Clearsource — EU public data APIs
Effective .

Terms of use for the Clearsource data actors on Apify

Version 1.0, effective .

These terms apply when you run one of the data tools (“actors”) that PPFTEC S.R.L. publishes on the Apify platform. They add to Apify’s Standard Actor Contract; they do not replace it.

1. Who we are and what these terms cover

1.1 These terms apply to the data actors published on the Apify platform by PPFTEC S.R.L., Str. Patriarh Iustinian Marina nr. 17-19B, bl. DC12, mansardă, ap. 25, Râmnicu Vâlcea, jud. Vâlcea, 240469, Romania, CUI 55537142, trade register no. J2026052999008 (“PPFTEC”, “we”). Contact: support@ppftec.com. Company website: https://ppftec.com. Product website: https://clearsource.ppftec.com.

1.2 By running one of our actors you (“the customer”, “you”) accept these terms. If you do not accept them, do not run the actors.

1.3 The actors covered are:

  • ted-tenders: EU public tenders from TED (Tenders Electronic Daily);
  • ro-company-status: status of Romanian businesses from the public web service of the Romanian tax administration (ANAF), in lookup mode and in watch mode;
  • ro-procurement-monitor: Romanian direct purchases and contracts from the open data published on data.gov.ro. This actor is not yet publicly available on Apify Store. The parts of these terms that concern it apply from the day it is made available to you.

Each actor’s description on Apify states which public source it uses.

1.4 These terms do not cover our HTTP API, SDK or MCP server, which will have their own terms.

2. What the service is and is not

2.1 Each actor retrieves data that a public body publishes, normalises it and delivers it to your Apify account with its provenance: the source URL, the retrieval time (UTC), the source version, and the licence and attribution text.

2.2 We are not a public authority. We are not affiliated with, approved by or endorsed by ANAF, the Authority for the Digitalisation of Romania (ADR), the Publications Office of the European Union, the European Commission or any other source body. Our actors do not issue official certificates.

2.3 The actors run on the Apify platform under your own contract with Apify. Apify’s terms (Apify General Terms and Conditions and Apify Actor Terms and Conditions) apply to your use of the platform. Your use of our actors is also governed by the Apify Standard Actor Contract, which applies by default to actors published on Apify Store under the Apify Store Publishing Terms and Conditions. These terms supplement the Standard Actor Contract and do not replace it: they add commitments and safeguards. If these terms and the Standard Actor Contract conflict, the provision that gives you more protection applies. If these terms and Apify’s platform terms conflict on the use of the platform, Apify’s terms prevail.

3. Who may use the actors

3.1 The actors are offered to businesses and professionals acting for business purposes. They are not offered to consumers.

3.2 You must have the authority to accept these terms for the business you represent.

4. Data “as is”; no advice

4.1 Data is delivered as is and as available. It reflects the source at the retrieval time shown on each record. We do not warrant that it is accurate, complete, current or available. Outages, delays and errors at the source pass through to you.

4.2 The official source prevails. For ro-company-status, the ANAF response is authoritative and our output is for information only. For ro-procurement-monitor, the data is quarterly open data published with a delay of weeks; it is not a live tender feed. For ted-tenders, the notice published on TED prevails.

4.3 Outputs are information only. They are not legal, tax, accounting or procurement advice, and they are not a certification, credit opinion or due-diligence report on any business. You remain responsible for your own decisions and legal obligations, including VAT treatment, invoicing and e-invoicing, and for checking critical results at the official source.

4.4 ro-company-status returns no insolvency information. “Not inactive” or “registered for VAT” does not mean that a business is solvent, trustworthy or compliant.

5. Attribution and licences

5.1 Each record carries an attribution text and a licence identifier. When you pass the data on to others, you must keep that attribution and the licence link, state that the data was modified where you modify it, and not suggest that the source body endorses you or your use.

5.2 The attribution texts are:

  • ro-company-status: “Sursa: ANAF”, with the service and the retrieval time;
  • ro-procurement-monitor: “Contains data from Autoritatea pentru Digitalizarea României, data.gov.ro, licensed CC BY 4.0 (https://creativecommons.org/licenses/by/4.0/); modified (normalised, filtered)”;
  • ted-tenders: “Source: TED — Tenders Electronic Daily, © European Union, https://ted.europa.eu”.

5.3 ANAF data is not published under an open licence. Do not label it as licensed under the Open Government Licence (OGL), Creative Commons or any similar licence.

6. Personal data: who is responsible for what

6.1 Your runs. You decide whose data is checked or retrieved, when and why, and you hold the results in your Apify account. For that processing you are the controller under the General Data Protection Regulation (GDPR, Regulation (EU) 2016/679). To the extent PPFTEC processes personal data in your actor input or actor output on your behalf (for example when you share a run with us for support), PPFTEC acts as your processor under clause 5.2 of the Standard Actor Contract and section 7 below.

6.2 Built-in safeguards are part of the actor. Each actor has documented safeguards: the fields it never requests or outputs, the rejection of 13-digit inputs, the minimisation of data about natural-person businesses, the shared rate limit, and the PPFTEC suppression list of people who have objected. They are part of the actor’s functionality as described on its Apify Store page. By running the actor you instruct them. You must not try to disable or work around them.

6.3 What PPFTEC decides alone. PPFTEC is an independent controller for: (a) the objection register and suppression list; (b) the logs of our rate-limit service; (c) the preparation, storage and supply to the actor of the minimised Romanian public-procurement data copy; and (d) your account and billing information that Apify makes available to us. Our privacy notice covers these.

6.4 Your own duties. You are responsible for your lawful basis, your retention, your own duty to inform the people concerned (Article 14 GDPR) where you store or use results, answering data-subject requests about results you hold, and your own transfers. If you are established outside the European Economic Area (EEA), clause 6.6 applies to procurement data.

6.5 Fallback. PPFTEC and you do not jointly determine the purposes of any processing. If a competent authority or court nevertheless finds that we are joint controllers for any operation, clauses 6.1 to 6.4 are our arrangement under Article 26 GDPR, and each party is the contact point for the duties allocated to it. A party that receives a data-subject request concerning the other party’s duties forwards it within 2 working days.

6.6 Customers outside the EEA (procurement data)

Where ro-procurement-monitor delivers procurement data from PPFTEC to a customer established in a country for which the European Commission has not adopted an adequacy decision, the Standard Contractual Clauses adopted by Commission Implementing Decision (EU) 2021/914 of 4 June 2021 (Official Journal L 199, 7.6.2021, p. 31), Module One (controller to controller), are incorporated into these terms by reference, with PPFTEC as data exporter and you as data importer. For Clause 13 the competent supervisory authority is the Romanian data protection authority (ANSPDCP); for Clause 17 we choose the law of Romania; for Clause 18 we choose the courts of Romania.

  • (a) This applies to the extent that your processing of the data is not itself subject to the GDPR.
  • (b) The Annexes to the Clauses are completed as set out in the Appendix to these terms.
  • (c) The optional docking clause (Clause 7) and the optional wording of Clause 11(a) (independent dispute resolution body) are not used.
  • (d) A copy of the Clauses as completed for you is available on request at support@ppftec.com.
  • (e) Nothing in these terms limits or contradicts the Clauses or the rights of data subjects under them. If anything in these terms conflicts with the Clauses, the Clauses prevail.
  • (f) This clause does not apply to ro-company-status or ted-tenders: PPFTEC holds and sends no personal data for them. Your own run obtains the data directly from the public source.

6.7 What we receive from your runs. In normal use we receive no personal data from your runs and keep no copy of your inputs or results. Our rate-limit service receives only a one-way hash of the run ID and the actor version. Our procurement data copy receives only the actor’s authenticated download requests, never your input or output.

7. Shared runs for support (we act as your processor)

7.1 If you turn on Apify’s option to share run data with developers, or send us run data for support, we can see the input, logs and outputs of the shared runs. For that data we act on your behalf and only on your documented instructions, which are: to diagnose and fix the support issue you raised.

7.2 We will:

  • (a) use the data only for that purpose;
  • (b) not copy, export or keep it outside the Apify platform, except for the minimum excerpt needed in a support ticket, which we delete when the ticket is closed;
  • (c) ensure that anyone at PPFTEC who sees it is bound by confidentiality;
  • (d) apply appropriate security measures, including access limited to named maintainers and two-factor authentication on our accounts;
  • (e) not engage another processor for it without your prior written consent (Apify processes it under your own contract with Apify);
  • (f) help you, as far as we reasonably can, to answer data-subject requests and to meet your duties under Articles 32 to 36 GDPR;
  • (g) on request, confirm the deletion of any excerpt we kept;
  • (h) give you the information needed to show that we comply with this section, and allow reasonable audits on 30 days’ notice, at your cost.

7.3 We will tell you without undue delay if we believe an instruction breaches the GDPR, and if we become aware of a personal-data breach affecting shared data.

8. Acceptable use

8.1 You must not use the actors or their outputs:

  • (a) to profile, score, rank or monitor private individuals, or to build files on them;
  • (b) to build contact, marketing or lead lists of natural persons or sole traders, or to send them unsolicited commercial communications;
  • (c) to combine outputs with other sources in order to identify, locate or track natural persons;
  • (d) to try to copy or rebuild a whole register, for example by submitting generated or enumerated identifiers;
  • (e) to submit Romanian personal numeric codes (CNP) or other national identification numbers;
  • (f) to get around source rate limits, terms, logins, paywalls or blocks, or to get around the limits, caps and suppression built into the actors;
  • (g) for any unlawful, discriminatory or harassing purpose;
  • (h) to suggest that a source body or PPFTEC certifies or endorses you, a business or a result.

8.2 Watch mode of ro-company-status is limited to one watch list of up to 5,000 tax codes per Apify account, each company checked at most once per calendar day. Natural-person businesses are not watched. Do not try to get around these limits, for example by using several accounts for one watch list.

8.3 We may refuse, throttle or stop runs, and suspend your access to our actors, if we reasonably believe that you breach this section 8. Where we can, we will tell you why.

9. Shared rate limits and fair use

9.1 Public sources set limits. For ANAF, one request per second with up to 100 tax codes is shared by all users of ro-company-status together. Your run may wait while others run. If our shared rate-limit service is unavailable, runs stop safely: no request is sent to ANAF, and you are not charged for items that were not checked.

9.2 We may change caps, spacing and daily budgets at any time to protect a source.

10. Stopping an actor; requests from source bodies

10.1 We may stop any actor, mode or source at once, without notice, when a source body asks us to stop or changes its terms or limits, when a source becomes unreliable, when we receive a credible legal complaint, or when we see abuse. We will post the reason in the actor’s description or changelog as soon as practical.

10.2 Requests from ANAF and other source bodies go to support@ppftec.com. We act on a request to stop or reduce traffic within 24 hours of receiving it: the affected actor or mode is disabled pending review. We confirm receipt, record the request and its outcome, and reply to the source body.

10.3 Takedown requests from rights holders about content are handled in the same way, at the same address and within the same 24 hours.

10.4 If we stop an actor or mode for these reasons, we are not liable for the interruption, to the extent permitted by applicable law. Pay-per-event charges apply only to results already delivered.

11. Objections by the people in the data

11.1 A natural person who objects to the processing of their data (Article 21 GDPR) can write to support@ppftec.com. For a natural-person business, or for a company whose name contains the person’s name (for example a single-member company named after its owner), we add its tax code to the suppression list within 24 hours of receipt, without asking for proof. From then on the actors neither query nor return it, in any mode; it is removed from our procurement data copy; and watch-list entries for it are deleted on the next run. Details are in our privacy notice.

11.2 If an affected person contacts you about results you hold, you handle the request as controller (clauses 6.1 and 6.4). If they contact us about results you hold, we will direct them to you where we know that you are the holder.

11.3 You must not try to get around the suppression list.

12. Prices and payment

12.1 Prices are pay-per-event on Apify, as shown in the actor’s listing at the time of the run. Invalid, suppressed and duplicate inputs, dry runs and failed requests are not charged. Billing and payment are handled by Apify under your contract with Apify.

12.2 We may change prices in line with Apify’s rules for paid actors.

13. Liability

13.1 To the extent permitted by applicable law, we are not liable for indirect or consequential loss, lost profits, lost tax deductions or tax adjustments, or for decisions you take on the basis of outputs.

13.2 No limitation of liability, whether in these terms or in the Standard Actor Contract, applies to liability under the Standard Contractual Clauses (clause 6.6).

13.3 Nothing in these terms limits or excludes liability that cannot be limited or excluded under applicable law, including liability for intent or gross negligence.

14. Changes and termination

14.1 We may change these terms. The current version and its date are shown on this page and in each actor’s description. Changes apply to runs started after the change. If we materially change section 6, 7 or 8, we will say so in the changelog.

14.2 We may withdraw an actor. Data already in your Apify account stays there under your control.

15. Law and courts

15.1 These terms are governed by Romanian law. The competent courts of Romania have jurisdiction over disputes arising from these terms.

15.2 The Standard Actor Contract remains governed by the law and courts stated in it. For the Standard Contractual Clauses, Clauses 17 and 18 of those Clauses apply as completed in clause 6.6.

16. Contact

PPFTEC S.R.L., Str. Patriarh Iustinian Marina nr. 17-19B, bl. DC12, mansardă, ap. 25, Râmnicu Vâlcea, jud. Vâlcea, 240469, Romania. E-mail: support@ppftec.com (questions, support, requests from source bodies, takedown requests and objections).

Appendix: Annexes I and II to the Standard Contractual Clauses (Module One)

This Appendix completes the Standard Contractual Clauses incorporated by clause 6.6. It concerns only ro-procurement-monitor.

Annex I.A. List of parties

  • Data exporter: PPFTEC S.R.L., Str. Patriarh Iustinian Marina nr. 17-19B, bl. DC12, mansardă, ap. 25, Râmnicu Vâlcea, jud. Vâlcea, 240469, Romania; CUI 55537142; contact support@ppftec.com. Role: controller. Activities: preparing a minimised copy of the Romanian public-procurement open data and supplying it to the ro-procurement-monitor actor. Signature and date: accepted by publishing these terms; date: the effective date of the version in force.
  • Data importer: the user of ro-procurement-monitor, as identified by its Apify account. Role: controller. Activities: retrieving and using procurement records for its own purposes within section 8. Signature and date: accepted by running the actor (clause 1.2); date: the date of the first run.

Annex I.B. Description of the transfer

  • Categories of data subjects: natural persons whose name is part of a company name (for example a single-member company named after its owner); natural persons named in free-text descriptions of purchases or contracts; any natural person wrongly classified as a legal entity despite our filter, which removes too much rather than too little.
  • Categories of personal data: names only, as they appear in company names and free text. No contact data, no addresses, no personal numeric codes (CNP), and no names or tax codes of natural-person suppliers (these are removed before the data enters our copy).
  • Sensitive data: none.
  • Frequency: per run, on the user’s request; only the records that match the user’s filters, up to the run’s result limit.
  • Nature of the processing: delivery of filtered records to the user’s run on the Apify platform.
  • Purpose: analysis of Romanian public procurement (market sizing, bid preparation, research), within section 8.
  • Retention by the importer: the importer’s own retention rules (clause 6.4), never longer than the purpose requires.
  • Onward transfers: only under Clause 8.7 of the Clauses.

Annex I.C. Competent supervisory authority

Autoritatea Națională de Supraveghere a Prelucrării Datelor cu Caracter Personal (ANSPDCP), Romania, https://www.dataprotection.ro.

Annex II. Technical and organisational measures

Measures taken by the data exporter:

  • Before the data enters our copy: supplier names and tax codes are kept only where the name carries a clear legal-entity form, and removed in every other case; identifiers of 13 or more digits are removed; e-mail addresses, phone numbers and personal numeric codes (CNP) in free text are replaced; each file passes a verification step before upload.
  • Storage in the European Union (Cloudflare R2, EU jurisdiction). Access only with a secret read key held as an Apify secret, never in source code, logs, datasets or actor descriptions. Requests without a valid key are refused. The key is rotated after any suspected leak and at least every 6 months.
  • A suppression list of people who have objected, applied when the copy is built and again on every read.
  • Retention: at most the 8 most recent quarters, and never longer than data.gov.ro shows the same record.
  • Maintainer accounts use two-factor authentication.

Measures expected from the data importer: access to results limited to staff who need them; no search, profiling or contact-list building about natural persons (clause 8.1); deletion when the data is no longer needed.

Versions

  • Version 1.0, effective : first published version.

Previous versions will be available on request.