Scope and controller
This policy covers etpcopier.com. The migrated notices identify Tomulet Ioana Maria PFA, trading under the name ETP (Expert Trading Programmers), with a registered office in Medias (Sibiu), Romania, as a controller of customer personal data.
The legacy pages also associated ETP Pro Soft SRL and ETP Software Consulting SRL with references to ETP, “us,” and “we.” Those pages used inconsistent wording about the relationship among the entities, so the current controlling entity requires operator review.
Personal data covered by the migrated notice
The source notices describe personal data supplied by customers and subscribers rather than an exhaustive list of fields. They cover personal data involved when a person enters an agreement for the service, sends a query, expresses interest in a product or service, subscribes to a newsletter, or uses an enabled email notification channel.
The old notice referred to people who bought a product or used a free trial. That historical wording is not a statement that ETP Copier currently offers a trial.
How we use personal data
The migrated policy says personal data may be processed to:
- provide the service requested by a customer;
- give access to products or services already of interest to the person;
- prepare an answer to a query; and
- send consented marketing communication, which the old notice said may be tailored to previous interests.
Why we process personal data
The primary reason stated in the migrated notice is to carry out the agreement made when a customer accepts the applicable terms. The notice also identifies answering queries and consent to receive a newsletter as reasons for processing. This migration does not add legal bases absent from the source pages.
Mailgun and other service providers
When a customer enables the ETP Copier email-notification channel, notification email is sent by the server through Mailgun. Mailgun therefore processes the information needed to deliver that enabled email notification. This statement is limited to notification delivery; it does not claim that Mailgun handles every ETP communication.
The migrated notice says personal data is disclosed only to service providers that support ETP as data processors or separate data controllers. It also says customer and subscriber personal information will not be shared, sold, rented, or traded other than as disclosed in the policy.
Marketing and the right to unsubscribe
Newsletter communication is tied to consent in the migrated notice. A subscriber may unsubscribe at any time without further obligation. Software notification settings are separate from newsletter consent.
GDPR rights
Where the GDPR applies, its conditions and exceptions may provide the right to access personal data, the right to correct inaccurate data, the right to erasure, the right to restrict or object to processing, the right to data portability, the right to withdraw consent, and the right to complain to a supervisory authority. The source expressly states the right to unsubscribe; the broader list here identifies rights arising under applicable law rather than additional contractual promises.
Deletion requests
To make a deletion request or another GDPR request, email support@experttradingprogrammers.com or use the details on the contact page, and identify the account or correspondence involved. The request will be reviewed under applicable data-protection law. The migrated source pages do not state a fixed retention period or promised deletion timeline, so this policy does not invent one.