Privacy Policy

Lavincom Prim SRL | Garduri.md
Version 2.0 | Effective Date: 23 August 2026
Drafted in accordance with Law No. 133/2011 and Law No. 195/2024 on the Protection of Personal Data

This Privacy Policy describes how Lavincom Prim SRL, operating under the Garduri.md trademark, collects, uses, stores and protects the personal data of website users, customers and business partners. We are committed to respecting your privacy and protecting your personal data.

This policy applies to all persons who interact with us through the garduri.md website, by phone, by e-mail or through messaging channels (WhatsApp, Viber). Please read this policy carefully. By submitting your data through any communication channel, you confirm that you have become aware of our personal data practices.

1. Data Controller

Information	Details
Legal name	Lavincom Prim SRL
Trademark	Garduri.md
Registered office	Str. Uzinelor 17, Chisinau, Republic of Moldova
IDNO	1003600023397
Website	www.garduri.md
E-mail for data protection	office@garduri.md
Phone	+373 79 207 400
Supervisory authority	CNPDCP — www.datepersonale.md | (022) 820 801

The company acts as a data controller within the meaning of art. 4 of Law no. 133/2011 and art. 4 point 7 of Law no. 195/2024, being responsible for processing your data in a safe, lawful and transparent manner.

2. Legal basis

This Privacy Policy is drafted in accordance with:

• Law no. 133 of 08 July 2011 on the protection of personal data (in force until 23 August 2026)
• Law no. 195 of 25 July 2024 on the protection of personal data (applicable from 23 August 2026), which fully transposes Regulation (EU) 2016/679 (GDPR)
• Government Decision no. 1123 of 14 December 2010 on the requirements for ensuring the security of personal data
• Council of Europe Convention no. 108 for the protection of individuals with regard to automatic processing of personal data

3. Definitions

For a better understanding of this policy, we define the following terms:

Term	Definition
Personal data	Any information that refers to an identified or identifiable natural person (name, IDNP, telephone, e-mail, IP address, image, etc.)
Processing	Any operation performed on data: collection, storage, use, transmission, deletion, etc.
Data controller	The legal entity that determines the purposes and means of data processing — in this case: Lavincom Prim SRL
Data subject	Any natural person whose data are collected and processed (customer, visitor, partner)
Processor	The person who processes the data on behalf of the controller (e.g. Microinvest, IT providers)
Consent	The free, specific, informed and unequivocal agreement of the data subject to the processing of his or her data
IDNP	State identification number of the natural person in the Republic of Moldova
CNPDCP	National Center for Personal Data Protection — the supervisory authority in Moldova

4. Categories of personal data collected

4.1. Data collected through the form on the website (garduri.md)

• Last name and first name
• Telephone number
• E-mail address
• The message / request sent

4.2. Data collected through messaging channels (WhatsApp / Viber)

• All data listed in 4.1
• Copy of the ID document (front/back) — sent upon express request, only for contracts or Microinvest verification
• Personal identification number (IDNP) — extracted from the ID document

Data transmitted via WhatsApp / Viber are treated with the same level of protection as any other channel. The copy of the ID document is requested exclusively when strictly necessary and is deleted according to the terms in chapter 7.

4.3. Data collected in the contractual process

• Series and number of the ID document
• IDNP
• Domicile address
• Billing data (full name / company name, IDNO, address)
• Signature

4.4. Data collected within the framework of financial intermediation services (Microinvest)

• Identification data listed in 4.3
• Financial data necessary to assess eligibility for microfinance products

These data are transmitted to Microinvest exclusively at the express request and with the written consent of the client.

4.5. Technical data collected automatically

• IP address, browser type, operating system
• Pages visited, session duration, traffic source
• Data collected through cookies (see chapter 10)

5. Source of personal data

Lavincom Prim SRL collects personal data:

• Directly from the data subject — via the form on the website, telephone, e-mail, WhatsApp, Viber or during direct meetings
• From authorized third parties — commercial partners who recommend clients to us, provided that they have the necessary information