Privacy Policy

1. Introduction
This Privacy Policy describes Batumi Ltd. View Luxury Hotel and Apparatus Management (445619475) (”Batumi View Luxury”, ”we”, “us” or “our”), at the address: Mikeil Lermontovi Street, 105a, apartment 75, Batumi, Georgia processes your personal data when you visit our website, use our mobile app or come into contact with us regarding our business and services. We process personal data in accordance with the General Data Protection Regulation 2016/679/ EU ("GDPR") with supplementary provisions to the General Data Protection Regulation, as well as other data protection legislation applicable at any given time. We are responsible for the processing of your personal data as described in the Privacy Policy in the capacity of data controller. If you would like to know more about our processing of your personal data, you are welcome to contact us, e.g. via our email address: privacy@batumiviewluxury.com.

It is important to us that you feel comfortable with how we process your personal data, and we therefore ask you to read through this Privacy Policy, which we may update from time to time. If we make changes to the Privacy Policy, the new version will apply from the time it is published on our website. At the top of the page, you can see when the Privacy Policy was last updated.

2. How we collect your personal data
The personal data we process relating to you is collected when you make reservations or use our services, e.g. when visiting our website, when you sign up and use your user account, or when we have contact with you via email, telephone, personal meeting and other similar occasions. We also process personal data that you provide to us when using our website.

3. How we process your personal data
We only process your personal data to the extent permitted in accordance with applicable data protection legislation. This means, that we need to have a legal basis for the purposes for processing your personal data, which in our context generally means one of the following bases.

Balancing of interests
– The processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, provided that they are not overridden by your interests or fundamental rights or freedoms (in which case the processing would not be allowed).

Performance of legal obligations
– The processing is necessary in order to fulfil our legal obligations, e.g. to the extent we are subject to regulatory requirements or orders by authorities.

Performance of a contract
– The processing is necessary in order for us to provide you with our services or otherwise perform a contract between us, or to take steps at your request prior to entering into a contract.

Consent
– The processing is carried out with your prior consent, where we, inter alia, are responsible for clearly informing you of what processing you consent to and your right to withdraw your consent in relation to our continued processing.

Below, we explain more about the categories of personal data we process, for what purposes we process them and what legal bases we rely on when processing your personal data, including for how long we store your personal data.

● Manage user accounts on our web- and mobile solutions
Purpose of the processing: Administration of your user account, so that you can register such an account with us, log in to it based on your user information, use the account to e.g. manage your reservations, and to be able to communicate with us for support regarding how to use the account. Categories of personal data: The personal data we process regards:

● Email address and password
● First and last name
● Date of last login
● Contact details, mailing address, email address and telephone number
● Order information such as information regarding your reservations
● Communication related to reservations made and support inquiries
● Payment information such as payment method and payment details
● Email address and password

Legal basis: Balancing of interests, where our legitimate interest is to be able to administer your user account and allow you to use the functions of the account. Storage period: We process and save your user information, your name, your contact details, your specified payment information (if you have chosen to save such information with us through your user account) as well as the communication established between us through your user account, for the time you choose to keep your account, but for a maximum of two (2) years from the last time you logged in to it. Information about reservations and related communication is mainly saved for up to two (2) years after the last day to which the reservation relates.

● Manage reservations
Purpose of the processing: Receive and process reservations, including communication with you regarding your reservations, as well as other customary activities such as sending reservation confirmations and handling payment details for invoicing.

Categories of personal data: The personal data we process regards:

● First and last name
● If applicable, the company you represent
● Contact details, such as your mailing address, email address and telephone number
● Booking information such as information regarding your booking
● Payment and billing details related to the booking

Legal basis: the processing is necessary in order for us to be able to enter into and fulfil the contract with you, i.e. deliver the services in accordance with the booking. If you enter into a contract and receive contracted services on behalf of another person, e.g. as a representative of a company, our processing is done on the basis of a balancing of interests, where our legitimate interest is to be able to enter into or fulfil the agreement with the party you represent Storage period: We process and save your personal data for as long as it is necessary for us to fulfil our obligations, but at most for two (2) years after the last day to which the booking relates. However, we may need to store data a longer time for other purposes, e.g. if it turns out that we need to take steps to establish, enforce or defend legal claims (normally no longer than 10 years). We may also need to save data for a longer period in order to comply with legal obligations, e.g. regarding bookkeeping.

● Maintenance and improvement of our website
Purpose of the processing: Collect statistics and analyze visitor traffic on our website in order to maintain and improve its features, user experience and our work to detect and neutralize any errors, intrusions and incidents. The statistics we compile and the analyses we perform are carried out using data in aggregated form and with the support of de-identified or anonymized data. Categories of personal data: The personal data we process regards:

● IP addresses
● Other technical information which is generated when visiting our website, such as the type

of technical device you have used, browser, visited pages and the time of your visits (browser information, time zone from the place where you visited our website, other web traffic information). Legal basis: Balancing of interests, where our legitimate interest is to create a basis for maintaining and improving the functionality, content and security of our website. The collection of information using cookies is based on your consent, with the exception of such use which is strictly necessary for you to be able to use our website efficiently. Storage period: Information about how visitors interact with our digital platform is stored for a maximum of six (6) months. In most cases, however, the collected personal data is converted into aggregated data (anonymized) at an earlier stage in connection with our production of statistics.

● Email marketing
Purpose of the processing: Administer and carry out marketing emails, in order to inform about our business and services. Categories of personal data: The personal data we process regards:

● First and last name
● Email address
Legal basis: If we already have a customer relationship with you (without you subscribing to our newsletters and having agreed to receive them), we will only send you email marketing unless you object to this in connection with us collecting your contact information. In such case, the processing is carried out after a balancing of interests, where our legitimate interest is to be able to advertise our similar services and inform you about our ongoing activities. You can unsubscribe from further emails at any time by using the unsubscribe link included at the end of each email sent by us. If we do not already have a customer relationship with you, we will only provide our email marketing to you if you have subscribed to our list and agreed to receive them. You can unsubscribe from further emails at any time by using the unsubscribe link included at the end of each email sent by us. Storage period: If we have a customer relationship with you (without you subscribing to our newsletters and having agreed to receive them), we process and save your first and last name and email address for continued email marketing for a maximum of one (1) year after the last day to which the reservation relates. If our marketing emails are based on your consent, we process and save your first and last name and email address for further marketing emails as long as you have not unsubscribed from receiving further emails.

● To create, maintain and develop potential business relationships
Purpose of the processing: Communication with you for the purposes of creating, maintaining and developing our customer relationship with you or the company you represent. This includes communication via email regarding our business and services. Categories of personal data: The personal data we process regards:

● First and last name
● Contact details such as your email address and telephone number
● Professional title and information regarding the company you represent
● Information that you otherwise provide us in our communications with you

Legal basis: Balancing of interests, where our legitimate interest is to create and maintain and develop a business relationship with you or the company you represent. Storage period: We process and save your personal data for a period of six (6) months after the data was collected. If a customer relationship is established between us and you or the company you represent during the said time period, we process and save your personal data as long as we have a customer relationship with you or the company you represent, but no longer than two (2) years from the last time we have been in contact with each other in relation to our customer relationship.

● To fulfil legal obligations or to establish, exercise or defend legal claims
We may process your personal data in order for us to fulfil our legal obligations according to law or other statutes or orders or decisions by courts or authorities. The legal basis for this processing of personal data is when it is necessary for us to fulfil our legal obligations. We may also process your personal data so that you or the company you represent, we ourselves, or a relevant third party can establish, exercise or defend its legal claims, e.g. in connection with a potential dispute between you and us or another party.

4. Security measures
We have taken measures to ensure that your personal data is handled in a safe way. For example, access to systems where personal data is stored is limited to our employees and service providers who need access to such data to fulfil their duties. Such parties are informed of the importance of maintaining security and confidentiality in relation to the personal data we process. We maintain appropriate safeguards and security standards to protect your personal data against unauthorised access, disclosure or misuse. We also monitor our systems to discover vulnerabilities.

5. How we share your personal data
Access to your personal data is limited to persons who require such access for the purposes described in Section 3 above. Your personal data may therefore be shared with the following categories of third party recipients: Companies within our group: We may share your personal data with other companies within our group. If we share your personal data with other companies within our group, we will ensure that the personal data continues to be processed in line with this Privacy Policy. Third party providers: We use third party service providers to manage parts of our business operations. We may share personal data with such third parties in order for them to perform services on our behalf, such as providing our booking system, managing payments, sending out marketing communications and assisting us with IT services. When we use such service providers, we enter into data processing agreements and take other suitable measures to ensure that your personal data is processed in line with this Privacy Policy. Our partners: We may from time to time cooperate with external parties in order to improve our services and business. Such parties either process your personal data as data controllers according to their own terms and policies for handling personal data or as our data processors according to our instructions. In the latter case, we enter into data processing agreements and take other suitable measures to ensure that your personal data is processed in line with this Privacy Policy. Sale or transfer of business: We may share your personal data with a buyer/investor or prospective buyer/investor in the event of a sale, assignment or other transfer of all or parts of our shares, assets or operations. Should such transfer occur, we will take actions in order to ensure that the receiving party processes your personal data in accordance with this Privacy Policy. The purpose of such sharing of your personal data is to let a (potential) buyer/investor to carry out an assessment of our operations and, where necessary, take actions and make preparations in the event of a sale, assignment or other transfer, where such sharing of your personal data is carried out with reference to the legitimate interests of allowing such assessment as well as potential actions and preparations. Public authorities: We may share your personal data with public authorities such as the Georgian Police or the Georgian Tax Agency when we are required to do so according to law, other legal statutes or orders or decisions by courts or authorities.

6. Where we process your personal data
We store and process your personal data only within the EU/EEA and do not transfer it to any country outside the EU/EEA.

7. Where we process your personal data
You have rights in relation to us and our processing of your personal data. Below, you will find information about your rights and how you can exercise them. Please note that your rights apply to the extent that follows from applicable data protection legislation and that there may be exceptions to the rights where applicable. We also ask you to note that we may need more information from you in order to confirm your identity before proceeding with your request to exercise your rights. To exercise your rights or request information about them we ask you to contact us via email at: privacy@batumiviewluxury.com.

● Right of access
You have the right to obtain a confirmation as to whether or not we process your personal data. If that is the case, you also have the right to access the personal data through a register extract as well as additional information about the processing, such as for what purposes the processing occurs, relevant categories of personal data and the recipients of such personal data.

● Right to rectification
You have the right to, without delay, have incorrect personal data about you rectified. You also have the right to have incomplete personal data completed.

● Right to erasure
You have the right to require that we erase your personal data if:

● The personal data is no longer necessary in relation to the purposes for which they were collected or otherwise processed;
● You withdraw your consent to the relevant processing (however, as a starting point, we do not process your personal data on the basis of consent);
● You object to processing that we carry out based on a legitimate interest, and your objection overrides our or another party’s legitimate interest of the processing;
● The personal data is unlawfully processed;
● The personal data has to be erased for compliance with a legal obligation.

● Right to restriction
You have the right to request that we restrict the processing of your personal data in the following circumstances:

● You contest the accuracy of the personal data during a period enabling us to verify the accuracy of such data;
● The processing is unlawful and you oppose erasure of the personal data and request restriction instead;
● We no longer need to process the personal data for the purposes they were collected, but you need the personal data to establish, exercise or defend legal claims;
● You have objected to the processing which we carry out based on a balancing of interests, pending the verification whether your objection overrides our or another party’s legitimate interest to continue with the processing.

● Right to object
You have a right to object to processing of your personal data when it is based on our or another party’s legitimate interest. If you object, we must demonstrate compelling legitimate grounds for the processing which overrides your interests, rights and freedoms in order to be allowed to continue with our processing.

● Right to data portability
If our processing of your personal data is based on the performance of a contract with you or your consent, you have the right to receive the personal data you have provided us relating to you in a commonly used format when technically feasible and it may be made in an automatic manner. You also have the right to have such personal data transferred from us directly to another data controller where applicable (so called data portability).

● Right to withdraw consent
If our processing of your personal data is based on your consent, you have the right to withdraw your consent at any time. A withdrawal of your consent does not affect the lawfulness of the processing that took place based on the consent before your withdrawal. As a starting point, we do not process your personal data based on consent.

8. Complaints to the supervisory authority
Georgian Personal Data Protection Service is the authority responsible for supervising the application of current data protection legislation. If you believe that we process your personal data in a wrongful manner, we encourage you to contact us so that we can review your concerns. You may, however, file a complaint with the Authority for Privacy Protection at any time.