GENERAL REGULATIONS FOR TRAVEL FREE EXCLUSIVE CLUBCARD
1. THE ORGANISER
Heinrig Impex SRL Filiala București, registered office in Str. Sabinelor nr. 104A, Sector 5, Bucharest, Romania, Tax ID RO 11955941, Trade Register no. J40/6143/1999, hereinafter called the “Organiser”.
2. PERSONAL DATA PROTECTION
Pursuant to the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons 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), Heinrig Impex SRL Filiala Bucureşti is bound to provide the safe management of your personal data, and solely for the specified purposes.
Personal data shall be any data concerning an identified or identifiable natural person; an identifiable natural person is that person who can be identified directly or indirectly. To be more exact, this implies any kind of information which helps at your identification as an individual. “Directly“ means such data as your name and address, for instance; “Indirectly” means any combination thereof and other kinds of data.
The types of personal data collected during the registration for the Travel Free Exclusive Club Card loyalty program are detailed below:
• Last name
• First name
• Home address (Street, street no., County, country)
• Email address
• Telephone number (mobile)
• Birth date
Heinrig Impex SRL Filiala Bucureşti uses the personal data you provide upon filling out a form registering for the Travel Free Exclusive Club Card loyalty program for the following purposes:
• to register personal data in the Heinrig Impex SRL Filiala Bucureşti company database;
• to carry out communication with you for the purpose of granting benefits, for instance, exclusive offers, avant premieres, the promotion of new company products, including the receipt of information materials from Heinrig Impex SRL Filiala Bucureşti, sent by mail, online by e-mail, or by text message, to collect your feedback on the services provided by Heinrig Impex SRL Fililala Bucureşti in stores;
• to store and analyse the information in your complaints made by telephone, by e-mail, through social media or by other means, when applicable;
• to meet your demands on the good operation of the Travel Free Exclusive Club Card Program
• to carry out personalised marketing
You are bound to provide your personal data, such as surname, first name, full home address, birth date, sex, signature, such being necessary to identify you in order to determine the contractual relationship between you and Heinrig Impex SRL Filiala Bucureşti, in order to be able to join the loyalty program and enjoy the benefits provided under the Heinrig Impex SRL Filiala Bucureşti program.
Your refusal shall trigger our impossibility to make an offer pursuant to the above and, therefore, your participation in the Travel Free Exclusive Club program shall not be possible.
Registered information is intended for the utilisation by the controller and is made available solely to contractual partners from Romania and other EU countries, for the purpose shown in this Regulation.
Pursuant to the provisions of Regulation (EU) 2016/679, you are beneficiary of the right of access to data, the right to the rectification thereof, the deletion of data (right to be forgotten), the right to restrict processing, the right to data portability and the right to object.
To exercise these rights, you may file a dated and signed written request sent to the Organiser’s address in Bucharest, i.e. Heinrig Impex SRL Filiala Bucureşti, registered office in str. Sabinelor nr. 104A, Sector 5 or by sending an e-mail at firstname.lastname@example.org, and Heinrig Impex SRL Filiala Bucureşti will reply within 30 days of the receipt of the request.
The General Regulations are available to all participants in the program for further reading, in any of the Travel Free stores in Romania and on the www.travel-free.ro website. The Organiser reserves the right to amend and change these General Regulations, and all amendments shall enter into force only following the notification of such amendments to the public. No amendment or suspension will give any rights to compensation of the member, and no member shall have any financial claim against Heinrig Impex SRL Filiala Bucureşti as a result of their participation in the Travel Free Exclusive Club Card program.
The Travel Free Exclusive Club Card loyalty program presented in these regulations is carried out throughout Romania, in the stores operated by Heinrig Impex SRL Filiala Bucureşti.
4. PROGRAM DURATION
The Travel Free Exclusive Club Card program duration is indefinite, and the participants will have the possibility to withdraw their consent for the processing of their data. The Organiser is entitled to decide to end or amend the program at any time. Notification concerning the cessation of the program shall be posted by the Organiser at least 15 days before the program ceases, in all Travel Free stores, in a visible place, and it shall also be sent to the participants by e-mail. The Travel Free Exclusive Club Card program shall be carried out pursuant to the provisions of these General Regulations.
5. PROGRAM REGISTRATION
Members of the Travel Free loyalty Program shall be natural persons who are of age (hereinafter called the “Participant”). The program may only be accessed by filling out the mandatory fields and by signing the Registration Form in the Travel Free Exclusive Club Card Program. The Registration Form is available in printed form at any of the Travel Free stores. Participants are bound to fully fill out the registration form entirely, with their actual data, by using legible capital letters. Mandatory fields are marked with * and these are as follows: surname, first name, sex, street, number, district/county, birth date and signature. The program Registration Form shall be filled out and handed over to the Travel Free store staff at the cash register. All unsigned forms or forms which include only partial or inaccurate data shall be invalid, and the persons who filled them will not be able to benefit from the Travel Free card advantages. Unsigned and partially filled out and/or inaccurate forms shall be destroyed.
6. THE TRAVEL FREE LOYALTY CARD
In order to get a Travel Free card, participants in the Travel Free Exclusive Club Card Program need to fill out the registration form shown in the Regulations. The card is personalised by way of a unique bar code assigned to each individual participant. The Travel Free Card is free of charge. Participants begin to collect points as of the first transaction they make after receiving the Travel Free Card.
For each purchase carried out in the Travel Free stores, when the Travel Free Card is presented and scanned, the participants’ account is supplied with one point for each EUR 1 spent (the reference rate of exchange shall be as indicated by BNR* on the transaction day, as listed at the cash registers), except the purchase of tobacco products. For the purchase of this products no points will be added to the participants’ account. No partial points shall be accumulated in the case of amounts lower than EUR 1. The points gathered by participants shall not be exchanged for money, products or services. No points shall be granted for values not paid with cash or by bank card. Participants gather points only for the difference between the total amount of the purchase and the value of vouchers used for the respective purchase.
The Travel Free Card holders who do not deliver their cards for scanning before the purchase will not be supplied with points and shall not benefit from any potential promotional campaigns aimed at the Travel Free Card holders valid when the purchase is made in the Travel Free stores.
The card holder shall be granted 50 bonus points free of charge, as a welcome in the Travel Free Exclusive Club Card Program.
For every 300 accumulated points, Participants will be granted a EUR 10 discount voucher (the equivalent value in lei shall be calculated based on the BNR* rate of exchange valid on the day when the voucher is used, as listed at the cash registers). The voucher shall be valid as of the day following the issuance and may be used for 2 months, in any Travel Free store in Romania. Upon utilisation, the voucher (printed or digital, on the mobile) shall be presented by the Participants to the Organiser’s staff in the Travel Free store, for scanning at the cash register, together with the Travel Free Card. Each granted voucher may be used once, within the set deadline. The Participant is directly responsible for keeping the voucher in optimal conditions for use. In case of loss or damage of the voucher, its collection can only be done from the account created on our website http://travel-free.ro . Registration on the website is based on the card series and the date of birth, but an e-mail address is also required in order to set the password. If on the initial registration form an e-mail address has not been filled in, the Participant has the option to fill in an update form to provide the e-mail address. On the website account are available information regarding vouchers and balance points.
Discount vouchers awarded to Participants as part of the Travel Free Exclusive Club Card Program may not be exchanged for money, products or services. Discount vouchers awarded to Participants as part of the loyalty program may not be used to purchase tobacco products.
Each year, if 12 months have elapsed since the Participant's entry into the Travel Free Exclusive Club Card program, the Participant receives 50 bonus points. Also the Participants shall be awarded 50 bonus points on their birth day and 20 loyalty points – free of charge – in exchange for their consent to receive personalised information by e-mail.
Participants in the Travel Free Exclusive Club Card loyalty program may also benefit from the following: up to 30% off for the selected products, the possibility to accumulate double or triple points for the selected products, personalised offers throughout the year, as per the Organiser’s marketing policy. Unused points accumulated by one card holder expire in twelve months.
Each participant is entitled to one Travel Free loyalty card. Forgery of any card shall be punished under the current Laws.
The balance of accumulated points may be checked in person, at the Travel Free stores, and online by accessing https://www.travel-free.ro, and filling out the card series and birth date to create an account.
If Participants should return the purchased goods for which they accumulate points on the Travel Free card, the Organiser shall cancel the number of points previously awarded for the purchase of returned goods. If participants should wish to return products purchased based on a discount voucher granted under the Travel Free Exclusive Club card loyalty program, they may only do so in the case of products with hidden flaws. No returns shall be accepted in the case of products in perfect state with no hidden flaws upon purchase. The return referred to in the aforementioned rule implies two situations:
- Participants wish to make a full return (of all products indicated in the receipt) – in this case, the participant will be returned the whole amount of cash paid on the initial purchase, and they will be issued another voucher. If full return should be made as part of several partial returns, the cash spread between the equivalent value of the product on purchase and the value of the used voucher shall be paid to the participants on the last partial return, and a new voucher shall be issued on the completion of the return, insofar as the value of the returned product is higher than that of the voucher. If the returned product costs less than the amount granted under the voucher, participants shall be returned the equivalent value of the product as on purchase, and no further vouchers shall be issued to the same.
- Participants wish to make a partial return (of one or all products indicated in the receipt) – in this case, the client will be returned the whole equivalent amount of the product(s) paid for on the time of purchase.
The Travel Free loyalty card is not a payment instrument. Holders may not purchase products or services based on this card, they may only benefit from the advantages granted by Heinrig Impex SRL Filiala Bucureşti.
The Organiser reserves the right to check the accuracy of the information provided by participants on the Registration Forms for joining the Travel Free Exclusive Club Card loyalty program upon signing the Registration Form.
7. UTILISATION OF THE TRAVEL FREE LOYALTY CARD
Utilisation of the Travel Free loyalty card may only be done by its holder, otherwise, the holder takes the whole liability for any issue which may occur in relation to the Travel Free Exclusive Club Card loyalty program benefits. In order for them to benefit from the Travel Free Exclusive Club Card loyalty program, upon purchase, the Travel Free loyalty card holders need to hand over their cards to the Travel Free store employee, who will return the card after scanning it with the help of the bar code reader. Upon scanning, the Organiser’s employee will be able to read the name and surnames of the card holders, for the purpose of identifying the card holder.
Cards will be automatically supplied with the points afferent to the respective purchase, pursuant to these Regulations.
The system is consolidated and it includes all Travel Free stores in Romania, so that all points earned in any Travel Free store shall be aggregated in the same Participant account as part of the Travel Free Exclusive Club Card loyalty program.
8. DEACTIVATION OF THE TRAVEL FREE LOYALTY CARD
Deactivation of the Travel Free card may be carried out only in the following cases:
- On the express request of the Card Holder for the card to be deactivated, by signed and dated request sent to the Organiser’s office or at email@example.com. Deactivation shall be carried out within 30 days as of receipt of the request by the Organiser.
- On the express request of the Card Holder for personal data to be erased from the Organiser’s database or to not be processed. The signed and dated request sent to the Organiser’s office or at firstname.lastname@example.org. Deactivation shall be carried out within 30 days as of receipt of the request by the Organiser.
- If Participants does not purchase any product or service from any Travel Free store for a consecutive 12-month period. The respective Participants shall lose all points accumulated in their account, as well as any other benefits arising out of their capacity as holders of the Travel Free loyalty card, respectively.
- In case of fraud, attempted fraud or improper use of the loyalty program.
If the card is deactivated, Participants lose all points accumulated in their account, as well as any other benefits generated by their capacity as holders of the Travel Free loyalty card, respectively.
After cancellation, the card will not be reactivated, but the card holders may request that a new Travel Free loyalty card be issued by filling out a Registration Form.
9. REPLACEMENT OF THE TRAVEL FREE CARD
Is allowed when the card is damaged, lost or stolen. To this end, the Travel Free card holders are asked to resort to the help of Travel Free Romania store employees. The holders of damaged, stolen or lost cards shall fill out and sign a card Replacement Form. In this case, participants are entitled to a new card being issued. Card replacement shall be done promptly, based on a Replacement Form being completed. The points already accumulated before the damaging, the theft or loss of the card shall be transferred to the new Travel Free card.
The first replacement of the card is free of charge. In the event that the replaced card is declared damaged, stolen or lost, 10 points will be withdrawn/charged for its replacement from all points accumulated by the cardholder.
If the replacement request is made during non-business days, the card holder shall be issued a new card, and the points afferent to purchases made before the assignment of the new card shall be transferred to the client’s account on the first business day.
The Organiser is entitled to check if card replacement or the issuance of a new card is justified and possibly decline that a new card be issued.
Heinrig Impex SRL Filiala Bucureşti is exempted from any liability related to all consequences, either direct or indirect, of potential malfunctions of the loyalty program. Heinrig Impex SRL Filiala Bucureşti will, however, do its best to keep its members in case of such malfunctions, so that such can benefit from the points accumulated until the respective time. No member may file any legal or extra judicial proceedings against Heinrig Impex SRL Filiala Bucureşti for any reason related to their participation in the Travel Free Exclusive Club Card program.
Legal obligations and defence in court
We may be required to use and keep personal data for legal and compliance reasons, such as the prevention, identification or investigation of a crime, the prevention of losses, of fraud or any other abuse on our services and computer systems. We may also use your data for the purpose of internal and external audits, for the security of data or to protect our rights, confidentiality, safety, ownership or the rights of other persons.
The exchange of personal data and their disclosure to third parties
Collected data may be disclosed to third parties under strict confidentiality conditions, for the purpose set out in these Regulations, or for the granting of benefits.
Suppliers of external services
If required, we shall employ other companies and natural persons to carry out certain tasks contributing to the performance of our services on our behalf, as part of data processing agreements. We may, for instance, provide personal data to agents, contractors or partners authorised to host our databases, to provide data processing services, or to send you the requested data.
We shall share or allow access to such data ONLY to external service suppliers, as required for our services to be supplied. Such data may not be used by external service suppliers for other purposes than those they are especially appointed by the Heinrig Impex SRL Filiala Bucureşti to fulfil. Heinrig Impex SRL Filiala Bucureşti external service suppliers are contractually bound to keep the confidentiality of personal data.
In relation to any reorganisation, restructuring, merger, sale or other transfer of assets (hereinafter collectively called “Business Transfer“), we will transfer information, including personal data, at a reasonable scale and as required for the purpose of the Business Transfer and provided that the recipient agree to observe your personal data under the current data protection laws.
We will disclose your personal data to public bodies only insofar as this is required by the law. For instance, Heinrig Impex SRL Filiala Bucureşti will meet the court requests, as well as those of law enforcement authorities, regulatory agencies and other public and governmental authorities, which may include foreign counterpart authorities (outside the country of residence).
The processing of children’s personal data
The Heinrig Impex SRL Filiala Bucureşti company does not collect minor children’s personal data for the purpose of processing for recruitment to the Travel Free Exclusive Club Card loyalty program.
Data management and security
To Heinrig Impex SRL Filiala Bucureşti, data security is a serious matter. We apply an adequate security level and, therefore, we implemented reasonable physical, electronic and administrative procedures to protect the collected data from accidental or illegal destruction, from loss, amendment, unauthorised disclosure or the accessing of personal data sent, stored or otherwise processed. Our data security policies and procedures are strictly aligned to the widely accepted international standards and are regularly revised and updated, as required to meet our business needs, technological changes, as well as the regulated requirements. Access to personal data is granted by Heinrig Impex SRL Filiala Bucureşti employees solely on your request.
In the case of any personal data security breach, Heinrig Impex SRL Filiala Bucureşti shall observe all current data breach notification laws.
All third-party suppliers involved shall be contractually bound to keep data confidentiality and utilise them solely for the purpose for which they are held.
Data storage: How long do we keep your personal data for?
We generally erase your personal data when they are no longer required for the purposes for which they are originally collected. However, we might be requested to keep personal data for a longer time, as per the legal requirements. We will store the loyalty program data during the performance of the Travel Free Exclusive Club Card program.
Information on your legal rights and contacts for any additional questions
If you have any questions concerning the protection of confidentiality or you wish to exercise any of your legal rights as set below, please contact us by email at email@example.com.
Your legal rights
As a data subject, you have specific legal rights related to the personal data we collect from you. Heinrig Impex SRL Filiala Bucureşti shall comply with your individual rights and shall manage your concerns appropriately.
The following is a list of your legal rights arising out of the data protection current laws:
● The right to rectification: You can have us rectify your personal data. We make reasonable efforts to keep personal data used on an ongoing basis, which we hold and control, accurate, complete, current and relevant, based on the latest data we have available.
● The right to restriction: You can restrict our processing of personal data as follows:
- by challenging the accuracy of your personal data during the time when we need to check accuracy,
- processing is illegal and you request that processing of data be restricted rather than data be deleted; we no longer need your personal data, but you request them to ascertain, exercise or defend a right, or you object to the processing during the time when we perform their checking, insofar as our legitimate reasons prevail over yours.
● The right of access: You can request us information about the personal data we hold which concern you, including information on the personal data categories we hold or control, the purpose of their use, their source, if we collected them from you directly and to whom they have been disclosed, if applicable. You can get a copy from us, free of charge, including the personal data we hold which concern you. We reserve the right to charge a reasonable fee for each additional copy you might request.
Str. Sabinelor nr. 104A, Cod Postal 050854, Sector 5, Bucharest, Romania, Tel: + 0214014 100, E-mail: firstname.lastname@example.org
● The right to portability: Upon request, we will transfer personal data to another controller, where technically possible, provided that processing be based on your consent or be necessary to carry out a contract. Instead of receiving a copy of your personal data, you may request that we transfer your data directly to another controller you specify.
● The right to deletion: you may have us delete your personal data as follows:
- your personal data are no longer required for the purposes for which they were collected or they are differently processed;
- you have the right to oppose the subsequent processing of your personal data (see below) and to exercise this right to object processing;
- personal data have been illegally processed;
- for the purpose of meeting a legal obligation which requires our processing;
- particularly for the purpose of legal requirements for the keeping of data;
- to ascertain, exercise or defend a right.
Except when processing is required.
● The right to object: You may object to the processing of personal data at any time. Upon objecting to the processing of data, please specify if you would like your personal data to be deleted or you wish to have our processing thereof restricted.
● The right to file a complaint: In the case of any alleged breach of the legislation in force on confidentiality, you may file a complaint with the data protection supervisory authority in your country of residence or where the alleged breach occurred. The Romanian authority for this purpose is the National Supervisory Authority for Personal Data Processing.
Please remember the following:
● The time period: We will do our best to solve your request within 30 days. However, the time period may be extended for specific reasons concerning the specific legal right or the complexity of the request, in which case we will inform you on the delay reasons as well.
● Access restriction: In certain situations, we may find it impossible to give you access to all or part of the personal data as a result of legal provisions to this end. Should we decline your access request, we will inform you on the reason substantiating our refusal.
● Impossibility to identify: In some cases, we may find it impossible to look for your personal data, as a result of the identification details provided in your request. One instance of personal data we may not be able to look up for you when you give us your name and e-mail address is represented by the data collected from public social media websites, provided under a penname we do not know.
In such cases where we cannot identify you as the data subject, we are not able to act on your request to implement your legal rights as shown in this section unless you provide us with additional information making your identification possible.
● Exercise your legal rights: In order for you to be able to exercise your legal rights concerning confidentiality, please contact the assistance office on any confidentiality issues, in writing, i.e., by e-mail or by filing a letter. You may also go directly to our person in charge of data protection. For any contact information, please check the end part of this Confidentiality Policy.
Person in Charge of Data Protection:
* BNR: National Bank of Romania