UAB VILLON and UAB GOLF AND SPA RESORT
both trading asVILNIUS GRAND RESORT
(hereinafter referred to as the Company)
Personal data includes any information based on which Your identity may be or is determined: surname, name, telephone number, e-mail address or postal address, information on the provision of services to You (date, service, price, quantity, amount, discount) and other information (hereinafter referred to as Personal Data).
How the Company processes Your data
Title, name, surname, place of residence (only when registering at the hotel), e-mail address, telephone number, age (year of birth only upon registration at the Your system), which You have submitted to the Company to use the Company’s services, by filling in the hotel registration form the registration form at the SPA center registration form, green card registration form, golf club membership agreement, Your registration form, loyalty card receipt form, newsletter receipt form, applicable forms of owners and or renters of the Villas, Townhouses and Apartments (situated within the resort) as well as other personal data to the Company on legitimate grounds. Your personal data may be submitted to the Company by the organizer of Your accommodation if You book the hotel accommodation service not by Yourself, but through another company, institution, or organization.
The Company processes Your image, which is recorded upon Your arrival at Vilnius Grand Resort complex, using video monitoring in the public areas of Vilnius Grand Resort with video surveillance cameras. The Company also processes the personal data of Yours (name, surname, telephone number, e-mail address), which You provide to receive newsletters of Vilnius Grand Resort by e-mail or to use the Company’s loyalty card.
Mandatory reporting and the consequences of non – submission
You must provide complete and correct personal information. This is necessary if the aim is to conclude or fulfill a contract already concluded with You (for the provision of accommodation services, golf club services, spa services, property services). If You do not provide personal data for the above-mentioned purposes, the Company will not be able to properly perform the agreement concluded with You.
Purposes and legal basis of data processing
Personal data is processed in the Company for the following purposes:
• To identify You when concluding service contracts with the Company
• to provide You with accommodation services, services provided by the golf club, the spa center, and to contact You for the service (regarding the adjustment of the time of reservation of services, etc.)
• to solve problems related to the provision of services to fulfill contractual obligations and other purposes related to the performance of contracts
• for identification purposes when You use a loyalty card
• to contact You about items left behind
• for direct marketing (offering goods and services to individuals and/or seeking their opinion on the goods and services offered)
• to inform You about the Company’s planned celebrations, events, and promotions, service offers, other news
• to ensure the security of the Company’s employees, other guests, and the security of the Company’s property (video data from surveillance cameras, sound recording data at the hotel reception)
• to make, enforce and defend legal claims
• to comply with statutory obligations (i.e. tax obligations) in order to issue financial documents
• for other legitimate purposes related to the above.
The basics of personal data processing are:
• Your consent to the use of personal data or when it can be concluded that You have consented to their use for a specific purpose • a contract concluded or executed when You are one of the parties (hotel, spa complex, and golf club registration forms filled in and signed by You are contractual documents)
• personal data must be processed for a legitimate interest pursued by the Company or a third party to whom the personal data are disclosed and if Your interests or fundamental rights and freedoms necessitating the protection of personal data do not prevail (i.e. video surveillance justified by the legitimate interest of the Company to ensure the safety of employees, guests of the complex, the safety of the Company’s property)
• the processing of personal data is necessary to fulfill the legal obligation applicable to the Company (i.e. The obligation to archive documents established by law, the obligation to preserve financial documents for tax purposes, the obligation to provide data to public authorities, etc.)
. Use of personal data for direct marketing purposes; the Company also processes Your data for direct marketing purposes
• sending newsletters to the e-mail address You specified with Company’s news about ongoing events, promotions, and latest offers/advertising of goods/services, asking customers’ opinions on the offered goods and services
• providing You with discount offers if You are registered to participate in the Company’s loyalty program. Your personal data will be stored and used for direct marketing purposes only if You have submitted Your data on the Company’s website and agreed to receive the Company’s newsletters and special offers by e-mail or by post
• In the registration forms You have indicated that You agree to receive the Company’s newsletters and special offers by Your e-mail or by post.
• You have indicated in the registration forms that You agree that the Company will contact You for the purposes of direct marketing via the specified telephone number
• In the loyalty program registration form, You have indicated that You agree to receive the Company’s loyalty program news, the Company’s newsletters, and special offers by e-mail. by mail. If You give Your explicit consent to the use of Your personal data for direct marketing purposes, the Company may use Your data to analyze and improve the effectiveness of its websites, advertising and market research, and for other marketing and sales purposes.
• You have the right to demand that the Company acquaints You with the personal data processed by You, and to inform You what Your personal data is, from which sources, for what purpose and how it is processed, and to whom it is provided;
• that the Company corrects or supplements incorrect, incomplete, inaccurate personal data and/or restricts the processing of such personal data, except for storage
• that the Company destroys (deletes) Your illegally stored personal data or suspends the processing of such personal data, except for storage
• receives personal data relating to You that You have provided to the Company and transfer that data to another data controller. You have the right to object to the processing of Your personal data for direct marketing purposes, and You have the right not to state the reasons for such objection. You have the right to withdraw Your consent to the processing of personal data at any time. In this case, Your personal data is destroyed immediately, except where personal data must be protected in fulfillment of a legal obligation, in cases where the legitimate interests of the controller outweigh Your interests, rights, and freedoms, or in order to assert, enforce or defend legal claims.
Data retention period
For the purposes of direct marketing, and the loyalty program – 10 years from the moment of receipt of the consent to process the data (or from the moment of receipt of the data, when the consent is not mandatory)
To send newsletters – as long as the newsletters are sent and one month after the person refused to receive the newsletter, but not longer than 10 years.
For the performance of the contract, as long as the contract is valid and for 10 years after the end of the contract, to conclude the contract from the first contact with a potential client until the conclusion of the contract, or one year when the contract is not concluded.
When seeking to enforce or defend legal claims, Your personal data may be processed for as long as necessary in those cases.
Transfer of data to third parties
The Company may transfer Your data for processing only to the following third parties:
• Company data processors – server service provider, website administrator, persons responsible for creating and sending newsletters to Your; persons responsible for the administration of databases and information systems used by the Company
• public authorities or law enforcement agencies if the data are required on a lawful legal basis.
The Company does not transfer Your personal data to third countries outside of the European Union.
Examination of requests and complaints
You have the right to submit requests related to Your rights specified in this policy, as well as claims and complaints regarding unauthorized processing of personal data or possible violation of Your rights to the Company at Ežeraičių st. 2, Ežeraičiai, Vilnius district. sav., Republic of Lithuania, by e-mail firstname.lastname@example.org. You also have the right to submit Your complaints to the State Data Protection Inspectorate, A. Juozapavičiaus str. 6, 09310 Vilnius.