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LAZART HOTEL, PRIVACY POLICY NOTICE
Lazart Hotel Trademark Collection By Wyndham Privacy Policy
This Privacy Policy Notice describes our practices in connection with information that we collect a)through websites operated by us from which you are accessing this Privacy Policy Notice (the "Websites"), b)through the software applications made available by us for use on or through computers and mobile devices (the "Apps"), and c)through our social media pages that we control from which you are accessing this Privacy Policy Notice (collectively, our "Social Media Pages"), (collectively, including the Websites, the Apps and our Social Media Pages, the "Services"). This Privacy Policy Notice also applies to our offline collection of information. The information you provide helps us to operate effectively and continually provide you with the best hospitality products, services and experiences.
This Privacy Policy Notice describes how the Lazart Hotel Trademark Collection By Wyndham collects, uses, consults or otherwise processes an individual’s Personal Data when using our websites, a or when relying on our hospitality services. Please note that if you plan to submit someone else’s Personal Data to us, for example when making a booking on their behalf, you may only provide us with that person’s details with their consent and after they have been given access to information about how we will use their details, including the purposes set out in this Privacy Policy.
EU Privacy Law requires us to be specific about our reasons and legal grounds for using your Personal Data. Accordingly, for the purposes of EU Privacy Law only, the information below describes the type of data we process where we get your data from, the grounds we rely on to carry out the processing, and who we may share your data with.
For the purpose of the EU Privacy Law, depending on the type of Personal Data processing described in this Privacy Policy Notice, Lazart Hotel Trademark Collection By Wyndham may be operating as a sole or joint Controller. If operating as a joint controller, both entities jointly determine the means and purposes of the processing of your personal data. What it means for you is that you can exercise your rights against either of joint Controllers by contacting our company as set below.
In some situations, described in this Privacy Policy Notice, the Hotel where you made a booking and/ or stay will process your data as a joint or sole Controller. The hotel will be solely responsible for the processing activities for which it is the Sole Controller
Lazart Hotel Trademark Collection By Wyndham is a Hotel Company incorporated under Greek Law, operated by Zeus International Hotel Management and Consulting, having its registered seat and its offices at 2 Megalou Alexandrou Street, 10437, Athens, Greece, telephone number: 216-8009900.
Your acceptance of our Privacy Policy Notice: By using the Services, you accept the terms of this Privacy Policy Notice and the ways we may use your information. If you do not accept the terms of this Notice, please do not continue to use the Services.
This Privacy Policy Notice includes detailed description of your Data Protection Rights, including some of the processing activities we carry out. Please note that your rights as a data subject may vary depending upon where you live.
DEFINITIONS
Affiliates and Subsidiaries: Any corporation, firm, partnership or other entity which directly or indirectly controls, is controlled by, or is under common control with Zeus International.
Controller: The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data, where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State Law.
EU Privacy Law: Regulation 2016/679 of the European Parliament and of the Council 27 April 2016 on the protection of natural persons with regard to the processing of Personal Data on the free movement of such data (the ‘’GDPR’’), as well as any legislation and/or regulation implementing or created pursuant to the GDPR and the e-Privacy legislation, or which amends, replaces, re-enacts or consolidates any of them, and all other national applicable laws relating to the processing of Personal Data and privacy.
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. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of processing.
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 Article 51 of the General Data Protection Regulation.
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 name, an identification number, location data, an online identifier or to one or more factors specific to the physical, psychological, genetic, mental, economic, cultural or social identity o 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
Privacy Shield: The EU-U.S. and Swiss-U.S. Privacy Shield legal framework, designed by the U.S Department of Commerce and the European Commission and Swiss Administration to provide companies on both sides of the Atlantic with a mechanism to comply with data protection requirements when transferring Personal Data from the European Union and Switzerland to the United States in support of transatlantic commerce.
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.
HOTEL BOOKING PROCESS
- HOTEL BOOKING PROCESS
In the context of the hotel booking process-whether this takes place online on one of our brand websites, through an online booking channel, via a travel agent, through our call center or directly at the hotel-we process your Personal Data for the purposes of a) enabling you to reserve a room in the hotel of your choice; b) verifying the availability of the hotel and to administer the booking; c) sending you a booking confirmation; d) sending you non-commercial pre-arrival emails. You may unsubscribe from pre-arrival emails at any time by clicking on the unsubscribe link in the emails sent to you.
Processed data categories
Address, Date of arrival and departure, Email address, First Name/ Last Name of adult co-guest(s), Payment card type, number and expiration date, Telephone number, Title.
We may collect Personal Data from when you interact with us such as when you:
- Register for a product or service
- Contact us with a question or request
- Use our Services
- Make a payment for a product or Service
- Stay at one of our properties
- Provide a testimonial or story
- Participate in a competition or sweepstake
- Participate in our loyalty program
- Cookies: This Website uses ‘’cookies’’. By using this Website and agreeing to this Notice, you consent to our use of cookies in accordance with the terms of this Notice. Cookies are small text files which this Website stores to your computer hard drive for record-keeping purposes and this information is stored in a file on your computer's hard drive. Cookies make web surfing and browsing easier and faster for you by saving your preferences so that we can use these to improve your next visit to this Website.
- One of the purposes of cookies is to simplify the use of the Website. A cookie may save a user’s login details for example, so that the user does not need to login every time. Cookies, by themselves, do not provide us with your personal information.
- Cookies may be either ‘’persistent’’ or ‘’ temporary’’ (or ‘’session’’) cookies. A persistent cookie retains user preferences for a particular Website allowing these preferences to be used in future browsing sessions and remains valid until its set expiry date (unless deleted by the user before the expiry date). A temporary cookie, on the other hand, will expire at the end of the user session when the web browser is closed.
- Cookies are also used for statistical or marketing purposes, to determine how the Website is used. These cookies are provided by us as well as by third parties (e.g. advertising partners). While we do not control or have access to the advertiser cookies, we do permit those cookies to be used on this Website to facilitate tailored advertising and to monitor patterns of buying specific goods or interest in for example, holidays or hobbies. These cookies run advertisements tailored to the user base on his/her online buying habits.
- For a current list of advertising partners who use cookies on this Website, and to modify your cookies settings, please access our Cookie Constent tool. Additionally, your browser may be set to allow you to be notified when a cookie is to be placed on your browser, decline the cookie, or delete cookies that have been placed on your browser. Some functions of our Web sites may not work or may work slowly if a cookie is refused.
- Google Analytics: We use Google Analytics to help us get a better understanding of how visitors use this Website. The information generated by the Google Analytics cookie about your use of this Website is transmitted and stored by Google. If you do not want your activity on this Website to be tracked by Google Analytics, you may opt out by using this link : http://tools.google.com.dlpage/gaoptout?hl=en
- Pixels, Beacons: We or third party ad servers may use invisible pixels or beacons on this Website to count how many users visit certain pages. This information is collected and reported in the aggregate. We may use this information to improve our marketing programs and content, and to target advertisements at this Website and/or on other sites.
- From Other Sources: We may receive your Personal Information from other sources, such as public databases, joint marketing partners, data firms, social media platforms, from people with whom you are friends otherwise connected on social media platforms, as well as from other third parties. For example, if you elect to connect your social media account to your Website account, certain Personal Information from your social media account will be shared with u, which may include Personal Information that is part of your public profile or your friends’ public profiles.
- Mobile Devices: When you use or access our Services from a mobile device, we may collect information such as your unique device ID and your location.
- Adobe Marketing Cloud Device Co-Op: WHG participates in the Adobe Marketing Cloud Device Co-Op to better understand how you use our Websites across the various devices you use, and to deliver tailored promotions. Go to https://marketing.adobe.com/resources/help/en_US/mcdc/mcdc-overview.html to learn more about how Adobe does this to manage your choices relating to this linking of devices.
- Do Not Track Signals: At this time, we do not respond to browser ‘do not track ‘ signals, as we await the work of interested stakeholders and others to develop standards for how such signals should be interpreted. Third parties including our service providers, may collect information about your online activities over time and across different websites, including when you visit our website . You can learn about how to exercise choice regarding the collection of information about your online activities over time and across third-party websites or online services by visiting www.aboutads.info and networkadvertising.org
- Internet Based Advertising: We may use third-party advertising companies to serve advertisements regarding goods and services that may be of interest to you when you access and use our Services and other websites, apps or online services, based on information relating to your access and use of our Services and other websites, apps and services on any of your devices, as well as information received from third parties. To do so, these companies may place or recognize a unique cookie on your browser (including through the use of pixel tags). They may also use these technologies, along with information they collect about your online use, to recognize you across the devices you use, such as a mobile phone and a laptop. If you would like more information about this practice, and to learn how to opt out of it in desktop and mobile browsers on the particular device on which you are accessing this Privacy Policy Notice, please visit aboutads.info and www.networkadvertising.org to opt out in mobile apps. You may also opt out in Twitter by going to your account privacy settings and unchecking the box next to “Tailor ads based on information shared by ads partners’’.
- Other Non-Personal Information: In addition to any Personal Information or other information that you choose to provide to us on the Services, we and our third-party service providers may use a variety of technologies, now and hereafter devised, that automatically collect certain website usage information whenever you visit or interact with the Services. This information may include browser type, operating system, the page served, the time, the source of the request, the preceding page view, and other similar information. We may use this usage information for a variety purposes, including to enhance or otherwise improve the Services. In addition, we may also collect your IP address or some other unique identifier for the particular device you use to access the Internet, as applicable (collectively referred to herein as a ‘’Device Identifier’’). A Device Identifier is a number that is automatically assigned to your device, and we may identify your device by its Device Identifier. When analyzed, usage information helps us determine how our Services are used, such as what types of visitors are interested in particular kinds of content and advertising. We may associate your Device Identifier or web site usage information with the Personal Information you provide, but we will treat the combined information as Personal Information.
As aggregated or anonymized information does not constitute Personal Information, we may use it for any purpose. If we combine anonymized or aggregated data with Personal Information, we will treat the combined information as Personal Information according to this Privacy Policy Notice.
Why and How We Use your Information
We may Process Personal Information in connection with any following:
- Our business transactions with you, including, but not limited to:
- To enter into or perform a contract with you
- To respond to your inquiries and fulfill your requests, such as to send you newsletters.
- To send administrative information to you, for example, information regarding the Services or an event in which you are attending and changes to our terms, conditions and policies.
- To complete and fulfill any purchases or requests for services, for example, to process your payments or a hotel stay or vacation rental, communicate with you regarding your purchase and provide you with related customer service.
- To send you marketing communications that we believe may be of interest to you via postal mail, email, telephone or SMS.
- To personalize your experience on the Services by presenting products and offers tailored to you.
- To allow you to participate in sweepstakes, contests and similar promotions and to administer these activities. Some of these activities have additional rules, which could contain additional information about how we use and disclose your Personal Information, so we suggest that you read these rules carefully.
- To facilitate social sharing functionality.
- To allow you to send messages to a friend through the Services. By using this functionality, you are telling us that you are entitled to use and provide us with your friend’s name and email address.
- For our business purposes, such as data analysis, audits, fraud monitoring and prevention, developing new products, enhancing, improving or modifying our Services, identifying usage trends, determining the effectiveness of our promotional campaigns and operating and expanding our business activities.
- As we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.
- In accordance with any consent you may have provided. You have the right to decline to provide your consent and, if consent is provided, to withdraw your consent at any time.
- As necessary or appropriate for legal reasons, including but not limited to:
- Under applicable law
- To comply with legal process
- To respond to requests from public and government authorities, including those outside
- To enforce our terms and conditions
- To protect our operations or those of any of our Affiliates or third parties
- To allow us to pursue available remedies or limit damages we, our Affiliates, or third parties, may sustain.
We may disclose your information as follows:
- Franchised Hotels, Managed Hotels, Vacation Rentals: We may share personal information with the owners and operators of our franchised hotels or owners of hotels that we manage but do not own and timeshare resorts in order to provide you with services.
- Vendors and Service Providers: We may disclose your Personal Information to vendors and service providers we retain in connection with our business such as: travel services companies, financial services companies, property owners’ associations, vacation insurance companies, website hosting, data analysis, payment processing, order fulfillment, information technology and related infrastructure provision, customer service, email delivery, credit card processing, tax and financial advisers, legal advisers, accountants or auditing services.
- Message Boards: We may take message boards, blogs, and other such user-generated content facilities available to users. Any information that is disclosed in these areas becomes public information and you should always be careful when deciding to disclose your personal information. We are not responsible for privacy practices of other users including website operators to whom you provide information.
- Business Partners, Sponsors, and Other Third Parties: We may disclose your Personal Information to business partners, co-sponsors of promotions, and other third parties in order to provide you with services that may be of interest to you. For example, we may share your Personal Information with the owners and operators of affiliated and unaffiliated hotels and resorts, airlines, car rental services, retail store, credit agencies and other third parties to facilitate reservations, to offer you products or services, or in connection with our loyalty program or a loyalty program of one of our partners. We may also co-sponsor promotions, sweepstakes, or other events with a third party and may share your Personal Information in connection with these events. Further, we may share your Personal Information with third party providers located on-site at hotels or resorts, such as time-share, spa, golf, concierge and dining providers. If you provide additional information to any of these third parties, such information will be subject to such third parties privacy practices.
- Third Parties: Subject to your marketing preferences (which may include consent to marketing under applicable law), we may license, sell or otherwise share your Personal Information with selected third parties for compensation for their own business purposes. Once we share your Personal Information with a third party for such purposes, the information shared becomes subject to such third party’s privacy practices.
- Disclosure Permitted by Law: We may disclose your Personal Information to law enforcement authorities, government or public agencies or officials, regulators, and/or to any other person or entity having appropriate legal authority or justification for receipt of your information, if required or permitted to do so by law or legal process, to respond to claims, or to protect our rights, interests, privacy, property or safety, and/or that of our Affiliates, you or other third parties.
- Anonymized/Aggregated Information: Because aggregated or anonymized information does not personally identify you, we may use it for any purpose. If we combine anonymized or aggregated data with personal information, we will treat the combined information as personal information according to this Privacy Policy Notice.
- Security of Your Information: We will take reasonable steps to protect the information you provide us from loss, misuse and unauthorized access, disclosure, alteration and destruction. We have implemented appropriate physical, electronic and managerial procedures to help safeguard and secure your information from loss, misuse, unauthorized access or disclosure, alteration or destruction. Unfortunately, no security system is 100% secure, thus we cannot ensure the security of all information to provide us via the Services.
- Information Provided on Someone Else’s Behalf: If you provide us with information about someone else, please ensure you have the person’s permission to do so for the purposes detailed in this Privacy Policy Notice.
- Links to Websites: The Services may have links to other websites that are not operated by us. We have no control over how these websites may collect your information and no liability for the practices, policies and security measures implemented on these websites. You should read the privacy notices on those other websites before you submit your information through them.
- Social Media Sites: Please note that we are not responsible for the collection, usage and disclosure policies and practices (including data security) of other organizations, such as Facebook, Apple, Google, Microsoft, RIM or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including any Personal Information you disclose to other organizations through or in connection with the Apps or our Social Media Pages.
- Changes to Our Privacy Policy Notice: From time to time we may revise this Privacy Policy Notice and/or use Personal Information for new, unanticipated uses not previously disclosed to meet changes in the regulatory or business environment, or to satisfy the needs of our customers and service providers. Updated and date stamped versions will be posted on the Services. Unless otherwise required under applicable law (e.g obtaining consent from you for the relevant material changes) the revised Privacy Policy Notice will take effect immediately upon such posting.
- Minors: We do not knowingly collect, maintain or use Personal Information from individuals under 18 years of age in connection with, and no part of our Websites, Social Media Pages, and Apps is directed to, individuals under the age of 18. If we do incidentally collect or maintain Personal Information from individuals under 18 years of age, you may request deletion of such information by contacting us as set forth under ‘’How Can You Contact Us?’’ below.
- International Transfers: We are an international company and we may, subject to applicable law, transfer your information, to our Affiliates or selected third parties outside the country where you are located and where information protection standards may differ (e.g. your information may be stored on servers located in other jurisdictions). We will utilize appropriate safeguards governing the transfer and usage of your Personal Information, such as an adequacy decision by the European Commission, Model Clauses or other applicable adequacy mechanisms. If you would like further detail on the safeguards we have in place you can contact us directly as set forth in "How Can You Contact Us" below.
- Retention Period: We will retain your Personal Information for the period necessary to fulfill the purposes outlined in this Privacy Policy Notice unless a longer retention period is required or permitted by law.
- Changes to your Marketing Preferences: We may contact you by email, telephone, SMS or postal mail with information about our products or services offered by Zeus International or a third party that may be of interest to you. You can opt-out from receiving future marketing communications from us at any time by:
- Using the unsubscribe function in the e-mail you receive from us; or
- If you do not wish to receive further direct marketing from us about Wyndham products or services, send an email to: privacy.policy@wyn.com
- Withdrawing Your Consent: You may withdraw any consent that you have provided to us to Process your information at any time.
- Accessing your Information: In accordance with applicable law, you may access the Personal Information we Process about you.
- Correcting your information: We will take reasonable steps to ensure the accuracy of the Personal Information we retain about you. It is your responsibility to ensure you submit true, accurate, and complete information to us, and timely update us in the event this information changes. You may request that any inaccurate or incomplete Personal Information held by us or on our behalf is corrected, by contacting us as set forth under ‘’How Can You Contact Us’’ below.
- Deleting your Information: Under certain circumstances, you may request we delete Personal Information we hold about you by contacting us as set forth under “How Can You Contact Us?’’ below. We will assess your request and determine, under applicable law, whether we are required to delete this information.
- Objecting to Processing: If you would like us to stop Processing your Personal Information, you can request this by contacting us as set forth under ‘’How Can You Contact Us?’’ below. We will assess your request and determine, under applicable law, whether we have any justification for the continued Processing.
- Transferring your Information: Under certain circumstances, you may receive your Personal Information in a format that allows you to spend it to another company or to direct us to tranfer it directly to another company.
Notice to California Residents: Your California Privacy Rights: If you are a resident of California, California Civil Code Section 1798.83 allows you to request information regarding the Personal Information we collected and third parties to whom we disclosed your Personal Information for the third parties’ direct marketing purposes during the preceding calendar year. To make such a request, please send an email to dpo@zeusintl.com or send a letter to: 22 Sylvan Way, Parsippany, New Jersey 07054, Attn: Legal Privacy.
Notice to Russian Citizens: In accordance with Russian Federal Law “On Personal Data” No. 152-FZ we collect, record, systematize, accumulate, store, update (renew and modify), and extract Personal Data about Russian citizens using databases located in the territory of the Russian Federation. If you indicate that you are a Russian citizen of the Russian Federation, we will process your Personal Data in compliance with this requirement and your profile will be maintained on databases in the Russian Federation. If you do not indicate that you are a citizen of the Russian Federation, we are not able to process and maintain your Personal Data under these requirements and will not be liable for that. You are solely responsible for indicating the country of your citizenship. Information containing Personal Data of Russian citizens may be transmitted from the Russian Federation to countries that ensure an adequate level of protection for Personal Data, including member states of the European Union and other countries which Russian law recognizes as ensuring adequate to protection, and also to other countries that may not ensure adequate level of protection for Personal Data. By submitting information to us on our sites and apps, submitting forms to us, or registering on our sites, programs and apps, or making reservations, you grant us consent to process your Personal Data.
SOCIAL MEDIA AND ONLINE REVIEWS
We may process your Personal Data through social media platforms (including Facebook, Instagram, Twitter, LinkedIn) or online reviews (including on Booking and TripAdvisor) concerning our Hospitality brands for the purposes of a) addressing your questions or complaints; b) monitoring our online reputation; and c) improving our services and identifying opportunities on which we could focus.
Please remember that any content submitted to one of our social media pages can be viewed by the public and you should be cautious about providing certain personal information via these platforms. We are not responsible for any actions taken by other individuals if you post personal information on one of our social media platforms. Please also refer to the respective privacy and cookies policies of the social media platforms that you are using.
What Rules Apply to Children
We do not knowingly collect Personal Data from anyone under the age of 18 or allow such persons to book a room in one of our hotels.
In the event that we are informed that we have collected Personal Data from a child under the age of 18 without verification of parental content, steps will be taken promptly to remove that information. If you believe that we may have information from or about a child under 18 years old, please contact us at dpo@zeusintl.com .
How Can You Contact Us?
- Contact Information: If after reviewing this Privacy Policy Notice, you have any questions, complaints or privacy concerns, or would like to make any requests in relation to your Personal Information, or obtain further information on safeguards used for international transfers please send an email to dpo@zeusintl.com or send a letter to: