We collect Your Personal Data for Direct Marketing provided directly from you as you subscribe to Our marketing newsletters and offerings and declare consent when:

1. Signing up Your account/profile on Our website(s);
2. Making bookings/reservations of Our hotel rooms/bars and restaurants through Our Website(s),
3. Checking in at Our premises upon Your arrival as a primary booker or as an accompanying guest.

Also, we collect Your Personal Data when purchasing and using Our products and services through Our operation systems.

By agreeing to this Direct Marketing Policy, you confirm that you have read it and give your consent for to process Your Personal Data for direct marketing purposes.

1. How We use Direct Marketing
   • We use e-mail provided by You for Direct Marketing purposes to send you information about Our and affiliate companies from Our group of companies 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 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. You have right to withdraw your consent at any time with no cost. 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.
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 marketing newsletters and special offerings regarding products and services as outlined in section 2 of this Direct Marketing Policy.
   • Our employees, who need to have access to and process Your personal data for direct marketing purposes and who are bound by confidentiality obligations with respect to proper handling, processing, storing and non-disclosure of your personal data;
   • Trusted third party contractors, including contractors acting as data processors 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. Platforms Used for Marketing Communications

   To provide you with marketing communications, we use the marketing platforms: MailChimp, Sendgrid and/or Omnisend, with which we share your email addresses provided to us for the purpose of sending marketing communications. Through these platforms, we also collect information about email openings and clicks, in order to monitor and improve the direct marketing process.

   The companies providing the mentioned platforms are legal entities registered in the United States and Latvia, which, in turn, process personal data in accordance with their personal data protection policies:

   • Mailchimp privacy policy (The Rocket Science Group, LLC, 675 Ponce de Leon Ave NE Suite 5000, Atlanta, GA 30308 USA).
   • Sendgrid privacy policy (Twilio Inc. c/o Corporation Service Company, 251 Little Falls Drive, Wilmington, DE 19808).
   • Omnisend privacy policy (Omnisend group companies: UAB Omnisend, Verkių g. 25C-1, LT-08223 Vilnius, Republic of Lithuania; Omnisend, LLC. Address - Unit A3, Gateway Tower, 32 Western Gateway, London, E16 1YL; Omnisend, Ltd. 1401 Sam Rittenberg Blvd Suite 2, Charleston, SC 29407, United States).

   By sharing data with the companies based in the United States, your personal information will also be stored on servers located in the United States. The United States is not included in the list of countries with adequate guarantees for the protection of personal data according to the relevant normative act of the Head of the Personal Data Protection Service. Therefore, by transferring your personal data outside the jurisdiction of Georgia: (a) they will be subject to the laws and regulations of the relevant country, (b) under such laws and regulations, you may not be able to exercise the same or equivalent rights in relation to your personal data as provided for under Georgian legislation.

   We inform you that the above-mentioned companies, based on relevant contractual obligations, undertake: to ensure that the data is processed in accordance with data protection standards in the European Union, to protect the confidentiality of “personal information” and to process it only in accordance with our instructions.

   After reviewing the above information and understanding the risks of transferring your personal data outside the jurisdiction of Georgia, by agreeing to this policy, you agree to the sharing of your email address with the named companies for the purpose of receiving marketing communications and to the processing of the data by these companies in accordance with their personal data protection policies.

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

   You can withdraw your consent at any time. 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.