PRIVACY POLICY

We respect and protect the privacy of every person whose private data it collects. Collection and safekeeping of data are conducted by with the Law on personal data protection of Montenegro, as well as with the General Data Protection Regulation of EU (hereinafter referred to as the “Law”).

We value you as our guest and recognize that privacy is important to you.

To protect the privacy of every person whose private data it collects, we render its Privacy policy. Such Privacy policy defines which personal data we collect, for which purpose we use them, how we protect them, and what your rights are. Namely, we have developed this Privacy policy to explain our practices regarding the personal information we collect from you or about you on this site, through written or verbal communications with us, when you visit one of our properties, or from other sources.
Ananti holds all copyrights for the usage of photos, texts, and other published material, within the meaning of statutory legal regulations in Montenegro. Photographs, texts, and other material can’t be published, sold, publicly or privately published, or in any other manner used without our consent. Non-compliance with the above-stated terms entails responsibility and obligation of remuneration of non-material damage to Ananti per violation of each material.

GENERAL PROVISIONS

SCOPE OF APPLICATION

This Privacy policy applies to every Ananti’s personal data handling.

“Personal Data” are data that identify you as an individual or relate to an identifiable individual.

We collect Personal Data by Law.

If you submit any Personal Data about other people to Ananti’s service providers (e.g., if you make a reservation for another individual), we shall deem that you have the authority to do so and you permit us to use the data following this Privacy policy.

DATA HANDLER AND LEGAL FRAMEWORK

Ananti, as handler of your data, respects your privacy and undertakes to protect your personal data.

HOW WE COLLECT PERSONAL DATA

We collect Personal Data in a variety of ways:

1) ONLINE SERVICES (RESERVATION OF ACCOMMODATION VIA INTERNET)

We collect Personal Data when you make a reservation, purchase services from our website, communicate with us, or otherwise connect with us or post to social media pages, or sign up for a newsletter or participate in a survey, contest or promotional offer.

2) PROPERTY VISITS AND ACCOMMODATION AGREEMENTS.

We collect Personal Data when you visit our properties, villas, apartments and other amenities, or use on-property services such as: beach with floating pier, bar, restaurant, swimming pools, Spa facilities and fitness.

We collect Personal Data in the event of filling accommodation agreements.

We collect Personal Data when you make a reservation over the phone, communicate with us by email or via fax.

3) OTHER SOURCES

We collect Personal Data from other sources, such as public databases, joint marketing partners and other third parties. We can obtain personal data from third parties that we have close collaboration with (e.g. including travel agency, event and congress organization agency, business partners, associates, suppliers, etc.).

4) BY VIDEO SURVEILLANCE

We collect images and video and audio data via security cameras located in public areas, such as hallways and lobbies, in our properties.

HOW WE COLLECT OTHER DATA

1) COOKIES

We collect certain data from cookies, which are pieces of data stored directly on the computer or mobile device that you are using. Cookies allow us to collect data such as browser type, time spent on the online services, pages visited, referring URL, language preferences, and other aggregated traffic data.

We use the data for security purposes, to facilitate navigation, to display data more effectively, to collect statistical data, to personalize your experience while using the online services and to recognize your computer to assist your use of the online services.

We also gather statistical data about use of the online services to continually improve design and functionality, understand how they are used and assist us with resolving questions.

Cookies further allow us to select which advertisements or offers are most likely to appeal to you and display them while you are using the online services or to send marketing emails. We also use cookies to track responses to online advertisements and marketing emails.

You can choose whether to accept cookies or not to accept cookies. If you changed your mind regarding settings of cookies on our website page, you can always erase or block cookies by changing settings on your web browser and disable further handling of your personal data, accordingly. These setting depends on your browser.

If you block cookies, it is possible that some options on web page will not be available.

We store cookies in the database and saves them for 5 years at most.

2) YOUR IP ADDRESS

We collect your IP address, a number that is automatically assigned to the computer that you are using by your Internet Service Provider. An IP address is identified and logged automatically in our server log files when a user accesses the online services, along with the time of the visit and the pages that were visited. We use IP addresses to calculate usage levels, diagnose server problems and administer the online services. We also may derive your approximate location from your IP address.

IMPLEMENTATION OF DATA PROTECTION PRINCIPLES

We, within implementation of this Privacy policy, especially take care of data procession principles, therefore these data are processed:

• Lawfully – processing will be possible if the Law allows it and within the boundaries set by the Law.
• Fairly – with respect of uniqueness of every relationship, applying all adequate measures for protection of personal data and privacy in general, and without preventing examinee to exercise their rights.
• Transparent – by informing examinees on personal data procession. From the collection of data, when the examinees are informed on every aspect of data procession, till the end of data procession, examinees will have simple and fast access to their data which includes possibility of inquiry and obtaining of copy following the provisions of the Law. Certain information can be limited only when it is obligatory by Law or if necessary, for protection of third persons.
• With limitation of safekeeping – by safekeeping of data in the form that provides identification of the examinee only for the period necessary for the purpose for which personal data are handled, and longer only if allowed by the Law.
• With reduction of the data amount – by handling data only if they are appropriate, relevant, and limited to what’s necessary. Particular care will be taken not to collect data for which there is no justified need for handling.
• By taking care of accuracy – by taking care of accuracy and up-to-datedness of the data, and by deleting incorrect data within capacity.
• By taking care of completeness and confidentiality – by giving technical and organizational measures necessary safety of personal data, including protection from unauthorized or illegal handle, and accidental loss, destruction, or damage by applying necessary technical and organizational measures. Relevant measures are applied concerning the risk during every type of data handling.

PURPOSE OF THE COLLECTION

We are obliged to collect some of your personal data to fulfil accommodation agreement and due to rules regulating hospitality industry, but we can collect some other or same data for other purposes, primarily for contact, i.e.:

• realization of accommodation agreement;
• security of payment;
• fulfilment of legal requests and other statutory legal regulations regulating hospitality industry;
• for direct marketing;
• sending of offers;
• for improvement and personalization of services for you as a guest;
• for property protection and safety of individuals by usage of video surveillance.

Ananti warrants to use collected data only for the purposes above stated. Ananti can use depersonalized data for statistics.

USE OF PERSONAL DATA AND OTHER DATA

We use Personal Data and Other Data to provide you with services, to develop new offerings and to protect our guests. In some instances, we will request that you provide Personal Data or Other Data to us directly. If you do not provide the data that we request, or prohibit us from collecting such data, we may not be able to provide the requested Services.

1) PROVIDE THE SERVICES YOU REQUEST

We use Personal Data and Other Data to provide Services you request, including:

• To facilitate reservations, payment, send administrative information, confirmations or pre-arrival messages;
• To complete your reservation and stay, for example, to process your payment, ensure that your room is available and provide you with related customer service;
• To support our electronic receipt program. When you provide an email address in making a reservation, we use that email address to send you a copy of your bill. If you make a reservation for another person using your email address, that person’s bill will be emailed to you, as well. You can opt out of receiving your bill via email and instead receive a paper copy by contacting the front desk of the hotel.

We will use Personal Data and Other Data to manage our contractual relationship with you, because we have a legitimate interest to do so and/or to comply with a legal obligation.

2) PERSONALIZE THE SERVICES ACCORDING TO YOUR PERSONAL PREFERENCES

We use Personal Data and Other Data to personalize the Services and improve your experiences to:

• Present offers tailored to your Personal Preferences.

We will use Personal Data and Other Data to provide personalized Services according to your Personal Preferences either with your consent or because we have a legitimate interest to do so.

3) COMMUNICATE WITH YOU ABOUT SERVICES ACCORDING TO YOUR PERSONAL PREFERENCES

We use Personal Data and Other Data to:

• Send you marketing communications and promotional offers, as well as for a market research or quality assurance surveys.

We will use Personal Data and Other Data to communicate with you with your consent, to manage our contractual relationship with you and/or because we have a legitimate interest to do so.

4) BUSINESS PURPOSES

We use Personal Data and Other Data for data analysis, audits, security and fraud monitoring and prevention (including with the use of closed-circuit television, card keys, and other security systems), developing new goods and services, enhancing, improving or modifying our Services, identifying usage trends, determining the effectiveness of our promotional campaigns and operating and expanding our business activities.

We use Personal Data and Other Data in this way to manage our contractual relationship with you, comply with a legal obligation and/or because we have a legitimate interest to do so.

LEGAL BASIS FOR COLLECTIONS

Legal basis for stated collections is:

• Law;
• Accommodation agreement;
• Consent or explicit consent of the examinee, depending on the purpose of handling and type of personal data.

CONSENT AND RIGHT TO WITHDRAW YOUR CONSENT

When giving information to us, in any form (booking, contract, etc.), you guarantee that the information you provided is accurate, that you are legally competent and authorized to dispose of such information, and that you agree that we can use your data and collect them following the Law and terms and conditions of this Privacy policy.

If you have given us consent concerning particular processing or activities, you can withdraw your consent at any time by contacting us on reservations@ananti.me.

PERIOD OF DATA SAFEKEEPING

Ananti is obliged to keep safe the data collected based on the Law for as long as requested by certain law or other statutory legal regulation.

Data collected by Ananti based on contractual relations, will be kept only as long as necessary for fulfilment of contract i.e. for the providing of service.

Data on name, surname and e-mail address collected by Ananti based on legitimate interest for direct marketing will be kept in its guest database for 10 years.

Other data collected by Ananti based on explicit consent of the guest (mobile telephone number, number of children, marital status, pets, meanings of travelling, accommodation preferences) will be kept in its guest database for 5 years.

RIGHTS OF EXAMINEE

Regardless of the basis of data collection, you can ask at any time, free of charge, for the:

• access, you have right to know if your personal data are handled or not;
• amendment of data in all personal databases, after which we will amend your data in all its bases depending on your request;
• erasure (“right to be forgotten”) of personal data in all personal databases, after which we will erase you from all its bases, except from the bases which Ananti is obliged to hold and keep by statutory legal regulations, or in the event of more powerful legitimate reasons for handling or if handling is not necessary for submission, exercise, or defence of legal requests;
• limitation of handling of your data or file complaint on handling of such data;
• transfer of data on you collected by us to you or third parties (“right to data portability”), following statutory legal regulations;
• if data are given based on consent, you can withdraw this consent at any time without any negative consequences,
• right to file complaint to competent supervisor authority, the Agency for Personal Data Protection, with registered seat in Podgorica, Montenegro.

If you have any questions regarding our Privacy Policy, or described handling of your data, or doubt or complaint regarding implementation of this Policy, or if you wish to send a request for access to your personal data that Ananti has about you or for their erasure, you can send us your written request to the contact address: reservations@ananti.me or via postal service to address:

Ananti Resort, Residences & Beach club – Drobnici bb, 85310 Budva, Montenegro.

PERSONAL DATA COLLECTED FROM THE PERSONS BOOKING THE ACCOMMODATION

Your personal data, which you have to provide to receive accommodation services, Ananti, as data handler, keeps in its database only for fulfilment of accommodation agreement, and for fulfilment of its legal obligations, and for collecting of personal data related to hospitality industry, and is allowed to use them for other purposes by statutory legal regulations. If you fail to provide to Ananti necessary minimum of data required for the guest registration with all competent authorities, we will not be able to provide you with accommodation following the accommodation agreement and the Law.

Personal data, which Ananti registers upon the reservation and arrival to facilities, are collected based on the Law regulating hospitality industry and for service provision to guests. Those are following data (that can be changed by statutory legal regulations):

• name and surname;
• residence address (Montentgrin citizens);
• date of birth;
• number, type of ID and issuing place;
• citizenship;
• number of accommodation unit;
• date of arrival and departure of the guest;
• sex.

Ananti keeps the data in its guest database and sends them to a system (electronic system for guest registration) to competent authorities of Montenegro, and those data have to be kept in the system for 10 years. Also, we are obliged to keep all invoices issued to guests with personal data of the guest following law regulations.

Moreover, to fulfil of its contractual obligation, upon reservation and arrival to facilities, Ananti collects following information:

• e-mail;
• telephone number.

Other data connected to your staying, such as: means of traveling, marital status, number of children, pets, also can be collected if they have direct connection with providing accommodation.

Based on the legitimate interest, Ananti has rights to collect your personal data (name, surname, e-mail address) to its personal guest database and to use them for direct marketing, exclusively for notification on offers and news via e-mail. In such event, at any time and free of charge, you can ask for the erasure (“right to be forgotten”) from personal database for that purpose.

During and after your staying, we will send you to your mail address survey to evaluate the service provided to you (hereinafter referred to as: the “Survey”). Survey is filled out only with your consent. The primary purpose is collection of data on service for satisfaction survey improvement of service, and Ananti depersonalizes and handles data from the Survey for statistics purposes.

Additionally, person booking the accommodation, that is, a guest can give special permit, consent, to Ananti, to all his data, such as:

• name;
• surname;
• e-mail;
• date of birth;
• country;
• other personal data collected during staying (such as mobile number, sex, marital status, number of children, pets and activities during staying, means of traveling, accommodation preferences, etc.),

To collect and use for further profiling of examinees to contact and notify on special and personalized offers, news and events organized by Ananti via e-mail, web, internet promotion. In this event, the examinee has right to withdraw given consent at any time, which includes handling for profiling to the extent to which it is connected to such direct marketing, regarding initial or further handling, at any time and free of charge, as well as the right to change the data at any time, and right to be forgotten.

PERSONAL DATA COLLECTED VIA SUBSCRIPTION TO NEWSLETTER

In the event of subscription to newsletter, the examinee will have a possibility to give, with a consent, the following additional data (not including name, and surname, and e-mail address which we collect based on legitimate interest):

• sex;
• date of birth.

In the event of newsletter subscription update, the examinee will have possibility to give, with a consent, the following additional data:

• street, home number, postal code, city;
• mobile telephone number;
• means of traveling;
• pets;
• accommodation preferences.

Collected data are collected based on explicit consent to notify about special and personalized offers, news, and events organized by Ananti via e-mail, web, internet promotion. Data are kept in Ananti’s guest database for 10 years.

As the Examinee, you have right to change data and right to be forgotten. You have possibility to unsubscribe from mailing list, if you no longer wish to receive our newsletter.

PERSONAL DATA WE SHARE

To offer you the expected level of hospitality and to provide you with the best level of service, we may share your personal information among members of Ananti, our service providers, and other third parties.

SENSITIVE DATA

The term “sensitive data” refers to data related to your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, sex life, or sexual orientation, genetic information, criminal background, and any biometric data used for the purpose of unique identification.

We do not generally collect sensitive data unless it is volunteered by you or unless we are required to do so according to applicable laws or regulations. We may use health data provided by you to serve you better and meet your particular needs (for example, the provision of disability access).

PERSONAL DATA FROM CHILDREN

We do not knowingly collect personal data from individuals under 18 years of age. As a parent or legal guardian, please do not to allow your children to submit personal information without your permission.

LINKS TO THIRD-PARTY WEBSITES AND SERVICES

Our site may contain links to third parties’ websites. Please note that we are not responsible for the collection, use, maintenance, sharing, or disclosure of data and information by such third parties. If you provide information on and use third-party sites, the privacy policy and terms of service on those sites are applicable. We encourage you to read the privacy policies of websites that you visit before submitting personal information.

PROCEDURE IN THE EVENT OF PRIVACY POLICY VIOLATION

In the event of personal data violation, Ananti, as data handler, is obliged to inform competent authority on the violation of personal data, without necessary delay and, if possible, within 72 hours of learning about that violation, unless it’s unlikely that personal data violation will cause risk for rights of individuals.

Notification delivered to competent authority holds all the information following the Law. In the event of personal data violation that probably will cause high risk for rights of individuals, Ananti, as a data handler, will inform examinee on personal data violation without necessary delay. In cases when it is not legally obligatory, Ananti will not inform examinees.

TRANSPARENCY

This Privacy Policy is available on web page www.ananti.me as well as at reception desks of hotel.

If we decide to change its Privacy Policy, changes will be set and published on web page www.ananti.me as well as at reception desks of hotel.

SUNTIME D.O.O with its registered address at Drobnici bb, 85310 Budva, Montenegro, TIN: 02632934 is a legal owner of Ananti Resort, Residences & Beach club.