Respecting the right to personal data, as well as the right to a protected private life, is one of the fundamental missions of the TRICKSHOT group restaurants.

Considering the legislative changes at the level of the European Union by Regulation (EU) 2016/679 regarding the protection of natural persons with regard to the processing of personal data and the free movement of such data and the repeal of Directive 95/46/EC ("GDPR ”) which becomes applicable as of May 25, 2018, we want to make sure that your rights are protected and that you are aware of how TRICKSHOT processes your personal data.

Personal data means any information on an identified or identifiable individual (“subject”); an identifiable individuals is a person who can be identified, directly or indirectly, especially by reference to an identification element, such as name, identification number location data, online ID, or one or several specific elements, inherent to their physical, physiological, genetic, psychic, economic, cultural or social identity.

 

Our four restaurants are: TRICKSHOT Promenada, TRICKSHOT Mega Mall, TRICKSHOT Afi Brașov and TRICKSHOT Afi Cotroceni, and they are managed by the four associated operators:

 

SC Entertainment Business Development (EBD) SRL – TRICKSHOT Promenada, J40/12268/2013, CIF RO 32317652, Calea Floreasca no. 246B, postal code 014476, Spatiul Comercial UNIT.(2F-000), Spatiu G2 in the Promenade in Floreasca City Bucharest, Sect.1, Bucharest.

Operator of the TRICKSHOT PROMENADA location in Calea Floreasca No. 246 B, sector 1, Bucharest, Mall Promenada., et 2;

SC Food Business Development (FBD) SRL – TRICKSHOT Mega Mall, J40/1056/2017, CIF RO36989907, Calea Floreasca no. 246B, postal code 014476, Spatiul Comercial UNIT (2F-000), Space G2 in Promenade in Floreasca City Bucharest, Sect.1, Bucharest.

Operator of the TRICKSHOT MEGA MALL location at Boulevard Pierre de Coubertin 3-5, Bucharest 021901, sector 2, Mega Mall, floor 2;

SC TRICKSHOT ENTERTAINMENT SRL – TRICKSHOT Afi Brașov, J40/18040/2021, RO45091114, cu sediul în Sediul in Bucuresti, Str. Toamnei, nr. 117, parter, ap. 2+6, sector 2.

Operator of the TRICKSHOT AFI BRASOV location from Boulevard 15 Noiembrie No. 78, Afi Brașov mall, 1st floor.

and

SC TRICKSHOT RESTAURANT SRL – TRICKSHOT Afi Cotroceni, J40/18090/2021, RO45094943, with headquarters in Bucharest, Str. Autumn, no. 117, ground floor, apartment 2+6, sector 2.

Operator of the TRICKSHOT AFI Cotroceni location in Bd. General Paul Teodorescu 4, 1st floor Bucharest.

 

Please read below, in the dedicated sections, details about:

What types of personal data do we process?

Personal data of minors.
Sensitive data.
For what purpose and on what grounds do we process your personal data?
To whom do we transmit your personal data?
Do we collect personal data from third parties?
Do we transfer your data outside the EU/EEA?
Your provision of personal data of other natural persons.
How long do we keep your personal data?
What are your rights?
Is your data safe?
Links to other websites.
Questions or complaints.
Policy Changes

WHAT TYPES OF PERSONAL DATA DO WE PROCESS?

Customers or prospective customers:

We collect personal data as a result of most interactions with you, as well as in other aspects of our business. Categories of personal data we collect:

a) your surname and first name, email address, phone number and address;
b) information you provide about your marketing preferences or during participation to contests, raffles or certain promotional offers;
c) your provided personal data for registration in a program for your members and/or in a loyalty program;
d) reviews and opinions on our services;
e) any other type of information you choose to provide

At the same time, surveillance cameras and other security measures on our properties may capture or record images of guests in public areas (such as the entrance to the restaurant, hallways), as well as you location data (through images caught by surveillance cameras, access cards and other technologies).

You can choose what personal data you wish to provide at any time. However, if you choose not to provide certain personal data, in case our request grounds are the observance of a contractual obligation or obligations required for concluding a contract, we are not able to provide certain services, for example: if you do not wish to provide surname, first name, email address or phone number, in case you wish to make a reservation or place an order, we cannot make the reservation or order.

If you are a member of the TRICKSHOT loyalty program:

We also process the data obtained through the loyalty program. For more details related to the data processed, the method, purposes and grounds of the processing, please consult the privacy policy presented in the TRICKSHOT application.

If you are not a member, we invite you to read more on www.trickshot.ro website

Prospective employees:

We collect the information in your resume, as well as any other information sent with your resume.

PERSONAL DATA OF MINORS

We do not process personal data of minors under 16 years of age.

SENSITIVE DATA

The term “sensitive data” refers to racial or ethnic origin, political beliefs, religious denomination or philosophical beliefs or membership to syndicates and processing of genetic data, biometric data, health data or data referring to sexual life or sexual orientation.

Generally, we collect sensitive information only if you wish to provide them. We can use health data provided by you for better service and for special needs (for example, preparing food without certain ingredients to which you are allergic, providing access to disabled persons).

FOR WHAT PURPOSES AND GROUNDS DO WE PROCESS YOUR PERSONAL DATA?

If you are a customer:

a) Restaurant booking or, in case of offer or booking requests sent by you for certain organized events or events that can be organized

Purpose: we process your personal data (i) to book a seat in the restaurant and (ii) to answer offer or booking requests send by you.

Grounds: concluding a contract

b) Bowling and billiard booking

Purpose: we process your personal data (i) to book a bowling lane or a billiard table and (ii) to answer offer or booking requests sent by you.

Grounds: concluding a contract

c) Pick-up or delivery orders

Purpose: we process your personal data to fulfil the orders placed by you, irrespective of whether you choose to serve them on location or for personal pick-up or delivery.

Temei: executarea contractului de prestări servicii de restaurant

d) Feedback:

Purpose: we process your personal data to make sure you had a good time with us.

Grounds: our legitimate interest to constantly improve the services we provide and to offer services as adequate as possible and compliant with our customers’ standards

e) Marketing:

Purpose: we process your personal data for marketing purposes, such as commercial newsletters and marketing communications for new products and services or other offers we believe could interest you.

Grounds: we rely on the legitimate interest to promote our services by sending offers we deem of interest to you (please see “Right to Oppose” in “Your Rights” Section).

If necessary, according to the applicable laws, we obtain you consent before processing your personal data for direct marketing purposes. In such case, we inform you that you can withdraw your consent for marketing processing at any time, in which case you no longer receive any marketing communications from us.

We include an unsubscribe link you can use if you no longer wish to receive messages from us.

At the same time, on the occasion of organizing certain events in our restaurants, we may take several photographs, and some of them may be shared online to show others how our events take place. In such case, because we keep in mind your right to privacy, we make sure the photographs do not show certain people and we do our best to notify you that photographs are taken (for objections on our photographs please see “Right to Oppose” in “Your Rights” Section).

f) Other communications: by email, mail, phone or SMS

Purpose: these communications are made for a specific reason, such as: (i) to answer your requests, (ii) if did not complete an online booking, we may send you an email to remind you to complete the booking, (iii) to notify you about the way we settled complaints and/or incidents occurred during the time spent in our restaurant.

Legal grounds: our legitimate interest to provide services at the highest standards by settling possible requests/complaints and to ensure our full availability.

g) Analysis, improvement and research:

Purpose: to constantly ensure the qualitative evolution of our services, we make sure we analyse each complaint/suggestion from you, therefore we prepare statistical reports to identify issues, degree of repetition and to find the best solutions for remedying them

Grounds: We rely on our legitimate interest to provide services that meet your and TRICKSHOT's standards.

 

Users of our website www.trickshot.ro

Purpose: monitoring traffic in order to identify errors and/or any other malfunctions of our website.

Grounds: we rely this data processing activity on our legitimate interest, namely making available a completely functional website for you by repairing all errors, as well as continuously improving it

Representatives or contact persons of our providers or business partners

Purpose: developing contractual relations with our providers or business partners.

Grounds: performing a contract.

Prospective employees:

Purpose: assessing your employment application.

Grounds: concluding a contract

Employees:

Please see the privacy policy related to employees, brought to your attention at the time of employment and available at any time in the human resources department.

 

For all categories of persons above, we may also process your data in the context of the following activities:

a) Internal restructuring and reorganizations or for sales of assets or social parts/shares:

Purpose: we process your data for performance of operations specified above

Grounds: legitimate interest to perform the operations, especially under the conditions they would be unachievable in the absence of processing your data

However, we assure you that this possible processing shall take place according to this policy and implementing measures providing data privacy.

b) Security:

Purpose: we process personal data for property security and physical integrity of persons.

Grounds: we rely on our legitimate interests to provide protection for your properties, restaurant’s properties, as well as individual protection.

c) Legal reasons:

Purpose: in certain cases, we must process provided information that may include personal data in order to settle legal disputes or complaints, for inquiries and observing legal applicable regulations, in order to enforce an agreement or to comply to the requests of public bodies to the extent such requests meet the conditions required by law.

Grounds: the reasons for processing can be represented by legal obligation (if we have a legal obligation to disclose certain personal data to public authorities) or by our legitimate interest to resolve possible disputes and/or complaints.

TO WHOM DO WE TRANSFER YOUR PERSONAL DATA?

In order to provide you with the expected level of hospitality and provide you with high quality services, we may pass your personal information between our three restaurants (TRICKSHOT Promenada, TRICKSHOT Mega Mall, TRICKSHOT Afi Brasov, TRICKSHOT Afi Cotroceni), to our suppliers services and other third parties as detailed below:

a) Providers: in order to provide the requested services, in some cases, we may need to transfer some of your personal data to providers, and they have the capacity of proxies and they process the data on behalf of, for and according to our directions (such as software, IT, accounting services providers, marketing agencies, medical services providers, payroll providers).

b) TRICKSHOT restaurants: for similar purposes or in relation to those for which they were collected.

c) Events: if you participate in certain events within the restaurant, and this event is organized in collaboration with third parties, your personal data provided in order to participate in the events may be shared with the other organizers and, if applicable, with other event participants .

d) Business partners: in certain cases, we associate with other companies to provide products, services or offers (for example the partnership with MasterCard that implies awarding discounts to customers’ bill paying with a MasterCard bank card).

e) Cosponsors of promotions: in certain cases, we cosponsor promotions, raffles, lotteries, contests or competitions with other companies or we may provide prizes for lotteries and contests sponsored by other companies. If you participate to such lotteries or contests, we may send your personal data to the collaborating sponsor or to a third sponsor

 

Authorities and/or public institutions for: (i) observing legal provisions, (ii) answering their requests, (iii) for public interest reasons (e.g.: national security).

The privacy of your data is important to us, therefore, where possible, sending personal data according to the ones above takes place only based on a privacy commitment from the recipients, guaranteeing that such data is kept safe and the provision of such information takes place according to the laws in force and the applicable policies. In any case, every time we only send the recipients information that is strictly necessary for achieving the purpose.

DO WE COLLECT PERSONAL DATA FROM THIRD PARTIES?

In order to offer you the expected level of hospitality and to provide you with the best level of services, it is possible that the personal data provided to the TRICKSHOT Promenada restaurant will also be transmitted to TRICKSHOT Mega Mall, TRICKSHOT Afi Brasov and/or TRICKSHOT Afi Cotroceni and vice versa. Your personal data may also be shared with our business partners and other third parties as detailed below:

a) TRICKSHOT restaurants: for similar purposes or in relation to those for which they were collected.

b) Partners such as: BestJobs, publi24, OLX, professional high schools and vocational schools, LinkedIn, other providers of professional training in order to hire staff.

c) Co-sponsors of promotions: In certain cases, we co-sponsor promotions, sweepstakes, raffles, competitions or contests with other companies or may provide prizes for sweepstakes and contests sponsored by other companies. If you participate in sweepstakes or contests, we may collect your personal data from the collaborating sponsor or a third-party sponsor for the purpose of conducting the sweepstakes and awarding the prizes.

In any case, we assure you that your data collected from third parties are processed under the same conditions as if they had been directly collected from you. At the same time, we shall only collect what is necessary for achieving our purposes (please see Section “FOR WHAT PURPOSES AND ON WHAT GROUNDS DO WE PROCESS YOUR PERSONAL DATA?”).

Additionally, when we contact you for the first time, we inform you, first of all, about the source where we obtained your personal data.

DO WE TRANSFER YOUR PERSONAL DATA OUTSIDE EU/EEA?

No, your data will not be transferred to countries that are not part of the European Union or the European Economic Area.

PROVISION OF PERSONAL DATA OF OTHER INDIVIDUALS BY YOU

If you provide us with personal data of other individuals, please inform them before this disclosure about the method in which it is to be processed, as described in this privacy policy.

HOW LONG DO WE KEEP YOUR PERSONAL DATA?

Your personal data is kept for the duration of the purposes detailed in this policy, unless a longer retention period is required or permitted by applicable law (for example surveillance camera recordings will not be kept for more than 30 days ).

We constantly review the need to retain your personal data, and to the extent that processing is no longer necessary and there is no legal obligation to retain the data, we will destroy your personal data as soon as possible and in a way that does not can still be recovered or reconstructed (for example, we will delete/destroy all data of people who were not hired following interviews, if there is no serious prospect of employment in the future).

If personal information is printed on paper, it will be securely destroyed by shredder, and if it is saved on electronic media, it will be deleted by technical means to ensure that the information cannot be recovered. or reconstituted later.

WHAT RIGHTS DO YOU HAVE?

As subject, you have the following rights provided by GDPR:

• a) The right to access: you can request us (i) a confirmation if personal data is processed or not and, if yes, access to that data and information about it, as well as (ii) a copy of the personal data we have (art. 15 of GDPR);
• b) The right to rectification: you can inform us about any change in your personal data or you can ask us to correct the personal data we have on you (art. 16 of GDPR);
• c) The right to delete (“the right to be forgotten”): in certain cases (for example (i) in case data is illegally collected, (ii) the term for storing the data expired, (iii) you exercised your right to oppose or (iv) data processing takes place based on consent and you withdrew your consent), you can ask us to delete the personal data we have about you (art. 17 of GDPR);
• d) The right to restrict processing: in certain cases (for example if you contest the accuracy of such data or the processing legality), you can ask us to restrict your data processing for a certain period (art. 18 of GDPR);
• e) The right to data portability: you can ask us to send your personal data to a third party or directly to you (art. 20 of GDPR);
• f) The right to object: in certain situations (such as processing that has as its legal basis the legitimate interest), you can ask us to stop processing your data (art. 21 of the GDPR).

In case we use your personal data based on your consent, you care entitled to withdraw this consent at any time. In such case, your data shall no longer be processed by us, except for the case when a legal provision obliges us to keep and archive them. In any case, we shall inform you if there is such a legal provision and we shall expressly specify it.

In order to find out how you can exercise any of the rights above, please see section “Questions or Complaints”.

IS YOUR DATA SAFE?

We take your personal security very seriously, which is why we take important security measures necessary to protect against unauthorized access to data or unauthorized modification, disclosure or destruction of data. This involves internal reviews of data collection, retention and processing practices and security measures, as well as physical security measures to protect against unauthorized access to the systems where we store personal data.

Solicit our furnishings for our pre-paid services and your partners if the date of delivery is necessary to protect your imports without the authorization of the date without modification, or if the date is not authorized.

LINKS TO OTHER WEBSITES

Our website contains links to third party websites. Please note that we are not responsible for the collection, use, retention, sharing or disclosure of data or information by such third parties. If you use or provide information on third-party sites, the terms and privacy policy of those sites apply. We advise you to read the privacy policy of the websites you visit before submitting personal data.

The use of Internet services provided by our restaurants is subject to the terms of use and privacy policy of the Internet providers. You can access those terms and policies by using the links on that service's login page or by visiting your Internet provider's website.

QUESTIONS OR COMPLAINTS

If you have any questions or concerns related to the processing of your personal data or if you wish to exercise any of the rights mentioned above, you are welcome to contact us in writing at the following e-mail address: marketing@trickshot.ro.

Also, to the extent that you do not have electronic means or do not want to use them, you can make a written request that you submit to the address Calea Floreasca No. 246 B, sector 1, Bucharest, Mall Promenada., et 2 , TRICKSHOT.

For any other additional information, you can contact us at marketing@trickshot.ro.

After submitting the request, a TRICKSHOT representative will contact you and request additional information to identify you and facilitate the exercise of the right. It is important that you comply with the TRICKSHOT representative's request and provide all necessary information to be able to identify you, otherwise, for security reasons, we will have to reject your request.

In any case, we will respond within 30 days of receiving the request.

To the extent that you are not satisfied with the way in which your request was resolved, you can submit a complaint to the National Supervisory Authority for the Processing of Personal Data.

 

POLICY AMENDMENTS

This Privacy Policy is subject to periodic updates according to changes in European or national regulations regarding the protection of personal data. If we make material changes to it, we will post a link to the revised policy on the home page of our website. If we make significant changes that will have an impact on your rights and freedoms (for example, when we start processing your personal data for purposes other than those specified above), we will contact you before we start this processing.

To help you keep track of the most important changes, we will include a change history below to acknowledge changes to the Privacy Policy.

Last update: 08.10.2024.