GENERAL DATA PROTECTION REGULATION POLICY– DPP

 

The new EU Data Protection Regulation (GDPR) entered into force on May 25, 2016, but will begin to take effect as of May 25, 2018. This law is the most major change in personal data protection over the last 20 years, and has objectives that go far beyond just protecting private space.

The protection of your personal data is important to us, therefore we pay special attention to protecting the privacy of visitors visiting the ENKI BUSINESS site, in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 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 next Policy (“DPP”) to understand how your information will be treated (“personal data”).

DPP explains the online practices of ENKI BUSINESS regarding the application of the GDPR provisions, as well as the rights you enjoy with regard to how your information is used through the ENKI BUSINESS website.

The processing of personal data by ENKI BUSINESS will always be done in accordance with the GDPR provisions as well as with the personal data protection regulations specific to each country where ENKI BUSINESS operates.

Through DPP, ENKI BUSINESS wishes to inform visitors about the nature of the personal data we collect and process, as well as about the purposes of the processing. In addition, site visitors are informed through the DPP and about their rights.

WHO WE ARE?

We are ENKI BUSINESS S.R.L., a company with headquarters in Bucharest, sector 1, Caraiman street no. 59, block A, with serial number in the Trade Register J40 / 4545/2008, and unique registration code 23481965. We have as main field of activity, Activities of tour operators CAEN 7912, and our legal representatives are administrators Pricop Oana – Iulia and Deak Alina Nicoleta.

ENKI BUSINESS S.R.L. is also known under the trade name of FREE SPIRIT.

 

WHAT ARE THE PERSONAL DATA?

“Personal data” means any information or information that can identify you directly (for example, your name) or indirectly (for example, by pseudonymised data such as a unique identifier). This means that personal data includes things like email address, home address, mobile phone number, username, profile photos, personal preferences and shopping habits, user-generated content, financial information, and financial status information. This could include unique numeric identifiers, such as your computer’s IP address or MAC address of your mobile device, as well as cookies.

 

WHAT DOES THE PROCESSING OF PERSONAL DATA MEAN?

“Processing” means any operation or set of operations performed on personal data or on personal data sets with or without the use of automated means such as collecting, recording, organizing, structuring, storing, adapting or modifying, extraction, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

 

PERSONAL DATA OPERATOR

The Personal Data Operator (hereinafter referred to as the “Operator”) is ENKI BUSINESS.

 

DATA PROTECTION RESPONSIBLE (DPO)

ENKI BUSINESS, as an operator, designated Ms Adela Nuţă as Data Protection Officer (DPO), having the obligation to ensure compliance with the GDPR provisions in the data processing operations performed by the company.

Site visitors may at any time directly address the DPO on any matter related to this DPP using the contact details below:

Name DPO: Adela Nuță

E-mail DPO: adela.nuta@jantea-law.ro

Tel. DPO: 0766753560

Mailing address DPO: Bucharest, sector 1, no. 9, Transilvaniei street

PRINCIPLES ON DATA PROCESSING

ENKI BUSINESS undertakes to comply with the principles of personal data protection (hereinafter referred to as the “Principles”) set out in the GDPR to ensure that all data are:

  1. Processed fairly, legally and transparently;
  2. Collected for specified, explicit and legitimate purposes;
  3. Adequate, relevant and limited in relation to the purposes for which they are processed;
  4. Correct and up-to-date;
  5. Stored in a form that does not allow the identification of the data subjects longer than necessary for the purposes of the processing;
  6. Processed in accordance with the rights of the data subject, in a way that ensures adequate processing security so that the data is complete, confidential and available.

 

THE BASIS AND PURPOSES OF PERSONAL DATA PROCESSING

  • For the purpose of concluding and executing contracts – According to art. 6 par. 1 letter b) from 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 you own.
  • For the purpose of fulfilling legal obligations – According to art. 6 par. 1 letter c) of GDPR, personal data may be processed for the purpose of fulfilling legal obligations. We request a series of personal data, including, in some cases, the personal numeric code, in order to fulfill our tax authorities’ obligations regarding invoicing and reporting to tax authorities.
  • For marketing purposes – According to art. 6 par. 1 letter a) of GDPR, personal data may be processed if the data subject has given his / her consent to the processing of his or her personal data for one or more specific purposes. So if you subscribed to the Newsletter section, your personal data will be used to send you marketing messages, offers, news, upcoming campaigns and invitations to various events. Your personal data is to be deleted immediately when you cancel your subscription in the Newsletter section. You can unsubscribe at any time via the link attached to the received communications or by a written request addressed to the DPO.

 

PROCESSING THE CONTACT FORM

ENKI BUSINESS will use the information you provide in the appropriate contact section on the site solely for the purpose of processing your request.

By providing any personal data through the ENKI BUSINESS website, you understand and agree that your data will be processed in accordance with the DPP provisions of ENKI BUSINESS.

Please be aware that in order to be able to process your requests submitted to the site’s contact section, it is possible that under certain circumstances we will be required to disclose your data to partners with whom ENKI BUSINESS collaborates and / or other third-party service providers of ENKI BUSINESS.

However, ENKI BUSINESS has adopted appropriate technical and organizational measures to ensure the security of data transfer as well as the processing of your data by the entities mentioned above in accordance with the GDPR requirements of your data.

Your personal data may be transferred to other third parties only on your express consent, except where there is a legal obligation for ENKI BUSINESS to do so.

ENKI BUSINESS undertakes not to process personal data provided for any purpose other than that for which they were transmitted, except in cases where your express consent is for use for other purposes as well.

 

DISCLOSURE OF PERSONAL DATA TO THIRD PARTIES

Personal data processed through the ENKI BUSINESS website may be disclosed and / or transferred to third parties only if your express consent to doing so exists, except where there is a legal / contractual obligation to ENKI BUSINESS to do this.

Please note that under certain circumstances we may be required to disclose your personal data, partners with whom ENKI BUSINESS cooperates and / or other third-party service providers of ENKI BUSINESS.

 

DATA PROCESSING BY THIRD PARTY, OTHER SITES AND SPONSORS

The ENKI BUSINESS site may at any time contain access links to other sites whose data processing policies may be different from those of ENKI BUSINESS.

Please consider and consult the personal data protection policies of other sites, ENKI BUSINESS not accepting responsibility for the information sent or collected by these third parties.

 

AUTOMATIC DATA PROCESSING. COOKIE

The ENKI BUSINESS site uses cookie identifiers. In this regard, you can review our Cookie Policy, available on the site, and exercise your right to disable Cookies, as outlined below.

 

PERIOD OF DATA STORAGE

ENKI BUSINESS may keep the data processed for different periods of time deemed reasonable for the purposes indicated above. We only retain your data for the period necessary to achieve the purpose for which we hold the data, to meet your needs or to fulfill our statutory obligations.

To know how long your data can be stored, we use the following criteria:

  1. When you purchase products and services, we retain your personal data during our contractual relationship;
  2. If you participate in a promotional offer, we retain your personal data during the promotional offer;
  3. If you contact us for a question, we keep your personal data for as long as your questions are processed, but no more than 5 years after the last mail sent;
  4. If you create an account, we retain your personal data until you ask us to delete it or after a period of inactivity (without active interaction with our trademarks) defined in accordance with local regulations and guidelines. In this regard, please note that data processed for this purpose will be deleted 5 years after the last user account interaction (for example, login to your account);
  5. If you have given your consent to marketing, we retain your personal data until you unsubscribe or ask us to delete it or after a period of inactivity (without active interaction with our trade marks) defined in accordance with local regulations and guidelines. In this regard, we mention that the data stored in our databases for the purpose of direct marketing communications are deleted from the records of these databases at 5 years of the last interaction with you;
  6. If the cookies are stored on the computer, we keep them for as long as it is necessary for them to achieve their goals (for example, during a session for the cart cookies or cookies for ID’s of session) and for a defined period in accordance with local regulations and guidelines. In this regard, we mention that the data processed through the cookies used to provide online behavioral advertising, to personalize our services for you, and to allow our content to be distributed to social sites (distribution buttons to display the site) will be retained for a maximum period of 5 years from collection, based on your consent.

 

THE RIGHTS OF DATA SUBJECTS

According to GDPR, you have a number of rights regarding the personal data that ENKI BUSINESS processes:

  1. Right of access to processing data – You have the right to access our personal data. The first information will be provided without charge. If you will need copies of the information already provided, we may charge a reasonable fee, taking into account the administrative costs of providing information. The unreasonable, excessive or repeated requests may not be answered.
  2. Right to Data Rectification – You may request that your Data be rectified if inaccurate or obsolete and / or you should fill them in if it is incomplete. If you have an account, it can be easier to correct your own data through the “My Account” feature.
  3. Right to delete data (“the right to be forgotten”) – In some cases, you have the right to obtain the deletion or destruction of your Data. This is not an absolute right, because sometimes we may be forced to keep your Data for legal or legal reasons.
  4. Right to Restrict Processing – You have the right to request restriction of the processing of your Data. This means that your Data processing is limited so we can keep the Data, but not use or process it. This right applies in the specific circumstances set out in the General Data Protection Regulation, namely:
    • the accuracy of the Data is contested by the data subject (that is you) for a period that allows the operator (i.e. ENKI BUSINESS) to verify the accuracy of the Data;
    • processing is illegal and the data subject (i.e. you) opposes the deletion of the Data and requests the restriction of their use;
    • the operator (for example, ENKI BUSINESS) no longer needs Data for processing, but they are requested by the data subject (i.e. you) to establish, exercise or defend any legal claims;
    • the person concerned (i.e. you) objected to the legitimate processing of the operator (in this case ENKI BUSINESS) by verifying that the legitimate reasons of the operator (ENKI BUSINESS) exceed those of the data subject (i.e. you).

 

 

  1. Right to Data Portability – You may move, copy or transfer the data you are interested in from our database to another. This applies only to the data you have provided when processing is based on your consent or contract and is implemented by automatic means.
  2. Opposition Right – You may oppose at any time the processing of your data when such processing is based on a legitimate interest.
  3. 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 processing on the basis of consent prior to its withdrawal.
  4. Right to file a complaint with the competent supervisory authority – You have the right to complain to the data protection authority in your country of residence or domicile to challenge the data protection practices of ENKI BUSINESS.
  5. The right to oppose processing of your data for direct marketing purposes – You can unsubscribe or give up our direct marketing communication at any time. It’s easier to do this by clicking the “unsubscribe” link in any email or communication we send you.
  6. Right to oppose your processing of data by us when acting in the public interest or in our legitimate interests or by a third party – You may at any time oppose the processing of your data when such processing is based on a legitimate interest.
  7. Right to Disable Cookies – You have the right to disable cookies. Settings in Internet browsers are typically programmed by default to accept cookies, but you can easily adjust them by changing your browser settings. Many cookies are used to increase the usability or functionality of web sites / applications; therefore, disabling cookies may prevent you from using certain parts of our sites or apps, as detailed in the relevant Cookie table. If you want to restrict or block all cookies set up by our websites / apps (which may prevent you from using certain parts of the site) or any other sites / apps, you can do so through your browser settings. The Help feature 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 in respect of personal data that ENKI BUSINESS processes by addressing a simple request to the ENKI BUSINESS DPO. In such a situation, it is very possible to request proof of your identity.

 

LEGAL REQUESTS

We access, retain and provide your information to regulatory authorities, law enforcement or other entities:

  1. In response to a legal request, when we believe in good faith that the law requires us to do so. We may also respond to legal claims when we consider in good faith that the response required by the laws of that jurisdiction affects users in that jurisdiction and complies with internationally recognized standards.
  2. When we believe in good faith it is necessary to: detect, prevent and respond to acts of fraud, unauthorized use of any material belonging to us, violations of our terms or policies, or other harmful or unlawful activities, in order to protect ourselves (including our rights, property or materials), yourself and others, including during investigations or investigations of regulatory authorities, or to prevent imminent death or injury. For example, if relevant, we provide information to and receive third-party partner information about the reliability of your account to prevent fraud, abuse and other harmful activities inside and outside of our materials.

The information we receive about you may be accessed and stored for a longer period of time when they are subject to a legal request, or legal obligation, governmental inquiry or investigation regarding possible violations of our terms or policies, or in other cases to prevent damage.

 

RELATIONSHIP WITH OTHER OPERATORS

Depending on the context, we may find ourselves in the situation of the absolute need to provide information on a higher level, both globally and internally or externally, to our partners and to those with whom we transfer data in compliance with the above Regulation recalled, by virtue of providing the most professional services possible. The information controlled by ENKI BUSINESS could 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 to deliver the highest level of service and to continue to provide you with our best professional content. We use standard contractual clauses approved by the European Commission, and we rely on the appropriateness of the European Commission’s decisions on certain countries, as the case may be, for transfers of EEA data to the United States and to other countries.

 

SECURITY OF THE  PROCESSING

ENKI BUSINESS has adopted technical and organizational data processing measures updated in accordance with GDPR requirements to protect your personal data against any unauthorized access, improper use or disclosure, unauthorized modification, accidental destruction or loss. All employees and partners of ENKI BUSINESS, as well as any third parties acting in the name and on behalf of ENKI BUSINESS are bound to respect the confidentiality of your information and the GDPR requirements, in accordance with the provisions of this Policy.

 

EXEMPTION FROM LIABILITY

The ENKI BUSINESS web site may contain links to other sites and / or other web sites not owned by ENKI BUSINESS. ENKI BUSINESS 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. ENKI BUSINESS will not be responsible for the loss of personal data, any adverse effects on visitors’ personal data or other moral and / or patrimonial damage caused by access to those sites.

 

UPDATING OF THE PERSONAL DATA PROTECTION AND PROCESSING POLICY UPDATE

Please keep in mind that this Policy may be subject to regular content changes by updating the ENKI BUSINESS site.

How will we let you know about the changes made to this Policy?

We will send you a notification before making any changes to this Policy and will give you the opportunity to review the revised DPP before choosing to continue using our materials.

Please do not continue to use the ENKI BUSINESS website if you do not agree to such changes. We also recommend that you check this page for any updates.

DPP terms are interpreted in accordance with applicable law.

 

CONTACT

If you have any questions or concerns about the way we treat and use your personal data or want to exercise any of your rights, please contact us by accessing our DPO contact details.