Privacy Policy regarding the processing of personal data
We take the privacy of our customers seriously and will process your personal data as described below.
In accordance with Regulation (EU) 2016/679 of the European Parliament and Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (General Data Protection Regulation, hereinafter referred to as “GDPR”) and with national data protection law, we provide you with information on the processing of your personal data when using the services of www.bucovina-outdooradventure.com (hereinafter ” Bucovina OutdoorAdventure Services”).
Data protection is very important to us and we will protect the data you provide us. Our intention is to offer you, the website user, a safe online experience that will not negatively affect your personal life. In this regard, we make every effort to ensure that the information you enter into our database is used exclusively for your intended purposes.
The operator of personal data is the company SC CUMIRAD INVEST S.R.L., a Romanian legal entity, with its registered office in Magura city, no. 1343, Suceava county, registered at the National Trade Register Office under no. J33/1561/2017, having CIF RO 3817857.
The Associated Operators of CUMIRAD INVEST are entities representing venues, operators, the event listing platform and ticket sales www.booktes.com, who will have access to the data related to you after you buy a product/ticket/season pass/coupon/package (hereinafter ticket) or after registration for the event/activity they organize, listed on our website. Through the ticketing platform www.booktes.com whose ticketing engine has been integrated into our platform www.bucovina-outdooradventure.com to facilitate the choice and purchase of a package of services / services / product / ticket / subscription will makes all purchases of service packages / services / products / tickets / subscriptions. They, including the www.booktes.com ticketing platform, adhere to the CUMIRAD INVEST terms and conditions and process the data collected through the platform independently, in order to fulfill the order you place or to fulfill their own legal obligations, as operators, such as be accounting obligations.
To this regard, CUMIRAD INVEST has established a report of associated operators, by mutual agreement, with these entities, available in the Terms and Conditions of services. Thus, CUMIRAD INVEST allows entities to publish their own information note on data processing for the events/activities they publish, and your rights can be exercised both against CUMIRAD INVEST, using the contact details mentioned below, and against the entities representing venues, operators, ticketing platform www.booktes.com.
Contact details of the SC CUMIRAD INVEST S.R.L company, in order to exercise the rights provided by the GDPR, are the following: contact@booktes.com or the telephone number: (+40) 759 144 144.
The purposes for which your personal data are processed:
CUMIRAD INVEST uses the information collected, personal data provided by you at registration and the activity carried out on www.bucovina-outdooradventure.com in order to: provide CUMIRAD INVEST services, register and create your account on the platform www.bucovina-outdooradventure.com, provide customer service, communicate with you, place e-ticket orders, services / service packages, provide advertising and marketing activities, provide user reviews, provide proper functioning of legal actions, collect and improve our services through feedback, as follows:
For the account creation on bucovina-outdooradventure.com and for the provision of CUMIRAD INVEST Services, based on your unequivocal consent by creating the account, pursuant to art. 6 paragraph. (1) letter (a) of the GDPR.
Thus, CUMIRAD INVEST does not condition the use of account creation services, but always gives you the opportunity to register on the website and create a user account, to set your preferences and independently control your personal data. You can opt-out of your account at any time.
The data provided by you when creating the account will be used to manage this account, through which you can use our services, review the services purchased, manage events or activities, manage participation in events or activities and benefits access to all CUMIRAD INVEST news and offers. To have an account on an online platform, you must be at least 16 years old. CUMIRAD INVEST also gives you the option to order tickets as a guest, without creating an account. As an account holder, you will be able to withdraw your consent at any time for the processing of personal data for this purpose, by simply deleting the account.
Placing an order of electronic tickets, service packages, according to the terms and conditions of use of CUMIRAD INVEST services, pursuant to art. 6 paragraph (1) letter b of the GDPR.
CUMIRAD INVEST will collect data when you place an order for service packages / services / electronic tickets. The data will be collected as the case may be depending on the activity for which you will purchase service packages / services / electronic tickets. In addition to the standard account data, additional data related to several security or survey aspects will be collected. These data are necessary to secure the order and ensure participation in the activities in which you will purchase service packages / services / electronic tickets. These details are required depending on the specifics of the activities you sign up for and may include: professional details (such as work, role in the company), contact details of a third party (name, phone number and email), for potential cases emergency, residence, place of birth, preferences, delivery address. Also, there may be activities for which CUMIRAD INVEST requests the declaration of health status or clarifications related to medical conditions, but these data will always be processed only based on your explicit consent, in accordance with art. 9, paragraph (2), letter b of the GDPR.
Processing the payments you make for the purchase of service packages / services / electronic tickets, pursuant to art. 6 paragraph (1) letter b of the GDPR, as well as for the fulfillment of the legal obligations, as a result of these payments of CUMIRAD INVEST pursuant to art. 6 paragraph (1) letter c of the GDPR.
For example, when you choose to pay by credit or debit card, by clicking on the Credit / Debit Card button next to the Mastercard and Visa logos, you will take part in the following actions:
In this case, PayU will be responsible for processing the data collected on the PayU website / interface.
Communication between you and us, as a result of purchasing service packages / services / electronic tickets pursuant to art. 6 para. (1) lit. b of the GDPR and subsequently, until the development of the activity, based on legitimate interests, pursuant to art. 6 paragraph (1)letter f of the GDPR.
We will have access to the data related to you after purchasing a service package / service / electronic tickets or after registering for the activity we organize, listed on our website. The information provided to us is also necessary to allow you access to the locations where our activities are held, to resolve any issues related to your participation / reservation or based on the legitimate interest to stay in touch with you until the beginning of the activity and during the activity. We will use your personal data only for the purpose legally defined, namely making a reservation and / or purchasing service / service packages and tickets on paper or digital.
Communication with customers, based on the legitimate interests pursued by the operator, pursuant to art. 6 paragraph (1) letter (f) of the GDPR.
We will use the data to stay in touch and to keep you up to date with all aspects related to the event/activity you published and to keep you informed about the purchases made on our website.
We have a variety of reasons why we may contact you:
The customer relations service, based on the legal obligation to respond to your legally justified requests, according to art. 6 paragraph (1) letter c of the GDPR, as well as based on the legitimate interests pursued by the operator, pursuant to art. 6 paragraph (1) letter f of the GDPR, in order to prove documents and facts regarding your request and to defend our interests.
The operating hours of the CUMIRAD INVEST customer relations service are Monday to Friday from 10:00 to 18:00.
Through the customer service we will process the data related to your account, details about the services you have purchased in order to find a suitable solution for the challenge you face and to answer any questions you may have related to any aspect of the platform.
The process is simple, when contacting the customer service through any contact medium (phone, WhatsApp, Facebook, Instagram or any other social network, chat, email, etc.) the operator will request data specific to the action described by you (order number, number telephone number or any other detail established by the system) to identify and confirm you before starting the actual discussion. If these details are not provided then the operator will not be able to help you solve your request.
Improving CUMIRAD INVEST services, based on the legitimate interests pursued by the operator, according to art. 6 paragraph (1) letter (f) of the GDPR and art.12, paragraph (2) of Law no. 506/2004 on the processing of personal data and the protection of privacy in the electronic communications sector, with subsequent amendments and completions.
One of our biggest concerns is to continuously improve our services and for this, we may use personal data for analytical purposes to customize and optimize our online platform so that it matches your needs, constantly transforming websites to be easier to use and more user friendly, as well as to improve our Customer Service. We may also contact you to evaluate the quality of our services or to take part in surveys to improve our services. There may be situations when we contact you to retrieve information about certain events or activities for which you have already purchased tickets to investigate certain situations. Thus, you will be asked to provide us with a telephone number and to provide us, of course, with your consent for the purpose of further processing of this information and/or details.
Customer reviews, based on your consent, pursuant to art. 6 paragraph (1) letter (a) of the GDPR. CUMIRAD INVEST allows you to leave reviews related to the activities you participated in. If you post reviews, your account name and photo can be viewed by other users of the website. If you do not want this to happen, you should not post reviews or delete the post you made. Reviews can be done directly on the website after creating an account or buying a product or by completing the survey sent by us on your email.
Commercial advertising and marketing communications, only based on your consent, pursuant to art. 6 paragraph (1) letter (a) of the GDPR and according to art.12, paragraph (2) of Law no. 506/2004 on the processing of personal data and the protection of privacy in the electronic communications sector, with subsequent amendments and completions.
The personal data provided may be used for marketing activities which may include:
You must be at least 16 years old to subscribe to our email marketing communications.
Fulfilling the legal obligations of the operator CUMIRAD INVEST, pursuant to art. 6 paragraph (1) letter (c) of the GDPR.
We must use your data to comply with our legal obligations, such as, for example, obligations to maintain accounting records for financial and tax activities and reconciliations with entities representing venues, operators, event organizers and event promoters or with PayU. We may also use or disclose necessary data in connection with ongoing litigation in order to comply with court orders and to pursue and defend our legal rights.
The sale of our activity or assets, based on the legitimate interests pursued by the operator, according to art. 6 paragraph (1) letter (f) of the GDPR.
If all or part of the company / its assets are acquired by a third party, or we are involved in a merger or transfer of the business, we may, transfer or assign the data in part or in full to a third party as a part or in connection with the respective transaction. In the event of such a transfer, there is a possibility that the confidentiality policies of the beneficiary entity may govern the subsequent use and collection of personal information, in which case all necessary information regarding the processing of personal data will be transmitted to you.
Personal data or concerning categories of personal data
Personal data provided by you.
When you order or purchase an electronic ticket from CUMIRAD INVEST or through our other contact methods (phone, email, chat, face to face at our headquarters, Facebook or any social network, WhatsApp, etc.), we will require you to provide us with personal information, including first and last name, address, telephone number, email address, credit card information. Also, there may be events/activities for which we requests the declaration of health status or clarifications related to medical conditions, but these data will always be processed only based on your explicit consent, in accordance with art.9, paragraph (2), letter (b) of the GDPR.
Upon creating an account on our website, we will ask you to provide us with personal information, including first and last name, telephone number, email address and password. You will also be able to add your notification preferences to your user account. The user account also allows you to access all the e-tickets you have purchased and the events/activities you have set as favorites.
When you choose to send us a message, using the forms on our website or the instant chat application, we ask you to provide us with your contact details: name and surname, email address, telephone number.
Our website is also interacting with you and allows you to post your review on some events or activities you have participated in. If you choose to post reviews consisting of comments, your name, your photo and comments about events and activities uploaded to our website they will be viewable by other users of the website.
Personal data that we collect automatically
When visiting the website, we will automatically collect certain information, which includes, but is not limited to, your IP address, cookie information, more precisely the date and time you accessed our services, hardware, software or the browser you use and information about your computer’s operating system, such as settings for the language and location from which you access our services, in order to facilitate the operation of the site at optimal parameters and to provide our service to the required standards. Without this information, the site would not function properly.
When you create an account on pe www.bucovina-outdooradventure.com, when you purchase an e-ticket, we also collect information about your search history, purchases, favorite events and activity on our website, including information about clicks and https://www.bucovina-outdooradventure.com web pages you visited, but only with your consent. For more details, see also our cookie policy.
Personal data you provide us about other people
You can participate in certain events and activities with other people you will register from your account, people to whom you want to send tickets from our platform or people to whom you will have to provide all the details in order to be registered for access at the event/activity. These purchases can be made by phone, WhatsApp, email, chat or face to face at our headquarters, Facebook or through any other social network. In the cases described above, it is necessary to provide the contact details of those persons so that CUMIRAD INVEST can provide appropriate information that their data has been provided to CUMIRAD INVEST and that they are processed in accordance with this information note.
Source of personal data
Personal data are those provided directly by you. If you are the recipient of a ticket purchased by a www.bucovina-outdooradventure.com user, your data came from that user. Also, certain data specific to the cookies used, such as the IP address, may be automatically collected through these files.
Recipients of your personal data
For the purposes mentioned above, the recipients of your personal data may be:
We also inform you that we can empower a person to deal with data processing, but only if it has sufficient guarantees and is included in a written contract concluded between the parties involved, which contains a series of mandatory clauses, provided by art. 28, paragraph (3) of the GDPR, including the fact that the authorized person will process data only when CUMIRAD INVEST so requests.
Thus, your data may be processed, on behalf of CUMIRAD INVEST, by the following categories of recipients, whom CUMIRAD INVEST may contract for the provision of services, the fulfilment of the purposes pursued and for the proper conduct of business:
CUMIRAD INVEST uses the Mail Chimp platform to deliver marketing messages (notifications and newsletters) and notifications. Mail Chimp declares itself to be in compliance with GDPR Regulation no. 679/2016 and offers the possibility to unsubscribe at any time from subscribing to the newsletter.
Please note that CUMIRAD INVEST does not intend to transfer personal data to a third country or international organization, and if such processing is necessary, CUMIRAD INVEST will ensure, where appropriate, that there is a Commission decision on the appropriateness of such data or, in the case of transfers referred to in Article 46 or 47 or in Article 49 paragraph (1) of the Regulation, of the existence of adequate or appropriate guarantees, which it will make available to you by updating this information note.
CUMIRAD INVEST services are governed by and construed in accordance with the laws of Romania. CUMIRAD INVEST makes no warranty that its services are governed or operated in accordance with the laws of any other country.
If you are outside Romania, please be aware that the information collected, including personal information, may be transferred, processed, stored and used in Romania. In accordance with Romanian law, your personal data may be subject to requests for access from the Romanian Government, Courts or Law Enforcement.
Personal data period of storage
CUMIRAD INVEST processes and stores personal data for the duration necessary to carry out specific purposes and in its legitimate interest, in accordance with European law or other laws applicable to the company’s activity, and outside the duration of the specific purpose or legitimate interest we process and store data for as long as we allow. If the purpose of processing and storage is not applicable or if the legal retention period expires, personal data are usually blocked or deleted.
Thus, your personal data will be deleted when it is no longer reasonably necessary for the authorized purposes or when you withdraw your consent (where applicable) and it is no longer legally necessary to continue to store this data. However, we will retain your personal data, where necessary for us to support or defend you or others against any legal claims, until the end of the relevant retention period or until those claims have been resolved. If a financial transaction has been made through CUMIRAD INVEST website, the personal data will be archived for a period of five years, in order to comply with the rules of the Accounting Law and the specific Orders on the retention of documents justifying the accounting operations and financial reconciliation with associated operators or PayU.
We have implemented technical and organizational measures to organize the process and the criteria presented for deleting your personal data.
In accordance with the Data Protection Regulation, we inform you that you have the following rights:
If you wish to delete, modify or update the personal data you have provided through the www.bucovina-outdooradventure.com website, you can proceed by changing the settings in the www.bucovina-outdooradventure.com user profile or you can contact us by email cumirad.invest@yahoo.com and we will try to respond within a reasonable time. As mentioned earlier some data will have to be kept in order to function legally and keep certain services and processes functional.
Also, when creating your www.bucovina-outdooradventure.com account, you can subscribe to SMS and email notifications related to your preferences and news regarding events and activities. You can always go back to the account settings and deactivate these notifications or you can access the link at the base of the email to “Unsubscribe” and for SMS to answer the number 1847.
CUMIRAD INVEST through www.booktes.com, which is connected to the SMSO platform, uses the SMSO platform to transmit SMS messages (notifications and newsletters) and notifications. SMSO declares to be in accordance with GDPR Regulation no. 679/2016 and we offer the possibility to cancel at any time the subscription to notifications by unchecking the option from your user account.
CUMIRAD INVEST services and products may contain links to third-party websites or services as well as plug-ins. CUMIRAD INVEST may incorporate content feeds, video players, or other applications from third-party companies into the services and products offered, and such feeds or applications may appear to be part of CUMIRAD INVEST services but are provided or distributed by a third party. If you access another website or any such service, even those that may contain the BookTes.com logo or are framed by CUMIRAD INVEST services, please note that the operators of such websites or services may collect information about you or may place or read cookies, which will be used by them in accordance with their own privacy policies, which may differ from those of CUMIRAD INVEST website. We are not responsible for their policies, we do not approve or control the policies or practices of such websites or services. You should always carefully read the Privacy Policy of any website or service you access in order to understand the practices of using the information.
We clarify that the provision of personal data is required in part by law (eg tax regulations, accounting, labour law, archiving rules) or may result from contractual provisions. Sometimes it may be necessary to provide a paid service/concluded a contract according to which the person concerned provides us with personal data, which must be further processed by us to perform the service/contract. The person concerned is, for example, obliged to provide us with personal data when our company provides or is part of a paid service/concludes a contract with him or her. The refusal to provide personal data would have the consequence that the service could not be provided to the person concerned. Before providing personal data by the person concerned, the person concerned must contact the operator. The operator clarifies for the person concerned whether the provision of personal data is provided by law or contract or is necessary for the conclusion of the contract/service provider if there is an obligation to provide personal data and the consequences of refusal to provide personal data.
Children’s policy
CUMIRAD INVEST services are not intended for use by children under the age of 16. If you are under the age of 16, you are advised not to CUMIRAD INVEST services or to provide personal data and information. If CUMIRAD INVEST discovers that such data has been accidentally collected then, by law, we will delete this information from the CUMIRAD INVEST database. If a child under the age of 16 uses www.bucovina-outdooradventure.com and is discovered by a parent or guardian, they are advised to contact CUMIRAD INVEST via cumirad.invest@yahoo.com and notify us urgently about this case.
Security of personal data
We ensure that personal data is secured against threats and that it is protected by the IT infrastructure and appropriate security measures put in place by the latest technologies. Moreover, we have developed and implemented our own security measures, which allow us to detect, notify and document security breaches in the shortest possible time.
If any violation of personal data is discovered, which poses a risk to your rights and freedoms, according to the law in force, we will inform the National Authority for the Supervision of Personal Data Processing. You will also be informed of the breach of your personal data if this leads to a high risk to your rights and freedoms.
Please note that you must maintain privacy and protect the password you use to log on to www.bucovina-outdooradventure.com. CUMIRAD INVEST will not be responsible if your password is used by someone else.
A brief description of the roles and responsibilities of CUMIRAD INVEST’ internal organization for the protection of your personal data
CUMIRAD INVEST provides support, assistance, advice and training to all relevant departments, offices and related staff to ensure that they are able to comply with the law.
The Company’s management is responsible for reviewing and approving privacy policies and ensuring that there are appropriate policies and procedures in place within each department and that any breaches of data security are properly addressed. Each member of management is responsible for ensuring compliance with the General Data Protection Regulation in his area of responsibility; Also, the Company’s Management processes and response to formal requests for access to data; initiate regular reviews of data protection policies and procedures and ensure that documentation is updated as appropriate; organizes specific training and education sessions for staff; provides advice and guidance to staff on data protection issues; maintain a record of BookTes’ processing activities; collaborates with the Data Protection Authority when necessary/recommended, including in case of a data security breach.
CUMIRAD INVEST employees have certain key responsibilities for the information they keep on their computer or in hand-structured fact sheets about persons, which are summarized in terms of eight “Rules” that employees follow. Thus, CUMIRAD INVEST employees:
CUMIRAD INVEST knows that your privacy is very important to you. We are waiting for questions and comments regarding this privacy policy, so do not hesitate to contact us at cumirad.invest@yahoo.com or by phone at no. (+40) 759 144 144. If you are dissatisfied with our answer, you are free to file a complaint with the competent authority for data protection (www.dataprotection.ro).
Because Internet technologies are changing so fast, CUMIRAD INVEST reserves the right to change its privacy policy from time to time. By using the company’s website and services, you agree to the terms and conditions of this privacy policy.
CUMIRAD INVEST will change the privacy rules if it deems it necessary. CUMIRAD INVEST will be responsible for posting such changes on the Privacy Policy page to inform you of changes to the types of data that are collected and how they are used.