Privacy & Cookies Policy

CONTENTS

1. INTRODUCTION
2. GROUNDS FOR COLLECTION OF PERSONAL INFORMATION
3. THE INFORMATION WE COLLECT ON OUR WEBSITE
4. HOW WE USE YOUR INFORMATION
5. WHO WE MIGHT SHARE YOUR INFORMATION WITH
6. YOUR RIGHTS OVER YOUR PERSONAL INFORMATION
7. TRANSFER OF DATA OUTSIDE THE EEA
8. OUR POLICY TOWARD CHILDREN
9. HOW LONG WE KEEP YOUR INFORMATION FOR
10. SECURITY
11. COOKIES USED BY THIS WEBSITE
12. HOW TO CONTACT US
13. UPDATES TO THIS POLICY

INTRODUCTION

Mohari Hospitality Limited is registered in the Republic of Cyprus No. HE365047 (“We” or  “Mohari“). We are committed to protecting the privacy and security of your personal information. We take care to protect the privacy of our customers and users of our website (the “Website“), products or services (the Website, products and services shall collectively be referred to as the “Services“).

We have therefore developed this privacy policy to inform you of the personal information we collect, what we do with it, what we do to keep it secure as well as the rights and choices you have over your personal information.

GROUNDS FOR COLLECTION OF PERSONAL INFORMATION

Processing of your “personal information” (meaning any information which may potentially allow your identification with reasonable means) is necessary for the provision of our Services and the operation of our Website, the performance of our obligations towards you, to protect our legitimate interests and for compliance with legal and regulatory obligations to which we are subject.

When you use our Services, you consent to the collection, storage, use, disclosure and other uses of your personal information as described in this privacy policy.

THE INFORMATION WE COLLECT ON OUR WEBSITE

Personal Information

We only collect information in accordance with applicable laws, including the General Data Protection Regulation (GDPR). The type of information that we will collect on you, or which you voluntarily provide to us on this Website includes:

When using our Website – our webserver may automatically collect your IP address, and unique online identifiers.

When you send us an email or contact us – for example, through the contact form on our website, we will collect any information, including personal information that you choose to include in your inquiry to us. Such personal information may include your full name, your telephone number and your email address.

During provision of our Services – we may also collect your address and the name of your company. We may, in further dealings with you, extend this information to include your purchases, services used, and subscriptions, records of conversations and agreements and payment transactions .

Non-Personal Information

We also collect information about the use of our Services and the characteristics and activities of users, in order to operate it and improve it. We may collect the following non-Personal Data:

Technical information – when you use our Services we may collect such information as your operating system, device type, session start/stop time, time zone, network connection type (e.g., Wi-Fi, cellular), your general location (city and country) and general information regarding your online behavior (e.g. clicks, actions, viewed Website pages, etc.).

If we combine personal information with non-personal information, the combined information will be treated as personal information.

HOW WE USE YOUR INFORMATION

• To contact you, following your enquiry, reply to any questions, suggestions, issues or complaints you have contacted us about;
• Make available our products and services to you;
• For statistical analysis and to get feedback from you about our products, Website, mobile apps, and other services and activities. For example, occasionally we may invite you to review a product or service. If we do, it’s possible that we’ll use independent research and feedback providers to act on our behalf;
• To power our security measures and Services so you can safely access our Website and mobile apps;
• Help us understand more about you as a customer, the Services you consume, so we can serve you better;
• Help answer your questions and solve any issues you have.

WHO WE MIGHT SHARE YOUR INFORMATION WITH

We may share your personal information with other parties, in the following circumstances:

Internal concerned parties – we share your information with companies in our group, as well as our employees, in order to provide you with our services.

Providers – we share your information with business partners such as storage and analytics providers who help us provide you with our Services. These providers may have access to your personal information so that they may perform these tasks on our behalf, but they are obligated to comply with the highest security standards and applicable data protection legislation, and may not use your personal information for any other purpose. Among these are:

WordPress plugin “Contact Form 7” – The primary instance where our website will ask you for personally identifiable information is our contact form. The contact form specifically, is powered by a popular WordPress plugin called Contact Form 7. Upon completing your information, you will be asked to consent to our data processing policy which is outlined within this document. Once submitted, your information will be processed and forwarded to us within a single email sent by the website application. Your information will not be stored within the website application’s database.

Hotjar – We use Hotjar in order to better understand our users’ needs and to optimise this service and experience. Hotjar is a technology service that helps us better understand our users experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables us to build and maintain our service with user feedback. Hotjar uses cookies (listed later in this policy) and other technologies to collect data on our users’ behavior and their devices (in particular device’s IP address (captured and stored only in anonymized form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), preferred language used to display our website). Hotjar stores this information in a pseudonymized user profile. Neither Hotjar nor we will ever use this information to identify individual users or to match it with further data on an individual user. For further details, please see Hotjar’s privacy policy. You can opt-out to the creation of a user profile, Hotjar’s storing of data about your usage of our site and Hotjar’s use of tracking cookies on other websites by following this opt-out link.

HubSpot – Hubspot uses cookies (which are detailed below) and pixel tags to analyse your use of our website. This anonymous information is transferred to and stored in a HubSpot server in the USA. You can learn more about HubSpot’s privacy practices by reading their privacy policy.

Compliance with laws and law enforcement entities – we cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We will disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), to protect our or a third party’s property and rights, to protect the safety of the public or any person, or to prevent or stop any activity we may consider to be, or to pose a risk of being, illegal, unethical, inappropriate or legally actionable. We also may be required to disclose an individual’s personal Information in response to a lawful request by public authorities, including meeting national security or law enforcement requirements.

Merger and acquisitions – we may share your personal information if we enter into a business transaction such as a merger, acquisition, reorganization, bankruptcy, or sale of some or all of our assets. Any party that acquires our assets as part of such a transaction may continue to use your information in accordance with the terms of this Privacy Policy.

YOUR RIGHTS OVER YOUR PERSONAL INFORMATION

AS AN EU RESIDENT, YOU MAY REQUEST TO:

1. receive confirmation as to whether or not personal information concerning you is being processed, and access your stored personal information, together with supplementary information.
2. receive a copy of personal information you directly volunteer to us in a structured, commonly used and machine-readable format.
3. request rectification of your personal information that is in our control.
4. request erasure of your personal information.
5. object to the processing of personal information by us.
6. request to restrict processing of your personal information by us.
7. lodge a complaint with a supervisory authority.

Please note that these rights pertain to EU residents only, are not absolute, and may be subject to Mohari’s own legitimate interests and regulatory requirements.

YOUR CALIFORNIA PRIVACY RIGHTS

If you are a California resident, California Civil Code (Section 1798.83) permits users of the Services who are California residents to request and obtain from us a list of what personal information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year and the names and addresses of those third parties.  Requests may be made only once a year and are free of charge. Under Section 1798.83, California residents are entitled to request and obtain such information, by e-mailing a request to the email address provided below

USERS OUTSIDE THESE JURISDICTIONS

Some of the aforementioned rights are applicable in certain other jurisdictions as well. You are welcome to contact us for any questions or requests using the contact details below.If you would like to exercise any of these above rights, please contact us via the details listed at the very end of this policy.

TRANSFER OF DATA OUTSIDE THE EEA

If you reside in the European Union (“EU”), please note that some data recipients may be located outside the EEA. In such cases, we will transfer your personal information only to such countries as approved by the European Commission as providing adequate level of data protection, or enter into legal agreements ensuring an adequate level of data protection.

OUR POLICY TOWARD CHILDREN

We understand the importance of protecting children’s privacy, especially in an online environment. The site and services are not designed for or directed at children under the age of 18 years old (“minors”). We do not knowingly collect personal data from minors. If a parent or guardian becomes aware that his or her child has provided us with personal data, he or she should contact us using the details provided above.

HOW LONG WE KEEP YOUR INFORMATION FOR

We retain a record of your personal information in order to provide you with a high quality and consistent service. We will retain your personal information for as long as necessary to provide our Service, and as necessary to comply with our legal obligations, resolve disputes, and enforce our policies. Retention periods will be determined taking into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time. Under applicable regulations, we will keep records containing personal information, communications and anything else as required by applicable laws and regulations.

SECURITY

We have implemented administrative, technical, and physical safeguards to help prevent unauthorized access, use, or disclosure of your personal information. Your information is stored on secure servers and isn’t publicly available. We limit access of your information only to those employees or partners on a “need to know” basis, in order to enable the carrying out of the agreement between us.

While we seek to protect your information to ensure that it is kept confidential, we cannot absolutely guarantee its security. You should be aware that there is always some risk involved in transmitting information over the internet. While we strive to protect your Personal Data, we cannot ensure or warrant the security and privacy of your Personal Data or other content you transmit using the Service, and you do so at your own risk.

COOKIES USED BY THIS WEBSITE

WHAT ARE COOKIES?

Cookies are small pieces of data, stored in text files, that are stored on your computer or other device when a website is loaded within your chosen browser. They are widely used to ‘remember’ you and your preferences, either for a single visit (through a ’session cookie’) or for multiple repeat visits (using a ‘persistent cookie’). They ensure a consistent and efficient experience for visitors, and perform essential functions such as allowing users to register and remain logged in. Cookies may be set by the site that you are visiting (known as ‘first party cookies’), or by other websites who serve up content on that site (‘third party cookies’).

WHAT ARE ‘STRICTLY NECESSARY COOKIES’?

These are the cookies that are essential for this website to perform its basic functions. These include those required to allow registered users to authenticate and perform account related functions, as well as to save the contents of virtual ‘carts’ on sites that have an e-commerce functionality.

Strictly Necessary Cookies are highlighted with a double asterisk (**) in the tables below:

COOKIES SET BY WORDPRESS

Cookie Name	Description	Duration
wordpress_<hash> **	On login, wordpress uses the wordpress_[hash] cookie to store your authentication details. Its use is limited to the admin console area, /wp-admin/	2 years
wordpress_logged_in_<hash> **	After login, wordpress sets the wordpress_logged_in_<hash> cookie, which indicates when you’re logged in, and who you are, for most interface use.	Session
wp-settings-<time>-<UID> **	WordPress also sets a few wp-settings-<time>-<UID> cookies. The number on the end is your individual user ID from the users database table. This is used to customize your view of admin interface, and possibly also the main site interface.	Session
WordPress_google_apps_login **	This cookie is set by the plugin ‘Google Apps Login for WordPress’ and may be present for users who login to WordPress via their Google or GSuite account.	Session
wordpress_test_cookie	Used to check whether your web browser is set to allow, or reject cookies.	Session
wpe-auth

COOKIES SET BY GOOGLE ANALYTICS

Cookie Name	Description	Duration
_ga	Used to distinguish users.	2 years
_gid	Used to distinguish users.	24 hours
_gat	Used to throttle request rate. If Google Analytics is deployed via Google Tag Manager, this cookie will be named _dc_gtm_<property-id>.	1 minute
AMP_TOKEN	Contains a token that can be used to retrieve a Client ID from AMP Client ID service. Other possible values indicate opt-out, inflight request or an error retrieving a Client ID from AMP Client ID service.	30 seconds to 1 year
_gac_<property-id>	Contains campaign related information for the user. If you have linked your Google Analytics and AdWords accounts, AdWords website conversion tags will read this cookie unless you opt-out. Learn more.	90 days
_gaexp	Optimize 360 – Used to determine a user’s inclusion in an experiment and the expiry of experiments a user has been included in.	90 days

COOKIES SET BY CLOUDFLARE

Cookie Name	Description	Duration
__cfduid **	The __cfduid cookie is used to identify individual clients behind a shared IP address and apply security settings on a per-client basis.	1 years

MISCELLANEOUS COOKIES

Cookie Name	Description	Duration
complianceCookie	Used to distinguish your acknowledgement of our website’s Cookie Banner and subsequent policy (this document).	14 days

HOW TO CHANGE YOUR COOKIE PREFERENCES

The most popular web browsers typically provide additional tools to users for controlling or restricting cookies on their device. To find out more about cookies, including how to see what cookies have been set, you can visit www.aboutcookies.org.

Find out how to manage cookies on popular browsers:

• Google Chrome
• Microsoft Edge
• Mozilla Firefox
• Microsoft Internet Explorer
• Opera
• Apple Safari

To find information relating to other browsers, visit the browser developer’s website.

To opt out of being tracked by Google Analytics across all websites, visit http://tools.google.com/dlpage/gaoptout.

HOW TO CONTACT US

If you would like to exercise one of your rights as set out earlier in this policy, or you have a question or a complaint about this policy, the way your personal information is processed, please contact us at DPO@moharihospitality.com

UPDATES TO THIS POLICY

This Privacy Policy is subject to changes from time to time, in Mohari’s sole discretion. The most current version will always be posted on our Website (as reflected in the “Last Updated” heading). You are advised to check for updates regularly. By continuing to access or use our Services after any revisions become effective, you agree to be bound by the updated Privacy Policy.