Privacy Policy

Introduction
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Welcome to Hotel Management Company's ("HMC", "we", "us" or "our") privacy policy (the "Privacy Policy"). This Privacy Policy should be read together with our Website Terms and Conditions and any other documents referred to in it. Under the Website Terms and Conditions, you permitted us to process your personal data as stated in this Privacy Policy.

HMC respects and is committed to protecting the privacy of every individual who visits our website, www.adeera.com (the "Website"). This Privacy Policy sets out how we protect and use information that we collect through your use of the Website, including any data you may provide when you access the Website, register with us, contact us, send us your feedback, sign up to our newsletter or complete our customer surveys.

This Privacy Policy is designed to describe:

Who we are and how to contact us?
What information do we collect about you?
How is your personal data collected?
How we use your personal data and why?
When would we disclose your information?
How long will you use my personal data for?
Your rights and control of your information.
Changes to this Privacy Policy and your duty to inform us of changes.

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Please read this Privacy Policy carefully. By continuing to use our Website and by submitting personal data to us, you are agreeing to the terms of this Privacy Policy.
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1. Who we are and how to contact us?
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For the purposes of the GDPR and the Personal Data Protection Law and its Regulations issued by Royal Decree No. (M/19) dated 9/2/1443H and amended by Royal Decree No. (M/148) dated 5/9/1444 AH (the "PDPL") and, European data protection laws, including Reg. (EU) 2016/679 on the protection of natural persons with regard to the processing of personal data (“GDPR”), the data controller is Hotel Management Company and which is a company registered in the Kingdom of Saudi Arabia, under commercial registration number 1010661169, and having its office at Amrou Ibn Ummaiyah Al Shamri Street, Assafarat Dist. Riyadh 12512, Kingdom of Saudi Arabia.

The Hotel Management Company has been set up to run hotel operations in the Kingdom of Saudi Arabia and may collect personal data of customers, suppliers and employees, as further detailed in this Privacy Policy.

If you would like to contact us about this Privacy Policy or our privacy practices, please contact us at dataprivacy@adeera.com.

We would welcome addressing any concerns you may have about our handling of your personal data; however, under the PDPL you have the right to make a complaint within a period of ninety (90) days from the date you became aware of the incident to the Saudi Data and AI Authority (SDAIA) or any competent authority. If your complaint is made under the GDPR, you may file a complaint at any time reaching out the competent European data protection authority (typically, the authority of the Member State where you reside). You can find the list of European data protection authorities here (https://commission.europa.eu/law/law-topic/data-protection/reform/what-are-data-protection-authorities-dpas_en)
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2. What information do we collect about you?
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Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed and it can no longer be associated with a natural person (anonymous data). When you use the Website, we may collect and process the following information:

Identity Data includes first name, maiden name, last name, username or similar identifier and title.
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Contact Data includes postal address, email address, telephone numbers, messaging identifiers and social media handles.
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Financial Data includes bank account and payment card details.
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Transaction Data includes details about payments to and from you and other details of services you have purchased from us.
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Marketing and Communications Data includes your preferences in receiving marketing from us, our affiliated companies and our third parties and your communication preferences.
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Technical Data includes mobile device ID, internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our Website.
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Profile Data includes your username and password, your interests, preferences, feedback and survey responses.
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Usage Data includes information about how you use our Website, services, including survey responses.
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Employment/Qualifications Data includes employment history, nationality, date of birth, and other relevant information to enable us to conduct background checks, if applying for a job.

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We also collect, use and share Aggregated Data such as statistical or demographic data for specific purposes. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity and can no longer be associated with you. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.

We may collect Sensitive Categories of Personal Data about you (this may include for example details about your race or ethnicity, religious or philosophical beliefs, political opinions, information about your health, genetic and biometric data (such as the results of psychometric tests), and criminal convictions and offences. We will obtain your explicit consent before processing any Sensitive Categories of Personal Data about you.
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3. How is your personal data collected?
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We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity Data, Contact Data and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
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- make a booking for our services;
- create an account on our Website;
- request marketing to be sent to you;
- signup to our newsletter;
- follow any of our official social media accounts
- enter a competition, promotion or survey; or
- give us feedback or contact us.
- apply for a job with us‍
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Automated technologies or interactions. As you interact with our Website, we will automatically collect Technical Data about your equipment, devices and browsing actions. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy further details.‍
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Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources, which may be updated from time to time. The current list is as set out below:
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- analytics providers such as Google;
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When processing personal data from publicly available sources, we ensure that the collection is conducted in full compliance with legal requirements and aligns with the specified purposes under the law.
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4. How we use your personal data and why?
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We may use information about you in the following ways:

To improve our services and Website, and ensure that content from our Website is presented in the most effective manner;
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To provide you with information or services that you request from us, and which we feel may interest you where you have asked or consented to be contacted for such purposes;
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To carry out our obligations arising from any contracts entered into between us;
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To notify you about changes to our services;
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For our own market research purposes (for example to invite you to provide us with feedback on our services);
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To administer our Website and for internal operations including trouble-shooting, security purposes, data analysis, testing and statistical survey purposes.

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What is our legal basis for processing your Personal Data?
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We will only use your personal data when the law allows us to. In respect of each of the purposes for which we use your personal data, the applicable law requires us to ensure that we have a "legal basis" for that use. Most commonly, we will use your personal data in the following circumstances:

Where we need to perform a contract we are about to enter into or have entered into with you ("Contractual Necessity");
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Where it is necessary for our legitimate interests, and your interests and fundamental rights do not override those interests ("Legitimate Interests"). More detail about the specific legitimate interests pursued in respect of each purpose we use your personal data for is set out in the table below;
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Where we need to comply with a legal or regulatory obligation ("Compliance with Law"); and
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Where we have your specific consent to carry out the processing for the purpose in question ("Consent") in accordance with the applicable law and regulations.

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Purposes for which we will use your personal data
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We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your personal data. Please contact us if you need details about the specific legal basis we are relying on to process your personal data where more than one basis has been set out in the table below.
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Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register you as a new customer	Identity Contact	Contractual Necessity
To process your booking, order and subscriptions including managing payments, fees and charges and to deliver services to you (e.g. during your stay or meal)	Identity Contact Financial Transaction Profile	Contractual Necessity
To manage our relationship with you which will include: Notifying you about changes to our terms or privacy policy, Asking you to leave a review or take a survey	Identity Contact Profile Marketing and Communications	Compliance with the law Your explicit consent Legitimate Interests (to keep our records updated and to study how customers use our services)
To administer and protect our business and this Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	Identity Contact Technical	Legitimate Interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) Compliance with the law
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	Identity Contact Profile Usage Marketing and Communications Technical	Legitimate Interests (to study how customers use our services, to develop them, to grow our business and to inform our marketing strategy) Your explicit consent. To the extent the processing implies the use of cookies or other tracking tools, please see our cookie policy at [INSERT AS LINK TO WEBSITE'S COOKIE POLICY] for further details
To use data analytics to improve our Website, services, marketing, customer relationships and experiences	Technical Usage	Legitimate Interests (to define types of customers for our services, to keep our Website updated and relevant, to develop our business and to inform our marketing strategy) Your explicit consent
To make suggestions and recommendations to you about services that may be of interest to you	Identity Contact Technical Usage Profile Marketing and Communications	Legitimate Interests (to develop our services and grow our business) Your explicit consent
To review information during a job application	Identity Contact Profile Employment/Qualifications Data	Contractual Necessity Legitimate Interests (to employ appropriate candidates into our business)

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What happens if you fail to provide us with the necessary personal data?
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Where we need to collect your personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you our services). In this case, we may have to cancel an order or booking you have with us but we will notify you if this is the case at the time. If the processing relies on your consent, declining to provide it will not result in any consequences, except that we will be unable to perform the activity that relies on your consent. If the processing is based on our legitimate interest and you exercise your right to object, we will conduct a balancing test to re-evaluate the interests involved and the potential impact and consequences of not proceeding with the processing activity. In any case, if revoke your consent and/or object to the processing for marketing or profiling, we will promptly cease these processing activities.

Marketing
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We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased services from us and you have given us consent for such marketing.

Cookies
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You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this Website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy .

Change of purpose

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We will only use your personal data for the purposes for which we collected it, unless we reasonably consider through a specific assessment that we need to process it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact at dataprivacy@adeera.com . In any case, we will notify you as required by the applicable law, and we will explain the legal basis which allows us to do so.

Automated decision-making, including profiling
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Your personal data will not be processed and you will not be subject to a decision based solely on automated processing, including profiling, which may produce legal effects and/or similarly significantly affect you.

Security and the processing of your personal information
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We understand that security is an important concern for you when online. Information you give us will be stored securely on our systems and we use sophisticated technology to help make sure that all your personal details remain confidential.

Our security technologies and procedures are regularly reviewed to confirm that they are up to date and effective. For further verification, look for the padlock symbol in your browser window as you proceed through the order and payment process.

Unfortunately, the transmission of information via the internet is not completely secure and we cannot guarantee the security of any information transmitted to or from our Website. Any transmission is at your own risk and you should ensure that any payment transactions you make are made in a secure environment. You should keep confidential any personal security codes and passwords, and comply with any instructions that we may give you in order to keep such details confidential and safe.
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5. When would we disclose your information?‍
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We may share your personal data with the following parties for the purposes set out in the table under section 4 above:

Other companies in our group.

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Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Policy or, depending on the circumstances, you will be provided with all the relevant information.

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External third parties which may include the below:
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- Service providers providing identity verification and anti-money laundering check services.
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- Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
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- Regulators and other authorities who require reporting of processing activities in certain circumstances.
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- Third Party providers assisting us in running our business, including our payment and delivery service providers (such as OTAs), recruitment platform, software solutions used in the hospitality and travel industry, marketing agencies and website hosting providers.
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The above parties may process your personal data as autonomous data controller or on our behalf for specified purposes and in accordance with our instructions. In any case, we require all third parties to respect the security of your personal data and to process it in accordance with the law.

Third-party links
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This Website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Website, we encourage you to read the Privacy Policy of every website you visit.

International transfers
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Whenever we transfer your personal data to a recipient located in third countries, we will ensure an equivalent degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data. For further information, please contact us at dataprivacy@adeera.com; or
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We will take measures to comply with applicable data protection laws related to such transfers and use appropriate transfer solutions for any data transfers. Please contact us at dataprivacy@adeera.com if you want further information on the specific transfer mechanisms used by us when transferring your personal data abroad.
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6. How long will you use my personal data for?
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We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. Subject to applicable law, we shall retain your personal data for up to 5 years following your last transaction with us. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a reasonable prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

In some circumstances, you can ask us to delete your data. Please see your legal rights below for further information.

In some circumstances, we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
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7. Your rights and control of your information
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You have the right to, at any time:

Be informed. You are entitled to know the methods by which we collect your data, the legal basis for collecting it and processing it, how it will be processed, stored and destroyed, and with whom it will be shared. This is as set out in this Privacy Policy.
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Request access to your personal data (commonly known as a data subject access request). This enables you to receive both further information on the processing activities ongoing, and a copy of the personal data we hold about you and to check that we are lawfully processing it.
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Obtain portability of your data. Under certain circumstances, this enables you to receive your personal data provided to us, in a structured, commonly used and machine-readable format, and obtain the transmission of such data to another controller without hindrance from us.
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Request correction of the personal data that we process about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, completed or updated though we may need to verify the accuracy of the new data you provide to us.‍
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Request restriction or destruction of your personal data (commonly known as the right to be forgotten). This enables you to ask us to limit our processing activities (i.e., with the exception of storage, your data will only be processed with your consent, for the establishment, exercise or defence of legal claims, or for the protection of the rights of another natural or legal person), or to delete personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
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Object to the processing based on our legitimate interest, or withdraw consent where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out prior to your objection to the processing or withdraw your consent. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms. If you object to the processing or withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you object to the processing or withdraw your consent.
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If you wish to exercise any of the rights set out above, please contact us at dataprivacy@adeera.com.

You have also the right to file a complaint. Please see Section 8 below for further information.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances. We would timely inform you if this is the case.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within 30 days. Occasionally it could take us longer than 30 days (and up to two further months) if your request is particularly complex or you have made a number of requests. In this case, we will notify you within the first 30 days of the receipt and keep you updated.

8. Complaints and Inquiries
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If you have any concerns, or if we do not comply with the PDPL, you can file a complaint to Adeera Data Privacy using dataprivacy@adeera.com. If you are not satisfied with how we process your complaint, or if we fail to respond within 30 days, you can file a complaint with the Saudi Data & AI Authority (sdaia.gov.sa).

If the GDPR applies to your specific situation, you can always file a complaint at any time for any alleged violation of the GDPR before the competent European data protection authority (typically, the authority of the Member State where you reside). You can find the list of European data protection authorities here (https://commission.europa.eu/law/law-topic/data-protection/reform/what-are-data-protection-authorities-dpas_en)
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9. Changes to this Privacy Policy and your duty to inform us of changes
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We may occasionally update this Privacy Policy. We encourage you to periodically review this Privacy Policy to stay informed about how we are using and protecting information that we collect. Depending on the circumstances, will notify you of any significant change; however, by continuing to use our Website you are agreeing to any updates that we may make. This Privacy Policy was last updated on [October 3, 2024].

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

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