- Web server logs — 14 days.
- Your cookie banner choice — 12 months, after which we ask again.
7. Your rights
Under Law No. 195/2024 you have the right:
- of access to your data (Art. 15);
- to rectification of inaccurate data (Art. 16);
- to erasure of data (Art. 17);
- to restriction of processing (Art. 18);
- to data portability (Art. 20);
- to object (Art. 21);
- to withdraw your consent at any time, as easily as you gave it, without affecting the lawfulness of processing carried out before the withdrawal (Art. 7(3)).
To exercise your rights, write to the controller at info@applexium.com, call +373 78 76 87 65 or send a request by post to SCALELAW SOLUTIONS SRL, 2a Mihai Viteazul St., Chișinău. We reply within one month of receiving the request; in the cases provided by law this may be extended by two further months, and we will inform you.
You can withdraw consent for the external services via “Cookie settings” in the page footer, and consent given in the contact form by emailing info@applexium.com.
8. Right to lodge a complaint
If you believe your data is processed in breach of the law, you can lodge a complaint with the National Centre for Personal Data Protection:
9. Other information
- We do not make automated decisions or create profiles based on your data.
- The site is not aimed at children under 14. If you are under 14, please ask a parent or legal representative to contact us on your behalf.
- Data is protected by an encrypted connection (HTTPS) and restricted access to the server and the administration panel.
- We may update this policy; the current version and update date are shown at the top of the page.