Data Processing Policy - Bookster
- DEFINITIONS AND TERMS
BOOKSTER – refers to the registered trademark and trade name under which Bookster Experience S.R.L. operates, headquartered in Bucharest, Drumul Săbăreni no. 24-26, Administrative Building, Ground Floor, Sector 6, Romania, having the unique fiscal registration code 43370198, registered with the Trade Register under no. J40/16111/2020.
Contact Form – the section of the Website through which the data subject expresses their intent and consent to contact Bookster for the purpose of receiving offers and, where applicable, other information about the company’s services and prices.
Bookster Commercial Offer/Bookster Offer – a set of information regarding Bookster’s services and prices, customized according to the client’s needs and characteristics.
Data Subject – the natural person whose personal data is processed as a result of accessing the Website and, if applicable, completing and submitting the Contact Form to Bookster.
Website – companii.bookster.ro and its associated subdomains/pages.
- PERSONAL DATA PROCESSING POLICY
Ensuring the right to data protection is a fundamental commitment of Bookster. Therefore, we dedicate all necessary resources and make every effort to process your data in full compliance with Regulation (EU) 2016/679 (“General Data Protection Regulation” or “GDPR”) as well as any other applicable legislation. One of the essential principles of this legal framework is transparency, and we want you to be fully informed. Thus, this document presents the ways we collect, use, transfer, and protect your personal data.
We reserve the right to periodically update this Data Processing Policy (hereinafter referred to as the “Policy”) so that you are always aware of any changes in how we process your personal data and any other changes to legal requirements. In the event of such changes, we will display the updated version of the Policy on our website, and therefore we recommend you check its content periodically.
- DATA CONTROLLER
Bookster Experience S.R.L., a limited liability company headquartered at Drumul Săbăreni no. 24-26, Office 1A06F, Administrative Building, Sector 6, Bucharest, Romania, registered with the Trade Register under no. J40/16111/2020, having CUI 43370198, e-mail: olvasok@bookster.hu , operates as a data controller (hereinafter referred to as “Bookster” or “the Company”).
- PURPOSES, DATA CATEGORIES, LEGAL BASIS, AND DURATION OF PROCESSING
4.1 Completion and Submission of the Contact Form
To contact Bookster via the Contact Form, you must complete the required fields. By completing the Contact Form, you provide us with personal data such as: name, surname, organization name, number of employees, email address, and phone number.
This processing activity is based on your consent (Article 6 para. 1, letter a GDPR), being fully optional for the data subject to contact the Company through the Form for the purpose of receiving information about Bookster’s services and the Bookster Commercial Offer. Additionally, processing may occur in the context of taking steps to conclude a service contract if the Bookster Offer is selected and accepted (Article 6 para. 1, letter b GDPR).
Your personal data will be processed by Bookster throughout the management of the request submitted via the Contact Form. If the Bookster Commercial Offer is accepted and a service contract is concluded, your personal data may become part of the commercial agreement concluded with Bookster, in which case they will be retained during the contract’s execution period, as well as afterward for ensuring the company’s legitimate interest in protecting, exercising, or defending certain rights in court.
In the event that you decide not to continue discussions with Bookster initiated following the submission of the Contact Form or if the Commercial Offer is not accepted, your personal data will be retained for a maximum period of 3 years from the date of their collection or until consent is withdrawn, whichever occurs first.
4.2 Sending Newsletters
Bookster processes your personal data, such as your name and email address, to send marketing communications in the form of newsletters, based on your consent (Article 6 para. 1, letter a GDPR).
Through these communications, you are informed about aspects such as the latest campaigns, offers, and promotions by Bookster; recommendations for services and products offered by Bookster; events and experiences organized by Bookster; and other commercial and marketing information.
You have the option to withdraw your consent for receiving marketing communications by sending a request to olvasok@bookster.hu or by accessing the unsubscribe link in the footer of each marketing email sent by Bookster. Data will be kept and used for this purpose until the moment consent is withdrawn, but no longer than 3 years from the date consent was given.
4.3 Responding to Questions, Requests, or Complaints from the Data Subject
Bookster will process personal data such as your name, surname, email address, and any other information provided during correspondence to resolve and respond to questions, requests, or complaints regarding the Website’s use or the Contact Form.
This processing is based on our legitimate interest to maintain good relations with data subjects (Article 6 para. 1, letter f GDPR), allowing us to respond to your inquiries, requests, or complaints and to protect our company’s rights and assets.
4.4 Browsing the Website. Use of Cookies
When you visit/access companii.bookster.ro or its associated subdomains/pages, technical information that can identify the data subject may be stored and collected via cookies or similar technologies, such as your IP address or data regarding Website visits.
For more information about the use of cookies and their purposes, as well as ways to control and/or disable cookies, Bookster encourages you to review the Cookie Policy.
- DATA SECURITY
We are committed to ensuring the security of personal data by implementing appropriate technical and organizational measures in accordance with industry standards.
Despite the measures taken to protect your personal data, please note that data transmission over the Internet and other public networks is not entirely secure, and there is a risk that data may be seen and used by unauthorized third parties. We are not responsible for such vulnerabilities in systems that are not under our control.
2.5. LINKS TO FACEBOOK, INSTAGRAM, LINKEDIN, AND TIKTOK
To optimize the Website’s functionality, we have implemented links to Bookster’s accounts on Facebook, Instagram, LinkedIn, and TikTok.
You can recognize these links by the Facebook, Instagram, LinkedIn, and TikTok logos inserted on our Website. When you click on each logo, the link establishes a direct connection to the Facebook, Instagram, LinkedIn, or TikTok websites. If the data subject clicks the “share” button on Facebook while logged into their Facebook account, the content of our online services may be linked to their Facebook user account. Facebook may thus associate the use of our online services with their user account on the respective platform.
We would like to emphasize that the use of personal data through Facebook, Instagram, LinkedIn, and TikTok is subject to the terms, conditions, and privacy policies established by these companies, over which Bookster has no control or responsibility. For more information about the privacy policies adopted by these companies, please visit:
- (i) Facebook – https://www.facebook.com/policy.php
- (ii) Instagram – https://help.instagram.com/519522125107875
- (iii) LinkedIn – https://www.linkedin.com/legal/privacy-policy
- (iv) TikTok – https://www.tiktok.com/legal/privacy-policy-eea?lang=ro
If you do not wish Facebook, Instagram, LinkedIn, or TikTok to associate your use of our online services with your user account, please do not access the respective links from the Website.
This data processing activity is based on our legitimate interest in allowing interaction with individuals interested in Bookster’s content via social media platforms such as Facebook, Instagram, LinkedIn, and TikTok.
2.6. INTERACTIONS VIA SOCIAL MEDIA
We may process your personal data, such as your first and last name, image, username, and, if applicable, your email address, phone number, and any other information or details you provide when you interact with Bookster via social media platforms like Facebook, Instagram, LinkedIn, and TikTok on Bookster’s official pages or when you ask us questions or make requests through these communication channels. This is based on our legitimate interest in engaging with individuals interested in Bookster’s information published on its social media profiles and responding to their inquiries/requests.
Access to our official social media pages is governed solely by the terms and conditions established by Facebook, Instagram, LinkedIn, and TikTok. Each social media platform has its own data privacy policy. If you have questions about how your data is used by these platforms or would like more information on the types of personal data collected and processed by them, the rights of data subjects, or how to manage your privacy settings, we encourage you to consult their respective privacy policies (see point 2.5 above).
2.7. CHAT BOX
Bookster may process your personal data, such as your name, surname, email address, phone number, and any other information you provide when you contact us via the chat box on the Website. This processing is based on our legitimate interest in maintaining communication with Website visitors through this form of communication and managing conversations initiated through the chat box (Article 6 para. 1, letter f GDPR).
This data will be stored during the conversations initiated by the data subject when contacting Bookster via the chat box, as well as for the period necessary to protect the Company’s rights, taking into account the applicable law, including the limitation period.
2.8. BOOKSTER BLOG
You can access materials and articles posted by Bookster on its Blog (companii.bookster.ro/blog/), where you also have the option to share the accessed materials through social media channels. In this situation, personal data processing may occur as a result of your interaction with Bookster via social media channels and the sharing of Blog materials via your social media accounts.
For more information on data processing through social media channels and/or, where applicable, regarding the privacy policies of these platforms, please refer to points 2.5 and 2.6 in this Policy.
For additional details regarding privacy policies, you can also visit:
- (i) Twitter – https://twitter.com/en/privacy
- (ii) Telegram – https://telegram.org/privacy?setln=fa
This processing activity is based on our legitimate interest in interacting with individuals interested in Bookster through social media channels and the legitimate interest of the Company in promoting its services, including via the Blog.
2.9. INTERNAL STATISTICS
Personal data may also be processed for internal statistical purposes, based on Bookster’s legitimate interest and the existence of appropriate safeguards to protect the rights and freedoms of the data subject. Bookster’s safeguards ensure the implementation of necessary technical and organizational measures to adhere to the principle of data minimization, including pseudonymization measures.
Statistical processing generally means that the result is presented in an aggregated format, and such results or personal data will not be used to support measures or decisions concerning a specific individual. Data will be stored and used for this purpose for no more than 3 years from the date of collection.
For none of the above purposes does the Website collect or process sensitive data as defined by the GDPR’s special categories of personal data.
- PROCESSING OF DATA FOR INDIVIDUALS OVER THE AGE OF 18
Bookster does not intend to collect or process data from minors. Thus, all personal data processing activities described in this Policy apply exclusively to individuals who have reached the age of majority in their country of residence (in Hungary, this is 18 years old). Accordingly, anyone who provides their personal data to Bookster through the Website, Contact Form, or other applications or devices covered by this Policy guarantees that they are an adult.
The use of systems and the results of data processing are prohibited for individuals who have not reached this age. If, despite our reasonable efforts to prevent this, such processing still occurs, we will cease it as soon as we become aware that the individual has not reached the required age.
AUTOMATED DECISION MAKING AND AUTOMATED PROFILING
Bookster sometimes uses automated processing to provide you with more personalized and enjoyable browsing experiences and interactions with the Website, as well as more coherent services and offers tailored to customer needs and interests, along with marketing information that we believe may be of interest to you.
In this regard, certain personal data referred to in this Policy, namely your name and surname, email address, telephone number, role in the company, as well as information regarding the company name and the number of employees, are subject to automated decision-making processes, including profiling.
The purpose of this type of processing is to provide Commercial Offers tailored to the needs and interests of the organization (company/society) in which you operate and/or on whose behalf you contact us, as well as to send personalized marketing communications based on the data subject’s consent, through the communication channels selected by them.
These categories of data are useful and can be used to configure and communicate personalized services and pricing offers, as well as to determine future marketing communications that may be of interest to the data subject and, if applicable, the organization they belong to and/or on whose behalf they contacted us through the Contact Form. The logic behind this processing is to provide customized offers and marketing communications, taking into account the role in the company as well as information about the company name and the number of employees.
The anticipated meanings and consequences of this processing for the data subject are that they will be provided with personalized commercial offers and, if applicable, personalized marketing communications. These aspects may influence the data subject’s position regarding the opportunity/possibility of accessing Bookster’s services and, if applicable, the completion of the commercial service contract between the organization and Bookster, or the decision to use the Bookster Platform.
RECIPIENTS OF PERSONAL DATA
Where appropriate, we may transmit or provide access to certain personal data to the following categories of recipients: IT system providers and their support services, including email archiving; telecommunications service providers, backup and disaster recovery services, and IT security services; marketing service providers; customer support and courier service providers; employers/companies in which you operate; other outsourced service providers.
The personal data we disclose is limited to the minimum personal information necessary to provide these services, and we require these partners not to use personal data for any other purpose. We make every effort to ensure that all entities we work with store personal data securely.
Personal information may also be made available or transferred to third parties in the following situations, where they may access the data in fulfilling their tasks or interactions with the Company: (i) public authorities, financial or legal auditors, or institutions with powers to conduct inspections and controls of the Company’s activities and assets, which request the Company to provide information in accordance with its legal obligations; (ii) to comply with a legal requirement or to protect the rights and assets of our Company or other entities or individuals, such as bailiffs, courts, and other competent state bodies, under the conditions and within the limits provided by law and as a result of explicit requests; (iii) third-party acquirers, to the extent that Bookster’s business is transferred (in whole or in part), and the data subjects’ data would be part of the assets involved in such a transaction.
Personal data will not be transferred abroad to third countries outside the EU or EEA.
DATA PROCESSING SECURITY
We are committed to ensuring the security of personal data by implementing appropriate technical and organizational measures in accordance with industry standards.
We keep your personal data on secure servers and ensure storage redundancy.
Despite the measures adopted to protect your personal data, we note that the transmission of information over the Internet in general, as well as through other public networks, is not entirely secure, and there is a risk that data may be seen and used by unauthorized third parties. We cannot be held responsible for such vulnerabilities in systems that are not under our control.
REFUSAL TO PROVIDE DATA AND CONSEQUENCES
If you do not provide the minimum personal data requested in the mandatory fields of the Form, you will not be able to contact Bookster through this method, and we will not be able to provide you with information regarding our Commercial Offer; accordingly, the steps will not lead to the completion of a commercial service contract.
RIGHTS OF THE DATA SUBJECTS
In the context of personal data processing, data subjects have the following rights:
Access
You can ask us:
- To confirm whether we are processing your personal data;
- To provide you with a copy of this data;
- To offer you other information about your personal data, such as: what data we have, how we use it, to whom we disclose it, and how we protect it, how long we retain it, what rights you have, how you can file a complaint, and where we obtained your data – provided that this information has not already been provided through this notice.
Rectification
You can ask us to correct or complete your personal data if it is inaccurate or incomplete. We may attempt to verify the accuracy of the data before correcting it.
Erasure of Data
You may request that we delete your personal data in the following situations:
- The data is no longer necessary for the purposes for which they were collected;
- You have withdrawn your consent;
- You exercise a legal right to object;
- The data was processed unlawfully;
- We are legally obligated to do so.
We are not obligated to comply with a request to delete your personal data if data processing is necessary:
- For compliance with a legal obligation;
- For establishing, exercising, or defending a legal claim.
Data Portability
You can request that we provide your personal data in a structured, commonly used, and machine-readable format or request that it be directly "ported" to another data controller, but only if:
- The processing is based on your consent or on the conclusion or execution of a contract with you; and
- The processing is carried out by automated means.
Objection
You can object to data processing for reasons related to your particular situation when processing is based on a legitimate interest, as well as to oppose data processing for direct marketing purposes, including profiling.
AUTOMATED DECISION MAKING
You may request not to be subject to a decision based solely on automated processing, including profiling, but only when the respective decision:
- Produces legal effects concerning you;
- Affects you in a similar and significantly impactful way.
This right does not apply if the decision resulting from automated processing:
- Is necessary to conclude or perform a contract we have with you;
- Is authorized by law and includes appropriate safeguards for your rights and freedoms;
- Is based on your explicit consent.
RIGHT TO WITHDRAW CONSENT
In cases where processing is based on your consent, you can withdraw it at any time. The withdrawal of consent will only apply to future actions; processing performed before withdrawal will remain valid.
You can withdraw your consent by sending a request to the following email address: olvasok@bookster.hu or by sending a request to the company’s headquarters at Drumul Săbăreni no. 24-26, Administrative Building, Ground Floor, Sector 6, Bucharest, Romania. You may also withdraw consent by clicking the unsubscribe link included in the footer of every commercial email sent by Bookster.
COMPLAINTS
You have the right to submit a complaint to the supervisory authority regarding the processing of your personal data.
EXERCISING YOUR RIGHTS
To exercise your rights, you may contact us using the contact details listed above. If you wish to exercise your rights, please keep the following in mind:
Identity Verification: We take the confidentiality of all records containing personal data seriously. We reserve the right to verify your identity by requesting additional information aimed at confirming your identity.
Response Time: We aim to respond to any valid request within a maximum of one month unless this is particularly complex or if you have made multiple requests. In such cases, the response period may be extended by up to two months. We will notify you if we require more than one month. We may also ask you to provide additional details about your request. This will help us act more quickly and shorten the response time.
Third-Party Rights: We are not required to comply with a request if it would adversely affect the rights and freedoms of other persons.