Privacy Policy – GDPR
Personal data processing policy
The Personal Data Processing Policy describes the categories of your personal data that we process, the methods and purposes for which we collect them, the situations in which we transfer personal data, as well as the rights and options available to you in this regard. At the same time, the Personal Data Processing Policy details how we process personal data in managing customer relationships, often to keep you informed about the latest developments or events in your field of interest. When you use the services of Aerotravel, you entrust us with your information. The purpose of this Privacy Policy is to explain what data we collect, why we collect it, and what we do with the personal data you provide to us. This policy is applicable from May 25, 2018.
The operator of your personal data
The operator in relation to your personal data is Aerotravel SRL, a legal entity established and organized under the laws of Romania, registered with the Trade Registry Office in Bucharest under no. J40/8755/1997, VAT number 9919750, with headquarters in Bucharest, Timisului Street, no. 67, ground floor, sector 1, and branches in Bucharest, Mantuleasa Street, No. 31, 1st floor, sector 2. The representative for the protection of personal data for the data operator is Codruta Jold. You can contact the data protection officer by mail at the address of the workplace in Bucharest mentioned above or by email at codruta.jold@aerotravel.ro.
The data we process
The personal data we process may include contact information such as name, employer name, and position held within a company, home and/or business address, phone number, mobile phone number, email address, nationality, information regarding the identity card and/or passport; Additional information processed in the context of a contractual relationship or voluntarily communicated by you, such as instructions given, payments made, information on legal matters, family status, etc. In the context of the services provided, we may also collect and process personal data of your children when your vacations or travels involve them. Of course, we attach special importance to these data and will ensure their specific protection. Data resulting from your browsing on our website collected through cookies and similar technologies (IP address, etc.). For more details, please study our cookie policy. We do not intend to collect sensitive personal data such as racial or ethnic origin, political opinions, religious beliefs or philosophical convictions, union membership, and the processing of genetic data, biometric data for the unique identification of an individual, data concerning health, or data concerning the sexual life or sexual orientation of an individual.
Legal grounds for processing personal data
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Any operation of processing your personal data will be carried out based on one of the legal grounds below:
- Processing is necessary for the conclusion or performance of a contract to which you are a party;
- Processing is necessary for compliance with a legal obligation of the operator;
- Processing is carried out based on your consent;
- Processing is necessary to protect your vital interests or those of another natural person;
- Processing is necessary for the purposes of the legitimate interests of Aerotravel or a third party (e.g., when processing is necessary for the performance of a contract to which your organization is a party), except where your fundamental interests or rights and freedoms prevail over these interests;
- In the case of special categories of data, processing will be carried out if, in addition to a general legal basis for data processing, one of the following specific conditions for processing is met: (1) The consent of the data subject has been obtained; (2) We have a legal obligation to process such categories of data; (3) Processing is necessary for the establishment, exercise, or defense of a legal right.
Also, based on your consent, we may send you various communications by email or phone to keep you informed about the latest developments in the tourism industry, announcements, and other information about Aerotravel’s services, products, events, and promotional projects.
Disclosure of your data
We may disclose your personal data to affiliated companies of the Aerotravel group – Aerovacante SRL and Cruise Hub SRL – contractual partners involved in the tourism or travel circuit you choose, lawyers, consultants, judicial or arbitral courts, as well as other public authorities, entities indicated by you, or other entities in the context of providing Aerotravel services (such as insurance service providers, accounting service providers, IT, telephone, email, etc.).
Transfer of your personal data abroad
We may transfer your personal data to countries that are part of the European Economic Area or to countries that have been recognised by the European Commission as ensuring an adequate level of protection of personal data, if such transfer is necessary for processing in accordance with the Permitted Purposes described above.
In exceptional situations, if necessary for the Permitted Purposes, we may transfer your personal data to third countries that have not been recognized by the European Commission as providing an adequate level of protection. We will ensure that such international transfers are made subject to adequate safeguards (such as, under Standard Contractual Clauses approved by the European Commission) as required by the General Data Protection Regulation (EU) 2016/679 or other applicable legal provisions. You may contact us at any time, using the contact details below, if you would like further information about these safeguards.
Updating your personal data
If any of the personal data you have provided to us changes, for example if you change your first name, last name or e-mail address or if you wish to cancel any request made to us, or if you become aware that we hold any incorrect personal data about you, please contact us by e-mail at: datepersonale@aerotravel.ro.
We will not be liable for any loss arising from incorrect, unauthentic, insufficient or incomplete personal data you provide to us.
How long do we keep your personal data?
Aerotravel has implemented technical and organisational measures to organise the process and specific criteria for storing your personal data (including according to our archiving procedures).
We will cease processing personal data when it is no longer reasonably necessary for the Permitted Purposes, or when you withdraw your consent (if applicable) and (i) there are no longer compelling legitimate grounds justifying further processing by Aerotravel (including Aerotravel’s legal obligation to continue to store that data) that override your interests, rights and freedoms, or (ii) it is no longer necessary for us to establish, exercise or defend a legal claim.
Your rights in relation to the processing of personal data
Subject to certain legal conditions, you have the following rights in relation to the processing of your personal data:
The right to request a copy of the personal data we hold about you;
The right to rectify any inaccurate or incomplete personal data;
The right to object to or restrict our use of your personal data;
The right to withdraw your consent to the processing of data processed on the basis of consent;
The right to erasure of your personal data, in situations where you have withdrawn your consent, the processing is no longer necessary or the processing is contrary to law;
The right to data portability which allows you to receive a copy of the processed data we have received from you or to transmit it to another entity indicated by you;
The right to withdraw your consent for processing carried out on the basis of consent. Withdrawal of your consent will not affect the lawfulness of the processing based on your consent prior to withdrawal. In cases where you withdraw your consent, Aerotravel will no longer process your personal data and will take appropriate measures to delete your personal data. Aerotravel may, however, process your personal data if there is another legal basis for such processing.
If you wish to exercise the above-mentioned rights, please contact us using the following contact details: address – Bucharest, str. Mantuleasa, Nr. 31, Floor 1, sector 2; E-mail – datepersonale@aerotravel.ro; Fax – +40 21 316 7308
With regard to marketing communications received from us, you may also withdraw your consent at any time by simply clicking on the “unsubscribe” link at the bottom of each e-mail message received from us.
In order to comply with our legal obligations of data security and confidentiality, when you exercise one of your rights as a data subject, we may ask you to prove your identity by providing us with a copy of an identification document or any other information necessary to verify that the request is from the relevant data subject.
We will consider any requests or complaints that we receive and will provide you with a response in accordance with the deadlines provided by law. If you are not satisfied with our response or if you consider that the processing is done in breach of the applicable law, you may lodge a complaint with the data supervisory authority in Romania: Autoritatea Nationala de Supraveghere a Prelucrarii Datilor cu Caracter Personal – located at Bd. Gheorghe Magheru nr. 28-30, Bucharest, Romania.
Updates to this personal data processing policy
The most recent update of this Personal Data Processing Policy was made in May 2018. We reserve the right to periodically update and amend this Personal Data Processing Policy to reflect any changes in the way we process your personal data or any changes in legal requirements. In the event of any such changes, we will post the amended version of the Personal Data Processing Policy on our website and/or otherwise make it available to you.