PRIVACY NOTICE

Nordis Hotel SRL takes the issue of safeguarding your privacy seriously. Our Privacy Notice describes what information we collect from hotel guests and Private Residence owners, as well as visitors to the Nordis Hotels website and mobile App, and the way in which Nordis Hotels uses this information to better serve your needs.This Privacy Notice has been adopted by all the distinct legal entities that manage and operate Nordis Hotels.

‍What personal information do we collect?
‍Personal information is any information that may identify or relate to you as an identifiable individual. The personal information that we collect about you could include:
- Identity information – such as name, age, gender, passport information or data from government-issued identity cards;
- Contact information – such as your home address, zip/postal code, email address and phone number;
- Public information – such as when we review public platforms to understand what you are saying about us or the hospitality industry;
- Technical information – such as information about the device you use to interact with us (including the unique device identifier, hardware model, IP address, geolocation, operating system and version, and mobile network information and unique device identifiers, in the case of our mobile App); and
- Correspondence information – when you contact us, such as to send an enquiry or make a request, any correspondence or application may be kept and added to your personal information.

‍How do we use your personal information?
‍For each of the categories of personal information described above, we use your personal information for the following purposes:
- to enable you to use our website and our mobile App;to help us recognize or identify you and any accounts you hold with us;
- to provide superior customer service to you;to send you newsletters or marketing communications regarding our properties and to advise you of promotions or to inform you of offers or other information that may be of interest to you (if, where required, you separately provide your consent for us to do so);
- to personalize and enhance your online and guest experience;to conduct surveys or focus groups to receive your views of our properties and service delivery (if, where required, you separately provide your consent to this);
- to respond to a specific “Information Request” from you about one of our hotels or residential properties and deal with any other enquiries, correspondence, concerns or complaints you have raised;
- for marketing, advertising and promotional purposes, such as through one of our on-line promotions or on third party social networks, consistent with your preferences and applicable law;
- to analyze customer trends and insights; and
- to operate our business, including for internal purposes such as auditing, data analysis, statistical and research purposes and troubleshooting to help us improve our services.
Occasionally we will combine information from a number of Guests and Owners to better understand trends and your expectations. When this occurs, all identifiers are removed and the aggregate, anonymized information cannot be linked to any specific individual or household.

‍On what basis do we use your personal information?We use your personal information on the following basis:
- to comply with legal and regulatory obligations, including financial reporting requirements imposed by government regulators and our auditors;
- to enter into agreements with you, and to perform our agreement to provide services to you when you stay with us;
- for legitimate business purposes – using your personal information helps us to operate and improve our business and minimise any disruption to the services that we may offer to you. It also allows us to make our communications with you more relevant and personalised to you, and to make your experience of our services more efficient and effective;
- because you have given your consent – at times we may ask for your consent to allow us to use your personal information for one or more purposes.for purposes disclosed at the time you provide your personal information or as otherwise set forth in this Privacy Notice; or
- for the establishment, exercise or defence of legal claims or proceedings.

‍How and from what sources is personal information collected?
‍For each of the categories of personal information and purposes described above, we gather information when you provide it to us, or interact with us directly, for example:
- when you create a profile or sign in to access an existing profile on our website or App;We also collect your personal information while monitoring our technology tools and services, including comment cards and email communications sent to and from Nordis Hotels.
We may also receive information about you from other sources, such as our business partners and publicly available sources, or from other members of your traveling party or other individuals. We combine information that we have about you from various sources, including the information that you have provided to us.
Finally, we may collect your photograph from publicly available sources so that we can recognize you in order to provide you with superior customer service.

‍Cookies and other data
‍We collect information automatically from you through the use of cookies, pixel tags and similar technologies, when you visit our website or use our mobile App or read our emails, and we may use third party partners to collect this device and usage information. For example, we collect information about how you use our website and mobile App, such as the pages you visit or links you click and if you use multiple devices, and information about the device you use, such as the IP address, device type, operating system, and a unique ID that allows us to uniquely identify a browser, mobile device or account (including, e.g., a persistent device identifier or AdID), and other such information. If permitted by your device settings, we and our third-party providers may collect location data through GPS, Wi-Fi or other methods to personalize and enhance your online experience and to improve the effectiveness of our website, mobile App, offers, advertising, communications and customer service. We collect analytics data or use third party analytics tools to help measure traffic and usage trends and to understand more about the demographics and behaviors of our users.
We, or our third party partners, may use the data collected through cookies and similar technologies to remember information so that you will not have to re-enter it during your visit or the next time you visit the website or mobile App; provide custom, personalized content and information; identify and contact you across multiple devices; provide and monitor the effectiveness of our website and mobile App and perform analytics; diagnose or fix technology problems; detect or prevent fraud or other harmful activities, and otherwise to plan for and enhance our online properties and services.
We may also use third party advertising companies to serve advertisements regarding goods and services that may interest you when you access and use our websites and mobile App. To serve such advertisements, these companies place or recognize a unique cookie on your browser (including through use of pixel tags).  For more information about our and our third-party partners’ use of cookies and related technologies to collect information automatically, please see our  Cookie Notice .

‍How do we protect personal information?
‍We use a variety of physical, technical and administrative security measures and technologies to help preserve the integrity and security of your personal information, consistent with applicable data protection and privacy laws.
We endeavor to protect the privacy of your account and other personal information that we hold in our records, but unfortunately, we cannot guarantee complete security. Unauthorized access or use, hardware or software failure, and other factors, may compromise the security of user information.  Also, while we endeavor to put adequate contractual protections in place, we cannot guarantee the security of any personal information in databases hosted by third parties.It is important to note that any e-mail communication is not secure. This is a risk inherent in the use of e-mail. Please be aware of this when requesting information or sending forms to us by e-mail (for example, from the “Contact Us” section of our website). We recommend that you do not include any confidential information (e.g. credit card information) when using e-mail. For your protection, our e-mail responses to you will not include any sensitive personal information.

‍Will personal information be provided to third parties?
‍For each of the categories of personal information, sources of information and purposes described above, we may share certain of your personal information with:
- agents, contractors or third-party service providers of Nordis Hotels who provide services to Nordis Hotels or on our behalf, including as needed to better serve your needs as a Guest or Owner;
- others with your consent or at your direction;escrow agents, third party lenders and loan-servicing agents;
- a prospective buyer, investor or other third party in the event that we are involved with a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of any business or assets or similar business transaction;
- online advertising partners, analytics and search engine providers that assist Nordis Hotels in the improvement and optimization of the website and our mobile App, or for advertising, analytics, attribution or research purposes;our professional advisors and auditors; and
- local or foreign regulators, governments, courts, law enforcement and national security authorities.
Where a third party engaged by Nordis Hotels processes personal information on our behalf, Nordis Hotels takes steps to contractually require these parties protect your personal information in a manner consistent with the principles articulated in this Privacy Notice.If you have chosen to join a subscription list, please note that they are only used for internal purposes, and we do not sell or rent our subscription lists to third parties for their direct marketing purposes.
If Nordis Hotels suspects any unlawful activity is taking place, it may investigate and/or report its findings or suspicions to the police or other relevant law enforcement agency.
We may also disclose information as may be required by law or legal process, or if we reasonably believe such disclosure is necessary to comply with legal process or the reasonable requests of law enforcement or to exercise or protect the rights, property or personal safety of the Nordis Hotels, our Guests or Owners, or others.

‍Your rights
‍Depending on applicable law, which may be determined by your country, region or state of residency, you may be able to exercise one or more of the following rights relating to our processing of your personal information. You may also have other rights under the laws of your jurisdiction of residence.To protect your personal information, we may require that you prove your identity to us at the time your request is made. This may involve providing us with information which we hold on to file about you (e.g. a home or business address), or we may require you to produce some form of photo or government issued identification.

‍Accessing, correcting or deleting your personal information
‍We understand that you may like to know what personal information we hold about you, or to correct or delete certain information we hold about you. We are happy to assist you with your request.Nordis Hotels reserves the right to decline a request to access, correct or delete your personal information under certain circumstances as permitted by applicable law.  There may be a variety of legitimate business reasons why we may be unable to delete your personal information and where we are permitted to decline your request to delete your information.

‍Right to decline marketing communications
‍If you do not wish to receive marketing communications from Nordis Hotels, you may indicate your wishes on your registration card when you stay with us or send an e-mail to: office@nordishotels.com. You will always have the ability to accept or decline any form of communication from Nordis Hotels. You may unsubscribe from electronic marketing communications at any time by selecting the “unsubscribe” link included in such communications. Please note that you may not be able to opt out of service-related communications (e.g., account verification, transactional communications, technical and security and notices).

‍Other rights
‍You may also be entitled to:
- request the restriction of the processing of your personal information, or object to that processing;
- opt out from the processing or disclosure of your personal information for direct marketing purposes; and
- withdraw your consent to the processing of your personal information (where Nordis Hotels is processing your personal information based on your consent).
Where you are given the option to share personal information with Nordis Hotels, you can always choose not to do so.If you object to the processing of your personal information, or if you have provided your consent to processing and you later choose to withdraw it, we will respect that choice in accordance with our legal obligations.This could mean that we are unable to perform the actions necessary to achieve the purposes of processing described above (see ‘How do we use your personal information?’) or that you are unable to make use of the services offered by us.After you have chosen to withdraw your consent, Nordis Hotels may be able to continue to process your personal information to the extent required or otherwise permitted by law.If at any time you wish to exercise any of these rights, you can do so by:
- e-mail at office@nordishotel.ro
- phone call +40 (374) 435 544
- via letter –Attention: Nordis Hotels Headquarter
21 Alley Alexandru,
1st District, Bucharest, Romania
Alternatively, you can contact our Customer Care via the details in the ‘Contact us’ section.
You may make a request through an authorised agent (such as a lawyer).  We may request evidence of their authority to act on your behalf.Contact usIf you have any questions or concerns regarding this Privacy Notice, please contact our Customer Care by writing to the following address:
Customer Care
Nordis Hotels
21 Alley Alexandru
1st District, Bucharest, Romania