Respecting your privacy is one of our fundamental commitments, and therefore we pay the utmost attention to the processing of your personal data, in accordance with the applicable legislation.
TRAVLOCALS PROMO S.R.L., with its registered office at str. General Marin Ionescu, no. 15, room 2, Pitești, Argeș, Romania, fiscal identification code 40956886, registered with the Trade Register under no. J03/1121/2019 (“Travlocals”, the “Company”, “we”), processes, as a data controller, your personal data (“Personal Data”).
The purpose of this information notice (“Privacy Policy”) is to detail how Travlocals processes your Personal Data in the context of using the Travlocals platform available at www.travlocals.com (the “Platform”).
Terms written with capital letters and not defined in this Privacy Policy shall have the meaning set out in the Platform’s Terms and Conditions, which can be accessed here (“Terms”).
1. PERSONAL DATA PROCESSED, PURPOSES AND LEGAL GROUNDS
A. SITUATIONS APPLICABLE TO HOSTS
a. Processing a request to enroll on the Platform as a Host
Personal Data processed: first name, last name, email address, phone number.
Purpose of processing
Verification of Hosts by Travlocals for the purpose of accepting or rejecting their listing as a Host on the Platform.
Legal basis
Performance of a contract to which the data subject is a party or taking steps at the request of the data subject prior to entering into a contract (Art. 6(1)(b) GDPR).
b. Creation of the User Account for Hosts
Personal Data processed: first name, last name, email address, identity card data, image, bank account details.
Purpose of processing
Creation of the User Account.
Legal basis
Performance of a contract or taking steps prior to entering into a contract (Art. 6(1)(b) GDPR).
c. Creation of a Host Page
On our Platform, each Host presents their services through a dedicated web page. This page includes certain Personal Data of the Hosts (first name, last name, image), which will be publicly available on the Platform.
Purpose of processing
Creation of a Host Page and display of the Host’s accommodation services on the Platform.
Legal basis
Performance of a contract or taking steps prior to entering into a contract (Art. 6(1)(b) GDPR).
d. Issuing invoices
If the Host is a natural person, the following Personal Data will be processed: first name, last name, home address or personal identification number, payable amount, email address.
If the Host is a legal entity, the following Personal Data of the Host’s representative will be processed: first name, last name, email address.
Purpose of processing
Issuing invoices for the services provided by the Company.
Legal basis
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Performance of a contract (Art. 6(1)(b) GDPR);
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Compliance with a legal obligation (Art. 6(1)(c) GDPR).
Details: issuance of fiscal invoices.
B. SITUATIONS APPLICABLE TO CLIENTS
a. Creation of the User Account for Clients
Personal Data processed: first name, last name, phone number, email address, image, bank account details.
Purpose of processing
Creation of the User Account.
Legal basis
Performance of a contract or taking steps prior to entering into a contract (Art. 6(1)(b) GDPR).
b. Making a reservation by the Client
Personal Data processed: first name, last name, email address, phone number, image (profile picture).
This information will be transmitted to / available to the Host.
Purpose of processing
Making a reservation for the purpose of purchasing accommodation services from Hosts.
Legal basis
Performance of a contract or taking steps prior to entering into a contract (Art. 6(1)(b) GDPR).
C. SITUATIONS APPLICABLE TO HOSTS, CLIENTS AND OTHER USERS
a. Editing/completing the User Account
Users may edit the information in their Account. In this case, the edited Personal Data will be processed.
Purpose of processing
Updating the information included in the User Account.
Legal basis
Performance of a contract or taking steps prior to entering into a contract (Art. 6(1)(b) GDPR).
b. Publishing a review
Hosts and Clients may publish reviews regarding their interactions, the services provided by Hosts, or the behavior of Clients. These reviews (including Personal Data) will be public on the Platform.
Personal Data processed:
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regarding the user posting the review: first name, last name, username, image (profile picture);
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regarding the reviewed user: first name, last name, username, image, any information included in the review.
Purpose of processing
Informing other Users about a User’s behavior or the services offered by Hosts.
Legal basis
Legitimate interest of the Company or a third party (Art. 6(1)(f) GDPR).
Details: the Company’s legitimate interest in creating a safe, transparent and trustworthy Platform.
c. Payments made by Clients and transfer of amounts to Hosts
Personal Data processed: first name, last name, payable amount, bank details.
Purpose of processing
Collecting payments from Clients and transferring amounts to Hosts as payment for accommodation services.
Legal basis
-
Performance of a contract (Art. 6(1)(b) GDPR);
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Compliance with a legal obligation (Art. 6(1)(c) GDPR).
d. Direct communication between Clients and Hosts via chat
Personal Data processed: first name, last name, username, image (profile picture).
Purpose of processing
Providing a direct communication channel between Clients and Hosts regarding reservation details.
Legal basis
Performance of a contract (Art. 6(1)(b) GDPR).
e. Communication between Users and the Company
Personal Data processed: first name, last name, email address, phone number.
Purpose of processing
Communication with the User regarding requested offers or issue resolution.
Legal basis
Performance of a contract (Art. 6(1)(b) GDPR).
f. Contractual notifications
We will use your email address to notify you of changes to the Platform’s terms and conditions or other contract-related matters.
Legal basis
Performance of a contract (Art. 6(1)(b) GDPR).
g. Commercial messages (marketing)
Personal Data processed: first name, last name, email address.
Purpose of processing
Sending promotional messages regarding the Company’s services.
Legal basis
Consent of the data subject (Art. 6(1)(a) GDPR).
h. Dispute resolution
Personal Data processed: first name, last name, home address.
Purpose of processing
Defending legitimate rights and interests before courts or public authorities.
Legal basis
Legitimate interest of the Company (Art. 6(1)(f) GDPR).
2. PROVISION OF PERSONAL DATA
You may refuse to provide certain Personal Data; however, in such cases, you may not benefit from certain services described in this Privacy Policy.
3. LEGAL BASES
The legal basis for processing differs depending on the specific situation and the Personal Data processed.
Where processing is based on consent, such consent will be freely given, informed, specific and unambiguous.
4. AUTOMATED PROCESSING
Your Personal Data will not be processed for decisions based solely on automated processing as defined by Art. 22(1) GDPR.
5. DATA RETENTION PERIOD
Personal Data is generally retained for the duration of the User Account.
Data processed based on consent will be retained until consent is withdrawn.
In certain cases, data may be retained longer for legal or dispute-related purposes.
6. TRANSFER OF PERSONAL DATA
Personal Data may be transferred to Hosts, Clients, IT service providers, accounting providers, marketing providers, SMS/email notification providers, or public authorities.
Transfers outside the EU/EEA will only occur with appropriate safeguards in place.
7. DATA SECURITY
We apply appropriate technical and organizational measures to protect Personal Data. However, absolute security cannot be guaranteed.
8. DATA SUBJECT RIGHTS
You have the right to access, rectify, erase, restrict processing, data portability, object to processing, withdraw consent, avoid automated decision-making, and lodge a complaint with the Romanian Data Protection Authority (ANSPDCP).
9. CONTACT
If you have questions regarding this Privacy Policy, please contact us at:
📧 support@travlocals.com
