BIRP SOFTWARE S.R.L. · birp.io · sistemerp.md · BIRP Platform
Version 1.0 · Effective date: 23 August 2026
Preamble
This Policy supplements BIRP’s Privacy Policy. It describes the trackers placed or read on the devices of visitors to our websites and of users of the Platform, their purposes, their lifetimes, and the ways in which you express, change or withdraw your choice.
It is drawn up with regard to Article 5(3) of Directive 2002/58/EC, its national transpositions (in France, Article 82 of Law No. 78-17 of 6 January 1978, as amended), CNIL Deliberation No. 2020-091 of 17 September 2020 setting out guidelines on cookies and other trackers, and Regulation (EU) 2016/679.
1. What a tracker is
A tracker is information placed on your device (computer, tablet, phone) or read from it when you visit a website or use an online service. This definition is not limited to cookies: it also covers local storage, invisible pixels, device identifiers and any equivalent technology.
Unless a legal exemption applies, placing and reading a tracker requires your prior consent.
2. Who places trackers on our websites
| Issuer | Capacity | Establishment |
|---|---|---|
| BIRP SOFTWARE S.R.L. | Controller | Republic of Moldova |
| Google Ireland Limited | Capacity determined according to the services and settings actually activated (see section 6) | Ireland |
| Meta Platforms Ireland Limited | Joint controllers (BIRP and Meta) for the collection and transmission of data via the Meta Pixel; Meta acts as controller for subsequent processing (see section 4.2) | Ireland |
Where a third-party issuer acts as BIRP’s processor, the processing is governed in accordance with Article 28 of the GDPR. Where certain features or settings lead a third party to act for its own purposes, its capacity as controller is indicated in the tracker table and in the consent manager.
3. Strictly necessary trackers
These trackers are essential to the operation of the websites and the Platform. Where they meet the conditions of the exemption provided for by the texts referred to in the preamble, they are placed without prior consent. They cannot be disabled without compromising the operation of the service.
They are used in particular to ensure security, maintain your session, manage authentication, balance the load, remember your language preference and store your choice regarding trackers.
| Name | Purpose | Issuer | Lifetime |
|---|---|---|---|
| BIRP session and authentication cookies | Security, session continuity, authentication management | BIRP | Session |
| Language preference | Remembering the interface language (RO / RU / EN / FR) | BIRP | 12 months |
| Tracker choice | Storage of your consent or refusal | BIRP | 6 months |
4. Trackers subject to consent
These trackers are neither placed nor read before your consent is obtained. They are not triggered if you refuse, and are deactivated if consent is withdrawn.
4.1 Audience measurement
These trackers make it possible to understand page traffic, identify browsing paths and improve our content. BIRP uses for this purpose a tag manager and an audience measurement tool provided by Google Ireland Limited.
| Name | Purpose | Issuer | Lifetime | Issuer’s capacity |
|---|---|---|---|---|
| Google Tag Manager | Loading of audience measurement tags | Google Ireland Limited | 365 days | Processor of BIRP |
| Google Analytics (_ga, _ga_*) | Aggregated traffic statistics | Google Ireland Limited | 365 days | Processor of BIRP; controller for any purposes of its own, depending on the settings activated |
Retention period for audience data: 14 months, according to the settings selected.
4.2 Marketing
These trackers make it possible to measure the effectiveness of BIRP’s campaigns run on Meta’s networks and to improve their relevance. They are placed only after your consent.
| Name | Purpose | Issuer | Lifetime | Issuer's capacity |
|---|---|---|---|---|
| Meta Pixel (Facebook Pixel) | Measurement and improvement of BIRP’s campaigns | Meta Platforms Ireland Limited | 365 days | Joint controllers (BIRP and Meta) for collection and transmission; Meta controller for subsequent processing |
4.3 What BIRP does not use
BIRP does not use any tracker other than those described in this Policy. Apart from the marketing trackers in section 4.2, placed only with your consent, BIRP does not use any cross-site tracking device. The advertising features, cross-device measurement signals and data sharing with other services of the provider of the audience measurement tool are disabled.
BIRP does not sell any data derived from trackers and uses audience data only for aggregated statistical purposes. Data from the Meta Pixel is used solely to measure and improve BIRP’s campaigns.
5. How you express your choice
On your first visit, a banner allows you to express your choice. This banner complies with the following principles.
- Acceptance results from a positive action. Continuing to browse, scrolling the page or closing the banner does not constitute consent.
- Refusing is as accessible as accepting, from the first level of the banner, via a button of the same kind and the same visibility.
- You can customise your choice purpose by purpose.
- Refusal does not entail any degradation of your browsing or of the essential functions of the website or the Platform.
- Your choice is kept for 6 months, after which you are asked again.
- You can change or withdraw it at any time, as easily as you expressed it.
6. Legal basis
| Category | Legal basis |
|---|---|
| Strictly necessary trackers | BIRP’s legitimate interest in ensuring the operation and security of the service - Article 6(1)(f) of the GDPR, the consent exemption under Article 82 of Law No. 78-17 also being applicable |
| Audience measurement trackers | Consent - Article 6(1)(a) of the GDPR, and Article 82 of Law No. 78-17 |
| Marketing trackers | Consent - Article 6(1)(a) of the GDPR, and Article 82 of Law No. 78-17 |
7. Changing or withdrawing your choice
7.1 From our websites
The permanent "Manage my cookies" link, present in the footer of every page, opens the management panel at any time. There you can make changes purpose by purpose, or withdraw your consent entirely. Withdrawal takes effect immediately and deactivates the trackers concerned.
Withdrawal does not affect the lawfulness of the processing carried out before it.
7.2 From your browser
Your browser also allows you to delete trackers already placed and to configure their acceptance. These settings are specific to each browser and each device.
We draw your attention to two points: blocking all trackers indiscriminately may impair the operation of the websites, in particular authentication; and deleting trackers also deletes the tracker storing your choice, so the banner will be shown to you again.
8. Transfers outside the European Union
The audience measurement and marketing tools are provided by Google Ireland Limited and Meta Platforms Ireland Limited, established in Ireland. Their use may involve the disclosure of data to Google LLC and to Meta Platforms, Inc. in the United States.
Google LLC and Meta Platforms, Inc. declare that they adhere to the EU-U.S. Data Privacy Framework, which is the subject of an adequacy decision of the European Commission of 10 July 2023. Where applicable, these transfers are supplemented by the standard contractual clauses adopted by Implementing Decision (EU) 2021/914.
A copy of the applicable safeguards may be requested from privacy@birp.io.
Such processing takes place only after your consent.
9. Your rights
Trackers placed with your consent give rise to processing of personal data, in respect of which you have the rights of access, rectification, erasure, restriction, objection and portability, as well as the right to withdraw your consent at any time.
The ways to exercise these rights, the response times and the avenues for complaint are described in section 13 of the Privacy Policy.
You may lodge a complaint with a supervisory authority, in particular, in France, with the Commission Nationale de l’Informatique et des Libertés (CNIL), 3 place de Fontenoy, TSA 80715, 75334 Paris Cedex 07.
10. Contact
BIRP SOFTWARE S.R.L.
5 Miorița Street, MD-2065 Chișinău, Republic of Moldova
Data protection: privacy@birp.io
Representative in the European Union: Ungurean Victor, 55 avenue Marceau, 75016 Paris, France, privacy@birp.io
11. Amendments to this Policy
BIRP may amend this Policy, in particular in the event of a change of tracker, purpose, provider or applicable legal framework. The version in force and its effective date are accessible from the footer of the websites. Previous versions are archived and provided upon request.
