GTM - Global Travel Management SRL (hereinafter referred to as the Company, the agency, GTM or AnyFlight) is a legal entity established under Romanian law and the operator of the website www.AnyFlight.com.
Registration number at the Trade Register: J22/3028/26.09.2017
Fiscal code: 38269678
Registered office: Municipiul Iasi, Soseaua Stefan Cel Mare si Sfant, Nr. 4, parter, Bloc A17/ 4, Judet Iasi, Romania.
GTM appreciates your visit to our website and mobile applications (together referred to as "ONLINE OFFERS") and your interest in our company and products.
These Terms and Conditions represent an agreement between you (as a website user or customer) and GTM - Global Travel Management S.R.L., as operator of the www.AnyFlight.com website. These are the conditions in accordance with European and Romanian law, under which GTM - Global Travel Management S.R.L. provides information, software and services on www.AnyFlight.com. AnyFlight services are offered only in cases where the consumer has accepted these Terms of Use.
The protection of privacy during the processing of personal data as well as the security of all business data is an important concern for us. We maintain the confidentiality of personal data collected during your visit to ONLINE OFFERS and process it only in accordance with legal regulations.
Data protection and information security are included in our corporate policy.
Airline Ticket: the passenger transport contract between the air carrier and the passenger, mediated by GTM and for which payment has been processed by the passenger and a ticket number issued;
Reservation: request from the passenger to GTM to mediate the contract with the air carrier and for which a ticket number has not necessarily been issued, i.e. payment has not been processed by the passenger;
Airline: air carrier that is IATA accredited;
Low Cost Carrier: air carrier which is not IATA accredited;
IATA: International Air Transport Association;
Easy connection: combinations of flights operated by different airlines and issued on different tickets and offering the most advantageous price and travel time option.
Carrier: the operator of the passenger transport service by air or land, which provides the service to the final beneficiary and collects the amount of the service provided.
TSF: Transaction Service Fee / Ticket Service Fee - service charge on transactions carried out in order to purchase a travel ticket;
Tourism Service Provider: participant in the process of offering tourism services to the consumer through and represented by the GTM
Consumer/User/Customer/Passenger: natural or legal person who purchases tourist products or services from AnyFlight for personal purposes.
Total Price: the final price for the tourist service or product purchased on AnyFlight, including all taxes.
Cancelled Flight: failure to fly as originally scheduled, at the decision of the airline operator, with or without notifying the passenger of this decision.
Modified Flight: substitution of the originally scheduled flight by changing the departure time, point of origin or destination, travel date, itinerary by adding or excluding connections.
Additional services: any service not included in the basic airfare, but which is available for booking at the passenger's request and for an additional fee which varies according to the air carrier's fare schedule.
Agency operator: the AnyFlight representative who advises GTM customers on the best solution for each request.
Voluntary change of ticket: change of itinerary, date of travel, flight number, fare class, at the passenger's request and with the acceptance of the change fee.
Voluntary ticket cancellation: cancellation of flight segments with a ticket issued at the passenger's request and with acceptance of the fare conditions and penalties set by the operating airline.
Check-in: check-in procedure for the flight for which the passenger has a ticket, valid for both scheduled and low-cost airlines.
2.1. The Terms of Use are binding for all AnyFlight customers and users. By clicking on the "I have read and agree to the Terms of Use" box, the customer agrees, fully accepts and undertakes to act in accordance with this policy established by GTM through the Terms and Conditions section, in accordance with the legislation in force.
2.2 If you do not fully agree to these Terms and Conditions you may not use this Site in any way or order services or products of AnyFlight.
For air tickets, reservations cannot be made without payment being recorded in the GTM account, therefore AnyFlight does not guarantee that you will reserve the seats and fares communicated at the time of the reservation request. These will only be guaranteed after the flight tickets are issued.
Please note: between the time you make your booking request on the website or by telephone and the time your flight tickets are paid for and the payment is viewed by AnyFlight's employees on your AnyFlight account, changes in fares may occur or seats may no longer be available for reasons beyond AnyFlight's control. In these situations, AnyFlight will notify passengers and communicate the next fare or propose new flight options that meet their needs.
The service charge is the amount you have to pay to the tourism service provider, in this case GTM, for services that are usually not offered directly by the flight operators, such as:
- Information and support for passengers in case of changes or modifications that may occur in the processing of the reservation or in the flight itself;
- Individual advice and assistance to each customer on preferred payment methods;
- Mediate discussions between the passenger, the flight operator and the airport;
- Covering the costs of issuing the flight ticket;
- Assistance in situations such as: change of flight, reimbursement of costs for an unused flight ticket.
Service charges applied by AnyFlight are not included in the airfare and may vary from offer to offer. AnyFlight reserves the right to decide which service fees it applies. For additional services (including, but not limited to: baggage, preferential seating, sports equipment, pets, special assistance service, etc.), purchased with or after the issuance of the air tickets, AnyFlight reserves the right to apply a service charge.
In the event of cancellation of air tickets/tour services (by the Consumer or the Travel Service Provider/Airline/Hotel etc.), the service charge levied by AnyFlight at the time of ticket issuance or sale of any tour services is non-refundable.
Force majeure" means unforeseeable events caused by natural phenomena: earthquakes, landslides, fires, droughts, strong winds, heavy rain, floods, frost, snow, etc. or by economic or social circumstances: revolution, belligerent state, blockade, strike, bankruptcy, state import or export ban, epidemic, etc. The list of such phenomena and circumstances is not exhaustive. The event can only be recognised as force majeure if its existence has objectively led to the impossibility of fulfilling contractual obligations or to their non-fulfilment.
The non-performance of the obligation is not attributable to the debtor if it is due to force majeure, if the occurrence or effects of the force majeure could not have been known to the debtor at the time the obligation arose or if the debtor could not prevent or remove the occurrence of the force majeure or its consequences.
6.1 By means of the website www.AnyFlight.com and/or specialized software, the company GTM - Global Travel Management S.R.L. and its partners offer a dynamic online database for booking and payment of air tickets, with the help of which, when the customer makes a query using a special search form, all available flight options and their prices at the time of the query can be displayed on the website. By completing the booking form, provided by the AnyFlight website and/or the specialised software, the customer books a flight option.
6.2 The information provided on our website at the time of the customer's enquiry regarding flight options and their prices is information from the airlines operating the requested routes.
6.3 Through this website we offer an online platform through which all types of temporary accommodation (e.g. hotels, motels, hostels and B&Bs, called ˝hotels/rooms˝) can promote their rooms for booking, and through which visitors to the website can make these bookings. By booking a room through AnyFlight, you enter into a direct contractual (legally binding) relationship with the accommodation establishment where you make your reservation. From the moment you make the booking, AnyFlight acts solely as an intermediary between the User and the accommodation establishment, forwarding the User's booking details to the relevant accommodation establishment and sending the User a confirmation email for and on behalf of the accommodation establishment.
6.4 Each Supplier remains responsible at all times for the accuracy, completeness and correctness of the (descriptive) information (including prices and availability) presented on our website. Our website does not constitute and should not be regarded as a recommendation or endorsement of the quality, level of service or rating of any accommodation that is available.
6.5 GTM's services are available for personal and non-commercial use only. Therefore, the user is not permitted to resell, use, copy, monitor, display, save or reproduce any content or information, software, products or services available on the AnyFlight.net website for any commercial or competitive activity or purpose.
6.6 Our website is not and should not be construed as a recommendation or guarantee for the benefit (quality, service level or rating) of any proposed flight option.
6.7 For each specific query, at each specific moment in time, the dynamic database forms a variant of the current tourist services at the time of the query, and which corresponds to the actual availability of the services according to the criteria requested by the user/customer.
6.8 Any reservation made on AnyFlight.net will be considered as the User's intention to purchase a specific tourist product or service from the Tourist Service Provider. If the user/customer's request is accepted, AnyFlight will send a confirmation email.
6.9 All tourist services published on the website and/or through the AnyFlight.net software are subject to the availability of the Tourist Service Providers. The terms and conditions of the Tour Service Provider (including the rules of carriage of passengers imposed by airlines) will apply in addition to the Terms and Conditions stipulated by AnyFlight.
6.10 The Tour Supplier's Terms may include provisions relating to various payment procedures, obligations, cancellations, changes to bookings and refunds (if applicable) or other restrictions. Some airlines may impose additional charges. AnyFlight is not responsible for costs that may arise when transferring from one airport to another or from one terminal to another.
6.11 AnyFlight is not responsible for the collection of various local, additional charges by some hotels.
6.12 The consumer is directly responsible for complying with the conditions imposed by the Travel Service Provider regarding boarding times, flight reconfirmation or any other rules.
7.1 Seat reservations for flights are made using international computerised reservation systems, which allow access to the airline's database and the actual reservation of seats for a specific flight for potential passengers.
7.2 Reservations may or may not be free of charge, depending on the options offered by each airline, and are made before the departure date. The duration of the flight option booking varies depending on the limit set by the airline or airlines operating the flights in the flight option booked. The reservation period may be changed at any time by the airline or airlines operating the flights of the booked flight option without prior notification to the airline.7.3 Upon making the reservation, the passenger will receive information on the price of the flight (valid at the time of reservation), as well as information on the conditions and rules applicable to the flight ticket that may be purchased under that reservation.
7.4 All conditions, rules and restrictions applicable to an air ticket are those dictated by the airline as well as other factors (e.g. visa requirements) beyond AnyFlight's control. These rules, as well as the price of the air ticket, may be changed, at the will of those who imposed them, up to the time of the actual purchase of the ticket, without AnyFlight being responsible for this. The price of the air ticket for certain flight options may change during the ticketing process. If there is such a likelihood of an increase after the customer has paid for the flight option, the customer will be notified before the ticket is issued. If the flight options become more expensive after payment, the passenger will be offered the possibility to pay the difference in the process of issuing the flight options, or will be refunded the full amount paid, by the same payment method by which the payment was made. AnyFlight is not responsible for any increase in the price of the flight tickets in the process of issuance even after payment for this purpose by the customer.
7.5 The presentation at the customer's request on the website www.AnyFlight.net of the flight variants represents an offer to the customer to pay for a variant offer and represents confirmation of the passenger's agreement to enter into the contract of sale of air tickets with AnyFlight and the contract of carriage of passengers and baggage with the airline. As soon as the passenger receives the air ticket according to the offer selected and paid for by the customer, the contract of sale of air tickets between the passenger and AnyFlight and the contract of carriage between the airline and the passenger shall be considered concluded. The route itinerary, sent to the e-mail address indicated by the customer at the time of selection and payment for the flight, is the document of passage, which confirms the conclusion of the contract of sale of air tickets and the contract of carriage.
7.6 By paying for the ticket, the customer confirms that he/she understands that he/she is entering into a contract of carriage and is entering into a direct legal relationship with the carrier. By paying for the ticket, the Customer also accepts that in the event of any claims/claims arising in connection with the transport services, he/she shall submit them directly to the transport company, including in the event of its insolvency (bankruptcy). GTM is not a guarantor or representative of the transport company.
7.7 At the time of booking a flight, the user has the possibility to enter the details of the frequent flyer card if he/she is already enrolled in such a programme of an airline; these frequent flyer programmes are subject to the terms and conditions imposed by the airline with which he/she is enrolled as a user/customer.
7.8 The prices of air tickets sold on AnyFlight are the result of a complex system of fare rules, contractual fares, fares published in centralised reservation systems, special fares, AnyFlight service fares, etc. Under these conditions, each individual flight involves the calculation of the price applicable to the air ticket in question. The same flight with the same airline may generate different prices on other platforms.
7.9 Some fares or special offers cannot be cancelled or modified. The user is obliged to check the rules of the fare for the air ticket booked before booking the ticket.
7.10 Payment of the air ticket means that the user/passenger has taken note of all the conditions of the fare and agrees to them.
7.11 The air ticket is the document, writing or electronic agreement on the basis of which the flight is performed. The flight ticket is issued by GTM but is the property of the airline to which it is issued.
7.12 The passenger in possession of the purchased air ticket is obliged to keep it in good condition and to present it for boarding in order to be admitted to the flight. The loss or damage of the flight ticket by the passenger does not entitle him/her to receive a new ticket, the non-operation of the flight for this reason being the sole responsibility of the passenger, without the passenger being entitled to claim any compensation from GTM or the airline.
7.13 The conditions of the contract and the information on the air ticket supplement these general conditions. The passenger who has taken possession of the air ticket shall be deemed to have read all this information.
7.14 The customer/passenger shall comply with the boarding terms (before departure) recommended by the airlines. This is usually 120 minutes for international flights and 90 minutes for domestic flights.
7.15 Some airlines require reconfirmation of the flight at least 72 hours before departure, the Passenger being directly responsible for reconfirming or not the flight, GTM being exonerated from any fault in this respect. Failure to comply with this rule may result in cancellation of the flight reservation. The flight ticket coupons must be used in consecutive order. In the event of non-compliance with this provision, the airline reserves the right to cancel the ticket in question.
7.16 AnyFlight is not liable and cannot be claimed compensation for the passenger not having flown if the passenger is in one of the following situations:
- the passenger did not present himself on time for boarding (at least 120 min before the departure time indicated on the ticket or the time indicated by the airline in each case);
- the passenger is denied boarding because of problems with his/her travel documents (including lack of entry visa for the country of destination, false visa, passport ban, etc.) or in the event of an unjustified refusal by the authorities to allow travel;
- other circumstances or force majeure which AnyFlight could not foresee or avoid.
7.17. GTM is not liable for cancellations, delays or schedule changes of the airline for which the ticket has been issued, for the quality of the flight or for flight-related services (e.g. loss of luggage), which are the direct responsibility of the airline. GTM, in accordance with the Warsaw International Conventions, is subject to the claims of the airlines. In such situations, the passenger will apply directly to the carrier, which will compensate the passenger in accordance with international regulations.
7.18. The passenger may cancel the purchased ticket at any time before the departure date. Regardless of the reason for the cancellation, with the return policy applying in accordance with the rules imposed by the airlines. As a rule, a penalty of 100% of the ticket value including taxes and FST + EUR 10 FST cancellation fee is applied. If airline rules allow for more favourable return conditions, AnyFlight will apply these rules in favour of the passenger without affecting the retention of TSF and cancellation TSF.
7.19. The passenger may change the original ticket purchased under the conditions set by the airline for which the ticket was issued, on a case-by-case basis, by paying an additional fee set by the airline, usually with the application of a penalty of 100% of the value of the ticket including taxes and GST + EUR 10 cancellation GST. If the airline rules allow for more advantageous return conditions, AnyFlight will apply these rules in favour of the passenger without affecting the retention of the TSF and TSF cancellation fee.
7.20. The passenger cannot use only component parts of the flight related to the purchased ticket. The passenger's failure to appear for the first flight shall be considered as a waiver of the ticket and the provisions of these General Conditions shall apply.
7.21. The passenger may not transfer the flight ticket to a third party.
7.22. Non-attendance on the flight will normally entail the loss of the ticket, with a penalty of 100% of the ticket price.
7.23. It is the passenger's responsibility to ensure that he/she is in order with regard to all the formalities required for the journey (police, customs, health, passport, visa, etc.), AnyFlight having no liability to the passenger in this respect. Denial of boarding for any of these or similar reasons is the sole responsibility of the passenger, who may not claim any compensation from GTM.
7.24. Because of the situation created by the massive applications for political asylum or illegal stays in Western countries, the authorities of all states, even with the presence of the entry visa issued by the embassies of the countries concerned, can refuse without explanation to cross the border or to allow the passenger to board the plane. In such cases, no compensation can be claimed from GTM, since the impossibility of transport is due to the action of a third party.
8.1. In response to the query filled in by the customer/user in the search form on the AnyFlight.net website or via the related software, all the tourist service options that were queried and accessible at the time of the query and the prices valid at the time of the respective request are displayed.
8.2. Some tariffs or special offers cannot be cancelled or modified. The Client/User shall check the specific rules of the tariff of the booked tourist services, assuming the present provisions of the Terms and Conditions when booking a service.
8.3. For payment by bank card directly on the website, AnyFlight will charge the amount for the ticket as follows:
- In Euro currency, regardless of the base currency of the payer's card.
In addition, in order to minimise the effects of attempted bank card fraud, before issuing travel documents, AnyFlight reserves the right to carry out random checks: to ask for proof of the user's address, a photo of the card with which payment is being made, a photo of an identity document of the person holding the card in question, and a recent bank statement. All rates and fees may fluctuate due to changes in exchange rates.
8.4. The prices of the services marketed through AnyFlight are the result of a complex system of tariff rules, contractual tariffs, tariffs published in centralised reservation systems, special tariffs, AnyFlight's service fee, etc. Under these circumstances, each individual tourist product involves the calculation of the price applicable to the respective service. The same service, with the same supplier, company can generate different prices. Given the multitude of prices applicable to tourist services, these, as well as the rules applicable to them, cannot be displayed or published.
8.5. The price of any service implies special conditions, rules and restrictions applicable to that service. The Customer/User/Passenger is obliged to inform himself/herself about these rules before purchasing the product. After purchasing the service, the Customer/User/Passenger is deemed to be aware of all these rules and can no longer claim not to have been informed.
8.6. If the Client/User/Passenger pays for the flight ticket in cash at the Partner Agency's office, the payment shall be made in RON or EUR, at the exchange rate of the National Bank of Romania +2% against USD or another currency to which the airline fares are linked.
8.7. We do not accept any other means of payment other than those presented on the Website and we do not assume any responsibility for money sent by courier.
8.8. For the specific activity, the GTM agency applies a service fee policy, called TSF (Ticket Service Fee or Transaction Service Fee). TSFs are non-refundable in case of cancellation or change of ticket by the customer.
8.9. GTM or the Service Provider reserves the right to additionally charge any fees (or Commissions) that may apply at the time of booking by credit card. In this case you will be informed of the applicable fees.
9.1. These Rules and the provision of our services are governed by Romanian law, the Rules of the International Air Transport Association (IATA) and the Warsaw Convention.
9.2. The display by GTM of these General Conditions implies the obligation of the Client/User to read them. The User/Customer/Passenger who has purchased the tourist service from GTM is deemed to have taken cognisance of the contents of these conditions and may not subsequently invoke ignorance or lack of information.
9.3. Unless otherwise agreed, the information and any computer programs, software, necessary for the provision of GTM services and used on the website and the copyright and economic rights thereto as intellectual property belong to GTM or its suppliers.
9.4. All disputes, arising in connection with these Rules, the contract of sale of air tickets, the contract of carriage and the provision of our services, shall be settled by negotiation or in the competent courts of Romania, unless otherwise provided by law.
9.5. According to the limitations, set forth in these Rules for the provision of services, GTM is liable only for direct damages, caused actually or as a result of the actual non-performance of our obligations in the framework of the provision of services by us and only within the limit of the commission received from the respective Service Provider.
9.6 If any provision or part of these Conditions is declared invalid, the remaining provisions shall continue to have effect.
9.7. If complaints arise in connection with the non-performance or improper performance of the obligations of GTM as set forth in these Terms and Conditions, they shall be settled on the basis of negotiations or in the order of claims. Any complaint regarding the purchased service shall be made in writing within a maximum of 7 days from the date of the occurrence of the complained event. The deadline for responding to the claim is 30 calendar days.
9.8. All disputes arising in connection with these Terms and Conditions and the provision of our services shall be settled in the competent courts of Romania.
GTM is the controller responsible for processing your data; exceptions are outlined in this data protection notice.
Collection, processing and use of personal data
Categories of data processed
The following categories of data are processed:
Customer's first and last name;
Customer identification data meaning identification number and series, personal numerical code;
E-mail address;
Telephone number;
Delivery address;
Billing address;
Bank account number;
Transaction data relating to the payment made by the customer;
We also inform you that we also process necessary personal data:
Communication between GTM and the customer, as well as for the reservation of services requested by accessing our platform.
Behaviour records on websites operated by GTM.
Principles
Personal data is any information relating to an identified or identifiable person and includes, for example, names, addresses, telephone numbers, e-mail addresses, contractual master data, information about the payment made by you, which is an expression of a person's identity.
We collect, process and use personal data (including IP addresses) only when there is a legal basis for doing so or you have given your consent to the processing or use of personal data in relation to this matter, for example, through registration on the website operated by GTM.
Data processing purposes and legal basis
We and the service providers engaged by us process personal data for the following purposes:
Providing these Online Offers (our websites and on mobile apps).
Legal basis: justified interest on our part for direct marketing, insofar as this takes place in accordance with data protection and competition law.
Providing these Online Offers and executing a contract on the terms offered by us
Legal basis: performance of a contract.
Determination of disruptions/disruptions and for security reasons.
Legal basis: fulfilment of legal obligations to ensure data security and justified interest in the resolution of disruptions/disruptions and the security of our offers.
Self-promotion and promotion by other operators, as well as market research and analysis within the legally permitted scope
Legal basis: justified interest on our part in direct marketing, to the extent that this takes place in accordance with data protection and competition law
Customer surveys or product surveys conducted by mail, email and/or telephone
Legal basis: our justified interest in improving our products/services; your consent.
Note: If we commission a market research institute to do this, that institute will only act on the basis of the assignment and will comply with our guidelines.
Sending an e-mail or SMS/MMS newsletter with the consent of the recipient.
Legal basis: your consent.
Securing and asserting our rights.
Legal basis: justified interest on our part in securing and asserting our rights.
Registration
If you want to use/access benefits that require a contract, you must register. In order to register we collect personal data necessary for the conclusion and execution of the contract (e.g. first name, last name, date of birth, e-mail address, if applicable, data on preferred payment method or account holder) as well as, if applicable, additional data on a voluntary basis. Mandatory fields are marked separately.
Log files
Every time you use the Internet, your browser transmits certain information that we store in so-called "log files".
Log files are only saved for a short period of time to determine disruptions, but also for security reasons (e.g. to clear up attempted attacks), and then deleted. Log files to be managed as evidence are excluded from the deletion rule, but only until the incident has been fully resolved, and may, depending on the individual case, even be passed on to the competent investigative authorities.
Log files are also used for analysis purposes (with or without the full IP address). See the Web Analysis module.
The following information in particular is stored in the log files:
The IP address (Internet Protocol address) of the terminal that is used to access the Online Offers;
The Internet address of the website from which the Online Offer was accessed (so-called source URL or referral URL);
Name of the service provider used to access the Online Offer;
Name of the files or information accessed;
Date and time as well as the duration of the retrieval;
Amount of data transferred;
Operating system and information about the internet browser used, including installed add-ons (e.g. Flash Player);
http status code (e.g. "Request was successful" or "File not found").
Data transfer
Transferring data to other controllers
Personal data is transferred to other controllers mainly only when necessary for the performance of a contract, if we or the third party has a legitimate interest in the transfer or if you have given your consent. Details of the lawful basis can be found in the section Processing purposes and lawful basis (Article 4.3). Where data is transferred to third parties on the basis of a legitimate interest, this is explained in this data protection notice.
In addition, data may be transferred to other controllers when we are obliged to do so under applicable legal regulations.
Service providers (general)
We have engaged external service providers for tasks such as sales and marketing services, contract management, payment management, scheduling, data hosting and courier services. We have carefully chosen these service providers and regularly evaluate them, particularly in terms of effective management and protection of stored data. All service providers are obliged to ensure confidentiality and comply with legal provisions.
Payment service providers
We use external payment service providers.
Depending on the type of payment method chosen during the order process, we transfer the data used for payment processing (e.g. bank account or credit card data) to the financial institution in charge of the payment or to payment service providers contracted by us. Sometimes payment service providers also collect and process such data as controllers. In this case, (payment service providers are data controllers) the data protection notice or privacy policy of the respective payment service provider applies.
Transfer to recipients outside the EEA
We may also transfer personal data to recipients outside the EEA, in so-called third countries. In such cases, before the transfer we ensure that the data recipient ensures an adequate level of data protection (e.g. as a result of an adequacy decision of the European Commission on that country or agreement with the recipient based on so-called EU model clauses) and that you have given your consent to such a transfer.
You have the right to receive an overview of third country recipients and a copy of the agreed specific provisions ensuring an adequate level of data protection, but only at your express written request. Use the information in the Contact section for this purpose.
Duration of storage of personal data
In accordance with applicable law, for the purposes of performing the contract and for the purposes of recording the contract and any future application, as well as for the protection of the rights and obligations of the parties, the storage and processing of personal data is carried out for a maximum period of 10 years after the last contract has been performed, unless otherwise provided by law for the maintenance of contractual documentation for a longer period (e.g. we are obliged to make documents such as contracts and invoices available for a certain period of time due to retention periods under applicable law).
Essentially, we store your data for as long as is necessary to provide our Online Offers and related services, as long as we have a justified interest in storing it.
The processing mentioned above is possible under Article 6(1)(b) of Regulation (EU) 2016/679 of the European Parliament and of the Council: 'processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract'. "
Use of cookies
General data
Cookies are small text files saved on your computer when you visit an Online Offer. If you access this Online Offer at another time, your browser will transmit the contents of the cookies to the respective provider, thus enabling the re-identification of your terminal. Reading cookies allows us to optimally configure the Online Offers, making them easier to use.
Disabling and deleting cookies
When you visit our web pages you will be asked in a pop-up window whether you agree to the use of cookies on our page or wish to disable them in your settings.
If you decide to block cookies, your browser has a blocking option. This cookie only serves to allocate your objection. Disabling cookies may disable individual functions of our web pages. Please note that, for technical reasons, a blocking cookie can only be set for the browser that was used to set it. If you delete cookies, if you use a different browser or terminal, you will have to block them again.
Preferences do not apply to cookies that are set during your visits to third party websites.
Your browser allows you to delete all cookies at any time. To do so, please consult the support functions of your browser. However, this may cause individual functions to become unavailable.
In addition, you can manage and disable third-party cookies on the following web page:
http://www.youronlinechoices.com/uk/your-ad-choices.
As we do not operate this website, we are not responsible for and cannot influence the content and availability.
Overview of cookies used by us
In this section you can find an overview of the cookies used by us.
Absolutely necessary cookies
Certain cookies are necessary to be able to securely provide our Online Offers. This category includes, for example:
Cookies that identify or authenticate our users;
Cookies that temporarily save certain information entered by the user;
Cookies that store certain user preferences (e.g. searches or language settings);
Cookies that store data to ensure unobstructed playback of video or audio content.
Analytical cookies
We use analytics cookies to record the usage behavior (e.g., banner ads accessed, searches performed) of our users and to evaluate it statistically.
Advertising cookies
We also use cookies for advertising purposes. The usage behaviour profiles created with such cookies (e.g. banners visited, subpages visited, searches performed) are used by us to show you advertisements or offers tailored to your interests ("interest-based advertising").
Conversion cookies
Our conversion tracking partners set a cookie on your computer ("conversion cookie") if you arrived at our website through an advertisement from that partner. These cookies generally expire after 30 days. If you visit certain pages that we host and the cookie has not yet expired, we and that conversion tracking partner may see that a particular user has accessed the advertisement and been directed to our page. The information collected through the conversion cookie is used to create conversion statistics and to determine the total number of users who have viewed that ad and been directed to a page with a conversion tracking tag.
Tracking cookies in association with social plugins
Certain pages of our Online Offers integrate content and services from other providers (e.g. Facebook, Twitter), which may in turn use cookies and active components. cannot influence the processing of personal data by these providers.
Web analytics
We need statistical information about the use of our Online Offerings in order to design them to be more user-friendly, to conduct broad measures and market research.
To do this, we use the web analytics tools described in this section.
The usage profiles created by these tools, using analytics cookies or analyzing log files, do not contain personal data. The tools either do not use IP addresses at all, or restrict them immediately when collecting data.
The tools provide processed data only to processors who obey our guidelines and not for their own purposes.
Below you can find information about what each tool offers and how you can refuse the collection and processing of data by that tool.
Please note that for tools that use blocking cookies, the blocking function affects a device or browser and is thus valid for the terminal or browser used at the time. If you use multiple devices or browsers, you must perform blocking on each device and browser.
Otherwise, you can generally avoid the formation of usage profiles by disabling the use of cookies; to do this, see the section Disabling and deleting cookies.
Google Analytics
Google Analytics is provided by Google Inc, 1600 Amphitheatre Parkway, Mountain View, CA 94043, U.S.A. ("Google") We use Google Analytics with the additional function provided by Google to anonymize IP addresses. At this time, Google already shortens IPs within the EU in most cases, but only does so in exceptional cases in the United States, and in both regions only saves the short form of IP addresses.
You can refuse the collection or processing of your data by using the following link to download and install a browser plugin: http://tools.google.com/dlpage/gaoptout?hl=en
Use of remarketing tools
In order to optimise our online marketing we use so-called remarketing technologies. This aims to create a more interesting Online Offer, tailored to your needs. To do this, we use the tools below.
Usage profiles created using advertising cookies or third-party advertising cookies, so-called web beacons (invisible graphical elements also called pixels or pixel counts) or comparable technologies that are not combined with personal data.
The tools are used by vendors to show our users online offers or advertisements based on their interests and to control the frequency with which users see certain advertisements. The person responsible for processing the data associated with the tools is the respective provider. Tool providers may, where appropriate, transfer information to third parties for the reasons mentioned above.
Tools either do not process users' IP addresses at all or restrict them immediately after data collection.
You can find information about a tool provider for each tool, as well as how you can refuse data collection by that tool.
Please note that for tools that use blocking cookies, the blocking function affects a device or browser and is thus valid for the terminal or browser used at the time. If you use multiple devices or browsers, you must perform blocking on each device and browser.
Google AdSense
Google AdSense is provided by Google Inc, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA ("Google").
You can refuse the collection and processing of your data by this tool by going to the user references.
DoubleClick
DoubleClick is provided by Google Inc, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA ("Google").
You can refuse the collection and processing of your data by this tool by accessing the user references.
Social plugins
In our Online Offerings we use so-called social plugins from various social networks; these are described individually in this section.
When using plugins, your browser establishes a direct connection to the servers of the respective social network. In this way, the respective provider receives information that your browser has accessed from the website of our Online Offers, even if you do not have a user account with this provider or are not logged into your account at the time. Log files (including IP addresses) are in this case transmitted directly from your browser to the respective provider and may be stored there. The provider or its servers may be located outside the EU or EEA (e.g. in the United States).
Plugins are individual extensions provided by social network providers. For this reason, we cannot influence the scope of data collected and stored by them.
You can find the purpose and scope of the social network's data collection, processing and continued use of data, as well as your rights and privacy setting options by consulting the data protection notices of the respective social network.
If you do not want social network providers to receive and, if applicable, store or use your data, you should not use those plugins.
By using the so-called two-click solution (provided by Heise Medien GmbH & Co. KG) we protect you against the implicit recording and processing of your visit to our websites by social network providers. When using a website of ours, which contains such plugins, they are initially deactivated. The plugins will only be activated when you click the button provided.
Facebook plugins
Facebook is operated at www.facebook.com by Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA and at www.facebook.de by Facebook Ireland Limited, Hanover Reach, 5-7 Hanover Quay, Dublin 2, Ireland ("Facebook"). You can find an overview of Facebook plugins and their layout here: http://developers.facebook.com/plugins; find information about data protection at Facebook here: http://www.facebook.com/policy.php.
Newsletter, with subscription option; right to withdraw consent
You can subscribe to newsletters about our Online Offers. For this, we use the so-called two-step subscription procedure, which means that we will only send you a newsletter via email, mobile messenger (e.g. WhatsApp), SMS or push notification after you have explicitly confirmed the activation of the newsletter service by clicking on the link in the notification. If at a later date you no longer wish to receive newsletters, you can unsubscribe at any time by withdrawing your consent. You can withdraw your consent for email newsletters by clicking on the link provided in the email for Online Offers, as applicable. This takes place within your administration settings. Alternatively, you can contact us using the contact details provided in the Contact section.
External links
Our Online Offers may include links to third party websites - providers that are not associated with us. Once you access the link, we have no influence on the collection, processing and use of personal data transmitted by accessing the link to the third party (such as IP address or URL of the site where the link is located), as we cannot, of course, monitor the behaviour of third parties. We assume no responsibility for the processing of such personal data by third parties.
We recommend that you read their privacy policies to see how your personal information is collected and processed.
Security
Our employees and companies providing services on our behalf are required to ensure confidentiality as well as compliance with applicable data protection laws.
We take all necessary technical and organisational measures to ensure an adequate level of security and to protect your data administered by us, in particular against the risks of destruction, manipulation, loss, illegal or unintentional modification or unauthorised disclosure or access. Security measures are constantly improved in line with technological progress.
User rights
To exercise your rights, please use the details provided in the Contact section. In this case, please ensure that it is possible to identify the person concerned precisely.
Right to information and access:
You have the right to obtain our confirmation of the processing or non-processing of your personal data, as well as access to this data.
Right to correction and deletion:
You have the right to rectify your personal data without undue delay. In view of the purpose of the processing, you have the right to complete incomplete personal data, including by providing an additional statement.
This does not apply to data required for billing and accounting purposes or which are subject to a legal retention period. If access to such data is not necessary, processing is restricted (see below).
Restriction of processing:
You have the right to request restriction of the processing of your data, but provided that the legal requirements requested in this case are met.
Refusal of data processing:
You have the right to refuse the processing of your data by us at any time. We will no longer process your personal data unless we can prove compliance with the legal requirements to provide justified reasons for further processing, beyond your interests, rights and freedoms or for the establishment, exercise or defence of legal claims.
Refusal of direct marketing:
In addition, you may at any time refuse the processing of personal data for direct marketing purposes. Please note that for organisational reasons there may be a temporary overlap between your refusal and the use of that data for the purposes of the campaign already in progress.
Refusal to process data on the legal basis of "justified interest":
In addition, you have the right to refuse the processing of personal data at any time, provided that the legal basis of justified interest is applicable. In this case, we will stop processing your personal data unless we can demonstrate compelling legitimate grounds, as required by law, for the processing that override your rights.
Withdrawal of consent:
If you have consented to the processing of your data, you have the right to withdraw your consent with immediate effect. The lawfulness of data processing prior to the withdrawal of consent remains unaffected.
Data portability:
You have the right to receive the data you have provided to us in a common, structured, software-readable format - if technically possible - for requesting the transfer of that data to a third party.
The right to lodge a complaint with the supervisory authority:
You have the right to lodge a complaint with a supervisory authority. You can appeal to the supervisory authority with jurisdiction in your place of residence or in your country or to the supervisory authority responsible in our case. See below:
National Supervisory Authority for Personal Data Processing
B-dul G-ral. Gheorghe Magheru 28-30
Sector 1, postal code 010336
Bucharest, Romania
Phone: +40.318.059.211; +40.318.059.212
Fax: +40.318.059.220
E-mail: [email protected]
Web: www.dataprotection.ro
Amendments to the Data Protection Notice
We reserve the right to change our security and data protection measures if necessary due to technical progress. In such cases, we will amend the Data Protection Notice accordingly. Therefore, please keep an eye on the current version of the Data Protection Notice as there may be changes.
Contact
If you would like to contact us, you can find us at: info (at) gtm.agency
To exercise your rights and for suggestions and complaints regarding the processing of your personal data, as well as to withdraw your consent, we recommend that you contact our Data Protection Commissioner at the following e-mail address:
gdpr (at) gtm.agency
If we decide to amend this notice to provide better protection of your rights and personal data, we will publish the new version here and it will replace the current version.
Thank you for trusting us with your personal data and for taking the time to read our notice on the processing of personal data. Please do not hesitate to contact us if you have any questions about your personal data and our processing of such data.
Effective date of these provisions: 20.07.2022