We treat you with the utmost respect, value your trust, and fully understand the importance of protecting your privacy. Therefore, this Policy has been developed to explain our practices regarding personal information received verbally or in writing, or provided when visiting this website, our hotel, or obtained from other sources.

By using any of our products or services and/or agreeing to this Policy, you acknowledge and consent to the collection and use of personal data in accordance with the information outlined herein.

Please note that this Policy does not apply to the processing of personal information on behalf of or under the instructions of third-party companies and service providers, including travel package providers, marketing partners, or corporate clients.

11 MIRRORS DESIGN HOTEL manages all guest data using the Fidelio V8 system.

1. Personal Information Collected by 11 MIRRORS DESIGN HOTEL

11 MIRRORS DESIGN HOTEL collects personal data when interacting with guests and other contacts in the course of conducting business, as well as through the Fidelio V8 system. Such personal information may include: your first and last name, mailing address, billing address, email address, phone number, booking information, details of your stay or visits to the hotel; information regarding participation in loyalty programs; participation in contests, sweepstakes, or marketing programs (even if you do not stay at one of our hotels); details of purchased products or services; personal data such as nationality, income level, passport number, place and date of passport issuance; travel information; payment details, authentication information, and other account-related data associated with mobile accounts; room preferences; information about the amount and type of marketing communications you wish to receive; details about vehicles you may use when arriving at our hotel; reviews and opinions about our brand or hotel (if identified or associated with you); purchased service packages that include hotel reservations; groups with which you are associated during your stay at the hotel; and other types of information provided by you or obtained by us about you.

11 MIRRORS DESIGN HOTEL may request information regarding travel groups, including the names and numbers of participants. We may also collect information related to conversations, including the recording or monitoring of calls associated with customer service for quality control and training purposes, as well as other forms of communication, such as messages received through applications or SMS messages.

In addition, below are the cases in which 11 MIRRORS DESIGN HOTEL may require additional personal information:

• Surveys. During surveys, 11 MIRRORS DESIGN HOTEL may request demographic data or other personal information.

• Information Collection at the Hotel. In some cases, in accordance with local legislation, 11 MIRRORS DESIGN HOTEL may be required to request additional personal information during registration and check-in. Within the hotel complex, we may use CCTV systems and other security measures that allow us to record and store images of guests and visitors in public areas, as well as information related to your location within the hotel (through key cards and other devices). We may also use surveillance systems and other technologies that record audio or video in legally permitted cases to protect our employees, guests, and visitors. In addition, we may require extra information in order to provide certain services, such as event organization or excursion arrangements.

• Event Profiles. When planning an event, 11 MIRRORS DESIGN HOTEL records details such as the event or meeting information, date, number of guests, and room descriptions. For corporate events, we may require information about the organization, including its name, annual budget, and number of sponsored events per year. We also collect information about guests who are members of your group or participants in the event. If you visit us as part of a group, we may hold personal information provided by the group and may contact you regarding your stay or participation in the event, at your discretion and where permitted by law. If you visit us within the framework of an event, we may share your personal information with the event organizers where legally permitted. If you organize an event, we may also share information about your event with third-party service providers who may offer services related to the event, where permitted by law.

• Social Media. If you wish to participate in events and promotions conducted by 11 MIRRORS DESIGN HOTEL on social media, we may require certain information from your social media account, such as your location, hotel check-ins, participation in events, interests, photographs, status updates, and friends list. 11 MIRRORS DESIGN HOTEL may also allow you to participate in competitions involving submitted photographs, for example those taken during your stay, which may be shared on social media for voting, display, or participation in promotional campaigns.

In addition to the information received directly from you, 11 MIRRORS DESIGN HOTEL may also generate information about you based on the information you provide or other information we collect.

2. Personal Information Received from Third Parties

11 MIRRORS DESIGN HOTEL may also receive information about you from third parties, including travel operators and travel agencies, payment card service providers, social media platforms in accordance with your privacy settings, and other external sources that may legally provide us with information about you.

11 MIRRORS DESIGN HOTEL may use and share this information (as well as combine it with other information we already hold about you) for the purposes described in this Policy.

3. Use of Personal Information Provided by You

11 MIRRORS DESIGN HOTEL uses your personal data in various ways, including to provide and personalize the services you request and expect from us, to offer the highest level of service during your stay, to manage loyalty programs, and to carry out direct marketing and sales activities as described below. Before processing your data, we will obtain your consent where required by applicable law.

11 MIRRORS DESIGN HOTEL must collect certain information, including your name, address, payment details, and, in some countries, travel document information, in order to process your booking. If you refuse to provide the required information, we may be unable to complete your reservation.

• Administrative Service Management. 11 MIRRORS DESIGN HOTEL uses your personal information to administer programs in which you participate, including providing you with access to information such as bonus balances and offers for which you are eligible, fulfilling services related to such programs, and simplifying data collection processes.

• Business Meetings and Events. 11 MIRRORS DESIGN HOTEL may use personal data to provide you with information about planned meetings and events.

• Marketing and Communications. Where permitted, 11 MIRRORS DESIGN HOTEL may use your personal information to provide or offer subscriptions to newsletters, promotions, special offers, and other marketing communications according to your preferred communication methods. We use your information to send stay-related messages, account notifications, booking confirmations, marketing communications, surveys, sweepstakes, prize draws, and competitions. These communications may be delivered via email, post, internet advertising, social media, telephone, text messages (including SMS and MMS), push notifications, in-app messages, or other methods (including hotel-based messaging systems such as in-room television systems). With your consent, we may also use your social media content (such as photographs) for media advertising, on our website, and in applications. We may collect payment card information, which may be combined with your personal information and used by us or our business partners to identify the type of card you use. We may also work with third-party companies to determine whether a visitor to our website has used a cashback offer related to their payment card and provide advertising and information explaining how to use this offer during their stay.

• Service Improvement. 11 MIRRORS DESIGN HOTEL may use your personal information to improve services and ensure that our website, products, and services are relevant and valuable to you.

We also use your personal information to provide the level of service you expect both in your room and throughout the hotel.

• Data Accuracy, Analytics, and Personalization. 11 MIRRORS DESIGN HOTEL may combine your personal information with data from third-party sources for data organization and analytics. We also use information from external sources to deliver a higher level of personalized service. For example, if you connect social media services or other accounts to our services, we may use this information to provide a warmer welcome, a more personalized experience, or share it with third parties in accordance with this Policy.

4. Personal Information Shared with Third Parties

To provide the highest level of service expected by our guests, 11 MIRRORS DESIGN HOTEL may share your personal information with service providers, business partners, and other third parties as explained below:

• Group Events or Meetings. If you stay at the hotel as part of a group event or meeting, information collected for event planning may be shared with the organizers and, where necessary, with guests involved in organizing or participating in the event.

• Business Partners. 11 MIRRORS DESIGN HOTEL may cooperate with other companies to provide you with products, services, or offers related to your stay and may share your information with business partners accordingly. For example, we may arrange additional services with partners, which requires us to provide them with your personal information. We may also share your email address with travel partners to help them evaluate compliance with travel policies, use of special rates, or participation in joint marketing activities. In addition, we may cooperate with travel operators, travel agencies, and payment card providers to deliver advertising to mutual customers. Our partners may provide you with relevant offers based on information about your stay. We may also allow third-party partners to recognize you when visiting websites or using applications in order to present more relevant offers. We may securely share your hashed email address with third-party companies so they can match it with their own hashed email databases and deliver advertising on our behalf online and by email.

• Promotional Partners. 11 MIRRORS DESIGN HOTEL may cooperate with other companies in promotional campaigns, prize draws, lotteries, competitions, or contests and may provide prizes for such events. If you participate, we may share your information with event partners or sponsors.

• Hotel Services. 11 MIRRORS DESIGN HOTEL may provide personal information to third-party suppliers offering services on hotel premises, including conference services, catering, and related services.

• Service Providers. 11 MIRRORS DESIGN HOTEL engages third-party companies to provide products and services on our behalf and may share your personal information where appropriate. Generally, these providers are contractually required to protect your information and may not otherwise use or disclose it except as legally required. Fraud prevention providers may use, but not disclose, your personal data to detect fraud. We may also engage service providers to deliver news, advertising, and promotional materials on our behalf, including personalized online and mobile advertising according to your preferences and applicable law. We only cooperate with companies that allow you to opt out of such advertising. We may also share information with service providers to help you create itineraries, choose venues, activities, or restaurants based on your preferences and third-party data.

• Business Transactions. As our business develops, 11 MIRRORS DESIGN HOTEL may sell or acquire businesses or assets, or cease management of certain hotel properties within our brand portfolio. In such cases, we may transfer, sell, or assign collected information, including General Information and personal data, to one or more affiliated or independent third parties as part of these transactions. Where required by local law, we will notify you of such transfers and explain how you may opt out.

• Additional Disclosures. 11 MIRRORS DESIGN HOTEL may also disclose personal information:
(i) where required by law;
(ii) in response to requests from government authorities;
(iii) in connection with legal proceedings;
(iv) to protect the rights, privacy, safety, or property of 11 MIRRORS DESIGN HOTEL, website visitors, guests, employees, or the public;
(v) to protect our legal rights or limit potential damages;
(vi) to enforce website terms and conditions;
(vii) in emergency situations.

5. General Information

When you visit and use our websites and applications, 11 MIRRORS DESIGN HOTEL collects other information that does not personally identify you, such as the pages you visit and the number of visits to our websites (“General Information”). 11 MIRRORS DESIGN HOTEL uses General Information, as well as data received from third parties, to deliver advertising to you by email, online and through mobile applications.

11 MIRRORS DESIGN HOTEL uses cookies and other technologies, such as web beacons, clear GIFs, email links, JavaScript, device identifiers assigned by Google or Apple, and similar technologies to collect such information. You may delete or block cookies at any time by changing your browser settings.

6. Sensitive Information

“Sensitive information” means information related to your race or nationality, political views, religious or philosophical beliefs, trade union membership, health, sexual life or orientation, genetics, criminal history, and biometric data used for identification.

11 MIRRORS DESIGN HOTEL generally does not collect sensitive information unless you provide it voluntarily or unless required by applicable law.

7. Personal Information from Children

11 MIRRORS DESIGN HOTEL does not knowingly collect personal information from individuals under the age of 18. If you are a parent or guardian, please do not allow your children to provide personal information without your permission.

8. Links to Third-Party Websites and Services

Our website may contain links to third-party websites. Please note that 11 MIRRORS DESIGN HOTEL is not responsible for the collection, use, management, sharing, or disclosure of data by such third parties.

Your use of hotel internet access may also be subject to the terms of use and privacy policy of the third-party internet provider.

9. Protection of Personal Information

11 MIRRORS DESIGN HOTEL takes reasonable measures to protect personal information from unauthorized access, disclosure, alteration, or destruction, and to keep information accurate and up to date where appropriate.

In the event of a security incident, we will notify supervisory authorities and/or customers in accordance with applicable laws and regulations.

To protect your confidential data, please do not send payment card numbers or other sensitive personal information by email.

10. Changing and Accessing Personal Information

Where required by applicable law, 11 MIRRORS DESIGN HOTEL may provide you with information about the data we hold about you. You may also withdraw your consent to certain types of data processing and/or request that your personal data be changed, corrected, deleted, or that its processing be suspended.

Requests may be sent by email to info@11mirrors-hotel.com or to the 11 MIRRORS DESIGN HOTEL employee responsible for data protection via Viber / WhatsApp / Telegram: +38 044 581 11 11.

11. Retention of Personal Information

11 MIRRORS DESIGN HOTEL stores your personal information for the period defined by this Policy, unless a longer retention period is required or permitted by applicable law.

We retain personal data collected for the purposes described in this Policy for three years after the end of your stay. Other personal data may be stored for a shorter period.

12. Marketing Communications Choices

If you have provided us with your contact information, 11 MIRRORS DESIGN HOTEL may inform you about our products and services or invite you to events by email, online advertising, social media, WhatsApp, Viber, Telegram, phone, text messages, push notifications, internal messages, mail, customer support, and other means.

You may unsubscribe from electronic marketing materials at any time using the unsubscribe function in the email received from us. Processing an unsubscribe request may take up to ten business days.

13. Changes to This Policy

This Policy may be updated from time to time. If significant changes are made, a link to the updated version will appear on the homepage of our website, and registered users may receive a notification through their selected communication method.

Any changes take effect from the date the updated version is published on the website.

14. Contact Us

If you have any questions about this Policy or about how 11 MIRRORS DESIGN HOTEL uses your personal data, or if you wish to send feedback or a complaint, please contact us by email at info@11mirrors-hotel.com or via Viber / WhatsApp / Telegram: +38 044 581 11 11.

We will respond as soon as possible.

15. Changes to the 11 MIRRORS DESIGN HOTEL Privacy Policy

This Policy has been updated to provide more detailed information about how 11 MIRRORS DESIGN HOTEL collects, uses, shares, and protects the personal data of our guests.

Appendix 1 has been added: “Additional Provisions Applicable to the Processing of Personal Data of EEA Residents.” Appendix 1 provides detailed information in accordance with Regulation (EU) 2016/679, commonly known as the General Data Protection Regulation (GDPR).