Privacy Policy

I. General provisions
Dear customers, thank you for your interest in the services of zbor24.ro.
The website https://www.zbor24.ro/ (hereinafter referred to as the "site"), intended for online reservation – sale of airline tickets, belongs, as author/owner/administrator, to the travel agency "EMA Plus Solutions" S.R.L., CUI: 38540407, Registration No. in the Trade Register: J40/19757/2017, with headquarters at GHEORGHE SIMIONESCU, No.19, Ap B26, Sector 1, Bucharest 014155, Romania (hereinafter referred to as the "Agency").
We aim to provide visitors and users of the site with a safe online experience that does not in any way affect their personal life. The Agency has committed through the Privacy Statement to respect the privacy of visitors and users of the site. We take data protection, security, and compliance with legislation regarding personal data protection and privacy seriously.
Therefore, we pay special attention to protecting the privacy of users who access our site and we undertake to process, under safe conditions and only for the specified purposes, the personal data provided to us in accordance with:

Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 regarding the protection of natural persons with regard to the processing of personal data and the free movement of such data ("GDPR"),
Law no. 190/2018 regarding measures for implementing Regulation (EU) 2016/679,
Requirements regarding ensuring the security of personal data during their processing within personal data information systems, and
The security policy regarding the protection of personal data during their processing within the information systems managed by "EMA Plus Solutions" S.R.L.

The terms "personal data", "processing of personal data", "controller", "third party", "data subject" have the meaning defined in Regulation (EU) 2016/679 (GDPR), but in any case, personal data represent any information relating to an identified or identifiable natural person, regardless of the form or format in which such data exist.

II. What kind of personal data do we collect and process?
You can browse most pages of this site without having to provide personal data. However, in some cases, in order to provide the requested services, such data are needed, namely for performing online operations (reservations, ticket purchases, medical insurance, filling out forms, creating your account on our site, subscribing to our services, etc.), only for the purposes specified in this Privacy Policy.
The provision of personal data by the client is an act of trust, and the Agency will take the necessary measures to justify this trust.
Any processing of personal data, except for those expressly mentioned in the applicable legislation, may be carried out only if the data subject has given their unambiguous consent, in written or electronic form, or by using electronic communication means regarding the intended processing.
To the extent that special categories of personal data are required, the Agency will request your consent in accordance with the provisions of art. 9 of Regulation (EU) 2016/679 (GDPR).
We receive and store any information you enter on the site, provide to Customer Support Service and the Agency in any other way, to the extent necessary only to provide the services or to perform the contractual relationship with you. Personal data may also be collected and processed automatically when you use this site (for example, through cookies).
When using the site, the Agency receives, collects, stores, and processes the following personal data:

name, surname, patronymic, date of birth, gender, citizenship, mobile phone number, home/residence address and email;
document data necessary for identification purposes (for example, passport number and series, validity period);
the last 4 digits of the payment card number;
log files (IP address, browser type, referral/exit pages and URLs, number of clicks and how you interact with the site, domain names, landing/content pages, viewed pages/content, device ID and device location);
profile information (preferences, data from your search history, reservation history data, travel plans and other information about you);
user content (opinions and comments you upload on the site);
user behavior (your activity on the platform, login time and location, comments and uploads);
any other information you voluntarily place on the site;
personal data collected through cookies (see below).

We may also request additional information, which may include "sensitive" personal data (for example, information that may identify your health condition or religious beliefs) in order to provide you with the highest possible level of services. This information may be correlated with your preferences related to seat selection in transport or hotels, menus, the need for additional assistance or the use of additional equipment when using the services. Such "sensitive" information is provided on your own initiative and with your explicit consent and only if the provision of services would be impossible without such "sensitive" information. Sharing such sensitive personal data with third parties may be required during the provision of the requested services by us based on mandatory legal provisions.
We also offer the possibility to register and create an account through your existing social network profile (such as Facebook). In this case, your authentication information (name and email address) will be imported from your social network account. It is important to note that when using this option, we may receive certain information through the respective social network, such as your name, age, location, preferences, occupation and other information from your public profile. Not all this information is requested by us, but it is automatically provided by the social network provider by using the "social sign-on" option. However, we will only use the information necessary to create your account and will delete unnecessary data after receiving any additional information. After creating your account, you will have the possibility to complete it with any information you wish to share and that is necessary for providing the services.

Data of another data subject. If you create a reservation for services and/or make a payment on behalf of or for the benefit of another data subject, the information you provide about these subjects will be collected and processed by the Agency in accordance with the same terms and conditions that apply to your personal data. By providing such information about other data subjects, you confirm that these subjects are familiar with the present terms and understand their consequences, as well as that they give their unconditional and full consent for the collection and processing of their personal data in accordance with these terms and agree that access to such information is possible from your Account section.
Collection of minors' data. If you have not reached the age of majority, you must not use this site and are required to leave it immediately. This site must not be used and is not intended to collect information about minor users or to advertise services to children without parental consent. The Agency processes personal data of minors exclusively in cases where this information is provided by parents or their legal representatives and only for the purpose of creating a reservation. If the Agency detects the use of the site by a minor and the provision of personal data by them, or in the case of requests from parents or legal representatives regarding the deletion of personal data, this information will be deleted within a reasonable period of time, and the Agency will make all efforts to prevent the storage and processing of minors' personal data.
Automatic data collection and cookies. Like most websites and mobile applications, we use automatic collection of information about you, cookies and social network plug-ins, provided that you have given your consent to their use (for example through the banner on our site), to optimize our services and the site, except in cases where cookies are strictly necessary for the technical functioning of the site.
When you use this site, automatic collection of information about the device you use to access the site takes place, for example software, operating system, IP address, source of links to and from this site, web pages you clicked on, links you used to access the site, etc. Automatic data collection takes place in order to adapt the use of the services offered by zbor24.ro and the offers intended for you, as well as to prevent possible fraud.
If you use social networks to connect to the site, we may receive your data and preferences from these social networks in accordance with the rules for providing information by these service providers and the terms of the privacy policy set by you.
Automatic collection of certain data and the use of “cookie” and “web beacon” technologies improve the functions of the site and develop the most convenient use of zbor24.ro services, and also help us evaluate the implementation of advertising and marketing campaigns, provide information that may interest you and be useful to you, and build usage profiles for market research.
Until you log in to the "My Account" section, the use of this data for the purposes described in the previous paragraph will be in pseudonymized form. This means that we will replace your name and other characteristics that can identify you with another identifier to make it impossible to identify you as a person and we will not link such usage profiles with other data we store about you. After you log in to the "My Account" section, the use of this data for the purposes described in the previous paragraph will be personalized and connected to you. Cookies are small text files that can be stored on a computer (or any other device) during the first visit to the site and allow us to identify the computer during your visit (for example, to remember your login data for "My Account"). We use in particular (i) functional cookies that do not collect personal data and (ii) cookies that help us generate aggregate data about traffic and user interactions, which gives us the possibility to offer better functionality on the site and personalized advertising. We may also use trusted third-party services that track this information on our behalf. You can choose to have your device notify you each time a cookie is set or you can choose to disable cookies entirely. However, if you disable cookies, some features may be disabled and some of our services may not function properly.

III. How we use your data and the data of another data subject
We use your personal data to:

provide the services ordered by you;
communicate with you regarding the services ordered and to send you reservation confirmation;
create, process and edit your Reservation;
provide assistance and customer support in using the site and zbor24.ro services;
provide information about available and future services and offers, if you have given your consent for such use;
improve the performance and quality of the site;
respond to your requests and comments;
calculate bonuses if you participate in our loyalty programs "Bonus Program";
encourage you to participate in our surveys and provide feedback;
learn about services that may interest you;
satisfy your claims;
inform you about possible illegal or unlawful actions;
resolve any issues that may arise in connection with the fulfillment of the Terms and conditions;
for any other purposes necessary to fulfill our contractual obligations about which we will notify you before carrying out the new processing. If necessary, we will request your consent before starting the new data processing activity.

Thus, the collection will be carried out for specified, explicit and legitimate purposes, and will not be further processed in a manner incompatible with these purposes.
Please note that providing the services may be impossible if some personal data have not been provided by you.
With your consent, we will also process your personal data (name, email address and preferences) in order to send you periodic emails (Newsletter), as well as to send notifications regarding our services, special offers, promotions and auxiliary services.
The Agency makes every effort to provide you with services at the highest level. Thus, with your consent, we may send you information with the list of offers on our site that may interest you and that may be related to the services selected by you. If you do not wish to receive such emails, you can opt out of receiving them.
The legal basis for the collection and use of personal data described above depends on the personal data concerned and the specific context in which we collect them. However, we will normally process personal data only (i) where we need the personal data to provide the services or to perform the contractual relationship with you, (ii) where we have your consent, or (iii) where the processing is in our legitimate interests and is not overridden by your rights. In some cases, we may also have a legal obligation to collect personal data from you.
If you wish, you can contact us to receive additional information and clarifications regarding the personal data we collect and process.

IV. Data storage
We store the personal data we collect from you for as long as necessary for any legitimate need at the time (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements) or for the limitation period provided by the relevant legislation. When we no longer have a legitimate ongoing need to process your personal data, we will delete or anonymize them or, if this is not possible (for example, because your personal data have been stored in archives in accordance with applicable law), then we will securely store your personal data and isolate them from any further processing until deletion is possible. In any case, personal data will be processed until the withdrawal of consent.

V. Transfer of your data
Where necessary for the proper provision of the services selected and booked by you, we transfer your personal data to third parties as the services cannot be provided without such transfer.

You confirm and agree that, in order to provide the services, the Agency may transfer your personal data to recipients located outside Romania and Europe or in states that do not ensure an adequate level of data protection, in order to obtain the appropriate level of the ordered services. Thus, your personal data may be accessed by persons authorized by the controller and by service providers from countries that do not offer the same level of data protection as in the European Economic Area. The storage and processing of your personal data may be carried out on servers and resources owned/leased by the Agency, controllers or independent contractors, which may be located in any country in the world (including but not limited to countries of the European Union or the European Economic Area, USA, Canada).

Therefore, the Agency, if applicable, will take all reasonable measures in relation to the recipients of your personal data, which are necessary to ensure an adequate level of protection, as defined by the applicable personal data protection law, in particular by applying contractual clauses that stipulate that the country in which the recipient of the transferred data is located provides an adequate level of data protection.

You are aware and agree that, depending on the chosen travel destination, your personal data may be transferred to countries (country of registration/operation of operators, airports, etc.) where an adequate level of personal data protection cannot be ensured.

Any cross-border data transfer is limited to those categories of data and recipients necessary to comply with the Terms and conditions, these provisions and to provide you with the requested and contracted services.

VI. Your rights
Regulation (EU) 2016/679 (GDPR) grants any user of this site the following rights:

the right to be informed (art. 13-14 GDPR);
the right of access to personal data (art. 15 GDPR);
the right to rectification (art. 16 GDPR);
the right to erasure ("right to be forgotten") (art. 17 GDPR);
the right to restriction of processing (art. 18 GDPR);
the right to data portability (art. 20 GDPR);
the right to object (art. 21 GDPR);
the right not to be subject to a decision based solely on automated processing (art. 22 GDPR);
the right to lodge a complaint with the supervisory authority (ANSPDCP).

All these rights can be exercised through a written, dated, signed request addressed to the Agency.

The Agency may collect personal data from you, but only with your consent and only if you provide them voluntarily. If you do not want your data to be collected, please do not provide them to us.

If, after providing us with your data, you wish them to be updated or removed from the database, or you wish to withdraw your consent, without affecting the lawfulness of processing carried out based on consent before its withdrawal, you may modify or withdraw your consent at any time, and we will act immediately accordingly, unless there is a legal reason or legitimate interest not to do so. In this regard, you can notify us at any time at the following address: contact@zbor24.ro

If you consider that the processing of your personal data by the Agency violates the legal provisions in the field of personal data protection, you may also file a complaint at the following address: contact@zbor24.ro or with the National Supervisory Authority for Personal Data Processing (ANSPDCP), www.dataprotection.ro.

VII. Changes
The Agency, at its sole discretion and as necessary, may periodically introduce changes to this Privacy Policy. The Agency will publish the changes on the site to be accessible to the general public. The Agency is not obliged to notify you about the changes made to these terms, but only to publish them on this site. The changes take effect on the date of their publication. You must independently check updates of this site regularly. You confirm and agree that your explicit acceptance of these provisions and/or your use of the site after the publication date of the changes will be considered as your full and unconditional agreement with the amended policy. If you do not accept the amended privacy policy, you must cease using the Site.

Our site may contain links to other websites outside our control. If you access these links, please check the privacy policy applicable to those websites, which may differ from that of the Agency.