The private limited company VILLON (company code 110004884, address Ežeraičių str 2, Ežeraičiai, Vilnius district municipality, Republic of Lithuania, tel. +37052739700, email firstname.lastname@example.org, hereinafter – the Company).
Processed Personal Data and their sources
The Company processes the following personal data of Yours: name, surname, place of residence (only upon registration at the hotel), e-mail address, telephone number, age (year of birth) (only upon registration at the Golfbox system), sex (only upon registration at the Golfbox system),
which are submitted by You to the Company in order to use the Company’s services, upon completing the registration form at the hotel, the registration form at the SPA centre, the registration form for the green card courses, the golf club membership agreement, the registration form at the Golfbox system, the loyalty card issuance form, the newsletter order form, including other ways of providing Your personal data to the Company under legitimate grounds. Your personal data may be submitted to the Company by the organizer of Your accommodation, if You order the hotel accommodation service not by Yourself but through another company, organization.
The Company processes the image of Yours which is recorded upon Your arrival at Vilnius Grand Resort complex, by means of video monitoring in the public areas of Vilnius Grand Resort with video surveillance cameras.
The Company also processes the personal data of Yours (name, surname, telephone number, e-mail address), which You provide in order to receive newsletters of Vilnius Grand Resort by e-mail or to use the Company’s loyalty card.
The compulsory nature of the submission of data and the consequences of failure to submit
You are obliged to provide complete and correct personal data. This is necessary in order to conclude or execute the agreement already concluded with You (regarding the accommodation service, the golf club’s service, the SPA centre’s service). In case of failure to provide personal data for the purposes referred to above, the Company will not be able to properly execute the agreement with You.
Purposes and legal grounds of processing of Personal Data
The Personal Data are processed in the Company for the following purposes:
• to identify You when entering into agreements with the Company on the provision of services;
• to provide You with accommodation services, golf club’s services, SPA centre’s services, to contact You for the purpose of provision of services (for adjusting the service booking time, etc.);
• to fulfil contractual obligations and for other purposes relating to the performance of agreements, to solve problems relating to the provision of services;
• for the identification purposes when You use Your loyalty card;
• to contact You for left items;
• for direct marketing purposes (to offer and / or request opinions on goods and services offered to individuals);
• to inform You on the Company’s holidays, events and discounts, service offers and other news;
• to ensure the safety of employees and guests of Vilnius Grand Resort complex, the security of the Company’s property (video data from surveillance cameras, sound recording at the hotel reception);
• to claim, enforce and defend legal requirements;
• to comply with statutory obligation (e. g., financial obligations) in issuance of financial documents;
• for other legitimate purposes related to the above-mentioned purposes.
Legal grounds of processing of personal data:
• Your consent to the use of Personal Data or a consequential conclusion that You have agreed with Your Personal Data being used for a specific purpose;
• the concluded or implemented agreement in which You are one of the parties (registration forms at the hotel, at the SPA complex or at the golf club completed and signed by You constitute contractual documents);
• the legitimate interest of the Company or a third party receiving the Personal Data, which requires processing of Personal Data, unless the legitimate interests and the main rights and freedoms of Yours which require the protection of Personal Data prevail over it (e. g. the collection of image data by video surveillance cameras is justified by the legitimate interest of the Company in ensuring the safety of the employees, the guests of complex, the security of the Company’s property);
• the necessity to fulfil the legal obligation imposed on the Company (e. g., the obligation to archive documents prescribed by law, the obligation to keep financial documents for tax purposes, the obligation to submit data to public authorities, etc.).
Use of Personal Data for direct marketing purposes
The Company also processes Your data for direct marketing purposes:
• sends newsletters to Your e-mail address with the Company’s news about current events, discounts, latest offers / advertisement of goods / services, asks for customers’ opinions on the products and services offered;
• offers You discounts if You are registered in the Company’s Loyalty Program.
Your Personal Data will be stored and used for direct marketing purposes only if:
• You have submitted Your data on the Company’s website and have agreed to receive the Company’s newsletters and special offers by e-mail indicated by You;
• in Vilnius Grand Resort registration forms, You have indicated that You agree to receive the Company’s newsletters and special offers by e-mail indicated by You;
• in Vilnius Grand Resort registration forms, You have indicated that You agree with the Company contacting You by phone indicated by You for direct marketing purposes;
• in the registration form of the Vilnius Grand Resort Loyalty Program You have indicated that You agree to receive the Company’s news on the Loyalty Program, the Company’s newsletters and special offers by e-mail indicated by You;
If You give Your explicit consent to Your Personal Data being used for direct marketing purposes, the Company may use Your data to analyse and improve the effectiveness of its websites, advertising and market researches, as well as other marketing and sales purposes of the Company.
You have the right to require:
• the Company to introduce You with Your Personal Data being processed, to inform You about what Personal Data of Yours are processed, what sources they are received from, for what purposes and how they are processed, who they are provided to;
• the Company to correct or supplement incorrect, incomplete, inaccurate Personal Data of Yours and / or limit the processing of such Personal Data, except for storage;
• the Company to destroy (delete) the illegally collected Personal Data of Yours or to stop processing of such Personal Data, except for storage.
• to receive Personal Data relating to You, which You have submitted to the Company, and to forward those data to another data controller.
You have the right to disagree with processing of Your Personal Data for direct marketing purposes and You have the right not to disclose reasons for such disagreement.
You have the right to cancel the given consent for the processing of Personal Data at any time. In this case, Your Personal Data will be immediately destroyed, except in cases where Personal Data must be protected in compliance with the statutory obligation, in cases where the controller’s legitimate interests are superior to Your interests, rights and freedoms, or in order to claim, execute or defend legal requirements.
Data storage periods
For direct marketing purposes, for loyalty program purposes – 10 years from the time of receipt of Your consent to process the data (or from the moment of receipt of data, when the consent is optional);
for the purpose of sending newsletters – as long as newsletters are sent, and 1 month after the person’s refusal to receive newsletters, however, not more than 10 years;
for the purpose of performance of the agreement – as long as the agreement is in force, and 10 years after the termination of the agreement, for the purpose of conclusion of the agreement – from the first contact with the potential client to the conclusion of the agreement, or, in the absence of the agreement, for 1 year;
In case of pursuit to claim, enforce or defend legal requirement, Your Personal Data may be processed for as long as necessary in those cases.
Transfer of Personal Data to third parties
The Company may transfer Your data only to the following third parties:
• to the Company’s data processors – server providers, website administrators, persons responsible for the creation and sending of newsletters; persons responsible for the administration of databases and information systems used by the Company;
• to public authorities or law enforcement agencies, if such data are required by law on a legitimate basis.
The Company does not transfer Your Personal Data to third countries (outside the European Union).
Examination of requests and complaints
You have the right to submit requests relating to Your rights established in the present Policy, as well as claims and complaints regarding unauthorised processing of Personal Data or possible violation of Your rights to the Company at the address Ežeraičių str 2, Ežeraičiai, Vilnius district municipality, Republic of Lithuania, or by e-mail email@example.com. You also have the right to submit Your complaints to the State Data Protection Inspectorate at the address A. Juozapavičiaus str 6, 09310 Vilnius.