1. Introduction

This Privacy Policy explains how BeTransferred collects, uses, stores and protects personal information when you visit our website, submit an enquiry, request a booking, communicate with us or use our services.

BeTransferred is committed to handling personal information responsibly and in accordance with applicable data protection legislation, including the General Data Protection Regulation (EU) 2016/679 (“GDPR”), where applicable.

This Privacy Policy should be read together with our Terms & Conditions and Cancellation & Refund Policy.

2. Who We Are

For the purposes of applicable data protection legislation, the relevant BeTransferred entity acts as the data controller for personal data processed in connection with its own website, customer communications, bookings and business operations, except where another party is independently responsible for particular processing activities.

BeTransferred may also coordinate transportation services through independent chauffeurs, transportation operators or other professional service providers. Where personal information needs to be shared with such parties to fulfil a booking, it will be handled in accordance with this Privacy Policy and applicable data protection requirements.

BeTransferred
Email: office@betransferred.com
Phone: +40 793 146 365
Website: www.betransferred.com

3. Personal Information We Collect

Depending on how you interact with BeTransferred, we may collect different categories of personal information.

3.1 Information you provide directly

This may include:

• full name;
• email address;
• telephone number;
• WhatsApp contact details;
• company name and business contact details;
• pickup and destination addresses;
• journey date and time;
• flight number and flight details;
• number of passengers;
• luggage information;
• vehicle requirements;
• special journey requirements;
• information contained in communications with our team; and
• other information necessary to arrange or provide the requested service.

We only request information that is reasonably necessary for the relevant purpose.

3.2 Booking and journey information

When you request or confirm a journey, we may process information relating to that booking, including:

• booking reference;
• journey details;
• passenger information;
• pickup and destination locations;
• flight information;
• vehicle category;
• chauffeur or service assignment;
• booking status;
• payment status;
• cancellation information;
• modifications to the booking; and
• communications relating to the journey.

Some of this information may be shared with the chauffeur, transportation operator or other service provider responsible for fulfilling the journey.

3.3 Payment information

Where you pay for a service online, payment information may be processed by the relevant third-party payment provider.

For example, where Stripe is used, payment card information is processed by Stripe rather than being directly stored by BeTransferred.

BeTransferred may receive information such as:

• payment status;
• transaction reference;
• amount paid;
• currency;
• payment date; and
• limited payment-related information required for accounting, reconciliation or customer support.

We do not request or intentionally store complete payment card numbers or security codes through email, WhatsApp or our website forms.

4. Information Collected Automatically

When you visit our website, certain technical information may be collected automatically.

Depending on the technologies enabled on the website, this may include:

• IP address;
• browser type;
• device type;
• operating system;
• pages visited;
• referring website;
• approximate location derived from technical information;
• date and time of access;
• website interactions; and
• technical information concerning website performance and security.

This information may be collected through cookies, analytics tools, security systems and similar technologies.

5. Cookies and Similar Technologies

BeTransferred may use cookies and similar technologies to:

• operate and secure the website;
• remember preferences;
• understand website usage;
• measure website performance;
• analyse traffic;
• improve the user experience; and
• where applicable, support advertising and marketing activities.

The specific cookies and technologies used may change as website functionality and third-party services change.

Where consent is legally required for a particular category of cookie or tracking technology, we will request consent through the applicable cookie mechanism.

6. How We Use Personal Information

We may use personal information for the following purposes:

Booking and service coordination

To:

• process booking requests;
• review journey requirements;
• coordinate vehicles and chauffeurs;
• communicate booking details;
• issue booking confirmations and vouchers;
• provide requested transportation services;
• monitor flights where applicable;
• manage journey changes; and
• provide customer support.

Communication

To:

• respond to enquiries;
• communicate with clients;
• send booking-related information;
• provide operational updates;
• contact clients regarding changes or issues affecting a journey; and
• respond to complaints or support requests.

Payments and accounting

To:

• process and verify payments;
• issue invoices or payment documentation;
• reconcile transactions;
• manage refunds;
• prevent payment-related abuse; and
• comply with accounting and financial obligations.

Website operation and security

To:

• operate the website;
• protect against fraud, abuse and malicious activity;
• identify technical problems;
• maintain website security; and
• improve website performance.

Analytics and marketing

Where applicable and permitted by law, we may use information to:

• understand how visitors use our website;
• measure marketing performance;
• improve our advertising;
• understand customer journeys; and
• deliver or measure relevant advertising.

7. Legal Bases for Processing

Depending on the circumstances, BeTransferred may process personal information on one or more of the following legal bases under GDPR:

Performance of a contract

Where processing is necessary to provide a requested service, arrange a booking or take steps at the client’s request before entering into a contract.

Legal obligation

Where processing is necessary to comply with applicable legal, tax, accounting or regulatory obligations.

Legitimate interests

Where processing is necessary for legitimate business interests, such as:

• operating and securing our website;
• preventing fraud;
• managing customer relationships;
• defending legal claims;
• improving services; or
• maintaining appropriate business records,

provided that such interests are not overridden by the individual’s rights and freedoms.

Consent

Where processing requires consent under applicable law, we will request consent before carrying out that processing.

Where processing is based on consent, the individual may withdraw consent at any time. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.

8. Sharing Personal Information

We may share personal information where reasonably necessary to provide our services or operate our business.

Depending on the circumstances, recipients may include:

• chauffeurs;
• transportation operators;
• professional service partners;
• payment providers;
• accounting and financial service providers;
• website hosting providers;
• email and communication service providers;
• analytics providers;
• security and fraud-prevention providers;
• advertising and marketing platforms, where applicable;
• IT and technical service providers; and
• governmental or regulatory authorities where legally required.

We do not sell customer personal information as a business practice.

9. Transportation Partners and Chauffeurs

Where BeTransferred coordinates a journey through an independent chauffeur, transportation operator or service partner, certain information may need to be shared to enable the journey to be performed.

Depending on the service, this may include:

• passenger name;
• contact information;
• pickup location;
• destination;
• pickup time;
• flight information;
• passenger or luggage requirements; and
• other information reasonably necessary to perform the service.

Only information reasonably necessary for the relevant operational purpose should be shared.

10. Payment Providers

Online payments may be processed by third-party payment providers.

Where Stripe is used, Stripe may process payment and transaction information in accordance with its own privacy and data protection documentation.

BeTransferred may receive limited payment information necessary to identify and manage a transaction, but complete payment card details are generally handled directly by the payment provider.

11. International Data Transfers

Some of our service providers may process personal information outside Romania or the European Economic Area.

Where personal information is transferred outside the European Economic Area, BeTransferred will take appropriate steps to ensure that the transfer is carried out in accordance with applicable data protection legislation.

This may include reliance on:

• an applicable adequacy decision;
• Standard Contractual Clauses;
• other legally recognised transfer mechanisms; or
• another lawful basis available under applicable data protection law.

12. Data Retention

We retain personal information only for as long as reasonably necessary for the purposes for which it was collected, unless a longer retention period is required or permitted by law.

Different categories of information may therefore be retained for different periods.

For example:

• booking and transaction information may need to be retained for accounting, tax and contractual purposes;
• customer communications may be retained for as long as necessary to manage the relevant relationship or potential disputes;
• security and technical information may be retained for appropriate security and operational periods; and
• marketing information may be retained according to the applicable consent or legal basis.

When personal information is no longer required, it will be deleted, anonymised or otherwise securely disposed of where reasonably practicable.

GDPR requires the controller to provide either the applicable retention period or the criteria used to determine it.

13. Data Security

BeTransferred takes reasonable technical and organisational measures to protect personal information against:

• unauthorised access;
• accidental loss;
• misuse;
• alteration;
• disclosure; and
• destruction.

However, no internet transmission or electronic storage system can be guaranteed to be completely secure.

Where a data security incident occurs that triggers a legal notification obligation, BeTransferred will take the required steps under applicable law.

14. Your Data Protection Rights

Depending on the circumstances and applicable law, you may have the right to:

• request access to your personal information;
• request correction of inaccurate or incomplete information;
• request deletion of your personal information;
• request restriction of processing;
• object to certain processing;
• request portability of certain personal information;
• withdraw consent where processing is based on consent; and
• lodge a complaint with a competent data protection supervisory authority.

These rights are subject to applicable legal conditions and limitations.

GDPR expressly provides for rights including access, rectification, erasure, restriction, objection and portability, subject to the applicable conditions.

15. How to Exercise Your Rights

To exercise a data protection right or ask a question about how your personal information is processed, contact us at:

Email: office@betransferred.com

Please provide enough information for us to understand and process your request.

We may need to verify your identity before disclosing or modifying personal information.

We will respond to valid requests within the timeframe required by applicable law.

16. Marketing Communications

Where permitted by law, BeTransferred may send marketing communications regarding services, destinations, offers or company updates.

Where consent is required, marketing communications will only be sent after the appropriate consent has been obtained.

You may unsubscribe from marketing communications at any time using the available unsubscribe mechanism or by contacting us.

Transactional and operational communications relating to an existing booking are not considered marketing communications merely because they are sent electronically.

17. Third-Party Websites and Services

Our website may contain links to third-party websites or use third-party services.

Third-party websites and services operate under their own privacy policies.

BeTransferred is not responsible for the privacy practices of third-party websites that are not controlled by us.

18. Children’s Privacy

Our services are intended primarily for adults and business or travel customers.

We do not knowingly collect personal information from children for independent marketing purposes.

Where information relating to a minor is necessary for a journey, such information may be processed where required to provide the requested service and in accordance with applicable law.

19. Automated Decision-Making and Profiling

BeTransferred does not intend to make decisions producing legal or similarly significant effects on individuals solely through automated processing.

Where third-party analytics or advertising technologies involve profiling for marketing purposes, such processing will be subject to the applicable legal requirements and consent mechanisms where required.

20. Changes to This Privacy Policy

BeTransferred may update this Privacy Policy from time to time to reflect:

• changes to our services;
• changes to our website;
• new technologies;
• changes to our service providers;
• changes in applicable legislation; or
• changes to our data processing practices.

The current version will be identified by the Last Updated date displayed at the beginning of this page.

21. Contact

For questions concerning this Privacy Policy or the processing of your personal information, please contact:

BeTransferred
Email: office@betransferred.com
Phone: +40 793 146 365
Website: www.betransferred.com