Welcome, and thank you for your interest in Ratehawk Premier ("Ratehawk Premier", "we," or "us"), our web site at https://premier.ratehawk.com/ (the "Website"), and all related web sites and other services provided by us or our partners and on which a link to this Privacy Policy ("Policy") is displayed, and all other communications with individuals though from written or oral means, such as email or phone.



This Policy describes the information that we gather on or through the Website, how we use and disclose such information, and the steps we take to protect such information.



Definitions

Booking means Ratehawk Premier services for the search of suitable accommodation options in the Hotel upon the request of the User.

Data Controller means the company Emerging Travel Inc., having its registered address at 3500 S. DuPont Hwy in the City of Dover, County of Kent 19901, Delaware, USA, registration number 4869611.

Hotel means premises in which the User is offered paid accommodation, including accommodation for rent, apartments for rent, condominiums, campsites and any other types of paid accommodation, or persons providing housing and accommodation to Users and other related products.

Personal Account the set of data about the User, necessary for his identification (authentication) and for providing access to his Personal Data and settings, which is formed after User's registration on the Website.

Personal Data means any information relating to an identified or identifiable natural person, which makes possible to determine the User's identity. Such information may also include data about other people for whom the User requests a Booking search.

User means a capable individual over 18 years of age, who is visiting or uses the Website.



2. The Information We Collect on the Website

We collect different types of information from or through the Website. The processing is carried out in Ratehawk Premier' legitimate interests, which are further explained in the section "How We Use the Information We Collect". We may also process other data upon the User's consent, asking for it as appropriate.

2.1 User-provided Information. When the Website is used, User may provide, and we may collect, some of the User's Personal Data. Examples of Personal Data include the User's name, surname, email address, mobile phone number, preferred date of arrival at the Hotel. User provides us with Personal Data in various ways on the Website. For example, we may collect a User's Personal Data when User registers for a Personal Account, uses the Website, or sends us customer service -related requests.

2.2 Personal information the User gives us about others. Of course, the User might not simply be requesting Booking accommodation search for him/her-self. The User may be travelling with other guests whose details the User provides as part of the Booking, or the User may make a request for Booking search on behalf of someone else. At this point we have to point out that it's the User's responsibility to ensure that the person or people the User has provided personal information about are aware that the User's done so, have given their consent, and have accepted this Policy.





3. How We Use the Information We Collect

3.1 We use the information that we collect in a variety of ways in providing the Website and operating our business, including the following:

(i) General Use. We use Personal Data and other information collected through the Website to (a) register the User with the Website and create his/her Personal Account, (b) provide the User with the requested services (mainly to process the search of appropriate Booking for the User) (c) provide the User with information about our services on the Website (including the process of appropriate Booking search) to the extent necessary to provide such requested services, (d) build features that will make the Website easier to use, (e) conduct surveys, (f) for an improved user experience, internal training and general optimization purposes, (g) for the detection and prevention of fraud and other illegal or unwanted activities or (h) contact the User in case there is any issue with his/her Booking search. This includes faster search requests, better customer support and timely notice of new services and special offers.

(ii) Operations. We use the information to operate, maintain, enhance and provide all features of the Website, to provide the services and information that the User requests, to respond to comments and questions, to resolve any incidents and to provide support to the User of the Website.

(iii) Improvements. We use the information to understand and analyze the usage trends and preferences of our Users, to improve the Website, and to develop new products, services, feature, and functionality. Should this purpose require Ratehawk Premier to process Personal Data, then the data will only be used in anonymized or aggregated form.

(iv) Marketing Activities & Reminders: We also use the User's information for marketing activities, as permitted by law. For example: when the User sets up a Personal Account or provides us with his/her contact details we may use the User's contact information to send the User news of products and services relevant and useful for travelers. With the User's consent – if consent is required under local law – we may also send the User other regular newsletters by email. The User can opt out, or unsubscribe, from marketing communications at any time using the "Unsubscribe". Based on the information the User shares with us, individualized offers may be shown to him/her on the Website, in mobile apps or on third-party websites, including social media sites. These might be offers that the User can book directly on the Website.

If the User has not finalized online registration, we may send the User a reminder to continue with his/her registration. We believe that this additional service is useful to the User because it allows the User to carry on with a booking without having to fill in all the registration details from scratch.

When the User participates in other promotional activities, including but not limited to our referral programs, relevant information will be used to administer these promotions.

Please note that the confirmation emails and text messages sent after the registration completion are not marketing messages. These messages are part of the registration process. Respectively, they contain information that is necessary for the registration on the Website and tools to optionally rate our services after the use of them. The User will continue to receive them, even if he/she has opted out of our marketing messages.

We may use the User's email address or other information to contact that User and responding to and handling any requests he/she have made or with updates on promotions and events, relating to products and services offered by us and by third parties we work with.

(v) Analytics. We use Google Analytics to measure and evaluate access to and traffic of the Website, and create User navigation reports for our Website administrators. Google operates independently from us and has its own privacy policy, which we strongly suggest the User reviews. Google may use the information collected through Google Analytics to evaluate Users' activity on our Website. For more information, see Google Analytics Privacy and Data Sharing. We take measures to protect the technical information collected by our use of Google Analytics. The data collected will only be used on a need to know basis to resolve technical issues, administer the Website and identify the User preferences; but in this case, the data will be in non-identifiable form. We do not use any of this information to identify Users.



3.2 To process Personal Data as described above, we rely on the following legal bases:

(i) Legitimate interests: We may use the User's Personal data for our legitimate interests, such as to provide the User with the best suitable content of the Website, emails and newsletters, to improve and promote our products and services and the content on the Website, and for administrative, fraud detection and legal purposes.

(ii) Consent: We may rely on the User's consent to use his/her Personal Data for certain marketing purposes. The User may withdraw his/her consent at any time by contacting us as described in the section "How to Contact Us" or through the Personal Account settings (if any).

(iii) Compliance with a legal obligation required by law. Ratehawk Premier may, in compliance with applicable law, disclose Personal Data to protect ourselves against liability, to respond to subpoenas, judicial processes, legitimate requests, warrants or equivalent by law enforcement officials or authorities, to investigate fraud or other wrongdoing or as otherwise required or necessary in order to comply with applicable law, protect our legitimate interests or to the purchasers in connection with any sale, assignment, or other transfer of all or a part of our business or company.

We may also, in compliance with applicable law, disclose Personal Data to enforce or apply the terms and conditions applicable to our services or to protect the rights, property or safety of Ratehawk Premier, our Users or others.



4. To Whom We Disclose Information

4.1 Except as described in this Policy, we will not intentionally disclose the Personal Data that we collect or store on the Website to third parties without the consent of the applicable User. We may disclose information to third parties if the User consents to us doing so, as well as in the following circumstances:

Providers of travel services that are booked by the User's request. After the completion of the Booking search, we transfer relevant reservation details to third parties which travel services the User wishes to book. This may include name, surname, contact details, the names of guests travelling with the User and any preferences the User additionally specified when contacting us. If the User has a query about his/her Booking, we may contact service providers and ask them to handle such request.

Third-party Personal Data processor. We may use service providers to process Personal Data on our behalf. This processing is for several purposes, including for example sending out marketing material. Third party service providers are bound by confidentiality clauses and are not allowed to use Personal Data for other purposes.

Competent authorities. We disclose Personal Data to law enforcement insofar as it is required by law or is strictly necessary for the prevention, detection or prosecution of criminal acts and fraud. We may need to further disclose Personal Data to competent authorities to protect and defend our rights or properties, or the rights and properties of our business partners.

Business partners. We work with many business partners around the world. Some of these business partners distribute or advertise our services, as well as help our other business partners distribute and advertise their own travel-related services. This may mean that their services are integrated into our Website, they have been enabled to show the User a customized advertisement, or Ratehawk Premier online reservation services are integrated in their websites and/or apps.

4.2 Different service providers. We work with third party service providers who provide Website, hosting, maintenance, and other services for us. These third parties may have access to, or process Personal Data as part of providing those services for us. We limit the information provided to these service providers to that which is reasonably necessary for them to perform their functions, and our contracts with them require them to maintain the confidentiality of such information.

4.3 Law Enforcement, Legal Process and Compliance. We may disclose Personal Data or other information if required to do so by law or in the good-faith belief that such action is necessary to comply with applicable laws, in response to a facially valid court order, judicial or other government subpoena or warrant, or to otherwise cooperate with law enforcement or other governmental agencies.

We also reserve the right to disclose Personal Data or other information that we believe, in good faith, is appropriate or necessary to (i) take precautions against liability, (ii) protect ourselves or others from fraudulent, abusive, or unlawful uses or activity, (iii) investigate and defend ourselves against any third-party claims or allegations, (iv) protect the security or integrity of the Website and any facilities or equipment used to make the Website available, or (v) protect our property or other legal rights, enforce our contracts, or protect the rights, property, or safety of others.

4.4 Change of Ownership. Information about the Users, including Personal Data, may be disclosed and otherwise transferred to an acquirer, successor or assignee as part of any merger, acquisition, debt financing, sale of assets, or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets and only if the recipient of the User Data commits to a Privacy Policy that has terms substantially consistent with this Privacy Policy.

Personal Data may be physically or electronically transferred to an acquirer, or successor or assignee as part of any merger, acquisition, debt financing, sale of assets, or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets, for the sole purpose of continuing the operation of the Service, and only if the recipient of the Personal Data commits to a Privacy Policy that has terms substantially consistent with this Privacy Policy.



5. Third-Party Services

The Website may contain features or links to web sites and services provided by third parties. Any information the User provides on third-party sites or services is provided directly to the operators of such services and is subject to those operators' policies, if any, governing privacy and security, even if accessed through the Website. We are not responsible for the content or privacy and security practices and policies of third-party sites or services to which links or access are provided through the Website. We encourage the User to learn about third parties' privacy and security policies before providing them with information.



6. Minors and children's privacy

Protecting the privacy of young children is especially important. Our Website is not directed to children under the age of 18, and we do not knowingly collect Personal Data from children under the age of 18 without obtaining parental consent. If you are under 18 years of age, then please do not use or access the Website at any time or in any manner. If we learn that Personal Data has been collected on the Website from persons under 18 years of age and without verifiable parental consent, then we will take the appropriate steps to delete this information. If you are a parent or guardian and discover that your child under 18 years of age has obtained an Account on the Website, then you may alert us at [email protected] and request that we delete that child's Personal Data from our systems.

The Website is not intended to be used by minors, and is not intended to be used to post content to share publicly or with friends. To the extent that a minor has posted such content on the Website, the minor has the right to have this content deleted or removed using the deletion or removal options detailed in this Privacy Policy. If you have any question regarding this topic, please contact us as indicated in the section "How to Contact Us" section. Please be aware that, although we offer this deletion capability, the removal of content may not ensure complete or comprehensive removal of that content or information.



7. Data Security and Retention

We follow generally accepted industry standards to protect the information submitted to us, both during transmission and once we receive it. We maintain appropriate administrative, technical and physical safeguards to protect Personal Data against accidental or unlawful destruction, accidental loss, unauthorized alteration, unauthorized disclosure or access, misuse, and any other unlawful form of processing of the Personal Data in our possession. This includes, for example, firewalls, password protection and other access and authentication controls. We use SSL technology to encrypt data during transmission through public internet, and we also employ application-layer security features to further anonymize Personal Data.

If we learn of a security systems breach, we will inform the User and the authorities of the occurrence of the breach in accordance with applicable law.

In accordance with European data protection laws, we observe reasonable procedures to prevent unauthorized access to, and the misuse of, Personal Data. Only authorized personnel are permitted to access personal data in the course of their work.

We only retain the Personal Data collected from a User for as long as the User's Personal Account is active or otherwise for a limited period of time as long as we need it to fulfill the purposes for which we have initially collected it, unless otherwise required by law.



8. The User's Choices

8.1 Access, Correction, Deletion. We respect the User's privacy rights and provide him/her with reasonable access to the Personal Data that he/she may have provided through the use of the Website. If the User wishes to access or amend any other Personal Data we hold about him/her, or to request that we delete or transfer any information about him/her that we have obtained, the User may contact us as set forth in the section "How to Contact Us". At the User' request, we will have any reference to his/her deleted or blocked in our database.

The User may update, correct, or delete his/her Personal Account information and preferences at any time by accessing his/her Personal Account settings page on the Website. Please note that while any changes the User makes will be reflected in active user databases instantly or within a reasonable period of time, we may retain all information the User submits for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so. The User can also delete his/her Personal Account accessing the settings section in it.

The User may decline to share certain Personal Data with us, in which case we may not be able to provide to him/her some of the features and functionality of the Website.

The User can also withdraw his/her accept to this Policy in his/her Personal Account at any time. In case the User does this, Ratehawk Premier cease the processing of his/her Personal Data based on consent, but will continue to process it on other legitimate grounds which do not require his/her consent (please, see section 3 "How We Use the Information We Collect").

At any time, the User may object to the processing of his/her Personal Data, on legitimate grounds, except if otherwise permitted by applicable law. If the User believes his/her right to privacy granted by applicable data protection laws has been infringed upon, he/she may contact us at [email protected]. The User also has a right to lodge a complaint with data protection authorities and request any other information he/she is interested in due to his/her Personal Data processing.

8.2 Opting out from Commercial Communications. If the User receives commercial emails from us, he/she may unsubscribe at any time by following the instructions contained within the email, or by sending an email to the address provided in the section "How to Contact Us".

Please be aware that if the User opts-out of receiving commercial email from us or otherwise modifies the nature or frequency of promotional communications he/she receives from us, it may take up to 3 (three) business days for us to process such request. Additionally, even after the User opts-out from receiving commercial messages from us, he/she will continue to receive administrative messages from us regarding the Website.



9. Changes and Updates to this Policy

Please revisit this page periodically to stay aware of any changes to this Policy, which we may update from time to time. If we modify the Policy, we will make it available through the Website, and indicate the date of the latest revision, and will comply with applicable law. The User's continued use of the Website after the revised Policy has become effective indicates that the User has read, understood and agreed to the current version of the Policy.



12. How to Contact Us

Please contact us with any questions or comments about this Policy, your Personal Data, our use and disclosure practices, or your consent choices by email at [email protected], or by phone number +357 25-281-918, or by post address: 3500 S. DuPont Hwy in the City of Dover, County of Kent 19901, Delaware, USA



Last update: 15.11.2018