1. Overview
This Privacy Policy describes how HKR Media SRL ("HKR", "we", "us") collects, uses, and shares personal data in connection with HKR's products and services (the "Service").
This Privacy Policy applies to personal data where HKR is the Controller — meaning data where we determine the purposes and means of processing. That includes:
- Account and authentication data of individuals who register for the Service
- Billing and transaction data of Service Customers
- Communications and support metadata
- Website analytics, cookies, and tracking technologies
- Marketing data of business contacts who interact with us
This Privacy Policy does not cover personal data that Customers send us as Inputs for the production of Deliverables. HKR processes those personal data on Customers' instructions and acts as a Processor; that processing is governed by HKR's Data Processing Agreement.
The Service is offered to businesses and is not directed at children. HKR does not knowingly collect or process personal data of individuals under the age of 16. If you believe a child has provided HKR with personal data, please contact us at privacy@hkr.ai.
2. Who we are
The data Controller for personal data covered by this Privacy Policy is:
HKR Media SRL
Office address: Mindspace, Globalworth Campus A, Bd. Dimitrie Pompeiu 4–6, Bucharest, Romania
Trade Register Number: J2021011826401
VAT / Tax ID: RO 36035484
For all privacy-related questions, requests, and rights exercises, contact us at:
Email: privacy@hkr.ai
HKR maintains certifications relevant to information security and quality management. Current details of HKR's certifications are available at hkr.ai/trust-center.
3. Data we collect
HKR collects the following categories of personal data:
| Category | Examples |
|---|---|
| Account data | Name, business / work email, business title, organization name, business identifier (VAT number, EIN, or equivalent) |
| Billing data | Company name, billing address, tax ID, transaction records. Full card-payment details are processed by our payment processor as a separate Controller; HKR does not receive or store full card numbers. |
| Authentication data | Hashed passwords, magic-link tokens, single sign-on (SSO) claims |
| Communications metadata | Email and support-ticket headers, in-platform messages, customer-interaction logs |
| Website analytics and device data | IP address, browser type and version, device type, operating system, pages visited, referring URLs, timestamps |
| Cookies and tracking technologies | See Section 9 |
| Marketing preferences | Subscription / unsubscribe status, email engagement metrics |
HKR collects personal data directly from data subjects (at signup, purchase, or support interactions), via Customers (when an account administrator invites Authorized Users), automatically (cookies, server logs, analytics), and from third-party services (sales tools, sanctions screening, business-data enrichment).
4. How we use data
HKR processes personal data for the following purposes, on the legal bases set out below:
| Purpose | Legal basis |
|---|---|
| Provide the Service to Customers and Authorized Users | Contract |
| Account creation, authentication, account management | Contract |
| Billing, invoicing, tax compliance | Legal obligation and contract |
| Security, fraud prevention, abuse monitoring | Legitimate interests |
| Compliance with legal obligations (sanctions screening, anti-money-laundering, tax, regulatory requests) | Legal obligation |
| Service improvement, internal analytics, debugging | Legitimate interests |
| Marketing communications about HKR's services | Consent or legitimate interests as appropriate. Every marketing communication includes an unsubscribe / opt-out mechanism. You can also opt out at any time by emailing privacy@hkr.ai. |
HKR does not engage in automated decision-making that produces legal effects or similarly significant effects on data subjects. The Service uses AI for the production of creative Deliverables under human supervision.
5. Who we share data with
HKR shares personal data with the following categories of recipients only where necessary and under appropriate safeguards:
- HKR personnel authorized to access personal data, under confidentiality obligations
- Sub-processors engaged to provide the Service (cloud and hosting infrastructure, AI / ML model providers, communication tools, analytics, support tooling). The current list is published at hkr.ai/trust-center.
- Payment processor for card and bank-transfer processing. The payment processor acts as a separate Controller for card-payment data. By completing a transaction, Customers agree to the payment processor's terms and privacy policy.
- Accounting and tax service providers for invoicing and statutory filings
- Legal advisors, auditors, and insurers under professional confidentiality
- Authorities when legally required (tax, sanctions, judicial requests, regulatory inquiries)
- Successors in interest in connection with a merger, acquisition, reorganization, or sale of business assets
HKR does not sell personal data. HKR does not rent or trade personal data with third parties for their independent marketing purposes.
6. International transfers
HKR is established in Romania and processes personal data within the European Economic Area ("EEA") where possible. Some of HKR's sub-processors are based outside the EEA — in particular major cloud and AI / ML model providers.
Where HKR transfers personal data outside the EEA, HKR applies appropriate safeguards under Chapter V of the GDPR:
- Adequacy decisions of the European Commission, where applicable
- Standard Contractual Clauses
- Transfer Impact Assessments where required
Where a sub-processor offers an EEA data center or region, HKR will generally prefer it where commercially viable.
7. Retention
When the personal data collected is no longer required by us, we and our service providers will perform the necessary procedures for destroying, deleting, erasing, or converting it into an anonymous form as permitted or required under applicable laws.
8. Your rights
Under the GDPR, data subjects have the following rights with respect to their personal data:
- Right of access — confirmation of whether HKR processes the data subject's personal data and a copy of that data
- Right to rectification — correction of inaccurate personal data and completion of incomplete personal data
- Right to erasure (the "right to be forgotten") — deletion of personal data, subject to applicable exceptions
- Right to restriction of processing — limitation of processing in specific circumstances
- Right to data portability — receipt of personal data in a structured, commonly used, machine-readable format
- Right to object — objection to processing based on legitimate interests, including direct marketing
- Right to withdraw consent — where processing is based on consent, the right to withdraw consent at any time without affecting the lawfulness of processing prior to withdrawal
- Right to lodge a complaint with a supervisory authority — in Romania, the relevant authority is ANSPDCP (www.dataprotection.ro); data subjects resident in other EEA Member States may also lodge a complaint with their local supervisory authority
To exercise any of these rights, contact HKR at privacy@hkr.ai. HKR will respond within one month of receipt. This period may be extended by up to two further months for complex or numerous requests, in which case HKR will notify the data subject within one month of receipt with the reasons for the extension. HKR does not charge a fee unless a request is manifestly unfounded or excessive.
9. Cookies
HKR's websites may use cookies and similar tracking technologies. Detailed information about the cookies used, their purposes, durations, and how to manage consent is available in the Cookie Declaration accessible through the consent banner displayed on first visit and via the cookie-management interface on the websites.
10. Changes and contact
HKR may update this Privacy Policy from time to time. The most up-to-date version is always available at hkr.ai/privacy and is identified by a version date. Customers and other data subjects are responsible for reviewing the current version periodically.
For all privacy-related questions, requests, or rights exercises, contact:
HKR Media SRL
Email: privacy@hkr.ai