as of 20 May 2018
RomFriend SRL, a limited liability company incorporated in Romania and the operator of www.romanianfriend.com, captures, processes and uses data as part of its online services offer (the 'Service'). The protection of your personal data, as part of the services we provide to all RomanianFriend.com users, is very important to us.
The party responsible for data protection is RomFriend SRL, a limited liability company incorporated in Romania and headquartered at 2 Duiliu Zamfirescu Street, room 3, Oradea, Bihor county (“RomFriend” or “we”), to whom you have given the appropriate consent for the use of your personal data. We reserve the right to adjust the content of this privacy statement from time to time. It is therefore advisable to periodically review this privacy statement.
RomFriend considers data protection and privacy to be of paramount importance. We never sell personal data and we carry out all processing operations in strict compliance with the EU General Data Protection Regulation (“GDPR”) (specifically but not limited to Article 6(1)(b) to (f) and Article 28) as well as the Laws of Romania (together the “Applicable Law”), where RomFriend is incorporated.
1. General Information
We commit ourselves to observe the applicable data protection laws, in particular, the provisions of Law No. 677/2001 on the Protection of Individuals with Regard to the Processing of Personal Data and the Free Movement of Such Data and the Data Protection Authority specific decisions applicable in Romania, in accordance with GDPR.
We collect, process and use your personal data only with your consent or when this processing or use is permissible by law. We only process or use the data which is required for using the site, processing a booking request or the data which you provide to us.
2. Personal Data
Personal data is specific information about personal or factual circumstances regarding an identified or identifiable natural person, in accordance with the applicable legislation in Romania.
RomFriend collects the following personal data when a user is making a booking request on the website: full name, residence address, email and telephone number. This information is needed (1) for the purposes of billing the user the service fee charged by RomFriend for its Service and (2) to provide the Service by facilitating contact between a client of RomFriend and our partner-guides.
Except for sections 3 and 5, no other personal data is collected by RomFriend from the visitors of this website.
3. What kind of Personal Data we collect, when and how we use it
We collect, process and use information about you in the following situations and for the following purposes:
- 3.1 When providing our Service (the booking request)
In order for us to provide the Service, we collect your personal data when you go through the process of requesting a booking for a specific tour. The data we collect is your full name, address, email and telephone number.
We will use the above information for billing purposes when processing the online payment. The booking process requires that you pay (1) an advance of the tour price and (2) the RomFriend Service fee.
We are an intermediary and as part of our Service, if your booking is confirmed by our partner-guides we will share your personal details with the relevant partner guide (operator of the tour you booked) in order to facilitate contact between the two of you. This is done for the purposes of setting up meeting details and other details. Each of our partner-guides is an independent entity and if you have any questions regarding how they store, use and process your personal data you should ask them directly.
If your booking is declined by our partner-guides, we will not share your personal data with anyone.
All personal data collected during the booking process will be stored by us on our servers and using our custom-built website content management system. After the provision of the Service, we may use your email address to send you our newsletter and other emails regarding news and promotional offers connected to our Service. When going through the booking process, you have the option to opt-out of this subscription.
- 3.2 When you contact us
On our site you have the opportunity to contact us and ask questions about visiting Romania, our tours and/or clarifications about the Service we provide.
If you send us a message using the contact form on our website we collect and process your name and email address. We use this data solely in connection with answering the queries we receive.
We will store and use your email address to send you newsletters or promotional offers connected to our Service, but only if you opt-in to receive such emails from us by ticking the box on the contact form page.
- 3.3 When you chat with us live
Through Smartsupp we are able to see certain information about website visitors who are browsing the website at any given moment, such as country of residence, device used and internet browser. No personal data is collected, stored or managed in this process.
If the live chat feature is not available, website visitors are able to leave an offline message via the Smartsupp chatbox. In order for us to respond to any question, we will need your name and email address. This information will be used by us the same way as described in section 3.2 above.
The legal entity operating the Smartsupp service may collect, processes or store any personal data according with its own policies. RomFriend does not offer any representation, warranties or guarantees that this is done in compliance with applicable data protection laws and RomFriend shall not be liable in any way for any breaches or non-compliance with such applicable laws.
- 3.4 When you visit our website. Cookies and Google Analytics
RomFriend stores this information in a pseudonymized user profile meaning that we can only see certain technical and non-specific information about a visitor, such as the geographical location, the operating system and device used, internet provider, screen resolution and information about the web-sites that directed you to us, the number and date of your visits, your average time on our site and which of our website’s pages you visited. Cookies are not used to collect any personal data that would allow us to identify individual users or to match it with further technical data of any kind. This data collecting, processing and storage is done automatically via Google Analytics (see section 5 below). The evaluation is done anonymously and exclusively for statistical purposes with the goal of continuing to improve our web presence for you.
Cookies are stored on your individual device and you have full control over their use. You may deactivate or restrict the transmission of cookies by changing the settings of your web browser. Cookies that are already stored may be deleted at any time. Should you visit RomFriend website with cookies deactivated, you may possibly not be able to use all of the functions on our site to the full extent.
4. Transfer of Personal Data
RomFriend will not share any data collected about you, whether personal or not, with any third parties, unless the transmission is required or by applicable laws. We will, in particular, not sell or otherwise market your data to third parties. Transfers of data to government institutions and authorities is done only within the scope of mandatory national legal requirements. Our employees and partners are obligated by us to maintain secrecy and to comply with legal personal data protection regulations.
5. Cookies and Google Analytics
6. Use of your data for newsletter
Based on your declaration of consent, RomFriend will process and use your personal data (email address) for marketing activities and campaigns, such as for sending emails with general information, advertising or promotional offers (newsletters).
Your consent to receive our newsletter is implied when you are making a booking request (using our Service), but you have the option to opt-out. The consent is not implied when you use our contact form to send us a message, but you can opt-in. You can always revoke your consent to receiving such newsletters at any time by clicking on the ‘unsubscribe’ button located at the end of each email or sending us an email asking to be remove you from our list of subscribers to the following address: email@example.com.
7. About Data Collected From Mobile Applications or Devices
When you visit our website using a mobile device (smartphone, tablet, etc.) we also collect information about the device you are using.
No other personal data or information is collected in the process other than in the situations described in sections 3 above.
8. Your data = your rights
You have a right to be informed of any personal data processed by RomFriend, a right to rectification/correction, erasure and restriction of processing. You also have the right to receive from RomFriend a structured, common and machine-readable format of any personal data you have provided to us and the right to object to any processing of this personal data by us.
We can only identify you via your email address and we can only adhere to your request and provide information if we have personal data about you if you have made a specific request for this by having contacted us directly. We cannot provide, rectify or delete any data that we store on behalf of other users or customers.
Where you have provided consent, you may withdraw it at any time, without affecting the lawfulness of the processing that was carried out prior to withdrawing it. Whenever you withdraw consent, you acknowledge and accept that this may have a negative influence on the quality of the Romanian Friend website and/or Service. You further agree that RomFriend shall not be held liable with respect to any loss and/or damage to your personal data if you choose to withdraw consent.
Where personal data is processed for the above purposes on the basis of RomFriend’s legitimate interests and for the provision of the Service, under the GDPR, you may object to such processing at any time. To do so please contact us at firstname.lastname@example.org.
In addition, you have the right to lodge a complaint with the data protection authority in the Romanian jurisdiction.
9. Data storage and duration of processing
We will store your data (personal or not) for a maximum period of 24 months or until such time when you withdraw your consent for us to do so. We may also retain information as required by law.
Once the personal data is no longer required by us or a user informs that he/she no longer wants to be contacted, we will immediately delete this data.
As part of the Service we offer, RomFriend attributes the very highest importance to the security and integrity of its customers’ personal data.
Thus and in accordance with the GDPR, RomFriend undertakes to take all pertinent precautions in order to preserve the security of the data and, in particular, to protect them against any accidental or unlawful destruction, accidental loss, corruption, unauthorised circulation or access, as well as against any other form of unlawful processing or disclosure to unauthorised persons.
To this end, RomFriend implements industry standard security measures to protect personal data from unauthorised disclosure, for example by using an SSL-encrypted connection. In using industry recommended methods of encoding, RomFriend takes the measures necessary to protect all information connected to personal data.
RomFriend does not store any bank card data. Please see section 3.1 for more information about this.
Notwithstanding this, there is no absolute safety from piracy or hackers. That is why in the event a breach of security were to affect you, RomFriend undertakes to inform you thereof without undue delay and to use its best efforts to take all possible measures to neutralize the intrusion and minimize the impacts. Should you suffer any loss by reason of the exploitation by a third party of a security breach, RomFriend undertakes to provide you with every assistance necessary so you are able to assert your rights regarding your personal data.
You should keep in mind that any user, customer or hacker who discovers and takes advantage of a breach in security renders him or herself liable to criminal prosecution and that RomFriend will take all measures, including filing a complaint with the relevant authorities and/or bringing court action as reasonably possible, to preserve the data and the rights of its users and of itself and to limit the impacts.
Please direct requests for information, questions, complaints or suggestions to the following address:
2 Duiliu Zamfirescu Street, room 3, Oradea, Bihor county
Trade Registry no. J5/2249/2016
Sole Registration Code 36873898