PRIVACY AND PERSONAL DATA PROCESSING POLICY
INFORMATION NOTE FOR THE PROCESSING OF PERSONAL DATA
Free Worlding Club SRL, based in Sos. Alexandria no. 9, bl. 4, sc. A, ap 9, sector 5, Bucharest, registered in the Trade Register under no. J40/692/2009, CUI: 24979438, having bank account no. RO15RZBR0000060019546302 opened at Raiffeisen Bank, telephone 0764.044.737, e-mail email@example.com
SC Adventure Unfiltered SRL, having the following identification data: CUI: 40850370. No. Reg. J40 / 4039/2019, Address: Gheorghe Ioachim Str. no. 5, lot 1, room 5, sector 5, Bucharest, Romania, Tour operator license: 1842 / 07.05.2019, insurance policy series IF-i no: 3203 / 27.10.2021 valid until 29.10.2022
- the stipulations of Regulation no. 679/2016 on the protection of individuals with regard to the processing of personal data and on the free circulation of such data and on the repeal of Directive 95/46/CE – “GDPR”,
- the processing of personal data of natural person contractual partners, contact persons, legal or contractual representatives, collaborators, employees and/or other natural persons designated by legal person contractual partners, transmitted to Free Worlding Club SRL for the purpose of negotiation, conclusion and performance of contractual relations, we inform you about the processing of personal data carried out for the purpose of negotiation, conclusion and performance of contracts to which Free Worlding Club SRL and Adventure Unfiltered SRL are party:
- The quality that the two entities have in terms of personal data processing
Free Worlding Club SRL and Adventure Unfiltered SRL are personal data controllers in accordance with the provisions of Article 4(7) of the GDPR.
- Categories of data subjects
The personal data that are processed by Free Worlding Club SRL and Adventure Unfiltered SRL belong to the following categories of persons: users of the website, users of the media channels belonging to the two entities, contractual partners natural persons, contact persons designated by the contractual partners, their legal or conventional representatives, collaborators, employees and/or other categories of natural persons whose data are disclosed to Free Worlding Club SRL and Adventure Unfiltered SRL by the contractual partners (collectively referred to generically, in the following , “Data Subjects”). These personal data are transmitted to Free Worlding Club SRL and Adventure Unfiltered SRL at the initiation of contractual relations with the contractual partners or during their development.
- Purpose and basis of personal data processing
The purposes of processing your personal data are:
– the initiation of the contractual relationship, the negotiation, conclusion and performance of the contracts with the contractual partners of Free Worlding Club SRL and Adventure Unfiltered SRL, including the provision of services, the delivery of the products that are the subject of the contracts and their payment or marketing communications
– the fulfillment of the legal obligations of Free Worlding Club SRL and Adventure Unfiltered SRL in the context of the development of contractual relations, such as: the obligations of preparation and storage of financial-accounting documents; personal data storage during the entire period of development of contractual relations and archiving of documents; carrying out audits; the transmission of information that represents personal data at the request of the competent state authorities; ensuring the security of systems and databases (including by making backup copies); other applicable legal obligations depending on the nature of the contractual relationship and/or the quality of the contractual partner;
– to pursue the legitimate interests of the Data Operator or a third party, such as: for the operator’s internal reports or for the efficiency of the company’s processes; for the management of contracts or supporting accounting documents; for communication with the representatives of the contractual partners, for the resolution of notifications; for auditing or verifying internal processes; fraud prevention; for the defense of the operator’s rights, such as the recovery of claims held by him and the formulation of defenses in the event of any litigation; The legal bases of the data processing operations refer to the relevant articles of the GDPR, as detailed above.
- Categories of personal data
The categories of personal data that Free Worlding Club SRL and Adventure Unfiltered SRL process for the aforementioned purposes may be, but are not limited to:
For the Beneficiary – natural person/representative of the legal entity, signatories of the contracts
* Name, surname
* Data from the identity document: home address, number, series, date of issue, issuing body,
expiry date, CNP, image
* Holographic or electronic signature
* Email address, phone number
* Mailing address (if applicable)
* Bank account
* Bank card data in case of electronic payment;
* The image (in the case of photos)
- Provision of data and the consequences of non-compliance
The provision of the previously mentioned personal data is necessary to achieve the purposes specified above. Your refusal to provide the data may lead to the impossibility of providing the services or products that are the subject of the contracts.
- Duration of personal data processing
Free Worlding Club SRL processes all the information and personal data provided by the contractual partners during the entire period of negotiation and performance of contractual relations. Upon the termination of these reports, the information and personal data will be archived for a period of 10 years, according to the legal provisions. After this period your personal data will be destroyed.
- Transmission of personal data to fulfill the processing purposes of Free Worlding Club SRL and Adventure Unfiltered SRL
Your personal data may be disclosed: to the persons concerned for the exercise of their rights, auditors, the supervisory body according to the legislation applicable to the service provided, public authorities and institutions based on public law obligations, lawyers to represent us in the event of any litigation or for consulting, bailiffs for contractual communications or the enforcement of possible court decisions, debt recovery companies, contractual partners of Free Worlding Club SRL (courier companies, suppliers, subcontractors, consultants and technical experts, etc.) for the conclusion and execution of contracts, banks for mortgaging claims and/or obtaining financing and/or guarantee instruments, insurance companies for obtaining guarantee instruments, Free Worlding Club SRL affiliated companies and in any other justified situations with your prior notice, but only in order to fulfill the purposes mentioned above and aiming to protect your rights as a priority.
- Transfer of data outside the European Union
Free Worlding Club SRL and Adventure Unfiltered transfer your personal data outside the European Union to the service providers they collaborate with, in order to provide the tourist service packages purchased by you.
- Rights of data subjects
The rights you benefit from in accordance with the provisions of EU Regulation 2016/679 are:
* The right to information: the right to be informed about the identity and contact details of the operator and the Data Protection Officer, the purposes for which the data is processed, the categories of personal data concerned, the recipients or the categories of recipients of the data, the existence of the rights provided by the legislation on the protection of personal data for the data subject and the conditions under which they can be exercised;
* The right of access to data: the right to obtain from the data operator confirmation as to whether or not personal data concerning you are being processed by the data operator;
* The right to rectification: the right to obtain the rectification of inaccurate data concerning you, as well as the completion of incomplete data;
* The right to restrict processing if the data subject objected to the processing for the purposes of the legitimate interests pursued by Free Worlding Club SRL and Adventure Unfiltered SRL or by third parties, or if Free Worlding Club SRL and Adventure Unfiltered SRL no longer need personal data, but the data subject requests it for establishing, exercising or defending a right in court;
* The right to withdraw your consent at any time, to the extent that the data processing operation is based on your consent;
* The right to delete data before signing the contract with Free Worlding Club SRL and Adventure Unfiltered SRL. After signing the contract, Free Worlding Club SRL and Adventure Unfiltered SRL will store the data related to the certificate for the 10-year period mentioned above.
* The right to portability of the data provided, to the extent that the data processing operation is based on consent or is based on the contract concluded with you.
* The right to object for reasons related to your particular situation on data processing carried out for the purpose of pursuing the legitimate interests of Free Worlding Club SRL and Adventure Unfiltered SRL or of third parties.
* Free Worlding Club SRL and Adventure Unfiltered SRL will notify recipients to whom it has disclosed their personal data of any erasure, rectification or restriction of the processing of personal data, unless this proves impossible or involves disproportionate efforts.
* The right to contact the ANSPDCP to defend any rights guaranteed by applicable personal data protection law that have been violated. In order to exercise your rights over personal data, you can use the following contact details:
* Email address: firstname.lastname@example.org
* Correspondence address: SC Adventure Unfiltered SRL, Gheorghe Ioachim Street no. 5, lot 1, room 5, sector 5, Bucharest, Romania
If you make a request concerning the exercise of your personal data protection rights, you will receive a reply as soon as possible, but without exceeding 30 days, under the conditions provided by the GDPR.
As a user of the website or as a beneficiary of any services purchased, you confirm that you are aware of the provisions of this notice and expressly consent to the processing of personal data, including your photo image. You also declare on your own responsibility that you agree to the use of the photos and or videos taken / dissemination of your image (unpaid) in order to promote the Free Worlding Club SRL and Adventure Unfiltered SRL the brand through their own projects, including but not limited to appearances on social networks, appearances in the press, on the websites of Free Worlding Club SRL and Adventure Unfiltered SRL and any other events and activities of the two entities.
The use of photographic images/video clips for purposes other than those described above or for marketing by transferring the images to third parties is prohibited.
- Cookies and the use of the website