ARENA FRANZ Ferdinand GmbH

Privacy Policy

Available: at https://www.franz-ferdinad.at/  and at reception desks of all our facilities.

Any change of this Privacy Policy will be available and published on the website https://www.franz-ferdinad.at/ and at reception desks of all our facilities.

We at ARENA FRANZ ferdinad GmbH AND OUR AFFILATES (hereinafter: “Company”, “AFF”, “we”, “our”, “us”) are dedicated to protecting the privacy of all persons whose personal data we collect (hereinafter: “you”, “your”). Please carefully read the following privacy policy (hereinafter: “Privacy Policy”) to gain insight how we process your personal data.

„Personal data“ means any information relating to an identified or identifiable natural person (“data subject”). Ann identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

We only process your Personal Data in compliance with the European and Austrian data protection law: Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (hereinafter: “General Data Protection Regulation”, “GDPR”), Austrian Federal Act concerning the Protection of Personal Data (DSG, Bundesgesetz über den Schutz personenbezogener Daten) with all its amendments and other regulations governing the personal data protection.

1. ABOUT US

ARENA FRANZ ferdinad GmbH is a limited liability company established in the Republic of Austria with its registered seat in Tröpolach 152a, 9631 Jenig-Tröpolach, Landesgericht Klagenfurt, Austria, Company No.: FN566299v, TIN: ATU77504149, which operates under the legislation of the Republic of Austria (hereinafter: “AFF”). AFF manages the prestigious hotel Arena Franz Ferdinand Nassfeld formerly known as “FRANZ ferdinand MOUNTAIN RESORT NASSFELD” in Nassfeld, Austria.  This four-star hotel is superbly located next to the valley station of Nassfeld Ski Resort in Carinthia and offers instant access to an impressive 110km of the region’s ski slopes.

AFF is part of a group led by Arena Hospitality Group d.d. for tourism and hospitality (abbreviated name: Arena Hospitality Group d.d.) which is joint stock company established in Pula, Smareglina ulica 3, Republic of Croatia, PIN: 47625429199, and which operates under the legislation of the Republic of Croatia and the EU acquis Communautaire (hereinafter: “AHG”).

AHG is an international, dynamic hospitality company which owns, co-owns, leases, operates and develops full-service upscale, upper upscale and lifestyle hotels, self-catering holiday apartment complexes and campsites primarily in Croatia, Germany, Austria, Hungary and Serbia. In addition to operating and developing its own brands, Arena Hotels & Apartments® and Arena Campsites®, through our majority shareholder PPHE Hotel Group Limited (‘PPHE Hotel Group’ or ‘PPHE’) AHG has the exclusive right to operate and develop the international Park Plaza® brand in 18 countries in the Central and Eastern European region (the ‘CEE region’) and to manage certain art’otel® branded properties, enabling us to further grow our presence. As part of the expanded cooperation with the Radisson Hotel Group, PPHE has secured access to the entire range of Radisson Hotel Group brands, including the Radisson Collection, and has the right to sublicense them to AHG. AHG is thereby enabled to exploit the leading market brands of the Radisson Hotel Group in various market segments, in addition to its existing activities in the high-end and lifestyle hotel segment.

AFF has entrusted certain personal data processing activities with AHG and guarantees appropriate personal data protection measures in accordance with the GDPR and other applicable data protection regulations. AHG’s Privacy Policy is available at LINK

AHG and AFF are the data controllers responsible for your personal information. In relation to some of your personal information which we process we may be considered a joint data controller or data controller in common with a third party.

2. PUSPOSE OF THIS POLICY – PROTECTING OF YOUR RIGHTS

This Privacy Policy explains our approach to processing of any personal information that we might collect from you or which we have obtained about you from a third party and the purposes for which we process your personal information.

Please take a moment to read and understand this Privacy Policy. Please note that it should be read in conjunction with our Website Terms of Use and Cookie Policy.

Please also note that this Privacy Policy only applies to the use of your personal information obtained by us, it does not apply to your personal information collected during your communications with third parties.

You have the following rights in relation to the personal information we hold about you:

• Your right of access;

In case of your inquiry, we’ll confirm whether we’re processing your personal information and, if so, provide you with a copy of that personal information (along with certain other details). If you require additional copies, we may need to charge a reasonable fee.

• Your right to rectification;

You should update the personal data held by us by contacting us directly by mail, email or by making a change during your stay or on your registration card at check-in, or by other appropriate channels of communication or appropriate forms. We encourage you to update your details as and when there is a change to them.

If the personal information we hold about you is inaccurate or incomplete, you’re entitled to have it rectified. If we’ve shared your personal information with others, we’ll let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.

• Your right to erasure;

You can ask us to erase or remove your personal information in some circumstances such as where we no longer need it or if you withdraw your consent (where applicable). If we’ve shared your personal information with others, we’ll let them know about the erasure where possible. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.

• Your right to restrict processing;

You can ask us to ‘block’ or suppress the processing of your personal information in certain circumstances such as where you contest the accuracy of that personal information or you object to us processing it. It won’t stop us from storing your personal information though. We’ll tell you before we lift any restriction. If we’ve shared your personal information with others, we’ll let them know about the restriction where it is possible for us to do so. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.

• Your right to data portability;

You have the right, in certain circumstances, to obtain personal information you’ve provided us with (in a structured, commonly used and machine readable format) and to reuse it elsewhere or to ask us to transfer this to a third party of your choice.

• Your right to object;

You can ask us to stop processing your personal information, and we will do so, if we are: a) relying on our own or someone else’s legitimate interests to process your personal information, except if we can demonstrate compelling legal grounds for the processing; or b) processing your personal information for direct marketing.

• Your rights in relation to automated decision-making and profiling;

You have the right not to be subject to a decision when it’s based on automatic processing, including profiling, if it produces a legal effect or similarly significantly affects you, unless such profiling is necessary for entering into, or the performance of, a contract between you and us, or if the decision is based on law, if that law prescribes appropriate measures to protect the rights, freedoms and legitimate interests of the data subject, or is based on your explicit consent.

• Your right to withdraw consent;

If we rely on your consent (or explicit consent) as our legal basis for processing your personal information, you have the right to withdraw that consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal. Prior to giving consent you will be informed thereof. It shall be as easy to withdraw as to give consent.

• Your right to lodge a complaint with the supervisory authority;

If you have a concern about any aspect of our privacy practices, including the way we’ve handled your personal information, you can lodge the complaint with the Austrian Data Protection Authority or other relevant personal data protection authorities within the EU.

3. HOW TO CONTACT US?

If you have any questions about this Privacy Policy or want to exercise your rights set out above, please contact us in written by sending:

1) an e-mail to privacy@arenahospitalitygroup.com  ; or/and

2) a letter at Arena Hospitality Group d.d., (for Data Protection Officer), Smareglina 3,   52100 Pula, Croatia.

We will respond to all such requests regarding the exercise of your rights without undue delay and in any event within one month of receipt of the request. The period may be extended by two further months where necessary, considering the complexity and number of the requests. We will inform you of any such extension within one month of receipt of the request, together with the reasons for the delay. If we have reasonable doubts concerning the identity of the applicant, we may request the provision of additional information necessary to confirm the identity. Where requests from the applicant are manifestly unfounded or excessive, in particular because of their repetitive character , we may either a) charge a reasonable fee taking into account the administrative costs of providing the information or communication or taking the action requested, or b) refuse to act in the request.

4. WHAT PERSONAL INFORMATION DO WE COLLECT AND HOW DO WE USE IT?

We use your personal data for a range of purposes set out below in more detail however our primary uses are as follows: (i) to perform the Services; (ii) to help us improve our Sites and/or Services and develop and market new Services; and (iii) to comply with any applicable law, court order, other judicial process, or the requirements of a regulator.

In particular, we use your personal information for the following purposes:

• To deliver our services (4.1.)
• To communicate with you by way of our newsletter and to provide you with selected business information (4.2.)
• To address your enquiries and provide customer service support (4.3.)
• To improve our Sites and Services (4.4.)
• Customer insight and analysis (4.5.)
• Marketing communications (4.6.)
• Business administration and legal compliance (4.7.)
• Careers (4.8.)
• Security and surveillance (4.9.)
• Use of Apps (4.10.)
• Event management (4.11.)
• Loyalty program (4.12.)

The legal basis for the stated collection purposes are:

• legal – processing is necessary for compliance with a legal obligation to which the controller is subject
• contractual – processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract
• vital interests of the data subject – processing is necessary in order to protect the vital interests of the data subject or of another natural person
• legitimate interest – processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a minor
• consent – the data subject has given consent to the processing of his or her personal data for one or more specific purposes

 

• To deliver our Services

 

1. Sites and Services. We collect and maintain personal information that you voluntarily submit to us during your use of the Sites and/or our Services:
   • in connection with your use of this website and other websites operated or hosted by us, or on our behalf including via our mobile applications („Sites„); and our sites include:

• franz-ferdinand.at
• mobile app – AHG Hotels – available on App Store and Google Play

As our Sites contain cookies and other technologies you should be aware of, please read our Cookie Policy to get an information about our use of these technologies.

• Personal data is collected during the reservation process, check-in process and the course of your stay in our accommodation facilities and/or during your use of certain bars, restaurants, spas, leisure facilities and activities, and related hospitality services operated by the AFF and its affiliates (the “Services”).

We may use the contact, identification and payment details you have provided to us so that we can fulfil the supply of Services you have booked via our Sites, through third party, by phone or via in-person bookings, this may include use of information such as your name, title, address, previous stay information, service preferences, telephone number, gender, nationality, passport number, date and place of issue of your passport, payment information including credit card details and CVV code, flight details, names of other guests on the booking, room preferences, notes provided by you voluntarily,  and preferred communications methods. We also receive information from third party entities and sites, travel agents, social media sites, third party booking websites/agents/intermediaries, meeting and event planners, restaurant booking services which we will use for those purposes. This includes verifying your identity, contacting you in respect of hotel reservations and processing your reservation and booking payment.

Who do we share your personal information with for this purpose?

We may share your personal information with our affiliates and third parties for the following purposes:

1. To send you pre-arrival check-in/check-out communications;
2. To verify your identification;
3. To verify card payments (including the pre-authorisation process which may be conducted at check-in at our hotels) and process refunds;
4. To make reservations, cancellations and booking changes;
5. To facilitate your booking and any specific requirements or services requested;
6. To undertake loyalty programme membership services;
7. To send, where available, pre-arrival text or email with stay information, free service offerings including online check-in, text messages on the day of check-in, room preference requests.

Legal basis

It is necessary for us to use your personal information to perform our obligations in accordance with any contract that we may have with you and our legitimate interest in providing you with information related to your stay and the services we provide.

1. Hotel registration and registration to the competent authority. Please note also that AFF needs to collect minimum information required by the law for your registration as a guest in all relevant registers.

Required data on accommodation service users:

• first name and last name, date of birth, gender, nationality, country of origin and address including postal code
• additional information for foreign guests – the type, number, date of issue and issuing authority of the travel document

Who do we share your personal information with for this purpose?

With authorised institutions and organizations of the Republic of Austria, as provided by the law.

Legal basis

Processing is necessary for compliance with a legal obligation to which the controller is subject.

1. Please note also that we are obliged by law to issue the invoice for the provided service in order we may process the next data:

• Name and surname;
• Address of residence.

Who do we share your personal information with for this purpose?

With authorised institutions and organisations of the Republic of Austria, as provided by the law.

Legal basis

Processing is necessary for compliance with a legal obligation to which the controller is subject.

• To communicate with you by way of our newsletter and to provide you with selected business information

We collect and maintain personal information including your name and contact details so that we can communicate with you via our newsletters and to provide you with information and benefits relating to the operation of our Services and related promotions and offers.

Legal basis

It is in our legitimate interest to use your personal information to communicate with you in this way.

Who do we share your personal information with for this purpose?

We may share that information with our affiliates and third party providers.

• To address your enquiries and provide customer service support

Where you enquire about our Services, or require customer support in respect of our Services we may collect personal information about you.  We use various user interfaces to allow you to request information about our Services or to make enquiries. Contact information may be requested in each case, together with details of other personal information that is relevant to your customer service enquiry. This information is used in order to enable us to respond to your requests.

Who do we share your personal information with for this purpose?

We may use a third party service providers included but not limited to providers who provide optional post-stay surveys to assist us with customer feedback requests, and which provide support for the interfaces through which you can communicate with us.

Legal basis

Depending on the nature of your enquiry or request the legal basis for us to process such personal information will either be because:

• processing is necessary to perform our obligations in accordance with any contract that we may have with you;
• because it is in our legitimate interest to use your personal information in such a way to ensure that we provide the very best customer service we can to you; and/or
• where you have consented to such processing until the consent withdrawal.

 

• To improve our Sites and Services

From time to we may contact you to invite you to provide feedback about our Services which may be in the form of online, postal or in-hotel surveys. We use this information to help us improve the quality of our Services.

Who do we share your personal information with for these purposes?

We may use a third party service provider to assist us with customer surveys and feedback requests in order to improve the Services we provide.

Legal basis

It is in our legitimate business interests to use the information you provide to us in your feedback for the purposes described above.

• Customer insight and analysis

We analyse your contact details with other personal information that we observe about you from your interactions with our Sites and/or your use of our Services and/or that we may receive from third parties. This may include personal information such as your travel history, guest preferences, service preferences, loyalty activity, marketing preferences and dates of previous stays amount of charges for previous stays.

Where you have given your consent (where lawfully required) we may also use “cookies” or “pixel tags” (“Tags”) and other technologies on our webpages and in our emails to collect personal information from the computer hardware and software you use. This may include:

• a session ID to track usage statistics on our Sites and to gather information regarding your personal or professional interests, demographics (such as your address, country of location, language of choice and gender), buying habits (such as your stay history); and
• Tags which allow us to track receipt of an e-mail to you, to count users that have visited a web page or opened an e-mail and collect other types of aggregate information.

Please see our Cookie Policy for further information.

Who do we share your personal information with for these purposes?

We may share your personal information with several third party service providers to assist us with customer insight analytics.

Legal basis

Where your personal information is completely anonymised, we do not require a legal basis to use it as the information will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of such anonymised personal information may be subject to other laws where your consent is required. Please see our Cookie Policy for further details.

Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information in such a way to ensure that we provide the very best Services to you and our other customers.

• Marketing communications

We carry out the following marketing activities using your personal information:

1. Email marketing

We use information that we observe about you from your interactions with our Sites, our email communications to you and/or with our Services and/or your email address, to send you marketing communications by email, where you have consented to receive such marketing communications, or where we have another lawful basis to do so.

We will abide by any request from you not to send you direct marketing materials.

You can unsubscribe from the newsletter list at any time by clicking on the unsubscribe link available in each newsletter we sent you or by sending email to privacy@arenahospitalitygroup.com.When such request is received, your contact details will be “supressed” rather than deleted, for a reasonable amount of time for legal or other compliance reasons.

Who do we share your personal information with for these purposes?

We may share your personal information with our affiliates and third party service providers who assist us in our email marketing activities.

Legal basis

It is in our legitimate interest to use your personal information for marketing purposes.

We will only send you marketing communications via email where you have consented to receive such marketing communications, or where we have a lawful right to do so.

1. Social media marketing

We may use the following social media sites to market our Services to you: Facebook, Instagram, YouTube, LinkedIn where you are a registered user of such services.  Where you participate in our sponsored social media activities or offerings we may collect certain information from your social media account with your permission such as location information, check-in notifications, social media activities, photos, status updates and publicly available comments and friends lists. Please note that such activity is also subject to the privacy choices you have elected to make on such services.

We may use information that we observe about you from your interactions with our Sites, our email communications to you and/or with our Services to provide you with personalised advertising on social media channels.

Who do we share your personal information with for these purposes?

We may share your email address with third party service providers who assist us with social media remarketing campaigns.

Legal basis

Where your personal information is completely anonymised, we do not require a legal basis to use it as the personal information will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of such anonymised personal information may be subject to other laws where your consent is required. Please see our Cookie Policy for further details.

Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information for marketing purposes.

• Business administration and legal compliance

We use your personal information for the following business administration and legal compliance purposes:

• for record keeping purposes;
• to comply with our legal obligations;
• to enforce our legal rights;
• protect rights of third parties; and
• in connection with a business transition such as a merger, acquisition by another company, or sale of all or a portion of our assets.

Who do we share your personal information with for these purposes?

We will share your personal information with professional advisers such as lawyers and accountants and/or governmental or regulatory authorities.

Legal basis

Where we use your personal information in connection with a business transition, enforce our legal rights, or to protect the rights of third parties it is in our legitimate interest to do so. For all other purposes described in this section, it is our legal obligation to use your personal information to comply with any legal obligations imposed upon us such as a court order.

Where we share your sensitive personal information, we shall obtain your consent to do so.

• Careers

We may collect personal information in order to consider and process any enquiries or applications regarding our employment opportunities.

We collect and maintain personal information that you voluntarily submit to us or which we collect from third-party recruitment agencies for this purpose. The information that we collect may include your name/surname, contact details, education details, and any other information that you include on your CV, application documents and cover letter.

Where you apply for a vacancy using social networks, we may collect any information you make publicly available through the concerned social network. We may use this information in order to communicate with you about your application.

Who do we share your personal information with for this purpose?

We may share your personal information with our affiliates.

Legal basis

It is in our legitimate business interests to use the information you provide to us when you apply for a job vacancy for the purposes described above.

• Security and surveillance 

We may use video surveillance to view and record individuals on or around (internally and externally) our accommodation facilities. The images of individuals recorded by video surveillance will constitute personal data.

Video surveillance may be used to record sound in certain places. Video surveillance images may be monitored by authorised personnel. We will display signs within our facilities to alert individuals that there images may be recorded where video surveillance is in use.

Who do we share your personal information with for this purpose?

We may share your personal information, recorded via our video surveillance with the third parties as required by law or as necessary for the functioning of the video surveillance security system, including law enforcement, the police, strictly necessary technical service providers, security service providers and our affiliates only as strictly required.

Legal basis

It is in our legitimate business interests to use the information recorded via our video surveillance for the following purposes:

• for the personal safety of our staff and guests;
• to act as a deterrent to prevent crime and protect our facilities and assets from damage;
• to protect guests’ belongings against damage and crime; and
• to support law enforcement bodies in the prevention, detection and prosecution of crime.

• Apps

By downloading our app AHG Hotels (hereinafter: “App”) you can use the services, where available, such as online check-in, digital key, online check-out, amending upcoming reservations, invoicing, ordering of on-site services and goods.

The App gives you all the useful information about the hotel and its facilities (restaurants, shopping, massage, sports etc.). You can contact the accommodation facility staff at all times directly from the App.

App may send push notifications to the user.

App can collect personal data which may be freely provided by you as the user, collected automatically when using App or collected through third parties for example cookies, usage data, email address, first and last name, username, location, IP address, system logs, payment details and various types of data necessary to provide the requested service and for performance and maintenance of the App, and also to provide you with useful information.

We can use your email address to send you email messages containing information of commercial or promotional nature concerning us and our hospitality group to which we belong.

You may choose not to use the App, and in such case the App will not process your personal data.

Who do we share your personal information with for this purpose?

We may share your personal information with our affiliates and third parties such as third-party technical service providers, hosting providers, IT companies which provide us with application usage, maintenance and analytical services.

Legal basis

Personal data will be processed if one of the following applies:

• Users have given their consent for one or more specific purposes;
• Provision of data is necessary for the provision of the agreement with the user or pre-contractual obligations;
• Processing is necessary for compliance with our legal obligation;
• Processing is necessary for the purposes of the legitimate interests pursued by us or by a third party.

 

• Organisation of events

If you want to organize a meeting or event (conferences, prom parties, weddings, etc.) in one of our accommodation facilities or you are a participant in a meeting or event, the personal data collected will be processed for the purpose of sending an offer and performing the event organization service.

We may also send you satisfaction surveys after your meeting or event to improve our Services.

The personal data we process are name and surname, address, e-mail and contact telephone number and, if necessary, other data necessary for the organization of the event.

Who do we share your information with for this purpose?

Depending on the situation or the needs of organizing the event, we may share your personal information with our business partners.

Legal basis

Processing of your personal data is  necessary for the performance of a contract or pre-contractual obligations. In addition, it is in our legitimate interest that we use your personal information so that we can communicate with you.

• Loyalty program

Arena Rewards is Arena Hospitality Group’s loyalty program in which AFF also participates, and in which members get instant rewards depending on the number of room nights spent at participating properties. Details about the loyalty program can be found at

5. OUR USE OF COOKIES AND SIMILAR TECHNOLOGIES

Our Sites use certain cookies, pixels, beacons, log files and other technologies of which you should be aware. Please see our Cookie Policy to find out more about the cookies we use and how to manage and delete cookies.

6. THIRD PARTY LINKS AND SERVICES

Our Sites contain links to third party websites and services. Please remember that when you use a link to go from our Sites to another website or you request a service from a third party, this Privacy Policy no longer applies. For more information, show more.

Your browsing and interaction on any other websites, or your dealings with any other third party service provider, is subject to that website’s or third party service provider’s own rules and policies.

We encourage you to become familiar with the privacy practices of every website you visit or third party service provider that you deal with and to contact them if you have any questions about their respective privacy policies and practices.

This Privacy Policy applies solely to personal information collected by us through our Service and does not apply to these third party websites and third party service providers.

7. HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION FOR?

We keep your personal information for no longer than is necessary for the purposes for which we collect it.

If your information is only useful for a short period e.g. for specific marketing campaigns we may delete it.

If we collect your data for the purpose of fulfilling our legal obligations, we store them for the duration prescribed by the applicable regulations.

We will keep the data we have collected on the basis of the contractual relationship as necessary for the purpose of fulfilling the contract or providing the service and in accordance with our retention obligations.

We will keep the data we collect on the basis of consent within the period provided for the purpose for which the consent was given or until the withdrawal of consent.

After the cessation of the purpose for which they were collected, we no longer use your personal data, and they remain in our storage system and we keep them as far as we are obliged by legal regulations on the preservation of archival material.

8. CONFIDENTIALITY AND SECURITY OF YOUR PERSONAL INFORMATION

We are committed to keeping the personal information you provide to us secure and we will take reasonable precautions to protect your personal information from loss, misuse or alteration.

We have implemented information security policies, rules and technical measures to protect the personal information that we have under our control from accidental or unlawful destruction, loss, alteration, improper use, unauthorized disclosure or access to personal data.

All of our employees and data processors (i.e. those who process your personal information on our behalf, for the purposes listed above), who have access to, and are associated with the processing of personal information, are obliged to respect the confidentiality of the personal information of all users of our Services.

9. CHANGES TO THIS PRIVACY POLICY

We may make changes to this Policy from time to time to reflect any changes to our use of your personal information or to comply with changes to law.

We may make changes to this Privacy Policy or supplement this Privacy Policy with privacy notices from time to time.

Any changes to this Policy will be posted to our website so that you are always informed of the way we collect and use your personal data. Updated versions will also be available at the receptions of accommodation facilities. Updated versions of our Policy will include the date of the revision at the end of this Policy so that you are able to check when the Policy was last amended.

Any changes to our Policy will become effective upon posting of the revised Policy on the website. Use of the website following such changes constitutes your acceptance of the revised Policy then in effect. We encourage you to review this Privacy Policy periodically to be informed of how we use your personal information.

10. TRANSFER OF PERSONAL DATA OUTSIDE TO OTHER COUNTRIES

Due to the global nature of our business and that of our third party suppliers who process your personal data on our behalf, personal information we collect from you may be transferred, processed and stored outside of  European Economic Area (EEA) including (where applicable) outside the jurisdiction where the personal information is collected.

We will take all necessary steps to ensure that your personal information is treated securely, and in accordance with this Privacy Policy and any applicable laws.

In particular, where your personal data is transferred from EEA to a jurisdiction outside of the EEA, we will comply with our legal and regulatory obligations (and will ensure that our third party suppliers comply with their obligations) in relation to the personal information, including having a lawful basis for transferring personal information and putting appropriate safeguards in place to ensure an adequate level of protection for the personal information.

11. DISCLOSURES OF PERSONAL DATA

 

1. Disclosure to Internal Third Parties

We may share your personal data with our affiliates.

1. Disclosure to External Third Parties

We set out in Section 4 (What personal information do we collect and how do we use it?) the purposes for which we may have to share your personal data with such third parties, and the types of third parties with whom we share your personal data. In addition we generally share personal data with third parties as follows:

• Service providers acting as processors who provide IT and system administration services, and to other processors who enable us to provide catering, hospitality and tourism services.
• To other providers if this is necessary for the provision of accommodation or other services (eg if you have booked the accommodation service and the tourist transfer service provided by our contractual partner)
• Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
• Regulators and other authorities, including tax authorities, who require reporting of processing activities in certain circumstances.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

It is possible that external third parties together with AHG, jointly determine the purposes and methods of personal data processing. In this case, third parties and AHG are joint controllers. The joint controllers transparently determine their responsibilities for compliance with the obligations from the Regulation with regard to exercising the rights of data subjects and the duty to comply with the transparency principles of processing, unless the responsibilities are determined by regulations.

12. GENERAL

Children and Minors

AFF may collect child’s personal information only where required by local laws (e.g. for the purposes of hotel registration and registration to the competent authority), and within the activity of “Berdinand kid’s club“ playroom based on written consent of the parents or guardians.

If you are a child or minor, you may only use our Site and Services with the permission of your parent or guardian. In relation to the offer of information society services directly to a child, the processing of the personal data of a child shall be lawful where the child is at least 14 years old.

Translations

This Policy is written in English language and may be translated into other languages. In the event of any inconsistency between the English version and the translated version of this Policy, the English version shall prevail.

 

Last updated: January 23, 2023.

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