SC ALPINTOUR CONSULTING SRL PERSONAL DATA PROCESSING POLICY, HEREBY NAMED ALPINE TOURS
YOUR PERSONAL DATA OPERATOR is SC ALPINTOUR CONSULTING SRL, Romanian legal entity, CUI 24788780, based in Vlădești, Vlădești commune no. 414, Vâlcea county, Romania.
PERSONAL DATA CATEGORIES PROCESSED
The personal data we collect / process may include:
Contact information such as your name, mailing address, including your home address, if you provided it, telephone number, mobile phone number, fax number and e-mail address, position held , within a company;
Additional information that must be processed for the purpose of concluding or exercising a contractual relationship or communicated voluntarily by you, such as instructions given, payments made, requests and projects;
Information collected from public sources or databases;
Other personal data necessary for the purpose of informing you if they prove relevant to the activity we carry out that falls within the legitimate interest of the operator;
In limited situations, in which to carry out our activity, we must collect special categories of personal data as they are to be found in art. 9 of the Regulation on the protection of individuals with regard to the processing of personal data and on the free movement of such data (“GDPR”), respectively the personal numerical code, your images, data on your membership of a professional or trade association or a union, personal health data, data on your political opinions and criminal record data, processing will be done only:
i. on the basis of your express prior consent or on the basis of fair evidence of your consent provided by a third party who communicates this information to us;
ii. based on a legal obligation to process these categories of data;
iii. on the basis of an obligation to defend a legitimate right;
IP addresses. Sites collect IP (Internet Protocol) addresses. An IP address is a number assigned to your computer by your ISP that allows you to access the Internet. An IP address can be a personal date. We use IP addresses to diagnose server problems, report information in aggregate form, determine the most efficient connection to our site, and to manage and improve the site.
HOW WE COLLECT YOUR PERSONAL DATA
We may collect personal data about you in certain circumstances, including:
- When you or your organization engages in a contractual relationships with us;
- When you voluntarily communicate to us or your organization, for any reason, your personal data;
- When browsing, requesting information or interacting, or your organization browsing, requesting information or interacting on our website www.alpine-tours.com, social media accounts (Facebook, Instagram, Youtube) or using Alpine Tours online applications ;
- During the events we organize by downloading and publishing images and videos on the web pages of Alpine Tours. The purpose of this processing is to promote the sports activities organized by Alpine Tours. The storage period of these images is 10 years. You can oppose this processing at any time, by means of the registration form you fill in or by sending a message to this effect to firstname.lastname@example.org This type of personal data is needed in order to be able to validate and ensure your registration for the chosen event. The basis of the processing is the contractual relationship between the parties as established by the Contest Rules / Rules of the chosen Activity. If you do not agree with the processing of your data, Alpine Tours will not be able to validate and secure your registration for the desired event. At the same time, in order to be able to issue the proof of payment related to the registration fee, we collect from you and your bank details, respectively: account number and bank name. By filling in and sending the registration form, you give us your consent for the processing of your image, in photo and video format. After the event we can publish such images on our website. At the same time, the photos and videos taken on the occasion of organizing the events will be published on our Facebook page, on the Instagram account, Youtube. The photos will be kept on the site and on the other accounts for a period of 10 years. To the extent that you do not agree that the pictures of you to be published on our website or on social networks or if the pictures currently appear on the site or on social networks and you do not agree to continue appearing, please let us know by request at email@example.com indicating the photos you want to delete and we will respond immediately to your request.
Through Cookies. Sites use “cookies”. A cookie is a small text file, stored on your computer, tablet, or phone when you open a website, that helps the site recognize you, including your preferences. Some cookies are deleted when you close your browser. These are called session cookies. Others remain on your device until they expire or you clear them from your cache. These are persistent cookies, which allow us to retain information about recurring visitors. The cookies we use allow us to recognize and count the present visitors, and to see where visitors are going to the site. Thus, we can improve the functioning of the sites, for example by organizing them so that users can easily find what they are looking for. Our cookies also allow us to personalize the content you view, based on your preferences.
Through Newsletters. Subscribing and unsubscribing to the Alpine Tours newsletter is free of charge and voluntary and is done exclusively based on your consent. The newsletter is a means of sending information, which takes place on a periodic basis, in an exclusively electronic form (by e-mail, SMS) about Alpine Tours promotional events, etc., without any commitment on the part of Alpine Tours with reference to the information contained therein. In order to provide marketing services, we collect from you the e-mail address, telephone number, name, surname. This data will be used exclusively to keep you informed about our events. The basis for the processing of personal data is your consent, the duration of processing being the entire duration of the consent.
Google Analytics. We use Google Analytics, a web analytics service provided by Google, Inc. (“Google”) http://www.google.com/analytics/ to analyze the use of pages, the interaction with the pages and the navigation options of the visitors on the site and we anonymize the analyzed characteristics.
LEGAL GROUNDS ON THE BASIS OF WHICH PERSONAL DATA PROCESSING
Any operation equivalent to the processing (collection, storage, registration, structuring, adaptation or modification, extraction, consultation, use, disclosure by transmission, destruction) of your personal data will be carried out on one of the following legal grounds. :
- Processing is required to perform a contract to which you are a party or your organization is a party, or such processing is required to enter into a contract with you or your organization;
- Processing is necessary in order to comply with a legal obligation;
- The processing is carried out with your prior and explicit consent;
- Processing is necessary in order to protect the vital interests of you or another natural or legal person;
- Processing is necessary for the purpose of our legitimate interests or those of a third party, unless your interests or fundamental rights and freedoms prevail over those interests.
- In situations where the applicable legal provisions require your prior and explicit consent for the processing of certain categories of data, we will process such data only on the basis of your prior and explicit consent. At the same time, we will make sure that any natural person or entity that communicates your special personal data to us has obtained your prior consent.
You can choose to withdraw your consent to the marketing materials at any time by simply accessing the ‘unsubscribe’ link at the bottom of each newsletter or event invitation, ours or our partners’.
In order to withdraw your consent for any processing on which you have previously consented, please send us an e-mail to firstname.lastname@example.org, contact us at + 40 746 327 791. In all cases, your consent may be withdrawn in the same manner as it was granted.
COLLECTION OF PERSONAL DATA OF MINORS
Alpine Tours does not allow the processing of personal data of customers under the age of 18. With regard to the provision of company services directly to a child, the processing of a child’s personal data is legal if the child is at least 16 years old. Alpine Tours makes every reasonable effort to verify in such cases that the parental responsibility has given or authorized consent, taking into account available technologies. Thus, the processing of personal data of minors by Alpine Tours will be done only with the explicit consent of parents or other legal representatives.
PURPOSES FOR WHICH YOUR PERSONAL DATA WILL BE PROCESSED
We may use your personal data only for the following purposes (“Allowed Purposes”):
- Compliance with our legal obligations (such as record keeping obligations), compliance verification or registration obligations which may include automatic verification of your contact details or other information you provide to us regarding your identity with applicable lists of the sanctioned persons and contacting you to confirm your identity in the event of a possible positive outcome, or recording the interaction with you that may be relevant for compliance purposes;
- Purposes such as advertising, marketing and publicity, statistics, exclusively in the interest of the operator or his proxies, the organization of courses, seminars, other events (including delegations, conferences and fairs), for educational purposes for the organization of training programs, for the issue of any financial documents, accounting, concluding contracts or other documents required in the activity of Alpine Tours;
- Analyzing and improving our services and communications to you, with reference to the services provided so far;
- Protecting security and managing access to our headquarters, IT and communication systems, online platforms, websites and other systems, preventing and detecting security threats, fraud or other criminal or malicious activities;
- For insurance purposes;
- For the purpose of monitoring and evaluating compliance with our policies and standards;
- For any purpose related to and / or ancillary to any of the above or any other purpose for which your personal data has been provided to us.
If you have given us your consent, we may also process your personal data for the following purposes:
- Communicating with you through the channels you have approved to keep you informed regarding events / information regarding Alpine Tours services, products as well as events and projects;
- Surveys among customers / partners / collaborators, marketing campaigns, market analysis,
- Raffles, contests or other activities or promotional events, for us or our partners, on our communication channels.
- With regard to communications related to marketing / information about events, we will make available to you – if legally required – that information only after you have selected to participate in our events and we will give you the opportunity to no longer participate at any time, in cases where you do not wish to receive marketing / information communications about events from us.
We will not use your personal data in making automated decisions that affect you or create profiles other than those described above.
TRANSMISSION OF YOUR PERSONAL DATA
- We may share your personal data obtained from you in the following circumstances:
- We may provide you with confidential contact information to third parties for the purpose of obtaining feedback from you on the provision of services by the company, to help us measure our performance and improve and promote our services;
- We may share your personal data with any third party to whom we assign or renew any rights or obligations;
- We may also use agreed personal data and statistics in order to monitor the use of the website to assist us in developing our website and services.
PERSONAL DATA THAT YOU PROVIDE US ABOUT OTHER INDIVIDUALS
If you provide us with personal data about another person (such as one of your administrators or employees, or a person with whom you have a professional relationship), you must ensure that you have the right to disclose this data to us and that, without further action, we may collect, use and disclose such personal data as described in this Personal Data Processing Policy.
In particular, you must ensure that the individual concerned is aware of the various aspects dealt with in this Personal Data Processing Policy, as they relate to that individual, including our identity, how he or she can contact us, the purposes for which we collect, our personal data disclosure practices, the right of the individual to gain access to personal data and to file complaints about the management of personal data, and the consequences of not providing personal data (such as our inability to provide services).
SECURITY OF YOUR PERSONAL DATA
Your personal data may be stored on our personal data technology systems, those of our contractors or in hard copy.
UPDATING YOUR PERSONAL DATA
If any of the personal data you have provided to us changes, for example if you change your first name, last name or e-mail address or if you wish to cancel any request to us, or if you become aware of the fact that we have any incorrect personal data about you, please let us know by sending an e-mail to email@example.com. We will not be liable for any loss arising from incorrect, inauthentic, insufficient or incomplete Personal Data you provide to us.
At the same time, we will take fair steps to periodically update our records regarding your personal data, but we will not be liable for any unforeseen changes to your personal data.
STORAGE PERIOD OF YOUR PERSONAL DATA
Your personal data will be deleted or deleted when it is no longer reasonably necessary in the Permitted Purposes or when you withdraw your consent (if it has been granted) and there is no legal obligation to continue the storage of personal data.
Unless you expressly request us to store your personal data for a longer period of time, personal data will be deleted within a maximum of 5 years from the date on which it was collected.
YOUR RIGHTS IN CONNECTION WITH THE PROCESSING OF PERSONAL DATA
Subject to applicable legal provisions and subject to certain legal conditions, you have the following rights in connection with the processing of your personal data:
- The right of access, which includes the right to know if we process data about you and the right to find out who they are, to whom they are transferred, how long they will be kept, where we obtained them and whether they are used for automated profiling / decisions.
- The right to rectification. If the data we have is incorrect, we need to correct it (unless we process it for someone else. In this case, we’ll let you know who to send your request to.).
- The right to delete / unsubscribe on request; we will delete your personal data as soon as possible, if 1) they are no longer necessary for the purpose for which they were obtained or 2) if you withdraw your consent for the processing of this data / if you have objections to the processing (more unless we need them for litigation, performance of a contract or legal obligations). Also, if we find that we have a legal obligation to delete or if the processing is illegal, we will delete them. If the data is also processed by third parties, we will take reasonable steps to inform them of the deletion request.
- The right to restrict processing, if they are illegal, allegedly incorrect, contested, or no longer necessary.
- The right to information. We inform you as clearly as possible about your rights in the field of personal data, and about what data we process about you or (if applicable) we share with third parties.
- The right to porting. If we process your personal data automatically, based on consent or contract, you can ask us to give it to you in a format and we will respond to your request within a reasonable time.
- The right to object. You can tell us if you want us to stop processing your personal data. We will grant your request if we cannot demonstrate sufficient legitimate interests. In any case, the data processed for direct marketing will be deleted on request.
- The right not to be subject to a decision based solely on automatic processing, including the creation of profiles, unless you have given explicit consent or are required to perform a contract.
- The right to submit a complaint to a supervisory authority, in Romania – ANSPDCP (National Authority for the Supervision of Personal Data Processing), web: www.dataprotection.ro, e-mail: firstname.lastname@example.org.
You also have the following rights:
- the right to request a copy of the personal data about you that we hold; if you exercise this right in a manner that is manifestly abusive or unfounded, we reserve the right to reimburse the necessary costs incurred for the processing of those copies and for the remission of the copies within a reasonable period of time;
- the right to rectify any incorrect personal data and the right to oppose or restrict our use of your personal data;
- you can also make a complaint if you are concerned about how we handle your personal data;
- the right to delete your personal data, in situations where you have withdrawn your consent, the processing is no longer necessary or the processing is contrary to law.
These rights can also be applied by sending an e-mail to email@example.com. Depending on your request, we reserve the right to request additional authentication, representing an identity document.
We will consider any requests or complaints we receive and send you a response as soon as possible.
If you are not sure how your request was resolved, you can submit the complaint to the National Authority for the Supervision of Personal Data Processing – based in Bd. Gheorghe Magheru no. 28-30, Bucharest, Romania.
UPDATES TO THIS PERSONAL DATA PROCESSING POLICY
The most recent update of this Personal Data Processing Policy was made in December 2019. We reserve the right to periodically update and amend this Personal Data Processing Policy to reflect any changes in the way we process your data or any changes to legal requirements. In the event of any such changes, we will display the modified version of the Personal Data Policy on our website.
AUTOMATIC COLLECTION OF NON-PERSONAL DATA
In some cases, Alpine Tours may collect non-personal information. Examples of information of this type are: the type of browser used, the operating system of the computer used and the domain name of the website where the connection to the WEB sites of the association was made. While browsing the site, Alpine Tours may store certain information of the User. This information will be in the form of a “Cookie” file or a similar file. These “Cookies” files help our association to respond as well as possible to the interests and preferences of Users. With most Internet browsers you can delete or block the “Cookies” files or you can receive a warning before receiving such a file. Alpine Tours recommends that Users consult the instructions of the browser used to identify how cookies can be used.
If you wish to contact us with any questions, comments or requests regarding the Personal Data Processing Policy, please send us an e-mail at firstname.lastname@example.org or contact us at: + 40 746 327 791.