We do not knowingly collect or solicit personal information from anyone under the age of 20 or knowingly allow such persons to register for the Services (as that term is defined in our Terms and conditions of Use). If you are under20, please do not attempt to register for the Services or send any information about yourself to us, including your name, address, telephone number, or email address. No one under age 20 may provide any personal information to us or on the Services. If we learn that we have collected personal information from a child under age 20 without verification of parental consent, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 20, please contact us at firstname.lastname@example.org
WHAT INFORMATION DOES ANELLO COLLECT AND PURPOSE?
Information You Provide to Us:
Personal information or Personal Data means and refer to information relate to you direct or indirect, ever record on the document or not which clearly or able to Identify. We receive and store any Personal Data information you knowingly provide to us and all personally identifiable information collected and recorded about an individual. We may collect the following Personal Data:
- Personal info: name, gender, nationality, date of birth, and names of your family members, their date of birth, nationality, etc.
- Contact information: address, telephone number, e-mail, address, etc.
- Payment information: credit card details, billing address, and other payment and billing information.
- Loyalty and referral program: details and partner program affiliation, marketing and analytical data.
- Accommodation information: dates of arrival and departure from our hotels, the location of the room, smoking/ non-smoking room, type of room and bed requests, preferred newspaper, etc.
- Feedback: records of your contact with us such as via the phone number, or if you get in touch with us online using our online services, details such as your mobile phone location data, IP address and MAC address, including history of any communications with us, and analysis of your interaction with us, which helps us to customize offers to you and provide information that we think are of interest or relevance to you.
- Technical information: IP address, geographic data, browser and computer system, application version, language settings and pages that have been shown to you, etc.
- Professional information: if you are applying for a position at Minor Group, in addition to the above mentioned information we may collect your education, training and employment records.
We do not request any sensitive information such as religious or philosophical beliefs, political opinions, information on health, racial origin or ethnicity, sexual orientation or union membership.
We also limit the information collected in relation to children under 20 years to their name, nationality, and date of birth, which can only be supplied to us by an adult. We kindly request that parent ensure that children do not send us any Personal Data without parental consent, and if such information was sent, please get in touch with us and we will delete such information.
Automatic Collection of Personal Data:
When we collect usage information, we only use such data in aggregate form, in a manner that assures your anonymity. We may provide this aggregate usage information to our partners; our partners may use such information to understand how often and in what ways people use our Website, so that our partners, too, can endeavor to provide you with an optimal online experience.
Collection of Personal Data
Personal Data may be requested or generated in different circumstances, including (but not limited to) the following:
- Marketing and communication activities: newsletters subscription, loyalty program registration, and participation in promotional offers, surveys, competitions, social media and SMS marketing campaigns.
- Reservations and purchasing activities: Products Purchase, check-in, and check-out, payment, submission of complaints or requests.
- Provided by third parties: information collected through marketing partners, Products Partners, tour operators, online systems, and other third parties, which may include information provided by your agent, airline, credit card, and other service providers.
- Internet activities: connection to any Minor Group site, online activities, questionnaires, and social media platforms etc.
- Job or internship applications.
E-mail and Other Communications:
We may contact you, by email or other means. If you do not want to receive email or other mail from us, please indicate your preference by changing your account accordingly.
Propose of Information Collected:
We use or share your Personal Data for the following purposes:
- Performing our customer service obligations: management of purchase, facilitate your use of the Services or access to the Platform including responding to your queries, feedback, claims or disputes through our outsourced customer service agents, process orders you submit through the Platform, Payments that you make through the Platform for products, deliver the products you have purchased through the Platform, update you on the delivery of the products, compare information, and verify to ensure that the information is accurate, verify and carry out financial transactions in relation to payments you make online, audit the downloading of data from the Platform, administer your account (if any), improve the layout or content of the pages of the Platform and customize them for users, identify visitors on the Platform, Carry out research on our users’ demographics and behavior, provide you with information including information of products and services, provide marketing or promotional materials about products and services from time to time and any of these purposes of Anello’s discretion.
- Improvement of our services: assessment of our services in retails, lifestyles, and other outlets, improvement the operation of our business, and development of new products and services.
- Personalization of our services and communications: personalize content and tailor our digital customer experience and offerings, understand customers’ requirements to develop targeted marketing programs, newsletters, and promotions.
- Recruitment: recruitment of staff or interns for Minor Group.
- Compliance purposes: fulfill our statutory and fiscal compliance obligations.
If you do not provide certain information to us, we will be unable to provide you with our products or services. In cases where providing some personal information is optional, we’ll make this clear.
WILL ANELLO SHARE ANY OF THE PERSONAL INFORMATION IT RECEIVES?
We neither rent nor sell your Personal Information in personally identifiable form to anyone. We share your Personal Information in personally identifiable form with third parties only as described below:
- Affiliated Businesses and Third Party Websites We Do Not Control:
In certain situations, businesses or third party websites we’re affiliated with may sell items or provide services to you through the Website (either alone or jointly with us). You can recognize when an affiliated business is associated with such a transaction or service, and we will share your Personal Information with that affiliated business only to the extent that we deem it related to such transaction or service. One such service may include the ability for you to automatically transmit information from your ANELLO account to an account on a third party website or service, such as Facebook. We have no control over the policies and practices of third party websites or businesses as to privacy or anything else, so if you choose to take part in any transaction or service relating to an affiliated website or business, please review all such business’s or websites’ policies.
We employ other companies and people to perform tasks on our behalf and need to share your information with them to provide products or services to you. Unless we inform you otherwise, our agents do not have any right to use the Personal Information we share with them beyond what we deem necessary to assist us in performing such tasks.
- Business Transfers:
We may choose to buy or sell assets. In these types of transactions, customer information (which may include your Personal Information) is typically one of the business assets that is transferred. Also, if we are acquired, or if we go out of business or enter bankruptcy, Personal Information would be one of the assets transferred to or acquired by a third party.
4. Disclosure of Personal Data
We may share Personal Data with the following third parties for the purposes listed above:
- Minor Group’ (including its subsidiaries and affiliated companies) employees: to offer you the best service, we can share your personal data and give access to appropriate person within Minor Group entities for certain specific categories of personal data, including but not limited to staff, outsource staff, IT departments, commercial partners and marketing services, etc.
- Business partners and external service providers: including IT services, marketing services, call centers, banks and credit card issuers, legal services, consultants, and social networking sites.
- Local authorities: should it be required by local legislation or as part of internal Minor Group investigations, in accordance with legal requirements.
We also reserves the right to transmit any personal data in the event of sale or transmission of part or all of the company or respective assets. In any case of transmission of personal data to third parties, we will comply with our legal obligations under the applicable laws.
- Protection of ANELLO and Others:
We may release Personal Information when we believe in good faith that release is necessary to comply with laws; enforce or apply our conditions of use and/or other agreements; or protect the rights, property, or safety of ANELLO, our employees, our users, or others. We may exchange information with other companies and organizations (including governmental authorities) for fraud protection and credit risk reduction.
- With Your Consent:
We will define retention period of your Personal Data based on the following criteria:
- Reasonable business needs: for as long as we provide goods and services to you, or managing our relationship with you, managing our operations; and/or
- Reasonable statutory periods: for as long as someone could bring a claim against us or for as long we need to comply with our fiscal and legal obligations; and/or
- Other retention periods in line with legal and regulatory guidance and requirements.
IS PERSONAL INFORMATION ABOUT ME SECURE?
Your account is protected by a password for your privacy and security. If you access your account via Facebook Connect, you may have additional or different sign-on protections through Facebook. You need to prevent unauthorized access to your account and Personal Information by selecting and protecting your password (or other sign-on protections) appropriately and limiting access to your computer or device by signing off after you have finished accessing your account.
We attempt to protect the privacy of your account and other Personal Information we hold in our records, but we cannot guarantee complete security. Unauthorized entry or use, hardware or software failure, and other factors may compromise the security of user information at any time.
WHAT PERSONAL INFORMATION CAN I ACCESS?
Through your account settings, you may access, and, in some cases, edit or delete the following information you’ve provided to us:
- name and password
- email address
- shipping and billing information
- user profile information and User Content.
The information you can view and update may change as the Website changes. If you have any questions about viewing or updating information we have on file about you, please contact us at email@example.com.
WHAT CHOICES DO I HAVE?
You can always elect not to disclose information to us. However, please keep in mind that we may need some information to allow you register with us or to take advantage of some or all of our features, and if you choose not to provide that information, your ability to use our Website and services may be limited.
You may be able to add, update, or delete information. When you update information, however, we may maintain a copy of the unrevised information in our records. You may request deletion of your account by visiting your account settings. Please note that some information may remain in our private records after your deletion of such information from your account. We may use any aggregated data derived from or incorporating your Personal Information even if you update or delete it, but we will not use that information in a manner that would identify you personally.
Personal Data Processing
We rely on the following legal bases to process your personal data:
- Contractual necessity: all stages and activities relevant to managing services rendered to you, including inquiry, application, administration and management of accounts, reservations, requests, and complaints.
- Our legitimate interests: performance of contracts and support of our business units, affiliates, subsidiaries, member product owners, partners, suppliers etc.
- Compliance with legal obligations: compliance with applicable laws, prevention of fraud or money laundering, or defense against legal claims, including those in the area of labor law, social security, and data protection, tax, and other, as the case may be.
- Consent, as permitted by applicable law.
QUESTIONS OR CONCERNS
If you have any questions or concerns regarding our privacy policies or cancel your consent or any, please send us a detailed message to firstname.lastname@example.org. We will make every effort to resolve your concerns.