Privacy Policy

2. What we collect

Service data

• The radio or navigation serial number you enter (for example 21090013).
• The email address you give us for delivery, and the country used for pricing.
• A random device identifier stored in a cookie, so that a returning visitor can find an order in progress.
• Order data: order number, time, amount, the code delivered.
• For invoices to customers in Romania: county and locality, as required by the e-Factura system.

Payment

• Payments are processed by Stripe on the System32 Limited account. We never see or store card details.
• Stripe shares with us the payer name and, where a wallet provides it, the billing address, which go on the invoice.
• A VAT number, if you enter one for a business purchase.

Support

• Conversations in the Intercom chat and emails you send us, including the details you choose to share.

Technical logs

• Server logs with IP address, pages requested, browser type and time, kept for security and troubleshooting. We do not run behavioural analytics on this site.

3. Why we process it (legal basis)

• Performing the contract (Art. 6(1)(b) GDPR): identifying the unit, retrieving and delivering the code, support, invoicing.
• Legal obligations (Art. 6(1)(c)): keeping tax and invoice records, typically for 10 years; VAT compliance.
• Legitimate interests (Art. 6(1)(f)): preventing fraud and misuse, keeping the Site secure, improving the service.
• Consent (Art. 6(1)(a)): only where we ask for it, for example non-essential cookies. We do not send marketing emails.

4. Legitimate use

The service is only for owners recovering the code of their own unit, or repairers acting with the owner's authorisation. Unlocking stolen equipment or any other unlawful use is prohibited. By using the service you confirm you have the right to unlock the unit whose serial number you enter.

5. Who receives your data

• Stripe (payments), Intercom (chat), our email delivery provider (the code and receipt) and our hosting provider.
• Smartbill and the Romanian tax authority (ANAF e-Factura) for invoices, where required.
• Authorities, when the law obliges us to.

We never sell personal data and never share it with third parties for their marketing.

6. How long we keep it

• Order and invoice records: as long as tax law requires, typically 10 years.
• Support conversations: up to 3 years after the last message.
• Server logs: up to 90 days.
• The device cookie: 2 years, or until you delete it.

7. Cookies

The Site uses a session cookie, the device identifier described above, a cookie remembering your language, and the cookies set by Stripe and Intercom when their components load. None of them is used for advertising.

8. Your rights

Under the GDPR (and similar laws such as the CCPA) you can ask us to:

• access the personal data we hold about you and get a copy;
• correct inaccurate data;
• delete data, except what we must keep by law;
• restrict or object to certain processing;
• receive your data in a portable format.

Write to privacy@system32.hk or use the contact form; we answer within 30 days. You can also complain to your data protection authority; in Romania that is ANSPDCP.

9. Contact

System32 Limited, Room 409, Beverley Commercial Centre, 87-105 Chatham Road South, Tsim Sha Tsui, Hong Kong · contact form · privacy@system32.hk