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Last update on the 12th May 2022

Orange Label s.r.o., Id. No. 27573311, with its registered office at Legerova 1820/39, 120 00 Praha, (hereinafter: “Company”, “Controller”) respects the personal rights of its clients, hence it prepared this Privacy Policy. This Privacy Policy describes how the Company, which are operated under the Orange Label trademark, collect, use or otherwise process your Personal Data.

Important to know

The Company operates in accordance with the Act No. 101/2000 Coll. on the Data Protection and with the Regulation (EU) 2016/679 of the European Parliament and of the Council, on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter as “GDPR”). This Policy is developed to explain our practices regarding the Personal Data we collect from you or about you at https://orangelabel.ru/(collectively, the "website"). The most important principles of processing your Personal Data are lawfulness and transparency, that is why we use Personal Data only if:

  • We obtain the consent of the data subject,
  • It is necessary for performance of a contract with data subject,
  • It is required for compliance with a legal obligation,
  • It is necessary in order to protect the vital interest of the data subject,
  • The Company has a legitimate interest in usage of the Personal Data.

For any questions concerning the processing of your Personal Data, please contact the Company whose contact details stated in clause 16 of this Privacy Policy. Please read this Privacy Policy carefully to understand how and for what purposes we process your Personal Data.

1. Definitions

Controller: A legal person, Orange Label s.r.o., Id. No. 27573311, with its registered office at Legerova 1820/39, 120 00 Praha who determines the purposes and means of the processing of Personal Data and the company which is operating the hotel where you stay.

Consent of the data subject: means any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of Personal Data relating to him or her;

Processor: A natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the controller.

Recipient: A natural or legal person, public authority, agency or another body, to which the Personal Data are disclosed, whether a Third Party or not.

Third Party: A natural or legal person, public authority, agency or body other than the data subject, controller, Processor and persons who, under the direct authority of the controller or processor, are authorized to process Personal Data.

Supervisory Authority: An independent public authority which is established by a Member State pursuant to Article 51 of the GDPR. Specifically, the Office for Personal Data Protection Pplk. Sochora 27, 170 00 Prague 7, Czech Republic, posta@uoou.cz, +420 234 665 800 (GDPR infoline).

Personal Data: Any information relating to an identified or identifiable natural person (“Data Subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, 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.

Processing: Any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Orange Label: The Company and its subsidiaries based in the European Economic Area (EEA), but also foreign subsidiaries which are operating under the Orange Label trademark in other countries outside of EEA. 

Standard Contractual Clauses: Sets of standard contractual clauses for transfers as adopted by the European Commission for the international transfer of Personal Data.

Personal Data Breach: A breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, Personal Data transmitted, stored or otherwise processed.

2. Personal Data that we collect and process

The Company collects and processes your Personal Data only where permitted by law. We only collect Personal Data relevant for the purpose described in this Privacy Policy and in accordance with the principles of lawfulness and transparency. Personal Data may include:

2.1.In the case of using website Orange Label the Company requests/can request that the User makes the following data available:

  • first name,
  • last name;
  • e-mail address;
  • phone number;

2.2.Also we may ask for additional information. We may also collect information such as in-app messages and SMS.

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.

3. Personal Data collected from third parties

It is important for us to keep your Personal Data up to date and accurate at all times, why we may import Personal Data about you from external sources such as public registers. When the law requires that consent be obtained for the processing of certain types of Personal Data or for certain forms of processing, consent will be obtained from you before processing takes place. 

We may also collect information about you from third parties, including information from airlines, payment systems, and other partners; from online social services consistent with your settings on such services; and from other third-party sources that are lawfully entitled to share your data with us. 

The Company uses and shares this information only for the purposes described in the relevant contracts with the third parties which are contractually obligated to protect your Personal Data. We will do our utmost to ensure that all of our partners comply with the applicable data protection laws and this Privacy Policy in relation to the processing of your Personal Data.

4. Use of collected Personal Data

We use your Personal Data in different ways where permitted: to improve and personalize the services you expect from Orange Label;

  • We use your Personal Data to maintain and improve this website, including improving your online experience and ensuring content is presented on the websites. To administer the website and for internal operations, data analytics, research, testing, statistical and survey purposes; as part of our efforts to keep the website safe and secure;
  • We may use your Personal Data to provide you with information about meeting and event planning;
  • Where permitted we may use your Personal Data to provide or offer you our  services;
  • We may use your Personal Data to improve our services and to ensure that our website, products, and services are of interest to you.
  • We use your Personal Data to notify you about changes to our services, the website, and this Policy.

You are entitled, at any time and without charge, to request us to refrain from processing your Personal Data for marketing purposes or revoke your consent thereto. Also, you have a right to get your Personal Data for further transfer. You may exercise these rights by contacting us at the address which is stated below.

5. Personal Data we share

Orange Label operates in many countries we endeavor to provide you with the same level of services throughout the world. Thus, we have to share your Personal Data with other recipients to the following conditions:

We rely on third parties to provide services and products on our behalf and may share your Personal Data with them as appropriate. All our service providers are contractually obligated to protect your personal information and may not otherwise use or share your Personal Data, except as required by law or stated in the contract.

With local authorities: We may be obliged to send your information to local authorities if this is required by law or as part of an inquiry. We will ensure that any such transfer is carried out in accordance with local regulations.

6. International Data transfers

The Controller may transfer your Personal Data to internal or external recipients who may be in countries offering different levels of personal data protection. To provide a necessary level of security and data protection Orange Label employs appropriate measures to ensure secure transfer of your personal data to the Controllers located in a country offering a different level of privacy from that in the country where the personal data was collected (outside of EEA). 

Your data may be sent, in particular as part of the process, to Orange Label located outside of the European Union, in particular in the following countries: Russia, Ukraine. In case you wish to obtain more details about our data transfer safeguards and the mechanisms in place, you may contact us at orange@orangelabel.com.

7. Other information

When you visit and interact with the website, the Company collects 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 web (“Other Information”). We use Other Information to deliver you email, online (on our sites and other sites), and mobile advertisements. 

The Company may also use Other Information to allow third-party partners to recognize you as a Orange Label’s client when you visit the partner’s website or app, or to recognize you as one of their customers when you visit Orange Labelwebsites or apps so that they may provide more relevant offers to you. 

Our website uses 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 relate to its digital services. The Company uses “Google Analytics”, a web analysis service from Google, Inc. (“Google”). 

Google Analytics uses so-called cookies, i.e. text files, which are stored on your computer and facilitate an analysis of your usage of the website. The data generated by the cookie relating to your use of this Site (including your IP address) is usually transmitted to a Google server in the USA, where it is stored. 

Google uses this data on behalf of the website operator to evaluate usage of the website, to produce reports on website activity for the website operator, and to perform further services connected to website usage and internet usage. Google may also transfer this information to third parties where required by law or insofar as third parties process this data on behalf of Google. Under no circumstances will Google associate your IP address with other Google data. 

You can prevent the installation of cookies by setting your browser software appropriately; please note however that, in this case, you will not be able to make full use of the functionality of our website. By using this website, you agree that the data relating to you which has been collected may be processed by Google in an aforementioned manner and for the aforementioned purpose. 

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 Data. If we do combine any Other Information with Personal Data, the combined information will be treated by us as Personal Data in accordance with this Statement.

8. 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. 

We don’t generally collect sensitive information unless it is volunteered by you. We may use health data provided by you to serve you better and meet your particular needs (for example, information that you state in the “Notes” section during the reservation procedure).

9.Personal Data from minors

We do not knowingly collect personal information from individuals under 18 years of age. As a parent or legal guardian, please do not allow your children to submit Personal Data without your permission. In the event we learn that we have collected Personal Data from a child under the age of 18 without verification of parental consent, steps will be taken promptly to remove that information. 

If you believe that we have or may have information from or about a child under 18 years of age, please contact us at orange@orangelabel.com.

10.Protection of Personal Data

The Company takes reasonable measures to (i) protect Personal Data from unauthorized access, disclosure, alteration or destruction, and (ii) keep Personal Data accurate and up-to-date as appropriate. We also seek to require our partners and service providers with whom we share Personal Data to exercise reasonable efforts to maintain the confidentiality of Personal Data about you. 

The Company uses SSL cryptography on its websites for online reservations. Any information shared by the data subject with the Company, its subsidiaries or partners shall be encrypted automatically and be protected when transferred through the network. 

When the information is received by our server, it is decoded by using an individual private key. SSL enables the browser to connect to the website and establish a secure communication channel in a transparent manner. SSL is the most widely used and most successful cryptographic system. In order to use the system, the data subjects simply need to verify their browsers’ compatibility. 

The Company shall ensure transparency to control and establish how and what personal data are transferred by applying data transferring devices, who and when entered which data into the system, and shall also make sure that the system can be restored in the case of a failure. Reports are generated with regard to errors occurring in the course of automated processing. 

The Company shall manage personal data confidentially, and shall not disclose them to unauthorized persons. 

The Company shall particularly protect personal data from unauthorized access, modification, transfer, publication, deletion, or destruction as well as from accidental destruction, harm, and inaccessibility due to modification of the applied technology. 

The Company shall take all security measures in order to ensure the technical protection of personal data. For online transactions, we use reasonable technological measures to protect the Personal Data that you transmit to us via our website. 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. 

We will not contact you by mobile/text messaging or email to ask for your confidential personal information or payment card details. In case of receiving a request about your payment card information by e-mail or SMS, please, do not reply, most probably you are communicating with swindlers. 

11.Changing, accessing, and portability of your Personal Data

GDPR grants specific rights, summarized below, which you may exercise free of charge, subject to statutory exceptions. These rights may be limited, for example, if fulfilling your request would reveal Personal Data about another person, or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping.

11.1. Right to withdraw consent

Wherever we rely on your consent, you will be able to withdraw that consent at any time you choose and at your own initiative on our website (if you have one) or by contacting us at orange@orangelabel.com. Also, in every letter received from us you will find a link to unsubscribe from the newsletter. The withdrawal of your consent will not affect the lawfulness of the collection and processing of your data based on your consent up until the moment where you withdraw your consent. Please note that we may have other legal grounds for processing your data for other purposes, such as those set out in this Privacy Policy.

11.2. Right to access and rectify your data

You have the right to access, review, and rectify your Personal Data. You may be entitled to ask us for a copy of your information, to review or correct it if you wish to rectify any information like your name, email address, passwords and/or any other preferences, you can easily do so by logging in to your account on our website (if you have one) or by contacting us at orange@orangelabel.com. You may also request a copy of the Personal Data processed as described in this Privacy Policy.

11.3. Right to erasure

In accordance with GDPR, you have the right to the erasure your Personal Data processed by us as described in this Privacy Policy in case it is no longer needed for the purposes for which the Personal Data was initially collected or processed or in the event you have withdrawn your consent or objected to processing as described in this Privacy Policy and no other legal ground for processing applies. Should you wish to have your Personal Data erased, please file a request via email at orange@orangelabel.com.

11.4. Right to restriction of processing

Under certain circumstances described in GDPR, you may ask us to restrict the processing of your Personal Data. This is for example the case when you contest the accuracy of your Personal Data. In such event, we will restrict the processing until we can verify the accuracy of your data.

11.5. Right to object to processing

Under certain circumstances described in GDPR, you may object to the processing of your Personal Data, including where your Personal Data is processed for direct marketing purposes. If you object the processing form marketing purposes, the Company will not process your Personal Data anymore for this purpose.

11.6. Right to data portability

Where you have provided your Personal Data directly to us and where the processing is based on your consent or the performance of a contract between you and us, you have the right to receive the Personal Data processed about you in a structured, commonly used, and machine-readable format, and to transmit this data to another service provider. 

Should you have unresolved concerns, you have the right to lodge a complaint with a Supervisory Authority where you live or where you believe a breach may have occurred. We encourage you to come to us in the first instance but, to the extent that this right applies to you, you are entitled to complain directly to the relevant Supervisory Authority. We will make all required updates and changes within the time specified by applicable law and, where permitted by law, may charge an appropriate fee to cover the costs of responding to the request. 

Such requests must be submitted by email at orange@orangelabel.com or in writing to the following postal address: Orange Label s.r.o., Legerova 1820/39, 120 00 Praha, Czech Republic.

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 that the Company ceases using personal information about you by contacting you via email. We will seek to honor those requests consistently with applicable law.

12.Retaining Personal Data

The Company retains your Personal Data for the period necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by applicable law. We will destroy your Personal Data as early as practicable and in a way that the Personal Data may not be restored or reconstructed. 

If it is printed on paper, Personal Data 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.

13.Choices of marketing communications

If you have given us your contact information (postal address, 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, telephone, text message, push notifications, in-app alerts, our customer service call center, and other means. 

If you have explicitly consented to receive our newsletters or marketing communications, including in relation to Orange Label, we may, from time to time, contact you with information about our services and latest offers and process your Personal Data for this purpose. 

If you no longer want to receive our newsletters or marketing communications, please let us know by sending us an email at orange@orangelabel.com. You can also unsubscribe from our marketing emails by clicking on the unsubscribe link in the emails sent to you. For Orange Label.

14.Modifications of Privacy Policy

The Company may modify this Privacy Policy from time to time. When we make material changes to this Privacy Policy we will post a link to the revised Privacy Policy on the homepage of our website, and if you have registered for any of your products or services, will also inform you through a communications channel that you have provided. 

You can tell when this Privacy Policy was last updated by looking at the link and at the date at the top of the Privacy Policy. Any changes to our Privacy Policy will become effective upon posting of the revised Privacy Policy on the website. Use of the website, any of our products and services, and/or providing consent to the updated Privacy Policy following such changes constitutes your acceptance of the revised Privacy Policy then in effect.

15.Contact information

If you have any questions about this Privacy Policy or how the Company or Orange Label processes your Personal Data, please contact us by email at orange@orangelabel.com or by mail to Orange Label s.r.o., Legerova 1820/39, 120 00 Praha, Czech Republic.

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