This Privacy Policy, hereinafter referred to as «Policy», applies to the processing of personal data that may be withdrawn by FOP Gulyanich O.I. types of physical persons (subjects of personal data) under the Constitution of Ukraine and the Law of Ukraine «On the Protection of Personal Data» dated 06/01/2010. No. 2297-VI (hereinafter referred to as the «Law»), as well as the General Regulations on Data Protection (EU) 2016/679 dated April 27, 2016. (EU General Data Protection Regulation, hereinafter referred to as «GDPR») and another important European legislation on data protection, collectively called «Legislation».
This Privacy Policy has been created to inform you:
• what is personal data;
• what personal data we collect about you;
• how and why we use them;
• to whom we transfer your personal data;
• how we protect the privacy of your personal data;
• how to contact us and who to contact if you have questions about the processing of your personal data.
We process your personal data only if one of the conditions specified in Article 6 of the GDPR is met, including but not limited to:
• You have consented to the processing of your personal data;
• processing is necessary to provide you with services;
• such processing is required by the law of the country where you are located.
We take the security of the personal data of our customers, potential customers and others who have contacted us seriously, so we are committed to protecting the privacy of your personal data. The administration undertakes to take all necessary measures to prevent misuse of your personal data that become known to us. We will process your personal data in strict accordance with the requirements of the applicable Law and only if there are legal grounds for such processing.
You are not required to provide us with personal data, but without certain information about you we will not be able to provide you with some of our services. In the event that we control the methods of collecting your personal data and determine the purposes for which these personal data are used, the Administration is the «Сontroller of personal data» for the purposes of the GDPR and other applicable European legislation on data protection, as well as the «Оwner of personal data» in the sense of the law.
Personal data — information or a set of information about a natural person who is identified or can be specifically identified (User);
Special categories of personal data — this is the so-called «sensitive» Personal Data, which may cause harm to the data subject at work, in an educational institution, in the living environment, or may lead to his discrimination in society. For example, this is Personal Data that contains information about racial origin, political or religious views, trade union membership, health, sex life, biometric or genetic data. In the terminology of Ukrainian legislation, these are personal data, the processing of which carries a special risk for the subjects of personal data;
Subject of personal data — is the natural person to whom the Personal Data belongs and who can be identified by this Personal Data, or who has already been identified;
Administration of the site (Administration, as well as hereinafter referred to as we, us) — FOP Gulyanich O.I., legal address: Ukraine, 88000, Transcarpathian region, Uzhgorod district, Uzhgorod city, prov. Girskyi, bldg. 2;
Processing of personal data — any action or set of actions, such as: collection, registration, accumulation, storage, adaptation, change, restoration, use and distribution (distribution, implementation, transfer), depersonalization, destruction of Personal Data, including using information (automated ) systems;
Distribution of personal data — actions regarding the transfer of information about a natural person with the consent of the Subject of personal data;
Use of personal data — any actions of the Administration on the processing of this data, actions on their protection, as well as actions on granting a partial or full right to process personal data to other subjects of relations related to Personal data, carried out with the consent of the Subjects of personal data or in accordance with the legislation of Ukraine;
Depersonalization of personal data — extraction of information that allows direct or indirect identification of a person;
User — Subject of personal data, any capable natural person who has joined this Policy in their own interests to obtain information on the pages of the web resource (site) or to obtain advice in online format on the site https://whitehills-hotel.com/en using the Internet;
Web-resource (site) — a set of data, electronic (digital) information, other objects of copyright and/or related rights, interconnected and structured within the website address and/or account of a person who has Intellectual Property rights (hereinafter — «IР») to the site. These objects are accessed through an Internet address, which may consist of a domain name, directory or call records, and/or a numeric Internet Protocol address. The web resource belonging to the Administration is located at the web address https://whitehills-hotel.com/en;
Policy — this Privacy Policy, which is located on the page of the web resource at the address https://whitehills-hotel.com/en/privacy-policy;
Personal data controller — is a natural or legal person who determines the purposes and means for the Processing of personal data and bears the main responsibility for their processing. The controller of personal data is the «Оwner of personal data» in the terminology of Ukrainian legislation. Within the framework of this Policy, the Controller of personal data is FOP Gulyanich O.I.;
Personal data processor — this is a natural or legal person who processes Personal Data for the Controller based on instructions (instructions, orders) of the Controller. A personal data processor is a «Personal data administrator» in the terminology of Ukrainian legislation.
2.1. The Policy applies to all your Personal Data that may be received by Us in the course of your use of the web resource. This Policy applies to Personal Data received both before and after the entry into force of this Policy.
2.2. The purpose of the Policy is to provide you with the necessary information to assess what Personal Data and for what purposes we process, how we process it and how we ensure its security.
2.3. When using the site, you, by providing your Personal Data to the Administration, including through third parties, acknowledge your consent to the processing of your Personal Data in accordance with this Policy.
2.4. In case of disagreement with the terms of this Policy, you must stop using the web resource.
2.5. Consent to the processing of Personal Data may be withdrawn by the Personal Data Subject. If the Personal Data Subject withdraws the consent to the processing of Personal Data, the Administration has the right to continue processing Personal Data without the consent of the Personal Data Subject if there are grounds specified in the legislation.
2.6 The Website Administration does not verify the accuracy of the Personal Data provided by the User and has no possibility to assess his/her legal capacity. However, the Administration assumes that the User acts in good faith, prudently, provides accurate and sufficient Personal Data and makes all necessary efforts to keep such data up to date and does not violate the rights of third parties.
2.7. By agreeing to the terms of this Policy, you confirm that at the time of collecting Personal Data, you are informed about the persons to whom Personal Data is transferred, the content and purposes of collecting Personal Data. You confirm (warrant) that the Personal Data transferred to Us for processing is transferred with the consent of the Personal Data owners and in accordance with the Law.
2.8. The Administration, having received the Personal Data from the User, does not undertake to inform the Subjects (their representatives) of the personal data transferred to it about the start of the Personal Data Processing, since the obligation to provide appropriate information when concluding an agreement with the Personal Data Subject and/or when obtaining consent to such transfer is borne by the User who transferred the Personal Data.
2.9. The processing of your Personal Data is carried out in accordance with the requirements of the Law. The processing of personal data of persons residing in the EU or who are EU citizens is regulated, in particular, by the EU General Data Protection Regulation 2016/679 (hereinafter referred to as the "GDPR"). The laws of other countries may also impose additional requirements.
2.10. This Policy applies to all information that the Administration may receive about the User while using the web resource, as well as during the execution by the Administration of any agreements and contracts with the User.
2.11. This Policy is an internal document of the Administration.
2.12. The Personal Data Controller shall be released from liability for the consequences arising in connection with the processing of Personal Data by it, if it is not responsible for the event that caused such consequences.
You also agree that the Personal Data Owner has the right to provide access to and transfer your Personal Data to third parties without any additional notifications, only if the purpose of their processing does not change and only in cases provided for by this Privacy Policy and/or the laws of Ukraine.
No one under the age of 18 should provide us with personal information through the website. We do not purposefully collect personal information from persons under the age of 18. Parents and guardians should constantly monitor the related activities of their children.
3.1. The Administration, in order to carry out its activities and fulfill its obligations, processes the User's Personal Data provided by him when visiting the website https://whitehills-hotel.com/en and stores it on the Administration's server.
3.2. The User's Personal Data includes: surname, name, patronymic, e-mail address, mobile/landline phone number, country of residence, place of work, position, date of birth, as well as other data that the User has entered in the feedback form or application for cooperation/partnership, or when filling out an application resume.
We ask you to provide only those Personal Data that are necessary to provide the service you have chosen, receive a newsletter or respond to your special request/claim. At the same time, if you decide to provide additional Personal Data, we will also be able to process it with the required level of protection.
3.3. The Administration has the right to establish requirements for the composition of Personal Data that must be provided when using the web resource. If certain information is not specified by the Administration as mandatory, its provision or disclosure is carried out by the User at his own discretion.
3.4. Data that is automatically transmitted to the Administration when the User uses the web resource using the software installed on the device: IP address, information about the browser and the type of operating system of the device, hardware and software specifications, date and time of access to the web resource.
4.1. The grounds for the Processing of Personal Data are:
1) consent of the Personal Data Subject to the processing of his/her Personal Data by the Administration;
2) conclusion and execution of an agreement to which the Personal Data Subject is a party or which is concluded in favor of the Personal Data Subject, or for the implementation of measures preceding the conclusion of an agreement at the request of the Personal Data Subject;
3) the need for the Administration to fulfill the requirements stipulated by the Legislation.
4.2. The purpose of Personal Data Processing is:
⦁ performing the functions assigned to the Administration in accordance with the laws of Ukraine and the GDPR;
⦁ collection, storage and Processing of personal data received on the Website in accordance with the Law and the GDPR;
⦁ to send the User commercial (marketing) messages containing additional information about services, current promotions and special offers, product catalogs related to the services provided by the Administration through the Website.
⦁ identification of the Personal Data Subject when using the Website;
⦁ communication with the Personal Data Subject, if necessary, including sending offers, informational materials, notifications, information and requests, advertising, as well as processing requests from the Personal Data Subject;
⦁ improving the quality of the website, its usability, developing new functionality and improving the quality of service;
⦁ improving the User's professional skills and qualifications;
⦁ conducting statistical and other research based on the Anonymized Data;
⦁ fulfillment by the Administration of contractual and other obligations to the User under agreements concluded between the Administration and the User or third parties in favor of the User.
5.1. The processing of personal data by the Administration is based on the following principles:
5.1.1. Legality of the purposes and methods of Personal Data Processing;
5.1.2. The Administration's good faith as the owner of Personal Data is achieved by complying with the requirements of the legislation of Ukraine regarding the processing of Personal Data;
5.1.3. Achieving specific, predetermined goals of Personal Data Processing;
5.1.4. Compliance of the purposes of Personal Data Processing with the purposes previously determined and stated when collecting Personal Data;
5.1.5. Compliance of the list and volume of processed Personal Data, as well as the methods of Personal Data Processing with the stated purposes of processing;
5.1.6. Reliability of Personal Data, their sufficiency for the purpose of processing, inadmissibility of Processing of Personal Data that is excessive in relation to the purposes of Personal Data Processing;
5.1.7. Ensuring, when processing Personal Data, the accuracy of Personal Data, their sufficiency, and, where necessary, relevance in relation to the purposes of Personal Data Processing.
5.1.8. Inadmissibility of combining databases containing Personal Data, the processing of which is carried out for incompatible purposes with each other;
5.1.9. Storing Personal Data in a form that allows to identify the Personal Data Subject no longer than the purpose of their processing requires.
5.1.10. The processed Personal Data is subject to destruction or depersonalization upon achievement of the processing purposes or in case of loss of necessity to achieve these purposes, unless otherwise provided by the legislation of Ukraine and the GDPR.
5.1.11. We must also take into account the periods for which we may need to retain your Personal Data to fulfill our legal obligations to you or regulatory authorities.
5.1.12. We may minimize your Personal Data that we use over time, or we may even make your data anonymous so that it cannot be linked to you personally. In this case, we will be able to use this information for statistical or other purposes without further notice to you, as such information ceases to be personal data.
5.2. Personal data is processed by the Administration for statistical or other research purposes, subject to the mandatory depersonalization of personal data.
5.3. The Administration does not process personal data relating to racial or ethnic origin, political, religious or ideological beliefs, membership in political parties and trade unions, conviction to criminal punishment, as well as data on health, sexual life, biometric and genetic data.
5.4. Personal data shall be processed in compliance with the conditions set forth in the legislation of Ukraine and the GDPR.
6.1. The terms of Personal Data Processing shall be determined based on the purposes of processing, but not longer than provided by the Legislation.
6.2. Personal data, the processing (storage) period of which has expired, must be destroyed or depersonalized, unless otherwise provided by the Law. Personal Data shall be stored in a form that allows identifying the Personal Data Subject no longer than the purpose of Personal Data Processing requires, unless the Personal Data storage period is established by the Law. The processed Personal Data is subject to destruction or depersonalization upon achievement of the processing purposes or in case of loss of the need to achieve these purposes, unless otherwise provided by the Law. We must also take into account the periods for which we may need to retain your Personal Data to fulfill our legal obligations to you or regulatory authorities (in accordance with EU Regulation 261/2004).
6.3. We may minimize your Personal Data that we use over time, or we may even make your data anonymous so that it cannot be linked to you personally. In this case, we will be able to use this information without further informing you.
7.1. In order to achieve the objectives of this Policy, only those employees of the Administration who are entrusted with such a duty in accordance with their official (labor) duties are allowed to process personal data. Other employees may be granted access only in cases provided for by the Law. The Administration guarantees from its employees the confidentiality and security of Personal Data during their processing.
7.2. The Administration has the right to transfer Personal Data to third parties in the following cases:
⦁ the Personal Data Subject has expressed his/her consent to such actions in writing;
⦁ the transfer is provided for by Ukrainian or other relevant legislation within the procedure established by law. At the same time, access to Personal Data is not provided to a third party if the said person refuses to undertake obligations to ensure compliance with the requirements of the Law or cannot ensure them.
7.3. The Administration has the right to entrust the Processing of Personal Data to a third party with the consent of the Personal Data Subject, unless otherwise provided by the legislation of Ukraine, on the basis of an agreement concluded with a third party, a condition of which is the observance of confidentiality and non-disclosure of Personal Data.
7.4. Representatives of public authorities (including controlling, supervisory, law enforcement and other authorities) shall have access to Personal Data processed by the Administration to the extent and in the manner prescribed by law.
8.1. The Administration's activities related to the Processing of Personal Data in information systems are inextricably linked to the Administration's protection of the confidentiality of the information received, unless otherwise provided by applicable law.
8.2. The Personal Data protection system includes organizational and (or) technical measures determined taking into account current threats to the security of Personal Data and information technologies used in information systems. The Administration updates these measures with the advent of new technologies, if necessary.
8.3. The exchange of personal data during their processing in information systems is carried out through communication channels protected by technical means of information protection.
8.4. When processing personal data in information systems, the Administration shall ensure:
⦁ taking measures aimed at preventing unauthorized access to Personal Data and (or) transferring it to persons who do not have the right to access such information
⦁ timely detection of facts of unauthorized access to Personal Data;
⦁ preventing any impact on the technical means of automated Personal Data Processing that may disrupt their functioning;
⦁ the possibility of immediate restoration of Personal Data modified and destroyed as a result of unauthorized access to them;
⦁ constant control over the security of Personal Data.
8.5. Personal information is kept confidential, except when the technology of the web resource or the software settings used by the User provide for the open exchange of information with other Users of the Sites or with any users of the Internet.
8.6. The Administration implements the following requirements of the legislation of Ukraine in the field of Personal Data:
⦁ requirements for the confidentiality of Personal Data;
⦁ requirements for ensuring the exercise of the Personal Data Subject's rights;
⦁ requirements for ensuring the accuracy of Personal Data, and, where necessary, relevance to the purposes of Personal Data Processing (with taking (ensuring the taking of) measures to delete or clarify incomplete or inaccurate data);
⦁ requirements for protection of Personal Data against unauthorized or accidental access to them, destruction, distortion, blocking, copying, provision, distribution of Personal Data, as well as other unlawful actions in relation to Personal Data;
⦁ other requirements of the Law.
8.7. In accordance with the Law, the Administration independently determines the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations under the legislation in the field of personal data from unauthorized or illegal processing and from unintentional loss, destruction or damage.
The Administration adheres to the principle of minimizing Personal Data. We process only the information about you that we need, or the information that you provide with your consent beyond the necessary processing. In addition, we have configured all the interfaces of the Website and the program for the provision of the Services so that the maximum possible confidentiality is maintained. When transferring Personal Data to government agencies, we always use the most secure and proven ways to transfer such data.
8.8. Cookies and other tracking technologies.
Cookies are small text files that are stored by websites on your computer or mobile devices when you start using them. In this way, the site will remember your preferences and the actions you have taken for a while, including so that you do not need to re-enter this data. Our cookies do not by themselves identify an individual user, but only identify the computer or mobile device you are using.
Cookies and other tracking technologies on our website can be used in various ways, for example, for the purpose of operating the website, analyzing traffic or advertising purposes. We use cookies and other tracking technologies, in particular, to improve the quality and efficiency of our services.
For more information on what cookies are, how they work, how to manage them, or how to delete them, please visit www.allaboutcookies.org.
Please be advised that you can configure your Internet browser settings to refuse cookies and other tracking technologies. At the same time, you should understand that if you disable some cookies, the functionality of the site may be limited and you may not be able to use all its benefits, and some pages may not work properly.
8.9. For more information about the cookie policy on our website, please visit https://whitehills-hotel.com/en/cookie-policy.
9.1. Rights of Personal Data Subjects in accordance with the legislation of Ukraine:
9.1.1. To know about the sources of collection, location of their Personal Data, the purpose of their processing, the location of the Personal Data Controller or to give an appropriate order to authorized persons to obtain this information, except in cases established by the Law.
9.1.2. Receive information about the conditions for granting access to Personal Data, including information about third parties to whom his/her Personal Data is transferred.
9.1.3. Access to your Personal Data.
9.1.4. Receive a response no later than thirty (30) calendar days from the date of receipt of the request, except as provided by the Law, whether and what kind of Personal Data is processed.
9.1.5. To submit a reasoned request to the Administration to object to the processing of their Personal Data.
9.1.6. Submit a reasoned request to change or destroy your Personal Data if the data is processed illegally or is unreliable.
9.1.7. To protect their Personal Data from unlawful processing and accidental loss, destruction, damage due to intentional concealment, failure to provide or untimely provision, as well as to protect against the provision of information that is inaccurate or discrediting the dignity and business reputation of an individual.
9.1.8. To file complaints about the processing of their Personal Data by the Administration to the Ukrainian Parliament Commissioner for Human Rights or to the court.
9.1.9. Apply legal remedies in case of violation of the legislation on the protection of Personal Data.
9.1.10. To make reservations regarding the restriction of the right to process your Personal Data when providing consent.
9.1.11. Withdraw consent to the Processing of Personal Data.
9.1.12. To familiarize yourself with the mechanism of automatic Personal Data Processing.
9.1.13. To be protected against an automated decision that has legal consequences for him/her.
9.1.14. The Administration has the right to entrust the Processing of Personal Data to a third party with the consent of the Personal Data Subject, unless otherwise provided by the legislation of Ukraine, on the basis of an agreement concluded with a third party, a condition of which is the observance of confidentiality and non-disclosure of Personal Data.
9.1.15. Representatives of public authorities (including controlling, supervisory, law enforcement and other bodies) shall have access to Personal Data processed by the Administration to the extent and in the manner prescribed by the legislation of Ukraine.
9.2. Other rights of Personal Data Subjects in accordance with the GDPR:
In addition to the Ukrainian legislation on the protection of Personal Data, the Administration is attentive to ensuring your rights under the GDPR.
9.2.1. The right to information.
We are ready to provide data subjects with information about what Personal Data we process.
If you want to know what Personal Data we process, you can request this information at any time, including by contacting the Administration. The list of data that we must provide you with can be found in Articles 13 and 14 of the GDPR. However, when you contact us, you must provide your specific requirements so that we can legally consider your request and respond.
Please note that if we are unable to verify your identity through electronic messaging or when you contact us by phone, or in case of reasonable doubt as to your identity, we may ask you to provide an identity document, including by personal appearance at the address of the Administration's location. This is the only way we can avoid disclosing your Personal Data to a person who may be impersonating you.
We will process requests as soon as possible, but at the same time, please remember that providing a complete and legitimate response regarding Personal Data is a complex process that can take up to a month.
9.2.2. The right to rectify data about you.
If you find that some of the Personal Data we process about you is incorrect or outdated, please let us know. In this case, we may ask you to provide an identity document, including by personal appearance at the address of the Administration's location.
In some cases, we may not be able to change your Personal Data. In particular, this may be the case when your Personal Data has already been used in the course of the contract performance and/or it is contained in a tax document that was executed in accordance with the Tax Law.
9.2.3. Withdrawal of consent to Personal Data Processing and the right to be forgotten
If the Administration processes your Personal Data on the basis of consent to the Processing of Personal Data (in particular, for the purpose of marketing/advertising mailings), further processing can be terminated at any time. It is enough to withdraw your consent to such processing.
You can also exercise your right to be forgotten. In the cases provided for in Article 17 of the GDPR, the Administration will destroy your Personal Data to the extent that it processes it, except for personal data that we are obliged to retain in accordance with the requirements of the law.
Also in this case, for security reasons, the Administration may ask you to provide an identity document, in particular directly at the address of the Administration's location.
The administration uses the company's cloud services to store personal data and ensure their security: "HOSTING UKRAINE" (https://www.ukraine.com.ua).
11.1. This Policy may be changed or terminated by the Administration unilaterally without prior notice to the Users, including if required by law. The new version of the Policy shall come into force upon its posting on the website, unless otherwise provided by the new version of the Policy. Therefore, we ask you to visit https://whitehills-hotel.com/en/privacy-policy to make sure you have the latest information.
12.1. If you have any questions, comments, complaints or requests regarding the protection and Processing of personal data, you can contact us by official e-mail, e-mail: whitehills.hotelinfo@gmai.com, or postal address: Ukraine, 88000, Transcarpathian region, Uzhhorod district, Uzhhorod, Myslyvsky lane, 7.
Be sure to include in all correspondence your name, surname, e-mail address, as well as detailed questions, comments, complaints or requests.
12.2. The administrative authority for personal data protection in Ukraine is the Department for Personal Data Protection of the Secretariat of the Ukrainian Parliament Commissioner for Human Rights. You may contact it with complaints or suggestions if you believe that your rights have been violated in connection with the processing of personal data.