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 applies from May 25th, 2018.
https://www.wenstravelstore.ro/
This section summarizes how we obtain, store, and use your data. This summary is intended to provide a general overview of our privacy policy only. This section is not a complete description and it is necessary to read the additional chapters in this document for completion.
https://www.wenstravelstore.ro/politica-de-cookie-uri
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 email at 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 titled 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 web server automatically logs your IP address that you use to access our website, as well as other information about your visit, such as pages accessed, information requested, date and time of the request, source of access to our site (e.g., web site or URL (link) that referred you to our site), and version of browser and operating system.
Our server is located in Romania within the European Economic Area.
Using information from the server logs of the website for IT security purposes
Our IT management and maintenance service providers collect and store server logs to ensure IT network security. This includes analyzing log files to help identify and prevent unauthorized access to our network, distribution of malicious code, forecasting DDOS attacks and other cyber attacks by detecting unusual or suspicious activities.
If we do not investigate a suspected or potential criminal activity, we do not make and do not allow our provider to make any attempt to identify you based on the information collected through the server logs.
Legal basis for processing: compliance with legal obligations to which we are subject (Article 6 (1) letter (c) of the General Data Protection Regulation).
Legal obligation: recording access to our website using server log files is a technical measure to ensure an adequate level of security to protect the information collected on our site in accordance with Article 32 (1) of the General Data Protection Regulation.
Using website server history information to analyze website usage and improve our websit.
We use information collected from our server log to analyze how our website users 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 we collect to change the information, content and structure of our website and individual pages based on what attracts the most users and how long they spend on certain pages on our website.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest: improving our website for our website users and knowing 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 on the use of cookies, see 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 rejecting them may affect the functioning of the website or some features of the website. For more information on cookies, including how to change your browser settings, visit www.apti.ro/cookies/ or see our cookie policy.
We collect and use information from individuals who contact us in accordance with this section and with the section titled 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, phone number, and information contained in any email signature block).
Legal basis for processing: our legitimate interests (Article 6 (1) (f) of the General Data Protection Regulation).
Legitimate interest: to respond to the 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 take steps at your request prior to entering into a contract (Article 6 (1) (b) of the General Data Protection Regulation).
Reason why it is necessary for making a contract: if your message concerns the supply of goods or services or taking measures at your request before supplying our goods and services (for example, providing information about such goods and services); we will process your information to do this).
Transferring and storing your informations
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 us will be stored within the European Economic Area on servers of a third-party email provider located 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, phone 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 respond to the questions and messages we receive and to keep a record of correspondence. Transferring and storing your information.
The messages you send us through our contact form will be stored within the European Economic Area on the servers of our hosting providers. Our hosting services provider partner is the company TravelFuse (Sc Innomarketing Srl) located in Romania.
For more information about the precautions taken when your data is transferred outside the European Economic Area, see the section in this privacy policy entitled Transferring 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 the company TravelFuse (Sc Innomarketing Srl) located in Romania. The messages you send us through 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 us during the conversation.
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 respond to the questions and messages we receive and to keep a record of correspondence.
Legal basis for processing: it is necessary for the performance of a contract or to initiate the process of entering into a contract at your request (Article 6 (1) (b) of the General Data Protection Regulation).
Reason why it is necessary for making a contract: if your message concerns the provision of goods or services or taking measures 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 this.
Transfer and storage of your information
Information about your call, such as your phone number and the date and time of your call, is processed by our phone services provider, Vodafone Romania SA and RCS&RDS SA. Their privacy policy is available at https://www.vodafone.ro/consumption/groups/public/documents/digital_asset/v364945.p df and https://www.digiromania.ro/confidentialitate. The information about your conversation will be stored by our phone services provider in accordance with Romanian law.
When you contact us by mail, we collect all the information you provide 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 respond to the questions and messages we receive and to keep a record of correspondence.
Legal basis for processing: necessary for performance of a contract or initiation of contract performance at your request (Article 6 (1) (b) of the General Data Protection Regulation).
Reason why it is necessary for making a contract: if your message concerns the provision of goods or services or taking actions 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 individuals who interact with certain features of our website, in accordance with this section and the section titled Disclosure and Additional
Uses of Your Information.
When you sign up for our newsletter https://www.wenstravelstore.ro/ or choose to receive offers or information from us by entering your email address and clicking on a button labeled “Subscribe,” we collect your email address.
Legal basis for processing: your consent (Article 6 (1) (a) of the General Data Protection Regulation).
Consent: you give your 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 third-party service to send our newsletter and manage our email list, MailChimp. The privacy policy is available here: https://mailchimp.com/legal/privacy/. The information you provide to subscribe to our newsletter will be stored outside the European Economic Area on our provider’s servers located at 675 Ponce de Leon Ave NE, Suite 5000, Atlanta, GA 30308 USA. For more information on the security measures taken when your information is transferred outside the European Economic Area, refer to the section in this privacy policy entitled “Transfer of Your Data Outside the European Economic Area”.
Use of web beacons in emails
We use technologies like web beacons (small graphic files) to measure the performance of our emails, such as delivery rates, open rates, and click-through rates. We will use web beacons in our emails only if you have given your consent for this.
For more information on 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 entering into a contract.
Reason why processing is necessary to perform a contract: creating an account on our website is necessary to allow you access to the services you have purchased from us.
Transfer and storage of your data
The information you provide us through the registration form on our website will be stored within the European Economic Area on servers of the company TravelFuse (Sc Innomarketing Srl) located in Bucharest, Romania. Our hosting provider – TravelFuse (Sc Innomarketing Srl) is located in Romania. The privacy policy is available here: https://www.travelfuse.ro/politica-de-confidentialitate.html
https://www.wenstravelstore.ro/
We collect and use information from individuals who place an order on our website in accordance with this section and the section titled Disclosure and additional uses of your data.
Necessary Information
When placing an order for services on our website, we collect your name, billing address, shipping address, ID number, CI series and number, phone, email, and company information. These details will be passed on to the tour operator, accommodation unit, or other travel 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 execution of a contract.
Reason why it is necessary for the execution of a contract: we need the mandatory information collected through our checkout form to establish who the contracting party 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:
After placing an order on our website, you will need 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 data
Netopia Mobil Pay is located in Romania. Your payment processing information is stored in the European Economic Area on Netopia Pay servers in Romania.
The legal basis for processing: necessary for performance of a contract (Article 6 (1) (b) of the General Data Protection Regulation).
The reason why it is necessary to perform a contract: to fulfill your contractual obligation to pay for the goods or services you ordered from us.
Our goods and services
You can sign up to receive marketing communications from us regarding our goods and services through email, text message, phone, or post.
We will only send marketing communications regarding 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 give your consent to receive 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 data
We use a third-party service provided by MailChimp to manage our email list. The information you submit to subscribe to our newsletter will be stored outside the European Economic Area on Mailchimp servers in Atlanta, Georgia, USA. For more information on the security measures used when your information is transferred outside the European Economic Area, please refer to the section in this privacy policy titled “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 rates. We will use web beacons in our emails only if you have given your consent for this.
For more information on how we use web beacons in our emails, please refer to our cookie policy available here: https://www.wenstravelstore.ro/cookie-policy
Third party goods and services
In addition to receiving information about our products and services, you can opt to receive marketing communications from us about third party goods and services by email, text message, telephone, or post by giving your consent, such as 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 give your consent for us 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. The third parties from whom we receive data about you will typically include group companies, affiliates, or business partners.
It is also possible for third parties with whom we have had no prior contact to provide us with information about you.
The information we obtain from third parties will generally include your name and contact details, but will include any additional information about you that they provide to us.
Legal basis for processing: necessary for the performance of a contract or taking steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why it is necessary for making a contract: If a third party has transmitted information about you (such as your name and email address) to provide you with services, we will process your information to take steps at your request to enter into a contract with us (as the case may be).
Legal basis for processing: consent (Article 6 (1) (a) of the General Data Protection Regulation).
Consent: In the case where you have requested that a third party disclose information about you and the purpose of disclosing this information is not related to us providing a contract or service to you, we will process the information based on your consent, which you grant by requesting the third party to transmit the information to us.
Legal basis for processing: our legitimate interests (Article 6 (1) (f) of the General Data Protection Regulation).
Legitimate interests: In the case where a third party has disclosed information about you and you have not given your consent in exchange for this information, we will have a legitimate interest in processing this information in certain circumstances. For example, we will have a legitimate interest in processing your information to fulfill our obligations that arise from our subcontract with the third party, in case the third party has the main contract with you. Our legitimate interest is fulfilling 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 in order to investigate and pursue any such potential violation.
If we inadvertently 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 we need to provide you with a service), we will obtain data about you from publicly accessible sources both within and outside the EU, such as partner agencies, social media, websites, including the website
https://www.wenstravelstore.ro/ .
Legal basis for processing: necessary for performance of a contract or taking steps at your request prior to entering into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why it is necessary for making a contract: If you have entered into a contract or requested to enter into a contract with us in certain circumstances, we will obtain information about you from public sources to allow 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 request us to send information to you via email and we don’t 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: in certain circumstances, we will have a legitimate interest in obtaining information about you from public and private sources. For example, if you have breached or we suspect you have breached any of our legal rights, we will have a legitimate interest in obtaining and processing information about you from these sources, to investigate and pursue any suspected or potential breach.
Legal basis for processing: consent (Article 6(1)(a) of the General Data Protection Regulation).
We use automated decision-making and profiling on our website. We do not consider 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 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 site, you can use a virtual private network (VPN) or a free service such as Tor.
You can find out 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 for making decisions by technological means (via a machine) without human involvement.
Use of automated decision-making mechanisms for advertising
We automate the display of ads that contain our products and services on other websites you visit using cookies. For more information about the types of cookies we use, please consult our cookie policy available here: https://www.wenstravelstore.ro/cookie-policy
The logic involved: Automatically displaying ads to people who have visited our site increases the efficiency of advertising and is more cost-effective for us than manual display or other advertising methods.
Meaning and predicted consequences: Cookies will be used to recognize that you have visited our site to display ads to you (unless you have blocked such cookies) and will gather information about your online behavior.
How to object: You can block these types of cookies by blocking third-party cookies using your browser settings.
Profiling refers to any form of automated processing of your information to evaluate personal aspects about you, especially to analyze or predict things such as work performance, economic situation, health, personal preferences, interests, reliability, behavior, location, or movements.
Using profiling for online behavior analysis
Our online behavior analysis service, Google Analytics, uses information such as your location (based on your IP address) and your behavior (based on cookies) when you access our website (such as the pages you access and what you click on). We will process information from cookies only if you have given your consent for storing cookies on your computer in accordance with our cookie policy available here:
https://www.wenstravelstore.ro/cookie-policy. The information collected about you, once collected, is anonymous and stored in an aggregated database.
The logic involved: By analyzing and automatically categorizing information such as location (based on your IP address) and the behavior and devices of website visitors (using cookies), we can better understand what website visitors want (in terms of website content and our products), how to improve the website, and how to advertise and market our services.
The predicted significance and consequences: Cookies will be used to track and store information about your behavior and device on our website, and your location will be analyzed based on your IP address. We can target advertisements based on the level of interest we receive from certain visitors and their behavior on our website.
The legal basis for processing: Your legitimate interests, Article 6 (1) (f) of the General Data Protection Regulation.
Legitimate interest: Improving the products and services created for our travelers. Profile usage in marketing emails
We use web beacons in our marketing emails to analyze who opens our emails and what actions they take (for example, what links they click on). We will only process information from web beacons if you have consented to their usage 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 effectiveness of our emails and deduce which people are most interested.
The predicted significance and consequences: your behavior when opening our emails will be tracked using small gif files (web beacons) to measure, among other things, the open rate.
Objection method: 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 level of 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 additional purposes for which we use your data.
We use a number of third-party providers to provide us with services that are necessary for running our business or helping us run our business and which process your information for us on our behalf. These include the following:
https://www.vodafone.ro/consumption/groups/public/documents/digital_asset/v364945.pdf and here https://www.digiromania.ro/confidentialitate
Our service providers are located in Romania OR in the 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 site or order goods and services from us.
We do not display the identity of our service providers publicly for security and competitive reasons. If, however, you would like additional information about the identity of our 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: where we share your information with such third parties in a context other than where it is 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 effectively.
Legal basis for processing: it is necessary for entering into a contract or taking steps upon your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why it is necessary for making a contract: we may share information with our service providers to enable us to fulfill our obligations under the contract or to take steps you have requested before entering into a contract with you.
We disclose your information to third parties in certain circumstances as set out 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 several 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 that information, and how to control the information you submit to Google, please visit 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: fulfillment 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