Privacy policy

1. Who are we? Normative base. Goals

2. What data do we collect about you?

3. Why do we process your personal data?

4. How will we inform you about changes to the Policy?

5. Your rights

6. Marketing emails

7. Who do we disclose your data to?

8. International transfers

9. Where and for how long do we store your data?

10. Technical and organizational measures and safety of processing ● 11. Links to Third Party Sites

12. Principles of personal data processing

13. Identification and contact details

14. Data Protection Authority

15. Cookie Policy

1.Who are we? Normative base. Goals

1.1. DRAGOMIRNA Ltd (hereinafter referred to in this Policy as "Dragomirna", "we", "us" or "our") is the data controller responsible for your personal data, with its registered office at 36 st. P. Rares, apt. 38, Chisinau, Republic of Moldova. We provide services in accordance with the Terms of Use. Our contact details can be found in section 14.

1.2. When processing personal data, within the organization, the principles set forth in international acts are applied, such as: "Universal Declaration of Human Rights", "Convention for the Protection of Human Rights and Fundamental Freedoms", "Convention for the Protection of Individuals with regard to Automatic Processing of Personal Data", "Directive 95/46 / EC of the European Parliament and of the Council of the European Union on the protection of the rights of individuals with regard to the processing of personal data and on the free movement of such data", as well as national ones, such as: "The Constitution of the Republic of Moldova", "Law on the protection of personal data ", "Law on Access to Information", "Requirements for ensuring the security of personal data regarding their processing in personal data information systems, approved by Government Decree No. 1123 of December 14, 2010", "Regulation on the Register of Personal Data Operator, approved by Government Decree No. 296 dated May 15, 2012" and other relevant legislative/regulatory acts.

1.3. The main objectives of the Policy are the availability, integrity and confidentiality of all information, including personal data processed by the company both manually and automatically. Security is an integral component of the optimal operation of IT processes within a company. The basis for adequate IT security is compliance with this Policy. This includes requirements and rules for the protection of information, including personal data, IT systems and processes from natural influences, human and technical errors, as well as from deliberate actions that may cause material or non-material damage or that may lead to violations of the law. Given that IT security cannot be guaranteed solely through technical systems, this Policy also covers organizational, legal and other issues.

2.What data do we collect about you?

2.1.1 Data provided by direct interaction

Registration and other account information

When you register to use our Services, we may collect the following information about you:

● When leaving a request on the site, you will need to send an e-mail address;

● If you leave a request on the site using your mobile phone number: we collect your mobile phone number.

While using our Services, you may provide us with the following additional personal data:

● Your name;

● Mobile phone number;

● Your credit card details (if you wish to purchase our services for a fee), as defined in the Terms of Use

Recording phone calls by our Guest Support staff.

When you call or choose to call one of our Guest Services representatives or other services, we will record the conversation with your explicit consent to improve your customer experience.

2.1.2 Information we collect automatically when you use our Services

When you interact with our site or use our Services, we automatically collect the following information about you:

Device Information

We collect information about devices, such as operating system version, unique identifiers. For example, the name of the mobile network you are using.

Client Data and Authentication

Technical details, including the device's IP address, time zone, and operating system. We will also store your authentication details (date of registration, date of last password change, date of last successful authentication), your browser type and version.

Browsing history data

We collect information about your activity on our site, including the web pages from which you accessed our Platform, the date and time of each visit, the search queries you performed, the banner ads or content you clicked on, your interaction with these types of advertising, the duration of your visit and the order in which you view the content of our Platform.

Cookies and similar technologies

We use cookies to manage user sessions, store language preferences and provide you with relevant advertising. Cookies are small text files that are transferred by a web server to your device's hard drive. Cookies can be used to collect data and record your visit time, browsing history, your preferences and username. You can set your browser not to store all or some cookies, or to warn you when websites set or access cookies. If you disable or refuse cookies, please note that our Services/Platform may become partially unavailable or may not function properly. For more information about the cookies we use, please see our Cookie Policy.

3.Why do we process your personal data?

We will only use your personal data when permitted by law. Most often, we will use your personal data in the following cases:

● If we are required to perform a contract we are about to enter into or have entered into with you;

● If it is necessary for our legitimate interests to improve the Services and keep the site safe and secure;

● If we are required to comply with legal or regulatory obligations;

● If you give us your explicit consent (eg in the case of audio recordings).

In certain circumstances, we may process your personal data based on your consent. If we do this, we will inform you of the purpose and category of personal data we process when we ask for your consent.

The following describes how we use your personal data and what legal bases we rely on. Where appropriate, we have also determined what our legitimate interests are.

3.1 To provide access and provide Services through our website

We will use your email address and mobile phone number (via SMS) to provide you with offers and recommendations about our services that may be of interest to you.

We will process the above information for the proper performance of our contract with you and based on our legitimate interest in conducting marketing activities to provide you with Services that may be of interest to you.

3.2 To improve your experience on the site

I. We use click data:

● for more relevant search results when using our Services.

● To determine how you navigate the site and how much time you spend doing so, in order to understand your interests based on this data and improve our Services. For example, we may: suggest certain content based on the content you have accessed.

II. Through your registration data, which includes your email address and phone number, we identify the various devices (eg personal computers, mobile phones, tablets) through which you access the site. This allows us to associate your activity on the site with different devices and provide you with the appropriate experience, according to which device you use.

We process the above information based on our legitimate interests to improve your experience with our site and to properly perform the terms of the contract with you.

3.3 To provide you with a safe and secure website

I. We use your phone number and unique device identifiers to manage and secure the site (including troubleshooting, data analysis, testing, fraud prevention, system maintenance, support, reporting, and data hosting).

We process the above information for the proper performance of our contract with you, to improve our services and based on our legitimate interest in fraud prevention.

3.4 To provide you with a powerful customer service

II. We record your conversations with support representatives only with your explicit consent;

We process the personal data mentioned above in order to subsequently analyze your interactions with our customer service representatives (as applicable) and improve the quality of our guest service.

You may, at any time and free of charge, withdraw your consent by sending us a request using the contact details set out in point 14 below. All processing activities carried out prior to the withdrawal of consent remain unaffected.

We may make changes to this Policy from time to time. We will post changes to this page and notify you by email or through the website. If you do not agree with the conditions set forth in this document, do not use the banya.md website and the services provided through it.

5.Your rights

In certain circumstances, you have rights under data protection law.

If you would like to exercise any of the following rights, please contact us using the contact details.

The right to request access to your personal data (commonly referred to as "requesting access to the data subject"). This allows you to obtain a copy of the personal data we hold about you and to verify that we are lawfully processing it.

The right to request the correction of any data we hold about you. This allows you to correct any incomplete or inaccurate data we hold about you, although it may be necessary to verify the accuracy of new data you provide to us.

The right to demand restriction of the processing of your personal data. This allows you to ask us to suspend the processing of your personal data in the following cases: (a) if you wish to ascertain the accuracy of the data; (b) if we use the data unlawfully; (c) if you need to retain the data, even if we no longer need it and you need it for the establishment and filing of legal claims; (d) if you object to our use of your information and we need to be satisfied that there are compelling legal grounds for using it.

The right to request the deletion of your personal data. This allows you to ask us to delete or destroy your personal data unless there is a compelling reason to continue processing it. You also have the right to ask us to delete or destroy your personal data if you have successfully exercised your right to object to processing (see below), if we have processed your data unlawfully, or if we are required to delete your personal data in accordance with local law. Please note that we are legally required to retain your data for certain purposes. See section 9 for details.

The right to object to the processing of your personal data if we are based on legitimate interests (or the interests of third parties), but any circumstances in your particular situation lead you to object to the processing of data because you believe that this affects your rights and your fundamental freedom. You also have the right to object if we process your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds for processing your data that go beyond your rights and freedoms.

The right to demand the transfer of your personal data to you or third parties. We will provide you or third parties with your personal data in a commonly used structured format that can be read by a computer. Please note that this right only applies to automatically collected data that you initially gave us consent to use, or if we used the data to perform a contract with you.

The right to withdraw your consent to the processing of your personal data at any time. This does not affect the lawfulness of any data processing that we have already carried out based on the aforementioned consent.

Fees are generally not required and you will not need to pay to access your personal data or to exercise any other rights. However, we may charge a reasonable fee if your request is manifestly unfounded, repeated or exaggerated. Otherwise, under such circumstances, we may refuse to comply with your request.

Response Time: We aim to respond to all legitimate inquiries within one month. If your request is particularly complex or you have made multiple requests, it may take more than a month to provide a response. In this case, we will notify you and keep you informed.

In addition, you have the right to lodge a complaint with a data protection authority at any time. Contact details - centru@datepersonale.md, (022) 820 801, MD-2004, Republica Moldova, mun. Chisinau, 48 st. Serghei Lazo

However, before filing a complaint with a data protection authority, we are first of all ready to solve your problems. In this regard, please contact support.

We will contact you via email, SMS, or application notification of the Services for other transactional communications related to our Services. Because we are required to provide you with these transactional communications, you cannot opt out of receiving them.

However, you can unsubscribe at any time by contacting us via our support service.

You may receive marketing communications from us if:

● you have requested such information from us;

● use our Site or Services

● provided us with your details when you entered a competition or registered for a promotion.

7.Who do we disclose your data to?

Personal data may be disclosed to the parties listed below, for the purposes previously set out in Section 3.

Third Party Service Providers. We partner with third party service providers who help us deliver certain aspects of the Services. Third party service providers may be located both inside and outside the Republic of Moldova.

To make payments on our platform, whether it is payment by card or payment by payment order, we use the services of commercial banks, payment processors authorized by us to perform these operations in accordance with the legislation of the Republic of Moldova. In this regard, when making payments for the purchase of services on our platform, we will transfer some of your personal data to a commercial bank for the purpose of processing payments and completing the corresponding transaction.

We conduct audits of third party service providers and ask them to respect the security of your personal data and treat it in accordance with the law. We do not allow your personal data to be used for our own purposes, we only process personal data for specific purposes and only in accordance with our instructions.

Criminal prosecution authorities, government agencies and others: We may disclose your personal data to criminal prosecution authorities, public authorities or governmental bodies and other relevant organizations as required by law or regulation. We may sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire or merge with other businesses. If there is a change in our company, the new owners may use your personal data in the same way as described in this Policy.

8.International transfers

When we transfer your personal data to a country outside the European Union, we ensure that the same degree of protection is provided by implementing at least one of the following safeguards:

● We will only transfer personal data to countries where the level of personal data protection is considered adequate by the European Commission. For more information see European Commission: Adequacy of the protection of personal data in non-EU countries.

● If we work with certain service providers, we may use special contracts approved by the European Commission, which will result in the protection of the personal data provided in accordance with EU regulations. For more information, see European Commission: Model contracts for the transfer of personal data to third countries.

● If we work with US service providers, we may transfer data to them if they are part of a Privacy Policy that requires them to provide appropriate protection for personal data transferred between Europe and the US. For more information see European Commission: EU-US Privacy Shield.

9.Where and for how long do we store your data?

The data that we collect about you will be stored and processed on secure servers both on the territory of the Republic of Moldova and abroad. This is done to provide users with the best experience, for example, to quickly create web pages or mobile applications.

We will retain your personal data for as long as necessary to fulfill the purposes we intended to collect it, including to satisfy any legal, accounting or reporting requirements.

In order to determine the necessary retention time for personal data, we consider the amount, nature and confidentiality of the data, the potential risk of harm caused by unauthorized use or disclosure of your personal data, the purposes for which we process your data, and the possibility of realizing these purposes by other means in accordance with applicable law. legal requirements.

10.Technical and organizational measures and safety of processing

All information we receive about you is stored on secure servers and we have taken appropriate technical and organizational measures to protect your personal data. We continually evaluate the security of the network and its compliance with our internal information security program, which is designed to: (a) protect your data from accidental or unlawful loss, access or disclosure; (b) to identify reasonably foreseeable security risks to our network, and (c) to mitigate security risks, including risk assessment and periodic testing. In addition, we ensure that all payment information is encrypted using SSL technology.

Please note that despite the measures we have taken to protect your data, the transmission of information over the Internet or other open networks is never completely secure and there is a risk that your personal data may be available to unauthorized third parties.

11. Links to Third Party Sites

Our platform may contain links to websites or third party applications. If you use one of these links, please note that each of these sites or applications will have their own privacy policy. We do not control these websites/apps and are not responsible for their policies. When you leave our Platform, we encourage you to read the privacy policy of each website you go to.

12.Principles of personal data processing

The processing of personal data is based on the following principles:

- lawfulness of the purposes and methods of processing personal data and good faith;

- compliance of the purposes of processing personal data with the purposes defined above and declared when collecting personal information;

- observance of the volume and nature of the processed personal data, methods of processing personal data in connection with the purpose of processing personal data;

- the reliability of personal data, the relevance and necessary scope of their processing, the inadmissibility of excessive processing in relation to the purposes of collecting personal data;

- legality of organizational and technical measures to ensure the security of personal data; - striving for continuous improvement of the personal data protection system.

For more information or to exercise your rights, please contact customer support by phone or email.

If you would like to contact us to request information regarding the processing of your personal data, you can send an email to:

DRAGOMIRNA Ltd.

Address: mun. Chisinau, 36 st. Petru Rares, app. 39

MD-2005

Settlement account no.: MD50ML000000022513094633

Branch "Centru" BC" Moldindconbank" SABIC: MOLDMD2X309 Fiscal code: 1022600034666

Administrator: Goncearova Eugenia

Tel: 069281212

E-mail: dragomirna.terme@gmail.com, Kaleamanova.ev@gmail.com

Schedule:

Monday: 10:00-23:00

Tuesday: 10:00-23:00

Wednesday: 10:00-23:00

Friday: 10:00-23:00

Saturday: 10:00-23:00

Sunday: 10:00-23:00

Sanitary day: Thursday (closed)

Customer support 09:00-23:00: +(373) 69 111 314 E-mail: go@banya.md

dragomirna.terme@gmail.com

14.Data Protection Authority

For data protection issues, you can contact your local authority, represented by the National Center for Personal Data Protection

Address: MD-2004, Republic of Moldova, mun. Chisinau, 48 st. Sergei Lazo Website: http://www.datepersonale.md/

15.Cookie policy

15.1.Our website uses cookies

The banya.md website uses cookies to improve the user experience of visitors and provide quality services tailored to the needs and interests of visitors. By visiting the banya.md website, you consent to the use of cookies in accordance with this Policy.

To navigate the site, you must enable cookies, if they were not previously enabled. If your browser is set to accept our cookies, we take into account this fact and that you agree to them.

Cookies can be disabled at any time by you in the settings menu of your web browser. However, we note that after disabling them, the site will not work with the same quality, and viewing certain content will become impossible. Disabling cookies does not guarantee the disappearance of advertising materials.

Our site may contain links to third party websites or applications, including those of our partners. Please note that these third party websites may use cookies. We do not control these third party websites and are not responsible for the cookies they set or access. If you click on one of these links or apps, please note that each site will have its own cookie policy. Therefore, please read the cookie policy of other sites or applications before using them.

15.2.What are cookies?

Cookies are small pieces of text for storing information in a web browser, created by the website you are visiting. With their help, the website remembers information about your visit, such as the selected settings, thereby simplifying the next visit to the site. When you visit the website, they are sent from our web server to your device (PC, laptop, smartphone or tablet) and stored in the Internet browser you are using. The cookies used can perform various functions.

Cookies contain information that links the user's browser to the site being visited. If the browser accesses the site again, it will be able to read the stored information and respond to certain user actions.

Cookies are not viruses or programs. They cannot install what you do not want to have on your device (computer, smartphone, tablet) or learn information from your device folders.

The information that cookies contain is usually encoded as a set of numbers and letters, which can only be correctly interpreted by the website that sets these cookies.

15.3. Does our Platform have third party cookies or plugins?

Third parties, such as ad networks and external service providers such as web traffic analytics, may use cookies, web beacons, software development kits (SDKs) or similar technologies to collect information about your visit to our Platform. This information is used to provide you with more relevant advertising on our platform or other online resource. We do not control the use of third party cookies, which are subject to the privacy/cookie policies of third parties.

Below is a list of third parties that we allow to install cookies or other technologies on your device.

Analytics partners:

To better understand how you use our cfqn, we work with different analytics partners. We allow analytics partners such as Google Analytics and Gemius to use cookies, SDKs and other related technologies.

Advertising networks:

The following ad networks may use targeting and advertising cookies to display content they think is most interesting to you and to measure the performance of such ads on our site: Google, Facebook.

Recipients/Categories of Recipients:

During the processing of data on the website, the data is transmitted to our company's specialized marketing/business intelligence department, to other technical service providers who have entered into contracts for order processing or technical support, in accordance with Art. 28 GDPR, before accessing the data, for assistance purposes, and to our advertising partners.

To improve the quality of our Services, we will occasionally share your information with analytics partners who help us analyze how data subjects use our site/service. We share your information in a non-identifiable form with them to monitor and report on campaign performance for our business partners and for internal company analysis. This information typically includes a cookie ID, referring URL, and browser and device information.

Upon request, we may disclose data to criminal prosecution authorities, state or governmental authorities and other relevant third parties in order to comply with legal or regulatory requirements. We may sell, transfer or merge parts of our business or assets. Alternatively, we may seek to acquire or merge with other businesses. If there has been a change in our company, the new owners may use your personal data in the same way as described in this Policy.

15.4 Retention period/Criteria for setting the storage time of cookies

Session cookies are deleted immediately after the browser is closed. Persistent cookies remain on your browser until you manually delete them.

15.5.What do we use cookies for? Purpose of processing/Legal basis for processing

Information that appears when using the page (the page on which the file was requested, the file name, the date and time of the request, the amount of data transferred, the access status, such as "Sending a file", "File not found", etc., a description of the used browser and IP address) are used by us for user guidance, statistical evaluation, tailoring our web pages to your needs, displaying advertisements on the page (displaying product information on the relevant buttons on this web page) and to protect against occasional requests to our web -offers. For this purpose, we use cookies with which we can monitor activity statistics on our web pages during a session. The data collected is not used to personally identify the visitor to this web page. User data stored in cookies is not centralized together with personal data. The legal basis for the legal basis for the storage and use of these data is Art. 6 couples (1) lit. (f) GDPR and Art. 5 couples (4) lit. (e) Law No. 133 of July 8, 2011 on the protection of personal data.

15.6 Site security and integrity

We use cookies to ensure the safe operation of the site, protect your account and your data.

For example: Cookies help us identify and apply additional security measures.

Advertising, statistics and measurement

We use cookies to serve ads to individuals who might be interested in the goods or services promoted through them, as well as to our advertising partners.

For example: Cookies help us, alone or with the help of partners, to serve ads to people who are interested in the product or service being promoted, what they searched for, bought or searched

for on our site. Also, cookies help limit the number of times a user sees ads so they don't always see the same ad.

We use cookies to measure the effectiveness of advertising campaigns carried out through the site

Cookies help us to serve ads and measure their performance on all browsers and devices used by an individual.

For example: Cookies help us prevent a large number of displays of one particular advertisement on the devices you use.

15.7 Services and site functionality

Cookies help us to create high-quality site functionality.

For example: Cookies help us store information about your search preferences so that the content displayed is more relevant, and information about browsing and interacting with site content.

15.8 Analytical data

Cookies help us collect the necessary information to understand how the site is used and to continuously improve it.

For example: Cookies help us learn how the site is used, analyze which of its services are most requested, at what time of the day the site is more or less navigable, the number of people who have visited the site, and to determine what needs to be improved.

15.9.What can you do to delete, disable or block cookies?

Your browser will usually tell you how to refuse, delete or block cookies. The links below provide information on the most commonly used browsers:

Google Chrome: https://support.google.com/

Internet Explorer: https://support.microsoft.com/en-in/help/17442/windows-internet-explorer- delete-manage-cookies

Mozilla Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website- preferences

Safari: https://support.apple.com/en-in/guide/safari/sfri11471/mac Opera: https://help.opera.com/en/latest/

You can opt out of the use of third-party cookies by Google Analytics through your advertising settings: https://tools.google.com/dlpage/gaoptout

15.10.Contact details

For more information or to exercise your rights, please contact our support team 09:00-23:00 +37369 111-314

The site administration reserves the right to make changes and (or) additions to the content of this Policy caused by site changes. In this regard, we recommend that you check the availability of up- to-date information on our website.