1. Data Controller
Thornwell Media SRL, Strada Academiei 26, București 010014, România. CUI: RO48261930. Contact: contact@thornwell.eu, +40 21 310 4500.
2. Data We Collect
2.1 Automatically collected data
When you visit thornwell.eu, our web server logs your IP address, browser type, operating system, referring URL, and the pages you visit. This data is retained for a maximum of 30 days for security and diagnostic purposes.
2.2 Contact form data
When you submit the contact form on the About page, we collect your name, phone number, and email address, together with the message content. This data is used solely to respond to your submission and is retained for 12 months from the date of receipt.
2.3 Cookies
We use a single first-party cookie to record your cookie consent decision (accepted or rejected). This cookie does not track behaviour and does not leave our domain. No third-party tracking cookies are set.
3. Legal Basis for Processing
Server log data is processed under Article 6(1)(f) GDPR (legitimate interests — security and diagnostics). Contact form data is processed under Article 6(1)(b) GDPR (responding to a request you initiated). The consent cookie is processed under Article 6(1)(c) GDPR (compliance with ePrivacy requirements).
4. Data Sharing
We do not sell, rent, or share personal data with third parties for marketing purposes. Server log data may be shared with our hosting provider (located in the European Union) for operational purposes only. No data is transferred outside the EU/EEA.
5. Your Rights
Under GDPR you have the right to access, correct, delete, or restrict processing of your personal data. You may also withdraw consent at any time (where processing is consent-based) and lodge a complaint with the Romanian National Supervisory Authority for Personal Data Processing (ANSPDCP) at www.dataprotection.ro.
To exercise your rights, contact us at contact@thornwell.eu. We respond within 30 days.
6. Cookies: Accept and Reject
A cookie consent banner is shown on your first visit to the homepage. Clicking "Accept" sets a cookie recording your acceptance; clicking "Reject" sets a cookie recording your rejection. Either action prevents the banner from appearing again. You may clear this cookie through your browser settings at any time, which will cause the banner to reappear on your next visit.
7. Third-Party Links
Articles on this archive link to external sources including the AMI Montessori website, the Romanian Ministry of Education, and PBLWorks. These sites are not operated by Thornwell. We are not responsible for their privacy practices.
8. Changes to this Policy
We may update this policy to reflect changes in our practices or applicable law. The "Last updated" date at the top of this page reflects the most recent revision. Continued use of the site after an update constitutes acceptance of the revised policy.