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INFORMATION

CONFIDENTIALITY OF DATA

Last Date Updated 27.04.2018

This Privacy Information ("Information") applies to TUSNAD S.A., its subsidiaries and all TUSNAD Hotels (collectively referred to as "TUSNAD", "us" or "us"). At TUSNAD, we do our best to deliver extraordinary products, services and experiences. We are glad that you are our client and value your loyalty. We are aware that privacy is an important issue for each customer. We have developed this Information to explain our practices regarding personal data we collect from you or yours on this site or our applications / forms through written or oral communications with us when visiting one of the properties or from other sources. Please note that this Information is not valid for personal data processing by us on behalf of third parties and in accordance with their instructions, such as airlines, car rental companies or other service providers, companies that organize or offers holiday packages, marketing partners, or corporate clients.


PERSONAL DATA THAT WE COLLECT

There is the possibility to collect personal data at every meeting or interaction with our guests as well as in other aspects of our work. This personal information may include: your identification data; your contact details; information about your reservation, stay or visit to a particular property; participating in a program as a member or loyalty program; participation in competitions, raffle or marketing programs (even if you are not staying at one of our hotels); information on the purchase and receipt of products or services; personal characteristics, nationality, income, passport number and date and place of issue; the history of the trip; Payment information, such as your credit card number and other card information, as well as authentication information and other billing details and accounts associated with the mobile billing system. guest preferences; advertising and communication preferences; information about the vehicles that you can bring to our properties; reviews and opinions about our accommodation facilities (if identified or associated with you); Affiliate programs for loyal airlines or partner travel programs and membership number; packages booked at hotels, airlines and car rental companies; the groups you are associated with for stays in hotels; information provided on membership applications and account applications; and other types of information you choose to provide us with or which we can obtain about you.

It is possible to request details of travelers, including their names and loyal customers' numbers, as well as the age of the rented car driver. It is also possible to collect information about conversations, including recording or monitoring calls to customer service for quality and training purposes, as well as other communications such as application messages and SMS.

In addition, we collect other personal information in certain situations, such as:
- Polls: There is a possibility to request demographics or other personal data in our customer surveys.
- Site collection: We collect additional personal information during registration / accommodation at our properties, including information that may be required by law. We can also use closed-circuit video or television cameras and other security measures on our properties that can capture or record images of guests and visitors in public places as well as information related to your location while you find our properties (by cards access and other technologies). It is also possible to use closed-circuit television and other technologies that record audio or video for the protection of our staff, guests and visitors to our properties in cases permitted by law.

Event profiles: If you plan an event with us, we collect conference or event specifications, event dates, number of guests, room details, and corporate events information about your organization (name, annual budget and number of events sponsored per year). In addition, we collect information about guests who are part of your group or event. If you visit us within a group, we may have personal information about you that the group has provided us and send you advertisements following your stay with your group or following an event, according to your preferences and according to the law. If you visit us at an event, we may send personal information about you to the event organizers to the extent permitted by law. If you are an event organizer, it is also possible to send information about your event to third-party service providers who can advertise their services to you to the extent permitted by law.

- Social networks: If you access TUSNAD pages / accounts through social networks, we can collect certain information from your social account depending on your social networking settings, such as (but not limited to) location, accommodations, activities , interests, photos, status updates, and friends list. We may also allow you to sign up for competitions where you must provide photographs, such as photos of your stay on our property, which you can share with people you are connected to on social networks for votes, joint offers or other promotions.
In addition to the information we collect directly from you, we can deduce information about you based on the information you provide us or on the basis of other information we receive.


PERSONAL INFORMATION THAT WE COLLECT FROM THIRD PARTIES

It is possible to collect information about you and third parties, including information from airlines, card partners and other partners, from social networking services that are consistent with your own settings for these services and other third-party sources that are authorized to transmit your data to us. We use and distribute this information (and we may add this information to other information we hold about you) for the purposes described in this Information.


USE OF PERSONAL DATA COLLECTED ABOUT YOU

We use your personal information for different purposes, including to offer and personalize the services you request and expect from TUSNAD to provide you with the expected hospitality level in your room and anywhere on our property and to conduct direct marketing actions and promotions, as detailed below:

- Service administration: We use your personal information to manage the programs you participate in, including to give you access to your account information, such as the status of rewards and bids for which you are eligible; to perform services that are part of such programs; to allow direct communication between properties within TUSNAD; and between TUSNAD and you; and to facilitate collections.
- Conferencing and Event Planning: We can use your personal information to provide you with information on conferences and events planning.

- Marketing and communication: We may use your personal information to provide you with, or offer, bulletins, special promotions and special offers as well as other advertising messages according to your preferences regarding your communication. We use your information to provide in-house messages, account alerts and reservations for reservations; to send you marketing messages; and to conduct studies, raffles, draws and other competitions. We can forward these communications via email, mail, online advertising, social networking, telephone, text messaging (including SMS and MMS), notifications, application messages and other means (including proprietary messages such as television in the room). With your consent, we use user-generated content (such as photos) from social networking services to display ads on our website and in our applications. It is possible to collect information from your card that may be associated with personal information and used by TUSNAD and to present and / or transmit advertising messages targeted to your payment method and according to your preferences.

- Service Improvement: We can use your personal information to improve TUSNAD services and to ensure that our site, products and services are of interest to you. We use your personal information and provide you with the expected hospitality level in your room and anywhere on our property.
- Fairness, analysis and personalization of data: We can corroborate your personal information with third-party data to update and analyze your information. We also rely on third-party information to provide better and more personalized services. For example, if you link social networks or other accounts to our services, we can use this information to make your experience with us more personal and social, or we can share it and use it as described in this Information.


THE PERSONAL INFORMATION THAT WE TRANSMIT

In order to provide you with the expected level of hospitality and provide the best level of service, we may share your personal information with our service providers and other third parties, as detailed below:
- Group Events or Meetings: If you visit TUSNAD in a group or conference, the information required for meeting and event planning can be shared with the organizers of these meetings and events and, if applicable, with the guests organizing or participating in the meeting or event.

- Business Partners: We can associate with other companies to provide you with products, services or offers based on your experiences on our properties and we can share the information properly with our business partners. For example, we can arrange for you to rent a car or provide other services from our business partners and we can therefore share your data with you. We can share your personal information, such as your email address, with your partners our tourism companies to assist them in assessing compliance with tourism policies or participating in special tariff plans or to engage in marketing in co-branding with our travel partners. We can also work with third parties such as airline partners or credit cards to enable us and our partners to provide advertisements to our common clients. Our partners can provide you with more relevant offers based on the information we provide about your experiences within our properties.
Additionally, we can allow third parties to recognize you when you visit the partner's website or application, or to recognize you as a customer when you visit TUSNAD websites or applications, so that you can provide more relevant offers. We may send a hash version of your email address to certain third parties using the available security measures; they can associate it with their own hash versions of email addresses so that they can forward online and through our email address advertisements on our behalf.

- Co-sponsors of promotions: We can sponsor promotions, lotteries, raffles, competitions or contests with other companies, or we can award prizes for lotteries and competitions sponsored by other companies. If you participate in these lotteries or contests, we may share your personal data with the collaborating sponsor or a third party sponsor.
- Location Services: We may transmit personal information to service providers such as concierge services, spa treatments, or festive dinners.

- Service Providers: We rely on third parties to provide services and products on our behalf and we can share your personal information with them accordingly. Our service providers are contractually bound to protect your personal information and may not use or otherwise distribute them except as otherwise required by law. However, our fraud detection service providers may use, but not distribute, your personal information for the purpose of detecting fraud. We may use service providers to communicate news and offer promotional and commercial materials on our behalf, including customized and customized mobile ads according to your preferences and applicable law.For more information, please see our Cookies Policy. TUSNAD only works with third parties that offer a method of unsubscribing from this type of advertising. We can share information with service providers and allow you to create itineraries by selecting sites, activities, and restaurants from custom lists for you based on your preferences and information from third parties.

- Commercial Transactions: As we grow our business, we can sell, buy, restructure or reorganize business or capital, or we can stop managing or keeping in the franchise a hotel that is part of our portfolio at the moment. In such circumstances, TUSNAD may transfer, sell or disclose the information collected, including, without limitation, Other Information (described below) and personal data to one or more third party affiliates or not affiliated with such commercial transactions. To the extent that the law so requires, we will provide a notice of our intention to transfer personal data to third parties for this purpose and we will explain how you can refuse such a transfer.

- Other: In addition, TUSNAD may disclose personal information to: (i) comply with applicable laws, (ii) respond to governmental or public authorities requests, (iii) protect TUSNAD's rights, confidentiality, security or property, site visitors (v) apply the terms and conditions of our sites and (vi) respond to an emergency .


OTHER INFORMATION

When you visit or interact with TUSNAD websites and applications, we collect other information that will not identify you directly with the use of the site, such as a catalog of the websites you visit and the number of visits to the websites ("Other Information"). We use Other Information as well as third-party data to send you emails and advertisements online (on our sites and on other sites) and on mobile. We may use Other Information and allow third parties to recognize you as their client when you visit TUSNAD websites or applications in order to provide you with more relevant offers.

We use cookies and other technologies (such as "pixel tags", "web beacons", "transparent GIFs", email links, JavaScript, device IDs assigned by Google, Facebook, Apple, or technologies similar) to collect this information. If you want to delete or block the Cookies on your device at any time, you can update your browser settings (refer to the browser's "Help" menu to learn how to delete or block Cookies). TUSNAD is not responsible for your browser settings. You can find appropriate and simple instructions on managing cookies on different types of browsers at www.allaboutcookies.org. For more information, please see our Cookies Policy.


SENSITIVE INFORMATION

The term "sensitive information" refers to information about your racial or ethnic origin, political opinions, religious or philosophical beliefs, union membership, health, sex or sexual orientation, genetic information, criminal history and any other biometric data used to unique identification. In order to provide healthcare services, we can collect your health data exclusively for this purpose. Your sensitive data will only be accessible to your attending physician. As regards their sharing with third parties, this will only take place on the basis of legal obligations (eg, reports to the National Health Insurance House, etc.). Your sensitive data will not be combined with other personal data we collect. We can also use the health data provided by you to better serve and meet your special needs (for example, providing access for people with special needs).


PERSONAL INFORMATION ABOUT MINORS

We do not consciously collect personal information about people under 18. As a parent or guardian, please do not allow children to transmit personal information without your permission.
LINKS TO WEB SITES AND THIRD PARTY SERVICES
Our site and mobile apps may contain links to third-party sites. Please note that we do not assume any responsibility for the collection, use, preservation, sharing or disclosure of data or information by such third parties. If you use or provide information on third-party sites, the terms and privacy policy of those sites apply. We encourage you to read the privacy policy of the sites you visit before sending personal data.
TUSNAD can associate with a limited number of Internet providers to provide internet access to our guests. The use of proprietary Internet services is subject to the terms of use and privacy of third-party internet providers. You can access these terms and policies by using the links on the service's login page, or by visiting the Internet provider's website.


PROTECTING PERSONAL DATA

TUSNAD will take all reasonable steps to: (i) protect personal information from unauthorized access, disclosure, or destruction, and (ii) maintain accurate and up-to-date personal information as appropriate. We also ask our affiliates and service providers with whom we share personal information to make reasonable efforts to maintain the confidentiality of your personal information about you. For online transactions, we use reasonable technological measures to protect the personal information you send us through our site . However, unfortunately, no security system or data transmission system on the Internet can guarantee the security of your data.
To protect your privacy, we recommend that you do not send us your credit card numbers or any other personal confidential information by email.
We will not contact you via mobile / text or email to request confidential information or credit card details. We will only request credit card details by phone when making a reservation.


INTERNATIONAL TRANSFER OF PERSONAL INFORMATION

We can associate with other companies outside of Romania to provide you with products, services or offers based on your experiences on our properties and we can share the information properly with our business partners. We do not transfer your personal data outside of the European Union.


MODIFICATION AND ACCESSING YOUR DATA PERSONAL

Under the current legislation, you have the right of access, data interference, the right of opposition, the right to delete the data, the right to data portability, the right not to be subject to an automatic individual decision and the right to appeal to the courts. You may request that we inform you of the personal data we hold about you, and in the necessary cases you may request us to update, correct and / or delete your personal data that we keep in our active data base. We will make any necessary updates and modifications within the time specified by the applicable law, and, if permitted by law, we may request an appropriate fee to cover the costs of responding to the request. Please send these requests in writing to jurist@tusnad.ro.

To protect your privacy, we can respond to such requests at the email address you have registered or provided by other means. Note that if you make a request to delete your data, we may not be able to offer you the quality and variety of services you are used to.
Also, under certain circumstances, depending on the applicable law, you may request that we discontinue the transmission of personal information about you to our business partners or you may request that TUSNAD cease to use your personal information about you by writing to us at the email address above. We will try to honor this request, in accordance with the legislation in force.


STORING PERSONAL DATA

We keep your personal data for the period necessary to achieve the purposes explained in this Information if a longer period of retention is not required or permitted by applicable law.
We will destroy your personal information as soon as possible and in a way that can no longer be recovered or reconstituted.
If personal information is printed on paper, it will be destroyed in a safe way by chopping or burning documents on paper or otherwise, and if it is stored on electronic media, it will be destroyed by technical means to ensure that information can no longer be recovered or reconstituted.
CHOICE - MARKETING COMMUNICATIONS

If you have provided us with your contact information (postal address, fax number, e-mail address or telephone number), we may, depending on your preferences and your consent in the necessary cases, inform you of our products and services, or invite you to events via e-mail, online advertising, social networking, phone, text messaging (including SMS and MMS), automatic notifications, application alerts, post, our customer support center and other means (including on-site messaging, for example on the TV in the room).
If you prefer not to receive any e-mail advertising materials, you can opt out by unsubscribing from the e-mail you receive from us. Requests for unsubscription may take up to ten business days to take effect.
In order to unsubscribe from text messages, you are communicating at the hotel reception that you no longer wish to receive text messages from our hotel or reply to the message with the text "STOP".

You can control if our mobile apps are sending notifications by changing notifications settings on your mobile device. If we send messages to your app, we will allow you to control them through the settings of our apps.


MODIFICATIONS OF INFORMATION

There is a possibility to make changes to this Information periodically. If we make significant changes to this Information, we will publish a link to the Revised Information on the homepage of our site, and if you have registered for any of our products or services, we will inform you through a communication channel to their provision. You may find out the date of the latest Update of the Information by consulting the link and the date of the beginning of the Information. Any change to this Information will take effect upon the publication of the Updated Site Information.