Privacy Policy

1. Data Controller

This website and its services are operated by:

This website and its services are provided under the brand STROP DE RAI, operated by Cosmin Onofrei through STROP DE RAI SRL, a registered company in Romania.
Registered business address: Str. Brândușa 4, 700374, Iași, Romania, European Union
Email: contact@cosminonofrei.com

As the data controller, Cosmin Onofrei determines how and why your personal data is collected, used, and protected.

2. Information We Collect

Personal Information

When you interact with this website, such as filling out a contact form or booking a session, we may collect:

• Your name
• Your email address
• Your phone number

Coaching & Session Data (Special Category Data)

During coaching sessions, you may choose to share personal, emotional, or relationship-related information.

This type of information is considered Special Category Data under GDPR due to its sensitive nature.

We only process this information with your explicit consent and solely for the purpose of delivering the coaching service.

Technical Information

When you visit the website, certain technical information may be collected automatically, including:

• IP address
• Browser type
• Device information

This information is used only for basic website functionality and security.

3. How We Use Your Information

Your data is used in a limited and transparent way to support your experience:

• To provide and deliver relationship coaching services
• To schedule sessions through Calendly
• To process payments securely via Revolut
• To communicate with you via Wix Business Email
• To respond to your inquiries or requests
• To comply with legal, accounting, and tax obligations

We do not use your data for profiling, automated decision-making, or advertising.

4. Legal Basis for Processing

Under GDPR Article 6, we rely on the following legal bases:

• Consent – when you submit forms or agree to communication
• Contract – when you book and receive coaching services
• Legal obligation – for financial and tax compliance
• Legitimate interest – for communication and basic service improvement

Under GDPR Article 9 (Special Category Data):

• We process sensitive coaching-related data only with your explicit consent.

Coaching services inherently involve the processing of sensitive personal data, and cannot be delivered without it.

This processing is carried out based on your explicit consent and is necessary for providing coaching services.

5. Third-Party Services

To operate this website and deliver services effectively, we use a small number of trusted third-party providers:

• Revolut – for secure payment processing
• Calendly – for scheduling coaching sessions
• Wix Business Email – for communication
• Hostinger – for website hosting

These providers process your data only as necessary and are required to handle it securely and in compliance with applicable laws.

6. Data Retention

Your personal data is not kept indefinitely. We retain it only as long as necessary for the purposes outlined in this policy:

• Coaching session notes: 3 years after your last session
• Payment records: 7 years (legal/tax obligation)
• Email subscriptions: until you unsubscribe
• Contact form inquiries: up to 2 years

After these periods, data is securely deleted or no longer actively used.

7. Cookies

This website uses only essential cookies required for proper functionality.

At this time, no analytics or advertising cookies are actively used.

If analytics tools are introduced in the future, you will be asked for clear consent through a cookie banner before any non-essential cookies are activated.

8. International Data Transfers

Some of the third-party providers we use may process data outside the European Economic Area (EEA).

When this occurs, we rely on Standard Contractual Clauses (SCCs) approved by the European Commission to ensure that your data remains protected.

9. Your Rights

You have the following rights under GDPR:

• Access your personal data (Article 15)
• Correct inaccurate data (Article 16)
• Delete your data (Article 17)
• Restrict processing (Article 18)
• Receive your data in a portable format (Article 20)
• Object to processing (Article 21)

To exercise any of these rights, contact: contact@cosminonofrei.com

10. Right to Lodge a Complaint

If you believe your data is not being handled correctly, you have the right to file a complaint with a supervisory authority.

In Romania, this is:

ANSPDCP – National Authority for the Supervision of Personal Data Processing

You also have the right to seek legal remedy through the courts if necessary.

11. Marketing Communication

You will only receive marketing or informational emails if you have provided your consent.

You can withdraw your consent at any time by unsubscribing or contacting us directly.

Withdrawing consent does not affect the legality of processing carried out before withdrawal.

12. Consent and Transparency

We aim to be transparent about how your data is collected and used.

When you submit your information or book a session, you are providing consent for us to process your data for that specific purpose.

We may retain basic records such as emails or booking confirmations to demonstrate how and when consent was given.

We do not use hidden tracking technologies or automated decision-making systems.

13. California Privacy Rights (CCPA/CPRA)

If you are a California resident, you have specific rights under the CCPA/CPRA, including:

• Requesting access to your personal data
• Requesting deletion of your data
• Understanding how your data is used
• Not being discriminated against for exercising your rights

We do not sell, rent, or share your personal data for advertising purposes.

14. Children's Privacy

This service is intended only for individuals aged 18 and older.

We do not knowingly collect personal data from minors. If such data is identified, it will be deleted.

15. Clarity in Love App

The Clarity in Love mobile application operates separately and has its own Privacy Policy.

You can review it here:

https://stropapps.com/clarityinloveapp/privacy-policy/

16. Governing Law

This Privacy Policy is governed by the laws of Romania.

By using this website and its services, you agree that any legal matters will be handled under Romanian jurisdiction, unless otherwise required by applicable data protection laws.