PRIVACY POLICY

Your privacy is one of our fundamental commitments at dnata Catering S.R.L., a company established and operating in accordance with Romanian law, registered with the Ilfov Trade Register under no. J2001001077237, with its registered office in Otopeni, Calea Bucureştilor, No. 224 R, Ilfov County, with unique registration code 4339914 (hereinafter, "dnata"), which owns/administers this application.

Therefore, we strive to process your personal data in accordance with the principles set out in the data protection legislation applicable in Romania, including Regulation (EU) 2016/679 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/ EC ( "GDPR"/"Regulation").

1. INFORMATION ON THE PROCESSING OF PERSONAL DATA

   This document is addressed to you in your capacity as a user of the dnata application and is intended to inform you, in accordance with the provisions of the Regulation, about the processing of personal data by dnata.

   For the purposes of the Regulation, personal data means any information relating to an identified or identifiable natural person, and an identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identification number or to one or more factors specific to his physical, physiological, mental, economic, cultural, or social identity.

   This privacy policy concerns the personal data of our customers, business partners, other persons who contact us and visit us, and their representatives, potential employees, and applies to data collected through the dnata application with regard to all other personal data collected by email or other offline contacts. The privacy policy describes:

   1. The purposes for which we collect and use your personal data;

   2. The reasons for processing for such purposes;

   3. The categories of personal data we collect and process;

   4. The duration of the processing of such data;

   5. Your rights as a data subject and how you can exercise them;

   6. The persons to whom personal data may be disclosed.

2. PURPOSES, GROUNDS FOR PROCESSING, AND CATEGORIES OF PERSONAL DATA

   In the context of our interaction with you as an individual, we process data for the following purposes:

   • improving the safety and security of users and services;

   • for support services;

   • for research and development;

   • facilitating communication between users;

   • for marketing and advertising;

   • to send users non-marketing messages;

   • for legal proceedings;

   • providing goods and services requested by users;

   • confirming ordered services and providing additional information about them;

   • bidding, contracting, and billing operations;

   • compliance with applicable laws;

   • informing about promotional offers, news about the services in the dnata portfolio;

   • preventing fraud and ensuring the security of the website and the information and premises where dnata operates, including video surveillance;

   • in relations with merchants;

   • in relations with dnata suppliers;

   • in relations with dnata's legal, tax, accounting, and marketing advisors.

     Therefore, personal data is used in the following cases:

   Provision of services

   dnata uses data to provide, personalize, maintain, and improve its services.

   This includes using data for:

   • crearea/actualizarea conturilor;

   • Performing operations necessary to maintain our services, including troubleshooting software errors and resolving operational issues.

     dnata performs the above activities because they are necessary to comply with our agreements with users, are compatible with the interests of those users, or are necessary in the legitimate interests of dnata and its users.

   Safety, fraud protection, and security

   We use data to maintain the safety, security, and integrity of our services and users, including:

   
   

   • verifying user accounts, identity, or compliance with safety requirements;

   • using customer service information (including safety incident reports), device data, and data about the use of the dnata app;

   • using reported incidents, user ratings, and other forms of feedback to encourage safe use of the dnata app and compliance with our terms;

   • using reported incidents, user ratings, and other forms of feedback to encourage safe use of the dnata app and compliance with our terms;

   • using partner merchant data;

   • using the phone number, user name, and other relevant information to provide support.

   The fraud prevention and detection activities described above may be considered profiling under applicable laws and may result in the deactivation of users (usually only after an assessment by a human being).

   dnata carries out the above activities because they are necessary to comply with our agreements with users and/or in the legitimate interests of dnata, its users, and the general public regarding safety and security.

   Research and development

   e use data for analysis, machine learning, product development, research, and testing. This allows us to provide more convenient and user-friendly services, improve the safety and security of our services, and develop new services and features.

   dnata carries out the above activities because they are necessary in its legitimate interest to improve its services and features, as well as to create new ones.

   Marketing and advertising

   dnata uses data to promote its services and those of its partners.

   In particular, we use account, device, and usage data, as well as preferred language, to provide personalized advertising and marketing communications based on users' location, interests, and observed or inferred characteristics.

   This includes using such data to:

   • send emails, text messages, push notifications, and in-app messages or other marketing or promotional communications about dnata products, services, features, offers, promotions, sweepstakes, news, and events.

   • displaying personalized advertisements in apps or on third-party websites;

   • displaying third-party advertisements in the dnata app or in connection with our services. For example, we display advertisements for restaurants or merchants available in the dnata app. These advertisements (referred to as "sponsored ads")

   We also display advertisements for third-party products that are not available in the dnata app. These advertisements may contain links to third-party apps or websites. Users should consult the privacy policies of these third parties for information on their data collection and use practices when accessing such apps or websites. We also measure the effectiveness of dnata and third-party advertisements displayed in the dnata app or in connection with our services.

   dnata carries out the above activities because they are necessary for dnata's legitimate interest in informing its users about the services and features offered by dnata or dnata's partners.

   Non-advertising messages

   dnata may use data to send surveys and other messages that are not intended to market dnata's or its partners' services or products. We may also send users messages about legal measures or pending laws regarding dnata's services in the users' respective regions.

   dnata carries out the above activities because they are necessary to comply with our agreements with users or in the legitimate interest of dnata and its users to inform users about events that may impact their use of dnata services.

   Legal procedures and requirements

   We may use data to investigate or resolve claims or disputes related to the use of dnata services, to comply with legal requirements, regulations, or licenses or applicable operating agreements, or in response to legal proceedings or government requests, including from law enforcement agencies.

   dnata carries out the above activities because they are necessary in dnata's legitimate interest to investigate and respond to complaints and disputes regarding the use of dnata services and features and/or to comply with applicable legal requirements.

3. COOKIES AND THIRD-PARTY TECHNOLOGIES

   dnata and its partners use cookies and other identification technologies in our applications, websites, emails, and online advertisements for the purposes described in this policy and in Cookie Policy available at https://www.henriappport.ro.

   Cookies are small text files stored in browsers or on devices by websites, apps, online media, and advertisements. dnata uses cookies and similar technologies for purposes such as:

   • authenticating users;

   • saving user preferences and settings;

   • determining the popularity of content;

   • delivering and measuring the effectiveness of advertising campaigns;

   • analyzing trends and traffic on websites and generally understanding the online behavior and interests of those who interact with our services.

   We may also allow other entities to provide us with measurement and statistical services, to serve ads on our behalf on the internet or for other companies' products and services in our applications, and to track and report on the performance of those ads. These entities may use cookies, web beacons, SDKs, and other technologies to identify the devices used by visitors to our websites, as well as when they access other websites and online services.

   For more information about the use of cookies and other technologies described in this section, please refer to the Cookie Policy available at https://www.henriappport.ro .

   Users who do not want third-party cookies can use their preferred browser settings to delete or block them.

   Users can configure their browser to reject cookies.

   To delete or block third-party cookies, users can use their browser settings:

   • Internet Explorer : link

   • Microsoft Edge: link

   • Mozilla Firefox : link

   • Google Chrome : link

   • Safari : link

   Cookie blocking extensions such as UBlock, Ghostery, AdBlock, and Privacy Badger can also be installed.

4. DATA TRANSFER AND DISCLOSURE

   Some of dnata's services and features require sending data to other users, at their request or with their consent. We may also send data to our affiliates, subsidiaries, and partners for legal reasons or in connection with claims or disputes.

   Data may be sent by dnata to:

   • - dnata's business partners. For example, if a user has requested a service through a partnership or promotional offer run by a third party, dnata may send certain data to those third parties. These may be, for example, other services, platforms, applications, or websites that integrate our APIs, suppliers, third parties whose APIs or services we integrate, or restaurants, merchants, or other dnata business partners and their users, for promotions, contests, or specialized services;

   • - emergency services. We offer features that allow users to send personal data to police, fire, and ambulance services in case of emergency or after certain incidents;

   • - the general public. Questions or comments from users submitted through public forums on social networks may be visible to the public, including the data in the questions or comments submitted by users;

   • - Subsidiaries and affiliates. We send information to our subsidiaries and affiliates to help us provide our services or process data on our behalf.

   • - dnata service providers and business partners. If a third party is identified, please refer to its privacy policies for information on its collection and use of personal data.

   • - marketing partners and providers of marketing platforms, including social media promotion services, advertising networks, third-party data providers, and other service providers, to attract or better understand users and measure the effectiveness of advertisements displayed;

   • - research partners, including those who conduct surveys or research projects in collaboration with or on behalf of dnata;

   • - service providers that help dnata improve the safety and security of dnata's applications and services;

   • - service providers that provide us with artificial intelligence and machine learning tools and services;

   • - accountants, consultants, lawyers, and other professional service providers;

   • - financial services and insurance partner;

   • - airports;

   • - for legal reasons or in the event of a dispute, dnata may send user data when it deems it necessary as required by law, regulations, operating authorization or agreement, legal procedures or government requests, insurance policy or, if applicable, for safety or other similar reasons;

   • - with the consent of users, dnata may send user data other than as described in this policy if we notify the user and they give their consent.

   • - other persons, at the user's request

   We currently store and process your personal data within Romania.

   However, we may transfer some of your personal data to entities located in the European Union or outside the Union, including countries that the European Commission has not recognized as having an adequate level of personal data protection.

   We will always take steps to ensure that any international transfer of personal data is carefully managed in order to protect your rights and interests. Transfers to service providers and other third parties will always be protected by contractual commitments and, where appropriate, other safeguards, such as standard contractual clauses issued by the European Commission or certification schemes.

   You can contact us at any time using the contact details above to find out more about the countries to which we transfer your data and the safeguards we have put in place in relation to these transfers.

5. DATA RETENTION AND DELETION

   Personal data is processed securely. dnata has taken appropriate technical and organizational measures regarding data security, against unauthorized processing or alteration, against loss or destruction, as well as against disclosure and unauthorized access to personal data transmitted, stored, or processed. dnata ensures the integrity, availability, confidentiality, and authenticity of personal data.

   dnata uses advanced security methods and technologies, together with employee policies and work procedures to protect the processing of personal data, in accordance with the legal provisions in force. Your personal data is stored within the European Union.

   dnata makes every reasonable and commercially justified effort to protect the personal data it holds, analyzes new technologies in the field, and, when appropriate, applies them to upgrade its security systems.

   dnata has also implemented appropriate technical and organizational measures to ensure that only personal data necessary for the specified purposes is processed. The principle of data protection by default will also be followed in the development of new products or services.

   On the dnata app, personal data is stored according to the type of user and the purpose for which it was collected. Here are the main situations:

   1. Active account users: : Personal data is retained until the account is deleted, either at the user's initiative or at the initiative of the platform.

   2. Deletion or request for deletion of data : In certain cases, dnata may temporarily retain data to fulfill legal or contractual obligations, in accordance with the platform's Terms and Conditions.

   3. Data used for marketing purposes : Information such as name, surname, email address, and phone number is kept until consent is withdrawn, but for no longer than 5 years.

   4. Data stored for the duration of legal obligations : In certain cases, some personal data may be retained for the duration required by legal obligations.

   At the end of the storage period, the data is either deleted or irreversibly anonymized, thus ensuring the protection of user privacy.

   However, despite our efforts to store the information collected in a secure operating environment that is not available to the public, we cannot guarantee the absolute security of this information during transmission or storage in dnata systems. In the event of a security breach that compromises the privacy or personal information of users, dnata undertakes to inform you of this, either through this website or by other means at its disposal (messages, email, phone calls).

   Upon request to delete the account, we will delete the user's account and data, except where retention is necessary for safety, security, fraud prevention, or legal compliance purposes, or due to issues related to the user's account (such as claims for compensation or an unresolved claim or dispute).

6. USER RIGHTS

   The Data Protection Regulation grants you a number of rights in relation to your personal data. You may request access to it, correct any errors in our files, and/or object to the processing of your personal data. You may also exercise your right to complain to the competent supervisory authority or to take legal action. Where applicable, you may also have the right to request the deletion of your personal data, the right to restrict the processing of your data, and the right to data portability.

   Access, Information, Rectification, and Objection

   You can contact us and we will inform you about the personal information we have collected and processed about you and the purposes for which this data is used.

   You have the right to correct any inaccurate, incomplete, outdated, or unnecessary personal information stored about you.

   You may object to certain uses of personal information, including direct marketing, if this data is processed for purposes other than those necessary to perform our services or to comply with a legal obligation. You may also object to any further processing of personal information after prior consent has been given. If you object to the further processing of personal information, this may result in fewer opportunities to use our services.

   Deletion and right to restrict processing

   You can also request that we delete your personal information from our systems. We will comply with this request unless we have a legitimate reason not to delete the data. After deleting the data, we may not be able to immediately delete all residual copies from all of our systems. These copies will be deleted as soon as possible.

   You can ask us to restrict the processing of certain personal information, but this may result in fewer opportunities to benefit from the services offered.

   Right to portability

   You have the right to receive the personal information you have provided to us in a structured, commonly used format.

   Your rights are:

   1. Right of access – this means you can ask dnata to confirm whether or not they're processing your personal data, and if so, you have the right to ask for access to that data, as well as extra info like: why they're processing it, who they're sharing it with, and how long they plan to keep it. In situations where you may need to exercise your right of access, please contact dnata and request confirmation by email at office@dnata.ro. Please note specific situations that are exempt from the right of access, such as information that identifies other individuals or is subject to confidentiality obligations.

   2. Right to rectification – allows you to request the correction of any inaccurate personal data that dnata holds, as well as to ensure that your data is complete.

   3. Right to erasure – allows you, in situations expressly regulated by law, to request the erasure of your personal data. The situations in which the law provides for the possibility of erasing personal data are those in which the processing is unlawful or when the processing is based on your consent, which you have withdrawn.

   4. Right to restriction of processing – allows you to obtain restrictions on the processing of your data from dnata. This right can only be exercised in specific situations, such as when you contest the accuracy of your data. During the period necessary to correct the data, you may ask us to restrict the processing of your personal data.

   5. Right to data portability – this involves your right to receive your personal data in a structured, commonly used format and to transmit this data to another controller. This right will only apply to personal data that you have provided and where the processing is carried out by automated means based on consent or for the performance of a contract you have entered into with dnata.

   6. The right to object to the processing of personal data by dnata for reasons related to your particular situation applies only in situations where the legal basis is consent (e.g., use of email address for marketing messages).

   7. The right to lodge a complaint – allows you to challenge the way dnata processes your data with the competent data protection authority.

   8. Right to withdraw your consent for various processing operations, in cases where consent is the legal basis for processing. In cases where you withdraw your consent to the processing of your data, the processing will be terminated from the moment the withdrawal takes place, without any effect on the processing that took place prior to the withdrawal.

7. EXERCISING YOUR RIGHTS

   These rights can be exercised by sending a written request to the email address office@dnata.ro . We may request additional information necessary to confirm your identity.

   We may reject requests that are unreasonably repetitive, excessive, or manifestly unfounded. We reserve the right to respond to only one request for information per year. In certain situations, we may request payment for the cost of providing this information.

   We aim to respond to all valid requests within one month, unless it is particularly complex or you have made multiple requests, in which case we will extend this period to three months. We will notify you if we need an extension. However, please note that for technical reasons, it may take a few days to implement your requests or choices, during which time dnata will continue to process your personal data based on your previously expressed choices. In certain exceptional cases, the options expressed may only be implemented for the future, for example only in relation to future promotional campaigns.

   If you believe that our personal information processing activities do not comply with applicable data protection laws, you may file a complaint with: National Supervisory Authority for Personal Data Processing, B-dul G-ral. Gheorghe Magheru 28-30, Sector 1, postal code 010336, Bucharest, Romania, telephone: +40.318.059.211 or +40.318.059.212, e-mail: anspdcp@dataprotection.ro sau pe www.dataprotection.ro .

   PFor questions about data protection or your personal data at Vivo Fusion Food Bar, you can contact our data protection officer:

   Data controller:

   DNATA CATERING SRL

   Calea Bucurestilor nr. 224R, Otopeni, jud. Ilfov, Romania Trade Register Number: J2001001077237 Unique identification code: RO 4339914 DPO: Preda Adina

   E-mail: adina.preda@dnata.ro office@dnata.ro

   To ensure that your data is processed securely, we have made every effort to implement reasonable measures to protect your personal information.

8. UPDATES TO THIS PRIVACY POLICY

We may occasionally update this policy. If we make significant changes, we will notify users in advance of the changes using the dnata applications or other means, such as email. We encourage users to periodically review this policy to stay informed about our privacy practices.

Your use of our services after the update constitutes your agreement to the updated policy, to the extent permitted by law.