AMBERTON HOTELS

We care about safety of your personal data, therefore, we aim at ensuring the processing of personal data with utmost transparency. We prepared the present privacy policy, which specifies the types of personal data we collect, how we acquire these data, your rights and the procedure of implementation thereof.

GENERAL DATA CONTROLLERS

Your personal data shall be processed by the general data controllers

UAB „Šventaragio slėnis“

Legal entity code 300084300

Address: L. Stuokos-Gucevičiaus St. 1, LT-0122 Vilnius, Lithuania

Tel.: +370 5 2107461

E-mail: vilnius@amberton.lt

UAB „Hoteliers Co.”

Legal entity code 302306618

Address: L. Stuokos-Gucevičiaus St. 1, LT-0122 Vilnius, Lithuania

Tel.: +370 5 2107461

E-mail:

UAB „Klaipėdos“ viešbutis

Legal entity code: 140557410

Address: Naujojo Sodo St. 1, LT-92118 Klaipėda, Lithuania

Tel.: +370 46 404 372

E-mail: klaipeda@amberton.lt 

UAB „Šventaragio slėnis“ Kauno filialas

Legal entity code: 303488942

Address: Kuzmos St. 8, LT-44280 Kaunas, Lithuania

Tel.: +370 37 22981

E-mail: kaunas@amberton.lt

Palangos konferencijų centras, UAB

Legal entity code: 302447394

Address: Algirdo St. 14, LT-35245 Panevėžys, Lithuania

E-mail: palanga@amberton.lt

Druskininkų konferencijų centras, UAB

Legal entity code: 304144136

Address: Algirdo St. 14, LT-35245 Panevėžys, Lithuania

E-mail: druskininkai@amberton.lt

Marabel Holdings Ltd.

Legal entity code: HE382708

Address: Neapoleos St. 1, Oroklini 7041, Larnaka, Cyprus

E-mail: amberton@marabelholdingsltd.com.cy

The said data controllers shall be hereinafter referred to as the AMBERTON HOTELS or we.

This privacy policy (hereinafter – the Privacy Policy) is intended for the persons using AMBERTON HOTELS accommodation, SPA, restaurant, conference room rent and other services, purchase the goods or visit the website https://ambertonhotels.com, https://www.ambertonvillas.com and the candidates participating in the selection procedure for the vacancies published by AMBERTON HOTELS.

TERMS AND DEFINITIONS USED IN THE PRIVACY POLICY

Personal data shall mean any information pertaining to a natural person, whose identity is known or may be verified (data subject); a natural person whose identity can be verified is a person whose identity can be directly or indirectly verified, first of all, according to the indicators, such as name and surname, personal ID number, location data and online identifiers, or according to one or several physical, physiological, genetic, psychological, economic, cultural or social identity indicators of that natural person.

Data subject shall mean a person who uses AMBERTON HOTELS services, purchases the goods or visits the website https://ambertonhotels.com, https://www.ambertonvillas.com, contacts AMBERTON HOTELS regarding services/goods or for other purposes, as well as the candidates participating in the selection procedure for the vacancies published by AMBERTON HOTELS.

Request shall mean the request of the data subject regarding implementation of his/her rights.

Regulation shall mean the 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 (General Data Protection Regulation).

Website shall mean the website of AMBERTON HOTELS at https://ambertonhotels.com, https://www.ambertonvillas.com.

The present Privacy Policy may use other terms, the definitions of which shall conform to the provisions of the Regulation.

GENERAL PROVISIONS

The present Privacy Policy shall not constitute our agreement with you regarding processing of your personal data. By means of the present Privacy Policy, we intend to inform you about the main principles of processing of personal data and implementation of the rights of the data subjects. The additional information on processing of your personal data can be provided in the sale and purchase, service and other types of agreements.

By using the services of AMBERTON HOTELS, purchasing the goods, submitting your data, sending the CV, filling out the enquiry or reservation forms, continuing surfing the Website, you confirm that you have familiarised with the present Privacy Policy and understand its provisions.

The present Privacy Policy shall not apply when using the services or websites of other companies or other booking systems, such as, for example www.booking.com. We recommend reading the notifications of other service providers and contacting them directly regarding processing of your personal data.

PRINCIPLES OF PERSONAL DATA PROCESSING

AMBERTON HOTELS processes personal data in accordance with the legal acts of the European Union and the Republic of Lithuania regulating processing of personal data.

The scope of personal data processed depends on the services and goods ordered or used, AMBERTON HOTELS legal relations with the data subject or other persons, as well as the information submitted by the person ordering and/or using the services, purchasing the goods, visiting the Website or contacting AMBERTON HOTELS.

We process your personal data only in the presence of a lawful processing criterion – seeking to take actions upon your request prior to conclusion of the agreement or to perform the agreement; upon your consent; where processing of Personal Data is mandatory under the particular legal acts; where the Personal Data must be processed for the protection of our or the third party's legitimate interests.

The aim at processing of Personal Data in an accurate, fair and lawful manner, where the data processed for the purposes they were collected for and in conformity with the clear and transparent principles and requirements of processing of the Personal Data set forth in the legal acts.

HOW WE OBTAIN PERSONAL DATA

We can receive the Personal Data directly from you, when you:

• Fill out the enquiry or reservation forms on the website;
• Send your curriculum vitae (CV) and other information related to employment;
• Submit a request for the acquisition of services provided by AMBERTON HOTELS;
• Otherwise contact AMBERTON HOTELS;
• Communicate with AMBERTON HOTELS via social networks or simply follow AMBERTON HOTELS’ activities on social networks;
• Use the hotel room key cards at AMBERTON HOTELS.
• AMBERTON HOTELS provide you with services.

We can also obtain your Personal Data indirectly:

• From the online booking channel you use to complete reservation, such as www.booking.com and others;
• From your travel agent or another person ordering AMBERTON HOTELS services on your behalf;
• From the social media platforms or online surveys;
• From AMBERTON HOTELS groups of companies;
• From AMBERTON HOTELS data controllers or other external sources.

The Personal Data can be generated when you use the services or make inquiries in their respect, for example, by calling, sending SMS, e-mail, ordering services and goods, and visiting the Website.

You are not obliged to provide us with any of your Personal Data, however, it is possible that in the absence of availability thereof, we will be unable to performs certain actions, e.g., provide services, sell goods or issue invoices.

RECIPIENTS OF PERSONAL DATA

Your privacy is important, therefore, we shall not transfer your personal data to other persons without your consent, except to the following persons:

• AMBERTON HOTELS groups of companies;
• In the event of a dispute – to the persons providing legal services to AMBERTON HOTELS;
• Auditors and other consultants;
• Data processors or booking services suppliers engaged;
• Payment service providers (banks, credit institutions, payment initiation service providers, etc.);
• Online booking channels, the data subject uses to complete the reservation, such as www.booking.com, etc., and data controllers, for the purposes of ordering and provision of services to you;
• Your travel agent or another person ordering AMBERTON HOTELS services on your behalf, for the purposes of ordering and provision of services to you;
• The state institutions, law enforcement authorities and other persons in the procedure prescribed by the legal acts of the Republic of Lithuania.

Should we disclose your personal data to the data recipient groups other than those indicated in the present Privacy Policy, we will notify you about it no later than upon the first disclosure of the data, except in cases where such information has already been presented to you in other documents provided or documented concluded with you.

AIMS OF PROCESSING OF PERSONAL DATA

AMBERTON HOTELS shall process your personal data for the following purposes: order and supply of services/goods; direct marketing, customer service, room reservation, website traffic statistics and monitoring, website improvement, AMBERTON HOTELS promotion, analysis of AMBERTON HOTELS hotel rating and visitor opinion, complaint examination, improvement of services (including customer conduct monitoring), protection of assets and persons, internal administration, debt recovery and administration; presentation, execution and defence of legal claims, maintaining relations with customers and partners; accounting; administration and implementation of contracts; order administration; and recruitment.

GROUPS OF DATA SUBJECTS WHOSE PERSONAL DATA ARE PROCESSED BY AMBERTON HOTELS

We shall process your personal data, if you belong to any of the groups of persons listed below:

• Persons who use AMBERTON HOTELS services and goods or order AMBERTON HOTELS services and goods for other persons, or on whose behalf AMBERTON HOTELS services and goods have been ordered;
• Persons surfing the Website https://ambertonhotels.com, https://www.ambertonvillas.com;
• Persons who communicate in any manner with AMBERTON HOTELS or simply follow AMBERTON HOTELS activities in social networks;
• Persons who provide their opinion about AMBERTON HOTELS or present their assessment of AMBERTON HOTELS on the social media platforms;
• Persons who agreed to receive direct marketing messages or did not object to processing of their personal data for the purposes of direct marketing at the moment of collection of data;
• Candidates participating in the recruitment procedures;
• AMBERTON HOTELS buyers, business partners, employees and suppliers.

CATEGORIES OF PERSONAL DATA PROCESSES BY AMBERTON HOTELS

The following principal categories of personal data may be processed by AMBERTON HOTELS for the aforesaid purposes of processing of personal data, including, but not limited to:

• data subject's name and surname,
• date of birth, age,
• ID card (passport) number, date and place of issue,
• telephone number,
• address, country,
• e-mail,
• service/product purchased,
• check-in and check-out dates at AMBERTON HOTELS hotel,
• information on co-residents,
• data subject's preferences (food, etc.),
• discount code,
• reservation number,
• additionally ordered services,
• signature,
• IP address,
• Website browsing history and date,
• other information necessary for provision of services and goods, maintaining relations, issue of invoices and administration of contracts, and presentation of legal requirements,
• reviews and AMBERTON HOTELS reviews on social media,
• data subject's habits related to the services provided by AMBERTON HOTELS,
• data subject's profile and other information available on social media,
• video recordings,
• information received when you use AMBERTON HOTELS hotel key cards,
• data about your health condition,
• other data categories.

Detailed information about other data categories shall be presented in separate sections of the Privacy Policy.

PROCESSING OF HEALTH RELATED DATA

In order to properly provide you with the wellness services, AMBERTON HOTELS processes data about your health condition. Your health information received for the purposes indicated herein shall be kept confidential and shall not be shared with other persons.

DATA PROCESSING RELATED TO PAYMENT COLLECTION

Seeking to ensure payment for the services we provide, we:

• use services of entities providing payment collection services. For this purpose, we transfer your identification data, order data and e-mail to entities providing payment collection services, who send an invoice with a link for payment to your e-mail;
• collect your credit/debit card information. Upon receipt of your credit/debit card information, we shall verify your credit limit.

The data related to payment collection shall be processed only for the purposes of guarantee of payment for the services (for the protection of our legitimate interests).

In the event of cancellation or change of the order or in other cases of payment refund, we shall return the money directly via the commercial bank.

PROCESSING OF VIDEO RECORDINGS FOR THE PURPOSES OF PROTECTION OF ASSETS AND PERSONS, AND THEFT PREVENTION

Our hotels are provided with the video surveillance system seeking to protect our and your assets and property of other persons, as well as health and life of individuals on the ground of legitimate interests of AMBERTON HOTELS and the third persons.

The following information shall be collected during performance of the video surveillance: video recordings, date, time and place stamp of the video recordings.

The shall organise the video surveillance in the manner where the space under surveillance shall be restricted to only the necessary territory of our hotel (premises, part of premises). We shall monitor the inside area and entrances to the hotel premises.

No video surveillance shall be conducted in the rooms and/or territories designated for personal use, i.e., lavatories, showers, changing rooms, etc., as well as inside the hotel rooms.

The video recordings shall be used only for the purposes of exposure of suspected criminal activities and violations of administrative rights, or acquisition of evidence and disclosure of the damages incurred to the assets of AMBERTON HOTELS employees, service providers, third persons or assets of AMBERTON HOTELS, and human health and life, and may be transferred only to the persons authorised to receive this information in the procedure prescribed by law.

The video recordings may be viewed upon your request, if they are related to you personally, and where the period of retention of such recordings has not expired. If necessary, the video recordings may be transferred to the law enforcement authorities upon their request or demand for provision of such data. If the video recordings are viewed outside the premises of the law enforcement authorities or court, the viewing of the video recordings shall be conducted in a closed room of AMBERTON HOTELS. The data subject, responsible AMBERTON HOTELS employee and representatives of the law enforcement authorities shall have the right to participate during viewing.

The images of the video recording and video recording may be provided upon your request on the media of AMBERTON HOTELS or media provided by you.

PROCESSING OF KEY CARD DATA FOR THE PURPOSES OF PROTECTION OF ASSETS AND PERSONS, AND THEFT PREVENTION

Seeking to ensure that your stay at AMBERTON HOTELS hotel is safe, and for the purposes of protection of assets and persons, as well as theft prevention, AMBERTON HOTELS shall conduct the access control procedures. The access control procedure shall be performed by asking you to use the room key card issued by AMBERTON HOTELS.

The room key card shall register when you leave / enter your AMBERTON HOTELS hotel room. During your stay, we shall assign a number to your key card and set its validity period.

The data received from the use of the room key cards shall be used only for the purposes of exposure of suspected criminal activities and violations of administrative rights, or acquisition of evidence and disclosure of the damages incurred to the assets of AMBERTON HOTELS employees, service providers, third persons or assets of AMBERTON HOTELS, and human health and life, and may be transferred only to the persons authorised to receive this information in the procedure prescribed by law.

DATA PROCESSING FOR DIRECT MARKETING PURPOSES

When you provide to us your name, surname, e-mail address and telephone number, you can either consent or not consent to your data being used by us for the direct marketing purposes.

During processing of your personal data for direct marketing purposes, we can also receive information on whether or not the newsletter has been read: when and how many times the message or the link included have been opened.

Upon receipt of your consent, we will send you information about the services and goods offered by AMBERTON HOTELS and by other related companies.

If you have already purchased the goods or reserved/purchased services from us, also if you have already concluded an agreement with us and during collection of data did not object to processing of your personal data for direct marketing purposes, your personal data shall be processed on the ground of legitimate interest by sending messages about similar goods or services. In this case, you shall be able to refuse receiving the direct marketing messages by notifying us by e-mail privacy@amberton.lt, or by clicking the unsubscribe link on the bottom of the newsletter received from AMBERTON HOTELS.

You can withdraw your consent for processing of your personal data for direct marketing purposes at any time by notifying us at privacy@amberton.lt, or by clicking the unsubscribe link on the bottom of the newsletter received from AMBERTON HOTELS.

ANALYSIS OF AMBERTON HOTELS HOTEL RATING AND GUEST EVALUATIONS, AND EXAMINATION OF COMPLAINTS FOR THE PURPOSES OF IMPROVEMENT OF SERVICES

AMBERTON HOTELS shall process your personal data received via the social medial platforms (such as Facebook, Instagram, LinkedIn and other) or online reviews (e.g., TripAdvisor) seeking to examine your complaints or respond to positive feedback, and monitor our reputation online in order to be able to use these measures for evaluation and improvement of the quality of our services. For the purposes indicated in this section, your personal data shall be processed on the ground of legitimate interests of AMBERTON HOTELS.

For the purposes indicated in this section, we shall process your personal data you shared with us or published on the social media or in other online reviews about us.

TRACKING AND ANALYSIS OF YOUR BEHAVIOUR FOR THE PURPOSES OF IMPROVEMENT OF SERVICES

When you stay at AMBERTON HOTELS, we shall process you name, surname, number of stays at AMBERTON HOTELS, the amount and date of payment for the services, room service items and additional services ordered. We shall process these data in order to evaluate and improve the quality of our services and offer you customised services during your following stay at AMBERTON HOTELS. For the purposes indicated in this section, your personal data shall be processed on the ground of legitimate interests of AMBERTON HOTELS.

DATA PROCESSING DURING PURCHASE OF THE GIFT CERTIFICATE

We shall process your name, surname, information on the services/goods indicated on the certificate, your e-mail address, expiration date of the gift certificate, and payment information received during purchase of the gift certificate. If you purchase the gift certificate for another person, we shall also process the name of the certificate recipient.

PROCESSING OF PERSONAL DATA FOR PURPOSES OF EMPLOYMENT AT AMBERTON HOTELS

The potential AMBERTON HOTELS employees (candidates, persons applying for a job) shall provide the following personal data to AMBERTON HOTELS: curriculum vitae, name, surname, telephone number, e-mail address. We shall inform you about processing of your personal data as a potential employee and the retention period at the moment of the first contact either verbally or by e-mail. You can familiarise with processing of your personal data as a potential employee in this section of the Privacy Policy.

If you contact AMBERTON HOTELS via the social media, i.e. LinkedIn, the social network operator may process your inquiries in the vacancies published by AMBERTON HOTELS for the purposes set forth in the policy of the social network operator.

The data you provide when applying for a specific position announced by AMBERTON HOTELS shall be processed for the purposes of conclusion of an employment contract with you as a potential employee.

If you apply for a specific position announced by AMBERTON HOTELS, upon completion of selection for a specific position announced by AMBERTON HOTELS, your personal data shall be destroyed, except in cases where you provide your consent for storage of your personal data for the purposes of future recruitment at AMBERTON HOTELS. You can withdraw your consent for processing of your personal data for the purposes indicated in this section of the Privacy Policy at any time by expressing your will in a clear and unambiguous manner in writing to the employee of AMBERTON HOTELS by contacting AMBERTON HOTELS by telephone or e-mail.

PROCESSING OF PERSONAL DATA FOR PURPOSES RELATING TO THE EXISTING RESTRICTIONS OF COVID-19

If you visit AMBERTON HOTELS restaurants, we process your personal data, including your name, surname and telephone number. The mentioned data is processed according to the requirements of the Ministry of Health of the Republic of Lithuania for the purposes of implementation of COVID-19 disease (coronavirus infection) prevention and control measures. If you do not consent to the processing of your personal data, you will not be allowed to visit AMBERTON HOTELS restaurants.

RETENTION PERIOD OF PERSONAL DATA

The personal data shall be processed for a period no longer than necessary to achieve the purposes of data processing or no longer than required by the data subjects and/or provided in the legal acts.

Usually, the data shall be processed during validity of the contract, provision of services and 10 (ten) years following expiration of the contract and completion of provision of services by complying with the requirements related to storage of documents and those prescribed by the legal acts, as well as seeking to declare, implement or protect the legal requirements of AMBERTON HOTELS.

Upon consent of the data subject, AMBERTON HOTELS shall process personal data for the purposes of direct marketing for a period of 5 (five) years from the moment of receipt of the data subject's consent or until the data subject withdraws his/her consent for processing of the data.

For the purposes of direct marketing, when sending messages to the data subject about the similar goods or services of AMBERTON HOTELS on the ground of legitimate interests, AMBERTON HOTELS shall process the personal data during validity of the contract concluded with the data subject and 3 (three) years following expiration thereof or completion of acquisition of the goods/services (in the event of a single purchase of goods/services) or until the data subject expresses his/her objection to receiving such messages from AMBERTON HOTELS.

Upon completion of the selection procedure, the data submitted by the applicants, where no employment contract is concluded with the applicant, or where the applicant provided his/her data without applying for a specific position at AMBERTON HOTELS, shall, upon consent of the data subject, be retained for a period of 1 (one) year or until the data subject withdraws his consent for processing of the data.

AMBERTON HOTELS keeps records of telephone conversations made for the purpose of improving service for a maximum of 14 days.

AMBERTON HOTELS shall process the data during monitoring of the guest behaviour for the purposes of improvement of services and adaptation to the guest needs no longer than for a period of 3 (three) years of the last contact with the data subject.

Payment card data shall be retained for a period of 4 days after checkout. For bookings made before 31 of December, 2020, payment card data shall be retained up to 1000 days after checkout.

AMBERTON HOTELS shall process your personal data obtained via the social media platforms or online surveys seeking to examine your complaints or respond to positive feedback, monitor our online reputation for the purposes of evaluation and improvement of the quality of our services no longer than for a period of 1 (one) year of the moment of collection of such data.

The video materials containing personal data and personal data received during use of the key card shall be retained and processed no longer than for a period of 1 (one) month of the date of recording/receipt of the data.

Data on health status are stored for a period specified by law. Your sleep data, which is not included in the sickness card, will be deleted immediately after the services are provided.

Where the data subject withdraws his/her consent for processing of the data or the processing term of data expires (where the data are processed on the ground of the data subject's consent), in this case only the data confirming the facts of consent granted by the data subject shall be retained, however no longer than for a period of 10 (ten) years of the expiration of the consent term or withdrawal of consent, seeking to declare, implement or protect the legal requirements of AMBERTON HOTELS.

Your personal data obtained in accordance with the requirements of the Ministry of Health of the Republic of Lithuania for the implementation of COVID-19 disease (coronavirus infection) prevention and control measures shall be stored and processed for no longer than 21 days from the date of receiving of such data.

DATA PROCESSORS

Your personal data may be processed by the data processors providing accounting, legal, website hosting, data centre and/or server rental, IT maintenance, external audit, and other services to AMBERTON HOTELS, as well as to the operator of the hotel management systems and operators of the hotel booking system.

The data processor shall have the right to process the personal data only according to AMBERTON HOTELS instruction and only in the scope necessary seeking adequate implementation of the obligations established in the contract. By engaging the data processors, AMBERTON HOTELS seeks to ensure that the data processors have implemented the suitable measures ensuring organisational and technical security and protect secrecy of personal data.

COMMON DATA CONTROLLERS

Your personal data may be processed not only by the data controllers indicated in the present Privacy Policy, but also other data controllers (i.e., the common data controllers in the manner defined in Article 26 of the Regulation), for example, from other AMBERTON HOTELS groups of companies.

We have concluded agreements with the common data controllers, the essential provisions of which you shall have the right to familiarise with by contacting AMBERTON HOTELS. Upon your request, we shall provide the contact details of the common data controllers.

When we process your data together with other data controllers, you can invoke your rights set forth in the Regulation in respect to each of the common data controllers.

YOUR RIGHTS PERTAINING TO THE PERSONAL DATA

As a data subject, you shall have the following rights indicated in the present section.

The right to know (be informed) about processing of your personal data

When we receive information directly from you, we shall inform about processing of personal data at the moment of receipt of the data:

1. verbally (where communication with you is carried out by verbal means exclusively, e.g., on the phone);
2. in writing (information sent to you by e-mail shall be considered to have been provided in writing).

If we receive your data not directly from you, we shall inform you about processing of personal data verbally or in writing (as specified above) no later than within 1 (one) month of receipt of the data, and where we use your personal data to maintain communication with you – no later than at the moment of the first contact with you.

The right to familiarise with own personal data and a manner in which they are processed

You shall have the right to receive information on the retention period of personal data, information on the sources used to collect personal data, type of data collected, the purposes the data are processed for and who has access to the data.

Upon receipt of your request, we shall immediately, however, in any case no later than within 1 (one) month of the receipt of the request, verify whether your personal data are processed by AMBERTON HOTELS. Having established that we process your personal data, we shall provide to you the information on the personal data processed and a copy of the personal data in an electronic format or on a paper medium.

We shall be entitled, whenever necessary, to extend the response period depending on the complexity and number of your requests. We shall inform you about it by a separate notification. If we decide to extend the response period, you must contact the State Data Protection Inspectorate regarding such extension.

Normally, the information shall be provided free of charge. However, if your requests are obviously unsubstantiated or unreasonable, primarily due to their repeated content, or, if you prefer to receive a copy of the personal data processed in a format other than the electronic or paper form prepared by AMBERTON HOTELS, AMBERTON HOTELS may charge a fee comprising the expenses incurred by AMBERTON HOTELS due to provision of information or administration of the notification or actions requested.

Moreover, if your requests are obviously unsubstantiated or unreasonable, we shall have the right to refuse to execute your request.

Upon your request, the information may be provided verbally, allowing to familiarise with the document by presenting a statement, document extract or a paper copy of the document or an electronic medium attached to the reference file. If you do not indicate the format for provision of information, we shall present the information to you in the same format as the request received.

The right to request correction of personal data or termination of processing of such personal data, if, upon familiarisation with your personal data you established that the data are incorrect, incomplete or inaccurate

AMBERTON HOTELS shall inform you immediately about performance or non-performance of correction, destruction or cancellation of processing of personal data initiated upon your request. We shall also notify the data recipients about personal data corrected or destroyed, data processing actions terminated upon your request, except in cases where provision of such information is impossible or exceedingly difficult. In this case, upon your request, we shall provide you the information pertaining to such data recipients.

The right to destroy personal data or restrict the data processing actions in the even where, upon familiarising with own personal data, the data subject determines that the personal data have been processed unlawfully or fraudulently

AMBERTON HOTELS shall notify you immediately about implementation or non-implementation of the data processing restrictions.

The personal data, the processing of which is restricted, shall be retained. Prior to removing the restrictions, we shall notify you about it by electronic means of communication. We shall also notify the data recipients regarding the restricted processing of data implemented upon your request, unless this proves impossible or involves a disproportionate effort. In this case, upon your request, we shall provide you the information pertaining to such data recipients.

The right not to consent to processing of your personal data, except in cases where these personal data are processed for the legitimate interest sought by the data controller or the third party these personal data are provided to, and where the interests of the data subject are not more important

If you express objection to processing of your personal data, the processing of thereof shall be performed only where it has been reasonably deemed that the reasons the processing of personal is performed take priority over your interests, rights and freedoms, or if your personal data are required to declare, implement or protect legal requirements.

The right to object to processing of personal data for the purposes of direct marketing

You shall be able to refuse receiving the direct marketing messages by notifying us by e-mail privacy@amberton.lt, or by clicking the unsubscribe link on the bottom of the newsletter received from AMBERTON HOTELS.

The right to withdraw the consent for processing of personal data

You shall have the right to withdraw all your consents for processing of personal data at any time, if the ground for processing of your personal data is the consent provided to AMBERTON HOTELS upon your discretion.

The right to delete the data (the right “to be forgotten”)

You shall have the right to demand that AMBERTON HOTELS delete any personal data pertaining to you on the grounds prescribed in part 1 of the Regulation.

We shall have the right to refuse to comply with your request in cases prescribed by the legal acts, including, but not limited, to the cases described in Article 17(3) of the Regulation.

If we comply with your request, however, your personal data (deleted upon your request) have been transferred to the data recipients, we shall inform such data recipients, unless this proves impossible or involves a disproportionate effort. In this case, upon your request, we shall provide the information pertaining to such data recipients.

This right cannot be exercised, where we are obliged to retain the personal data according to law.

The right to data portability

You shall have the right to demand that the personal data you provided, if they are processed on the grounds of consent or contract, and where they are processed with the help of automated means, are transferred to another data controller or presented to you in a systematised, commonly used and computer-readable format, whenever technically possible. When contacting us to exercise the right to data portability, you shall indicate whether you prefer that your personal data are transferred to you or to another data controller.

If we comply with your request and you prefer that the data are transferred on a digital media, we shall provide your personal data processed by AMBERTON HOTELS on a CD-ROM you provide, or on a CD-ROM provided by AMBERTON HOTELS, whereas you shall compensate the acquisition cost of this media.

You shall not have the right to portability of the personal data, which are processed in a non-automated manner by systematised media, such as paper files.

The personal data transferred upon your request shall not be automatically deleted. If you would like your data to be deleted, you shall contact AMBERTON HOTELS regarding the execution of the right to demand to delete the data (“right to be forgotten”).

The right to object to processing of data exclusively in an automated manner, including profiling, being applied in respect of the data subject

You shall have the right to know and be informed about the logic, according to which the personal data are processed automatically, and the possible consequences of such processing of personal data, where the data are processed exclusively in an automated manner.

If you contact us regarding the review of the decision concerning the automated data processing (if such were to be adopted by AMBERTON HOTELS in your respect) we shall conduct a thorough evaluation of the significant data, including the information you provided.

The right to lodge a complaint to the State Data Protection Inspectorate or a competent court regarding processing of personal data

You can appeal our actions related to implementation of the rights of the data subject or omission thereof to the State Data Protection Inspectorate, address A. Juozapavičius g. 6, Vilnius, e-mail: ada@ada.lt, website: www.ada.lt, as well as to a competent court of the Republic of Lithuania. You shall have the right to appeal the actions of AMBERTON HOTELS or omission thereof personally or through a duly authorised representative or a non-profit institution, organisation or association conforming with the requirements of Article 80 of the Regulation.

The right to compensation of damages suffered due to violation of the data subject's rights

You shall be entitled to compensation of pecuniary and non-pecuniary damages, for the award of which, you must contact a competent court of the Republic of Lithuania.

PROCEDURE OF CONTACTING AMBERTON HOTELS REGARDING IMPLEMENTATION OF THE RIGHTS OF THE DATA SUBJECT

You shall be entitled to contact us regrading implementation of the data subject's rights verbally or in writing, by submitting a request personally, by post or electronic means using the contact details provided in the present Privacy Policy.

If you contact us verbally regarding implementation of the data subject's rights or submit a written request personally, you must confirm your identify by producing an ID document. If you fail to do so, we will be unable to accept your request and your rights of the data subject shall not be implemented. This provision shall not apply, if you contact us regarding information on the processing of personal data on the grounds of Articles 13 and 14 of the Regulation.

If you decide to submit a written request regarding implementation of the data subject's rights by sending your request by post, you shall be obliged to provide together with the request a copy of the ID document certified by a notary public or in another procedure prescribed by the legal acts.

If your personal data, such as the name and surname, have been changed, you shall also provide the copies of the documents confirming the change of these data; if they are sent by mail, the copies must also be certified by a notary public or in another procedure prescribed by the legal acts.

If you decide to submit the request by electronic means, the request shall be endorsed by a qualified electronic signature or generated by electronic means, which allow to ensure that the text is integral and indelible. This provision shall not apply, if you contact us regarding information on the processing of personal data on the grounds of Articles 13 and 14 of the Regulation.

The request for implementation of the data subject's rights shall be legible, endorsed, and include your name, surname, address and/or other contact details for communication or where the response regarding implementation of the data subject's rights shall be sent to.

You shall be entitled to implement your rights personally or through a representative. If you decide to implement your rights through a representative, your representative shall indicate in the request his/her name, surname, address and/or other contact information for communication, to which your representative prefers to receive the response, as well as your name and surname, and provide other data necessary for proper identification of the data subject, and present a document confirming authorisation for representation or a copy thereof.

Should there be any doubts as to your identity and data, we shall have the right to request additional information necessary for verification thereof.

For all questions related to management of the personal data of a data subject and exercise of your rights, you should contact the data protection official of AMBERTON HOTELS. When you contact the data protection officer of AMBERTON HOTELS by mail, we recommend to make a note on an envelope indicating that the correspondence is intended for the data protection officer of AMBERTON HOTELS.

If you contact us in prejudice to the procedure indicated in the present section, we shall inform you about it no later than within 7 (seven) calendar days of the date of receipt of your request and state the inconsistencies. If you fail to rectify the inconsistencies indicated or fail to provide the reasons to AMBERTON HOTELS why the inconsistencies indicated cannot be eliminated, your request shall not be examined.

In the presence of objective circumstances, due to which the said inconsistencies cannot be rectified, upon assessment of the circumstances, we could decide to accept and examine your request.

We shall not consider that your request has been submitted with inconsistencies, where your written request does not conform to the request format specified in the present section of the Privacy Policy.

ENSURING DATA SECURITY

AMBERTON HOTELS implements appropriate organisational and technical data security measures, including protection against unauthorised processing of data or illegal processing of data, and accidental loss, destruction or damaging (integrity and confidentiality principle) thereof. The access to the personal data shall be granted only to those employees, service providers and authorised data processors, who require access thereto for performance of the job functions or provision of services.

AMBERTON HOTELS’ SOCIAL MEDIA ACCOUNTS

AMBERTON HOTELS has created and manages the social media accounts on LinkedIn and Facebook. All information you provide via the social media means on LinkedIn and/or Facebook (including notifications, use of ‘Like’ and ‘Follow’ buttons, and other communication), or which is received when you view AMBERTON HOTELS social media accounts (including information received through the use of cookies by the social network operators), shall be controlled by the social network operators. We recommend reading the privacy notifications of the social network operators and contacting them directly regarding the use of your personal data.

As the administrator of LinkedIn and Facebook accounts, AMBERTON HOTELS selected the appropriate settings with regards to its target audience, as well as the activity management and promotions objectives. The social network operator granting the possibility to create and manage the AMBERTON HOTELS social network account may restrict the possibility to change certain essential settings, making it impossible for AMBERTON HOTELS to have influence on which information pertaining to you will be collected by the social network operator after AMBERTON HOTELS creates a social media account.

All such settings, both selected by AMBERTON HOTELS and defined by the social network operator may have influence on processing of your personal data during the use of the social media, visiting the AMBERTON HOTELS account or reading AMBERTON HOTELS social media messages. Even if you only view AMBERTON HOTELS messages on social media, the social network operator may obtain certain personal information, such as the end device used and your IP address.

The social network operator usually processes your personal data (even those obtained upon selection of additional account settings by AMBERTON HOTELS) for the purposes established by the social network operators on the basis of its privacy policy. However, when you use the social network, communicate with AMBERTON HOTELS via the social network, visit the AMBERTON HOTELS social network account or follow AMBERTON HOTELS posts on this network, AMBERTON HOTELS shall receive information about you. The scope of data received by AMBERTON HOTELS depends on the account settings selected by AMBERTON HOTELS, agreement with the social network operator for ordering of additional services and cookies used by the social network operator.

LinkedIn social network operator shall collect information on the type of content you view, your actions on LinkedIn social network, information on your education, who you communicate with and other information. To learn more about the privacy policy of LinkedIn operator go to https://www.linkedin.com/legal/privacy-policy.

Facebook social network operator collects information on the type of content you view, your actions on Facebook social network, what persons you communicate with, how often and how long you have been communicating with them, your activity level on the social network and other information, including information on the end device you use. To learn more about the privacy policy of Facebook operator go to https://www.facebook.com/policy.php.

BOOKING SYSTEMS

You can book the accommodation and other related services offered by AMBERTON HOTELS by means other than our booking system, such as external booking systems, e.g., www.booking.com, etc.

AMBERTON HOTELS can receive your orders submitted via such external booking systems, however, your personal data provided in the external booking systems shall be initially processed by operators of these external booking systems. We shall not bear responsibility for your personal data being processed by the external booking system operators. Therefore, prior to submitting any data in the external booking systems, we recommend to carefully reading the personal data privacy policy of the external booking system operators.

ONLINE SURVEYS

We value the feedback you provide in online surveys (e.g., TripAdvisor), however, please note that the personal data you provide in online surveys shall be processed by the online survey operators. We shall not bear responsibility for processing of your personal data by the online survey operators. Therefore, prior to submitting any data or providing feedback in online surveys, we recommend to carefully reading the personal data privacy policy of the online survey operators.

COOKIES

We use cookies seeking to improve your website experience – cookies are small elements of information created automatically during the Website browsing and stored on your computer or another end device.

Information collected allows to ensure enhanced comfort while surfing the Website, make offers and learn more about the conduct of our Website users, analyse trends and improve both the Website and services provided, save your completed or incomplete reservations allowing you to return to them later. The cookies allow AMBERTON HOTELS to offer services adapted to the consumer needs (e.g., by displaying only the content relevant for a particular consumer). If AMBERTON HOTELS Website contains links to other websites (including external booking systems or online reviews), which also use cookies, these have not been described herein.

Where the functional, tracking, advertising cookies and/or third party cookies are created, we shall ask for your consent. When necessary cookies are created, we shall use them on the ground of legitimate interest, which shall not require your consent for the use of such cookies.

If we receive your consent, when using the same cookie for the same purposes in the future, we shall not ask for your consent again. This also applies in the respect of using the third party cookies.

Detailed information on the cookies used by LinkedIn social network is available here https://www.linkedin.com/legal/cookie-policy.

Detailed information on the cookies used by Facebook social network is available here https://www.facebook.com/policies/cookies/

If you do not consent to cookies being stored on your computer or another end device, when we ask for your consent to store cookies, you can change your internet browser settings and disable all cookies, or to enable/disable them one by one. However, please be advised that, in certain cases, deleting cookies might slow down the browsing speed, limit certain functions of the Websites or block access to the Website. Detailed information is available at AllAboutCookies.org or www.google.com/privacy_ads.html.

STATISTICS

The Website visitor statistics shall be analysed with the help of Google Analytics. The information collected by Google Analytics cookies about our Website browsing history can be transferred and stored on the servers beyond the borders of the European Union.

OTHER PROVISIONS

By contacting us you express your will to allow AMBERTON HOTELS to contact you regarding your enquiry.

The enforcement and interpretation of the Privacy Policy shall be governed by the laws of the Republic of Lithuania. AMBERTON HOTELS may modify the present Privacy Policy upon its discretion, which shall come into force as of the moment of its publication on the Website https://ambertonhotels.com.

The present Privacy Policy has been updated on 2021/05/21.