Direct Marketing Policy

Published on: February 28, 2024

Please, carefully read this Direct Marketing Policy, as for the purposes of direct marketing, Adjara Hotels LLC (I/N: 404673947) (“Data Controller“) and Adjara Collective Management LLC (I/N: 404707171) („Data Processor“) (jointly – „We“, „Us“ or „Our“) will process your following personal data (the “Personal Data” or the “Personal Information”), if you click the direct marketing acceptance button on this website:

• Your Name and Surname;
• Your Date of Birth;
• Your ID Number;
• Your E-Mail Address;
• Your Phone Number (if provided).

Please, also refer to Our Privacy Policy which can be found here, to understand the further basis for processing the Personal Data, the principles we apply while processing your Personal Data and the rights that You, as the data subject (“You” / “Yours”), have in this regards.

Please, further note that, upon your consent to this Direct Marketing Policy, it automatically becomes an integral part of Our Privacy Policy, cited above.

1. How We use Direct Marketing

• We use e-mail provided by You for Direct Marketing to send you information about Our products and services, marketing newsletters and special offerings, advertisements, sales and promotions and collaborations with third parties (the “Marketing Communication”);
• We do not send Marketing Communication automatically to Our existing or prospective customers. We refer to an “Opt-in and Opt-out Policy” in this process, which implies that You will only receive Our Marketing Communication if We have Your express consent to this Direct Marketing Policy. Should you withdraw your consent to receive such communications from us, we will promptly cease all further Marketing Communication, no later than within 7 (seven) working days from the date of such withdrawal;
• You will not be receiving any Marketing Communication from Us via text message, phone call, post or fax.

2. What Kind of Marketing Communication You Might Receive from Us

Within the scope of your consent to receive Marketing Communication from Us, you will be receiving information about:

• Our products and services, which is customized to your interests and preferences;
• Our latest marketing newsletters and special offerings;
• Advertisement;
• News updates about Us and Our collaborations with other third parties;
• Our upcoming sales and promotions;
• Products and services offered by Our affiliate companies, including their marketing newsletters, special offers, advertisements, sales and promotions, as outlined in section 3 of this Direct Marketing Policy.

3. With Whom We Share Your Data for Direct Marketing Purposes

We may share your personal data with the following parties for direct marketing purposes:

• Our affiliates, which implies entities affiliated with/related to Us, i.e. any entity and/or person that is directly or indirectly controlled by Us, is under common control with Us or is controlled together with Us by other affiliated entity in consideration of common business interests. For the purposes of this Section, term “control” means possession, directly or indirectly, of the power to direct or cause the direction of the management and policies of an entity/person, whether through the ownership or control of interests or voting securities, by contract or otherwise.

Sharing is carried out in the frame of corporate governance/management structure and common business and marketing interests within Our group of affiliates, to provide you with their marketing newsletters and special offerings regarding their products and services.

• Our employees, who need to have access to and process Your personal data solely for direct marketing purposes and who are bound by the same degree of confidentiality obligations with respect to proper handling, processing, storing and non-disclosure of your personal data;
• Trusted third parties, acting as authorized persons to collect and process Your personal data on Our behalf, to help Us deliver efficient and quality services and effective Marketing Communication to You and which are bound by the same degree of confidentiality and standard of data security. Personal data sharing (Data transfer) with those third parties which are registered and operate abroad, is carried out in accordance with the rules established for the international transfer of data, under the applicable laws of Georgia.

4. If You Do Not Wish to Receive Marketing Communication from Us Anymore

Withdrawing your consent from direct marketing is just as easy as giving consent:

• Every Marketing Communication sent to you has an integrated Unsubscribe tool allowing you to easily opt-out of receiving any Marketing Communication from Us;
• Alternatively, you can also address us on the contact details indicated in section 6 of this Direct Marketing Policy.

Please, Note: If you opt-out of receiving direct marketing from Us, You will no longer receive any of Our Marketing Communications. We will ensure this opt-out request is processed within statutory timeframes (7 business days).

Withdrawing Your consent with Us will automatically result in withdrawing consent on receiving Marketing Communication from Our affiliates too. Therefore, You will not need to take any extra actions for them to cease Marketing Communication.

5. Storage Security and Duration

We treat Your Personal Information with utmost diligence and confidentiality and have implemented all the necessary technical and organizational security measures for the purposes of protecting this Information from unlawful usage, loss, alteration, erasure, processing or any other unauthorized forms of access to and impact on such Personal Data. These measures imply the storage of Your Personal Data on a secure electronic data base accessible only to a limited number of individuals, in accordance with internal standard operational procedures implemented and made binding by Us for Our personnel to comply with.

We will store and process Your Personal Data for direct marketing purposes throughout the duration of Our and/or Our affiliates/ operations unless You request its earlier withdrawal.

We further ensure that all the third parties indicated in clause 3 of this Direct Marketing Policy comply with the same rules and procedures.

6. Contact Information

For any questions, claims, requests or other inquiries, please contact Us here:

Adjara Hotels LLC (I/N: 404673947), Adjara Collective Management LLC (I/N 404707171).

Postal Address: 14 Kostava Street, Tbilisi, Georgia

E-mail address: pdsupport@adjaragroup.com

or, contact Personal Data Protection Service on the following information:

Personal Data Protection Service

Postal Address: 7 Nato Vachnadze Street, Tbilisi 0105

Phone: 032 242 10 00

E-mail Address: office@pdps.ge