Cookie Policy

1. Who operates this site

This policy applies to the layro.ro website and the app.layro.ro application, operated by:

2. Cookies and similar technologies

Cookies are small text files that a website stores on your device. Alongside them are other forms of local storage, the most widely used being Local Storage — an area of your browser in which a web application can keep information between visits.

Legally the distinction does not matter: Art. 4(5) of Romanian Law no. 506/2004 governs storing information, or gaining access to information stored, in a user’s terminal equipment, whatever the technical means. We therefore set out below everything we store in your browser, not only cookies as such.

What we store ourselves is held in Local Storage, not in cookies. The exceptions are the three third-party services described below — the support chat (section 3.3), signing in with Google (section 4.2) and the feedback page in the application (section 4.4). Their providers may also use cookies, but those are stored on their own domains, not on ours.

3. What we store on the public website (layro.ro)

3.1 Strictly necessary

Without this, the site cannot honour the choice you made. It requires no consent, because its whole purpose is to record your consent decision.

3.2 Analytics (PostHog)

We use PostHog to understand how the site is used: how many visits it gets, which pages are read, how far down a page people scroll and which buttons are pressed. Measurement runs in two modes, and what separates them is not whether we measure but whether anything is stored in your browser.

Without consent — the default mode. If you have not chosen yet, or if you declined, PostHog runs in cookieless mode: it writes nothing to your browser and reads nothing from it. Events leave without an identifier stored on your device, and PostHog derives a temporary identifier on its own server from the request metadata — your IP address and browser type — together with a secret value that changes daily. This lets us count visits and see which pages were read within a single visit, but we cannot recognise you from one day to the next and we cannot follow you onto other sites. Because nothing is stored in your terminal equipment, art. 4(5) of Romanian Law 506/2004 does not apply and we do not ask for your consent; the processing rests on legitimate interest (section 6).

With consent. If you press “Accept”, we additionally store a random identifier — in Local Storage and, this time, in a cookie set on the layro.ro domain as well. The cookie duplicates the Local Storage value because some browsers clear Local Storage far sooner than cookies — without it a returning visitor reads as a new one. The identifier stays on the website: the application at app.layro.ro does not read it and does not recognise you from it (section 4.3).

At the same point we also switch on:

• automatic capture of clicks on page elements;
• click and scroll maps, which show us where reading stops on a page and which elements get pressed although they are not buttons;

When you withdraw consent we delete the stored identifier immediately and return to cookieless mode.

In neither mode do we collect your name or your email address, do we read the contents of text fields, do we record your session or screen, do we run in-page surveys, do we measure your device's performance — and we measure nothing at all if your browser sends a Do Not Track signal.

Campaign parameters. If you arrive from an advertisement, the address carries parameters saying which campaign you came from (for example utm_source or fbclid). We hold them in the page's memory for the length of the visit only, and pass them on in the application's address when you press a sign-up button, so that we know which campaign brought a new account. They are not stored on your device and they are not sent back to the advertising network.

More about PostHog’s processing: posthog.com/privacy

3.3 Support chat (Brevo Conversations)

You can write to us directly through a chat: on the website, from a button in the corner of the page; in the application, from a page of its own, Help. The service behind it is Brevo Conversations, provided by Brevo SAS, a French company based in Paris.

It is not loaded until you open it. The button, and the page, are ours; Brevo’s code is only fetched at the moment you open the chat. Until then nothing is stored or read in your browser and no request is made to Brevo. If you never open the chat, nothing in the table below ever reaches your device.

From the moment you do open it, Brevo stores a conversation identifier so that our reply can reach you and the thread can be found again if you come back. Without it the conversation you just asked for cannot work, so this storage is strictly necessary to the service you requested and we do not ask for separate consent for it — but it remains entirely your choice, because it only happens if you open the chat.

What you write in the chat reaches Brevo and us, and is used solely to answer you. Please do not enter sensitive data into the chat.

More about Brevo’s processing: brevo.com/legal/privacypolicy

4. What we store in the application (app.layro.ro)

In the application we store only what is strictly necessary for it to work — to keep you signed in and to remember your language. This requires no consent, as it is indispensable to the service you asked for. We do not track how you use your projects, drawings or discussions.

We do count the steps someone goes through when creating an account (section 4.3), so that we know how many of the people who start signing up manage to finish. That measurement stores nothing on your device, which is why the application does not ask you for a separate consent.

You can clear this at any time, but doing so will sign you out of the application.

4.1 Error monitoring (Sentry)

The application is watched by Sentry, a service that tells us when something breaks. If an error occurs, your browser sends us a technical report: the error message, the place in the code where it happened, your browser type, the application version, and the last few pages you moved through.

It stores and reads nothing in your browser. It sets no cookies, writes nothing to Local Storage, and uses no other form of device storage, so Art. 4(5) of Law no. 506/2004 does not apply and we do not ask for your consent for it. It does not record your session or screen — the Sentry feature that could do so is switched off — and it does not measure how you use the application.

Reports are cleaned before they leave your browser: identifiers in page addresses are replaced with generic placeholders, and tokens carried in links — the client invitation, account activation, password reset — are stripped out. We do not send your name, email address, password or project content, and your IP address is not stored. What is collected, how long it is kept and on what basis — our legitimate interest in fixing faults — is set out in our Privacy Policy, sections 4, 6, 8 and 9.

Information about Sentry’s own processing: sentry.io/privacy

4.2 Signing in with Google

Besides a password, you can create your account and sign in with your Google account. The Sign in with Google button is not drawn by us but by a library supplied by Google — for users in the European Economic Area, Google Ireland Limited — which the page fetches from accounts.google.com.

It loads only on the sign-in and registration pages. It is not loaded when the application starts and appears nowhere else in it. If you are already signed in, or if you are a client invited to a project — who enters through the link in the invitation, without an account — Google’s code never reaches the page at all.

Unlike the chat in section 3.3, this load cannot be deferred to your first click, because the button is drawn by Google itself: the code is fetched the moment you open the sign-in page, whether you then choose Google or your password. We treat that as strictly necessary to the service you asked for — getting into your account, on the page that exists for exactly that purpose — and we do not ask for separate consent for it. If you would rather it did not happen at all, the email-and-password form remains fully functional, and accounts.google.com can be blocked in your browser settings without affecting the rest of the application.

We store nothing extra for it. If you sign in with Google, the application keeps exactly the same session tokens listed in the table at the top of this section and nothing more; we never receive or store your Google password. Google, however, may use cookies on its own domains, as on any visit to a Google service.

Through this, Google learns that you signed in to Layro, and we learn from Google your email address, your name and an identifier for your Google account. What Google does with its own data, and how you manage the applications connected to your Google account, is governed by Google’s policy, not ours. What we receive and how long we keep it is in our Privacy Policy, sections 4, 6, 9 and 10.

Information about Google’s own processing: policies.google.com/privacy

4.3 Measuring sign-up (PostHog)

We use PostHog to count the steps someone goes through when creating an account: how many people open the register form, how many submit it, how many are rejected by the server, and how many go on to activate the account from the email they receive. Without that count we cannot tell a form nobody finds from a form people abandon.

Nothing is stored on your device. As with the error monitoring in section 4.1, PostHog runs here in cookieless mode: it writes and reads no cookie and nothing in Local Storage. The visitor identifier is built on PostHog's own server from the request metadata and a secret value that changes daily. Because nothing is stored in your terminal equipment, art. 4(5) of Romanian Law 506/2004 does not apply and the application does not ask you for a separate consent; the processing rests on legitimate interest (section 6).

What is measured, and what is not. Only the five sign-up events are sent, each raised explicitly by the application. The rest of the application reports nothing:

• pages, clicks and scrolling are never captured automatically, so moving through projects, phases and drawings produces no event at all;
• there is no session or screen recording, no click maps and no in-app surveys;
• we do not send your name, your email address, your password or the contents of the form. When the server rejects a registration we send only the reason code (for example “that address is already in use”);
• page addresses are cleaned before they are sent, through the same allowlist used for error reports, so the activation key from your email link and the identifiers of your projects never leave the browser.

If you reached the application from an advertisement, the address may carry the campaign parameters passed on from the website (section 3.2). We attach them to these five events so that we know which campaign brought a new account. They are not stored on your device and they are not sent back to the advertising network.

More about PostHog's processing: posthog.com/privacy

4.4 Feedback: ideas, bug reports and what’s new (Canny)

The application has a Feedback page — for clients invited to a project, a tab of the same name in the portal — where you can suggest new features, vote on other people’s suggestions, report a problem and read what we have recently shipped. The boards and the list of updates are provided by Canny, a service of Canny Inc., a company based in the United States.

It does not load until you open the page. Like the chat in section 3.3, the Canny program is only fetched into the browser when you open Feedback. Until then nothing is stored or read in your browser for this service and no request is made to Canny. If you never open the page, nothing in the table below ever appears on your device.

You do not need a Canny account: the application tells Canny who you are through a token signed by our server, so that your suggestions and votes are recorded under your name. Canny then stores in your browser what the boards cannot work without — your session and security measures. That storage is strictly necessary for the service you asked for by opening the page, so we do not ask for separate consent to it. Canny’s non-essential cookies, including its analytics cookies, are switched off in our configuration.

When you open the page, Canny receives your name, email address and an identifier, and after that whatever you write and vote on there. It does not receive the content of your projects. What is processed, for how long and on what basis is set out in our Privacy Policy, sections 4, 5, 6, 8, 9 and 10.

Information on the processing carried out by Canny: canny.io/privacy

The application also has the Help page described in section 3.3 — for clients invited to a project, the same section appears as a tab in the portal. It behaves identically: the chat is neither loaded nor stores anything until you open that page yourself.

5. What we do not use

Layro does not use:

• advertising, remarketing or retargeting cookies;
• social media plugins that set tracking identifiers (Facebook Pixel, Google Ads and the like). Signing in with Google, described in section 4.2, is not one of these: it is a sign-in method you choose, used solely to get you into your account, not an advertising, remarketing or behavioural measurement tool;
• session or screen recording — neither on the website nor in the application;
• behavioural tracking in the app.layro.ro application: moving through projects, phases and drawings produces no event. Neither the error monitoring in section 4.1 nor the sign-up measurement in section 4.3 is that: the first fires only when the application breaks, the second counts only the five steps you pass through to create an account, and neither stores anything in your browser.

6. Legal basis

• Strictly necessary storage — Art. 4(5) of Law no. 506/2004 permits storage without consent where it is strictly necessary to provide the service the user requested. The corresponding data processing rests on performance of the contract or, as the case may be, on legitimate interests — Art. 6(1)(b) and (f) GDPR;
• Cookieless measurement — because we neither store nor read anything in your terminal equipment, Art. 4(5) of Law no. 506/2004 does not apply and we do not ask for your consent. Processing the technical data is still processing of personal data, and it rests on legitimate interests — Art. 6(1)(f) GDPR. The interest pursued is knowing whether the site is read and which sections are useful, so that we can improve it. We weighed that interest against your rights and limited the processing accordingly: nothing is stored on your device, we build no profiles, we do not follow you onto other sites, the server-side identifier changes daily, and the data is neither used for advertising nor sold. You may object to this processing at any time under Art. 21 GDPR — see section 7;
• The support chat — Art. 4(5) of Law no. 506/2004, storage strictly necessary to provide the service requested: it happens only once you have opened the conversation yourself, and only so that you can hold it. Processing the messages rests on our legitimate interest in answering enquiries we receive — Art. 6(1)(f) GDPR — or, where the exchange concerns entering into a contract, on Art. 6(1)(b) GDPR;
• Signing in with Google — Art. 4(5) of Law no. 506/2004, storage strictly necessary to provide the service requested: Google’s code is loaded only on the sign-in and registration pages, which exist precisely to get you into your account. Processing the data we receive from Google rests on performance of the contract or, when the account is created, on steps taken at your request prior to entering into it — Art. 6(1)(b) GDPR;
• The feedback page in the application — Art. 4(5) of Law no. 506/2004, storage strictly necessary to provide the service you requested: the Canny program loads only after you have opened the page yourself, and its non-essential cookies are switched off. Processing the data sent to Canny rests on our legitimate interest in receiving and answering your suggestions and reports — Art. 6(1)(f) GDPR;
• Error monitoring in the application — we store and read nothing in your terminal equipment, so Art. 4(5) of Law no. 506/2004 does not apply and we do not ask for your consent. Processing the technical data in the error report rests on our legitimate interest — Art. 6(1)(f) GDPR — in keeping the application working and repairing faults. You may object at any time under Art. 21 GDPR;
• The stored identifier and the wider website measurement — that is, the identifier in Local Storage and in the cookie on layro.ro, together with the automatic capture of clicks and the click and scroll maps (section 3.2) — your prior consent, given by pressing “Accept” in the banner, under Art. 4(5) of Law no. 506/2004 and Art. 6(1)(a) GDPR. Consent can be withdrawn at any time, as easily as it was given (section 7);
• The sign-up measurement in the application — we store and read nothing in your terminal equipment, so Art. 4(5) of Law no. 506/2004 does not apply and we do not ask for your consent. The processing rests on legitimate interest — Art. 6(1)(f) GDPR — in knowing how many of the people who start creating an account manage to finish, without which we cannot repair a broken sign-up. We weighed that interest against your rights and limited the processing accordingly: five explicitly raised events and nothing about how you use the application afterwards, no name, email address or form contents, nothing stored on your device, and no advertising use. What is measured is set out in section 4.3, and if you would rather not be measured at all, section 7 explains how — the Do Not Track signal, which we honour in the application too, or a written objection under Art. 21 GDPR.

7. Changing or withdrawing your choice

You can change your choice at any time, with no consequence for your use of the site:

• click Cookie settings — the link also sits in the footer of every page. The banner reopens and you can choose again;
• or clear the data stored by the site directly from your browser settings, in the section covering cookies and site data.

If you would rather not be measured at all, including in cookieless mode, you have two routes: switch on the Do Not Track signal in your browser settings — we honour it automatically and send no events — or write to us at contact@layro.ro, exercising the right to object under Art. 21 GDPR.

Instructions for the main browsers:

• Google Chrome — Settings → Privacy and security → Cookies and other site data Chrome guide
• Mozilla Firefox — Settings → Privacy & Security → Cookies and Site Data Firefox guide
• Safari — Preferences → Privacy → Manage Website Data Safari guide
• Microsoft Edge — Settings → Cookies and site permissions Edge guide

8. Where the data is stored

Data collected through PostHog is stored on PostHog’s infrastructure in the European Union (Frankfurt, Germany). Application data is hosted by Amazon Web Services, also in Frankfurt. Chat conversations are processed by Brevo SAS, which states that it stores its customers’ data in the European Union. The application’s error reports are stored in Sentry’s European Union data region; Sentry is a US provider whose engineering staff may access them from the United States, under the Standard Contractual Clauses. Signing in with Google is provided, in the European Economic Area, by Google Ireland Limited, which may process sign-in data outside the EEA in accordance with its own policy. Suggestions, bug reports and votes on the feedback page are stored by Canny Inc. in the United States, under the Standard Contractual Clauses. Full details of recipients, and of the situations in which data may travel outside the European Economic Area, are in our Privacy Policy.

9. Changes to this policy

We update this policy whenever we add or remove a tool that stores information in your browser. The date of the last update is shown at the top of the page. If we introduce new tools requiring consent, we will ask for your agreement again before activating them.

10. Related documents and contact

• Privacy Policy
• Terms & Conditions

For any question about this policy, write to us at contact@layro.ro.