This Privacy Policy on Personal Data Protection sets out how we, Iulian Cozma Outdoor adventures, collect, store and use your personal data when you access or interact with our website mountainguide.ro, and where we obtain or collect your data.
This Privacy Policy is applicable as of 1.05.2018.
- PURPOSE AND SCOPE OF THIS NOTICE
Iulian Cozma Outdoor adventures respects your privacy and is committed to protecting your personal data. This notice on the processing of personal data (hereinafter referred to as the “Notice”) is intended to provide you with relevant information on how we process your personal data when you visit our website or when you provide us by any other means with your personal data (such as: telephone, email), when you purchase tourist services, when you participate in a trip or when you request an offer from us, etc. This website is intended only for persons of age and the only situations in which we collect data relating to children are when you book tourist offers and for your children. This Notification informs you about the personal data processing operations (as defined by the relevant legislation on the matter, including the General Data Protection Regulation 2016/679 – hereinafter referred to as “GDPR”) carried out by Iulian Cozma Outdoor adventures, in consideration of its capacity as a personal data controller. The controller of your personal data is Step by Step Agency S.R.L. and it is responsible for your personal data (hereinafter referred to as “Iulian Cozma Outdoor adventures “, “we” or “us” or “our” or “travel agency” in this Notice).
- CONTROLLER OF YOUR DATA PERSONAL DATA AND CONTACT DETAILS OF THE DATA PROTECTION OFFICER
The controller of your personal data is Step by Step Agency S.R.L., having its registered office in Ucea de Sus, nr. 109, CUI: 14370100, registered with the Trade Register under No. J08/1360/2001, holder of Tourism License No. 1669 hereinafter referred to as “Iulian Cozma Outdoor adventures”, “we”, “us” or “our” in this Notice. In consideration of the applicable legal provisions, Iulian Cozma Outdoor adventures provides you with an e-mail address where you can contact us to request more information related to the collection of personal data: contact@mountainguide.ro It is important that the personal data we hold on you is accurate and up to date. Please let us know if any of the details you provide to us should change during the course of your relationship with us.
- EXTERNAL LINKS
This site may include links to third-party websites or applications. If you click on those links or enable those applications, third parties may allow the collection or sharing of data about you. We do not control these third party sites and are not responsible for their personal data processing policies. When you leave our site, please read the policies of each site you visit.
- PERSONAL DATA WE COLLECT ABOUT YOU.
According to applicable law, “personal data” means any information relating to an identified or identifiable natural person; an identifiable natural person is a person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to his or her physical, physiological, genetic, mental, economic, cultural or social identity. When you access our website or communicate with us or we provide tourism services or any other type of services to you, we may process the following categories of personal data, without the collection of which the provision of tourism services to you would be impossible:
Contact and / or identification data, including: name and surname, address (domicile or residence), telephone number, e-mail, identification document series and number (ID card / identity card / passport), personal numerical code as well as the information contained in these documents, voice, call history.
Data related to the services requested, including: information on the services requested or rendered, details of payments to and from you, including your bank account, contact and identification data for persons traveling with you, data related to the duration of the trip, number of days of vacation, and certain dietary preferences.
Data used for the purposes of advertising, marketing and publicity, including: name, surname, image, feedback provided, ID (username/name used on the social network) and social network account images (in the case of ID and images published on social network accounts, Iulian Cozma Outdoor adventures will mention the presence of the person in the photos and videos published on social network accounts or on websites belonging to Iulian Cozma Outdoor adventures), after signing an agreement to use the multimedia documents held by you, for this purpose.
Special categories of personal data such as: dietary requirements that may reveal your religious or philosophical beliefs and health data. We collect and process the above data only where it is strictly necessary to provide the tourist services you have purchased. In addition, we will only collect and process the special categories of special personal data mentioned above if you have provided us with your explicit consent to do so when completing the form or in subsequent telephone conversations. You are under no obligation to give your consent for us to process your special categories of personal data, unless it is necessary for the provision of the requested services. However, without your consent, we will not be able to take the necessary steps to provide the tourist services you have booked or are trying to book. Only if this information is necessary for the provision of the tourist services, if you do not provide us with this information and we do not have your consent, we will not be able to provide the tourist services you have requested
- SOURCE OF PERSONAL DATA
Personal data may be obtained from the following sources:
– Directly from you when: you request a travel offer or benefit from the tourist services we offer, when you subscribe to our newsletter or other publications, send feedback, participate in organized contests;
– through activities that you carry out during the period you benefit from the tourist services we offer, such as photos or videos shared on your social media accounts that link to our website or Facebook page;
– from third parties, such as where we receive your personal data from third parties who request the provision of tourism services (people traveling with you or other travel agencies).
- PURPOSE OF PROCESSING PERSONAL DATA
Iulian Cozma Outdoor adventures collects, processes and uses personal data:
– for purposes that enable the provision of a tourist offer or services;
– for purposes that allow the Travel Agency to fulfill its purposes related to its activity and its legal obligations;
– to enable the initiation or performance of a contractual relationship with you;
– for advertising, marketing and publicity purposes;
– for purposes that allow you to participate in competitions and events organized by Iulian Cozma Outdoor adventures, but for which the Travel Agency will ask for a usage agreement dedicated to each activity;
– for the exercise of the rights and obligations of the parties resulting from contracts signed by the parties or in connection with the services rendered;
– in order to protect the interests of the parties in promoting legal actions and defense against any claims and lawsuits;
– in order to ensure compliance with the legal provisions concerning the preservation and archiving of data/documents;
– for exercising the rights of the Travel Agency in accordance with the legal provisions and compliance with legal obligations;
– for purposes subsumed to the general purpose of providing tourist services.
For the avoidance of any doubt, Iulian Cozma Outdoor adventures will not use your personal data for advertising, marketing and publicity purposes unless you expressly give your consent to do so. The information you submit to subscribe to our newsletter will be stored in the European Union. You may at any time withdraw your consent to the storage of your data and e-mail address and their use for sending commercial e-mail messages. The revocation can be made from the unsubscribe link within the newsletter or by a message to the contact options below.
- DISCLOSURE OF PERSONAL DATA
Your personal data will only be disclosed within Iulian Cozma Outdoor adventures to management and other persons who need access to your personal data in order to fulfill their specific duties for the purposes listed in item 6 above or where required or permitted by applicable law. Iulian Cozma Outdoor adventures may also provide your personal data to third parties that provide services in connection with the requested tourism services, IT support services or technical and organizational services (in connection with Iulian Cozma Outdoor adventures business related activities) or to legal, auditing or other consultants or suppliers of the Travel Agency, solely for the purposes mentioned in this Notice. Iulian Cozma Outdoor adventures will exercise appropriate due diligence in the selection of third party service providers and will require that those providers maintain appropriate technical and organizational security measures to protect your personal data and to process it in accordance with applicable legal provisions. Iulian Cozma Outdoor adventures may also disclose your personal data to authorities as required or permitted by law, insurance entities, external consultants and/or courts of law. Your personal data will be disclosed to such third parties only to the extent necessary in connection with the performance of the contracts, the activities of the Travel Agency and/or for the purposes listed in point 6 above.
- TRANSFER OF PERSONAL DATA OUTSIDE THE EU OR SEE
The information you submit to subscribe to our newsletter will be stored in the European Union. Many of our external tourism service providers are located outside the European Union (EU) or the European Economic Area (EEA), so the processing of your personal data will involve a transfer of data outside the EU or EEA. If you have made a reservation for tourism services that are located or to be performed outside the EU or EEA, we are obliged and authorized to transfer your personal data to the service provider you have purchased, outside the EU or EEA, in order to fulfill the contract we have with you. Where personal data is processed for the purposes of advertising, marketing or publicity and is posted on social networks, the transfer of personal data will take place on the servers of the social networks which may also be located outside the territory of the European Union, including the United States of America. Please contact us if you would like further information on the specific mechanism used by us when transferring your personal data outside the EU or the EEA at the e-mail address: contact@mountainguide.ro
- LEGAL BASIS FOR PROCESSING PERSONAL DATA
The legal grounds for the personal data processing operations described in this Notice are: (i) the performance of a contract to which you are a party or to take steps prior to entering into a contract, (ii) our legitimate interests and/or the need to enter into or perform a contract in accordance with legal provisions on data privacy and (iii) your consent. Our legitimate interests or those of a third party include our requirements to use your personal data in litigation, law enforcement investigations, data processing for the purposes of advertising, marketing or publicity or other lawful purposes involving Iulian Cozma Outdoor adventures.
- DATA SECURITY
Iulian Cozma Outdoor adventures maintains physical, technical and organizational security measures to protect personal data against accidental, unlawful or unauthorized destruction, loss, alteration, disclosure, restriction or access, regardless of where it is processed.
- DURATION OF PROCESSING/ STORAGE OF PERSONAL DATA
We intend to keep your personal data accurate and up to date. We also endeavor to keep your personal data no longer than is necessary to fulfill the purposes listed in this Notice or required by law. In this respect, we inform you that Iulian Cozma Outdoor adventures keeps your personal data for the entire duration of your contract with Iulian Cozma Outdoor adventures and for a period provided for by the legislation in force after the date of termination of the relationship between you. In addition, please note that certain personal data may also be included in certain accounting documents of Iulian Cozma Outdoor adventures, therefore an extended retention period must be respected, in accordance with applicable law. Under certain circumstances, we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information for an unlimited period of time without prior notice to you. Transfer and storage of your data.
- PROCESSING OF PERSONAL DATA FOR ADVERTISING, MARKETING AND PUBLICITY PURPOSES
Image capturing (photography, video) or image use (photography, video) is permitted only with your prior consent and in the case of minors only with the prior consent of their parents. It should be noted that the right to image is not an absolute right, and the photographing and use of a person’s image is permitted even without prior consent when done in good faith in the exercise of other fundamental rights such as, for example, the right to free expression or our legitimate interest to ensure the security and safety of persons and property. If consent is given, Iulian Cozma Outdoor adventures will restrict the use of the image only on its website(s) and only on the main social media such as Facebook, Twiter, Instagram or on the websites associated with the Travel Agency or in the display for advertising, marketing and publicity purposes at its premises, events or presentations. There are situations, trips, group events where such collection of images or video is possible, and should be announced in advance and if the collection and processing is not desired, the event coordinator may be notified.
Use of web beacons and similar technologies in emails. We use technologies such as web beacons (also called ClearGIFs or tracking pixels) to measure the performance of our emails such as delivery rates, open rates and click-through rates and unsubscribe rates, links the customer interacted with. We will use this tracking modality to measure interactions from a newsletter. No personal data is collected through this modal. If you no longer wish us to process your personal data for advertising, marketing or publicity purposes, you can unsubscribe from receiving newsletters by clicking on the link at the end of the newsletter or you can request this at contact@mountainguide.ro or leave the social media page of the Travel Agency you belong to.
- YOUR RIGHTS. REGARDING PERSONAL DATA
In accordance with the applicable provisions regarding personal data, we inform you that you have the following rights, which may be exercised by making a request using the contact details indicated in Section 2 above:
The right of access to the personal data processed, meaning your right to obtain from Iulian Cozma Outdoor adventures a confirmation as to whether or not personal data concerning you is processed and, if so, access to the data and the conditions under which it is processed (including the purpose of the processing, the categories of data processed, the recipients of the data);
The right to request rectification or erasure of personal data, meaning your right to ask us to rectify inaccurate personal data or to complete incomplete data. The right to erasure of your personal data may also be exercised in certain circumstances provided for by the applicable law, including: where the personal data are no longer necessary in relation to the purposes of the processing, where the data subject objects to the processing and there are no other legitimate interests prevailing for the processing, where the personal data have been processed unlawfully.
The right to request restriction of processing, meaning your right to obtain from Iulian Cozma Outdoor adventures the restriction of processing in the following cases: (i) you contest the accuracy of the data (the restriction will last as long as it is necessary for the Travel Agency to verify the accuracy of the personal data); (ii) the processing is unlawful and you (iii) Iulian Cozma Outdoor adventures no longer needs the personal data for the above-mentioned purposes, but you request the personal data for the establishment, exercise or defense of a legal claim; or (iv) you have objected to the processing, for the period of time during which Iulian Cozma Outdoor adventures verifies whether the legitimate rights of the Travel Agency prevail over your rights;
The right to object to processing, meaning your right to object to processing on grounds relating to your particular situation where the processing (i) is based on the legitimate interests of the Travel Agency or a third party, or (ii) to the extent applicable, is carried out for the purpose of direct marketing communications, involving profiling;
The right not to be subject to automated decision making, including profiling;
The right to data portability, meaning your right to request the moving, copying or transfer of your existing data in the Travel Agency’s database to another database, in a structured, commonly used and machine-readable format, where the processing is based on a contract and is carried out by automated means;
The right to lodge a complaint with the National Supervisory Authority for the Processing of Personal Data and to apply to the competent courts.
- CHANGES TO THE NOTIFICATION
If we materially change our personal data practices or this Notice, we will issue a revised Notice and/or take other steps to notify you of the changes in accordance with applicable law.