PRIVACY POLICY AND PROTECTION OF PERSONAL DATA

In order to carry out its activities, Kultours SRL, as a data controller, processes personal data of certain categories of individuals. These may include personal data of users of this website, users who interact with pages created by Kultours SRL on social networks, our clients, our partners/potential contractual partners or their employees, representatives, or collaborators whose data is provided to us for processing, Kultours SRL employees, or candidates seeking positions within Kultours SRL.

According to Regulation No. 679 of April 27, 2016, on the protection of natural persons with regard to the processing of personal data and the free movement of such data, and repealing Directive 95/46/EC (“GDPR”), personal data means any information relating to an identified or identifiable natural person (“data subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier.

1. PURPOSES, LEGAL BASES, AND CATEGORIES OF PERSONAL DATA

The data processed by Kultours SRL may be used for purposes such as:

1.1 Administration and maintenance of this website, which includes the use of cookies to ensure quick and easy interactions between users and the site (legal basis: Article 6(1)(a) and (f) of the GDPR, respectively your consent and the legitimate interest of Kultours SRL, as the case may be). For more details on the use of cookies by Kultours SRL, please consult our Cookie Policy.

1.2 Registration and execution of your booking request and the provision of tourism and public catering services (legal basis: Article 6(1)(b) and (c) of the GDPR, respectively the execution of a contract or the undertaking of necessary steps at the request of the data subject before concluding a contract or fulfilling certain legal obligations of Kultours SRL, as the case may be). When you choose to book through the website, Kultours SRL processes the following categories of data: name, surname, gender, email address, phone number, country of residence, arrival date, departure date, bank account information, information about minor companions (age range), and optionally, the name, surname, and age of the adult companion. In the context of managing your booking, Kultours SRL may also process the following categories of data: data regarding your companion(s) to determine the room occupancy, details regarding your correspondence, requests, complaints, any other data or information related to your interaction with us. For the completion of the Arrival and Departure Announcement Form (in accordance with Decision 237/2001 for the approval of norms regarding access, registration, and protection of tourists in accommodation structures), Kultours SRL will process the following categories of data: name and surname, date of birth, place of birth, nationality, domicile (locality, street, number, country), date of arrival, date of departure, purpose of the trip, series and number of the identity document, signature, and optionally, email address.

1.3 Renting spaces, organizing private or corporate events (legal basis: Article 6(1)(b) of the GDPR, respectively the execution of a contract or the undertaking of necessary steps at the request of the data subject before concluding the contract).

1.4 Carrying out recruitment operations for purposes such as: evaluating the application, skills, qualifications, and interests in the available position for which you have applied and been contacted, organizing and conducting interviews, and selecting and recruiting you, facilitating access to occupational health services, and conducting general checks (legal basis: Article 6(1)(b) and (f) of the GDPR, respectively undertaking pre-contractual steps, concluding and executing the employment contract with you, or fulfilling our legitimate interests, as the case may be). In the context of your application, it is necessary to process the data included in the application you submit to us. These data will typically include your name, surname, contact details (phone number, email address), professional experience, education, and any other information you choose to include in the CV you send to us or in other documents we may request from you. Additionally, during the interview, we will process personal data such as your professional preferences, details regarding your experience and education not included in the submitted CV, and your salary expectations. As part of the hiring process, we may request additional documents (such as transcripts, diplomas, licenses, authorizations, professional qualifications, etc.), which will also contain personal data. For the purpose of evaluating your application, in addition to the information already provided, we may access your publicly available social media profiles (such as LinkedIn). Since your private life is not our concern, we will not consult or consider profiles or information from profiles that are clearly intended to remain private and do not have a professional component.

1.5 Conducting employment relations, executing employment contracts, fulfilling legal obligations, and/or fulfilling a legitimate interest (legal basis: Article 6(1)(b), (c), and (f) of the GDPR, as the case may be). In certain particular situations, Kultours SRL processes employees’ data based on their consent (legal basis: Article 6(1)(a) of the GDPR). The manner in which Kultours SRL processes its employees’ personal data is detailed in the information notice provided to them.

1.6 Organizing and conducting advertising campaigns by Kultours SRL and marketing and promotion activities (such as sending newsletters, promotional materials, commercial offers, marketing communications), requesting your opinion on the services we have provided (through customer satisfaction surveys), as well as conducting market, product, and service analysis studies (legal basis: Article 6(1)(a) and (f) of the GDPR, respectively your consent and the legitimate interests of Kultours SRL, as the case may be, including under Law No. 506/2004 regarding the processing of personal data and the protection of privacy in the electronic communications sector). Through direct marketing activities, we can keep you updated on our services and campaigns, in accordance with the applicable legal provisions. You can unsubscribe from the newsletter service at any time and free of charge by selecting the “Unsubscribe” option in the newsletter.

1.7 Ensuring the security of goods, persons, and spaces through video surveillance (legal basis: Article 6(1)(c) and (f) of the GDPR, respectively fulfilling a legal obligation and the legitimate interest of Kultours SRL). For this purpose, Kultours SRL processes your personal data, including your image captured through video surveillance, your name and surname, and the registration number of the vehicle, if applicable.

1.8 Communication with our collaborators and contractual partners (legal basis: Article 6(1)(b) and (f) of the GDPR, respectively concluding and executing the contract or the legitimate interest of Kultours SRL, as the case may be). For this purpose, Kultours SRL processes your name, surname, position and/or role, and the organization you represent, your handwritten or electronic signature, and the data in your identity document. If any contractual partner of Kultours SRL discloses the personal data of designated contact persons, legal or conventional representatives, collaborators, employees, and/or other individuals to Kultours SRL for or in connection with the conclusion and/or execution of a contract, considering that Kultours SRL does not have a practical way to directly inform these categories of persons, the contractual partner of Kultours SRL has the obligation to inform these persons about the processing of personal data by Kultours SRL. The contractual partner of Kultours SRL will take measures to ensure that this disclosure is made in accordance with any applicable requirements, including those regarding informing and obtaining the consent of the data subjects, if necessary, so that Kultours SRL can process the personal data for the purposes provided in the contract, without having to complete any formalities.

1.9 Handling your requests, questions, or complaints (legal basis: Article 6(1)(b) and (f) of the GDPR, respectively the execution of a contract or undertaking necessary steps at the request of the data subject before concluding the contract and the legitimate interest of Kultours SRL, as the case may be). For this purpose, Kultours SRL processes your name, surname, contact details, and the opinions you provide.

2. HOW DO WE OBTAIN DATA?

Kultours SRL may obtain data:

  • Directly from you, for example, when you use Kultours SRL services, when you contact us through various channels or request offers or information about Kultours SRL services, when you visit our website or social media pages, or when you apply for available positions within Kultours SRL;
  • From other sources, for example, from travel agencies, booking sites (e.g., Booking.com), from public authorities (for example, in case of court requests or judicial investigations).

3. RECIPIENTS OF YOUR PERSONAL DATA. DATA TRANSFER

Personal data may be disclosed by Kultours SRL to the following categories of recipients:

  • To you, when you exercise your rights under the GDPR;
  • To Kultours SRL’s contractual partners (such as courier companies, suppliers, collaborators, subcontractors, consultants, and technical experts, etc.) for the conclusion and execution of contracts;
  • To public authorities and institutions, based on our legal obligations in accordance with applicable laws; To Kultours SRL’s external auditors for fulfilling audit obligations;
  • To lawyers, tax/business consultants, to represent us in the event of a dispute or for consultancy;
  • To bailiffs, for contractual communications or for the execution of contracts or any court orders;
  • To debt collection companies;
  • In the event that Kultours SRL undergoes a sale or reorganization process, we will provide your data to the acquiring entity and/or its consultants or to the entity resulting from the reorganization process. To achieve some of the above-mentioned purposes, certain categories of personal data may be transferred outside Romania. Data may be transferred to states within the European Economic Area (EEA) as well as outside the EEA. For transfers outside the EEA, the company will base its transfer in accordance with GDPR requirements and on standard data protection clauses adopted by the European Commission, to ensure the necessary level of security and confidentiality or other guarantees recognized by law.

4. DURATION OF PERSONAL DATA PROCESSING

Kultours SRL processes your personal data for the entire duration necessary to fulfill the processing purposes for which they were collected, as well as afterward, if necessary, to comply with legal requirements applicable to our field of activity. In the case of CVs you send us, they will be kept for a period of 2 years after the recruitment process is completed, only if you have given your consent to this effect. It is possible that, after the expiration of the legal archiving terms, Kultours SRL may anonymize the data, thus depriving it of its personal character.

5. YOUR RIGHTS

In the context of processing personal data, you have the following rights: the right to be informed, the right to access data, the right to rectification of data, the right to deletion of data, the right to restriction of data, the right to data portability, the right to object, the right not to be subject to an individual decision, the right to address the National Supervisory Authority for Personal Data Processing (according to the information available on www.dataprotection.ro) or the competent courts. To exercise these rights, you can send a request addressed to Kultours SRL to the attention of the Data Protection Officer at the email address: office@casaluxemburg.ro or by mail/courier to the address of Kultours SRL mentioned above. This Policy is updated periodically; whenever we make a change, we will display it on our website www.casaluxemburg.ro.