PRIVACY POLICY

Privacy Policy of Avianna Group Hotels & Resorts

Introduction

• We want you to be familiar with how we collect, use, and disclose information. This Privacy Policy describes the privacy practices of Avianna Group Hotels & Resorts ("Avianna Group," "we," "us," and "our") in connection with the information that we collect:
• through aviannagroup.com operated by us, from which you are accessing this Privacy Policy
• when you visit or stay as a guest at one of our properties, or through other offline modes of communication
• through the email messages that we send to you that link to this Privacy Policy and through your communications with us.
• We want our services to be safe and secure for our users. Uniform practices for collecting, using, disclosing, storing, retaining, disposing, accessing, transferring or otherwise processing such information assist Avianna Group to process personal information fairly and appropriately, disclosing it and/or transferring it only under appropriate circumstances. This privacy policy relates to our use of any personal information we collect from you for providing hospitality-related services.
• This privacy policy intends to update you on how we use your personal information collected through aviannagroup.com or provided to us by other means. Please read this privacy policy before using aviannagroup.com or submitting any personal information. The privacy policy also relates to our use of any personal information you provide to us by phone, SMS, email, in letters, in person, through representatives and other correspondence or means.
• This policy will be updated subject to any changes in information collection, activities performed, or any applicable regulations. You are encouraged to review the privacy policy whenever you visit aviannagroup.com to make sure that you understand how any personal information you provide will be used and retained.

Please note:

The privacy practices set forth in this privacy policy are for aviannagroup.com only. If you link to other websites, please review their respective privacy policies, which may be very different.

Site

The Site makes available information relating to hotels and resorts owned or managed by Avianna Group Hotels & Resorts, a part of Avianna Group, and its subsidiaries, managed entities, affiliates, and related parties.

Purpose

The purpose of this policy is to highlight various obligations, best practices, and tools that support compliance with data privacy regulations applicable to Avianna Group in its role as both data controller and data processor, as applicable (if any).

Applicability

This privacy policy is applicable to:

• everyone who accesses and uses aviannagroup.com including but not limited to external legal entities, in any form or manner
• Avianna Group customers who visit or stay at one of our properties
• third-party service providers or their representatives

Collection and use of information

4.1 Collection of your information

Avianna Group collects, processes, and retains information about you when you visit our website, aviannagroup.com or stay in one of our hotels, or avail any other services provided by Avianna Group. You provide us with information, such as your name, email address, company information, street address, telephone number, other contacts, and demographic information, when you make a reservation, purchase a gift card, subscribe to the Avianna Group newsletter, or obtain web exclusive rates on aviannagroup.com.

Moreover, you may choose to provide your personal information in connection with sending an email or message, logging complaints, receiving promotional offers, or when you use our service.

Personal Information may include, but is not limited to:

Your name and physical address, email addresses, and telephone numbers

Behavioural or demographic attributes, when tied to personal identifiers

Credit card or debit card number

Social media account ID or user ID, profile photo, and other data you make available publicly or to us from your social media accounts, publicly available platforms, or other sources

Other similar information

If you submit any personal Information relating to other people to us or to our service providers in connection with the Services (e.g., if you make a reservation for another individual), you represent and warrant that you have the authority to do so and to permit us to use the information in accordance with this privacy policy.

• 4.2 How do we use your information?
• Any of the information we collect from you may be used in one of the following ways:
• To develop, customise and improve our services: We shall process your personal information, preferences, user characteristics, usage patterns, and feedback to develop, customise and improve our services.
• If you refuse consent for processing your personal information for the mentioned purposes in this subsection, you will not be significantly hindered in your use of the service. Refusing or withdrawing consent thus has no significant negative effects on your use of the service.
• Marketing purposes (including Avianna Group advantage or similar programmes), to inform you about other information, events, promotions, products or services we think will be of interest to you.
• To process personal information necessary for the performance of a contract and providing the services: We may use this information for the provision of the website and the provision of the service according to our Terms of Service. Further, to process and/or respond to your requests, submissions, queries, complaints, and any transactions, and to provide you with information or services requested.

If you object to processing of your personal information for the mentioned purposes in this subsection, we may block or limit your access to the service, and we reserve the right to end the agreement in accordance with the Agreement and/or the Terms of Use and/or statutory requirements.

To process your personal information necessary for compliance with a legal obligation: In order to prevent or investigate actual or suspected fraud, hacking, infringement, or other misconduct involving our services or website. Additionally, if we are required by law to disclose your information to any government authority, you consent to the provision of such information.

To send periodic emails: The email address you provide will be used to send you information and updates pertaining to the services provided by Avianna Group.

Select content, improve quality and facilitate use of the other interface channels : Avianna Group may use your Personal Information to help create and personalise content on our Channels (including but not limited to our website, social media pages, promotional programmes or campaigns, etc.), facilitate your use of the Channels (for example, to facilitate navigation and the login process), avoid duplicate data entry, enhance security, improve quality, track campaign and survey responsiveness, and evaluate page response rates.

Obtain third-party services: We also share Personal Information and Other Information with third parties who provide services to Avianna Group for website management, information technology and related infrastructure provision, marketing and campaign management, customer service, email delivery, auditing, and other similar services. When Avianna Group shares Personal Information with third-party service providers, we contractually take an undertaking that they use your Personal Information and Other Information only for the purpose of providing services to us and subject to terms consistent with this Policy as well as mutual Non-Disclosure Agreements.

Fairness and Purpose

Avianna Group will collect adequate, relevant, and necessary Personal information and will process such information fairly and lawfully for the purpose for which it is collected. The purpose of collection will be specified not later than at the time of data collection, or on each occasion of change of purpose.

Accuracy of information

The information held by Avianna Group on aviannagroup.com or in our other systems collected by other means at the time of registration shall be checked and, from time to time, we may change the information requested upon registration or with respect to certain features.