Privacy Policy

Who is responsible for your data

The data controller is S.R.L. Starion Digital (Republic of Moldova), the owner of suvenar.com and of the augmented reality viewer at ar3d.io. For anything to do with your data, including access and deletion requests, write to info@suvenar.com or call +373 680 33 007; we reply within 30 days. We have no separate data protection officer — requests are handled by the company’s director.

What we collect

We collect exactly what the site needs to work, and nothing beyond it:

• Catalogue visitors: technical request data — IP address, browser and device type, the page address. The hosting provider receives it automatically; it is needed to serve and protect the site.
• Site visit counter: how many different visitors and page views there were each day. The server recognises a visitor by an irreversible fingerprint derived from the IP address and the browser string using a secret key, and the fingerprint goes straight into a probabilistic counter (HyperLogLog) that can only count distinct values: neither the fingerprint nor the IP address is stored. No cookies or browser storage are used for this; the admin area and the experience pages are not counted.
• Partnership application: phone number, the login and password you choose, and optionally an email address, a postal address and a message. The sender’s IP address is stored as well: no more than two applications a day are accepted from one address.
• Partner account: name, login, phone, email and address, your prices and your role in the system. The password is stored only as an irreversible hash — neither we nor anyone who gained access to the database could read it.
• Orders: items and quantities, amounts, notes and delivery address, the date, and who actually placed the order — you or a manager on your behalf. The history of changes to an order is kept.
• Sign-ins: for each active session, the browser string (User-Agent), the dates it was created and last used, and the name you gave the session, if you gave one. The tokens themselves are stored as hashes.
• Email confirmation and password recovery: the address, a hash of the one-time code, the number of attempts and the expiry time.
• Augmented reality viewer: a scan counter; the stages of a viewing (page opened, camera allowed, souvenir found) with the language, the country derived from the IP address, the device and browser type; technical details of errors. So that a repeat viewing from the same phone is not counted as a new one, the server derives an irreversible fingerprint from the IP address and the browser string using a secret key. Nothing is stored in your browser for this, and the IP address itself is not kept in these records.

The camera in augmented reality

A “come-to-life” page asks for camera access — without it the souvenir cannot be recognised. The camera image is processed entirely on your device, by the browser: it is not sent to our servers, not recorded and not stored. We receive no frames, no photographs and nothing that happened to be in shot next to the souvenir. The permission is granted by your browser, and you can withdraw it at any time in its settings.

Why we do it and on what legal basis

Every kind of data has a specific purpose:

• Serving the site and protecting it from overload and password guessing — our legitimate interest.
• Reviewing a partnership application and creating an account — steps taken at your request before entering into a contract.
• Running the account area, accepting and fulfilling orders, keeping accounts — performance of our contract with you.
• Contacting you about an application or an order — performance of the contract and our legitimate interest.
• Keeping records of deliveries that matter for bookkeeping — compliance with a legal obligation.
• Counting scans and seeing where a viewing breaks, to know which experiences are in demand and whether they work — our legitimate interest. These records contain no names or contact details, and the device fingerprint cannot be turned back into an IP address.
• Counting site visits, to know how many people use the site — our legitimate interest. The counter holds no names, no IP addresses and no fingerprints.
• There is no advertising, no profiling and no automated decision-making about you on this site, and no ad networks on its pages.

Cookies and local storage

There is no third-party analytics and no advertising network on this site: we set no third-party cookie at all, and visits are counted by our own server without cookies, as described above. Everything stored in your browser is needed by the site itself, and all of it can be cleared in your browser — it will simply forget your language, theme and basket:

• session and session_bind — your sign-in. Not readable by page scripts, valid for seven days, deleted when you sign out.
• locale — the interface language you chose, one year.
• theme — light or dark appearance, kept in the browser.
• cart-storage and cart-owner — your basket: what you have set aside to order, and whose it is, so that another partner signing in on the same device does not see it. It stays in your browser and reaches us only when you place the order.
• cookieConsent — a note that you have read the notice at the bottom of the screen, so that it is not shown again.
• sd-staff-device — only on our staff members’ devices: a mark that keeps their visits out of the visit counter. It is never set for visitors.

Who we share data with

We do not sell data and do not hand it over for anyone’s advertising. It is seen only by the contractors the site cannot run without, each within its own part:

• site hosting (Vercel Inc., USA) — serves requests and keeps technical logs;
• the database (Neon Inc., servers in the USA) — stores accounts, orders and applications;
• Cloudflare R2 object storage and delivery network — product images, augmented reality files and backups;
• the mail server of our domain — messages with confirmation and password recovery codes;
• Telegram (Telegram FZ-LLC) — our work chat receives a notice about every new application and a file with the contents of every order, including the partner’s name, the items and the amounts;
• Upstash — briefly stores request-rate counters keyed to an IP address, to limit password guessing, guessing of experience addresses and inflating of counters, and keeps the site visit counter for up to 400 days, from which neither IP addresses nor fingerprints can be extracted;
• in addition, data may be disclosed on a lawful request from a public authority.

Transfers outside the country

Some of these contractors are located outside the Republic of Moldova and the European Economic Area, chiefly in the USA. The transfer relies on those providers’ standard contractual clauses and is necessary for the site to work: we run no servers of our own. If you need to know exactly which providers are involved today, write to us — we keep the list above up to date.

How long we keep data

Data lives exactly as long as it is needed:

• a partner account and its contents — while the partnership lasts and until you ask us to delete it;
• orders — for as long as bookkeeping rules require; a deleted order sits in the bin for seven days and is then erased for good;
• partnership applications — until they are reviewed and for a while afterwards, so that a refusal can be revisited;
• sign-in sessions — seven days, then deleted; sessions you end yourself go immediately;
• one-time confirmation codes — minutes, until they expire;
• the database backup — made every night, only the latest one is kept and the previous one is deleted.

How we protect data

The site works over HTTPS only. Passwords are stored as bcrypt hashes and sign-in tokens as SHA-256 hashes; the sign-in cookies cannot be read by page scripts and are not sent to other sites. Access to the admin area is split by role: an order manager does not see the settings, and an ordinary partner sees only their own prices and their own orders. The rate of sign-in attempts, code requests and applications is limited. No system is completely safe, so much depends on you too: use a password you use nowhere else, and end sessions you no longer need in your profile settings.

Your rights

You may exercise the rights below at any time. Send your request to info@suvenar.com — we answer within 30 days, and we may ask you to confirm that the account is yours so that we do not hand data to a stranger:

• find out what data we hold about you and receive a copy of it;
• correct inaccuracies — some of the data can be edited in your profile settings;
• ask for your data to be deleted, where it is no longer needed for the contract and the law does not require us to keep it;
• restrict the processing or object to it where it rests on our legitimate interest;
• receive your data in a machine-readable form;
• complain to a supervisory authority — in Moldova the National Centre for Personal Data Protection (datepersonale.md), in the EU the authority of your country.

Children

This site is meant for adults: the wholesale catalogue and the account area are for companies and sole traders, and we do not open accounts for anyone under 18. The augmented reality viewer is open to everyone and asks for no registration and no information about the person using it. If you believe a child has given us their data, write to us and we will delete it.

Changes to this policy

This policy is updated when the site itself changes — a new contractor, say, or a new form. The new version is published here with the date of the change. If a change is significant and affects partners, we will also announce it in the account area or through the contacts you gave us.