Observing the right to personal data protection, as well as the right to private life is one of the fundamental missions of restaurants in Trickshot Group.

Given the legislative changes on European Union level through Regulation (EU) 2016/679 on the protection of individuals in terms of personal data processing and the free circulation of such data and for the abrogation of Directive 95/46/EC (“GDPR”) that becomes applicable starting with 25th of May 2018, we wish to make sure your rights are protected and you are aware of the way 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 three restaurants are: Trickshot Promenada, Trickshot Mega Mall and Trickshot Afi Brașov, and they are managed by three associated operators:

 

SC Entertainment Business Development (EBD) SRL – Trickshot Promenada, J40/12268/2013, CIF RO 32317652, CALEA FLOREASCA NR.246B, postal code 014476, COMMERCIAL AREA UNIT.(2F-000), G2 AREA IN PROMENADA IN FLOREASCA CITY BUCHAREST, SECTOR 1, BUCHAREST

Working point: Calea Floreasca Nr.246 B, sector 1, Bucuresti, Mall Promenada., et 2;

 

SC Food Business Development (FBD) SRL – Trickshot Mega Mall, J40/1056/2017, CIF RO36989907, CALEA FLOREASCA NR.246B, postal code 014476, COMMERCIAL AREA UNIT (2F-000), G2 AREA IN PROMENADA IN FLOREASCA CITY BUCHAREST, SECTOR 1, BUCHAREST.

Working point: 3-5 Pierre de Coubertin Blvd., Bucharest 021901, sector 2, Mega Mall, 2nd floor; and;

 

and

 

SC TRICKSHOT ENTERTAINMENT SRL – Trickshot Afi Brașov, J40/18040/2021, RO45091114, with offices in Bucharest, 117 Toamnei St., ground floor, apt. 2+6, sector 2.

Working point : 78th “15 Noiembrie” Blvd., Mall Afi Brașov, 1st floor.

 

 

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

 

• What types of personal data do we process?
• Personal data of minors
• Sensitive data
• For what purposes and grounds do we process your personal data?
• To whom do we transfer your personal data?
• Do we collect personal data from third parties?
• Do we transfer your data outside EU/EEA?
• Provision of personal data of other individuals by you
• How long do we keep your personal data?
• What rights do you have?
• Is your data safe?
• Links to other websites
• Questions or complaints
• Policy amendments

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.

 

Members of Trickshot loyalty program:

At the same time, we process data obtained through the loyalty program. For more details about the processed data, methods, purposes and grounds of processing, please see the privacy policy on Trickshot app.

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.

Users of our website www.trickshot.ro:

The mere access to our website does not lead to collecting your personal data, except for the case when you willingly enter certain data (for example online bookings, vacancy applications, certain requests/applications etc.).

However, we collect the time and date of accessing the website and the IP address used to access our website.

Representatives or contact persons for our providers or business partners:

We collect the surname, first name, position and any other data provided by you or the company you represent.

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.

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?

Customers

• 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 compliant with 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 processing reasons may be the legal obligation (in case we have the legal obligation to disclose certain personal data to public authorities) or our legitimate interest

to settle possible disputes and/or complaints

TO WHOM DO WE TRANSFER YOUR PERSONAL DATA?

In order to provide the expected level of hospitality and to supply high quality services, we may send your personal information between our three restaurants (Trickshot Promenada, Trickshot Mega Mall and Trickshot Afi Brasov), to our services providers and to other third parties, as shown below in detail:

• 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 what they have been collected for
• c) Events: if you attend certain events in the restaurant, and this event is organized in collaboration with third parties, your personal data given for attending the events may be shared with the other organizers and, if applicable, with other participants to the event.
• 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 provide the expected level of hospitality and to supply the best level of services, the personal data provided to Trickshot Promenada restaurant may also be sent to Trickshot Mega Mall, and/or Trickshot Afi Brasov and vice versa. At the same time, your personal data may be sent to our business partners and other third parties, as shown below in detail:

• a) Trickshot Restaurants: for purposes similar or related to the ones for which they have been collected.
• b) Partners such as: BestJobs, publi24, OLX, professional high schools and vocational schools, LinkedIn, other professional training providers for staff hiring.
• c) Cosponsors of promotions: in certain cases, we cosponsor promotions, lotteries, raffles, competitions or contests with other companies or we may provide prizes for lotteries and contents sponsored by other companies. If you participate to lotteries or contents, we may collect your personal data from the collaborating sponsor or a third sponsor in order to organize them and to award 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 shall not be sent to third parties that are not part of the European Union or 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 entire period of achieving the purposes detailed in this policy, unless a longer keeping period is necessary or permitted by the applicable law (for example recordings of surveillance cameras shall not be kept for more than 30 days). We constantly review the need to keep your personal data, and in case the processing is no longer necessary and there is no obligation imposed by law to keep data, we destroy your personal data as soon as possible and in such a way that they cannot be recovered or reconstituted (for example we delete/destroy all data of individuals not employed after interviews, if there is not serious perspective of employment in the future). If personal information is printed on paper, it is destroyed in a safe manner, by shredder, and if they are stored by electronic means, they are deleted by technical means ensuring the information cannot be subsequently recovered or reconstituted.

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 oppose: in certain cases (for example processing with legitimate interest as legal ground), you can ask us not to process your data anymore (art. 21 of 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, therefore, we take important security measures, necessary for protection against unauthorized access to data or unauthorized change, disclosure or destruction of data. This implies internal reviews of data collecting, keeping and processing practices and of security measures, but also physical security measures for the protection against unauthorized access to systems where we store personal data. We ask our services providers as well as our business partners to take all necessary measures for protection against unauthorized access to data or unauthorized change, disclosure or destruction of data.

LINKS TO OTHER WEBSITES

Our website contains links to third party websites. Please note that we do not undertake liability for the collection, use, keep, share or disclosure of data or information by such third parties. In case you use or provide information on third party websites, the privacy terms and policy of those websites apply. We recommend you read the privacy policy of the websites you visit before sending personal data. The use of internet services provided by our restaurants is in the scope of use terms and privacy policy of internet providers. You can access these terms and policies using the links on the authentication page of the service or accessing the website of the internet provider.

QUESTIONS OR COMPLAINTS

If you have questions or concerns about the processing of your personal data or if you wish to exercise any of the rights specified above, please contact us in writing at the following email address: marketing@trickshot.ro. At the same time, if you do not own electronic means or you do not wish to use them, you can submit a written request at 246 B Calea Floreasca, sector 1, Bucharest, Mall Promenada, 2nd floor, Trickshot. For any other additional information, you can contact us at marketing@trickshot.ro. After sending the request, a Trickshot representative will contact you and request additional information for your identification and for facilitating the exercising of the right. It is important to comply with the request of the Trickshot representative and to provide all necessary information for your identification, otherwise, for security reasons, we will need to reject your request. In any case, we will answer within 30 days from receiving the request. To the extent you are not satisfied with the way your request had been settled, you can submit a complaint with the National Authority for Supervision of Personal Data Processing.

POLICY AMENDMENTS

This Privacy Policy is subject to periodical updates depending on the changes occurring in the European or national regulations on personal data protection. If we perform material changes to them, we publish a link to the reviewed policy on our website’s homepage. If we make significant changes impacting your rights and freedoms (for example, when we start processing your personal data for other purposes than the ones specified above), we contact you before starting this processing. To help you follow the most important changes, we include below a history of amendment for admitting the changes to the Privacy Policy.
Last update: 07th of November 2023