Privacy Policy

Updated on: May 23, 2023

This Website is operated by Old Tbilisi Hospitality LLC

This Privacy Policy explains the type of personal information (“Personal Information” or “Personal Data”) Old Tbilisi Hospitality LLC collects from you and the way our company (“We”, “Us” or “Our”) Uses it. By accessing our Website, continuing its use, and making reservations and bookings through it, you automatically consent that you have read and you agree with the present Privacy Policy. If you have any questions or concerns about privacy after reviewing this Privacy Policy, please address us at the contact details determined in Article 12 of this Privacy Policy. We may notify you regarding our most recent updates and amendments in this Privacy Policy, but we shall not be held liable if we do not act so. We recommend that you periodically check and review our latest updates made in this Privacy Policy on our Website.

PERSONAL INFORMATION WE COLLECT FROM YOU

If you are accessing Our Website without making any reservations and bookings through it, this is the Personal Information that will be collected and processed about you by Us: technical data (which includes your IP address, 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 Web-site), usage data (which includes information about how you use Our Website, products and services), marketing and communications data (which includes your preferences in receiving advertising from Us and Our third parties).

If you are signing-up as a subscriber and/or registering an account on Our Website, this is the Personal Information that will be collected and processed about you by Us: Identity data (which includes your name and surname), contact data (which includes your e-mail address) and marketing and communications data (which includes your preferences in receiving advertising from Us and Our third parties).

If you are booking through and making reservations on our bars and restaurants on our Website, this is the Personal Information that will be collected from you by Us : Identity data (which includes name, surname, date of birth (if provided) or similar identifier,), contact data (which includes email address and telephone/cell number(s)), specific data per customer (which includes your dietary restrictions, personal preferences, interests and notes (if provided)), usage data (which includes Information about how you use Our Website, products and services), marketing and communications data (which includes your preferences in receiving advertising from Us and Our third parties).

THIRD-PARTY DATA COLLECTORS AND PROCESSORS

We use Our contractors’ services, such as booking engines and data marketing platforms, who are bound by contractual undertakings to keep personal information confidential and to use it solely for the purposes for which We instruct them. By accessing Our Website and/or making reservations and bookings through it, Our contractors collect and process your Personal Data in the scope of and for the purposes of enabling hotel room and bar and restaurants reservations and bookings for you on Our Website and sending on-site marketing messages to Our Website’s online visitors, which they collect and process in compliance with their Privacy and Cookies Policies. Respectively, your Personal Information will be subject to such third-parties privacy and cookies policy as well, apart from this Privacy Policy and by accessing and/or signing up on our Website and/or making reservations and bookings through it, you consent to authorize them to collect, store and process your Personal Information that you provide on our Website in accordance with their Privacy and Cookies Policy as well. For a better insight on which third-party contractors collect and process your Personal Data, which Personal Data is collected and processed, and how, please, address us on our contact details determined in Article 12 of this Privacy Policy. We will provide you with corresponding information at our earliest convenience.

We may not be held liable or responsible for such third party’s collection, processing, disclosure, return, rectification or erasure of collected Personal Information and/or their procedure and response with respect to your rights to request access to, return, rectification and/or erasure of the Personal Data collected and processed by them.

We may not be held liable for notifying you about our Third-Party Data Collectors and Processors updates and amendments in their Privacy and Cookies Policies.

HOW AND WHEN DATA COLLECTION HAPPENS?

Personal Information may be obtained when you provide it to Us, e.g., when accessing to, signing up as a subscriber, registering an account and/or making purchases or reservations and bookings on Our Website.

We may also receive your Personal Information from other sources, such as joint marketing partners, booking engines, social media platforms and other third parties. When you access our Website through your social media account, Personal Information of your social media account will be shared with Us.

OUR PRIVACY PRINCIPLES

We collect and process your Personal Data explicitly for the purposes determined under this Privacy Policy and it is not further processed in a manner that is incompatible with those purposes;

We undertake that the Personal Data collected and processed by Us is adequate, relevant, and limited to what is necessary in relation to the purposes determined under this Privacy Policy;

Your Personal Data is kept in a form that permits its processing and use for no longer than is necessary for the purposes under this Privacy Policy;

We protect all non-public and public personal information We collect about you in compliance with strict standards of security and confidentiality;

We implement and maintain internal technical and organizational safeguards to store and protect your Personal Data in the utmost secure and confidential manner;

We require any third party providing products/services to Us to protect and respect the confidentiality of your Personal Information;

We permit only authorized employees and contractors to have access to your non-public Personal Information, who need to have access to and process your Personal Data solely for the purposes indicated in this Privacy Policy and who are bound by the same degree of confidentiality obligations with respect to processing, storing and non-disclosure of your Personal Data.

PURPOSE OF COLLECTING PERSONAL INFORMATION

We process Personal Information for providing you with the products and services offered through Our Website, conducting automatic payment procedures in case of no show-up after making Our hotel room reservations and bookings through Our Website, improving your experience and excelling Our services, customizing Our services to your needs and identifying any shortfalls that We might have in providing Information about Us through Our Website, communicating with you and providing you with our marketing newsletters and special offerings with respect to our products and services (including circulating promotional offers and client surveys). Therefore, some marketing offerings and promotions and enabling reservations and bookings on Our Website require your Personal Information to be shared with the third-party data collectors and processors as determined in Article 2 of this Privacy Policy.

Additionally, we use collected Personal Data for analytical and statistical purposes, i.e. to comprehend how Our users interact with Our Website. We periodically carry out quality surveys and actions to determine the level of our customers satisfaction.

SHARING

We may share your Personal Information with:

Our affiliates, which implies entities affiliated with/related to Us, including any other entity and/or person that is directly or indirectly controlled by Us, is under common control with Us or is controlled together with Us by other affiliated entity in consideration of common business interests, in the frame of corporate governance/management structure within Our holding (group of companies), for their legitimate financial purposes and for providing you with their marketing newsletters and special offerings regarding their products and services. We share your Personal Data explicitly with any of such affiliate companies from our group of companies who need to process your Personal Data solely for the purposes indicated in this Article 6 and who are bound by the same degree of confidentiality obligations with respect to processing, storing and non-disclosure of your Personal Data. The term “control” means the possession, directly or indirectly, of the power to direct or cause the direction of the management and policies of an entity/person, whether through the ownership or control of interests or voting securities, by contract or otherwise;

Our employees and contractors who need to have access to and process your Personal Data solely for the purposes indicated in this Privacy Policy and who are bound by the same degree of confidentiality obligations with respect to processing, storing and non-disclosure of your Personal Data;

Third-Party Data Collectors and Processors for the purposes of and in accordance with Article 2 of this Privacy Policy;

Governmental and public authorities, as required under applicable laws.

SUBSCRIPTIONS

On the basis of your subscription, We shall obtain your e-mail address for the purposes of sharing Information about Us. You may unsubscribe anytime by addressing us on the contact details indicated in Article 12 of this Privacy Policy.

If you subscribe to Our newsletter, We shall process your Personal Data to manage your subscription, including sending customized information on Our products and services via e-mail. We shall contact you for updates and informative notices related to Our products and services, to establish the degree of customer satisfaction.

COOKIES

By visiting Our Web-site, your computer or device may be provided a cookie, which tracks your preferences. This Information helps Us improve Our services and update/improve Our Web-site. We process Personal Information by Using cookies as per Our Cookie Policy determined below.

STORAGE AND SECURITY

We treat your Personal Information with utmost diligence and confidentiality in accordance with the principles determined under 4 of this Privacy Policy and have implemented all the technical and organizational security measures for the purposes of protecting this Information from unlawful usage, loss, alteration, erasure, processing or any other unauthorized forms of access to and impact on such Personal Data. These measures are implemented as per applicable law.

We shall keep your Data to the extent and for the period of what is necessary for the purposes of processing Personal Data under this Privacy Policy after which we routinely erase and destroy it or keep it in unidentifiable and depersonalized manner for our analytical and statistical purposes and ensure that Our affiliates comply with the same rule.

YOUR RIGHTS AND OBLIGATIONS

You are entitled to request access to, return, rectification, addition and erasure of your Personal Data which we collect and process and to withdraw your consent on this Privacy Policy at any time. We review and satisfy your request within the statutory timeframes determined under the applicable laws of Georgia or reject your respective request if it contradicts with our legitimate lawful interests, public interests, legal obligations or requirements of applicable law. In the event of return and/or erasure of your Personal Data upon your request, unsubscribing from Our newsletters, marketing communications and special offerings and/or withdrawal of your consent on this Privacy Policy, please note, that you might be unable to continue using our products and services through our Website or might have limited access to such use and/or will not receive any of Our newsletters, marketing communications and special offerings from Us regarding Our products and services. If you would like to submit your request with any of the foregoing inquiries regarding your Personal Data, please address us on the contact information indicated in Article 12 of this Privacy Policy.

Please, further note that We are solely liable and responsible for reviewing and satisfying or rejecting your request within the scope and to the extent of your Personal Data stored on our data servers. If you would like to have access to your Personal Data processed by our Third-Party Data Processors and Collectors determined in Article 2 above or request them to return, rectify, add or erase your Personal Data, please, address us on the contact information indicated in Article 12 of this Privacy Policy and we will provide you with their contact details at our earliest convenience. To avoid any doubt, we shall not be held liable for the outcomes if you do not address them with the respective request on the contact details provided by Us or for the responses issued, actions taken and procedures implemented by them with regard to your request.

You are liable for any loss or damage inflicted to Us or third party for submitting erroneous, inaccurate or incomplete Information in the newsletter registration, sign-up and/or reservation and booking forms. Please note, that you should provide only your own data and you are not allowed to provide Information on the third parties. If you share with Us Personal Data that belongs to the third parties, We imply, that such data is legally obtained by you from such third party and you have due authority and legal capacity to collect and transfer such third party’s Personal Data to Us.

Please note that certain Information should be kept by Us for recordkeeping purposes and for completing transactions that were commenced by you prior to requesting rectification or erasure.