Privacy Policy
1. The purpose and scope of this notice
Eturia respects your privacy and is committed to protecting your personal data. This notification regarding the processing of personal data (further referred to as "Notice") is intended to provide you with relevant information regarding how we process your personal data when you visit our website or when you provide us, through any other way your personal data (such as: phone, email, CV), when you purchase tourist services, when you sign up for our newsletter, when you participate in a trip or when you request an offer from us, etc.
This site is intended only for adults and the only situations in which we collect data related to children are those in which you reserve tourist offers for your children.
This notice informs you about the personal data processing operations (as they are defined by the relevant legislation in the matter, including the General Data Protection Regulation 2016/679 - further referred to as "GDPR") carried out by Eturia, in considering its quality as a personal data operator.
The operator of your personal data is ETURIA S.R.L. and is responsible for your personal data (further referred to as "Eturia", "we" or "our" in this notice).
2. The operator of your personal data and the contact details of the data protection officer
The operator of your personal data is ETURIA S.R.L., with its registered office in the City of Piatra Neamt, street. December 1st 1918, no. 58, Neamt county, trade register order number J27/908/2007, unique registration code RO 22067680 (hereinafter referred to as "Eturia", "we" or "our" in this notice).
Taking in consideration the applicable legal providiors, Eturia has appointed a data protection officer.
If you have any questions regarding this notice, including any request regarding the processing of your personal data or the exercise of your legal rights, please contact the data protection officer using the following contact details:
(1) Email: dpo@eturia.ro
(2) Correspondence address: City Piatra Neamt, street. December 1st 1918, no. 58, Neamt county, Romania;
It is important that the personal data we hold is correct and up-to-date. Please let us know if any of the details you provide should change during your relationship with us.
3. External links
This site may include links to third-party websites or applications. If you click on those links or if you activate these applications, it is possible that thedr third parties will be allow the collection or sharing of data about you. We do not control these third-party websites and we are not responsible for their policies regarding the processing of personal data. When you leave our site, please read the policies of each site you visit.
4. The personal data we collect about you
According to the legislation in force, "personal data" means any information regarding an identified or identifiable person; an identifiable person is a person who can be identified, directly or indirectly, in particular by reference to an identification element, such as a name, an identification number, location data, an online identifier, or to one or more many specific elements, specific to his physical, physiological, genetic, psychological, economic, cultural or social identity.
When you access our website or communicate with us or we provide tourist services or any other type of services for you, we may process the following categories of personal data:
Contact and/or identification data, including: first and last name, address (domicile or residence), telephone number, e-mail, series and number of the identification document (bulletin/identity card/passport), personal numerical code as well as the information contained in these documents, voice, conversation history;
Data related to the services requested, including: information regarding the services requested or provided, details regarding payments to and from you, including the bank account, contact and identification data for the people who participate in the trips with you, the history of conversations within the group of on WhatsApp;
Data related to candidates (in the case of recruitment processes), including: candidate details, e-mail address, address, current employer, employment history, education, licenses/certifications, information related to studies as well as other information included in the curriculum vitae;
Data used for advertising, marketing and advertising purposes, including: name, first name, image, voice, feedback sent, ID (username/name used on the social network) and images on social networks (in the case of the ID and images published on the account of the social networks, Eturia will mention the presence of the respective person in the pictures and video clips published on the social network accounts or on the websites belonging to Eturia).
Special categories of personal data such as: dietary requirements that may reveal your religious or philosophical beliefs and health data.
We collect and process the above data only if it is strictly necessary to provide the tourist services you have purchased. In addition, we will collect and process the special categories of special personal data mentioned above, only if you have provided us with your explicit consent in this regard.
You do not have any obligation to give your consent to process your special categories of personal data, except when they are necessary for the provision of the requested services. However, without your consent, we will not be able to take the necessary steps to provide the tourist services you have booked or are trying to book.
Only if this information is necessary for the provision of tourist services, if you do not provide us with the respective data and we do not have your consent, we will not be able to provide the requested tourist services.
5. The source of personal data
Personal data can be obtained from the following sources:
directly from you when: you request a travel offer or benefit from the tourist services we offer, when you subscribe to the newsletter or other publications, send feedback, participate in organized contests,
through the activities you carry out during the period when you benefit from the tourist services offered, such as photos, the history of conversations in groups on WhatApp;
from third parties, such as when we receive your personal data from third parties requesting the provision of tourist services (people traveling with you or other travel agencies)
6. Purpose of personal data processing
Eturia collects, processes and uses personal data:
for purposes that allow the provision of an offer or the provision of tourist services;
for purposes that allow Eturia to fulfill its goals related to its activity and its legal obligations;
to enable the initiation or development of a contractual relationship with you.
for marketing and advertising purposes;
for purposes that allow you to participate in contests and events organized by Eturia;
for exercising the rights and obligations of the parties resulting from the contracts signed by the parties or in connection with the services provided;
in order to protect the interests of the parties in promoting legal actions and defending against any claims and lawsuits;
in order to ensure compliance with the legal provisions regarding the storage and archiving of data/documents;
for the exercise of Eturia's rights in accordance with legal provisions and compliance with legal obligations;
for purposes subordinated to the general purpose of providing tourist services.
Avoidance of any doubt, Eturia will not use your personal data for advertising, marketing and publicity purposes except to the extent that you expressly consent to do so.
At the same time, Eturia mentions that there is no automated decision-making process (including the creation of profiles) based on your personal data.
7. Disclosure of personal data
Your personal data will be disclosed within Eturia only to management and other people who need access to your personal data ("need to know basis") to fulfill their specific duties for the purposes listed in point 6 above or if this is necessary or permitted by the applicable legislation.
Eturia may also provide your personal data to third parties that provide services related to the requested tourist services, IT support services or technical and organizational services (in relation to activities related to Eturia's activity) or to legal consultants, audit or to other consultants or suppliers of Eturia, only for the purposes mentioned in this Notice. Eturia will exercise due diligence in selecting third-party service providers and will request that these providers maintain appropriate technical and organizational security measures to protect your personal data and to process them in accordance with the applicable legal provisions.
Eturia may also disclose your personal data to authorities, as required or permitted by law, insurance entities, external consultants and/or courts. Your personal data will be disclosed to such third parties only to the extent that it is necessary in connection with the execution of contracts, with Eturia's activities and/or with the purposes listed in point 6 above.
8. Transfer of personal data outside the EU or EEA
Many of the external providers of tourist services are located outside the European Union (EU) or the European Economic Area (EEA), so the processing of your personal data will involve a transfer of data outside the EU or the EEA.
If you have made a reservation for tourist services that are located or are to be performed outside the EU or the EEA, we are obliged and are authorized to transfer your personal data to the service provider you have purchased, outside EU or EEA, to fulfill the contract we have with you.
If personal data are processed for marketing or advertising purposes and are posted on social networks or are transmitted via WhatApp, the transfer of personal data will take place on the servers of social networks that can be located including outside the territory the European Union, including the United States of America.
Please contact us if you would like additional information regarding the specific mechanism we use when we transfer your personal data outside the EU or EEA."
9. The legal basis for the processing of personal data
The legal bases of the personal data processing operations described in this notice are: (i) the execution of a contract to which you are a party or to take steps before concluding a contract, (ii) our legitimate interests and/or the need to conclude or execute a contract, in accordance with the legal provisions regarding data confidentiality and (iii) your consent.
Our legitimate interests or those of a third party include our requirements to use your personal data in litigation, investigations by the authorities, data processing for advertising, marketing or publicity purposes or for other legal purposes involving Eturia.
10. Data security
Eturia maintains physical, technical and organizational security measures to protect personal data against destruction, loss, modification, disclosure, restriction or accidental, illegal or unauthorized access, regardless of where it is processed.
Our security policy regulates the way we protect your personal data; a copy of this security policy can be obtained from the data protection officer.
11. Length of time for processing/storage of personal data
We intend to keep your personal data accurate and up-to-date. We also strive to keep your personal data for no longer than is necessary to fulfill the purposes listed in this Notice or as required by law.
In this sense, we inform you that Eturia keeps your personal data for the entire duration of your contract concluded with Eturia as well as a period stipulated by the legislation in force after the date of termination of the relationship between you and Eturia.
In addition, please note that certain personal data may be included in certain accounting documents of Eturia, therefore an extended retention period must be observed, in accordance with the applicable law.
If you are a candidate for a position offered by Eturia (without having formalized any relationship with Eturia), your personal data made available to Eturia will be kept for a period of 1 year.
As regards the personal data obtained by means of video surveillance, they will be kept for a maximum of 30 calendar days from the date of registration, with the exception of situations where there are good reasons to be stored for a longer period.
In certain circumstances, we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information for an unlimited period without notifying you in advance.
12. Processing of personal data for advertising and marketing purposes"
Capturing the images (photograph, video) or using the images (photo, video) is allowed only with your prior consent and, in the case of minors, only with the prior consent of their parents. It should be mentioned that the right to the image is not an absolute right, and the photographing and use of a person's image are allowed even without prior consent when they are done in good faith in the exercise of other fundamental rights such as, for example, the right to free expression or our legitimate interest to ensure the safety and security of people and goods.
In the case of granting consent, Eturia will restrict the use of the image only on its website(s) and only on the main social media, such as: Facebook, Twitter, Instagram, WhatsApp or on the Internet pages associated with Eturia or within the display for the purpose of marketing and advertising within the premises, events or presentations.
There are situations, trips, group events where such collection of images or video is possible, to be announced in advance and if the collection and processing is not desired, the organizer of the event or the personal data protection officer can be notified.
If you no longer want us to process your personal data for advertising, marketing or advertising purposes, you can unsubscribe from receiving newsletters by accessing the link at the end of the newsletter or you can request this contact the data protection officer or leave the WhatApp group you belong to.
13. Your rights regarding personal data
In accordance with the applicable provisions regarding personal data, we inform you that you have the following rights, which can be exercised by making a request in this regard using the contact data indicated in Section 2 above:
The right of access to processed personal data, meaning your right to obtain from Eturia a confirmation that personal data concerning you is being processed or not and, if so, access to the respective data and the conditions under which they are processed (including the purpose of the processing, the categories of data processed, the recipients of the data);
The right to request the rectification or deletion of personal data, meaning your right to request the rectification of inaccurate personal data or the completion of incomplete data.
Also, the right to delete your personal data can be exercised in certain circumstances provided by the applicable law, including: the situation in which the personal data is no longer necessary in relation to the purposes of the processing, the situation in which the data subject objects to processing and there are no other legitimate interests that prevail for the processing, the situation in which the personal data were processed illegally.
The right to request the restriction of processing, meaning your right to obtain from Eturia the restriction of processing in the following cases: (i) you dispute the accuracy of the data (the restriction will last as long as it is necessary for Eturia to verify the accuracy of the personal data); (ii) the processing is illegal and you object to the deletion of the data, requesting instead the restriction of their use; (iii) Eturia no longer needs the personal data for the purposes mentioned above, but you request the personal data for establishing, exercising or defending a right in court; or (iv) you objected to the processing, for the period of time in which Eturia checks whether the legitimate rights of Eturia prevail over your rights;
The right to object to processing, meaning your right to object to processing for reasons related to your particular situation, when processing (i) is based on the legitimate interests of Eturia or a third party, or (ii) insofar as it is applicable, it is carried out for the purpose of direct marketing communications, involving the creation of profiles;
The right not to be subject to an automated decision, including profiling;
The right to data portability, meaning your right to request the moving, copying or transfer of your existing data in Eturia's database to another database, in a structured, commonly used and automatically readable format , if the processing is based on a contract and is carried out by automatic means; The right to file a complaint with the National Supervisory Authority for the Processing of Personal Data and to address it to the competent courts.
14. Changes to this notice
If we change our personal data practices or this notice, we will issue a revised notice and/or take other steps to notify you of the changes, in accordance with applicable law.