Personal Data Processing Policy

This Privacy Policy describes the categories of personal data we process, the methods and purposes of collection, the circumstances under which data may be shared, and the rights and options available to you. It also details how we handle personal data in managing our client relationships — most often to keep you informed of the latest developments in your areas of interest.

When you use Aerotravel’s services, you entrust us with your information. The purpose of this Privacy Policy is to explain what data we collect, why we collect it, and how we use it. This policy is effective as of May 25, 2018.

The data controller for your personal data is Aerotravel SRL, a legal entity incorporated under Romanian law, registered with the Bucharest Trade Register under no. J40/8755/1997, Tax ID 9919750, with its registered office at Str. Timisului no. 67, Ground Floor, Sector 1, Bucharest, and a branch office at Str. Mantuleasa no. 31, 1st Floor, Sector 2, Bucharest. The data protection representative is Codruta Jold. You may contact the data protection officer by mail at the branch address above or by email at codruta.jold@aerotravel.ro.

The personal data we process may include: contact information such as name, employer name, job title, home and/or office address, phone number, mobile number, email address, nationality, and ID or passport details; supplemental information provided in connection with a contractual relationship or voluntarily shared by you, such as instructions, payment details, legal matters, or family status. When travel or vacation arrangements involve your children, we may also collect and process their personal data. We treat such data with particular care and apply appropriate protections. We also collect data generated through your use of our website via cookies and similar technologies (e.g., IP address). For more details, please review our Cookie Policy. We do not intend to collect sensitive personal data, including racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data for unique identification, health data, or data relating to sexual life or orientation.

If you leave a comment on our site, you may opt to save your name, email address, and website in cookies for your convenience, so you do not have to re-enter them on future visits. These cookies are valid for one year.

All processing of your personal data is carried out on one of the following legal bases:

Processing is necessary for entering into or performing a contract to which you are a party; processing is required to comply with a legal obligation applicable to the data controller; processing is based on your consent; processing is necessary to protect your vital interests or those of another natural person; processing is necessary for the legitimate interests of Aerotravel or a third party (e.g., where processing is required to perform a contract to which your organization is a party), except where your interests or fundamental rights override those interests. For special categories of data, processing will occur only when, in addition to a general legal basis, one of the following conditions is met: (1) your explicit consent has been obtained; (2) we have a legal obligation to process such data; or (3) processing is necessary for the establishment, exercise, or defense of legal claims.

With your consent, we may also send you email or phone communications to keep you informed about the latest developments in the travel industry, announcements, and updates on Aerotravel’s services, products, events, and promotional activities.

We may disclose your personal data to Aerotravel Group affiliates — Aerovacante SRL and Cruise Hub SRL — as well as to contractual partners involved in the travel or itinerary you have chosen, legal counsel, consultants, courts or arbitration bodies, and other public authorities, entities indicated by you, or other parties in connection with the provision of Aerotravel’s services (such as insurance providers, accounting, IT, telephone, and email service providers).

We may transfer your personal data to countries within the European Economic Area or to countries recognized by the European Commission as providing an adequate level of data protection, where such transfer is necessary for the permitted purposes described above.

In exceptional circumstances, if required for permitted purposes, we may transfer your data to third countries that have not received an adequacy decision from the European Commission. In such cases, we will ensure that appropriate safeguards are in place (such as Standard Contractual Clauses approved by the European Commission), as required by the General Data Protection Regulation (EU) 2016/679 or other applicable legislation. You may contact us at any time using the details below if you wish to obtain further information about these safeguards.

If any of the personal data you have provided changes — for example, if your name or email address changes, or if you wish to withdraw a request — or if you become aware that we hold inaccurate data about you, please contact us at: datepersonale@aerotravel.ro.

We will not be liable for any loss resulting from inaccurate, incomplete, or insufficient personal data that you provide.

Aerotravel has implemented technical and organizational measures governing the retention of your personal data in line with established archiving procedures.

We will cease processing your personal data when it is no longer reasonably necessary for the permitted purposes, or when you withdraw your consent (where applicable) and (i) there are no compelling legitimate grounds for continued processing that override your interests, rights, and freedoms, or (ii) the data is no longer needed for the establishment, exercise, or defense of legal claims.

Subject to applicable legal conditions, you have the following rights with respect to the processing of your personal data:

The right to request a copy of the personal data we hold about you; the right to rectification of any inaccurate or incomplete data; the right to object to or request restriction of our use of your data; the right to withdraw consent for processing carried out on the basis of consent; the right to erasure of your personal data where consent has been withdrawn, processing is no longer necessary, or processing is unlawful; the right to data portability, allowing you to receive a copy of the data you have provided to us or to have it transferred to a third party of your choosing; the right to withdraw consent at any time without affecting the lawfulness of processing carried out prior to withdrawal. Upon withdrawal, Aerotravel will cease processing your data and take appropriate steps to erase it, unless another legal basis for processing exists.

To exercise any of the above rights, please contact us at: Address — Str. Mantuleasa no. 31, 1st Floor, Sector 2, Bucharest; Email — datepersonale@aerotravel.ro; Fax — +40 21 316 7308.

For marketing communications, you may also withdraw your consent at any time by clicking the “unsubscribe” link at the bottom of any email we send you.

To comply with our legal data security and confidentiality obligations, we may ask you to verify your identity when exercising your rights, by providing a copy of an identification document or other information necessary to confirm that the request comes from the relevant data subject.

We will consider all requests and complaints received and respond within the timeframes required by law. If you are not satisfied with our response or believe that processing is being carried out in violation of applicable law, you may file a complaint with the Romanian data protection authority: the National Supervisory Authority for Personal Data Processing (ANSPDCP) — Bd. Gheorghe Magheru no. 28-30, Bucharest, Romania.

This Privacy Policy was last updated in May 2018. We reserve the right to update and amend it periodically to reflect changes in how we process personal data or changes in legal requirements. Any amendments will be published on our website and/or communicated to you through other appropriate means.