Effective Date: September 14, 2026
This Privacy Policy explains how Duncan Prim SRL (str. Victor Crasescu 78, MD2059, Chișinău, Moldova), operating the REG.AC platform ("REG.AC", "we", "us", "our"), processes data in connection with automatically generated business micro-sites, and what rights business owners and other data subjects have.
1. Who We Are
- Operator: The REG.AC platform is operated by Duncan Prim SRL, registered in Moldova at str. Victor Crasescu 78, MD2059, Chișinău.
- Contact: For any question about this Policy or your data, contact privacy@reg.ac — we treat this as our single point of contact for privacy matters, including for individuals and supervisory authorities in the EU.
- EU Representation: As our processing activity grows in scale or regularity, we will assess whether a formal EU representative under Article 27 GDPR is required, and appoint one at that point. Until then, privacy@reg.ac remains the fastest way to reach us on any data protection matter.
2. What Data We Collect and Its Source
- We create draft micro-sites for businesses on REG.AC using publicly available information, primarily sourced from Google Maps / Google Business Profiles. This may include: business name, public address, publicly listed phone number, category, and opening hours.
- We do not collect private, sensitive, or non-public information as part of this process.
3. Legal Basis for Processing
- We rely on Legitimate Interest (Article 6(1)(f) GDPR, where applicable to the data subject's location) for the initial creation of draft, unpublished-by-default micro-sites from public sources, for the purpose of offering businesses a free website tool on the REG.AC platform.
- We have assessed that this interest is balanced against the data subject's rights by:
- keeping unclaimed drafts unindexed by search engines (noindex),
- clearly labeling drafts as automated and unverified,
- offering instant, no-condition removal at any time,
- not publishing any information beyond what is already public.
- If you object to this processing at any time, we will honor that objection immediately (see Section 7). We do not treat silence or inaction as consent to further processing — the legitimate interest basis applies only to the limited, reversible act of preparing a draft, not to ongoing publication after an objection.
4. How We Communicate This to Businesses
- We may contact businesses by physical mail to inform them that a draft micro-site exists on REG.AC and to invite them to view, claim, edit, or remove it. These communications are clearly marked as promotional/informational offers, not official notices, invoices, or legal documents, and identify Duncan Prim SRL as the sender with a return address.
- We do not send unsolicited marketing email or SMS in connection with this service.
5. Account Creation and Access Control
- Viewing a draft preview requires no account and no personal data.
- Creating an editing account requires the user to provide their own email address and set their own password. We do not generate or pre-assign login credentials to third parties.
- We do not label any unverified account or draft as "Verified" in relation to business ownership. Where we reference Google Maps as a data source, we label this specifically (e.g., "Data Verified with Google Maps") rather than implying identity verification.
- Higher-risk actions (such as changing or adding a business's public contact phone number or address) require an additional explicit confirmation step beyond email registration (see Section 9.3).
6. Data Retention
- Unclaimed drafts: Retained only as long as necessary to fulfill the purpose described in Section 3, and deleted upon request without delay.
- Claimed/active accounts: Data is retained for the duration of the subscription plus 30 days after cancellation, then deleted, unless a longer retention is legally required.
6a. Ownership Disputes
- If a business's legitimate owner or authorized representative believes an account on REG.AC was activated by someone without authority to do so, they may submit a dispute at any time via dispute.reg.ac or by emailing privacy@reg.ac, with no requirement to submit documents at this stage.
- Upon receiving a dispute, we will immediately freeze further edits to the disputed listing pending review. Freezing is a neutral protective measure and is not a determination of wrongdoing by either party. We aim to resolve disputes within 10 business days. If the account holder cannot promptly demonstrate a connection to the business, control of the listing reverts to draft/unclaimed status and any subscription fees paid by the disputed account holder are refunded in full (capped at the preceding 3 months of subscription fees).
6b. What "Verified" Means on This Platform
- Where we display "Data Verified with Google Maps" or similar wording, this indicates only that the listed business name, address, and phone number match a corresponding public Google Maps listing at the time of check. It is not a verification of who controls the REG.AC account, and it is not a confirmation that the account holder is the business owner. Account ownership itself is based on the self-certification described in Section 9.3, subject to the dispute process in Section 6a, not on independent identity verification by REG.AC.
7. Your Rights
Any individual or business representative may, at any time and without needing to justify the request:
- Erase the profile instantly via delete.reg.ac (no waiting period, no conditions).
- Object to processing by emailing privacy@reg.ac.
- Access what data we hold about a given business by request.
- Rectify inaccurate data.
- Port data on request, where technically applicable.
- We process erasure requests submitted via delete.reg.ac immediately and automatically. Requests submitted by email are processed within a maximum of 30 days, in line with Article 12 GDPR, and we aim for substantially faster turnaround in practice.
- We keep a suppression list of addresses that have requested removal or objected to processing, to ensure we do not contact them again by mail.
8. Cookies
- We use only strictly necessary cookies required for basic site functionality and security (e.g., session management, fraud prevention). We do not use marketing or advertising trackers. Where any non-essential cookie is used, we will request consent first.
9. Data Accuracy Disclaimer
- 9.1 Pre-activation data (sourced from public directories): Because initial draft data is mirrored from third-party public sources such as Google Maps, we do not guarantee its complete accuracy, completeness, or timeliness. We encourage businesses to claim and correct their listing. This disclaimer applies to data accuracy only, and does not limit our responsibility for how we process, present, label, or grant access to that data before it is claimed.
- 9.2 Post-activation data (entered or edited by the account holder): Once an account on REG.AC is activated, the account holder is solely responsible for the accuracy, legality, and currency of any information they enter or edit — including contact details, business description, media, and pricing. REG.AC does not verify, endorse, or guarantee user-submitted content, and is not liable for errors or omissions introduced by the account holder after activation.
- 9.3 Ownership self-certification: At activation, and again at any point the account holder adds or changes public contact information (phone, address, email), the account holder affirmatively confirms — via an explicit, non-preselected checkbox — that they are the business owner or an authorized representative. This confirmation is logged with timestamp and IP address. Where an account holder has provided this confirmation and it is later found to be false, responsibility for the resulting inaccurate claim of ownership rests with the account holder who made the false statement, without prejudice to the rights of the actual business owner under Section 6a and Section 7.
10. Limitation of Liability
- Nothing in this Policy is intended to exclude or limit liability that cannot be excluded or limited under applicable law, including liability arising from our own unlawful processing of personal data.
11. Complaints
- If you are located in the EU, you have the right to lodge a complaint with your local data protection supervisory authority (for example, the CNPD in Portugal at www.cnpd.pt, or the equivalent authority in your own country of residence), in addition to (not instead of) contacting us directly at privacy@reg.ac.
12. Governing Law
- REG.AC operates internationally, and Duncan Prim SRL is registered in the Republic of Moldova. This Policy is governed by the laws of the Republic of Moldova as our general governing law. Where our processing of a data subject's personal data falls within the territorial scope of the GDPR (Article 3(2)) or of another country's applicable data protection law, that law's mandatory protections apply to that processing regardless of this clause, and nothing here limits a data subject's mandatory rights under the law of their own country of residence.
13. Changes to This Policy
- We will notify users of material changes to this Policy via the Site, with a clear effective date, before such changes take effect.