3.1 According to GDPR law, and with regard to the processing of all aggregated data or personal data of Accommodation Provider’ guests (the "Data"), both Parties agree that:

The Accommodation Provider is the Data Administrator (Controller)
Hotel Linkage Private Company is the Data Processor.

3.2 Specification of the purpose
The processing of the Data is entrusted for the following purposes:

collection of the Data from the Guest who makes the reservations of the hotel rooms for and in the name of the Controller;
transfer of the data to the Controller, and
rendering of the technical assistance to the Controller relating to the Processor services

The Processor may extend the scope of the processing of the Data beyond the frames specified above only following the documented request of the Controller in that respect.

3.3 The Processor ensures that the persons authorized to process the data will be bound with the non-disclosure obligation.
To the possible extent and taking into account the nature of the processing, the Processor will assist the Controller in realization of its duties to respond to the requests of data subjects in relation to the execution of their rights specified in section III of GDPR through adequate technical and organizational measures. The Processor will make available to the Controller all the information necessary to prove that the obligations specified in art. 28 of GDPR are fulfilled and will enable the Controller or the auditor authorized by the Controller to make audits including the inspections. In that respect the Processor assists the Controller.

The Processor declares that it has implemented the adequate safety measures aiming at the processing of the Data complies with the law. The Processor is obliged to keep in secret any information received in relation to its access to the Data and their protection against any unauthorized access. In particular, the Processor will not process the Data in a way which contradicts with the law add it will not reveal and make them available to unauthorized persons.

3.4 External services - In the event of the use of a third party services in relation to the processing of the Data, the Processor will observe the requirements specified in art. 28 items 2 and 4 of GDPR.

3.5 Winding up of the processing - Following the winding up of the services relating to the processing, the Processor will transfer the data to the Controller and destroys any existing copies thereof. This action will be performed separately in relation to each portion of the Data transferred to the Controller.

3.6 Each Party shall take reasonable steps to protect personal data (i.e., information that relates to an identified or identifiable natural person) processed in the context of the Agreement against loss and unauthorized access, use, deletion and disclosure; and, as required by applicable laws, process personal data in a manner that ensures appropriate confidentiality and security of the personal data.

3.7 The Accommodation Provider acknowledges that it is responsible for the handling and security of the personal data it holds and processes within the context of the Agreement and Hotel Linkage Private Company acknowledges that it is responsible for the handling and security of the personal data it processes within the context of the Agreement. Accommodation Provider shall provide personal data to Hotel Linkage Private Company only if such disclosure is permitted under applicable laws. Hotel Linkage Private Company shall be a data controller (i.e. determines the purposes and means of the data processing) for any personal data it processes. Accommodation Provider shall become data controller upon receipt of the personal data of the guest. The Parties shall, if required by applicable laws, cooperate in good faith and provide assistance in the event data subjects wish to exercise their rights of access, correction, erasure or portability, or in case of requests from competent authorities to demonstrate compliance with obligations applicable to the Party.

3.8 Accommodation Provider shall process personal data that Accommodation Provider received from Hotel Linkage Private Company as part of the Services under the Agreement only so far as necessary to perform the requested reservation services, or as otherwise agreed to between the Parties in writing, in accordance with applicable law, including (if applicable) Directive 95/46/EC and 2002/58/EC (as amended or replaced by subsequent legal acts) on the processing of personal data and the protection of privacy or the EU General Data Protection Regulation or if Accommodation Provider has obtained explicit consent from the guest to any other use of guest’s personal data.

3.9 The accommodation provider is the sole owner of the reservations’ personal data received from Hotel Linkage as part of the Services under the Agreement, neither Hotel Linkage nor any reseller or agent has the right to own the reservations’ personal data. Hotel Linkage do not use any guest information for marketing or any similar purposes.

This policy is effective as of 24 May 2018

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