We care about the security of your personal data and we strive to ensure a particularly transparent processing of your personal data. We have prepared this privacy policy for you, which sets out what personal data we collect, how we obtain that data, what your rights are and how to exercise your rights.

GENERAL DATA CONTROLLERS

Your personal data is processed by joint controllers:

Blulita UAB

Company ID  302336337

Address: Vilkpėdės g. 24, LT-03151 Vilnius, Lithuania

Phone number +370 52 653 532

E-mail: [email protected]

„Kurpiai Suites & Spa”

Address: Kurpių g. 3, LT-91248, Klaipėda, Lietuva

Phone number: +370 666 94900

E-mail: [email protected]

Hereinafter, all data controllers are referred to as KURPIAI SUITES & SPA or we.

This privacy policy(„Privacy policy“) is addressed to persons who use the accommodation, spa, conference room rental and other services provided by KURPIAI SUITES & SPA, or visit the website https://kurpiaihotel.lt/lt/, to candidates who participate in the recruitment process for jobs advertised by KURPIAI SUITES & SPA.

TERMS USED IN THE PRIVACY POLICY

Personal Data – any information about a natural person whose identity is known or can be determined (data subject); a natural person whose identity can be determined is one whose identity can be directly or indirectly determined, particularly by reference to an identifier such as a name, identification number, location data, or an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.

Data Subject – a person who uses the services of KURPIAI SUITES & SPA, visits the website https://kurpiaihotel.lt/lt/, contacts KURPIAI SUITES & SPA for services or other purposes, as well as a candidate participating in the selection process for job positions announced by KURPIAI SUITES & SPA.

Request – a request from the data subject regarding the exercise of their rights.

Regulation – 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 – the KURPIAI SUITES & SPA website https://kurpiaihotel.lt/lt/,.

Other terms used in this Privacy Policy may have meanings corresponding to the provisions of the Regulation.

GENERAL PROVISIONS

This Privacy Policy does not constitute an agreement between us and you regarding the processing of your data. This Privacy Policy informs you about the basic principles of personal data processing and the exercise of the rights of the data subject. Additional information about the processing of your personal data may be contained in purchase and sale, service and other agreements.

By using the services of KURPIAI SUITES & SPA, purchasing goods, submitting your data, sending a CV, filling in enquiry or reservation forms, continuing to browse the Website, you confirm that you have read this Privacy Policy and understand its provisions.

This Privacy Policy does not apply to the use of other companies' websites or services or other reservation systems, such as www.booking.com. We recommend that you read the privacy notices of other service providers and contact them directly regarding the processing of your personal data.

PRINCIPLES FOR PROCESSING PERSONAL DATA

KURPIAI SUITES & SPA processes personal data in accordance with the legal acts of the European Union and the Republic of Lithuania regulating the processing of personal data.

The scope of personal data processed depends on the services, goods, legal relations of KURPIAI SUITES & SPA with the data subject or other persons and the information provided by the person when ordering and/or using the services, purchasing goods, visiting the Website or contacting KURPIAI SUITES & SPA.

We only process your Personal Data under the criterion of lawful processing - in order to take action at your request prior to entering into a contract or to perform a contract; with your consent; where we are obliged to process Personal Data by the relevant legislation; and where the processing of Personal Data is necessary for the purposes of a legitimate interest of ours or a third party.

We aim to ensure that Personal Data is processed accurately, fairly and lawfully, that it is processed only for the purposes for which it was collected, and that it is processed in accordance with the clear and transparent principles and requirements for the processing of Personal Data as set out in law.

HOW WE OBTAIN PERSONAL DATA

We may receive personal data directly from you, when:

• When you fill in enquiry or booking forms on the Website;
• sending your curriculum vitae (CV), other information related to recruitment;
• you place an order with us to purchase services provided by KURPIAI SUITES & SPA;
• otherwise contact KURPIAI SUITES & SPA;
• interact with KURPIAI SUITES & SPA via social networks or simply follow KURPIAI SUITES & SPA on social networks;
• use KURPIAI SUITES & SPA apartments room lock cards.
• KURPIAI SUITES & SPA provides you with the following services.

We may also receive your personal data indirectly:

• through the online booking channel you use to make your reservation, such as www.booking.com and others; www.booking.com and others;
• from your travel agent or any other person who books the services provided to you by KURPIAI SUITES & SPA;
• from social media platforms or online reviews;
• from KURPIAI SUITES & SPA's data processors or other external sources.

Personal data may be generated when you use or enquire about services, such as when you make a phone call, send a text message, send an email, order services, goods or visit the Website.

You are not obliged to provide us with any Personal Data, but we may not be able to carry out certain activities, such as providing services, selling goods or billing, without your Personal Data.

RECIPIENTS OF PERSONAL DATA

Your privacy is important to us and we will not share your personal data with anyone else without your consent, except for the following:

• in the event of a dispute, persons providing legal services to KURPIAI SUITES & SPA;
• auditors, other consultants;
• data processors, reservation service providers;
• payment service providers (banks, credit institutions, payment initiation service providers, etc.);
• online booking channels used by the data subject to make reservations, such as www.booking.com and others, for the purpose of ordering services from the controllers, for the purpose of providing services to you;
• to your travel agent or any other person who books the services of KURPIAI SUITES & SPA for the purpose of ordering, providing services to you;
• to public authorities, law enforcement agencies and other persons in accordance with the procedure established by the legislation of the Republic of Lithuania.

If we disclose your personal data to other groups of data recipients than those specified in this Privacy Policy, we will inform you of this fact no later than the first disclosure of the data, unless we have already provided you with such information previously in other documents we provide to you or conclude with you.

PURPOSES OF PROCESSING PERSONAL DATA

KURPIAI SUITES & SPA processes your personal data for the following purposes: ordering and providing services, direct marketing, customer service, room reservation, statistics and monitoring of the Website traffic, improvement of the Website, promotion of KURPIAI SUITES & SPA, KURPIAI SUITES & SPA apartments rating and analysis of guests' opinion, complaint handling, improvement of the services (including monitoring of guests' behaviour), for the purpose of protection of property and persons, for the purpose of internal administration, debt collection and administration; legal claims, enforcement and defence, customer and partner relations; accounting; contract administration and enforcement; enquiry management; recruitment purposes.

GROUPS OF DATA SUBJECTS WHOSE PERSONAL DATA ARE PROCESSED BY KURPIAI SUITES & SPA

We process your personal data if you belong to one of the following groups of people:

• persons who use the services of KURPIAI SUITES & SPA or who order the services of KURPIAI SUITES & SPA for other persons or for whom the services of KURPIAI SUITES & SPA are ordered;
• persons who visit the Website https://kurpiaihotel.lt/lt/;
• persons who interact with KURPIAI SUITES & SPA in any way;
• persons who give their opinion about KURPIAI SUITES & SPA;
• persons who have consented to receive direct marketing communications or have not objected to the processing of personal data for direct marketing purposes at the time of collection;
• candidates who take part in job openings;
• KURPIAI SUITES & SPA customers, business partners, employees, suppliers.

CATEGORIES OF PERSONAL DATA PROCESSED BY KURPIAI SUITES & SPA

The following main categories of personal data may be processed by KURPIAI SUITES & SPA for the purposes of the processing of personal data set out above, including but not limited to:

• name of the data subject,
• ID card (passport) number, date and place of issue,
• phone number,
• address, country,
• e-mail,
• the service purchased,
• date of check-in and check-out at KURPIAI SUITES & SPA,
• information on persons living together,
• the data subject's preferences (food, etc.),
• discount code,
• reservation number,
• additional services booked,
• signature,
• IP address,
• Website browsing history and date,
• other information necessary for the provision of services, goods, relationship management, billing and contract administration, legal claims,
• reviews and ratings of KURPIAI SUITES & SPA on social media,
• the habits of the data subject in relation to the services provided by KURPIAI SUITES & SPA,
• the data subject's profile and other information on social media,
• videos,
• other categories of data.

More detailed information on other categories of data is provided in the individual sections of the Privacy Policy.

PROCESSING OF DATA RELATING TO THE COLLECTION OF CONTRIBUTIONS

In order to ensure that you pay for the services we provide, we:

• use the services of providers of collection services. For this purpose, we provide your identification data, order data and email details to the collection service providers, who send the invoice with a link for payment to your email address;
• collect your credit/debit card details.

We only process data relating to the collection of payments for the purpose of guaranteeing payment of services (our legitimate interest).

In the event of cancellation, modification of your order or other refund conditions, we will refund your money directly through your commercial bank.

VIDEO RECORDING FOR THE PROTECTION OF PROPERTY AND PERSONS, THEFT PREVENTION

We carry out video surveillance in our apartment's area in order to protect our property, your property and the property of others, as well as the health and life of individuals, on the basis of the legitimate interests of KURPIAI SUITES & SPA and third parties.

We collect the following information in the course of video surveillance: video recordings, date and time of video recording, location.

We organise the video surveillance in such a way that the surveillance field does not extend beyond the strictly necessary area of our apartments (room, part of a room). The interior of our apartments premises and the entrances to the apartments shall be monitored.

Video surveillance of rooms and/or areas intended for the private use of individuals, i.e. toilets, showers, changing rooms, etc., as well as of our apartments rooms is not carried out.

Video recordings may only be used to disclose suspected criminal offences, administrative offences, or to prove damage to the property of KURPIAI SUITES & SPA employees, service providers, third parties, or to the property of KURPIAI SUITES & SPA, or to the health or life of individuals, and may only be communicated to persons who are entitled to receive such data as provided for by law.

Video recordings may be made available for viewing at your request, provided that the video relates to you and that the retention period for such video recordings has not expired. If necessary, video recordings may be transferred to law enforcement authorities following a written law enforcement request or a data request. If the video recordings are viewed outside the premises of law enforcement authorities or a court, the viewing of the video recordings must take place in an enclosed area of KURPIAI SUITES & SPA. The data subject, a responsible employee of KURPIAI SUITES & SPA, and representatives of law enforcement authorities shall have the right to participate in such review.

At your request, photographs of the video may be provided, as well as the video on your own or on KURPIAI SUITES & SPA's storage media.

DATA PROCESSING FOR DIRECT MARKETING PURPOSES

By providing us with your name, surname, email address or telephone number, you can consent or not to the use of your data for direct marketing purposes.

With your consent, we will send you information about the services offered by KURPIAI SUITES & SPA and other related companies.

If you have already booked/purchased services from us, or if you have entered into a contract with us and you have not objected to the processing of your personal data for the purpose of direct marketing at the time of collection, we will process your data for this purpose on the basis of a legitimate interest when sending you communications about similar goods or services. In this case, you may opt out of receiving direct marketing communications at any time by contacting us at [email protected].

You may withdraw your consent to our use of your data for direct marketing purposes at any time by emailing [email protected]

KURPIAI SUITES & SPA APARTMENTS RATING AND GUEST EVALUATION ANALYSIS AND COMPLAINT HANDLING FOR SERVICE IMPROVEMENT

KURPIAI SUITES & SPA may process your personal data obtained through social media platforms (such as Facebook, Instagram, LinkedIn, etc.) or online reviews (such as TripAdvisor) in order to investigate your complaints or to respond to your positive feedback about us and to monitor our online reputation, in order to enable us to evaluate and improve the quality of our services through these tools. For the purposes set out in this section, we process your personal data on the basis of the legitimate interest of KURPIAI SUITES & SPA.

For the purposes set out in this section, we may process your personal data that you share with us or post on social media or other online reviews about us.

TRACKING AND ANALYSING YOUR BEHAVIOUR TO IMPROVE OUR SERVICES

When you stay at KURPIAI SUITES & SPA, we record your name, how many times you have stayed at KURPIAI SUITES & SPA, when you stayed at KURPIAI SUITES & SPA, the price you paid for the services, what you ordered in your hotel room and what additional services you ordered. We process this data in order to evaluate and improve the quality of our services and to offer you tailored services the next time you stay at KURPIAI SUITES & SPA. For the purposes set out in this section, we process your personal data on the basis of the legitimate interest of KURPIAI SUITES & SPA.

PROCESSING OF PERSONAL DATA FOR THE PURPOSE OF EMPLOYMENT AT KURPIAI SUITES & SPA

Potential employees of KURPIAI SUITES & SPA (candidates, job seekers) provide KURPIAI SUITES & SPA with the following personal data: curriculum vitae, name, surname, telephone number, email address. We will inform you about the processing of your personal data as a potential employee, the data retention periods during the first contact verbally or by e-mail. You can get acquainted with the processing of your personal data as a potential employee in this section of the Privacy Policy.

If you connect with KURPIAI SUITES & SPA via social media, such as LinkedIn, the social network manager may process your interest in positions posted by KURPIAI SUITES & SPA for the purposes set out in the social network manager's policy.

Your personal data provided when applying for a specific position advertised by KURPIAI SUITES & SPA is processed for the purpose of concluding an employment contract with you as a potential employee.

If you apply for a specific position but are not offered a job, your personal data will be deleted after the selection process for the specific position advertised by KURPIAI SUITES & SPA has ended, unless you provide your consent to the storage of your personal data for the purpose of future KURPIAI SUITES & SPA recruitment. You may withdraw your consent to the processing of your personal data for the purposes set out in this section of this Privacy Policy at any time by clearly and unambiguously expressing your will in writing to an employee of KURPIAI SUITES & SPA, by contacting KURPIAI SUITES & SPA by telephone or by e-mail.

PROCESSING OF PERSONAL DATA FOR PURPOSES RELATED TO THE RESTRICTIONS IN FORCE IN COVID-19

If you visit KURPIAI SUITES & SPA we process your personal data, including your name and telephone number. The above data is processed on the instructions of the Ministry of Health of the Republic of Lithuania for the purpose of implementing measures for the prevention and control of COVID-19 disease (coronavirus infection). If you do not consent to the processing of your personal data, you will not be admitted to KURPIAI SUITES & SPA.

PERSONAL DATA PROCESSING PERIOD

Personal data is processed no longer than necessary to achieve the purposes of data processing or as required by the data subjects and/or as stipulated by law.

Typically, we will process data during the contract or service provision and for 10 years after the end of the contract, service provision, or the end of the relationship, to comply with document archiving requirements set by law and to assert, exercise, or defend legal claims of KURPIAI SUITES & SPA.

For direct marketing purposes based on the consent of the data subject, KURPIAI SUITES & SPA processes personal data from the time the consent is received for no longer than 5 years or until the data subject withdraws their consent.

For direct marketing purposes, providing notifications about similar KURPIAI SUITES & SPA products or services based on legitimate interest, KURPIAI SUITES & SPA processes personal data during the validity of the contract with the data subject and for 3 years after the end of the contract or the purchase of the product/service (in the case of a one-time purchase) or until the data subject objects to receiving such notifications from KURPIAI SUITES & SPA.

Data submitted by candidates, after the specific selection process ends and if no employment contract is concluded, or if the candidate submits their data without applying for a specific position at KURPIAI SUITES & SPA, are stored for 1 (one) year upon receiving the data subject's consent or until the data subject withdraws their consent.

Data collected during guest behavior monitoring for service improvement and tailoring purposes is processed by KURPIAI SUITES & SPA for no longer than 3 years from the last contact with the data subject.

Payment card data is stored for 4 days after departure. For reservations made until December 31, 2020, payment card data is stored for up to 1000 days from departure.

Your personal data, obtained through social media platforms or online reviews to address your complaints or respond to positive feedback about us, monitor our online reputation, and to evaluate and improve our service quality, is processed by KURPIAI SUITES & SPA for no longer than 1 year from the date of collection.

Video surveillance material with personal data and personal data obtained through the use of a key card is stored and processed for no longer than 1 month from the date of recording/receipt.

Health-related data is stored for the period specified by law. Data about your sleep, which is not included in the medical record, is deleted immediately after the service is provided.

If the data subject withdraws their consent to data processing or the data processing period ends (when the data is processed based on the data subject's consent), only data confirming the fact of consent will be stored, but no longer than 10 (ten) years from the end of the consent period or the withdrawal of consent, to assert, exercise, or defend legal claims of KURPIAI SUITES & SPA.

Your personal data obtained in compliance with the orders of the Ministry of Health of the Republic of Lithuania for the implementation of COVID-19 disease (coronavirus infection) prevention and control measures is stored and processed for no longer than 21 days from the date of recording/receipt.

DATA PROCESSORS

Your personal data may be processed by data processors providing accounting, legal, website hosting, data center and/or server rental, IT maintenance, external audit, and other services to KURPIAI SUITES & SPA. This also includes managers of hotel management systems and hotel reservation system administrators.

Data processors have the right to process personal data only according to the instructions of KURPIAI SUITES & SPA and only to the extent necessary to properly fulfill the obligations specified in the contract. KURPIAI SUITES & SPA, in engaging data processors, aims to ensure that data processors have implemented appropriate organizational and technical measures to ensure security and maintain the confidentiality of personal data.

COMMON DATA CONTROLLERS

Your personal data may be processed not only by the data controllers specified in this Privacy Policy but also by other data controllers (i.e., common data controllers, as understood in Article 26 of the Regulation), such as other companies within the KURPIAI SUITES & SPA group..

We have agreements with joint data controllers, the essential terms of which you have the right to review by contacting KURPIAI SUITES & SPA. Upon your request, we will provide you with the contact information of the joint data controllers.

When your data is processed jointly with other data controllers, you can exercise your rights under the Regulation with respect to each of the joint data controllers.

YOUR RIGHTS REGARDING PERSONAL DATA

When we obtain information directly from you about the processing of personal data, we will inform you at the time of data collection:

The right to know (to be informed) about the processing of one's personal data

When we receive information directly from you about the processing of personal data, we inform you about the processing of personal data at the time of data collection.

1. Verbally (if we are communicating with you only verbally, e.g., by phone);
2. In writing (information sent to you by email is considered to be provided in writing).

If we receive your data not directly from you, we will inform you about the processing of your personal data verbally or in writing (as indicated above) no later than one month from the receipt of the data. If we use your personal data to maintain contact with you, we will inform you no later than the first time we contact you.

Right to access your processed personal data and how it is processed

You have the right to obtain information about the retention period of your personal data, the sources from which and what personal data has been collected, the purpose for which it is processed, and to whom it is disclosed.

Upon receiving your request, we will promptly, but in any case no later than one month from the receipt of the request, verify whether your personal data is being processed by KURPIAI SUITES & SPA or not. If we determine that your personal data is being processed, we will provide you with information about the processed personal data and a copy of the processed personal data in electronic format or on paper.

The response period may be extended if necessary, considering the complexity and number of your requests. We will inform you separately about this. If we decide to extend the response period, you have the right to contact the State Data Protection Inspectorate regarding such an extension.

We will usually provide information to you free of charge. However, if your requests are clearly unfounded or excessive, particularly due to their repetitive nature, or if you wish to receive a copy of the processed personal data in a form other than the electronic or paper format prepared by KURPIAI SUITES & SPA, KURPIAI SUITES & SPA may charge a fee that will cover the administrative costs of providing the information or the communications or actions requested.

Additionally, if your requests are clearly unfounded or excessive, we have the right to refuse to fulfill your request.

At your request, information may be provided verbally, by allowing you to review the document, by issuing a certificate, an extract of the document, or a paper copy of the document, an electronic medium, or access to an information file. If you do not specify the form of information provision in your request, we will provide the information to you in the same form in which the request was received.

Request to Rectify Personal Data and Suspend Processing Activities If, upon reviewing your personal data, you find that the data is incorrect, incomplete, or inaccurate, you have the right to request that KURPIAI SUITES & SPA rectify such data and suspend processing activities.

KURPIAI SUITES & SPA will promptly notify you of any rectification, deletion, or suspension of processing of your personal data performed upon your request. We will also inform data recipients of the rectification, deletion, or suspension, except in cases where it is impossible or would require disproportionate effort. Upon your request, we will provide you with information about these data recipients.

Right to Request Deletion or Restriction of Personal Data Processing, If you determine that your personal data is being processed unlawfully or unfairly, you have the right to request the deletion or restriction of processing of such data.

KURPIAI SUITES & SPA will promptly notify you of any restriction or non-restriction of processing performed upon your request.

Personal data for which processing is restricted will be stored. Before lifting the restriction, we will inform you via electronic means. We will also inform data recipients of the restriction, unless it is impossible or requires disproportionate effort. Upon your request, we will provide you with information about these data recipients.

Right to Object to Personal Data Processing, You have the right to object to the processing of your personal data, except when such data is processed for the legitimate interests pursued by the data controller or a third party, and these interests do not override your interests.

If you express your objection to the processing of personal data, further processing will only be carried out if it is determined, with justification, that the reasons for processing the personal data outweigh your interests, rights, and freedoms, or if your personal data is necessary to assert, exercise, or defend legal claims.

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

You have the right to opt out of receiving direct marketing communications at any time by notifying us via email. [email protected]

The right to withdraw consent for data processing

You have the right to withdraw all your consents for the processing of personal data at any time, where the legal basis for processing your personal data is the consent you provided to KURPIAI SUITES & SPA

The right to request data erasure (the right„to be forgotten“)

You have the right to request that KURPIAI SUITES & SPA delete personal data relating to you for reasons provided in Part 1 of the Regulation.

We have the right to refuse to fulfill your request in cases established by law, including, but not limited to, those cases discussed in Article 17(3) of the Regulation.

If we fulfill your request and your personal data (deleted upon your request) has been disclosed to recipients, we will inform those recipients about the erasure, unless it is impossible or requires disproportionate effort. Upon your request, we will provide information about such recipients.

This right cannot be enforced if we are required by law to retain the personal data.

The right to data portability

You have the right to request that your personal data, which you have provided based on consent or contract and which is processed by automated means, be transmitted to another data controller or provided to you in a structured, commonly used, and machine-readable format, where technically feasible. When exercising your right to data portability with us, you must specify whether you prefer your personal data to be transferred to you or to another data controller.

If we fulfill your request and you request that the data be transferred in digital form, we will provide you with your personal data processed by KURPIAI SUITES & SPA on a one-time recordable compact disc. You may choose to either provide us with the disc or have us provide it, with you compensating the cost of acquiring this storage medium.

You do not have the right to data portability for personal data that is processed non-automatically in structured files, such as paper files.

Your request to transfer personal data is not automatically deleted. If you wish to do so, you must contact KURPIAI SUITES & SPA to exercise your right to request data deletion ("right to be forgotten").

The right to not be subject to a decision based solely on automated processing, including profiling

You have the right to know and be informed about the logic involved in automated processing of personal data, as well as the potential consequences of such automated data processing for you as a data subject.

If you request a review of a decision based on automated processing (if KURPIAI SUITES & SPA makes such decisions about you), we will conduct a thorough assessment of all relevant data, including the information you provide.

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

You can lodge a complaint with the State Data Protection Inspectorate regarding our actions or inaction related to the implementation of data subject rights at A. Juozapavičius Street 6, Vilnius, email address [...]. [email protected], web page www.ada.lt, You also have the right to lodge a complaint with the competent courts of the Republic of Lithuania regarding the actions or inaction of KURPIAI SUITES & SPA. You may do so yourself or through a duly authorized representative, nonprofit organization, institution, or association that meets the requirements of Article 80 of the Regulation.

The right to compensation for damages suffered due to a violation of data subject rights.

If you have suffered material or non-material damage due to a violation of data subject rights, you have the right to compensation. You may seek compensation through a competent court of the Republic of Lithuania.

REQUEST TO KURPIAI SUITES & SPA PROCEDURE, IMPLEMENTING DATA SUBJECT RIGHTS FOR YOU

To exercise data subject rights, you have the right to do so verbally or in writing by submitting a request in person, by mail, or electronically using the contact details specified in this Privacy Policy.

If you request the exercise of data subject rights verbally or submit a written request in person, you must verify your identity by providing a document confirming your identity. Failure to do so will result in us being unable to accept your requests, and your data subject rights will not be fulfilled. This provision does not apply if you are requesting information regarding the processing of personal data under Articles 13 and 14 of the Regulation.

If you decide to exercise data subject rights by submitting a written request by mail, you must also include a copy of a document confirming your identity, certified by a notary or according to other legal procedures.

If your personal data, such as name, surname, has changed, you must also provide copies of documents confirming these changes; if they are sent by mail, the copies must be certified by a notary or according to other legal procedures.

If you decide to submit a request electronically, the request must be signed with a qualified electronic signature or formed using electronic means that ensure the integrity and non-repudiation of the text. This provision does not apply if you are requesting information regarding the processing of personal data under Articles 13 and 14 of the Regulation..

The request to exercise data subject rights must be considered valid if signed and include your name, surname, address, and (or) other contact details for communication purposes, or where you wish to receive a response regarding the implementation of data subject rights.

You can exercise your rights yourself or through a representative. If you choose to exercise your rights through a representative, your representative must specify their name, surname, address, and (or) other contact details for communication purposes, where they wish to receive a response. Additionally, your representative must provide your name, surname, and any other details necessary for the proper identification of the data subject, and submit a document or a copy thereof confirming the representation

If we have doubts about your identity or the data, we have the right to request additional information necessary to verify it.

In all matters related to the processing of personal data of the data subject and exercising your rights, you have the right to contact the data protection officer of KURPIAI SUITES & SPA. When contacting the data protection officer of KURPIAI SUITES & SPA by mail, we recommend indicating on the envelope that the correspondence is intended for the data protection officer of KURPIAI SUITES & SPA.

If you fail to adhere to the procedures outlined in this section when contacting us, we will inform you of the deficiencies within 7 calendar days of receiving your inquiry and specify the issues. If you do not rectify the identified deficiencies or fail to inform KURPIAI SUITES & SPA about the reasons why these deficiencies cannot be corrected, we will not process your request.

In the presence of objective circumstances that prevent the identified deficiencies from being corrected, after evaluating such circumstances, we may decide to accept and process your request.

We will not consider your request as deficient if, when submitting it in writing, you did not adhere to the request format specified in this section of the Privacy Policy.

DATA SECURITY ENSURANCE

KURPIAI SUITES & SPA implements appropriate organizational and technical data security measures, including protection against unauthorized or unlawful processing of data and accidental loss, destruction, or damage (integrity and confidentiality principles). Access to personal data is restricted to employees, service providers, and authorized data processors who require it to perform their job functions or provide services.

KURPIAI SUITES & SPA SOCIAL MEDIA ACCOUNTS

KURPIAI SUITES & SPA has created and manages accounts on social media platforms. All information that you   provided on social media platforms such Facebook (including messages, use of 'Like' and 'Follow' buttons, and other communications) obtained when you visit KURPIAI SUITES & SPA profiles on social media is controlled by the social network manager. This includes information gathered through cookies used by the social network managers. Therefore, we recommend reading the privacy notices of the social network managers and contacting them directly regarding the use of your personal data.

As Facebook account administrators, KURPIAI SUITES & SPA selects appropriate settings considering its target audience and management and promotional objectives. The social network manager, when providing the ability to create and administer a KURPIAI SUITES & SPA account on the social network, may restrict the ability to change certain essential settings. Therefore, KURPIAI SUITES & SPA cannot influence what information the social network manager collects about you after creating the account on the social network.

All such settings, whether chosen by KURPIAI SUITES & SPA or set by the social network manager, can impact the processing of your personal data when using social media platforms, visiting KURPIAI SUITES & SPA profiles, or reading KURPIAI SUITES & SPA posts on social media. Even if you are merely viewing KURPIAI SUITES & SPA posts on social media, the social network manager may obtain certain personal information, such as the device you are using and your IP address.

Typically, the social network manager processes your personal data (including those collected by KURPIAI SUITES & SPA through additional account settings) for purposes set by the social network manager, based on their privacy policy. However, when you use the social network, interact with KURPIAI SUITES & SPA through it, visit KURPIAI SUITES & SPA profiles, or view KURPIAI SUITES & SPA posts, KURPIAI SUITES & SPA receives information about you. The extent of data received by KURPIAI SUITES & SPA depends on the account settings chosen by KURPIAI SUITES & SPA, agreements with the social network manager regarding additional service orders, and cookies set by the social network manager.

Facebook social network manager collects information about the type of content you view, your activities on Facebook, interactions with other individuals, the frequency and duration of your interactions, your level of activity on the platform, and other information including details about the device you use. To learn more about Facebook's privacy policy, you can click here. https://www.facebook.com/policy.php.

RESERVATION SYSTEMS

Accommodation and related services at KURPIAI SUITES & SPA can be booked not only through our reservation system but also using external reservation systems such aswww.booking.com ir pan.

KURPIAI SUITES & SPA may receive your bookings made through such external reservation systems; however, your personal data provided in these external reservation systems is primarily processed by the operators of these external reservation systems. We are not responsible for how your personal data is handled by the operators of external reservation systems. Therefore, before providing any data through external reservation systems, we recommend thoroughly reviewing the privacy policy regarding personal data of the operators of these external reservation systems.

ONLINE REVIEWS

We appreciate your feedback on online review platforms (e.g., TripAdvisor), but please note that your personal data provided in these online reviews is processed by the operators of these review platforms. We are not responsible for how your personal data is handled by the operators of online review platforms. Therefore, before providing any data or writing reviews on online platforms, we recommend thoroughly reviewing the privacy policy regarding personal data of the operators of these online review platforms.

COOKIES

o enhance your browsing experience, we use cookies – which are small text files automatically created when browsing the Website and stored on your computer or other end device.

The information collected through cookies allows us to enhance your browsing experience on the Website, provide suggestions, gain insights into the behavior of our Website users, analyze trends, and improve both the Website and the services offered. Cookies also help KURPIAI SUITES & SPA to save your completed or incomplete reservations so you can return to them later. Cookies enable KURPIAI SUITES & SPA to provide services tailored to user needs (for example, by displaying content relevant to specific user interests). If there are links on the KURPIAI SUITES & SPA Website to other websites (including external reservation systems or online reviews) that also use cookies, they are not described here.

When functional, tracking, advertising cookies, and/or third-party cookies are being set, we request your consent. For essential cookies, we use them based on legitimate interest and do not require your consent for the placement of such cookies.

If we have obtained your consent, we will not ask for consent again in the future when using the same cookie for the same purpose. This applies to cookies used by third parties as well.

Detailed information about social networks Facecbook used cookies You can find here https://www.facebook.com/policies/cookies/

If you do not agree to the placement of cookies on your computer or other device when we request your consent for placing cookies, you can change your internet browser settings and disable all cookies or enable/disable them one by one. However, please note that in some cases this may slow down your internet browsing speed, limit the functioning of certain website features, or block access to the website. For more detailed information, please visit the address AllAboutCookies.org arba www.google.com/privacy_ads.html.

STATISTICS

Website visitor statistics are analyzed using Google Analytics. Information collected by Google Analytics cookies about your website browsing history may be transferred to and stored on servers located outside the European Union.

OTHER PROVISIONS

When contacting us, you express your consent for KURPIAI SUITES & SPA to contact you regarding your inquiry.

The implementation and interpretation of the Privacy Policy provisions are governed by the laws of the Republic of Lithuania. KURPIAI SUITES & SPA may change this Privacy Policy at its discretion, which takes effect upon publication on the Website. https://kurpiaihotel.lt/lt/.

This Privacy Policy was updated on 2023-09-25.