BOOKING

DATA PROTECTION AND PRIVACY POLICY

We value your data and take your privacy seriously.

Orbi Hotels (“Orbi”, “we”, “us” and “our”) takes the issue of safeguarding your privacy seriously. Our Privacy Notice describes what information we collect from hotel guests, Private Residence owners, prospective Private Residence owners, renters and exchange guests (collectively referred to as "Guests and Owners") as well as visitors to the Orbi hotels website and the way in which ‘Orbi Hotels’ uses this information to better serve your needs.

What personal information do we collect?

Personal information is any information that may identify or relate to you as an identifiable individual. The personal information that we collect about you could include:

Identity information – such as name, age, gender, passport information or data from government-issued identity cards;

Contact information – such as your home address, zip/postal code, email address and phone number;

Images – such as CCTV images, publicly available photographs and images captured at events or during your stay

Financial and payment information – such as your itemized spending and transaction history;

Reservation information – such as the type and location of the rooms you reserve and the dates of your reservations;

Health information – where disclosed and relevant to the provision of services;

Preference information – such as special requests, service issues and other preferences for your stay;

Public information – such as when we review public platforms to understand what you are saying about us or the hospitality industry;

Technical information – such as information about the device you use to interact with us (including the unique device identifier, hardware model, IP address, geolocation, operating system and version, and mobile network information and unique device identifiers); and

Correspondence information – when you contact us, such as to send an enquiry or make a request, any correspondence or application may be kept and added to your personal information.

How do we use your personal information?

For each of the categories of personal information described above, we use your personal information for the following purposes:

to enable you to use our website;

to help us recognize or identify you hold with us;

to provide superior customer service to you;

to assist us in making your reservation and providing the services you request at any of our properties;

to process transactions through our website (including taking payment for purchases you may make through our website) and to assist in any inquiries about your transaction;

for billing purposes in relation to your stay with us;

to confirm prior transactions and reconcile statements or invoices;

to contact you in relation to matters that arise from your stay with us;

to send you newsletters or marketing communications regarding our properties and to advise you of promotions or to inform you of offers or other information that may be of interest to you (if, where required, you separately provide your consent for us to do so);

to personalize and enhance your online and guest experience;

to conduct surveys or focus groups to receive your views of our properties and service delivery (if, where required, you separately provide your consent to this);

to respond to a specific "Information Request" from you about one of our hotels, or residential properties and deal with any other enquiries, correspondence, concerns or complaints you have raised;

for marketing, advertising and promotional purposes, such as through one of our on-line promotions or on third party social networks, consistent with your preferences and applicable law;

to analyze customer trends and insights; and

to operate our business, including for internal purposes such as auditing, data analysis, statistical and research purposes and troubleshooting to help us improve our services.

Occasionally we will combine information from a number of Guests and Owners to better understand trends and your expectations. When this occurs, all identifiers are removed and the aggregate, anonymized information cannot be linked to any specific individual or household.

On what basis do we use your personal information?

We use your personal information on the following basis:

to comply with legal and regulatory obligations, including financial reporting requirements imposed by government regulators and our auditors;

to enter into agreements with you, and to perform our agreement to provide services to you when you stay with us;

for legitimate business purposes – using your personal information helps us to operate and improve our business and minimize any disruption to the services that we may offer to you. It also allows us to make our communications with you more relevant and personalized to you, and to make your experience of our services more efficient and effective;

because you have given your consent – at times we may ask for your consent to allow us to use your personal information for one or more purposes.

for purposes disclosed at the time you provide your personal information or as otherwise set forth in this Privacy Notice; or

for the establishment, exercise or defense of legal claims or proceedings.

How and from what sources is personal information collected?

For each of the categories of personal information and purposes described above, we gather information when you provide it to us, or interact with us directly, for example:

when you create a profile or sign in to access an existing profile on our website or App;

when you make a purchase through our website;

when you make a reservation online, by calling one of our Worldwide Reservation Offices or by contacting a particular hotel or resort directly; and

during your stay at a hotel, resort, Residence Club property or Private Residence, including information provided during check-in.

We also collect your personal information while monitoring our technology tools and services, including comment cards and email communications sent to and from Four Seasons

We may also receive information about you from other sources, such as our business partners and publicly available sources, or from other members of your traveling party or other individuals. We combine information that we have about you from various sources, including the information that you have provided to us.

Finally, we may collect your photograph from publicly available sources so that we can recognize you in order to provide you with superior customer service.

How do we protect personal information?

We use a variety of physical, technical and administrative security measures and technologies to help preserve the integrity and security of your personal information, consistent with applicable data protection and privacy laws.

We endeavor to protect the privacy of your account and other personal information that we hold in our records, but unfortunately, we cannot guarantee complete security. Unauthorized access or use, hardware or software failure, and other factors, may compromise the security of user information.  Also, while we endeavor to put adequate contractual protections in place, we cannot guarantee the security of any personal information in databases hosted by third parties.

It is important to note that any e-mail communication is not secure. This is a risk inherent in the use of e-mail. Please be aware of this when requesting information or sending forms to us by e-mail (for example, from the “Contact Us” section of our website). We recommend that you do not include any confidential information (e.g. credit card information) when using e-mail. For your protection, our e-mail responses to you will not include any sensitive personal information.

Finally, to be prudent, please be sure to always close your browsers when you are done using a form or the reservation site. Although the session will terminate after a short period of inactivity, it is best to close your browsers immediately upon completion, especially when using a public computer.

Will personal information be provided to third parties?

For each of the categories of personal information, sources of information and purposes described above, we may share certain of your personal information with:

agents, contractors or third party service providers of Orbi Hotels  who provide services to Orbi or on our behalf, including as needed to better serve your needs as a Guest or Owner;

others with your consent or at your direction;

escrow agents, third party lenders and loan-servicing agents;

a prospective buyer, investor or other third party in the event that we are involved with a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of any business or assets or similar business transaction;

our professional advisors and auditors; and

local or foreign regulators, governments, courts, law enforcement and national security authorities.

Where a third party engaged by Orbi Hotels processes personal information on our behalf, Orbi Hotels takes steps to contractually require these parties protect your personal information in a manner consistent with the principles articulated in this Privacy Notice.

If you have chosen to join a subscription list, please note that they are only used for internal purposes and we do not sell or rent our subscription lists to third parties for their direct marketing purposes.

If Orbi Hotels suspects any unlawful activity is taking place, it may investigate and/or report its findings or suspicions to the police or other relevant law enforcement agency.

We may also disclose information as may be required by law or legal process, or if we reasonably believe such disclosure is necessary to comply with legal process or the reasonable requests of law enforcement or to exercise or protect the rights, property or personal safety of the Orbi Hotels our Guests or Owners, or others.

Your rights

Depending on applicable law, which may be determined by Georgia, region or state of residency, you may be able to exercise one or more of the following rights relating to our processing of your personal information. You may also have other rights under the laws of your jurisdiction of residence.

To protect your personal information, we may require that you prove your identity to us at the time your request is made. This may involve providing us with information which we hold on file about you (e.g. a home or business address), or we may require you to produce some form of photo or government issued identification.

Accessing, correcting or deleting your personal information

We understand that you may like to know what personal information we hold about you, or to correct or delete certain information we hold about you. We are happy to assist you with your request.

Orbi Hotels reserves the right to decline a request to access, correct or delete your personal information under certain circumstances as permitted by applicable law.  In particular, there may be a variety of legitimate business reasons why we may be unable to delete your personal information and where we are permitted to decline your request to delete your information.  

Other rights

You may also be entitled to:

request the restriction of the processing of your personal information, or object to that processing; opt out from the processing or disclosure of your personal information for direct marketing purposes; withdraw your consent to the processing of your personal information (where Orbi Hotels is processing your personal information based on your consent); and request the receipt or transmission to another organization, in machine-readable form, of the personal information you have provided to Four Seasons. Where you are given the option to share personal information with Orbi Hotels, you can always choose not to do so.

If you object to the processing of your personal information, or if you have provided your consent to processing and you later choose to withdraw it, we will respect that choice in accordance with our legal obligations.

This could mean that we are unable to perform the actions necessary to achieve the purposes of processing described above (see ‘How do we use your personal information?’) or that you are unable to make use of the services offered by us.

After you have chosen to withdraw your consent, Orbi Hotels may be able to continue to process your personal information to the extent required or otherwise permitted by law.

How long is my personal information retained?

Your personal information will be stored for the period of time required or permitted by law in the jurisdiction of any hotel holding the information. This may involve retaining information following your stay. We will delete your personal information once it is no longer reasonably necessary for any of the purposes described in this Privacy Notice.

We will also keep your personal information where we need to do so in connection with a legal action or an investigation involving Orbi.

Any financial information Orbi Hotels retains will be protected under the terms of this Privacy Notice and, where financing is arranged in the Georgia, under the Financial Services Modernization Act.

Third-Party Websites

Our websites and online services may include links to third party websites, plug-ins and applications. Except where we post, link to or expressly adopt or refer to this Privacy Notice, this Privacy Notice does not apply to, and we are not responsible for, any personal information practices of third party websites and online services or the practices of other third parties. To learn about the personal information practices of third parties, please visit their respective privacy notices.

Updates to this Privacy Notice

We will update this Privacy Notice from time to time. When we make changes to this Privacy Notice, we will change the "Last Updated" date at the beginning of this Privacy Notice and will provide any other form of notice as may be required by law. All changes shall be effective from the date of publication unless otherwise provided.

Contact us

If you have any questions or concerns regarding this Privacy Notice, please contact our lawyers by writing to the following address: lawyer@orbi.ge