隐私政策

1. Who we are

ALComm Solutions Sh.p.k. is the data controller for the personal data described in this policy.

This policy applies to visitors of www.alcomm.al, people who contact us or request an offer, representatives of our clients, suppliers and partners, job applicants, and visitors at our premises and project sites. It does not apply to third-party websites we link to, or to personal data we process solely on behalf of a client under a service contract.

2. Legal framework

We process personal data under Law No. 124/2024 “On the Protection of Personal Data” of the Republic of Albania, in force since 1 February 2025 and aligned with Regulation (EU) 2016/679 (GDPR). Where we offer goods or services to individuals in the EU, or monitor their behaviour there, the GDPR applies directly in addition to Albanian law.

• Personal data — any information relating to an identified or identifiable natural person.
• Processing — any operation performed on personal data, including collection, storage, use, disclosure and deletion.
• Controller — the party that determines the purposes and means of processing: ALComm Solutions Sh.p.k.
• Processor — a party that processes personal data on the controller’s instructions.
• Data subject — the individual the personal data relates to.

3. Personal data we collect

We collect only what we need for the relationship we have with you. We do not sell personal data.

We do not knowingly collect special categories of data through the website. Where a specific project or employment obligation requires such data, we process it only on a legal basis permitted by Law No. 124/2024 and tell you separately at the point of collection. Providing personal data is generally voluntary; if you do not provide data needed to answer an enquiry, issue an offer or perform a contract, we may not be able to proceed.

4. Why we process it, and on what legal basis

We do not use automated decision-making or profiling that produces legal effects for you or similarly significantly affects you.

5. Cookies

Our website uses cookies and similar technologies. Strictly necessary cookies are set automatically; all other categories are set only after you accept them in the cookie banner.

You can change or withdraw your choice at any time through the cookie settings link in the website footer, or block/delete cookies in your browser settings. We do not respond to browser “Do Not Track” signals because there is no agreed standard for interpreting them.

6. Who we share it with

We disclose personal data only where there is a lawful reason and only to the extent needed:

• Service providers acting as processors — hosting, email, IT maintenance, accounting, payroll, CRM, marketing, courier and postal services, each bound by a written processing agreement.
• Manufacturers, distributors and technology partners — where warranty registration, licensing, technical certification or manufacturer support requires it.
• Subcontractors — engineering, installation and maintenance partners engaged on a specific project, limited to the contact and access data needed for that project.
• Professional advisers — external lawyers, auditors and insurers where necessary.
• Public authorities — tax authorities, courts, police and regulators where disclosure is required by law or needed to establish or defend a legal claim.
• Acquirers — in the event of a merger, sale or reorganisation of the business, subject to equivalent protection.

We do not sell, rent or trade personal data, and we do not disclose it for third-party marketing.

7. Transfers outside Albania

Some of our providers are established outside Albania, mainly in the EEA and the United States. Where personal data leaves Albania, we rely on one of the following:

1. The recipient country provides an adequate level of protection recognised under Law No. 124/2024.
2. Standard contractual clauses or equivalent appropriate safeguards are in place with the recipient.
3. Authorisation from the Commissioner has been obtained where the law requires it.
4. A derogation applies, such as your explicit consent or necessity for the performance of a contract.

You can request details of the safeguards applied to a specific transfer by writing to privacy@alcomm.al.

8. How long we keep it

When a retention period ends, we delete the data or anonymize it. Where deletion is not technically possible — for example in encrypted backups — we isolate the data and delete it on the next backup cycle.

9. Security

We apply technical and organisational measures appropriate to the risk, including:

• Encryption of data in transit (TLS) and at rest on company devices and servers.
• Role-based access control granted on a need-to-know basis and reviewed periodically.
• Multi-factor authentication on email, cloud and administrative accounts.
• Network segmentation, firewalls and endpoint protection.
• Regular backups with restoration tested periodically.
• Confidentiality undertakings and data protection training for staff.
• Written processing agreements with all providers that handle personal data on our behalf.
• Logging and monitoring of access to systems holding personal data.

If a personal data breach is likely to result in a risk to your rights and freedoms, we notify the Commissioner within 72 hours of becoming aware of it, and inform affected individuals without undue delay where the risk is high.

10. Your rights

To exercise any right, write to privacy@alcomm.al or to Rr. Todi Shkurti, Nr. 8/4, Tiranë. We respond within one month. We do not charge a fee unless a request is manifestly unfounded or excessive.

11. Complaints

If you believe we have processed your personal data unlawfully, please contact us first at privacy@alcomm.al. You also have the right to lodge a complaint with the supervisory authority:

You may also bring proceedings before the competent Albanian courts.

12. Children and video surveillance

Children. Our website and services are directed at businesses and public institutions, not at children. We do not knowingly collect personal data from anyone under 16. If you believe a child has provided us with personal data, contact privacy@alcomm.al and we will delete it.

Video surveillance. We operate CCTV at our offices, warehouse and certain project sites for the security of people, property and equipment. Cameras are signposted at every monitored entrance. Footage is retained for 30 days unless needed for an incident under investigation or a legal claim. Cameras are not installed in areas where people have a reasonable expectation of privacy, and footage is not used to monitor employee performance. Access to recordings is restricted to authorised personnel and is logged.

13. Changes to this policy

We review this policy at least once a year and update it when our processing activities or the applicable law change. The version in force is the one published at www.alcomm.al with its effective date shown at the top. Where a change materially affects how we use your personal data, we will notify you by email or through a notice on the website before it takes effect.