Legal

Privacy Policy

Effective date: July 6, 2026

ProactiveLabs S.R.L., trading as Orythemes ("Orythemes", "we", "us", or "our"), is committed to protecting your personal information. This Privacy Policy explains what data we collect when you use our website at orythemes.com (the "Service"), how we use it, and what rights you have over it.

Data Controller:
ProactiveLabs S.R.L., trading as Orythemes
Romania, European Union
Email: privacy@orythemes.com

ProactiveLabs S.R.L. processes personal data as a data controller under the General Data Protection Regulation (EU) 2016/679 ("GDPR").

1. Information We Collect

Information you provide directly

  • Waitlist information: email address when you join the waitlist
  • Purchase information: billing name, address, and payment details — collected and stored by our payment processor (Lemon Squeezy / Stripe). We never see or store your raw card number
  • Communications: messages you send us via email or support channels
  • Marketing consent: your implicit opt-in when joining the waitlist

Information collected automatically

  • Log data: IP address, browser type, operating system, referring URLs, and pages visited
  • Usage data: features accessed, timestamps, and session duration
  • Cookies and similar technologies: we use minimal cookies for analytics and essential functionality (see Section 7)

2. How We Use Your Information

We use the information we collect to:

  • Send you updates about Orythemes (theme launches, product news)
  • Process purchases and deliver theme files
  • Send transactional emails (purchase confirmations, download links)
  • Respond to support requests and enquiries
  • Monitor and improve the performance, security, and reliability of the Service
  • Comply with legal obligations

We process your data on the following legal bases:

  • Performance of a contract (Art. 6(1)(b)): processing purchases, delivering theme files
  • Legitimate interests (Art. 6(1)(f)): security, fraud prevention, product improvement
  • Legal obligation (Art. 6(1)(c)): tax and compliance records
  • Consent (Art. 6(1)(a)): marketing communications — you may withdraw at any time via the unsubscribe link in any email

3. How We Share Your Information

We do not sell, rent, or trade your personal information. We share data only in the following circumstances:

  • Service providers: We share data with trusted vendors who process data on our behalf under data processing agreements:
    • Lemon Squeezy / Stripe (payment processing)
    • Cloudflare, Inc. (CDN, hosting, Workers)
    • Resend, Inc. (email delivery)
  • Legal requirements: We may disclose information if required by law, court order, or governmental authority.
  • Business transfers: In the event of a merger, acquisition, or sale of all or substantially all of our assets, your information may be transferred as part of that transaction.

4. Data Retention

We retain your data for as long as necessary to provide the Service and fulfil the purposes described in this policy. If you request deletion, we will delete or anonymise your personal data within 90 days, except where we are required by law to retain it longer (for example, financial records retained for seven years as required by Romanian accounting law).

5. Security

We implement industry-standard technical and organisational measures to protect your data, including TLS encryption in transit and access controls within our infrastructure.

No system is perfectly secure. While we take reasonable precautions, we cannot guarantee that unauthorised access will never occur.

6. International Data Transfers

ProactiveLabs S.R.L. is based in Romania, European Union. Several of our third-party processors are based in the United States, which means your personal data may be transferred outside the European Economic Area (EEA). For each of these transfers, we rely on Standard Contractual Clauses (SCCs) approved by the European Commission under GDPR Article 46(2)(c).

You may request a copy of the applicable SCCs by contacting us at privacy@orythemes.com.

7. Cookies

We use minimal cookies and similar technologies:

  • Strictly necessary: Essential cookies required for core functionality. These do not require consent.
  • Analytics: We use Cloudflare Web Analytics, which is privacy-respecting and does not use cookies or track individual visitors.

8. Your Rights under GDPR

You have the following rights regarding your personal data:

  • Access (Art. 15): request a copy of the personal data we hold about you
  • Rectification (Art. 16): correct inaccurate or incomplete data
  • Erasure (Art. 17): request deletion of your data ("right to be forgotten")
  • Restriction (Art. 18): ask us to limit how we process your data
  • Portability (Art. 20): receive your data in a machine-readable format
  • Objection (Art. 21): object to processing for direct marketing
  • Withdraw consent (Art. 7): withdraw consent at any time

To exercise any of these rights, contact us at privacy@orythemes.com. We will respond within 30 days.

If you are dissatisfied with our response, you may lodge a complaint with the Romanian data protection authority, ANSPDCP ( www.dataprotection.ro), or the supervisory authority in your EU member state.

9. Children's Privacy

The Service is intended for use by individuals who are at least 18 years of age. We do not knowingly collect personal information from anyone under 18.

10. Changes to This Policy

We may update this Privacy Policy from time to time. When we make material changes, we will update the effective date above and, where possible, notify you by email.

11. Contact Us

If you have questions about this Privacy Policy, please contact:
ProactiveLabs S.R.L. (trading as Orythemes)
Email: privacy@orythemes.com