POLICY ON THE PROTECTION AND PROCESSING OF PERSONAL DATA
Privacy Policy

• General Information

1. The protection of your personal data is important to AMMS Studio, therefore we pay special attention to safeguarding the privacy of visitors who access the website www.ammsstudio.com, as well as those whose personal data has been provided to us by a third party or to which we have had access from another source. We comply with Regulation (EU) 2016/679 adopted by the European Parliament and the Council of the European Union on 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (the General Data Protection Regulation – GDPR).

2. Please read carefully the terms of the following Privacy Policy on the protection and processing of personal data to understand how your information will be handled. This Policy serves as a notice and explains AMMS Studio’s online practices regarding the application of the GDPR, as well as the rights you have in relation to how your information is used through the AMMS Studio website.

3. The processing of personal data carried out by AMMS Studio will always be performed in accordance with the GDPR and the applicable national data protection legislation. Through this Privacy Policy, AMMS Studio seeks to inform visitors about the nature of the personal data it collects, uses, and processes, as well as the purposes of such processing. In addition, website visitors are informed, through this Policy, about the rights they enjoy.

4. Please note that this Policy applies both to the website and to media pages associated with our brand and name (e.g., our pages on social networks such as Instagram, Facebook, YouTube, etc.). By visiting our website, requesting our services, or interacting with AMMS Studio by any means of communication (email, phone, social networks), each data subject confirms that they agree with this Privacy Policy. If you do not agree and do not wish to accept the situations and conditions described in this Policy, please leave the website and do not provide us with personal data.

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• Definitions

1. For the purposes of this Privacy Policy, unless otherwise stated, the terms below shall have the following meanings:

   •  AMMS Studio / we / us / our – means AMMS Studio S.R.L., a Romanian legal entity, with registered office in Bucharest, Str. Dimitrie Marinescu no. 32, Sector 2, registered with the Trade Register under no. J1995000776402, having VAT no. RO 6979103, email: office@ammsstudio.com. AMMS Studio S.R.L. provides the services available on the Website and is the website owner.

   • Consent – any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which they, by a statement or by a clear affirmative action, signify agreement to the processing of personal data relating to them.

   • Personal data – any information relating to an identified or identifiable natural person, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to their physical, physiological, genetic, mental, economic, cultural or social identity.

   • Controller – the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.

   • Data subject – any identified or identifiable natural person whose data is processed by AMMS Studio as controller (for example: prospective clients, subscribers to our communications, or website visitors).

   • Privacy Policy / Policy – this notice containing the provisions described in this document. It supplements the Website Terms and Conditions and the Cookies Policy and may also be referred to as the Data Protection Policy.

   • Cookies Policy – the document providing information on the “cookie” files our website uses and the purposes for which they are used. The Cookies Policy supplements this Privacy Policy as well as the Website Terms and Conditions.

   • Processing – any operation or set of operations performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

   • GDPR – Regulation (EU) 2016/679 adopted by the European Parliament and the Council of the European Union on 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, repealing Directive 95/46/EC (General Data Protection Regulation).

   • Visitor – any person who visits, views, or accesses the website www.ammsstudio.com.

• Personal Data Controller

1. The controller of personal data is AMMS Studio S.R.L., a Romanian legal entity, with registered office in Bucharest, Str. Dimitrie Marinescu no. 32, Sector 2, registered with the Trade Register under no. J40/776/1995, having VAT no. RO6979103, email: office@ammsstudio.com.

2. As a personal data controller, AMMS Studio is responsible for processing the personal data that belongs to you and which it collects directly or from other sources. Please note that, to ensure the safe protection and processing of your data, AMMS Studio has made all necessary efforts to implement reasonable and appropriate technical and organizational measures.

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• Data Protection Officer (DPO)

1. AMMS Studio is not legally required to appoint a Data Protection Officer. Therefore, any request related to your personal data must be addressed using the contact details mentioned above.

2.  If you have any concerns, questions, comments or complaints regarding this Policy or the use of the personal data we process, or if you wish to exercise any of your rights under the GDPR, you may send your request at any time to office@ammsstudio.com.

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• What personal data do we process?

1. Depending on the services and functionalities you wish to use or the relationships you will have with us, it may be necessary to collect, use, store and/or transfer certain personal data.

2.  Your personal data that we may process includes the following:

   • Identification data: e.g., first and last name;

   • Contact data: e.g., home/residence address, email address, phone number;

   • Technical data: e.g., IP address, browser type and version, operating system, platform and other technology on the device you use to access the website;

   • Marketing and analytics data: e.g., information on the use of our website, preferences regarding receipt of marketing communications, feedback provided or survey responses;

   • Aggregated data: we may collect, use and share aggregated data such as statistical or demographic data. These may be derived from personal data but are not considered “personal data” by law as they do not directly or indirectly reveal your identity. In the exceptional situation where aggregated data is combined with personal data so that a person can be identified directly or indirectly, the resulting combined data will be treated as personal data and used in accordance with this Policy.

3.  If you do not wish to provide the requested information, please note that you may be unable to access certain website functionalities, we may be unable to conclude any contracts or subsequent necessary collaborations, or we may be unable to respond to your requests.

4.  AMMS Studio may hold personal data of data subjects both as a result of direct interaction with them and through data obtained indirectly or through technology (e.g., automatic collection of technical data). For example, AMMS Studio may receive personal data about you in the following situations:

   • Completing a contact and/or appointment form on the website – when you provide data (such as name and email address) via the forms available on our website to contact us or schedule a meeting/consultation;

   • Subscribing to the newsletter – if you choose to subscribe to our newsletter by providing your email address and possibly other contact details;

   •  Sending a message (email or private message on social media) – if you contact us directly by email or via a message on social platforms;

   • Interactions on social platforms – for example, when you comment on our social pages, tag us in your posts or share content we publish.

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• Principles of data processing

1. AMMS Studio undertakes to comply with the personal data protection principles set out in the GDPR, thus ensuring that all personal data it processes is:

   • processed lawfully, fairly and transparently;

   • collected for specified, explicit and legitimate purposes;

   • adequate, relevant and limited to what is necessary in relation to the purposes for which it is processed;

   • accurate and up to date (measures are taken to erase or rectify inaccurate data without delay);

   • kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the data are processed;

   • processed in a manner that ensures appropriate security of the data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, by implementing appropriate technical and organisational measures.

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• Legal basis and purposes of processing personal data

1. Under Article 6(1)(b) GDPR, personal data may be processed where necessary for the performance of a contract to which the data subject is party or in order to take steps at the data subject’s request prior to entering into a contract. To provide you with our services or to conclude any subsequent collaboration agreements, it is necessary to process certain personal data belonging to you (such as name, email address, phone number, etc.).

2.  Under Article 6(1)(c) GDPR, personal data may be processed where necessary for compliance with a legal obligation to which the controller is subject. In order to comply with imposed legal obligations (e.g., tax and financial accounting obligations, responding to official requests from authorities), AMMS Studio may request and process a series of personal data, such as name, address, personal identification number or ID series and number, as applicable, for issuing invoices, reporting to competent authorities, or fulfilling other legal obligations.

3. Under Article 6(1)(a) GDPR, personal data may be processed on the basis of the data subject’s consent for one or more specific purposes. AMMS Studio explicitly relies on consent only for direct marketing purposes. Thus, in certain situations, personal data may be used for purposes such as: a) sending newsletters or other marketing, informational or commercial communications; b) participation in any contests or promotions organised by us. (In these cases, your consent will be explicitly requested and you may withdraw your consent at any time without affecting processing already carried out.)

4. Under Article 6(1)(f) GDPR, personal data may be processed for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject. When relying on this basis, AMMS Studio will first assess your interests and ensure that your fundamental rights and freedoms are not affected. Legitimate interests may include, for example, ensuring the proper and secure functionality of the AMMS Studio website, as well as the continual improvement of visitors’ experience on the site.

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• Processing for the purpose of sending the Newsletter

1. If you have given your consent to subscribe to the AMMS Studio newsletter, please note that your personal data will be collected, processed and used exclusively to send you various updates from our field of activity and information about any campaigns or marketing messages.

2. Please note that AMMS Studio reserves the right to select the recipients of its newsletters, as well as the right to remove from the database any subscriber who previously consented to communications, if deemed necessary. AMMS Studio may exercise these rights without prior notice and without any other obligation to the subscriber.

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• Processing for the purpose of responding to requests

1. If you contact us by sending a request, notice, question or message of any kind (via website forms, email, phone or social networks), AMMS Studio will collect and process the personal data you provide and may request additional personal data in order to respond to your request and resolve the situation or issue raised.

2.  By contacting AMMS Studio through any of the communication channels provided (including messages on social platforms), you understand and agree that your personal data will be processed in accordance with the provisions of this Privacy Policy.

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• Processing for the purpose of handling legal requests

1. AMMS Studio may collect, process and disclose information regarding your personal data to regulators, law enforcement bodies or other entities in the following specific situations:

   • In response to a legal request – when we believe, in good faith, that the law requires us to disclose data (for example, pursuant to a subpoena, order, or official request from a competent authority);

   • To protect rights and prevent fraud – when we believe, in good faith, that it is necessary to disclose certain data to detect, prevent or respond to fraudulent actions, unauthorised or abusive use of our materials, breaches of our Terms and Conditions or other policies, or in the event of other harmful or illegal activities. This may also be necessary to protect us (including our rights, property or materials), you and/or others, including in investigations initiated by regulatory authorities.

2. Information regarding personal data that we receive from or about you may be accessed, processed and stored for a longer period if it is subject to a legal request, a legal retention obligation, a government investigation or other investigations into possible violations of our terms and conditions or policies, or, in other cases, to prevent potential harm.

3. By providing any personal data via www.ammsstudio.com, you understand and agree that your data will be processed in accordance with this Privacy Policy. AMMS Studio undertakes to process the personal data provided only for the purposes for which they were transmitted, except where it is reasonably necessary to use them for another purpose compatible with the initial purpose of processing or where your express consent exists to use them for other purposes as well.

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• Disclosure of personal data to third parties

1.  Personal data processed via the AMMS Studio website will be disclosed and/or transferred to third parties only where we have your express consent to do so, except in cases where AMMS Studio has a legal or contractual obligation to proceed otherwise.

2.  By way of example, AMMS Studio may provide personal data to various bodies of the judicial system (such as prosecutors’ offices, police, courts) or other competent public authorities, on the basis of and within the limits of legal provisions and following an express request to that effect.

3. Also, to be able to process requests submitted via the website forms, it may be necessary, in certain circumstances, to disclose your personal data to partners with whom AMMS Studio collaborates and/or to other third-party service providers of AMMS Studio.

4.  By way of example, AMMS Studio may transmit collected personal data to different partners, such as: IT service providers (cloud or hosting – for example, the Wix.com platform hosting our site), electronic communications providers, advertising and marketing agencies, accounting services, human resources services, providers of integrated solutions or legal services.

5. Nevertheless, AMMS Studio has adopted appropriate technical and organisational measures to ensure the security of data transfers and the processing of such data in accordance with GDPR requirements by the entities mentioned above.

6.  AMMS Studio ensures, within reasonable limits, that the personal data collected will not be transferred to countries outside the European Economic Area (EEA). However, should a data transfer to third countries (outside the EEA) occur, AMMS Studio will ensure that such transfers are lawful and carried out on the basis of your express consent or another accepted legal ground. In such cases, we will, where appropriate, use the European Commission’s standard contractual clauses and/or rely on adequacy decisions issued by the European Commission (for example, for transfers of data from the EEA to the United States or other countries for which an adequacy decision exists).

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• Processing by third parties and external websites

1. The website www.ammsstudio.com may, at times, contain links to other websites whose data processing policies may differ from those of AMMS Studio. We recommend that you consult the privacy policies of any such website you access. AMMS Studio assumes no responsibility for information collected or submitted by these third parties via their websites.

2.  Likewise, if you interact with AMMS Studio via social media platforms (e.g., Facebook, Instagram), please note that those third-party platforms may also collect and access certain personal data provided by you through those networks (for example, data from your public social network profile, the content of messages or comments addressed to us, etc.). These data processing activities are governed by the respective social media platforms’ own privacy policies, and AMMS Studio has no control over how they process your data.

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• Automated data processing. Cookies

1. Our website is built on the Wix platform provided by Wix.com, Inc. As a result, certain personal data (such as IP address, information about the device and browser used, as well as cookie-type identifiers) may be collected and processed automatically through Wix’s infrastructure. According to Wix’s privacy policy, that company acts solely as a data processor for visitors’ data, while AMMS Studio remains the data controller. Consequently, responsibility for compliance with data protection legislation lies primarily with AMMS Studio as the website owner. (For more details, you can consult the privacy policy available on Wix’s website.)

2.  The www.ammsstudio.com website also uses cookie identifiers to offer users an optimal browsing experience. Matters relating to the use of cookies are detailed in the Cookies Policy document, which forms an integral part of this Policy and supplements the Website Terms and Conditions. Please read the full content of the Cookies Policy available on our website.

3.  As a data subject, you may exercise your right to disable cookies, as detailed in the section on your rights below. Note that most internet browsers automatically accept cookies, but you can change your browser settings to reject them or to alert you when a cookie is placed on your device. For more details, please see our website’s Cookies Policy.

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• Data storage

1.  AMMS Studio may retain processed data for different periods, depending on the specific purposes for which they were collected, respecting the principles of proportionality and minimisation. We will keep data only as long as necessary to achieve the stated purposes or for periods set by special legal provisions. Certain legal obligations of AMMS Studio, judicial proceedings and/or investigations may require the retention of certain data for longer periods, in accordance with legal requirements.

2.  In general, we keep your personal data only for as long as needed to fulfil the purpose for which you provided it, to meet your needs (e.g., to provide the requested service), to respond to your requests, or to meet our legal obligations.

3.  Below are some criteria and examples regarding retention periods, depending on the context in which you provided us with data:

   • If you provided information to conclude and perform a contract or collaboration agreement: we will process and store personal data for the purpose of concluding and performing the contract and for fulfilling related legal obligations (e.g., accounting and tax obligations). Such personal data will be processed and stored for the time necessary to perform the contract and thereafter, in accordance with legal requirements. For example, financial-accounting supporting documents (which may contain personal data) are kept, by law, for 10 years from the end of the financial year in which they were drawn up.

   • If you subscribed to the AMMS Studio newsletter: we will process and store personal data (e.g., your email address) to send you agreed updates and marketing messages until you decide to unsubscribe. You may unsubscribe at any time, either by clicking the unsubscribe link at the bottom of the emails you receive or by sending us an unsubscribe request. After unsubscribing, we will no longer use your contact details for newsletter purposes, but we may retain your email address on an internal watchlist (blacklist) to ensure that you no longer receive unwanted communications.

   • If you contact us with questions or specific requests: we will collect and process the personal data provided (e.g., name, email address, phone) to respond to your request. Such personal data will be processed and stored for the period necessary to process and resolve the request, but no longer than 5 years from the date of the last communication sent in that correspondence.

   • For cookies used on the website: these are stored on your device for varying durations depending on the nature and purpose of each cookie. For example, some cookies are session cookies (deleted automatically when you close the browser), while others may be persistent (expiring after a preset period). All our cookies have a limited lifespan and are managed in accordance with standard regulations and practices. For full details on the categories of cookies used and their retention periods, please see the Cookies Policy on our website.

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• Rights of data subjects

1.  Data subjects (all individuals whose data we process) have the following rights under the GDPR regarding their personal data processed by AMMS Studio:

   • Right of access: You have the right to obtain from us confirmation as to whether or not we process personal data concerning you, as well as access to such data and information about how it is processed. The first provision of information about processed data will be provided free of charge. For any additional copies of information already provided, we reserve the right to charge a reasonable fee based on administrative costs. Manifestly unfounded, excessive or repetitive requests may be refused.

   • Right to rectification: You have the right to request that we rectify or complete your data if it is inaccurate or incomplete. Upon your request, we will correct without undue delay any inaccurate information concerning you.

   • Right to erasure (“right to be forgotten”): You have the right to request the deletion of your personal data in certain circumstances provided by law (e.g., if the data are no longer necessary for the purposes for which they were collected, you have withdrawn consent and there is no other legal basis for processing, the data have been unlawfully processed, etc.). Following a deletion request, we may anonymise such data (remove its personal character) and continue processing for statistical purposes under the same legal conditions. Please note that the right to erasure is not absolute – in some cases we have a legal obligation to retain certain data (e.g., financial-accounting documents) for a certain period, even if you request their deletion.

   • Right to restriction of processing: You have the right to obtain restriction of the processing of your personal data in certain situations provided by the GDPR. The consequence of restriction is that we may only store the respective data without further active use. You may request restriction if:

     •  you contest the accuracy of the data – restriction applies for a period that allows us to verify the accuracy of the data;

     • processing is unlawful and you oppose the erasure of the data and request restriction instead;

     •  we no longer need the personal data for the purposes of processing, but you require it for the establishment, exercise or defense of legal claims;

     •  you have objected to processing (see the right to object below) and you are verifying whether our legitimate grounds as controller override yours as data subject.

   • Right to data portability: You have the right to receive the personal data you have provided to us in a structured, commonly used and machine-readable format (e.g., electronic format). You also have the right to request that this data be transmitted directly to another controller indicated by you, where technically feasible. The right to portability applies only to personal data you have provided directly to us, processed by automated means, on the basis of consent or for contract performance.

   • Right to object: You have the right to object at any time, on grounds relating to your particular situation, to the processing of your personal data where such processing is based on a public interest or our (or a third party’s) legitimate interests. In the event of your objection, we will no longer process the data in question, unless we can demonstrate compelling legitimate grounds that override your interests, rights and freedoms, or if the purpose is the establishment, exercise or defense of legal claims.

   • Right to withdraw consent: Where processing is based on your consent, you have the right to withdraw your consent at any time for that processing. Withdrawal of consent will only take effect for the future; processing performed prior to withdrawal remains valid.

   • Right to lodge a complaint with the supervisory authority: You have the right to lodge a complaint with the national supervisory authority for the processing of personal data if you consider that your rights have been infringed. In Romania, the supervisory authority is the National Supervisory Authority for Personal Data Processing (ANSPDCP), headquartered in Bucharest, Bd. General Gheorghe Magheru no. 28–30, Sector 1, postal code 010336, phone +40.318.059.211, email anspdcp@dataprotection.ro.

   • Right to object to processing for direct marketing purposes (right to unsubscribe): You may object at any time to the processing of your data for direct marketing purposes without having to provide any reason. In practice, this means you can unsubscribe from our newsletter at any time or request that we stop sending you commercial communications. Unsubscribing can be done by clicking the unsubscribe link in our marketing emails or by sending AMMS Studio an email explicitly requesting to unsubscribe/remove you from our marketing database. Once you have unsubscribed, you will no longer receive marketing communications.

   • Right to disable cookies: You can disable (partially or fully) the collection of data via cookies. Most web browsers are set by default to accept cookies, but you can configure your browser to reject certain types or all cookies, if you wish. You can also delete cookies already stored via your browser settings. For more details about the cookies we use and your options, please consult the Cookies Policy on the site.

2.  You may exercise any of the rights mentioned above regarding the personal data processed by AMMS Studio by sending us a written request using the contact details provided in this Policy (e.g., to office@ammsstudio.com). In this context, we may ask you for proof of identity (e.g., providing additional information necessary to verify your identity) to ensure that we disclose personal data to the entitled person.

3.  Please note that the rights listed above are not absolute. There are cases where these rights may be limited by law. Each request received will be analysed individually to determine whether it is founded. If the request is justified, we will act in accordance with your request. If the request is unfounded, we will refuse it and inform you of the reasons for the refusal and the rights you have (e.g., the right to lodge a complaint with the supervisory authority or to bring an action before the courts).

4.  AMMS Studio will make every effort to respond to legitimate requests within no more than 30 days from their receipt. The deadline may be extended, if necessary, by up to 60 days depending on the complexity and number of requests (we will inform you if we need to extend the response time and will state the reasons).

5.  In the case of unsubscribing from marketing communications (newsletter), please note that this does not apply to personal data you have provided to us in the context of other relationships or purposes. For example, if you have entered into a contract with AMMS Studio or requested a particular service, we will continue to process your data for that (contractual) purpose even if you have unsubscribed from marketing communications – unsubscribing refers strictly to stopping promotional messages and does not affect data processing necessary for contract performance or the requested service.

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• Security of processing

1. AMMS Studio has implemented appropriate technical and organizational measures, in accordance with GDPR requirements, to ensure an adequate level of security for the processing of your personal data. These measures are intended to protect data against unauthorized or unlawful access, disclosure, alteration or destruction, as well as against accidental loss. All AMMS Studio employees and collaborators, as well as any third parties acting on behalf of and for AMMS Studio, are required to maintain the confidentiality of the personal data to which they have access, in accordance with this Policy and the applicable legal obligations.

2. To protect personal data, AMMS Studio has taken, among others, the following measures: adoption of specific internal policies and procedures regarding data processing and security, minimizing the data collected and processed to what is necessary (the “data minimization” principle), restricting access to personal data only to those employees/collaborators who need it to perform their duties, implementing technological security solutions (e.g., encryption, pseudonymization, backup, firewall, up-to-date antivirus), as well as periodic staff training on legal data protection requirements.

3.  Nevertheless, we emphasize that no data transmission over the internet and no electronic storage technology is 100% secure. Unforeseen events may occur that lead to incidents or security breaches. In the unfortunate event of a security incident affecting your personal data, AMMS Studio will follow the legal procedures for notifying the authorities and, where appropriate, the affected data subjects. We will also take all necessary steps to limit the consequences of the incident and restore normality.

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• Disclaimer

1.  The AMMS Studio website may contain links to other websites and/or other web pages that are not owned or controlled by AMMS Studio. AMMS Studio assumes no responsibility for the content of these external sites and, therefore, will not be held liable for any damage or loss that may result from accessing or using those sites. This includes, without limitation, any issues related to the content, advertising, products, services, software, information or other materials available on or through such websites.

2.  AMMS Studio will not be responsible for the loss or unauthorized disclosure of personal data or for any negative effects on visitors’ personal data, nor for other damages (moral and/or pecuniary) caused by accessing those third-party sites. Accordingly, we encourage and advise you to read and ensure you understand the privacy policies of any website or application you visit before providing your personal data to those third parties.

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• Updating the personal data protection policy

1. This Privacy Policy may be subject to periodic changes (for example, to reflect legislative changes, updates to our data processing practices, or new website functionalities). Any such change will be published by updating the content of this page on the AMMS Studio website. We recommend that you check this Policy periodically to stay informed of any changes.

2.  If you do not agree with the changes that may be made to the Policy, please do not continue to use the AMMS Studio website after such changes are published. We will consider that you accept the changes to the Policy if you continue to use our website and services after the date on which the update was published on the site.

3. The terms of this Privacy Policy are interpreted in accordance with the applicable laws of Romania, including the General Data Protection Regulation (GDPR).

4. If you have additional questions regarding this Policy or how AMMS Studio processes your personal data, please do not hesitate to contact us at: office@ammsstudio.com.