Last updated: 12 October 2026
This policy explains how personal data is processed in Avacone Planner (the "Planner"), Avacone's internal tool for time off, rotas and related staff records, in line with Regulation (EU) 2016/679 (GDPR) and Romanian data-protection law.
1. Who is responsible
Controller: Avacone Romania S.R.L., Bdul. Nicolae Titulescu 4, Et. MEZ, Ap. XIV/A, Cluj-Napoca, Județ Cluj, Romania, Trade Register J2021003530123, CUI 44632114 ("Avacone", "we"). Avacone decides why and how personal data in the Planner is processed and hosts the Planner.
Processor: Web Runner S.R.L., Str. Eroilor 196, Ap. 11, Sat Florești, Județ Cluj 407280, Romania, Trade Register J2025025706003, CUI 51609874, which develops and maintains the Planner on Avacone's documented instructions, under a data-processing agreement (art. 28 GDPR).
Contact for data-protection questions and requests: info@avacone.com.
2. What data we process
| Category | Examples |
|---|---|
| Identity and work details | name, work email, phone, job title, team, department, reporting line, role, contract type, first working day, country used for public holidays, profile photo (optional), birthday (day and month are shown to colleagues) |
| Time off | requests, dates, leave type, notes, approvals and decisions, balances, carry-over, generated leave forms |
| Health-related data | sick-leave periods and supporting documents such as medical certificates (special category data) |
| Other supporting documents | e.g. marriage or death certificates, when a leave type requires proof |
| Working time | rota shifts, hours, night hours, attendance sheets |
| Account and security | password (stored only as a one-way hash), sign-in sessions, device type, IP address, sign-in history, audit log of changes, calendar-sync link |
| Preferences | notification settings, theme, chosen views |
We do not use the Planner for automated decision-making or profiling with legal or similarly significant effects.
3. Why we process it and on what legal basis
| Purpose | Legal basis |
|---|---|
| Managing leave, working time, rotas and the related records, attendance sheets and payroll inputs | performance of the employment or service contract (art. 6(1)(b)) and legal obligations under the Romanian Labour Code, e.g. keeping working-time records (art. 6(1)(c)) |
| Sick leave and medical certificates | employment and social-security law obligations (art. 9(2)(b) GDPR) |
| Approvals, team calendars, notifications (in-app, email, optional Microsoft Teams posts) | contract (art. 6(1)(b)) and Avacone's legitimate interest in organising work (art. 6(1)(f)) |
| Security, access control, audit logs and backups | legitimate interest in protecting systems and data and being able to demonstrate correct processing (art. 6(1)(f)); security obligations (art. 32) |
| Birthdays on the home page and profile photos | legitimate interest in team cohesion (art. 6(1)(f)); you can object or remove your photo at any time |
4. Who can see your data
- Inside Avacone, by role: colleagues see your name, team, photo, birthday (day and month) and when you are "out of office" (the leave type only if Avacone enables it); your team lead, managers and administrators see the details they need to approve and plan (leave types, notes, balances, documents, history). Administrators manage accounts and settings.
- Web Runner S.R.L., as processor, for development, maintenance and support.
- Service providers (sub-processors) used to run the Planner: Amazon Web Services (AWS EMEA SARL) for hosting; the email provider Avacone configures for notifications (e.g. Microsoft 365); Microsoft, only if Avacone turns on Teams channel posts (these contain names and dates, never reasons or documents).
- Your own calendar app, only if you turn on calendar sync - you choose what it contains.
- Authorities, auditors or courts where the law requires it.
We do not sell personal data or use it for advertising.
5. Where the data is stored
The Planner and its database run in AWS region eu-west-2 (London, United Kingdom). The United Kingdom benefits from an adequacy decision of the European Commission under art. 45 GDPR. If a provider processes data outside the EEA or the UK, this happens under an adequacy decision (e.g. the EU-US Data Privacy Framework) or the European Commission's Standard Contractual Clauses.
6. How long we keep it
- Leave, working-time and related personnel records: for as long as you work with Avacone and afterwards for the periods required by Romanian law for personnel, working-time and payroll records, then deleted or anonymised.
- Supporting documents: as long as the related leave record is kept.
- Sign-in sessions: up to 30 days; one-time sign-in links: up to 7 days; read notifications: 180 days; records of sent emails and Teams posts: 60 days; backups: 14 days.
- Audit and security logs: as long as needed to secure the Planner and demonstrate correct processing.
- Your account is deactivated when you leave; the data is then kept only as described above.
7. How we protect it
Encrypted connections (HTTPS), passwords stored as strong one-way hashes, encrypted storage of secrets, role-based access, automatic sign-out, lockout after repeated failed sign-ins, uploaded files checked and served only to authorised people, audit logs and regular backups.
8. Your rights
You have the right to access your data, to have it corrected, to have it erased or restricted where the conditions are met, to object to processing based on legitimate interest, to data portability, and not to be subject to solely automated decisions. Some data must be kept by law even if you ask for erasure. To exercise your rights, contact info@avacone.com; we answer within one month.
You can also complain to the Romanian supervisory authority: Autoritatea Națională de Supraveghere a Prelucrării Datelor cu Caracter Personal (ANSPDCP), B-dul G-ral. Gheorghe Magheru 28-30, Sector 1, București, Romania - www.dataprotection.ro.
9. Cookies
The Planner uses only strictly necessary cookies (to keep you signed in and, if you choose one, remember your theme) - no analytics, advertising or third-party cookies. Strictly necessary cookies don't require consent, which is why the Planner shows no cookie banner. Details in the Cookie Policy.
10. Changes
We update this policy when the processing changes. The Planner asks you to acknowledge substantial updates; the date at the top shows the current version.