This Privacy Policy defines how we, SC Wens Tour SRL, collect, store and use your personal data when you access or interact with our website. https://www.wenstravelstore.ro/and where we obtain or collect your data
This Privacy Policy is effective as of 25.05.2018.
• Summary
• Details about our company
• What information we collect when you visit our website
• What information we collect when you contact us
• What information we collect when you interact with our website
• What information we collect when you place an order https://www.wenstravelstore.ro/
• Use of automated decision-making and profiling systems
• How we collect information about you from third parties
• Disclosure and additional uses of your data
• Duration of storage of your data
• Securing your information
• Transfer of your data outside the European Economic Area
• Your rights to personal data
• Your right to object to the processing of data for certain purposes
• Sensitive personal data
• Changes to our privacy policy
• Privacy of minors
• Copyright
This section summarizes how we obtain, store and use your data. This summary is only intended to provide a general picture of the privacy policy. This section is not a complete description and it is necessary to read the additional chapters present in this document for completion.
• Data controller: SC Wens Tour SRL
• How we collect or obtain information about you:
— when you provide such data (e.g. by contacting us, placing an order on our website and subscribing to a newsletter)
— when you access our website, some data is collected through cookies and other similar technologies, e.g. web beacons
• What information we collect: name, ip, contact details, payment information such as credit/debit card details, information from cookies, information about the device used (e.g. device type and web browser), information about how you use our website (which pages you visited), date/time you accessed our website and what you clicked on, geographical location from which you have accessed our website (based on IP address), company or business name (if applicable), VAT registration number (if applicable) applicable)
How we use your data: for business and administrative purposes (in particular to contact you and process the orders you place on our website), to improve our business and website, to fulfil our contractual obligations, to promote our goods and services, to analyse your use of our website and in relation to your rights and our legal obligations.
• Disclosure of user data to third parties: the minimum necessary for the operation of the business, suppliers, compliance with legal obligations, compliance with any contractual obligation to you
• Is user data sold to third parties? (other than the sale or purchase of the business/company): No
• How long your information is stored: no longer than is necessary, depending on our legal obligations (e.g. to maintain accounting records), or any other legal basis for using the information (e.g. consent, contractual obligations, legitimate interests). Information about specific periods of storage of user data can be found in the section Duration of storage of your data.
• How your data is secured: through the use of technical and organizational solutions such as: storing information on secure servers, encrypting data transfers to and from our servers using SSL technology, encrypting payment transactions on the site using SSL technology, allowing access to your personal data only when necessary and encrypting emails, pseudonymizing and/or anonymizing processing of personal data.
• Use of cookies and similar technologies: We use cookies and similar information collection technologies, such as web beacons on our website including essential, functional, analytical and targeting cookies. For more information, please visit our cookie policy here: https://www.wenstravelstore.ro/politica-de-cookie-uri
• Transfer of your personal data outside the European Economic Area: we will only transfer your personal data outside the European Economic Area if we are obliged to do so by law OR in certain circumstances where the transfer is necessary for the performance of the contract signed with you. When we do this, we will ensure that there are adequate safeguards in place, including that third parties who transfer your personal data outside the European Economic Area have self-certified as compliant with the EU-US Privacy Shield.
• Use of automated decision-making and profiling processes: we use automated decision-making and profiling processes by using Web Analytics tools, cookies, web beacons or server log analysis tools (profiling) or using targeting cookies to serve ads to people who visit our website on other websites (for example, by using the Google AdSense network).
• Your rights in relation to your personal data
— you have the right to access your data and receive information about its use
— you have the right to request the correction and/or completion of the information
— you have the right to request the deletion of your data
— you have the right to restrict the use of data
— you have the right to receive the data in a portable format
— you have the right to object to the processing of your data
— you have the right to withdraw your consent to the processing of your data
— you have the right not to be subject to a meaningful decision about you solely on the basis of automated processing of your data, including profiling
— you have the right to appeal to a supervisory authority
Sensitive Personal Information: We do not intend to collect what is commonly referred to as “sensitive personal data”. Please do not send sensitive personal information about yourself. For more information, please refer to the main section entitled “Sensitive Personal Information
The data controller for our website is: SC Wens Tour SRL. You can contact the data controller by writing to: Wens Tour, Strada Republicii nr. 10, 400015, Cluj-Napoca or by e-mail to protectiedate@wens.ro.
If you have any questions about this privacy policy, please contact the data controller.
We collect and use information from website visitors in accordance with this section and the section entitled Disclosure and Additional Uses of Your Data
We use a third-party server to host our website called Voxility IRD, whose privacy policy is available here:https://www.travelfuse.ro/politica-de-confidentialitate.html. Our website server automatically records the IP address you use to access our website, as well as other information about your visit, such as the pages accessed, the requested information, the date and time of the request, the source of access to our website (for example, the website or URL (link) that referred you to our website) and the version of your browser and operating system.
Our server is located in Romania within the European Economic Area.
Use of information from website server logs for IT security purposes
Our IT management and maintenance service providers collect and store server logs to ensure the security of the IT network. This includes analyzing log files to help identify and prevent unauthorized access to our network, distributing malicious code, anticipating DDOS attacks and other cyberattacks by detecting unusual or suspicious activity.
If we do not investigate suspicious or potential criminal activity, we do not make or allow our provider to make any attempt to identify you based on information collected through server logs.
Legal basis for processing: compliance with the legal obligations to which we are subject (Article 6 (1) (c) of the General Data Protection Regulation).
Legal obligation: The registration of access to our website using server log files is a technical measure to ensure an adequate level of security to protect the information collected from our website in accordance with Article 32 (1) of the General Data Protection Regulation.
Use of information from website server history to analyze site usage and improve our website
We use the information collected from our server log to analyze how users of our website interact with our website and its features. For example, we analyze the number of visits and unique visitors we receive, the time and date of the visit, the location of the visit, and the operating system and browser used.
We use the information collected from the analysis of this information to improve our website. For example, we use the information collected to modify the information, content and structure of our website and individual pages, depending on what attracts the most users and the length of time spent on certain pages of our website
Legal basis for processing: our legitimate interests (Article 6 (1) (f) of the General Data Protection Regulation).
Legitimate interest: to improve our website for our website users and to know the preferences of website users so that our website can better respond to their needs and wishes
Cookies are data files that are sent from a website to a browser to record information about users for various purposes.
We use cookies and similar technologies on our website, including essential, functional, analytical and targeting cookies and web beacons. For more information about the use of cookies, please refer to our cookie policy, which is available here:https://www.wenstravelstore.ro/politica-de-cookie-uri
You can reject some or all of the cookies we use on our website by changing your browser settings, but by rejecting them you can affect the functioning of the website or some features of the website. For more information about cookies, including how to change your browser settings, visit www.apti.ro/cookies/ or consult our cookie policy.
We collect and use information from individuals who contact us in accordance with this section and the section entitled Disclosure and Additional Uses of Your Information.
When you send a message to the email address displayed on our website, we collect your email address and any other information you provide in that email (such as your name, your phone number and the information contained in any signature block in the email).
Legal basis for processing: our legitimate interests (Article 6 (1) (f) of the General Data Protection Regulation).
Legitimate interest: To answer questions and messages we receive and to keep records of correspondence.
Legal basis for processing: it is necessary for the performance of a contract or to start the process of employment in a contract at your request (Article 6 (1) (b) of the General Data Protection Regulation).
Reason why it is necessary for the performance of a contract: If your message concerns the provision of goods or services or taking steps at your request before providing you with our goods and services (for example, providing information about such goods and services); we will process your information to do so).
Transfer and storage of your information
We use a third party email provider to store the emails you send us. Our email provider is HostVision SRL located in Romania. Its privacy policy is available here: https://hostvision.ro/protectia-datelor-personale-gdpr. The emails you send to us will be stored within the European Economic Area on the servers of a third party email provider in Romania.
We inform you that when you contact us using the contact form, we collect the following personal data from you: name, surname, e-mail, telephone number.
If you do not provide the mandatory information requested in the contact form, you will not be able to submit the contact form and we will not be able to receive your request.
Legal basis for processing: our legitimate interests
Legitimate interest: to answer questions and messages we receive and to keep records of correspondence. Transfer and storage of your information
The messages you send to us via our contact form will be stored within the European Economic Area on the servers of the hosting providers. Our hosting partner is TravelFuse (Sc Innomarketing Srl) located in Romania.
For more information about the precautions taken when your data is transferred outside the European Economic Area, please see the section of this privacy policy below entitled Transfer of your data outside the European Economic Area.
We use a third-party contact form provider to store the messages you send us. Our contact form provider is TravelFuse (Sc Innomarketing Srl) located in Romania. The messages you send to us via our contact form will be stored within the European Economic Area on the servers of our contact form provider located in Romania.
When you contact us by phone, we collect your phone number and any information you provide to us during your conversation with us.
We do not record phone calls.
Legal basis for processing: our legitimate interests (Article 6 (1) (f) of the General Data Protection Regulation)
Legitimate interest: to answer questions and messages we receive and to keep records of correspondence.
Legal basis for processing: it is necessary for the performance of a contract or to start the process of employment in a contract at your request (Article 6 (1) (b) of the General Data Protection Regulation).
Reason why it is necessary for the performance of a contract: If your message concerns the provision of goods or services or taking steps at your request before providing you with our goods and services (for example, providing information about such goods and services); we will process your information to do so).
Transfer and storage of your information
Information about your call, such as your telephone number and the date and time of your call, is processed by our telephone service provider Vodafone Romania SA and RCS&RDS SA. Its privacy policy is available here:https://www.vodafone.ro/consumption/groups/public/documents/digital_asset/v364945.pdfand here https://www.digiromania.ro/confidentialitate. The information about your call will be stored by our telephone service provider in accordance with the Romanian legislation.
If you contact us by mail, we will collect all the information you provide to us in any postal communications you send us.
Legal basis for processing: our legitimate interests (Article 6 (1) (f) of the General Data Protection Regulation)
Legitimate interest: to answer questions and messages we receive and to keep records of correspondence.
Legal basis for processing: it is necessary for the performance of a contract or to start the process of employment in a contract at your request (Article 6 (1) (b) of the General Data Protection Regulation).
Reason why it is necessary for the performance of a contract: If your message concerns the provision of goods or services or taking steps at your request before providing you with our goods and services (for example, providing information about such goods and services); we will process your information to do so).
We collect and use data from people who interact with certain features of our website in accordance with this section and the section entitled Disclosure and Additional Uses of Your Information.
When you sign up for our newsletter https://www.wenstravelstore.ro/or you choose to receive offers or information from us by entering your email address and clicking on a button titled “Subscribe”, we collect your email address.
Legal basis for processing: your consent (Article 6 (1) (a) of the General Data Protection Regulation).
Consent: You consent to receive our e-newsletter by signing up to receive it, using the steps described above.
Transfer and storage of your data
We use a service provided by a third party to send our e-newsletter and to manage our mailing list, MailChimp. The privacy policy is available here: https://mailchimp.com/legal/privacy/.
The information you submit to subscribe to our newsletter will be stored outside the European Economic Area on our provider's servers at 675 Ponce de Leon Ave NE, Suite 5000, Atlanta, GA 30308 USA. For more information about the security measures taken when your information is transferred outside the European Economic Area, please see the section of this privacy policy below, entitled Transfer of your data outside the European Economic Area.
Using Web Beacons in Emails
We use technologies such as web beacons (small graphic files) to measure the performance of our emails such as delivery rates, open rates and click rates. We will only use web beacons in our emails if you have given your consent.
For more information about how we use web beacons in our newsletter emails, please see our cookie policy, which is available here: https://www.wenstravelstore.ro/politica-de-confidentialitate
When you register and create an account on our website, we collect your email address.
If you do not provide the mandatory information required by the registration form, you will not be able to register or create an account on our website.
Legal basis for processing: necessary to take action at your request before concluding a contract.
Reason why processing is necessary to perform a contract: Creating an account on our website is necessary to allow you to access the services you have purchased from us.
Transfer and storage of your data
The information you provide to us through the registration form on our website will be stored within the European Economic Area on the servers of TravelFuse (Sc Innomarketing Srl) in Romania — Bucharest. Our hosting service provider — TravelFuse (Sc Innomarketing Srl) located in Romania. The privacy policy is available here: https://www.travelfuse.ro/politica-de-confidentialitate.html
We collect and use information from individuals who place an order on our website in accordance with this section and the section entitled Disclosure and Additional Uses of Your Data.
Necessary information
When you place an order for services on our website, we collect your name, billing address, delivery address, CNP, serial number and CI number, telephone, email, company data. This information will be forwarded to the tour operator, accommodation or other tourist service providers.
If you do not provide this information, you will not be able to purchase services from our website or enter into a contract with us.
Legal basis for processing: necessary for the performance of a contract
The reason it is necessary for the execution of a contract: We need the mandatory information collected through our verification form to determine who the contractor is and to contact you to fulfill our obligations under the contract, including sending receipts and order confirmations. Legal basis for processing: compliance with a legal obligation
Legal obligation:
— we have a legal obligation to issue you an invoice for the services you have purchased from us, in which you are registered for VAT purposes and we request the mandatory information collected for this purpose by our payment form.
— we are obliged to confirm your booking, for this purpose we collect data necessary to transmit it to third parties (other service providers).
After you place an order on our website, you will have to pay for the goods or services you have ordered. To process your payment, we use a third-party payment processor, Mobil Pay Netopia. Your payment will be processed by Mobil Pay, which collects, uses and processes your information, including payment information, in accordance with their privacy policies. You can access the privacy policy: https://www.mobilpay.ro/public/politica-de-confidientialitate/
Transfer and storage of your information
Netopia Mobil Pay is located in Romania. The information regarding the processing of your payment is stored in the European Economic Area on Netopia Pay servers in Romania.
Legal basis for processing: necessary for the performance of a contract (Article 6 (1) (b) of the General Data Protection Regulation).
The reason why we need to execute a contract: to fulfill your contractual obligation to pay for the goods or services you have ordered from us.
Our goods and services
You can sign up to receive marketing communications from us in relation to our goods and services [by email, text message, telephone, post.
We will only send you marketing communications in relation to our goods and services if you sign up to receive them.
Legal basis for processing: consent (Article 6 (1) (a) of the General Data Protection Regulation).
Consent: You consent to send you information about our goods and services by signing up to receive such information in accordance with the steps described above.
Transfer and storage of your information
We use a third-party service for managing our email list, MailChimp. The information you submit to subscribe to our newsletter will be stored outside the European Economic Area on Mailchimp servers in the USA, Atlanta, Georgia. For further information on the security measures used when your information is transferred outside the European Economic Area, please refer to the section of this privacy policy below entitled “Transfer of your data outside the European Economic Area”
Use of web beacons and similar technologies in emails
We use technologies such as web beacons (small graphic files) to evaluate the performance of our emails such as delivery rates, open rates and click-through rates. We will only use web beacons in our emails if you have given your consent.
For more information about how we use web beacons in our emails, please see our cookie policy, available here:https://www.wenstravelstore.ro/politica-de-cookie-uri
Goods and services of third parties
In addition to receiving information about our products and services, you may opt to receive marketing communications from us in relation to third party goods and services by email, text message, telephone, post by giving your consent e.g. by ticking a box indicating that you wish to receive such communications.
Legal basis for processing: consent (Article 6 (1) (a) of the General Data Protection Regulation).
Consent: You consent to send you information about third party goods and services by signing up to receive such information in accordance with the steps described above.
This section sets out how we obtain or collect information about you through third parties.
In general, we/do not receive information about you from third parties. Those third parties from whom we receive data about you will generally include group companies, affiliates or business partners.
It is also possible that third parties with whom we have had no prior contact may provide us with information about you.
The information we obtain from third parties will generally be your name and contact details, but will include any additional information about you that they provide to us.
Legal basis for processing: it is necessary for the performance of a contract or to take steps at your request to conclude a contract (Article 6 (1) (b) of the General Data Protection Regulation).
Reason why it is necessary to perform a contract: If a third party has provided information about you (such as your name and email address) to provide you with services, we will process your information to take action on your request to enter into a contract with us (as applicable).
Legal basis for processing: consent (Article 6 (1) (a) of the General Data Protection Regulation).
Consent: If you have requested that a third party disclose information about you to us and the purpose of disclosing such information is not related to the performance of a contract or service by us to you, we will process your information on the basis of your consent, which you provide by requesting the third party to forward the information to you us.
Legal basis for processing: our legitimate interests (Article 6 (1) (f) of the General Data Protection Regulation).
Legitimate interests: If a third party has disclosed information about you to us and you have not given your consent in exchange for that information, we will have a legitimate interest in processing this information under certain circumstances. For example, we will have a legitimate interest in processing your information to fulfill our obligations under the subcontract with the third party, if the third party has the main contract with you. Our legitimate interest is the fulfilment of our obligations under our subcontract.
Similarly, third parties may transmit information about you to us if you have violated or could violate any of our legal rights. In this case, we will have a legitimate interest in processing this information to investigate and pursue any such potential breach.
If we mistakenly receive information about you from a third party and/or do not have a legal basis for processing this information, we will delete your information.
In certain circumstances (for example, to verify the information we hold about you or to obtain missing information that we need to provide you with a service), we will obtain data about you from certain publicly accessible sources, both within the EU and outside the EU, such as: partner agencies, social media, websites, including the website https://www.wenstravelstore.ro/
Legal basis for processing: it is necessary for the performance of a contract or to take steps at your request to conclude a contract (Article 6 (1) (b) of the General Data Protection Regulation).
Reason for entering into a contract: If you have entered into a contract or asked us to enter into a contract with you in certain circumstances, we will obtain information about you from public sources to enable us to understand your business and provide services to a sufficient standard for you.
For example, we will obtain and/or verify your email address from your website if you ask us to send you information by email and we do not have or need confirmation of your email address.
Legal basis for processing: our legitimate interests (Article 6 (1) (b) of the General Data Protection Regulation).
Legitimate interests: Under certain circumstances, we will have a legitimate interest in obtaining information about you from public and private sources. For example, if you have infringed or suspect that you have violated any of our legal rights, we will have a legitimate interest in obtaining and processing information about you from these sources in order to investigate and pursue any suspected or potential infringement.
Legal basis for processing: consent (Article 6 (1) (a) of the General Data Protection Regulation).
We use automated decision-making and profiling mechanisms on our website. We do not believe that this has a legal effect on you or affects you in a similar way.
You have the right to object to our use of automated decision-making and profiling mechanisms described in this section. You can do this by opting out of cookies and similar technologies in accordance with the method described in the relevant section of this privacy policy. If you do not want us to process your real IP address (usually the IP address assigned by the Internet Service Provider) when you visit our website, you can use a virtual private network (VPN) or a free service such as Tor.
You can learn more about the use of cookies and similar technologies (including the legal basis for their use) and how to opt out of them in the cookie policy, available here: https://www.wenstravelstore.ro/politica-de-cookie-uri
Automated decision-making mechanisms are those mechanisms that make decisions by technological means (by means of a machine) without human involvement.
Use of automated decision making mechanisms for advertising
We automate the display of advertisements containing our products and services on other websites that you visit through the use of cookies. For more information about the types of cookies we use, please refer to our cookie policy, available here: https://www.wenstravelstore.ro/politica-de-cookie-uri
The logic involved: Automatically displaying ads to people who have visited our site leads to increased advertising efficiency and is more economical for us than manual or other advertising methods.
Significance and expected consequences: Cookies will be used to recognise that you have visited our website to show you advertisements (unless you have blocked such cookies) and collect information about your online behaviour.
How to object: You can block these types of cookies by blocking third party cookies using your browser settings
Profiling is any form of automated processing of your information to assess personal aspects about you, in particular to analyze or predict things such as performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements.
Using Profiling to Analyze Online Behavior
Our online behavior analysis service, Google Analytics, uses information such as your location (based on your address). IP) and your behaviour (based on cookies) when you access the website (such as the pages you visit and what you click on). We will only process information from cookies if you have given your consent to the storage of cookies on your computer in accordance with the cookie policy https://www.wenstravelstore.ro/politica-de-cookie-uri. The information collected about you, once collected, is anonymous and stored in an aggregated database.
Logic involved: By automatically analysing and classifying information such as location (based on IP address), as well as the behaviour and devices of visitors to our website (using cookies), we can better understand what visitors to our website want (in terms of our website content and our products), how to improve the website and how to advertise and to market our services.
Meaning and expected consequences: Cookies will be used to track and store information about your behavior and device on our website, the location will be analyzed based on your address. IP. We may target ads based on the level of interest we receive from certain visitors and their behavior on our website.
Legal basis for processing: Your legitimate interests Article 6 (1) (f) of the General Data Protection Regulation.
Legitimate interest: improving products and services created for our travelers
Using Profiling in Marketing Emails
We use web beacons in our marketing emails to analyze who opens our emails and what actions they take (for example, which links they click on. We will only process information from web beacons if you have consented to their use in accordance with our cookie policy https://www.wenstravelstore.ro/politica-de-cookie-uri
The logic involved: By analyzing how email recipients respond to our emails, we can improve the content and efficiency of our emails and infer who are most interested.
Significance and Expected Consequences: Your behavior when opening our emails will be tracked using small gif files (web beacons) to measure the opening rate as well.
How to object: unsubscribe from the newsletter service
Legal basis for processing: legitimate interest (Article 6 (1) (f) of the General Data Protection Regulation).
Legitimate interest: Analyzing the engagement and effectiveness of our emails and marketing content.
This section sets out the circumstances in which we will disclose your data to third parties and any other additional purposes for which we use your data.
We use a number of third parties to provide us with services that are necessary to run our business or to help us run our business and who process your information for us on our behalf. These include the following:
• Telephone service providers, including Vodafone and RCS&RDS. Their privacy policy is available here: https://www.vodafone.ro/consumption/groups/public/documents/digital_asset/v364945.pdfand here https://www.digiromania.ro/confidentialitate
• Email service providers, including Maichimp. Their privacy policy is available here: https://mailchimp.com/legal/privacy/.
• IT service providers, including Itech Media SRL. Their privacy policy is available here: http://dominopc.ro/politica-de-confidentialitate/
• Developers of websites and web hosting services, including TravelFuse. Their privacy policy is available here:https://www.travelfuse.ro/politica-de-confidentialitate.html
Our service providers are located in Romania OR USA (Mailchimp).
Your information will be shared with these service providers where necessary to provide you with the service you have requested, whether that request is to access our website or order goods and services from us.
We do not publicly disclose the identity of our service providers for security and competitive reasons. If, however, you would like further information about the identity of the service providers, please contact us directly by email: protectiedate@wens.ro and we will provide you with such information if you have a legitimate reason to request it.
Legal basis for processing: legitimate interests (Article 6 (1) (f) of the General Data Protection Regulation).
Legitimate interest based on: If we share your information with these third parties in a context other than where necessary to perform a contract (or following your request to do so), we will share your information with such third parties to enable us to conduct and manage our business efficiently.
Legal basis for processing: it is necessary for the performance of a contract or to take steps at your request to conclude a contract (Article 6 (1) (b) of the General Data Protection Regulation).
Reason why it is necessary to perform a contract: We may share information with our service providers to enable us to fulfill our obligations under that contract or to take the steps you requested before entering into a contract with you.
We disclose your information to third parties under certain circumstances, as shown below.
Providing information to third parties, such as Google Inc. Google collects information through our use of Google Analytics on our website. Google uses this information, including IP addresses and cookie information, for a number of purposes, such as improving the Google Analytics service. The information is shared with Google on an aggregated and anonymous basis. To learn more about what information Google collects, how it uses this information, and how to control the information sent to Google, see the following page: https://www.google.com/policies/privacy/partners/
Legal basis for processing: our legitimate interests (Article 6 (1) (f) of the General Data Protection Regulation).
Legitimate interests: Fulfilment of contractual obligations to Google under the Google Analytics Terms and Conditions (https://www.google.com/analytics/terms/us.html). You can opt out of Google Analytics by installing the browser plugin here: https://tools.google.com/dlpage/gaoptout
