Through this Privacy Notice, we want to provide you details about the processing of your personal data in the context of participating in marketing events organised by Therme and its processors.

By marketing events we mean any event of contest, campaign, image promotion, products and services organised through the online platforms (website, social networks - Facebook, Instagram, Youtube etc.) and physically, in the locations of Therme Bucharest complex or in other places where the events take place.

We also refer to both public and private events.

We recommend that you read this Privacy Notice together with the Privacy Policy, in order to obtain as much information as possible on how we protect your personal data.

Further information on the processing of your personal data will be also provided  in the regulations of competitions and campaigns, image releases or other documents used when events are being organised.


Before we organise an event, we will always make sure that we only ask you for the data that is necessary to fulfill the purposes pursued. We do not collect excessive data for which there is no well-defined purpose.

Depending on the nature of the event, we process the following categories of personal data:

  • Identification and contact details: first name and last name, email address, address, phone number, signature, age, or other necessary data;
  • Public data from your social media accounts (first name and last name, pseudonym, image, voice, opinions, posts, comments, data from your profile, etc.);
  • Any other information that you provide or we request depending on the nature of the event and which is not public (image, voice, opinions, comments, experiences in your life etc.);
  • Any data disclosed in written interviews and audio-video materials;
  • Preferences in relation to products and services provided by Therme;
  • Prizes or benefits obtained from participating in the events;
  • Remuneration obtained as a result of an event, if the processing of personal data is the subject of a contract ;
  • Unique identifiers in documents, including copies of supporting documents – only if there are legal provisions that oblige us to process this data or if we have legitimate interests.


We process this data for:

  • Organizing and conducting the event by performing the activities of registration, participation, selection of winners, awarding and communication with the participants during the event;
  • Promoting Therme’s products and services;
  • Promoting Therme’s and the Therme group’s image;
  • Compliance with Therme legal obligations;
  • Therme’s legitimate interests.


Depending on the context in which we process your data, we may use several legal grounds.

We use consent as a legal basis when we ask for your consent to collect and process data, for example to register or participate in an event. We use this legal basis only if we can fulfill all conditions of consent, such as the possibility to withdraw your consent at any time of processing. The performance of a service or the performance of a contract is not conditional on participation in consent-based activities.

The performance of a contract is another basis on which we rely in the event that the processing of your data is carried out on the basis of a contract to which you are a party. For example, the processing of your image in the media used in Therme campaigns may be carried out both under an image contract or other similar type of agreement.

Fulfillment of our legal obligations following the conduct of events (e.g. data processing for financial-accounting purposes, archiving etc.).

We may also process your data on the basis of our legitimate interests, such as:

  • Organizing events and carrying out all necessary processing activities;
  • Verification of compliance with the conditions for participation in various events;
  • Verification of compliance with the conditions of the applicable regulations, where applicable;
  • Keeping audio-video files recorded in the events;
  • The retention of records and supporting documents;
  • Posting data on social networks or other locations available to the general public.
  • Disclosure of data to our collaborators and contractual partners who help us in the performance of our business;
  • Defense of Therme rights in court;
  • Recovery of damages;
  • Other similar situations described in the Privacy Policy.

When we use legitimate interest as a legal basis for our activities, we are committed to protecting your data so that the processing does not override your fundamental interests or rights and freedoms.


Where necessary, personal data may also be accessed by other third parties, to the extent that this is reasonably necessary in accordance with the purposes mentioned in this Privacy Policy.

Marketing partners and processors, event collaborators and organisers, application providers and web tools providers will have access mainly to this data.

For details about our data processors, please refer to the dedicated section of the Privacy Policy.

Also, your data that is used to promote Therme’s image, products and services may be disclosed in public spaces such as: social networks, websites, physical locations that can be accessed by an unlimited number of people, magazines, publications, billboards, etc.


As a rule, your personal data is processed in Romania, within European Union and countries that provide an adequate level of protection.

Depending on the nature, context and location of the marketing event, your personal data may also be disclosed to international destinations that do not provide an adequate level of protection, such as the United States. In this situation, for the protection of your data, we will take additional protection measures.

To learn more about the conditions under which we may transfer your data to third-party destinations, please refer to the “International data transfer” section of the Privacy Policy.


Data retention periods vary depending on the purpose for which they are processed and may be influenced by the nature of the event and the legal grounds we use.

Therefore, the criteria on which we establish data retention are:

  • Withdrawal of consent, in which case your personal data will be deleted if it is not necessary for other purposes;
  • Legal retention periods, in accordance with the legal provisions, where applicable;
  • The retention periods set out in the contract, where applicable;
  • Therme’s legitimate interests.

We keep the data that is necessary for financial and accounting purposes, according to the legal provisions of national and European law, at least 10 years after the issue of the supporting documents containing them. After the expiry of this period, the data will be deleted/destroyed within 1 year, according to internal storage policies.

Data processed on the basis of legitimate interests are assigned retention periods in accordance with the purposes for which they were collected. We periodically evaluate storage periods to ensure that we retain your data only for as long as necessary in relation to the purposes pursued.


Depending on the legal grounds on which we process your data, you have the following rights:

  • Right to be informed;
  • Right of access;
  • Right to rectification;
  • Right to erasure, under the conditions stipulated by law;
  • Right to restriction of processing;
  • Right to data portability to another controller, under the conditions stipulated by law;
  • Right to object to the processing of your personal data;
  • 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 the exceptions set out in data protection laws;
  • The right to withdraw consent at any time;
  • Right to lodge a complaint with a supervisory authority.


The information presented in this Privacy Notice will be reviewed periodically to reflect any changes in current processing activities.

Please visit this page periodically to make sure you always have up-to-date information.

However, if we intend to significantly change the way we use your personal data, we will notify you in advance.

Last update: April 2022