PROCESSING OF PERSONAL DATA
The new European Union law on personal data protection, GDPR (“General Data Protection Regulation”) entered into force on 25 May 2016, and became applicable in all European Union member states on 25 May 2018. This The law is the biggest change in the field of personal data protection in the last 20 years and has objectives that go far beyond the mere protection of privacy.
The protection of your personal data is important to us, therefore, we pay special attention to the protection of the privacy of all those who provided us with their data by transmitting the data through the contact form on www.incoming.christiantour.ro, through participation in events / campaigns organized by us, of persons who send us personal data in order to process a request, of those whose data have been provided to us through contracts, as well as of those whose personal data are not were provided by a third party, or to which I have had access from another source, in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and the free movement of such data (hereinafter referred to as “GDPR”).
Please pay special attention to reading the following Policy (hereinafter “PPD”) to understand how your information will be treated (“personal data”).
PPD explains the practices of MEMENTO HOLIDAYS, regarding the application of the provisions of the GDPR, as well as the rights you enjoy regarding the way in which your information is processed by MEMENTO HOLIDAYS.
The processing of personal data carried out by MEMENTO HOLIDAYS will always be carried out in accordance with the provisions of the GDPR, as well as with the regulations on the protection of personal data, specific to each country in which MEMENTO HOLIDAYS operates.
Through PPD, MEMENTO HOLIDAYS wishes to inform data subjects about the nature of the personal data we collect and process, as well as about the purposes of processing. In addition, data subjects are informed through the PPD and about their rights.
WHAT IS PERSONAL DATA?
“Personal data” means any information or information that can identify you directly (for example, your name) or indirectly (for example, through pseudonymous data, such as a unique identification number). This means that personal data includes things like email address, home address, mobile phone, username, profile pictures, personal preferences and shopping habits, user-generated content, financial information, and financial statement information. It may also include unique numeric identifiers, such as the IP address of your computer or the MAC address of your mobile device, as well as cookies.
WHAT DOES PERSONAL DATA PROCESSING MEAN?
“Processing” means any operation or set of operations performed on personal data or sets of personal data, with or without the use of automated means, such as the collection, recording, organization, structuring, storage, adaptation or modification, extraction, consultation, use, disclosure by transmission, dissemination or otherwise made available, alignment or combination, restriction, deletion or destruction.
WHAT IS YOUR DATA? WHAT DO WE PROCESS WITH PERSONAL CHARACTER?
Your personal data that will be processed are the following: name and surname, e-mail address, telephone number, domicile / correspondence address, occupation and in some cases the data entered in the Identity Card.
PERSONAL DATA OPERATOR
The personal data controller (hereinafter referred to as the “controller”) is MEMENTO HOLIDAYS.
PRINCIPLES REGARDING DATA PROCESSING
MEMENTO HOLIDAYS undertakes to comply with the principles of personal data protection (hereinafter referred to as the “Principles”) set out in the GDPR, in order to ensure that all data are:
- Processed correctly, legally and transparently;
- Collected for specified, explicit and legitimate purposes;
- Adequate, relevant and limited in relation to the purposes for which they are processed;
- Correct and updated;
- Kept in a form which does not allow the persons concerned to be identified for longer than is necessary in relation to the purpose of the processing;
- Processed in accordance with the rights of the data subject, in a way that ensures adequate security of processing, so that the data are complete, confidential and available.
BASIS AND PURPOSES OF PERSONAL DATA PROCESSING
- For the purpose of concluding and executing contracts – According to art. 6 para. 1 lit. b) of the GDPR, personal data may be processed for the purpose of concluding or executing the contract. In order to be able to offer you our products and services, we need to process personal data that belongs to you.
- In order to fulfill certain legal obligations – According to art. 6 para. 1 lit. c) of the GDPR, personal data may be processed in order to fulfill certain legal obligations. We request a series of personal data, including, in certain situations, the personal numerical code, in order to fulfill our obligations imposed by the tax authorities in connection with invoicing and reporting to the tax authorities.
- For marketing purposes – According to art. 6 para. 1 lit. a) of the GDPR, personal data may be processed if the data subject has given his or her consent to the processing of his or her personal data for one or more specific purposes. Thus, in certain situations, your personal data will be used in order to send you marketing messages, offers, news, future campaigns, invitations to various events.
PROCESSING THE CONTACT FORM
MEMENTO HOLIDAYS will use the information you provide in the relevant contact section, existing on the site, exclusively for the purpose of processing your request.
By providing any personal data through www.incoming.christiantour.ro, you understand and agree that your data will be processed in accordance with the provisions of the PPD of MEMENTO HOLIDAYS.
Please note that in order to be able to process your requests sent in the contact section of the site, we may, in certain circumstances, have the obligation to disclose your data to the partners with whom MEMENTO HOLIDAYS collaborates and / or others. third party service providers of MEMENTO HOLIDAYS.
However, MEMENTO HOLIDAYS has taken appropriate technical and organizational measures to ensure the security of data transfer, as well as the processing of your data in accordance with the GDPR requirements by the aforementioned entities.
MEMENTO HOLIDAYS undertakes not to process personal data provided for any purpose other than that for which they were transmitted, unless there is your express consent to use them for other purposes.
It is also possible that MEMENTO HOLIDAYS has access to other personal data by establishing a link with MEMENTO HOLIDAYS, by processing the data communicated following telephone conversations, e-mail conversations, presentation at our headquarters in viewing information, etc.
By contacting MEMENTO HOLIDAYS in any manner set forth above or any other method that involves mediated or direct communication between you and MEMENTO HOLIDAYS, you understand and agree that your data will be processed in accordance with the PPD provisions of MEMENTO HOLIDAYS
DISCLOSURE OF PERSONAL DATA TO THIRD PARTIES
Personal data processed by MEMENTO HOLIDAYS may be disclosed and / or transferred to third parties only if there is your express consent to do so, unless there is a legal / contractual obligation for MEMENTO HOLIDAYS to proceed in this way.
Please note that in certain circumstances we may be required to disclose your personal information to the partners with whom MEMENTO HOLIDAYS works and / or to other third party service providers of MEMENTO HOLIDAYS.
DATA PROCESSING BY THIRD PARTIES, OTHER SITES AND SPONSORS
The site www.incoming.christiantour.ro may contain, at a given time, access links to other sites whose data processing policies may be different from those of MEMENTO HOLIDAYS.
Please consider and consult the personal data protection policies of the other sites, MEMENTO HOLIDAYS not assuming responsibility for the information sent or collected by these third parties.
AUTOMATIC DATA PROCESSING. COOKIE
DATA STORAGE PERIOD
MEMENTO HOLIDAYS may keep the data processed for various periods of time, deemed reasonable, in accordance with the purposes indicated above. We keep your data only for the period necessary to achieve the purpose for which we have the data, to meet your needs or to fulfill our obligations imposed by law, especially regarding the data necessary to conclude insurance contracts.
To know how long your data can be kept, we use the following criteria:
- When you purchase products and services, we retain your personal data for the duration of our contractual relationship, as well as for a later period in the event that there is a legal obligation to keep MEMENTO HOLIDAYS;
- If you participate in a promotional offer, we keep your personal data for the duration of the promotional offer;
- If you contact us for a question, we keep your personal data for the time necessary to process your questions;
- If you have given your consent for marketing, we will retain your personal data until you withdraw your consent and request that we delete them;
- If cookies are stored on your computer, we keep them for as long as necessary to achieve their purposes (for example, during a session for shopping cart cookies or cookies for shopping cart IDs). session) and for a period defined in accordance with local regulations and guidelines. In this regard, we note that the data processed through cookies used to provide online behavioral advertising, to personalize our services for you and to allow the distribution of our content on social networking sites (distribution buttons for displaying the site), will be kept for a maximum period of 3 years from their collection.
THE RIGHTS OF THE PERSONS CONCERNED
According to GDPR, you have a number of rights regarding the personal data that MEMENTO HOLIDAYS processes:
- Right of access to data processing – You have the right to access the personal data we hold. The first provision of information will be made without charging any fee. If you still need copies of the information already provided, we may charge a reasonable fee for the administrative costs of providing the information. Clearly unfounded, excessive or repeated requests may not be answered.
- Right to rectify data – You have the right to request that your Data be rectified if it is inaccurate or outdated and / or to complete it if it is incomplete. If you have an account, it may be easier to correct your own data through the “My Account” feature.
- Right to Erase Data (“Right to Be Forgotten”) – In some cases, you have the right to have your Data erased or destroyed. This is not an absolute right, as we may sometimes be forced to retain your Data for legal or legal reasons.
- Right to Restrict Processing – You have the right to request a restriction on the processing of your Data. This means that the processing of your Data is limited so that we can store the Data but not use or process it. This right shall apply in the specific circumstances provided for in the General Data Protection Regulation, namely:
- the accuracy of the Data is contested by the data subject (ie by you), for a period that allows the operator (ie MEMENTO HOLIDAYS) to verify the correctness of the Data;
- the processing is illegal and the data subject (ie you) opposes the deletion of the Data and requests the restriction of their use;
- the operator (for example, MEMENTO HOLIDAYS) no longer needs Data for processing, but they are requested by the data subject (ie by you) in order to establish, exercise or defend legal claims;
- the data subject (ie you) has raised objections to the processing based on legitimate reasons by the operator (in this case MEMENTO HOLIDAYS) on the basis of verifying whether the legitimate reasons of the operator (MEMENTO HOLIDAYS) exceed those of the data subject (ie you).
- Right to data portability – You have the right to move, copy or transfer the data you are interested in from one database to another. This only applies to the data you have provided, when the processing is based on your consent or on the basis of a contract and is implemented by automatic means.
- Right of opposition – You may object at any time to the processing of your data when such processing is based on a legitimate interest.
- Right to withdraw consent at any time – You may withdraw your consent to the processing of your data when such processing is based on consent. Withdrawal of consent does not affect the lawfulness of the processing on the basis of the consent before its withdrawal.
- Right to lodge a complaint with the competent supervisory authority – You have the right to lodge a complaint with the data protection authority of your country of residence or domicile to challenge the data protection practices offered by MEMENTO HOLIDAYS.
- Right to object to the processing of your data for direct marketing purposes – You may unsubscribe or opt out of our direct marketing communication at any time. It’s easier to do this by clicking on the “unsubscribe” link in any email or communication we send you.
- Right to object to the processing of your data by us when we carry out actions in the public interest or in the legitimate interests of ourselves or a third party – You may at any time object to the processing of your data when such processing is based on a legitimate interest.
- The right to disable Cookies – you have the right to disable cookies. Settings in Internet browsers are usually set by default to accept cookies, but you can easily adjust them by changing your browser settings. Many cookies are used to increase the use or functionality of websites / applications; therefore, disabling cookies may prevent you from using certain parts of our sites or applications, as detailed in the relevant Cookie table. If you wish to restrict or block all cookies set by our websites / applications (which may prevent you from using certain parts of the site) or any other sites / applications, you may do so through your browser settings. . The Help function in your browser will tell you how. For more information, see the following links: http://www.aboutcookies.org/;
You may exercise any of these rights with respect to the personal data that MEMENTO HOLIDAYS processes by making a simple request to the DPO MEMENTO HOLIDAYS. In such a situation it is very possible to ask for proof of your identity.
We access, store and provide your information to regulators, law enforcement or other entities:
In response to a request of a legal nature, when we consider, in good faith, that the law requires us to do so. We may also respond to requests of a legal nature when we consider, in good faith, that the response required by the laws of that jurisdiction affects users in that jurisdiction and is in line with internationally recognized standards.
When we consider, in good faith, that it is necessary to: detect, prevent, and respond to acts of fraud, unauthorized use of any material belonging to us, breaches of our conditions or policies or other harmful or illegal activities, in order to protect us (including our rights, property or materials), you and others, including in investigations or investigations by regulators, or to prevent imminent death or personal injury. For example, if relevant, we provide information to and receive information from third parties about the reliability of your account to prevent fraud, abuse, and other harmful activities within and outside our materials.
The information we receive about you may be accessed and stored for a longer period of time when it is the subject of a legal request or obligation, a government investigation, or an investigation into possible breaches of our terms or policies, or in other cases to prevent damage.
RELATIONS WITH OTHER OPERATORS
Depending on the context, we may find it absolutely necessary to provide information at a higher level, both globally and internally or externally, to our partners and those with whom we transfer data in compliance with the GDPR, in the virtue of ensuring the provision of the most professional services possible. The information controlled by MEMENTO HOLIDAYS may be transferred, transmitted, or stored and processed in the EU or in countries other than the country where you live, for the purposes described in this policy. These data transfers are necessary in order to be able to provide services at the highest level, as well as to continue to provide you with our materials at the best professional level.
MEMENTO HOLIDAYS has adopted technical and organizational data processing measures, updated in accordance with GDPR requirements, in order to protect your personal data against any actions of unauthorized access, misuse or disclosure, unauthorized modification, destruction or accidental loss. All MEMENTO HOLIDAYS employees and collaborators, as well as any third parties acting in the name and on behalf of MEMENTO HOLIDAYS are obliged to respect the confidentiality of your information and the requirements of GDPR, in accordance with the provisions of PPD.
The MEMENTO HOLIDAYS site may contain links to other sites and / or other web pages that are not the property of MEMENTO HOLIDAYS. MEMENTO HOLIDAYS assumes no responsibility for the content of these sites and therefore cannot be held responsible for the content, advertising, goods, services, software, information or other materials available on or through these sites. -hate. MEMENTO HOLIDAYS will not be responsible for the loss of personal data, for any negative effects on the personal data of visitors or for other moral and / or patrimonial damages caused by the access to the respective sites.
UPDATING THE PROTECTION POLICY AND PROCESSING OF PERSONAL DATA
Please keep in mind that this Policy may be subject to periodic changes in content, by updating the site www.incoming.christiantour.ro.
How will we notify you of changes to this Policy?
- We will post on www.incoming.christiantour.ro information on the PPD change.
Please do not continue to use the site www.incoming.christiantour.ro if you do not agree with such changes. We also recommend that you check this page for any updates. PPD terms shall be construed in accordance with applicable law.
If you have any questions or concerns about how we treat and use your personal data or wish to exercise any of your rights, please contact us by accessing the contact details of our DPO.
- The site www.incoming.christiantour.ro is a site with informative content. MEMENTO HOLIDAYS assumes no responsibility for the correctness and accuracy of that information.
- MEMENTO HOLIDAYS does not guarantee in any way, explicitly or implicitly, the reality, timeliness and completeness of the data and information presented on the site. Any inconsistencies or errors that may occur at any time between the content of the site and the actual information do not imply any liability, of any kind, for MEMENTO HOLIDAYS.
- The data and information accessible to the public on this site do not constitute recommendations, guarantees, consultancy or commitment from MEMENTO HOLIDAYS.
- MEMENTO HOLIDAYS cannot be held liable to any person / entity for any damages that would result, directly or indirectly, from the use of the www.incoming.christiantour.ro site or as a result of any error or omission.
- MEMENTO HOLIDAYS also acts as an agent for third party providers such as: airlines, hotels, car rental companies and other Tourist Service Providers – hereinafter referred to as Suppliers.
- MEMENTO HOLIDAYS does not assume any responsibility for the tourist products and services offered by the Suppliers and does not guarantee in any way (either explicitly or implicitly) the accuracy or quality of the products and services reflected on this site.
Changes in the terms and conditions of use:
- MEMENTO HOLIDAYS may make changes to the terms and conditions of use, without prior notice in the content of the site. Please read the terms and conditions of use each time you access or use this site. Your use of the site, following the modification of these terms, constitutes your acceptance of the modified terms and conditions.
- This site may contain links to various sites. When you access these sites, you are implicitly outside the site www.incoming.christiantour.ro and you have the obligation to comply with the terms and conditions of use of the new sites accessed.