DRAFT: to be checked by a lawyer before publication. Not legal advice. Everything in
[SQUARE BRACKETS]must be filled in or confirmed. SeeCHECKLIST.md. If the two language versions differ, the Albanian version prevails. [LAWYER: confirm] Version: draft 1, 2026-11-04.
Privacy Policy
Union Cleaning & Facility Services SHPK Last updated: [PUBLICATION DATE]
This policy explains how we collect, use and keep your personal data when you visit our website unioncleaning.al, message us on WhatsApp, call us, ask for a quote or book a cleaning service.
We process personal data under Albanian Law No. 124/2024 “On Personal Data Protection” (Official Gazette No. 9, 17 January 2025), which is aligned with the EU General Data Protection Regulation (GDPR, Regulation (EU) 2016/679). For customers from the European Union (for example tourists or owners of short-term rental apartments), we apply the same standards as the GDPR.
1. Who we are (the controller)
| Legal name | UNION CLEANING & FACILITY SERVICES SHPK |
| NIPT (tax ID) | M62230023J |
| Address | Rruga “Naim Frashëri”, property no. 4/225, ZK 8210, Tirana, Albania |
| Phone / WhatsApp | +355 6X XXX XXXX [PLACEHOLDER — public number to be confirmed] |
| Privacy email | info@unioncleaning.al |
We have not appointed a Data Protection Officer (DPO), because our activity does not involve large-scale systematic monitoring or large-scale sensitive data. [LAWYER: confirm.] For any question, contact us at the details above.
2. What data we collect
Data you give us:
- Contact: first and last name, phone / WhatsApp number, email.
- Service details: property address, city, property type (e.g. 2-bedroom), size in m², preferred date and time, special notes (pets, product allergies, how to get in, gate or key-box codes).
- Photos of the premises that you send us for a quote, or that we take before and after the job (see section 4).
- Billing: business name, NIPT, billing address, payment method. We do not store full card numbers.
- Communications: WhatsApp messages, emails and notes from phone calls.
- Complaints and reviews you send us.
- Job applications (“Careers” page): CV, experience, contact details.
Data collected automatically when you visit the website:
- Technical data (IP address, browser, device, pages visited) through cookies and similar technologies: only strictly necessary cookies, or others after you consent. See our Cookie Policy.
We do not ask for sensitive data (health, religion, etc.). If you tell us something like that yourself (e.g. an allergy), we use it only to do the job safely.
3. Why we use it, and the legal basis
| Purpose | Legal basis |
|---|---|
| Answering your request for a quote or information | Steps before entering a contract, at your request |
| Booking, doing the job, scheduling messages | Performance of the contract |
| Invoicing, fiscalisation, accounting | Legal obligation (tax and accounting law) |
| Handling complaints, the guarantee and damage claims | Performance of the contract; legitimate interest |
| Before/after photos for quality control and resolving disputes | Legitimate interest |
| Publishing before/after photos on the website or social media | Only with your consent |
| Marketing messages (offers, reminders) | Your consent; or, for existing customers, legitimate interest for similar services, with the right to opt out at any time [LAWYER: check the Commissioner’s Instruction on direct marketing] |
| Website analytics and advertising (Google, Meta) | Your consent through the cookie banner |
| Website security and abuse prevention | Legitimate interest |
| Reviewing job applications | Steps before entering an employment contract |
| Defending our legal rights | Legitimate interest |
You can withdraw consent at any time. This does not affect processing done before you withdrew it.
4. Photos of the premises
Our team may take photos before and after cleaning for quality control and to resolve complaints or damage claims. We try not to photograph people, documents, screens or personal items. These photos are kept for [180 days] and are not published. They are published only if you give separate written consent (WhatsApp is fine), and without the address or details that identify you.
5. Who we share data with
We do not sell your data. We share it only with:
- Our staff who do the job (only what they need: address, time, access instructions). They are bound by confidentiality.
- Service providers working for us (processors): website hosting [NAME], email [Google Workspace / other], WhatsApp Business (Meta), form / booking tool [NAME], invoicing/fiscalisation software [NAME], accountant [NAME].
- Analytics and advertising providers (Google, Meta): only if you accepted those cookies.
- Authorities (e.g. the General Directorate of Taxes, courts, police) where the law requires it.
- Our insurer or legal advisers, if there is a damage claim.
6. Transfers outside Albania
Some providers (e.g. Google, Meta) may process data in EU/EEA countries, which are considered to offer an adequate level of protection, or in the United States and other countries. For transfers outside the EU/EEA we rely on appropriate safeguards, such as the provider’s standard contractual clauses. [LAWYER: confirm the basis for US transfers under Articles 39–41 of Law 124/2024.] You can ask us for a copy of these safeguards.
7. How long we keep it
| Data | Period |
|---|---|
| Quote requests that did not become a booking | [12 months] from the last contact |
| Customer data and service history | During the relationship and [3 years] after the last service |
| Invoices and accounting records | As required by accounting and tax law [LAWYER: confirm, e.g. 10 years] |
| Before/after photos | [180 days], or longer if a complaint/claim is open |
| Access codes and keys | Deleted/returned right after the job, except for recurring plans by agreement |
| Marketing messages | Until you withdraw consent |
| Job applications | [6 months], or longer with your consent |
| Cookies | See the Cookie Policy |
8. Your rights
You have the right to:
- be informed and access your data;
- have inaccurate data corrected;
- have your data erased (“right to be forgotten”);
- restrict processing;
- object to processing based on legitimate interest, and to direct marketing at any time;
- receive your data in a readable format (portability);
- withdraw consent at any time;
- not be subject to decisions based solely on automated processing (we make no such decisions).
To use these rights, write to info@unioncleaning.al or WhatsApp. We answer within 30 days [LAWYER: confirm the statutory deadline]. We may ask you to confirm your identity.
9. Complaints
If you think we have processed your data unlawfully, please contact us first. You also have the right to complain to:
Commissioner for the Right to Information and Personal Data Protection (Komisioneri për të Drejtën e Informimit dhe Mbrojtjen e të Dhënave Personale) Rr. “Abdi Toptani”, Nd. 5, Postal Code 1001, Tirana — www.idp.al
If you live in the EU/EEA, you can also contact the data protection authority in your country.
10. Security
We use reasonable technical and organisational measures: encrypted connections (HTTPS), password-restricted access, staff training and confidentiality. Access codes are not written in shared group chats. If a security breach puts your rights at risk, we notify the Commissioner within 72 hours and, where the risk is high, we notify you as well.
11. Children
Our services are for adults. We do not knowingly collect data from children under [16].
12. Changes
We may update this policy. The date at the top shows the latest version. We will tell you about important changes on the website or by message.
Short notice for the quote/booking form
(placed under the “Send” button)
When you send this form, we use your details to give you a quote and arrange the service. Read our Privacy Policy.
☐ I’d like to receive offers and reminders from Union by WhatsApp/email. (optional, not pre-ticked)
First automatic WhatsApp Business message
Hello! Thank you for contacting Union Cleaning. We use the details you send here only for your quote and service. More: [Privacy Policy link].