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Privacy Policy

Effective date: 23 August 2026

This Privacy Policy describes how SILENUS SRL, operating under the Winetours Moldova trademark, collects, uses, stores, transfers and protects the personal data of persons who use the www.winetours.md website, request information, make reservations or use our services.

The protection of your personal data is important to us. Personal data is processed in accordance with Law No. 195/2024 on Personal Data Protection, as well as, where applicable, Regulation (EU) 2016/679 on the protection of personal data (GDPR) and other applicable legislation.

1. PERSONAL DATA CONTROLLER

The personal data controller is:

Legal name: SILENUS SRL
Trademark: Winetours Moldova
IDNO: 1012600022176
Registered address: Chișinău municipality, Bubuieci commune, 13 Tereșkova Street
Business address: Chișinău, MD-2004, 23/2 P. Movilă Street
Telephone: +373 68 442 525
Email: info@winetours.md

For any questions concerning the processing of personal data or the exercise of your rights, you may contact us at info@winetours.md.

2. PRINCIPLES OF DATA PROCESSING

SILENUS SRL processes personal data in accordance with the following principles:

  • lawfulness, fairness and transparency;

  • collection of data for specified, explicit and legitimate purposes;

  • collection only of data that is necessary for the stated purposes;

  • keeping data accurate and, where necessary, up to date;

  • storing data only for as long as necessary;

  • ensuring the integrity and confidentiality of data;

  • implementing appropriate technical and organisational measures to protect data;

  • accountability for compliance with personal data protection legislation.

3. WHAT PERSONAL DATA WE MAY COLLECT

Depending on how you use the Winetours Moldova website and services, we may process the following categories of data.

3.1. Data provided for service reservations

In order to make and manage a reservation, we may request:

  • first and last name;

  • telephone number;

  • email address;

  • number of persons included in the reservation;

  • selected service or package;

  • requested date and time;

  • preferred language;

  • information concerning the requested accommodation, transport or tour;

  • special requests communicated by the customer;

  • information necessary to modify or cancel a reservation;

  • correspondence with the Winetours Moldova team concerning the reservation.

Please do not provide us with personal data that is not necessary for providing the requested service.

Where a special request contains special categories of personal data, including health-related information, such data will only be processed where necessary and where an appropriate legal basis exists under applicable legislation.

3.2. Payment and transaction data

When services are paid for, we may process:

  • the amount paid;

  • currency;

  • payment date and status;

  • transaction number or reference;

  • information necessary for payment confirmation, invoicing, refunds and accounting.

SILENUS SRL does not request or store the full bank card number, CVV/CVC code or other card authentication data.

The data required to make a card payment is entered and processed through the secure infrastructure of the payment processor. SILENUS SRL only receives the information necessary to confirm and manage the transaction.

3.3. Data provided when contacting us

When you contact us through a website form, email, telephone, WhatsApp or other communication channels made available by Winetours Moldova, we may process:

  • your name;

  • contact details;

  • the content of your message;

  • information and documents voluntarily provided;

  • communication history.

3.4. Technical data and website usage data

When you access the website, certain technical information may be collected automatically, including:

  • IP address;

  • device type;

  • browser type and version;

  • operating system;

  • date and time of access;

  • pages visited;

  • technical information concerning website operation;

  • cookie identifiers or similar identifiers, depending on the preferences expressed by the user.

This information may be used for the technical operation and security of the website. Analytics or marketing data is processed only in accordance with applicable legislation and, where required, after obtaining the user's consent.

3.5. Data used for newsletters and marketing communications

If you voluntarily subscribe to a newsletter or request to receive offers and promotional information, we may process:

  • your name, if provided;

  • email address;

  • communication preferences;

  • information concerning consent given and its withdrawal.

Receiving marketing communications based on consent is not a condition for making a reservation or receiving Winetours Moldova services.

4. PURPOSES AND LEGAL BASES FOR PROCESSING

Personal data is processed only where an appropriate legal basis exists.

4.1. Processing requests and reservations

Data is used for:

  • processing reservation requests;

  • checking service availability;

  • communicating with the customer;

  • confirming reservations;

  • modifying or cancelling reservations;

  • providing tours, transport, accommodation and other booked services.

Legal basis: taking steps at the request of the data subject prior to entering into a contract and performance of the contract.

4.2. Sharing data with booked service providers

Where fulfilment of a reservation requires the involvement of a winery, guesthouse, accommodation provider, transport provider or another partner, the strictly necessary data may be shared with the relevant provider.

Legal basis: performance of the contract and provision of the service requested by the customer.

4.3. Payment processing, invoicing and financial/accounting records

Data may be used for:

  • processing and confirming payments;

  • issuing payment documents;

  • processing refunds;

  • financial and accounting records;

  • complying with tax and other legal obligations.

Legal basis: performance of the contract and compliance with legal obligations applicable to SILENUS SRL.

4.4. Customer communication and support

Data is used to respond to requests, questions, complaints and other communications addressed to Winetours Moldova.

Legal basis: performance of the contract, taking pre-contractual steps or, where appropriate, the legitimate interests of SILENUS SRL in managing customer relationships and handling requests received.

4.5. Website security and prevention of misuse

Certain technical data may be processed for:

  • protecting the website and information systems;

  • detecting technical incidents;

  • preventing fraud and unauthorised access;

  • investigating potential misuse;

  • maintaining the security of the services.

Legal basis: the legitimate interests of SILENUS SRL in protecting the website, its information systems, the company's activities and users.

4.6. Website usage analytics

With the user's consent, where such consent is required, we may use analytics tools, including services such as Google Analytics, to understand how the website is used and to improve its structure, content and services.

Legal basis: the user's consent, where required by applicable legislation.

4.7. Newsletter and direct marketing

Data may be used to send offers, news and promotional materials where the user has consented to receiving such communications.

Legal basis: the consent of the data subject.

Consent may be withdrawn at any time as easily as it was given, without affecting the lawfulness of processing carried out before its withdrawal.

4.8. Establishment, exercise or defence of legal rights

Data may be retained and used where necessary for handling complaints or disputes, or for the establishment, exercise or defence of the rights of SILENUS SRL or data subjects.

Legal basis: legitimate interests and/or applicable legal obligations, as appropriate.

5. MANDATORY OR OPTIONAL PROVISION OF DATA

Data requested in the reservation form and marked as mandatory is required in order to process the request and provide the service.

If you refuse to provide data necessary for entering into or performing a contract, we may be unable to process or confirm your reservation.

Data requested for marketing, analytics or other purposes that are not necessary for providing the service is optional. Refusing or withdrawing consent does not affect your ability to use the main services offered by Winetours Moldova.

6. DATA RECEIVED FROM OTHER PERSONS

In certain situations, a reservation may be made by one person on behalf of other participants.

In such cases, we may receive participants' data from:

  • the person making the reservation;

  • a group representative;

  • an agency or partner involved in organising the service;

  • another provider involved in fulfilling the reservation.

A person who provides us with another person's data must ensure that they are authorised to provide such data and that the relevant persons have been properly informed.

7. WITH WHOM WE MAY SHARE PERSONAL DATA

SILENUS SRL limits access to personal data to persons and organisations that need such data for the purposes described in this Policy.

Depending on the requested services, data may be shared with the following categories of recipients:

  • wineries;

  • guesthouses, hotels and other accommodation providers;

  • transport companies and tourism service providers;

  • payment processors and financial institutions;

  • hosting and IT infrastructure providers;

  • maintenance and technical support providers;

  • email and communication service providers;

  • analytics and statistics service providers, only where permitted by law;

  • marketing service providers, where the user has provided consent when required;

  • accounting, legal or audit service providers;

  • public authorities, courts or other competent bodies where disclosure is required or permitted by law.

Only the data necessary for the relevant purpose is provided to suppliers and partners.

Processors acting on behalf of SILENUS SRL are required to ensure confidentiality and security and to process data only in accordance with applicable instructions and contractual obligations.

8. PROCESSING OF DATA FOR ONLINE PAYMENTS

Online payments are processed through a specialised payment service provider.

When making an online payment, card details are entered directly into the secure infrastructure of the payment processor.

SILENUS SRL does not store:

  • the full card number;

  • the CVV/CVC code;

  • passwords or authentication codes used to authorise the payment.

SILENUS SRL may receive information such as transaction status, amount, currency, payment date and transaction reference to the extent necessary to manage the reservation and comply with financial and accounting obligations.

9. TRANSFERS OF DATA OUTSIDE THE REPUBLIC OF MOLDOVA

Certain technical, analytics, communication, cloud or other service providers used by SILENUS SRL may process data outside the Republic of Moldova.

Where such processing involves a transfer of personal data to another country or an international organisation, SILENUS SRL will make such transfers only in compliance with personal data protection legislation.

Depending on the circumstances, the transfer may be based on:

  • a decision recognising an adequate level of protection;

  • appropriate safeguards provided by law;

  • applicable contractual clauses;

  • another lawful condition permitting the transfer.

Where services such as Google Analytics or other international providers are used, certain technical data and online identifiers may be processed outside the Republic of Moldova.

Users may request further information about international transfers and applicable safeguards by sending a message to info@winetours.md.

10. COOKIES AND SIMILAR TECHNOLOGIES

The www.winetours.md website may use cookies and similar technologies.

Cookies may be used for:

  • the technical operation of the website;

  • storing user settings;

  • security;

  • analytics and statistics;

  • measuring website performance;

  • marketing, where such technologies are used.

Cookies that are strictly necessary for the operation of the website may be used without enabling optional functionality.

Optional cookies and technologies for which legislation requires consent will only be activated after the user has expressed their choice.

Users must be able to accept, reject or change their preferences regarding optional cookies through the consent management tool available on the website.

Detailed information about the types of cookies used, their providers, purposes and duration will be provided separately in the Cookie Policy.

11. GOOGLE ANALYTICS AND OTHER ANALYTICS SERVICES

The website may use Google Analytics or similar tools to obtain statistical information about website usage.

These services may process information such as:

  • pages viewed;

  • duration of visits;

  • device type;

  • browser used;

  • approximate location inferred from technical data;

  • IP address, depending on service configuration;

  • online identifiers.

Where the use of such technologies requires consent, they will not be activated before the user has expressed their choice.

The user may subsequently change their choice through the cookie settings available on the website.

12. MARKETING COMMUNICATIONS AND NEWSLETTERS

Winetours Moldova may send offers, information about services, news or other commercial communications to persons who have requested or agreed to receive them.

Where processing is based on consent, that consent:

  • must be freely given;

  • must be specific and informed;

  • must not be given through a pre-ticked box;

  • must not be a condition for making a reservation where marketing is not necessary for fulfilling that reservation;

  • may be withdrawn at any time.

After consent is withdrawn or an objection to direct marketing is made, the data will no longer be used to send the relevant communications.

13. HOW LONG WE RETAIN DATA

Personal data is retained only for as long as necessary to fulfil the purposes for which it was collected or for the period required by applicable legislation.

When determining retention periods, we take into account:

  • the nature of the data;

  • the purpose for which it was collected;

  • the duration of the contractual relationship;

  • financial, accounting and tax obligations;

  • legal document retention obligations;

  • applicable limitation periods for bringing or defending claims;

  • the need to handle complaints and disputes;

  • the consent of the data subject, where processing is based on consent.

In particular:

  • data relating to reservations and contracted services is retained for the period necessary to provide the service and thereafter for as long as necessary to comply with legal obligations and protect legal rights;

  • financial and accounting documents are retained in accordance with the periods required by applicable legislation;

  • data relating to requests and correspondence is retained until the request has been resolved and, where necessary, thereafter for handling potential complaints;

  • data used for marketing based on consent is used until consent is withdrawn or the relevant purpose ceases, without prejudice to the retention of evidence necessary to demonstrate compliance with legal obligations;

  • the duration of cookies and similar identifiers is indicated in the Cookie Policy.

After the applicable periods expire, data is deleted, anonymised or archived only where there is a legal basis for continued retention.

14. DATA SECURITY

SILENUS SRL implements appropriate technical and organisational measures to protect personal data against:

  • unauthorised access;

  • loss;

  • destruction;

  • unauthorised alteration;

  • unauthorised disclosure;

  • unlawful or accidental use.

Such measures may include, where appropriate:

  • control and restriction of access to data;

  • the use of passwords and authentication mechanisms;

  • updating and protecting information systems;

  • backups;

  • secure connections;

  • security measures applied to IT infrastructure;

  • internal rules governing employee and contractor access to data;

  • confidentiality obligations;

  • selection of providers that offer appropriate data protection safeguards.

Employees and contractors of SILENUS SRL are permitted to access personal data only to the extent necessary to perform their duties.

15. RIGHTS OF DATA SUBJECTS

Subject to the conditions provided by Law No. 195/2024, data subjects have the following rights:

15.1. Right to information

You have the right to receive clear and transparent information about how your data is processed.

15.2. Right of access

You have the right to request confirmation as to whether or not we process your data and, where such processing takes place, to request access to the data and information relating to its processing.

15.3. Right to rectification

You have the right to request correction of inaccurate data and completion of incomplete data.

15.4. Right to erasure

In cases provided by law, you may request deletion of your personal data.

The right to erasure is not absolute. Certain data may be retained where a legal obligation or another legal basis requires or permits its retention.

15.5. Right to restriction of processing

In circumstances provided by law, you may request a temporary restriction on how your data is used.

15.6. Right to data portability

In cases provided by law, you may request to receive the data you have provided to us in a structured, commonly used and machine-readable format, or to have that data transmitted to another controller where technically feasible.

15.7. Right to object

You have the right, on grounds relating to your particular situation, to object to certain processing based on legitimate interests.

In the case of direct marketing, you have the right to object at any time without having to justify your decision.

15.8. Right to withdraw consent

Where processing is based on consent, consent may be withdrawn at any time.

Withdrawal of consent does not affect the lawfulness of processing carried out before consent was withdrawn.

15.9. Rights concerning automated decision-making

You have the rights provided by law in relation to decisions based solely on automated processing, including profiling, which produce legal effects concerning you or similarly significantly affect you.

15.10. Right to lodge a complaint

If you believe that your data is being processed in breach of applicable legislation, you have the right to lodge a complaint with the National Centre for Personal Data Protection (CNPDCP) and to use any other legal remedies provided by law.

16. HOW TO EXERCISE YOUR RIGHTS

To exercise your rights concerning personal data, you may send us a request at:

Email: info@winetours.md

To protect your data and prevent it from being disclosed to an unauthorised person, we may request additional information necessary to verify the identity of the applicant.

We will respond to requests without undue delay and, as a rule, within no more than one month from receipt of the request.

In the case of complex requests or a large number of requests, this period may be extended in accordance with the law. In such a case, the data subject will be informed of the extension and the reasons for it.

The exercise of rights is generally free of charge. In the case of manifestly unfounded or excessive requests, particularly repetitive requests, measures permitted by applicable legislation may be applied.

17. DATA RELATING TO MINORS

Winetours Moldova reservation services are primarily intended for persons who have the legal capacity to enter into contracts.

Where data concerning a minor is necessary for providing a service, such data must be provided by a parent, legal representative or person authorised to make the reservation and will only be processed to the extent necessary to provide the service and in accordance with applicable legislation.

We do not intentionally request additional data concerning minors where such data is not necessary for providing the service.

18. THIRD-PARTY LINKS AND SERVICES

The website may contain links to websites or services operated by third parties.

SILENUS SRL does not control how operators of such independent websites process personal data.

Before providing data to an external service, we recommend reviewing the privacy policy of the relevant provider.

19. CHANGES TO THE PRIVACY POLICY

SILENUS SRL may update this Privacy Policy where:

  • legislation changes;

  • the way in which data is processed changes;

  • new services or functionalities are introduced;

  • providers or tools used on the website are changed;

  • clarifications are required to provide more transparent information.

The updated version will be published on the website and will indicate the date of the latest update.

Where significant changes affect the way data is processed, users will be informed through appropriate means where required by applicable legislation.

20. CONTACT DETAILS

For questions concerning this Privacy Policy, the processing of personal data or the exercise of your rights, you may contact us using the following details:

SILENUS SRL — Winetours Moldova
IDNO: 1012600022176
Registered address: Chișinău municipality, Bubuieci commune, 13 Tereșkova Street
Business address: Chișinău, MD-2004, 23/2 P. Movilă Street
Telephone: +373 68 442 525
Email: info@winetours.md

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