PROVISIONS ON CONFIDENTIALITY OF CAUCASIA TRAVEL

This Regulation on the confidentiality of the CAUCASIA TRAVEL (hereinafter - the "Regulations") applies to the CAUCASIA TRAVEL, which is the tour operator of the Management Grup Otel (hereinafter referred to as CAUCASIA TRAVEL, “we” or “us”). All over the world, tourists / consumers of services under the umbrella brand "Management Grup Otel" are provided with services, travel products and conditions of the highest quality. We have great respect for your business and appreciate your trust. We understand the importance of confidentiality. We have therefore developed this Policy in order to clarify our policies regarding personal information received orally or in writing or provided when visiting this site, receiving our services or from other sources. Although this Regulation summarizes the rules adopted under the CAUCASIA TRAVEL umbrella brand worldwide, local laws are subject to change and restrictions may be imposed on our data processing activities in some jurisdictions. rules in these jurisdictions may be more limited than those described in this Regulation to ensure compliance with local requirements. If you are a resident of the European Economic Area (EEA), please read Annex 1 to this Regulation for additional information on the use of CAUCASIA TRAVEL of your personal data.

By using any of our products or services and / or agreeing to this Regulation, you understand and agree to the collection and use of personal data in accordance with the information provided in this Regulation.

Please note that this Regulation does not apply to the processing of personal information on behalf of or on behalf of third parties and service providers.

The services united under the umbrella brand CAUCASIA TRAVEL are tours which you can get acquainted with, having followed the link: https://caucasia.travel/

1. Personal information collected by CAUCASIA TRAVEL

CAUCASIA TRAVEL collects personal data when communicating with tourists / consumers and other contact persons in the course of doing business. Such personal information may include: your name, mailing address, billing address, email address, telephone number, tour booking information; information about participation in contests, lotteries or marketing programs (even if you have not used our services); information about purchased products or services; personal data: nationality, income level, passport number, place and date of passport issuance; travel data; payment information, such as your payment card number and other information, as well as authentication information and other account information and account associated with mobile accounts; information about your preferences when choosing a tour; information about the amount of marketing information you want to receive; information about the cars you can come in; review and opinions about our brand (if they are defined or related to you); ordered service packages, which include tour booking; groups you are connected with during the tour; information provided in connection with participation in the loyalty program; other types of information provided by you or received by us about you.

CAUCASIA TRAVEL may request information about tourist groups, including the names and numbers of program participants. We may also collect information related to conversations, including recording or monitoring customer service calls for quality control and training, and other communications, such as in-app messages or text messages.

In addition, the following are cases where CAUCASIA TRAVEL needs additional personal information.

• Survey. Demographic data or other personal information may be required during surveys of CAUCASIA TRAVEL

• Collection of information in the tour. Hotels where accommodation is used for the provision of services may use a video surveillance system and other security features that allow you to capture and store images of guests and visitors in public places, as well as information related to your location in our hotels (using the key -maps and other devices).

• Social networks. If you want to take part in events and promotions held by CAUCASIA TRAVEL on social networks, we may need some information from your account on the social network: location, registration for tours, participation in events, interests, photos, changes in status and friends list. CAUCASIA TRAVEL may also allow you to participate in contests by providing a photo, for example, taken during your stay with us, which you can post on social media for voting, showing or participating in other promotions.In addition to the information that CAUCASIA TRAVEL receives directly from you, we may also create information about you based on the information you provide or other information we collect.

2. Personal information received by CAUCASIA TRAVEL from third-party companies

CAUCASIA TRAVEL may also receive information about you from third parties, including information from tour operators and travel agents, payment card companies and other partners, from social networks in accordance with your settings regarding such services, as well as from other third-party sources who may provide us with information about you in accordance with the law. CAUCASIA TRAVEL may use and provide this information (as well as combine it with other data about us available to you) for the purposes specified in this Regulation.

3. Use of CAUCASIA TRAVEL by the personal information provided by you

CAUCASIA TRAVEL uses your personal data in various ways, including to provide and personalize the services you request and expect from us, to offer you the highest level of service you expect when choosing our tours, direct marketing activities. and marketing in accordance with the following detailed description. Before processing your data, we obtain your consent, if necessary in accordance with applicable law.

CAUCASIA TRAVEL is obliged to collect certain data, including your name, address, payment information, and in some countries - information about travel documents to process your reservation. In case of refusal to provide the necessary information, we will not be able to make your reservation.

• Administrative management of services. CAUCASIA TRAVEL uses your personal information for the administrative management of the programs, including providing you with access to information about your account, such as the bonus balance and offers to which you are entitled; and to simplify the data collection process.

• Marketing and communication. In permitted cases, CAUCASIA TRAVEL may use your personal information to provide or offer you subscriptions to newsletters, promotions and special offers, as well as other marketing messages in accordance with your communication preferences. We use your information to send messages during your stay, to confirm your booking, to send marketing messages, as well as to conduct surveys, lotteries, prize draws and other contests. We can send these messages to e-mail, regular mail, via online advertising, social media, by phone, in the form of text messages (including SMS and MMS), push messages, messages in applications, and others means (including sending messages to the hotel, for example, using the TV system in your room). With your consent, we also use your content (such as photos) from social networks to send display advertising, as well as on our website and in applications. We may also collect information about your payment card, which may be added to personal information and used by us or our business partners to determine the type of your card. We may also work with third-party companies to find out if a visitor to our site has taken advantage of a refund offer related to their payment card, and to provide visitors with promotional information explaining how to take advantage of this offer when choosing a tour.

• Improving the quality of services. CAUCASIA TRAVEL may use your personal information to improve the quality of our services in order to interest you in our site, products and services. We also use your personal information to provide you with the expected level of service when providing tour services.

• Data accuracy, analytics and personalization. CAUCASIA TRAVEL may combine your personal information with data from third-party sources for the purpose of systematization and analysis of data. We also use information from third-party sources in order to provide a higher level of service with an individual approach to each tourist. For example, if you have connected social media services or other accounts to our services, we may use this information to provide you with a warmer reception and personal approach, or provide it to third parties and use it in accordance with any clause of this Regulation. .

4. Personal information provided by CAUCASIA TRAVEL to third parties

In order to offer you the highest level of service in accordance with your expectations, CAUCASIA TRAVEL may provide your personal information to hotels united under the umbrella brand Management Grup Otel, our service providers, third parties and other third parties in accordance with the following explanation:

• Business partners. CAUCASIA TRAVEL can cooperate with other companies in order to provide you with products, services and offers based on your stay in the tour, and we may pass your information to our business partners, respectively. For example, we may agree with partners to provide you with other additional services. In order for these services to be provided, we must provide partners with your personal information. We may also pass on your personal information, such as e-mail addresses, to our travel partners to help them assess compliance with travel rules or the use of special tariff plans, or to provide the opportunity to participate in marketing activities with our travel partners. CAUCASIA TRAVEL can also work with third-party organizations, such as our partners, travel agents and payment card suppliers, to ensure that advertising is delivered to our joint customers. Our partners may be able to provide you with better offers based on information about your stay in our hotels. In addition, we may allow third-party partners to recognize you when visiting a website or used that partner's app, or to recognize you as one of their customers when visiting sites so that they can provide you with more relevant offers. We may use applicable security measures to transfer your hashed email address to third parties so that they can associate it with their hashed email addresses and send you advertisements on our behalf over the Internet and via email.

•Partners-organizers of advertising campaigns. CAUCASIA TRAVEL may, in cooperation with other companies, conduct advertising campaigns, raffles, lotteries, competitions or contests, as well as provide prizes for lotteries and competitions held by other companies. If you participate in one of the raffles or contests, we may provide your information to our event partners or outside sponsors.

• Service providers. CAUCASIA TRAVEL trusts third-party companies to provide services and products on our behalf and may transfer your personal information to them depending on the circumstances. As a general rule, our contractual service providers are required to protect your personal information and may not otherwise use or transmit your personal information unless required to do so by law. However, after fraud is detected, our service providers may use but not provide your personal data for fraud detection. CAUCASIA TRAVEL may also engage service providers to report news and deliver advertising and business materials on our behalf, including personalized advertising on the Internet and mobile applications in accordance with their preferences and applicable law. We work only with companies that provide an opportunity to abandon such advertising. We may also share information with service providers to allow you to design routes by selecting sites, events, and restaurants from lists we have personally prepared for you based on your preferences and third-party data.

• Addition. In addition, CAUCASIA TRAVEL may disclose personal information in the following cases: (I) in accordance with the requirements of applicable law; (II) in response to requests from the government or public authorities; (III) in accordance with the requirements of the trial; (IV) as protection of the rights, confidentiality, security or property of CAUCASIA TRAVEL, site visitors, tourists, workers or the public; (V) in order to protect their rights or reduce possible damages; (VI) in order to comply with the terms and conditions set out on our websites; (VII) in emergencies.

5. General information

КIf you visit and use our websites and applications, CAUCASIA TRAVEL collects other non-personally identifiable information about your use of the site, such as the directory of pages you visit and the number of visits to our sites ( "General information"). CAUCASIA TRAVEL uses General Information, as well as data received from third-party companies to deliver e-mail advertising to you, via the Internet (on our and other sites) and mobile applications.

CAUCASIA TRAVEL uses cookies and other technologies (for example, "dot markers", "web beacons", "transparent GIF files", links in e-mail messages, JavaScript, device identification numbers assigned by Google or Apple , or other similar technologies) to collect such information.

You can also delete cookies from your computer or block them at any time by changing your browser settings (information on how to delete or block cookies can be found in the browser's "Help" menu).

CAUCASIA TRAVEL is not responsible for setting up your browser. You can find simple and clear instructions on how to manage cookies for different types of web browsers at www.allaboutcookies.org.

Note for people living in the European Economic Area and the UK: If you are in Europe, you can also set your cookie preferences in the Cookie Settings section using the Cookie Consent Manager. cookie "), which can be found here: Cookie Preferences (" Cookie Settings ").

CAUCASIA TRAVEL may use the collected and accumulated information or anonymous personal information obtained from third parties to obtain a more accurate picture of our users (for example, we may use aggregate information to calculate the percentage of our users who have a specific phone code cities). This includes demographics, such as date of birth, gender, and marital status, presumed commercial interests, such as favorite products or hobbies, and other information we may receive from you or third parties.

As the General Information does not identify you, CAUCASIA TRAVEL may disclose this information in any cases permitted by law. In some cases, we may combine General Information with personal information. In the case of adding General Information to personal information with the resulting information, we will treat you as personal information in accordance with the rules of this Regulation.

6. Confidential information

The term "confidential information" means information related to your race or nationality, political views, religious or philosophical beliefs, trade union participation, health status, sex life and orientation, genetics, criminal history, and any unique biometric data used for identification purposes. In some jurisdictions, cell phone numbers, location data, and identification information are also confidential.

CAUCASIA TRAVEL does not normally collect confidential information unless it is provided by you voluntarily or unless required to do so by us in accordance with applicable laws or regulations. We may use the health information you provide to provide a higher level of service that best meets your needs (for example, to provide a room for people with disabilities).

7. Personal information received from children

CAUCASIA TRAVEL does not intentionally collect personal information about persons under 18 years of age. If you are a parent or guardian, do not allow your children to provide personal information without your permission.

8. Access to the site from a mobile phone and location-based services.

CAUCASIA TRAVEL offers mobile applications that can be downloaded to a smartphone or mobile device. These applications have different functionality, improve the quality of customer service. In addition to the service provided, our applications may collect personal and general information that will be used in accordance with this Regulation. For example, to make or change a reservation you will need to provide some personal information or other information as needed. Before downloading any of our applications, we provide visitors with a link to this Regulation.

If you allow our mobile applications to access your location information on your device, our mobile applications may use Global Positioning System (GPS) technology and other technologies (such as wireless transmitters known as "beacons") on your mobile device to provide give you information and suggestions according to your location. Lighthouses allow us to collect information about your location on the tour by interacting with mobile devices that are within reach. We may transfer this information to third parties, including business partners and service providers, in order to provide you with information, offers and services that may be of interest to you. You can disable or restrict the collection of location information by changing the settings in the application or changing the settings of your mobile device.

We offer all of these mobile and location-based services only to the extent permitted by local law.

9. Links to third party websites and services

Our website and mobile applications may contain links to third-party websites. Please note that our company is not responsible for the collection, use and management of this data, as well as the provision or disclosure of data and information by these third parties. If you provide information on third-party sites, it is subject to the privacy policies and terms of service on those sites. Before providing personal information to websites, we recommend that you read their privacy policy.

CAUCASIA TRAVEL can also cooperate with a limited number of Internet providers that provide free Internet access to our guests. Your use of the Internet in the hotel is carried out in accordance with the rules of use and privacy policy of a third-party Internet provider. You can read these terms and conditions by following the link on the login page or by visiting the ISP's website.

10. Protection of personal information

CAUCASIA TRAVEL will take reasonable steps to: (I) protect personal information from unauthorized access, disclosure, alteration or destruction; (II) monitor the accuracy and timely updating of information as appropriate. Our company employs a reliable team of information security professionals who are responsible for creating, updating and managing the security program of CAUCASIA TRAVEL.

The team of CAUCASIA TRAVEL Global Information Security LLC is responsible for, among other things, monitoring our systems for potential intrusions, responding to potential incidents, ensuring information security, regular analysis and updating of security controls used by our company to protect data, as well as training in the information security program of CAUCASIA TRAVEL.

In the event of an incident involving a security breach, our company will notify the regulatory authorities and / or customers in accordance with applicable laws or regulations.

CAUCASIA TRAVEL also requires that our partners and service providers do their utmost to maintain the confidentiality of personal information received. When performing transactions on the Internet, we use sufficient means of technical protection of personal information provided by you on our site. Unfortunately, there is no completely reliable security system or data transmission system over the Internet.

In order to protect your confidential data, do not send us payment card numbers or any other confidential personal information by e-mail.

11. Changes and access to personal information

In the cases established by the current legislation, CAUCASIA TRAVEL may provide you with information about the information available about you and even if necessary, you may withdraw your consent to certain types of processing of your data and / or ask to change, correct, delete your personal data and / or suspend its processing. All necessary updates and changes will be made within the period established by applicable law and in accordance with the requirements of the law. In cases where this is permitted by law, a fee may be charged to cover the costs associated with processing your request. Requests can be sent by e-mail to: 1@caucasia.travel or to the employee of CAUCASIA TRAVEL, responsible for data protection by phone Viber / WhatsApp: +998 78 113 66 30. In order to maintain confidentiality, a response to the request will be sent to an e-mail address registered with us or otherwise provided.

In addition, in certain circumstances and in accordance with applicable law, you may require that CAUCASIA TRAVEL not provide personal information about you to our business partners or that we stop using personal information about you by contacting us by e-mail or to the following email address. We satisfy such requests in accordance with applicable law.

12. Storage of personal information

CAUCASIA TRAVEL keeps your personal information for a period specified in the terms of this Regulation, unless it requires a longer period of storage or otherwise provided by applicable law. For three years after the end of your stay, we retain your personal data collected for the purposes set out in this Regulation. Other personal data is stored for a shorter period, if possible and if permitted by law.

We will destroy your personal data as soon as possible without the possibility of their recovery or reproduction. Personal data on paper will be securely destroyed, for example by shredding paper documents, burning or otherwise, and personal data stored electronically will be destroyed using technical means to ensure that this data cannot be further recovered or reproduced. .

13. Choice of marketing communications

If you have provided us with your contact information (postal address, e-mail address or telephone number) in accordance with your wishes and with your consent (in cases where it is required), CAUCASIA TRAVEL may notify you of our products and services or invite you to events by e-mail, via Internet advertising, social networks, WeChat, WhatsApp, Viber, Telegram, by phone, via text messages (including SMS and MMS), push messages, internal messages, mail , through the customer's support service, as well as through other means.

If you prefer not to receive electronic marketing materials from us, you can opt out at any time by using the unsubscribe feature in the email we receive. It may take up to ten business days to process a opt-out request.

14. Changes in the Regulations

This Regulation may be amended from time to time. If you make significant changes to this Regulation on the main page of our site, a link to an updated version of the Regulation will appear, and if you have registered to use any of the products or services, you will receive a message using the selected method of communication. The date of the last update of this Regulation is indicated in this link and at the top of the document.

Any changes to the Regulations shall take effect from the date of publication of its updated version on the website. Use of the Site, any of our products and services, and / or consent to the updated Terms after such changes have been made means that you agree to accept the revised Terms that have entered into force.

15. Contact us

If you have any questions regarding this Regulation or about the options for the use of your personal data by CAUCASIA TRAVEL, as well as if you would like to express your gratitude or send a complaint, send an e-mail to 1@caucasia.travel or call us at +998 78 113 66 30. We will answer you as soon as possible.

16. Changes in the Regulations on the Confidentiality of CAUCASIA TRAVEL

Updated to provide more detailed information on how CAUCASIA TRAVEL collects, uses, distributes and protects the personal data of our tourists.
• Annex 1 is added: "Additional provisions applicable to the processing of personal data of EEA residents". Annex 1 contains detailed information provided in accordance with Regulation (EU) 2016/679 of the European Parliament and of the April Council of 27 April {{2016}} on the protection of individuals with regard to the processing of personal data and on the free movement of such data, commonly referred to as the “Common Regulation”. EU on personal data protection "(GDPR).