1 PURPOSE

At Adams Beach Hotel we value our customers and take pride in providing you the best hospitality services available in the hotel industry today.

Adams Beach Hotel we strive to deliver outstanding products, services, and experiences around the world. We value your business and, more importantly, your loyalty. We recognize that privacy is an important issue. We have developed this Statement to explain our practices regarding the personal information we collect from you or about you via our applications, through written or verbal communications with us, when you visit our premises, or from other sources. While this Statement broadly describes the practices we have adopted, local laws vary and some jurisdictions may place restrictions on our processing activities (e.g., certain jurisdictions may require affirmative consent to send marketing messages). Therefore, our actual practices in such jurisdictions may be more limited than those described herein in order to enable us to comply with local requirements

By using any of our products or services and/or by agreeing to this Statement, e.g. in the context of registering for any of our products or services, you understand and acknowledge that we will collect and use personal information as described in this Statement.

Please note that this Statement does not apply to our processing of personal information on behalf of and subject to the instructions of third parties such as airlines, car rental companies and other service providers, companies that organize or offer packaged travel arrangements, marketing partners, or corporate customers.

The purpose of this Privacy Policy is to explain our practices and policies for collecting, using and sharing information and possibly Cookies collected from or about you. We have adopted additional policies and procedures described below but also more detail policy practices can be obtained by accessing the following links:

• Personal Information We Collect
• Personal Information We Collect from Third Parties
• Use of Personal Information Collected About You
• Personal Information We Share
•  Protecting Personal Information
• Sensitive Information
• Children Personal Information
• Other Information
• Transfer of Personal Information
• Changing and Accessing Your Personal Information
• Retaining Personal Information
• Links to Third-Party Websites and Services
• Choices – Marketing Communications
• Your rights (Regulation (EU) 2016/679)
• Statement Modifications
• Contact Us
• Mobile and Location-Based Services
• Privacy Statement Revisions
• Provisions Applicable to Processing of Personal Information of EEA Residents

“Additional Provisions Applicable to Processing of Personal Information of EEA Residents.” This includes detailed information provided pursuant to Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016, on the protection of natural persons with regard to the processing of Personal Information and on the free movement of such data, commonly referred to as the “General Data Protection Regulation” (GDPR).

This Privacy Policy applies regardless of whether you are accessing the website via a personal computer, a mobile device or any other technology or devices or been register as a quest in our hotel. If you have any questions, you can contact Adams Beach Hotel at DPO@adams.com.cy

2 TYPES AND USAGE OF INFORMATION WE COLLECT

3 DISCLOSURE OF PERSONAL INFORMATION

We will not sell, disclose, or rent your personal information to any third party/entities in ways different from what is disclosed in this privacy notice. However, we may disclose your personal information to third parties:

3.1 In the event that we sell or buy any business, assets or shares, we may disclose your personal data to the prospective seller or buyer of such business, assets or shares.

3.2 If we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation, in order to enforce or apply our terms and conditions, or to protect our rights, property, or safety, or those of our customers or others.

3.3 In order to cooperate with law enforcement agencies to enforce laws, as well as investigate and prosecute unlawful activities such as frauds and scams. We maintain the right to disclose any information about you to law enforcement and other government officials as we, in our sole discretion, believe necessary or appropriate, in connection with any investigation of fraud, scam or other activity that is illegal. In particular, these authorities are:

• Law enforcement Authorities and Law enforcement bodies at the countries we operate
• Governing bodies
• Anti-Money Laundering / Counter Terrorism Financing (AML/CTF) agencies

This includes exchanging information with other companies and organisations (e.g. banks, credit institutions) within or outside EU for the purposes of fraud protection and credit risk reduction. These entities may then use your personal information to investigate and act on any such breaches in accordance with their procedures.

3.4 Finally, we may disclose certain personal information to unaffiliated third-party service providers, agents or independent contractors who help us maintain our website and provide other administrative services to us (including, but not limited to, order processing and fulfilment, providing customer service, maintaining and analysing data, sending customer communications on our behalf, and entry collection, winner selection and prize fulfilment for contests, and other promotions). We seek to ensure that these unaffiliated third parties will not use the personal information for any other purpose than to provide the administrative services for which they are responsible. We also enter into contracts with these third parties that compel them to meet the privacy standards required by law in handling your personal information, and use the information only for the purposes for which it was conveyed to them.

Aiming to achieve the purposes described under section 2 of the current policy, the following third parties, located in the European Union, may receive your data:

• Payment providers
• AML/CTF and anti-fraud services
• Platform providers
• Services providers

3.5 We will not disclose your personal information with any third parties outside of the European Union in countries where there is no adequate data protection regime. However, in the event that such a data transfer occurs, we will take all reasonable steps possible to ensure that your data is treated as securely as it is within the EU/EEA and in accordance with this Privacy Policy and the applicable legislation. Additionally, we will update the current Privacy Policy in order to reflect the cross-border data transfer and the relevant safeguards for your privacy.

4 HOW LONG WE KEEP YOUR DATA

4.1 It is our policy to only retain client information for as long as is necessary for the purpose for which it was originally obtained, in alignment with the Data Minimisation and Storage Limitation principles. For all purposes below, your data will be retained for a seven years period, after the termination of the customer relationship. Additionally, we align the retention of your information with potential differentiations arising from the exercising of your data privacy rights (please refer to section 6). However, in some cases some personal information may be retained beyond that time period due to potential legal obligations, legitimate interest purposes, etc. Such reasons would be issues related to:

• Money laundering
• Taxation
• Credit Protection
• Civil Law
• Penal Law
• Any other legal issues

5 YOUR DATA PRIVACY RIGHTS

5.1 At any point while we are maintaining or processing your data, you have the following rights and can submit a relevant request via your personal account:

• Right of access – you have the right to access the personal data that we hold about you;
• Right of rectification – you have the right to correct data that we hold about you that is inaccurate or incomplete. Further analysed in section 7 of the current policy;
• Right to erasure – you can ask for the data we hold about you to be erased from our records and we are obliged to satisfy such request in certain circumstances;
• Right to restriction on processing – you have the right to request to restrict the processing of your personal information and we are obliged to satisfy such request when certain conditions apply;
• Right to data portability – you have the right to have the data we hold about you transferred to another organisation;
• Right to object – you have the right to object to particular processing activities, under certain conditions;

5.2 We will assess your request and reply to you regarding the progress and outcome of the request (granting of request, partial granting of request, rejection of request), as soon as possible and in any case in no longer than one month of the request’s submission.

In the event that Adams Beach Hotel refuses your request regarding the aforementioned Data Privacy Rights, we will provide you with a reason as to why. You have the right to lodge a complaint directly with the Regulatory authority and the DPO (via the means described in paragraph 13 of the current policy).

5.3 We reserve the right to reject requests that are unreasonably repetitive, require disproportionate technical efforts or have disproportionate technical consequences, risk the privacy of others, or would be extremely impractical.

6 UPDATING YOUR PERSONAL INFORMATION

6.1 Except for exceptional circumstances, you may review, update or delete certain personal information by, if you are a registered user of the website, logging on and using the tools provided to edit such information. However, certain data that are necessary to check eligibility, such as date of birth or age, cannot be deleted.

6.2 You can obtain a copy of your personal information through your personal account. For your protection, you will be required to provide proof of your identity to obtain such copies. You should include adequate information to identify yourself and such other relevant information that will reasonably assist us in fulfilling your request. If you would like to close your account, you can also contact customer services. If you would like to close your account, this could be done through your personal account. We will comply with such requests unless we have a legitimate ground to not delete the data.

7 SECURITY

7.1 Protecting your data is of utmost importance for Adams Beach Hotel and in this regard, we constantly strive to provide all possible means of assuring your personal data’s safekeeping, the restriction of unauthorised access and / or potential alterations. Such means include information security measures consistent with current best practices to protect our customers’ privacy. These measures include technical, procedural, monitoring and tracking steps intended to safeguard data from misuse, unauthorized access or disclosure, loss, alteration or destruction

8 PROFILING

8.1 We collect your personal data including transactional behaviour, spending activity and practices, possible cookies and geolocation information, amongst others, in order to provide you with customised and tailored to your preferences views and services. The profiling activity allows us to present you with a personalised view and experience on our website.

8.2 The profiling activity also allows us to detect and report potential fraudulent behaviour and violation of our Terms and Conditions potential money laundering practices and responsible spending behaviour, in line with our regulatory/ legal obligations of reporting such incidents to the relevant authorities.

To summarize the aforementioned, the profiling activity is deemed necessary for the following purposes:

•  Marketing reasons: You can receive customized offers, newsletters and general marketing campaigns, as well as customized hospitality experience.
• Responsible vocational reasons:  If your spending behaviour is deemed as “at risk” and you are considered to be addicted or you state that you are, your account will be closed for your own protection, according to our Terms and Conditions.
• Anti-Fraud reasons:  If you are found to violate our Terms and Conditions (e.g. by having two (or more) active accounts at our website) your account(s) will be closed and your betting activity will be cancelled, according to our Terms and Conditions.
• AML/CTF reasons: If, according to your profiling, your activity is deemed suspicious in terms of Money Laundering then, your activity will be reported at the relevant Law enforcement bodies at the countries we operate, according to our Terms and Conditions.

9 DIGITAL MARKETING

9.1 Additionally, and in order to provide to you personalised offers, promotions and marketing material, we collect your personal data, including transactional behaviour, spending & vocational activity and practices, possible cookies and geolocation information, amongst others. Usage of such services is on the sole discretion of you and the consent provided upon your registration. You can provide your consent at a later time or revoke an existing consisting consent for such services, through our dedicated consent management portal integrated in your personal account.

10 INTERNET PROTOCOL (IP) ADDRESS

When you visit the Website, we register your device`s IP address and browser settings. Your IP address is a unique address that devices use in order to identify and communicate with each other on a computer network. Browser settings can include the type of browser you use, browser language, and time zone. We collect this information so that we can personalize your experience and trace your device in cases of misuse or unlawful actions in connection with visits to or use of the service. Furthermore, we may use the IP address to approximate your location (at city level).

11 COOKIES

11.1 A ‘cookie’ is a small text file that is downloaded onto your access device when you visit a website and that enables the website to obtain certain information from your browser, such as your preferences. This website use cookies and similar technologies to manage login sessions, provide personalised web pages and to tailor advertising and other content to reflect your specific needs and interests.

11.2 You may configure your browser to block all cookies, including cookies associated with our services, or to indicate when a cookie is being set by us. However, it is important to remember that many of our services may not function properly if cookies are disabled. For example, we may not remember your language preferences. Please refer to your browser’s or mobile device’s technical documentation for instructions on how to delete and/or disable cookies.

11.3 For further information on cookies, how they are used and how they apply to the use of your personal data, please visit www.aboutcookies.org or www.allaboutcookies.org.

12 CHANGES TO OUR PRIVACY POLICY

12.1 We strive to constantly review and update our privacy policy in order to address potential legislative and regulatory requirements, while providing optimal protection of your privacy. Any update will be communicated to you via the current web page.

13 CONTACT US

13.1 If at any time you believe that we have not adhered to the provisions set out within this Privacy Policy or for any other Data Privacy related matter, please contact us through email. Kindly be informed that our Data Protection Officer is Eur Ing Dr Chrysanthos Mardapittas at DPO@adams.com.cy.

PERSONAL INFORMATION WE COLLECT

At Adams Beach Hotel are committed to safeguarding the privacy of our customers and website visitors. This policy explains how we handle your personal data.

1.   How we use your personal data

1.1 This section provides you with details about:

1. what personal data we may process;
2. in the case of personal data that we did not obtain directly from you, where we obtained that data from, and what types of data we have collected;
3. the purposes for which we may process your personal data; and
4. the legal grounds on which we process your data.

1.2 Account data. We may process the personal data that you have provided to us when you register so that we can set up your account with us (“account data”). The account data may include your name and email address. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you.

1.3 Usage data. We may process data about your use of our website and services (“usage data”). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of our website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.

1.4 Enquiry data. We may process information contained in any enquiry you submit to us regarding our services (“enquiry data”).

The enquiry data may be processed for the purposes of offering, marketing and selling relevant products and/or services to you.

The legal basis for this processing is consent.

1.5 Transaction data. We may process information relating to any transactions made to/by you through our website (“transaction data”). The transaction data may include your contact details, your bank account details, and the transaction details. The transaction data may be processed for the purposes of processing these payments and keeping proper records of those transactions.

The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely our interest in the proper administration of our website and business.

1.6 Correspondence data. We may process information contained in or relating to any communication that you send to us (“correspondence data”). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.

1.7 Other processing activities. In addition to the specific purposes for which we may process your personal data set out above, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. Please do not supply any other person’s personal data to us, unless we prompt you to do so.

At Adams Beach Hotel we collect personal information at every touch point or guest interaction, and in conducting every aspect of our business, we may collect personal information. This personal information may include: your name, mailing address, billing address, email address, phone number, information related to your reservation, stay or visit to our property; participation in a membership or loyalty program; participation in a contest, or marketing program (even if you do not stay at our hotel); information related to the purchase and receipt of products or services; personal characteristics, nationality, income (employees), passport number and date and place of issue; travel history; payment information, such as your payment card number and other card information, as well as authentication information and other billing and account details associated with mobile billing; guest preferences; marketing and communication preferences; information about vehicles you may bring onto our properties; reviews and opinions, frequent flyer or travel partner program affiliation and member number; hotel, airline and rental car packages booked; groups with which you are associated for stays at hotels; information provided on membership and account applications; and other types of information that you choose to provide to us or that we may obtain about you. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.

We may ask for details on joint travelers, including their names and frequent flyer numbers, and the age of the driver of the rental car. We may also collect information related to conversations, including recording or monitoring customer service calls for quality assurance and training purposes, and other communications such as in-app messages and SMS.

In addition, we collect other personal information in certain cases, such as:

• Participation: When you enrol in our membership facilities and we will ask you to create a user ID and password. We also collect information to administer our program and profiles, including transaction and correspondence details. The web base registry allows you to do such things as use your mobile device to check-in, select your room, receive a room key, and check out. When you manage your profile online, you have the opportunity to provide additional information, such as your preferred airlines and your loyalty program account numbers with them, your room type preferences, your language preferences, your payment card account(s), and your email subscription preferences for receiving news, offers and information from us and our partners. Also, when you book a reservation, including a Rewards Reservation, or, we may ask for additional specific account information such as account number, group or convention code, travel agent number. If you apply for a payment card or other account with one of our partners via one of our advertisements or on our properties, you may have the option to automatically add this information as part of your profile.
• Surveys: We may request demographic data or other personal information in customer surveys.
• On-property Collection: We collect additional personal information during registration/check-in at our properties, including such information as may be required by local laws. We may also use closed circuit television and other security measures at our properties that may capture or record images of guests and visitors in public areas, as well as information related to your location while on our properties (via key cards and other technologies). We may also use closed-circuit television and other technologies that record sound or video for the protection of our staff, guests and visitors to our properties where permitted by law. In addition, we may collect personal information in connection with on-property services, such as concierge services, health clubs, spas, activities, child care services, equipment rental, and our Digital Key functionality where available.
• Event Profiles: If you plan an event with us, we collect meeting and event specifications, the date of the event, number of guests, details of the guest rooms, and, for corporate events, information on your organization (name, annual budget, and number of sponsored events per year). We also collect information about the guests that are a part of your group or event. If you visit us as part of a group, we may have personal information about you provided to us by the group and may market to you as a result of your stay with a group or attendance at an event in accordance with your preferences as permitted by law. If you visit us as part of an event, we may share personal information about you with the event planners, as permitted by law. If you are an event planner we may also share information about your event with third-party service providers who may market event services to you as permitted by law.
• Social Media: If you choose to participate in social media activities or offerings, we may collect certain information from your social media account consistent with your settings within the social media service, such as location, check-ins, activities, interests, photos, status updates and friend list. We may also allow you to enter into contests to provide photos, such as of your stay with us, which you may share with your connections on social media for votes, shared offers or other promotions.
• Forward-to-a-Friend:  From time to time, we may offer a feature that allows you to send an electronic postcard or otherwise share a message with a friend, whether via the Internet, a stand-alone kiosk or mobile device. If you choose to use this feature, we will ask you for the recipient’s name and email address, along with the text of any message you choose to include. By using this feature, you represent that you are entitled to use and provide us with the recipient’s name and email address for this purpose.
• Employment Applications: If you choose to apply online for employment, please see our Applicant Privacy Notice.

In addition to the information we collect from you directly, we may also infer information about you based on the information you provide to us or from other Information we collect.

PERSONAL INFORMATION WE COLLECT FROM THIRD PARTIES

We may also collect information about you from third parties, including information from our airline, payment card, and other partners, including; from your social media services consistent with your settings on such services; and from other third-party sources that are lawfully entitled to share your data with us. We use and share this information (and may append this information to the other information we have on file for you) for the purposes described in this Policy Statement.

USE OF PERSONAL INFORMATION COLLECTED ABOUT YOU

We use your personal information in a number of ways, including to provide and personalize the services you request and expect from us, to offer you the expected level of hospitality in-room and throughout our properties, administer by us, conduct direct marketing and sales promotions and as set forth below in more detail. We will collect your consent prior to processing your data where required by applicable law.

We are obligated to collect certain data, including your name, address, payment information, and, in certain countries, travel document information, in order to process your reservation. Failure to provide this information will result in our inability to process your reservation.

• If you are a holder of Adams Beach Hotel membership, we use your information to administer our loyalty program, to personalize your experience across our services and applications, and in connection we, also use your information to communicate news, promotional, and transactional materials across different services and to personalize advertising and content delivered to you through online, email, mobile, and display advertising, as well as on our website and applications and through our customer service call centre in accordance with any communications preferences you have expressed.
• We use your personal information to administer programs in which you participate, including providing you with access to your account information, such as rewards status and offers for which you are eligible; to fulfil services that are part of such program; to enable direct communication between operations within the various functions; and to facilitate your hospitality.
• We may use your personal information to provide you with information about meeting and event planning.
• Where permitted we may use your personal information to provide or offer you newsletters, promotions and featured specials, as well as other marketing messages in accordance with any communications preferences you have expressed. We use your information to provide in-stay messaging, account alerts, and reservation confirmations; to send you marketing messages; and to conduct surveys, sweepstakes, prize draws, and other contests. We may provide these communications via email, postal mail, online advertising, social media, telephone, text message (including SMS and MMS), push notifications, in-app messaging, and other means (including on-property messaging, such as your in-room television). With your consent, we also use user-generated content (such as photos) from social media services to deliver display advertising or on our website and apps. We may also collect information from your payment card, which can be appended to personal information and used by us to recognize what type of card you have, such as the bank or network of the card, and present and/or send you targeted marketing messages based on your payment method and in accordance with your communication preferences. We may also partner with third parties to learn whether a visitor to our site has a cash-back offer associated with their payment card and to deliver the visitor advertising and information that explains how to take advantage of that offer through a stay at a hotel.
• We may use your personal information to improve our services and to ensure that our site, products, and services are of interest to you. We also use your personal information to provide you with the expected level of hospitality in-room and throughout our properties. This may include providing you with the ability to control your in-room technology through our website or apps on your personal devices.
• We may enrol you in our registration program and use your email address to send you your hotel bill via email. It is your responsibility to ensure that we have the correct (and preferred) email address for you. If you make a reservation for another person using your email address, that person’s registration will be sent to your email address.
• We may aggregate your personal information with data from third-party sources for purposes of keeping information up to date and analytics. We also rely on information from third parties in order to provide better, more personalized service. For example, if you connect your social media services or other accounts to our services, we may use this information to make your experiences with us more personal and social, or share and use it as described elsewhere in this Statement.

PERSONAL INFORMATION WE SHARE

In order to offer you the expected level of hospitality and to provide you with the best level of service, we may share your personal information among our departments, our service providers, and other third parties as set forth in detail below:

• We may share personal information within our hospitality operations, as well as with owners to provide you with services, personalization, and for the purposes described above. In addition, we may provide the owners with certain information about past or future guests of that hotel.
• If you receive an email (as discussed above), a summary detailing the goods and services provided to you during your stay will be shared with the payment card provider and, if you participate in a corporate billing program and use a corporate payment card, the payment card provider may share that summary with your employer. Additionally, if you participate in a special rate plan, we may share lists of honoured numbers that used the plan with the entity that provided the special rate plan to you. The privacy policies of your employer, the relevant payment card provider and card issuer apply once we have transferred your information.
• If you visit Adams Beach Hotel as part of a group event or meeting, information collected for meeting and event planning may be shared with the organizers of those meetings and events, and, where appropriate, guests who organize or participate in the meeting or event.
• We may partner with other companies to provide you with products, services, or offers based upon your experiences at our properties and may share your information with our business partners accordingly. For example, we may help to arrange rental cars or other services from our business partners, and share personal information with our business partners in order to provide those services. We may share your personal information with our business partners in order to credit you with mileage or other benefits earned through your participation in a bonus scheme program. We may also share your personal information, such as your email address, with our corporate travel partners to help them assess compliance with travel policies or participation in special rate plans or to engage in co-branded marketing with our corporate travel partners. We may also work with third parties, such as airlines and payment card partners, to allow us and our partners to deliver advertisements to our shared customers. Our partners may be able to provide more relevant offers to you based upon information that we share about your experiences at our hotel and facilities. Additionally, we may allow third-party partners to recognize you when you visit that partner’s website or app, or to recognize you as one of their customers when you our website or apps so that they may provide more relevant offers to you. We may share a hashed version of your email address with third parties using available security measures that may match it with their own hashed versions of email addresses so that they can send online and email advertisements to you on our behalf.
• We co-sponsor promotions, prize draws, competitions or contests with other companies, and we provide prizes and contests sponsored by other companies. If you enter one of these contests, we may share your information with the co-sponsor or third-party sponsor.
• We may share personal information with third-party providers of on-property services such as taxi services.
• We rely on third parties to provide services and products on our behalf and may share your personal information with them as appropriate. Generally, our service providers are contractually obligated to protect your personal information and may not otherwise use or share your personal information, except as may be required by law. However, our fraud detection service providers may use, but not share, your personal information for fraud detection purposes. We may use service providers to communicate news and deliver promotional and transactional materials to you on our behalf, including personalized online and mobile advertising in accordance with your preferences and applicable law. Please see our Cookies (paragraph 11) for more information. Adams Beach Hotel will only work with parties that offer a method to opt-out of such advertising. We may also share information with service providers to allow you to create itineraries by selecting sites, activities, and restaurants from lists that we have personalized for you based on your preferences and third-party data.
• As we develop our business, we might sell, buy, restructure or reorganize businesses or assets. In such circumstances, Adams Beach Hotel may transfer, sell or assign information collected, including, without limitation, Other Information (described below) and personal information, to one or more affiliated or unaffiliated third parties in connection with these business transactions. To the extent that local laws require it, we will provide notice of our intent to transfer personal data to a third party for this purpose, and explain how you can object to such transfer.
• If you stay at our Hotel we may share your telephone number among other Hotels in the event of overbooking, for purposes of facilitating your hospitality needs in accordance with your preferences and applicable law. We may also receive your telephone number from our partners or from other sources, which we may use for facilitation purposes.
• In addition, Adams Beach Hotel may disclose personal information in order to:
• 1. comply with applicable laws,
  2. respond to governmental inquiries or requests from public authorities,
  3. comply with valid legal process,
  4. protect the rights, privacy, safety or property of Adams Beach Hotel, site visitors, guests, employees or the public,
  5. permit us to pursue available remedies or limit the damages that we may sustain,
  6. enforce our websites’ terms and conditions, and
  7. respond to an emergency.

PROTECTING PERSONAL INFORMATION

At Adams Beach Hotel we will take reasonable measures to:

1. Protect personal information from unauthorized access, disclosure, alteration or destruction,
2. Keep personal information accurate and up-to-date as appropriate. Adams Beach Hotel employs a robust internal team of dedicated information security professionals who are responsible for creating, updating and managing Adams Beach Hotel’s security program. Our Information Security team is responsible for, among many other things, monitoring our systems for potential intrusions, responding to potential incidents, supporting property-level information security, regularly reviewing and updating the security controls we use to protect data, and providing training on information security programs. Adams Beach Hotel maintains an IT compliance program and is certified to ISO 27001. This compliance program generates audit reports concerning the adequacy and effectiveness of Adams Beach Hotel’s IT internal controls, including an external ISO 27001 accredited bodies and report addressing the Information Security general controls over systems that support certain accounting and financial reporting. In the event of a security incident, Adams Beach Hotel will notify regulators and/or consumers as required by applicable laws or regulations.

We also seek to require our affiliates and service providers with whom we share personal information to exercise reasonable efforts to maintain the confidentiality of personal information about you. For online transactions, we use reasonable technological measures to protect the personal information that you transmit to us via our site. Unfortunately, however, no security system or system of transmitting data over the Internet can be guaranteed to be entirely secure.

For your own privacy protection, please do not send payment card numbers or any other confidential personal information to us via email unless a secure encryption method applies.

We will not contact you by mobile/text messaging or email to ask for your confidential personal information or payment card details. We will only ask for payment card details by telephone when you are booking a reservation or promotional package. We will not contact you to ask for your Adams Beach Hotel account log-in information. If you receive this type of request, you should not respond to it. We also ask that you please notify us at DPO@adams.co.cy

SENSITIVE INFORMATION

The term “sensitive information” refers to information related to your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, sex life, or sexual orientation, genetic information, criminal background, and any biometric data used for the purpose of unique identification. In some jurisdictions, mobile phone numbers, location data, and information contained on identity documents also are considered sensitive information.

We do not generally collect sensitive information unless it is volunteered by you or unless we are required to do so pursuant to applicable laws or regulations. We may use health data provided by you to serve you better and meet your particular needs (for example, the provision of disability access, Spa facilities).

CHILDREN PERSONNAL INFORMATION

We do not knowingly collect personal information from individuals under 18 years of age. As a parent or legal guardian, please do not to allow your children to submit personal information without your permission. In our facilities we provide child care services, were children personal information may be requested with your permission, for the protection of the under aged family member, while attaining these services. All child personal data collected will be destroyed by the termination of your residency in our premises following your departure.

OTHER INFORMATION

When you visit and interact with our website and apps, we collect other information that does not directly identify you about your use of the site, such as a catalog of the site pages you visit, and the number of visits to our sites (“Other Information”). We use Other Information, as well as data received from third parties, to deliver you email, online (on our sites and other sites) and mobile advertisements. We may also use Other Information to allow third-party partners to recognize you as an Adams Beach Hotel regular visitor.

We use cookies and other technologies (such as “pixel tags,” “web beacons,” “clear GIFs”, links in emails, JavaScript, device IDs assigned by Google or Apple, or similar technologies) to collect this information. If you want to remove or block Cookies from your device at any time, you can update your browser settings (consult your browser’s “help” menu to learn how to remove or block Cookies). We are not responsible for your browser settings. You can find good and simple instructions on how to manage Cookies on the different types of web browsers at www.allaboutcookies.org.

Note for EEA and UK-Residents: If you are based in Europe, you also can adjust your Cookie preferences by adjusting the Cookie Settings through the Cookie Consent Manager, which can be found here: ‘Cookie Preferences’.

You can learn more about interest-based advertising and how to opt out of our vendors’ and other advertisers’ use of Cookies to tailor content or advertising to you by visiting:

http://optout.networkadvertising.org/#!/ and http://www.aboutads.info/choices

At this time, we do not respond to Do Not Track signals or other, similar mechanisms.  Please see our Cookies Statement (paragraph 11) for more information.

TRANSFERS OF PERSONAL INFORMATION

We endeavor to provide you with the same level of service that you have come to expect at Adams Beach Hotel. To provide this service, you acknowledge that we may share your personal information among our departments, our service providers, and other third parties, which may be located in countries outside of your own. When you stay at a Adams Beach Hotel property the data controller may also maintain a local copy of your personal information when so required by applicable laws or regulations. Although the data protection laws of various countries may differ from those in your own country, we will take appropriate steps to ensure that your personal information is handled as described in this Statement and in accordance with the law.

We may use information we have collected and aggregated or anonymized personal information, or anonymized personal information received from third parties, to understand more about our users (for example, we may use aggregated information for example to calculate the percentage of our users who have a particular telephone area code). This includes demographic data, such as date of birth, gender and marital status, inferred commercial interests, such as favorite products or hobbies, and other information we may collect from you or from third parties.

Because Other Information does not personally identify you, such information may be disclosed for any purpose where permitted by law.  In some instances, we may combine Other Information with personal information. If we do combine any Other Information with personal information, the combined information will be treated by us as personal information in accordance with this Statement.

CHANGING AND ACCESSING YOUR PERSONAL INFORMATION

If you are a hotel registered quest, the information you provided to us at the time of registration may be accessed, reviewed and updated at any time by sending us your request at DPO@adams.com.cy

To the extent required by applicable law, you may be able to request that we inform you about the personal information we maintain about you and, where appropriate, withdraw your consent for certain data processing activity and/or request that we update, correct, delete, and/or stop processing your personal information. We will make all required updates and changes within the time specified by applicable law and as required by law. When permitted by law, we may charge an appropriate fee to cover the costs of responding to the request. Such requests may be submitted in writing to DPO@adams.com.cy. To protect your confidentiality, we can only respond to such requests to the email address that you have registered or otherwise provided to us. Please remember that if you make such a request, we may not be able to provide you with the same quality and variety of services to which you are accustomed.

In addition, in some circumstances based on applicable law, you may request that we cease sharing personal information about you with our business partners or cease using personal information about you by contacting us using the email or mailing address above. We will seek to honor those requests consistently with applicable law.

RETAINING PERSONAL INFORMATION

We retain personal information about you for the period necessary to fulfill the purposes outlined in this Statement, unless a longer retention period is required or permitted by applicable law. We retain personal information collected in order to fulfill guest reservations for the legally accepted period after the stay is completed. We retain other personal information for shorter periods of time if possible and if permitted by law.

Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes. We will retain and delete your personal data in accordance with the legal obligation to which we are subject.

We may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

We will destroy your personal information as early as practicable and in a way that the information may not be restored or reconstructed.

If printed on paper, the personal information will be destroyed in a secure manner, such as by cross-shredding or incinerating the paper documents or otherwise and, if saved in electronic form, the personal information will be destroyed by technical means to ensure the information may not be restored or reconstructed at a later time.

LINKS TO THIRD-PARTY WEBSITES AND SERVICES

Our site and our mobile applications may contain links to third parties’ websites. Please note that we are not responsible for the collection, use, maintenance, sharing, or disclosure of data and information by such third parties. If you provide information on and use third-party sites, the privacy policy and terms of service on those sites are applicable. We encourage you to read the privacy policies of websites that you visit before submitting personal information.

Adams Beach Hotel may also partner with a limited number of Internet providers to offer Internet access to our guests. Your use of on-property Internet service is subject to the third-party Internet provider’s terms of use and privacy policy. You can access those terms and policies using the links on the service sign-in page, or by visiting the Internet provider’s website.

CHOICES – MARKETING COMMUNICATIONS

If you have given us your contact information (mail address, fax number, email address or phone number), we may want to inform you in accordance with any preferences you have expressed, and with your consent where required, about our products and services or invite you to events via email, online advertising, social media, WeChat, WhatsApp, telephone, text message (including SMS and MMS), push notifications, in-app alerts, postal mail, our customer service call center, and other means (including on-property messaging, such as your in-room television).

If you are a registered member, you may change the communications you receive from us by emailing us at DPO@adams.com.cy

If you prefer not to receive email marketing materials from us, you may opt-out at any time by using the unsubscribe function in the email you receive from us or by contacting us at DPO@adams.com.cy. Opt-out requests can take up to ten business days to be effective.

To opt out of text messages, tell the hotel management that you do not want to receive text messages from the hotel or reply “STOP” to the message you received.

To be added to Adams Beach Hotel internal do not call list, send a message to DPO@adams.com.cy

You may control whether our mobile apps send you push notifications by changing your notification settings on your mobile device. If we engage in sending you in-app messages, we will allow control for those in our apps’ settings. For more information about cookies and interest-based advertising and to learn about how to manage these technologies, please see paragraph 11.

YOUR RIGHTS

Exercising your rights. You may exercise any of your rights in relation to your personal data by written notice DPO@adams.com.cy to us in addition to the other methods specified above

You may instruct us to provide you with any personal information we hold about you; provision of such information will be subject to:

(a) your request not being found to be unfounded or excessive, in which case a charge may apply; and

(b) the supply of appropriate evidence of your identity (for this purpose, we will usually accept a photocopy of your passport certified by a solicitor or bank plus an original copy of a utility bill showing your current address).

We may withhold personal information that you request to the extent permitted by law.

You may instruct us at any time not to process your personal information for marketing purposes.

In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt out of the use of your personal information for marketing purposes.

The rights you have under data protection law are:

(a) The right to access;

Your right to access your data. You have the right to ask us to confirm whether or not we process your personal data and, to have access to the personal data, and any additional information. That additional information includes the purposes for which we process your data, the categories of personal data we hold and the recipients of that personal data. You may request a copy of your personal data.

The first copy will be provided free of charge, but we may charge a reasonable fee for additional copies

(b) The right to rectification;

Your right to rectification. If we hold any inaccurate personal data about you, you have the right to have these inaccuracies rectified. Where necessary for the purposes of the processing, you also have the right to have any incomplete personal data about you completed.

(c) The right to erasure;

Your right to erasure. In certain circumstances you have the right to have personal data that we hold about you erased. This will be done without undue delay. These circumstances include the following: it is no longer necessary for us to hold those personal data in relation to the purposes for which they were originally collected or otherwise processed; you withdraw your consent to any processing which requires consent; the processing is for direct marketing purposes; and the personal data have been unlawfully processed.

However, we will only process it for other reasons: with your consent; in relation to a legal claim; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

(d) The right to restrict processing;

Your right to restrict processing. In certain circumstances you have the right for the processing of your personal data to be restricted. This is the case where: you do not think that the personal data we hold about you is accurate; your data is being processed unlawfully, but you do not want your data to be erased; it is no longer necessary for us to hold your personal data for the purposes of our processing, but you still require that personal data in relation to a legal claim; and you have objected to processing, and are waiting for that objection to be verified. Where processing has been restricted for one of these reasons, we may continue to store your personal data.

However, we will only process it for other reasons: with your consent; in relation to a legal claim; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

(e) The right to object to processing;

Your right to object to processing. You can object to us processing your personal data on grounds relating to your particular situation, but only as far as our legal basis for the processing is that it is necessary for: the performance of a task carried out in the public interest, or in the exercise of any official authority vested in us; or the purposes of our legitimate interests or those of a third party. If you make an objection, we will stop processing your personal information unless we are able to: demonstrate compelling legitimate grounds for the processing, and that these legitimate grounds override your interests, rights and freedoms; or the processing is in relation to a legal claim.

(f) The right to data portability;

Your right to object to direct marketing. You can object to us processing your personal data for direct marketing purposes. If you make an objection, we will stop processing your personal data for this purpose

Automated data processing. To the extent that the legal basis we are relying on for processing your personal data is consent, and where the processing is automated, you are entitled to receive your personal data from us in a structured, commonly used and machine-readable format. However, you may not have this right if it would adversely affect the rights and freedoms of others.

(g) The right to complain to a supervisory authority;

Complaining to a supervisory authority. If you think that our processing of your personal data infringes data protection laws, you can lodge a complaint with a supervisory authority responsible for data protection. You may do this in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.

(h) The right to withdraw consent;

Right to withdraw consent. To the extent that the legal basis we are relying on for processing your personal data is consent, you are entitled to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

STATEMENT MODIFICATIONS

We may modify this Statement from time to time. When we make material changes to this Statement we will post a link to the revised Statement on the homepage of our site, and if you have registered for any of your products or services, will may also inform you though a communications channel that you have provided. You can tell when this Statement was last updated by looking at the link and at the date at the bottom of the Statement. Any changes to our Statement will become effective upon posting of the revised Statement on the site. Use of the site, any of our products and services, and/or providing consent to the updated Statement following such changes constitutes your acceptance of the revised Statement then in effect.

CONTACT US

If you have any questions about this Statement or how Adams Beach Hotel processes your personal information, or if you wish to either provide a compliment or a complaint, please contact us by email at DPO@adams.com.cy. We will respond within 30 days or sooner if practicable.

MOBILE AND LOCATION-BASED SERVICES

We may provide mobile apps that can be downloaded to your smartphone or mobile device. These apps have a variety of functionalities that enhance the customer experience. In addition to providing services, our apps may collect personal and Other Information that will be used in accordance with this Statement. For example, to book or change a reservation, including a reward stay, you will be required to provide some personal information, such as your Adams Beach Hotel frequent visitor credentials or other information as necessary. Our Digital Key functionality within the Adams Beach Hotel collects information we already have about you, including your Adams Beach Hotel number and user ID, and additional information, including use of the key. We may provide a link to this Statement to customers prior to their downloading of any of our apps.

If you allow any of our mobile apps to access your location information on your device, our mobile apps may use your mobile device’s Global Positioning System (GPS) technology and other technology (such as wireless transmitters known as beacons) to provide you with information and offers based on the location of your device. Beacons allow us to collect information about your location within participating hotel locations by communicating with mobile devices that are in range. We may use this location information to enhance your on-property experience by delivering push notifications and other content to your mobile device, providing navigation assistance as you move around our locations, and sending you information and offers about products, services, or activities we believe may be of interest to you. We may share this information with third parties, including business partners and service providers, to provide information, offers, and services that may be of interest to you. You may prevent or limit collection of location information by changing the settings in costumed applications, or by changing your device’s settings.

The hotel will access and use your personal information (such as your name, confirmation number, check-in and checkout dates, and room number) in providing these customized services. If you request SMS (text) communications, you will be required to provide your phone number. We may also communicate with you by means of third-party digital messaging apps. If we do so, the privacy policies of those services apply.

We are open to offer all of these mobile and location-based services only to the extent permitted by applicable local laws.

PRIVACY STATEMENT REVISIONS

• Updated to provide more detailed information about how we collect, use, share and protect personal information of our guests.
• Added hyperlinks to Adams Beach Hotel portal for guests to make individual rights requests pursuant to laws in some jurisdictions.

ADDITIONAL PROVISIONS APPLICABLE TO PROCESSING OF PERSONAL INFORMATION OF EEA RESIDENTS

For individuals residing in the EEA, this text outlines certain additional information that Adams Beach Hotel is obligated to provide to you, as well as certain rights you have with respect to the processing of your personal information, pursuant to applicable local laws. This text will control to the extent it conflicts with any provision in the main body of this Statement.

The legal bases for Adams Beach Hotel’s processing activities include processing such information as necessary to comply with our contractual obligations, compliance with our legal obligations, protecting the safety of our employees, guests and others, for our legitimate business interests, and pursuant to your consent.

The particular legal basis for the processing of your personal information is based on the purpose for which such information was provided or collected:

• We process the personal information obtained in connection with your participation in any of our hospitality programs on the basis of our contractual relationship with you and in furtherance of our business interests, including to personalize your use of our services and applications, to communicate news and promotional items, and to deliver personalized advertising and content.
• Completion of surveys is voluntary – we process the information obtained from surveys on the basis of your consent and in furtherance of our business interests, including marketing, service improvements, and analytics.
• On-property Collection:
• When you make a reservation and when you stay at our hotel properties, we process your name, address, contact information, along with the details of your stay (arrival and departure day and time, vehicle information and information regarding others traveling or staying with you), on the basis of our contractual relationship with you. We also process such data for our business interests, including for marketing, service improvements, administration of our data program, and analytics and service personalization, as described in our Privacy Statement (above).
• We collect certain additional personal information during registration/check-in at our properties (such as national ID or passport information), as necessary to comply with our legal obligations
• We use closed circuit television and other security measures at our properties that may capture or record images of guests and visitors in public areas, as well as information related to your location while on our properties (via keycards and other technologies) for the protection of our staff, guests and visitors to our properties.
• We process personal information in connection with on-property services (such as concierge services, health clubs, spas, activities, child care services, equipment rental, and our Key functionality), in order to provide the services to you and for our business interests including for marketing, service improvements, administration of our data program, and analytics and service personalization, as described in our Privacy Statement (above).
• We process the personal information obtained in connection with your event on the basis of our contractual relationship with you and for our business interests, including for marketing, service improvements, and analytics and service personalization, as described in our Privacy Statement (above).
• Participation in our social media activities and offerings is voluntary – we process information obtained from social media participation on the basis of your consent and in furtherance of our related business interests, including for marketing, service improvements, and analytics and service personalization, as described in our Privacy Statement (above).
• Participation in contests and other promotional offerings is voluntary – we process the information obtained from such participation based on your consent and as necessary to administer the offering. We also use certain data for our business purposes, including for marketing, service improvements, administration of our data program, and analytics and service personalization, as described in our Privacy Statement (above).
• We use your personal information to send you marketing messages on the basis of your consent. You may withdraw your consent for direct marketing communications at any time by contacting us at DPO@adams.com.cy or by following the unsubscribe instructions in the marketing message, or request by updating your communication preferences.
• Suppliers’ personal data is processed based on your consent and for our related business interests, including maintaining and enhancing our hospitality program.

Retention: We retain personal information about you for the time necessary to accomplish the purpose for which such information was collected, usually for the duration of any contractual relationship and for any period thereafter as legally required or permitted by applicable law. Our retention policies reflect applicable statute of limitation periods and legal requirements.

Data Subject Rights: Residents of the EEA have the following rights:

Access, Correction and Erasure Requests: You have the right to:

• ask us to confirm whether we are processing your personal information
• receive information on how your data is processed
• obtain a copy of your personal information
• request that we update or correct your personal information
• request that we delete personal information in certain circumstances

Right to Object to Processing: You have the right to request that we cease processing of your personal information:

• for marketing activities, including profiling
• for statistical purposes
• where such processing is based on our legitimate business interests, unless we are able to demonstrate a compelling legitimate basis for such processing or we need to process your personal information for the establishment, exercise or defence of a legal claim

Right to Restrict Processing: You have the right to request that we limit the processing of your personal information:

• while Adams Beach Hotel is evaluating or in the process of responding to a request by you to update or correct your personal information
• where such processing is unlawful and you do not want Adams Beach Hotel to delete your data
• where Adams Beach Hotel no longer requires such data, but you want us to retain the data for the establishment, exercise or defence of a legal claim
• where you have submitted an objection to processing based on our legitimate business interests, pending our response to such request
• Where we limit the processing of your personal information pursuant to your request, we will inform you prior to re-engaging in such processing.

Data Portability Requests: You have the right to request that we provide you or a third party that you designate with certain of your personal information in a commonly used, machine readable format. Please note, however, that data portability rights apply only to personal information that we have obtained directly from you and only where our processing is based on consent or the performance of a contract.

Submitting Requests: your requests may be submitted to us at DPO@adams.com.cy.

We will respond to all such requests within 30 days of our receipt of the request, unless there are extenuating circumstances, in which event we may take up to 60 days to respond. We will inform you if we expect our response to take longer than 30 days. Please note, however, that certain personal information may be exempt from such rights pursuant to applicable data protection laws. In addition, we will not respond to any request unless we are able to appropriately verify the requester’s identity. We may charge you a reasonable fee for subsequent copies of data that you request.

If you have concerns about our data practices or the exercise of your rights, you may either contact us at DPO@adams.com.cy or the supervisory authority in the Member State of your residence.

Right to Withdraw Consent: You have the right to withdraw your consent to any processing that we conduct solely based on your consent (such as sending direct marketing materials to your personal email account). You may withdraw your consent to marketing activities by following the instructions on any marketing emails, or contacting DPO@adams.com.cy. For any other activities for which you have previously consented, you may contact DPO@adams.com.cy to withdraw such consent.

Segmentation (also referred to as profiling) and Automated Decision Making: We use personal information to divide large groups of consumers into sub-groups of consumers (known as segments) based on some type of shared characteristics such as geography, behavior, or demographics.

With your consent, we make automated decisions, meaning without human interference, using segmentation and/or your specific personal information to offer you certain benefits based on your characteristics (such as discounted room rates or other special offers based on your geography, behavior, or demographics).

International Data Transfers: We may transfer the personal information we collect about you pursuant to the purposes described in this Statement to countries that have not been found by the European Commission to provide adequate protection.

We use appropriate safeguards for the transfer of personal information among our affiliates in various jurisdictions, and where required, we have implemented European Union controller-to-controller standard contractual clauses or other such safeguards for such purposes. To obtain a copy of theses clauses or additional information on transfers, you may send your request to

Applicant Privacy Notice

At Adams Beach Hotel we value the trust of individuals submitting job applications to Adams Beach Hotel (“you” or “Applicant”) and are committed to the responsible management, use and protection of personal information. This Applicant Privacy Notice (this “Notice”) applies to all the information collected by Adams Beach Hotel to facilitate your job application and includes your use of our careers site/facilities. This Notice explains how Adams Beach Hotel processes the personal information that we collect through the job application process (“personal information”).

Personal information submitted to other Adams Beach Hotel web sites will be used in accordance with our  Privacy Statement.

Where additional consent, consultation or other rights exist under local laws, Adams Beach Hotel’s processing of personal information will be subject to the exercise of those rights.

In some locations around the world, Adams Beach Hotel manages hotel properties on behalf of a third party owner. If you accept a position with Adams Beach Hotel, you will be considered an Adams Beach Hotel “Team Member” and a this policy notice will govern our use of your personal information.

Your Consent

Please read this Notice carefully and indicate your acceptance of our collection, retention, use, transfer and disclosure of personal information as described in this Notice

Adams Beach Hotel maintains safeguards designed to protect your personal information. Information You Provide

This Notice covers any personal information you submit to apply or search for a position at Adams Beach Hotel, which may include:

• Log-in and password, for users of the Careers Site;
• How did the applicant find out about the job?;
• CV, résumé, cover letter;
• Name and contact information (such as your home address, telephone number, mobile telephone number, and email address);
• References (name, employer, title, relationship, email, phone);
• Responses to screening questions;
• Employment preferences, willingness to relocate, willingness to travel, current salary, desired salary;
• Previous (or current) work experience (such as start and end date, employer, responsibilities)
• Education (such as Education level, School, Major)
• Certifications held;
• Self-Identification (such as Age range, Gender, Religion, Disabled, Ethnic Group) Adams Beach Hotel may also collect the following information from applicants in the United Kingdom and Ireland and other EEA jurisdictions:
• Right to Work Document Type
• If the document provided is a Visa/Work Permit, please provide the type:
• Number
• Country of Issue
• Place of Issue
• Issue Date
• Expiry Date

We do not require, but you may voluntarily choose to provide, other relevant information as part of your application. Please do not submit the following sensitive information unless we specifically request that you provide such information so that we may comply with our legal obligations and/or internal policies relating to diversity and anti-discrimination: sexual orientation, race, ethnic origin, religion, political and religious beliefs, disability, marital status, creed, nationality, national origin, color and/or age.

By voluntarily submitting information about your racial or ethnic origin; physical or mental health or condition; job evaluations or educational records; commission (or alleged commission) of an offence or related proceedings; political opinions or beliefs; religious beliefs; sex life; membership in a trade union or political party, you expressly authorize Adams Beach Hotel to receive and process such information for the purpose of processing your application.

Any information you submit must be true, complete, and not misleading and you must have the lawful right to provide it. If not, this may lead to a rejection of your application during the application process or disciplinary action including immediate dismissal if you have been hired.

If you intend to provide us with details of a reference or any other third party as part of your CV/resume, it is your responsibility to obtain consent from that third party prior to providing his/her personal information to us.

The provision of personal information, including on the Careers Site, is voluntary. Please note however that the failure to provide sufficient information may result in Adams Beach Hotel being unable to consider you for employment.

Legal Bases and Use of Personal Information

The information that you submit in your application on the Careers Site will be stored in our data base. It will be collected, used, transferred and disclosed by employees, consultants and/or service providers of Adams Beach Hotel to assist our recruitment functions and for related management and planning purposes, including, as permitted by local law, to:

• Process your application;
• Assess your capabilities and qualifications for a job;
• Provide to you any services available on the Careers Site from time to time;
• Communicate with you;
• Comply with any applicable law or regulation; and
• Conduct background checks if you are offered a job.

Personal information about you will be added to Adams Beach Hotel‘s candidate database and will be used for the purposes of considering whether your profile is suitable for other job vacancies at Adams Beach Hotel. If we elect to make you an offer, personal information you submit may be incorporated into our human resources system and used to manage the new-hire process. The processing of your personal information for these purposes is based on your consent. If you become a Team Member, any personal information that you submit may become part of your Team Member file and may be used for other employment/work-related purposes and otherwise in accordance with the Adams Beach Hotel Privacy Notice.

To the extent any use is inconsistent with or outside of the contemplated uses in this Notice, we will communicate it to you at the time of use.

Disclosure of Personal Information

Personal information about you will be reviewed by Adams Beach Hotel Team Members who have a business need to access such personal information and may include, human resources personnel, technical services personnel and managers or their designees.

We may share personal information about you with selected service providers or consultants acting on our behalf, such as third parties assisting Adams Beach Hotel who are required to use appropriate measures to protect the confidentiality and security of personal information.

Adams Beach Hotel also may disclose personal information about you in order to:

1. Protect the legal rights, privacy, safety or property of Adams Beach Hotel or its Team Members, agents, contractors, customers or the public;
2. Protect the safety and security of visitors to our web sites or other properties;
3. Protect against fraud or other illegal activity or for risk management purposes;
4. Respond to inquiries or requests from legal authorities;
5. Permit Adams Beach Hotel to pursue available remedies or limit the damages that we may sustain;
6. Enforce our website Terms of Service;
7. Respond to an emergency;
8. Comply with the law or legal process;
9. Effect a license, sale or transfer of a business or assets (including in connection with any bankruptcy or similar proceedings); or
10. Manage acquisitions, mergers and re-organizations.

Data Retention

If you are a resident of the EEA, we will retain your personal information for three years during which time we may contact you regarding open positions. Personal Information of candidates applying for will be retained in accordance with local law. If there is no activity in relation to the personal information, Adams Beach Hotel may remove it from its database, subject to Adams Beach Hotel‘s data retention obligations and policies and any applicable legal or regulatory obligations or for the period of time permitted by local laws, for the purpose of considering whether your skills are suitable for other opportunities.

Note that Adams Beach Hotel may delete personal information about you at any time (including your CV/resume), without any reason. Therefore, please retain your own copy of the personal information provided to us.

Passive Information Collection: Cookies and Similar Technology

We and our service providers may use “cookies” and similar technologies on the Careers Site. Cookies are data that a web server transfers to an individual’s computer for record keeping purposes. We use cookies and other technologies to better serve you with more tailored information and facilitate your ongoing access to and use of our Careers Site. If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows you to automatically decline cookies, or to be given the choice of declining or accepting the transfer of a particular cookie, or cookies from a particular website, to your computer. However, if you decline tis session management cookies, the Careers Site may not function properly for you.

If you are an EEA resident, we are required to obtain your consent before placing certain cookies or similar technology on your computer. We will separately prompt you for this consent before we attempt to place a cookie or similar technology on your computer.

Access, Correction and Deletion

If you choose to register on the Careers Site, you may access, review, and change some of the personal information collected about you and stored on the Careers Site by logging into the Careers Site and choosing to update your account information. The updated profile will be used as the default the next time you apply for a job using your account online. To change personal information that you already have submitted for consideration for a specific position, please resubmit your application to update personal information about you that is associated with that job application. We encourage you to promptly update your personal information if it changes or is inaccurate. Upon your request, we will deactivate or remove your personal information from our active databases, although some information may be retained as permitted or required by law.

If you have any questions or concerns about how we otherwise process personal information please contact us at the e-mail link below.

Click DPO@adams.com.cy to send an email

You may access, modify or object to the use of personal information as permitted by applicable local law. Please contact us at the e-mail link below with any such requests. Please note that certain personal information may be exempt from such access, correction, or objection rights pursuant to local data protection laws. Furthermore, if you are an EEA resident, you may have other rights with respect to your personal information as explained in

Career Site Security

We take reasonable precautions to safeguard the personal information transmitted between visitors and the Careers Site and the personal information stored on our servers. Unfortunately, no method of transmitting or storing data can be guaranteed to be 100% secure. Do not send sensitive information via email. It is your sole responsibility to use the appropriate level of care whenever communicating with us.

If you have reason to believe that your interaction with us is no longer secure (for example, you feel that the security of any account you might have with us has been compromised), you must immediately notify us of the problem by contacting us at the link below.

Click DPO@adams.com.cy to send an email

Adams Beach Hotel hereby disclaims, as far as permitted by law, any liability for itself and its affiliated companies and contractors for any of your information sent to our Careers Site that is lost, misused, illegally accessed, disclosed, altered or destroyed or not integrally or timely delivered to our Careers Site.

Links to other websites

The Careers Site may contain links to other websites. The operators of those other websites may collect information about you, through cookies or other technologies. If you link to another website, you will leave the Careers Site and this Notice will not apply to your use of and activity on those other sites.

If you provide personal information through or on any other site, your transaction will occur on that website (not the Adams Beach Hotel Careers Site) and the personal information you provide will be collected by, and controlled by the privacy policy of that website operator.

Links on the Careers Site to other websites are provided only as a convenience, and the inclusion of such links does not imply endorsement of the linked site. We encourage you to read the legal notice posted on those sites, including their privacy policies. We have no responsibility or liability for your visits to, or the data collection or use practices of, other sites.

Law Applicable to Job Application

The Careers Site allows you to benefit from Adams Beach Hotel‘s recruitment function, while applying for jobs worldwide.

About Children

The Careers Site is not intended for applicants under the age of 17 or the lawful age of employment.

Changes to the Notice

We reserve the right to amend this Notice at any time without advance notice in order to address future developments of Adams Beach Hotel, the Careers Site or changes in industry or legal trends. We will post the revised Notice on the Careers Site or announce the change on the home page of the Careers Site. You can determine when the Notice was revised by referring to the “Last issue” legend on the bottom of this Notice. Any changes will become effective upon the posting of the revised Notice on the Careers Site. By continuing to use the Careers Site following such changes, you will be deemed to have agreed to such changes. If you do not agree with the terms of this Notice, in whole or part, you can choose to not continue to use the Careers Site.