Legal information
Privacy Policy
To be reviewed by a legal adviser before being treated as final. The text below describes exactly what the association’s system does today; the legal wording remains to be confirmed. Updated on 6 August 2026 with the health file and the litter announcements — an addition that remains to be adopted by its own decision.
Who processes the data
Asociația Club Federal Chinologic – Royal, Tax ID 48828041. E-mail for any matter concerning personal data: contact@cfc-royal.ro.
The association is not legally required to appoint a data protection officer. Requests go directly to the address above and are answered within 30 days at the latest.
What we process, and why
We do not process data “in general”. Each activity has its own data, its own legal basis and its own retention period.
1. Communication and the contact form
Name, e-mail address, the message you write. Basis: the legitimate interest in answering the person who writes to us (Art. 6(1)(f)).
2. Membership
Name, contact details, county, subscription record, access code — kept only as a cryptographic fingerprint; the code itself is stored nowhere. Basis: performance of the membership relationship and the association’s legal obligations (Art. 6(1)(b) and (c)).
The membership application (the online “Become a member” form): name, e-mail, telephone, town/county, anything you write in the form and, optionally, the proof of payment of the joining fee. Your consent is recorded together with the exact text and version you ticked. The application follows the road set by the Internal Regulations (secretariat check, Board opinion, General Assembly decision), and each step stays in its history. Basis: steps taken at your request prior to entering the membership relationship (Art. 6(1)(b)).
Membership fee payments declared online: your declaration, the attached proof of payment and the resulting new term. The proof is seen only by the registry office and the administrator. Renewal reminders are sent automatically to the address in your membership record. Basis: performance of the membership relationship (Art. 6(1)(b)).
3. Show entries
The owner’s name and contact details, address, the dog’s details, the documents uploaded (pedigree, health record) and the proof of payment of the entry fee. Proof of payment is seen by the registrars and the administrator; it reaches no one else. Basis: performance of the participation contract (Art. 6(1)(b)).
4. The stud book
Breeder and owner details, the documents filed for the Mating and Whelping Declaration, scans of the ancestors’ pedigrees, the series of the certificates issued. Basis: keeping the record of origins, as an organisation affiliated to the World Dog Federation, and performance of your request (Art. 6(1)(b) and (f)).
On the public dog record and when a certificate is checked through its QR code, the microchip is shown masked — only the last four digits. Enough to recognise your own dog’s record or to compare it with the document in your hand, not enough for anyone else to use it. The full number is seen only by the registry office, the administrator and the breeder the file belongs to.
Ownership transfer of a dog: the new owner’s name, e-mail, town and (optionally) address, written by the seller; the new owner’s confirmation, given through the link received by e-mail, stands in for a signature. When the transfer is recorded, the new owner’s name and town go onto the certificate and into the stud book, and the previous owner remains in the document’s history; the e-mail address never goes onto the document. Basis: performance of the parties’ request and keeping the record of origins (Art. 6(1)(b) and (f)).
Homologation of champion titles: the applicant’s name and e-mail (the applicant may not be a member), the dog’s reference and the title requested. Basis: performance of your request (Art. 6(1)(b)).
Service orders (Performance Record Book, Starter Pack, priority dispatch, urgent processing, corrections): the service requested, the details you write and the proof of payment — seen only by the registry office and the administrator. Basis: performance of the contract (Art. 6(1)(b)).
5. The dogs’ health file
The dog’s microchip, the results of the tests filed (hip and elbow dysplasia, eye examination, DNA, genetic tests), who issued them (a vet or a laboratory) and the scanned certificate. The tests are optional. The certificate is seen by the registry office, which verifies it before the result appears publicly on the dog’s record; the record shows the verified result, not the document. The health data is about the dog; the certificate may additionally carry the name of the vet or of the owner, as printed on it. Basis: performance of the member’s request and the association’s legitimate interest in attesting the quality of breeding (Art. 6(1)(b) and (f)).
6. Litter announcements
When a breeder publishes a litter announcement, they choose which contact is shown publicly — name, telephone, e-mail — and how many puppies are available. The announcement is tied to one of their Mating and Whelping Declarations, is approved by the registry office and stays public for at most 90 days, after which it is withdrawn automatically; it can be withdrawn earlier, at any time. No prices are shown. Basis: the breeder’s consent, publishing their own contact (Art. 6(1)(a)) — withdrawn by withdrawing the announcement.
7. The School of Judging
Candidate details, progress through the modules, test and examination results, ring assistantships, appeals and their grounds, acceptance of the Code of Ethics. Basis: performance of the training relationship and the association’s legitimate interest in being able to evidence the training of the judges it authorises.
8. The newsletter and the School bulletin
The e-mail address, nothing more — plus the proof of consent: the text you ticked, its version, the moment of the request and of the confirmation, and a fingerprint of the IP address they came from (not the IP itself). The law requires us to be able to demonstrate that consent was given (Art. 7(1)), and that proof is the only thing that protects you if anyone were to claim otherwise. Basis: your consent (Art. 6(1)(a)).
Subscribing takes two steps: you ask from the site, then you confirm from an e-mail sent to that address. Without the second step the address goes nowhere — and the request deletes itself after 48 hours. That way nobody can subscribe you in your place.
Withdrawal takes a single click, from any message you receive: the link at the bottom removes the address on the spot, with no code, no form and no questions asked. The proof of consent remains, with the moment of withdrawal written into it — so that we can show, if needed, exactly when you left.
9. Audit log and system security
Who did what in the registry and when, the IP address of sensitive requests, the tokens of recognised devices, the count of failed sign-in attempts. Basis: the legitimate interest in being able to prove who issued a document and in defending the system against unauthorised access.
This also covers the intrusion watchdog: on every wrong code we record what kind of entrance was attempted, in which hour, and from which IP fingerprint — never the address itself and never the code that was tried. Without these notes there would be no way to tell someone who forgot their code from someone methodically looking for a way in. They delete themselves after 30 days.
10. Photographs taken at events
See the section below.
How long we keep data
| What | How long | Why that long |
|---|---|---|
| Contact messages | 2 years | as long as correspondence and its consequences may last |
| Member data | for the duration of membership + 5 years | the general limitation period |
| Membership application, rejected or not completed | 3 years | as long as the decision can be contested; an admitted application becomes part of the member’s file |
| Ownership transfer file | permanent | the evidence behind the change of owner on the certificate |
| Title homologation request | 5 years | as long as a homologated title can be contested |
| Service orders | 3 years | the consequences of an order; proofs of payment follow their own row (10 years) |
| Show entries | 3 years after the show | appeals, checks, statistics |
| Proof of payment | 10 years | the statutory retention period for financial records |
| Stud book (declarations, pedigrees, ancestry) | permanent | a certificate of origin must remain verifiable at any time |
| Health file (verified results, scanned certificates) | permanent, as part of the breeding record | the evidence behind the breeding recommendation |
| Litter announcement (contact published by the breeder) | public for at most 90 days, then withdrawn; the request stays in the audit log | it is a passing notice, not a record |
| Judging candidate’s file | during training + 10 years after authorisation | a judge must be able to evidence their training |
| Appeals and decisions | 10 years | evidential value and precedent |
| Bulletin address | until unsubscribed | |
| Proof of consent to the bulletin | 3 years from withdrawal | as long as a message received can be disputed |
| Unconfirmed subscription request | 48 hours, then deleted automatically | without confirmation there is no consent, hence no basis to keep it |
| Audit log | 5 years | as long as an issued document may be challenged |
| IP addresses, device tokens, attempt counters | 30 days | they expire on their own and are not restored from backups |
| Event photographs | until withdrawal is requested | the archive of the association’s activity |
Backups are encrypted and rotate. Once deleted from the system, a personal record also leaves the backups within 12 months at the latest.
Who receives the data
Some data is public by the very nature of the registry: the stud book shows the dogs that hold a certificate, with the breeder’s name and the kennel affix — the owner stays masked. In a litter announcement, the contact shown is the one the breeder chooses to make public. Otherwise, we neither sell nor rent data to anyone. It is seen only by:
- inside: the administrator; the registrars (entries, members, proof of payment); the School’s lecturers — only the candidates assigned to them; the examination board — only its own session;
- outside, only the providers the system needs in order to work:
| Provider | For what | Where |
|---|---|---|
| Netlify | hosting of the site and the data stores | USA (standard contractual clauses) |
| GitHub | the code and the encrypted backups | USA (standard contractual clauses) |
| Brevo | automated messages and the bulletin | European Union |
| Zoho Mail | the association’s mailbox | European Union |
| Vercel, Neon | the “Judging exercises” application | European Union |
| Cloudflare | the secure link to the show manager, on show day | USA (standard contractual clauses) |
| Anthropic | reading the parents’ pedigree certificates when a litter is registered | USA (standard contractual clauses) |
The last one in full, because it is the newest and the easiest to misread: when registering a litter, the registry office may request an automated reading of the two parents’ pedigree certificates, so that thirty ancestry positions need not be copied by hand. Only those two documents leave — not the proof of payment, not the buyers’ details, not the rest of the file. Besides data about the dogs, such certificates carry the owners’ names as printed on the document. The reading is started by a person, on a specific file; it never runs on its own. The provider does not use these documents to train its models. The result is a proposal shown to the registrar — nothing enters the register without their decision.
Data may also reach the authorities upon a legally founded request and — for the titles awarded — the World Dog Federation, strictly as far as necessary for their international recognition.
How we protect the data
Access is by role, with personal codes; codes are never stored in the clear. Operations that take data out of the system require a second factor — a recognised device. Study materials carry a watermark with the name of the person reading them. Every important act remains in the audit log. Backups are encrypted with a password held only by the association.
Photographs taken at events
At shows and events organised or hosted by the association, photographs are taken and may be published on the site and on the official pages, in order to document the association’s activity. A notice to this effect is displayed at the entrance.
Basis: the association’s legitimate interest in documenting its public activity (Art. 6(1)(f)).
If you appear in a published photograph and do not wish to, write to us at contact@cfc-royal.ro and we will take it down — without asking for reasons and with no consequence for you. We do not publish photographs in which a child is the main subject without the consent of a parent or guardian.
Your rights
You have the right to request access to your data, its rectification, erasure, restriction of processing, portability, and to object to processing based on legitimate interest. Where the basis is consent, you may withdraw it at any time, without affecting what was processed before.
One limit we state plainly from the outset: the stud book cannot be erased. A certificate of origin, once issued, has effects towards third parties — buyers, breeders, other organisations — and erasing it would make it impossible to verify a document that circulates in the world. What can be done is to rectify incorrect data and to restrict its use for other purposes.
Requests can be filed through the personal data requests form or at contact@cfc-royal.ro; we reply within 30 days. So that we do not hand your data to someone else, we may ask you for proof of identity before acting.
If you consider that we have infringed your rights, you may address the National Supervisory Authority for Personal Data Processing (anspdcp.ro) or the courts.