Privacy policy
INTRODUCTION
Through this Privacy Policy we want to provide you with all the necessary information in relation to the processing of personal data, which we collect directly or indirectly from you, when you interact with us.
We are committed to ensuring the privacy and protection of your data. and at the same time to be completely transparent about the situations, purposes and ways in which we carry out our processing activities.
When we request personal data from you, we will in particular ensure that it is adequate, relevant and limited to what is necessary in relation to the purposes of the specified explicit and legitimate processing.
We pay special attention to your rights. and respond to your requests. when you need more information.
Within this Privacy Policy you can access the Information Notes where we present in detail the main processing activities.
NOTE
The websites, applications or other tools used by Lagoon Park in the online environment are intended only for persons aged 16 or over. Please take this into account before accessing or using our online services: Lagoon Park does not knowingly solicit or process personal data from persons under the age of 16 for the purpose of providing information society services.
If you fall into this age category or are a parent/legal guardian of a minor under the age of 16 and you believe that their data has been processed, please contact us and we will make every effort to remove such data from our IT systems.
WHO ARE WE AND HOW CAN YOU CONTACT US?
We are Lagoon Parks S.R.L. (“Lagoon Park”, “We”), a Romanian legal entity registered with the Bucharest Trade Register under no. J40/8433/2024, CUI RO 49983884
When we process your data on the basis of purposes and means of processing set by us, we are a Personal Data Controller| and we are responsible for fulfilling all legal requirements regarding the processing of your personal data.
Our registered office is located in Romania, Bucharest, 136 Viitorului Street, 2nd floor, sector 2.
We carry out our activity at the address of the work point in Bucharest, 18 Coral Street, Sector 1, Romania (Lagoon Park Bucharest Complex).
We have a data protection team and we have appointed a data protection officer, who works at the workplace and can be contacted by email at dataprotection@lagoonpark.ro.
You can contact us both by mail/courier and by email, at the mentioned addresses.
WHO ARE WE ADDRESSING THROUGH THIS PRIVACY POLICY?
This Privacy Policy applies to you, as a visitor, customer, partner, user, employee, participant in various contests, events, winners, etc., when:
• Visit and use our services, within the Lagoon Park Bucharest complex as well as in adjacent spaces such as: parking lots, offices, transit areas, technical storage spaces, etc.
• Access and use the Lagoon Park website and related subdomains.
• Install and use the Lagoon Club mobile apps.
• Interact with us through online communication channels such as website, email, social media, or other methods:
• Participate in Lagoon Park Marketing Campaigns.
• You are a supplier, customer or other type of legal entity with which Lagoon Park has contractual relations;
• Other situations mentioned in the Information Notes.
In the same context, we may also refer to you as a “Data Subject”.
WHAT IS THE SOURCE OF PERSONAL DATA?
The data we process we obtain both directly and indirectly from you, when you interact with us according to the information presented in this Privacy Policy.
When you provide us with data that does not belong to you, in situations such as recording another person’s contact details, using another person’s bank card when making payments, providing personal data of children you are accompanying and for whom you do not have equal responsibility, sending other people’s CVs or other similar situations, Before using them in relation to us, please inform those individuals and their guardians accordingly by making our Privacy Policy known.
WHAT IS THE LEGAL FRAMEWORK UNDER WHICH WE PROCESS YOUR DATA?
We process your personal data in accordance with national and European provisions on the protection of personal data, in particular:
• Regulation (EU) 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data. (hereinafter referred to as the GDPR):
• Directive 2002/58/EC on the processing and protection of personal data in the electronic communications sector
• Law no. 190/2018 on measures for the implementation of Regulation (EU) 2016/679 of the European Parliament and of the Council;
In this Privacy Policy, we will collectively refer to them as “data protection laws”.
We will also take into account:
- Recommendations of the Supervisory Authority regarding the Processing of Personal Data or other competent institutions
- Any other national and European legal regulations that we are obliged to comply with regarding the processing of your personal data.
WHY DO WE PROCESS YOUR DATA?
The purposes for which we may process your data are varied.
In general, we process your personal data when it is necessary to provide you with Lagoon Park products and services, either on the basis of a contract or to fulfil our legal obligations arising from our activity (e.g. tax obligations, retention and archiving of supporting documents, communication with the authorities, etc.) or when necessary to defend our legitimate interests.
Legitimate interest relates to:
• Ensuring the protection of people’s health and safety;
• Preventing and combating crime and fraud
◦ Ensuring the security andprotectionof people, goods and values of Lagoon Park;
• Prevention of financial losses Damage recovery,
• Defending rights in court;
• Securing computer networks
• Providing and improving Lagoon Park’s products and services;
• Streamlining the internal processes of Lagoon Park taking into account the specific nature of the activity • Going through the necessary internal and legal procedures regarding the management of incidents/accidents;
• Taking the necessary steps to identify you, when necessary
• Protecting the image of Lagoon Park;
• Developing reports and analyses resulting from our activity;
• Use of cookies necessary for the functionality of the website; • Promotion of Lagoon Park products and services;
• Promotion of events and marketing campaigns;
• Promoting the image of Lagoon Park and the group it belongs to;
• Ensuring the compliance of visitors with regard to compliance with the Lagoon Park Internal Order Regulations;
• Solving the requests you send us
• Providing technical support;
• Other similar situations.
The processing of your data by us or other third parties for the situations mentioned above will always be carried out on the basis of a rigorous analysis from which it results the necessity of the processing and the fact that it does not unduly affect your fundamental rights and freedoms.
We will also use consent as a legal basis whenever we process your data based on your permission. which you grant in advance in various situations (registration for the Lagoon Park Newsletter, participation in opinion polls, etc.). Where we rely on this legal basis, you always have the right to withdraw your consent at any time. The withdrawal of consent does not affect the lawfulness of the processing carried out on the basis of consent before its withdrawal.
Please refer to our information notes for detailed information on the legal grounds and purposes that are used in connection with the processing of your data
WHO ELSE HAS ACCESS TO YOUR DATA?
Your data may also be disclosed to other third parties such as IT service providers, payment processors, financial and accounting service providers, marketing service providers, health and safety service providers, web application and tool providers, website and mobile application developers, market research providers, recruitment service providers, consultants, lawyers, legal advisers, auditors, or other similar entities.
We disclose your personal data to them only when necessary, taking into account the risks and applying appropriate protective measures.
Some of the categories of recipients mentioned may process your data for their own purposes or in accordance with the legal requirements imposed on them by the authorities. In this context, they acquire the quality of Data Controller for the processing activities carried out, becoming directly responsible for compliance with data protection laws.
Others will only process personal data at our request and for our purposes, based on prior instructions. They are considered our processors for the processing of your personal data. personally.
We only use trusted processors who provide sufficient safeguards to implement appropriate technical and organisational measures so that the processing of your personal data is carried out. comply with the requirements of data protection legislation. Processing of your personal data personal information by our processors is always governed by a contract or other legal act before disclosing your data to them.
LIST OF MAIN LAGOON PARK PROXIES
It is also possible to pass on your data to authorities or certain state institutions, only when we are required by law to do so or when we have a well-founded legitimate interest.
In specific situations, certain information about you (pseudonymised, anonymised or directly identifiable), usually statistical and marketing information may be shared globally with the Group of which the Company is a part.
INTERNATIONAL DATA TRANSFER
As a rule, the data we collect about you are processed on the territory of Romania, but also within the European Union, where the same legal provisions on data protection apply.
Your data they can also be transferred to countries that offer an adequate level of protection (e.g. the United Kingdom of Great Britain and Northern Ireland), according to the appropriate level decision adopted by the European Commission. In other words, transfers to these destinations are considered as safe as transfers between European Union member countries. Transfers made under these conditions do not require special authorisations.
We may also transfer your personal data to third countries such as the United States of America or international organizations that do not provide an adequate level of data protection in accordance with the requirements of the European Commission. In this situation, we will take all appropriate safeguards to protect your data and ensure that you have effective remedies to exercise your rights.
In this context, we will ensure that there will be standard contractual clauses, approved by the European Commission, to be signed with companies in these third countries, as well as contracts on data processing if these companies are our processors.
When we cannot find other appropriate safeguards, we will only carry out the transfer of data to these destinations under the following conditions:
• We ask for your consent in advance, after informing you of the possible risks:
• We only carry out the transfer of data at your request, in order to perform a contract or to apply necessary pre-contractual measures in relation to us.
• The transfer is necessary for the conclusion or performance of a contract entered into in your interest. between us and another natural or legal person;
• The transfer is necessary for important considerations of public interest;
• The transfer is necessary for the establishment, exercise or defence of a claim in court; • The transfer is necessary to protect your interests. or other persons, when you are not in the physical or legal capacity to express your consent
• Other situations provided for by law
We will ensure that any international transfer of personal data is handled with special care to protect your rights and freedoms.
HOW DO WE PROTECT YOUR DATA?
We make continuous efforts to protect your data throughout its lifetime, to prevent, eliminate or reduce the risks posed by processing activities.
Our data protection team is supported by cybersecurity experts, specialists in the legal field or various relevant areas of activity as well as top management of the Company who together define and implement appropriate strategies, policies and procedures for the protection of your data. personnel.
Our privacy and data protection program ensures that we effectively address all the necessary measures to meet legal requirements by implementing policies and procedures adapted to the specifics of our activity.
We periodically train our employees by referring to their field of activity and the risk that the activity carried out by them represents,
Through the information security program, we promote in particular techniques such as pseudominization and encryption of personal data.
We consider the risks and impact that a potential security incident may have on your rights and freedoms, which is why we have implemented procedures that help prevent, remedy or mitigate the impact on the privacy of your data. in the event of such a risk.
Before we start processing your data, we carry out data protection impact assessments whenever a particular processing activity may pose a risk to your fundamental rights and freedoms.
We impose special conditions on all our processors before transmitting their personal data, in accordance with data protection laws,
We ensure data protection from the moment of conception and implicitly throughout the processing period, when implementing new IT systems or new processing activities.
We have appointed a data protection team consisting of data protection specialists as well as a data protection officer, who together monitor the compliance of our personal data processing activities in accordance with legal requirements.
We keep records of the processing activities that fall under our responsibility as a personal data controller.
We have limited the retention of personal data in accordance with legal requirements and our legitimate interests and ensure that it is safely destroyed
We regularly audit the information systems in order to improve security measures ensuring an optimal level of security, in line with the technological development of the market.
WHAT ARE YOUR RIGHTS?
Under the conditions provided for in the data protection laws, as a data subject, you benefit from the following rights:
• The right to be informed, respectively the right to receive details regarding the processing of your data. as described in the Privacy Policy and Information Notes.
• The right of access to data, i.e. the right to obtain confirmation from us regarding the processing of personal data, as well as details of the processing activities.
• The right to rectification, respectively the right to obtain the correction of inaccurate/unjustified personal data, as well as the completion of incomplete data;
• The right to erasure of data without undue delay, (“right to be forgotten”), if applicable, under the conditions provided for by data protection laws
• The right to restriction of processing, insofar as you contest the accuracy of the data, the processing is unlawful and you object to the erasure, requesting in return the restriction of its use, or when we no longer have any purpose to process your data, but before you. You request them for the establishment, exercise or defence of legal claims or when you object to the processing of data for the period of time necessary to confirm the legitimate interests invoked by us.
• The right to data portability to another controller, under the conditions provided by law
• The right to object to processing at any time, free of charge and without any justification, where the data is processed for direct marketing purposes or where the processing is based on one of our invoked legitimate interests, unless we can demonstrate that there are compelling legitimate grounds justifying such processing.
• The right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects on you. or similarly affects you to a significant extent, with exceptions provided in data protection laws.
• The right to withdraw your consent at any time during the processing
• The right to apply to a supervisory authority, if you believe that the processing of your personal data has been compromised. violates data protection laws
HOW CAN YOU EXERCISE YOUR RIGHTS?
If you wish to exercise any of your rights regarding the processing of your personal data, obtain clarifications or additional information, please contact our Data Protection Officer by email at dataprotection@lagoonpark.ro.
We will respond to your request. within 30 calendar days from the date of registration of the application. Given the complexity and number of requests, we can extend this period by another two months. We will always inform you in advance of this extension, together with the reason for the delay.
Depending on the nature of the request, where the information you provide to us is insufficient to identify, investigate and resolve your request, we may request additional information from you.
Before responding to any request, we will always ensure that we have sufficient data to ensure that you are the holder of the data that is the subject of the request. If we are unable to identify you, we may refuse to provide you with requested information that may not belong to you.
We may also refuse to comply with your requests in situations where you ask us for the same repetitive, excessive or unjustified information.
INFORMATION NOTES:
To obtain details on the main processing activities carried out, please access the Information Notes below:
INFORMATION NOTICE ON THE USE OF COOKIES OR SIMILAR TECHNOLOGIES
INFORMATION NOTE REGARDING THE PURCHASE OF LAGOON PARK PRODUCTS AND SERVICES
INFORMATION NOTE ON THE USE OF THE ACCESS BRACELET
MARKETING NOTIFICATION NOTICE
INFORMATION NOTICE REGARDING THE CREATION AND USE OF THE MYLAGOON PARK ACCOUNT
INFORMATION NOTICE REGARDING THE CREATION AND USE OF THE MYLAGOON PARK CORPORATE ACCOUNT
INFORMATION NOTE REGARDING THE INSTALLATION AND USE OF MYLAGOON PARK MOBILE APPLICATIONS
INFORMATION NOTE ON THE RECEPTION AND MANAGEMENT OF YOUR REQUESTS
INFORMATION NOTE ON PARTICIPATION IN MARKETING EVENTS
INFORMATION NOTE ON PARTICIPATION IN OPINION POLLS
INFORMATION NOTE ON THE USE OF THE LAGOON PARK DATA NETWORK
INFORMATION NOTE REGARDING THE COMPLETION OF VARIOUS APPLICATIONS AND FORMS
INFORMATION NOTE ON VIDEO SURVEILLANCE
INFORMATION NOTE ON FIRST AID ASSISTANCE
INFORMATION NOTE ON THE SELECTION AND RECRUITMENT OF CANDIDATES
INFORMATION NOTE REGARDING THE PROCESSING OF DATA OF CONTRACTUAL PARTNERS
To the extent that you believe that the information presented in the Information Notes is not sufficient or you cannot find the information you are looking for, please contact us.
OTHER DATA CONTROLLERS WHO MAY PROCESS YOUR DATA
Your data may also be processed within the Lagoon Park Bucharest complex by other data controllers with whom you can interact in various situations:
• Taxi companies, when you use computer systems located in the reception area, to transmit orders
• Press, when we allow them access to conduct interviews for journalistic purposes
• Contractual partners to whom we allow access to carry out TV production events, product and service promotions, for their own purposes
• Any natural or legal person who carries out professional activities through which he decides the purposes and means of processing in relation to your personal data.
• Any other natural or legal person who processes data for their own purposes on the premises of Lagoon Park Bucharest with or without our authorization.
The data controllers mentioned above have full responsibility for fulfilling all legal obligations to you. according to data protection laws.
This Privacy Policy does not apply to data controllers other than Lagoon Park
UPDATING THE PRIVACY POLICY
We will update the Privacy Policy to the extent necessary to reflect any changes to the processing of your personal data. in relation to our processing activities and legislative changes that may occur in data protection laws.
Please visit this page periodically to ensure that you always have your information up to date.
Last updated: January 2026