Personal Data Protection Policy

1. SC NEOCONSTRUCT COMSERV SRL’S COMMITMENT TO PROTECTING PRIVACY

Because we consider you an important customer, our first priority is to offer you exceptional
times and stays at our hotel property.
Your complete satisfaction and confidence in SC NEOCONSTRUCT COMSERV SRL are
absolutely essential to us.
That is why, as part of our commitment to meeting your expectations, we have set up a
customer privacy protection policy. This Charter formalizes our commitments to you and
describes how SC NEOCONSTRUCT COMSERV SRL uses your personal data.
The main rules are founded on seven principles.

2. CONSENT

”Personal data” means any information collected and logged in a format that allows you to
be identified personally, either directly (e.g. name) or indirectly (e.g. telephone number) as a
natural person. Before providing us with this information, we recommend that you read this
document describing our customer privacy protection policy.
This Personal Data Protection Charter forms part of the terms and conditions that govern our
hotel services. By accepting these terms and conditions, you expressly accept the provisions
of this Charter.

3. SC NEOCONSTRUCT COMSERV SRL’S SEVEN PRINCIPLES FOR PROTECTING
YOUR PERSONAL DATA

The seven principles below are applicable throughout the world.
Transparency: When collecting and processing your personal data, we will communicate all
information to you and inform you of the purpose and recipients of the data.
Legitimacy: We will collect and process your personal data only for the purposes described
in this Charter.
Relevance and accuracy: We will only collect personal data that is necessary for data
processing. We will take all reasonable steps to ensure that the personal data we hold is
accurate and up to date.
Storage: We will hold your personal data for the period necessary for processing the same in
compliance with the provisions of the law.
Access, rectification, opposition: You may access, modify, correct or delete your personal
data. You may also oppose the use of your personal data, particularly to avoid receiving
sales and marketing information. The details of the department to contact in this respect are
via gdpr@athinasuiteshotel.com
Confidentiality and security: We will ensure reasonable technical and organizational
measures are in place to protect your personal data against alteration or accidental or
unlawful loss, or unauthorized use, disclosure or access.
Sharing and international transfer: We may share your personal data within SC
NEOCONSTRUCT COMSERV SRL or with third parties (such as commercial partners

and/or service providers) for the purposes set out in this Charter. We will take appropriate
measures to guarantee security when sharing or transferring such data.
For any questions concerning the seven principles of SC NEOCONSTRUCT COMSERV
SRL GDPR, please contact us by our mail address gdpr@athinasuiteshotel.com

4. SCOPE OF APPLICATION

This Charter applies:
To all data processing implemented in our subsidiary and managed hotel, i.e. those
operating under SC NEOCONSTRUCT COMSERV SRL (Athina Suites Hotel) This list is
regularly updated.
To SC NEOCONSTRUCT COMSERV SRL reservation website, including
www.athinasuiteshotel.com .
5. WHAT PERSONAL DATA IS COLLECTED?
At various times, we will be obliged to ask you, as an SC NEOCONSTRUCT COMSERV
SRL customer, for information about you and/or members of your family, such as:
Contact details (for example, last name, first name, telephone number, email)
Personal information (for example, date of birth, nationality)
Information relating to your children (for example, first name, date of birth, age)
Your credit card number (for transaction and reservation purposes)
Your arrival and departure dates
Your preferences and interests (for example preferred floor, type of bedding, etc.)
Your questions/comments, during or following a stay in one of our establishments.
The information collected in relation to persons under 18 years of age is limited to their
name, nationality and date of birth, which can only be supplied to us by an adult. We would
be grateful if you could ensure that your children do not send us any personal data without
your consent (particularly via the Internet). If such data is sent, you can contact the Data
Privacy department to arrange for this information to be deleted.
We do not deliberately collect sensitive information, such as information concerning race,
ethnicity, political opinions, religious and philosophical beliefs, union membership, or details
of health or sexual orientation.
Moreover, depending on applicable local laws, other information could be considered
sensitive, such as your credit card number, your leisure activities, personal activities and
hobbies, and whether or not you are a smoker. We may be obliged to collect such
information in order to meet your requirements or provide you with an appropriate service,
such as a specific diet.
In this case, depending on the laws in force in certain countries, your prior consent may be
required with regard to the collection of sensitive information.

6. WHEN IS YOUR PERSONAL DATA COLLECTED?

Personal data may be collected on a variety of occasions, including:
Hotel activities:
Booking a room

Checking-in and paying
Eating/drinking at the hotel bar or restaurant during a stay
Requests, complaints and/or disputes.
Participation in marketing programs or events:
Signing up for loyalty programs
Participation in customer surveys (for example, the Guest Satisfaction Survey)
Online games or competitions
Subscription to newsletters, in order to receive offers and promotions via email.
Transmission of information from third parties:
Tour operators, travel agencies, GDS reservation systems,online travel agencies,destination
management companies,event organizers and others.
Internet activities:
Connection to SC NEOCONSTRUCT COMSERV SRL website (IP address, cookies)
Online forms (online reservation, questionnaires, SC NEOCONSTRUCT COMSERV SRL
pages on social networks, network login devices such as Facebook login etc.).
7. FOR WHAT PURPOSES?
We collect your personal data for the purposes of:
Meeting our obligations to our customers.
Managing the reservation of rooms and accommodation requests:
Creation and storage of legal documents in compliance with accounting standards.
Managing your stay at the hotel:
Monitoring your use of services (telephone, bar, restaurant,etc.)
Managing access to rooms
Internal management of lists of customers having behaved inappropriately during their stay
at the hotel (aggressive and anti-social behavior, non-compliance with the hotel contract,
non-compliance with safety regulations, theft, damage and vandalism, or payment incidents).
Improving our hotel service, especially:
Processing your personal data in our customer marketing program in order to carry out
marketing operations, promote brands and gain a better understanding of your requirements
and wishes
Adapting our products and services to better meet your requirements
Customizing commercial offers and the promotional messages we send to you
Informing you of special offers and any new services created by SC NEOCONSTRUCT
COMSERV SRL or one of its subsidiaries.
Managing our relationship with customers before, during and after your stay:
Managing the loyalty program
Providing details for the customer database
Segmentation operations based on reservation history and customer travel preferences with
a view to sending targeted communications
Predicting and anticipating future behaviors
Developing statistics and commercial scores, and carrying out reporting
Providing context data for the offer push tool when a customer visits a Group website or
makes a reservation
Knowing and managing the preferences of new or repeat customers
Sending you newsletters, promotions and tourist, hotel or service offers, or offers from SC
NEOCONSTRUCT COMSERV SRL partners, or contacting you by telephone

Managing requests to unsubscribe from newsletters, promotions, tourist offers and
satisfaction surveys
Taking into account the right to object
Using a dedicated telephone service to search for persons staying in SC NEOCONSTRUCT
COMSERV SRL hotel in the event of serious events affecting the hotel in question (natural
disasters, terrorist attacks etc.).
Use a trusted third party to cross-check, analyze and apply certain devices to your collected
data at the time of booking or at the time of your stay, in order to determine your interests
and your customer profile, and to allow us to send you personalized offers.
Improving SC NEOCONSTRUCT COMSERV SRL services, especially:
Carrying out surveys and analyses of questionnaires and customer comments
Managing claims/complaints
Offering you the benefits of our loyalty program.
Securing and enhancing your use of SC NEOCONSTRUCT COMSERV SRL website,
especially:
Improving navigation
Implementing security and fraud prevention.
Conforming to local legislation (for example, storing of accounting documents).

8. CONDITIONS OF THIRD-PARTY ACCESS TO YOUR PERSONAL DATA

a. In order to offer you the best service, we can share your personal data and give access to
authorized personnel and external service providers from SC NEOCONSTRUCT COMSERV
SRL, including:
Hotel staff
Reservation staff using SC NEOCONSTRUCT COMSERV SRL reservation tools
IT departments
External Service provider of hotel management and sales & marketing management – SC
Iconik Hospitality SRL
Commercial partners and marketing services
Medical services if applicable
Legal services if applicable
Generally, any appropriate person within SC NEOCONSTRUCT COMSERV SRL entities for
certain specific categories of personal data.
b. With service providers and partners: your personal data may be sent to a third party for
the purposes of supplying you with services and improving your stay, for example:
External service providers: IT sub-contractors, international call centers, banks, credit card
issuers, external lawyers, dispatchers, printers.
Commercial partners: SC NEOCONSTRUCT COMSERV SRL may, unless you specify
otherwise to the Data Privacy department, enhance your profile by sharing certain personal
information with its preferred commercial partners. In this case, a trusted third party may
cross-check, analyze and apply certain devices to your data. This data processing will allow
SC NEOCONSTRUCT COMSERV SRL and its privileged contractual partners to determine
your interests and your customer profile, and will allow us to send you personalized offers.
Social networking sites: In order to allow you to be identified on the website without the need
to fill out a registration form, SC NEOCONSTRUCT COMSERV SRL has put the Facebook
& Google login system in place. If you log in using the Facebook or Google login system,
you explicitly authorize SC NEOCONSTRUCT COMSERV SRL to access and store the

public data on your Facebook and Google account, as well as the other data mentioned
during use of the Facebook and Google login system. SC NEOCONSTRUCT COMSERV
SRL may also communicate your email address to Facebook or Google in order to identify
whether you are already a Facebook or/and Google user, in order to post personalized and
relevant ads on your Facebook and Google account if appropriate.
c. Local authorities: We may also be obliged to send your information to local authorities if
this is required by law or as part of an inquiry and in accordance with local regulations.

9. PROTECTION OF YOUR PERSONAL DATA DURING INTERNATIONAL TRANSFERS

For the purposes set out in Clause 7 of this Charter, we may transfer your personal data to
internal or external recipients who may be in countries offering different levels of personal
data protection.
Consequently, in addition to implementation of this Charter, SC NEOCONSTRUCT
COMSERV SRL employs appropriate measures to ensure secure transfer of your personal
data to an SC NEOCONSTRUCT COMSERV SRL entity or to an external recipient located
in a country offering a different level of privacy from that proposed in the country where the
personal data is collected.
Other than those that are required to carry out your reservation, dataflows to countries
having different levels of personal data protection are regulated by standard contractual
manager-to-subcontractor clauses defined by the European Commission. Dataflows to the
United States are made to entities that belong to Safe Harbor.

10. DATA SECURITY

SC NEOCONSTRUCT COMSERV SRL takes appropriate technical and organizational
measures, in accordance with applicable legal provisions, to protect your personal data
against illicit or accidental destruction, accidental alteration or loss, and unauthorized access
or disclosure. To this end, we have taken technical measures (such as firewalls) and
organizational measures (such as a user ID/password system, means of physical protection
etc.).
When you submit credit card data when making a reservation, SSL (Secure Socket Layer)
encryption technology is used to guarantee a secure transaction.

11. COOKIES

Use of cookies by SC NEOCONSTRUCT COMSERV SRL
You are advised that the company SC NEOCONSTRUCT COMSERV SRL uses cookies or
other tracers on its online booking site and official website www.athinasuiteshotel.com
These tracers may be installed on your device depending on the preferences that you
expressed or may express at any time in accordance with this policy.
1. Why have a cookies policy?
With a view to provide information and ensure transparency, SC NEOCONSTRUCT
COMSERV SRL established this policy so that you can learn more about:

The origin and purpose of the information processed when you browse SC
NEOCONSTRUCT COMSERV SRL website.
Your rights with regard to cookies and other tracers used by SC NEOCONSTRUCT
COMSERV SRL.
2. What is a cookie?
Cookies and other similar tracers are packets of data used by servers to send status
information to a user's browser and return status information to the original server through
this same browser.
The status information can be a session identifier, a language, an expiration date, a
response field or other types of information.
During their validity period, cookies are used to store status information when a browser
accesses various pages of a website or when the browser returns to this website at a later
point.
There are different types of cookies:
Session cookies, which are deleted as soon as you exit the browser or leave the website
Persistent cookies, which remain on your device until their expiration or until you delete them
using the features of your browser
3. Why use cookies?
We use cookies and other tracers primarily for the following purposes:
Cookies strictly necessary for browsing the SC NEOCONSTRUCT COMSERV SRL website
and the ability to use all of their features, and intended in particular to:
Manage authentication of website visitors and the associated security measures, and ensure
proper functioning of the authentication module
Optimize the user experience and facilitate browsing, in particular determining "technical
routes" for browsing
Store information regarding the "cookies" information banner seen by website visitors who
then continue to browse the website after agreeing to accept cookies on their device
Implement security measures (for example, when you are asked to log in again for content
or a service after a certain period of time, or to ensure basic operation of SC
NEOCONSTRUCT COMSERV SRL website and use of their major technical features, such
as monitoring of performance and browsing errors, management of user sessions, etc.)
Cookies for features intended in particular to:
Adapt SC NEOCONSTRUCT COMSERV SRL website to the display preferences of your
device (language, currency, display resolution, operating system used, configuration and
settings of the display of web pages based on the device you are using and its location, etc.)
Store specific information that you enter on SC NEOCONSTRUCT COMSERV SRL website
in order to facilitate and customize your subsequent visits (including displaying the visitor's
first and last names if the visitor has a user account)

Allow you to access your personal pages more quickly by storing the login details or
information that you previously entered
Cookies for visitor tracking are aimed at improving the comfort of users by helping us
understand your interactions with SC NEOCONSTRUCT COMSERV SRL website (most
visited pages, applications used, etc.); these cookies may collect statistics or test different
ways of displaying information in order to improve the relevance and usability of our
services.
Advertising cookies are intended to (i) offer you, in advertising spaces, relevant, targeted
content that may be of interest to you (best offers, other destinations, etc.) based on your
interests, browsing behavior, preferences, and other factors, and (ii) reduce the number of
times that the advertisements appear.
Affiliate cookies identify the third-party website that redirected a visitor to SC
NEOCONSTRUCT COMSERV SRL website.
Social network cookies, set by third parties, allow you to share your opinion about and
content from SC NEOCONSTRUCT COMSERV SRL website on social networks (for
example, the "Follow" application buttons for social networks).
The social network applications on SC NEOCONSTRUCT COMSERV SRL websites as
mentioned above can in some cases allow the social networks concerned to identify you
even if you did not click on the application button. This type of button can allow a social
network to track your browsing on SC NEOCONSTRUCT COMSERV SRL website, simply
because your account in the social network concerned is enabled on your device (open
session) while you are browsing.
We recommend that you read the policies of these social networks to familiarize yourself
with how they use the browsing information they may collect, especially with regard to
advertising. These policies must specifically allow you to make choices on these social
networks, particularly by configuring your user accounts for each of them.
4. Consent
The installation of certain cookies is subject to your consent. Also, when you first visit the SC
NEOCONSTRUCT COMSERV SRL website, you are asked whether you agree to the
installation of this type of cookie, which is only activated after your acceptance.
This process is supported by means of an information banner on the homepage of the SC
NEOCONSTRUCT COMSERV SRL website, which informs you that by continuing to
browse, you are agreeing to the installation of cookies that require consent on your device.
You can change your mind at any time using the various methods described in section
”Deleting and/or blocking cookies”.
5. Deleting and/or blocking cookies
You have several options for deleting cookies and other tracers.

Browser settings
Although most browsers are set by default to accept cookies, you can, if you desire, choose
to accept all cookies, always block cookies, or choose which cookies to accept based on
their senders.
You can also set your browser to accept or block cookies on a case-by-case basis before
they are installed. Your browser also allows you to regularly delete cookies from your device.
Remember to configure all the browsers in your different devices (tablets, smartphones,
computers, etc.).
Regarding management of cookies and your preferences, configuration varies for each
browser. This is described in the Help menu of your browser, as well as how to edit your
preferences with regard to cookies. For example:
For Internet Explorer™: http://windows.microsoft.com/en-US/windows-vista/Block-or-allow-
cookies
For Safari™: http://www.apple.com/legal/privacy/en-ww/cookies
For Chrome™:
http://support.google.com/chrome/bin/answer.py?hl=en&hlrm=en&answer=95647
For Firefox™: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-
preferences
For Opera™: http://help.opera.com/Windows/10.20/en/cookies.html
Saving a cookie to your device depends on your wishes, which you can exercise and change
at any time and free of charge using the settings offered by your browser software.
If your browser is set to accept cookies on your device, the cookies embedded in the pages
and content that you view may be temporarily stored in a dedicated space on your device.
They can only be read by their issuer.
However, you can set your browser to block cookies. Keep in mind that if you set your
browser to block cookies, some features, pages and spaces on SC NEOCONSTRUCT
COMSERV SRL website will not be accessible, and we cannot be held responsible in this
case.

Specialized advertising platforms
Several professional advertising platforms also give you the option to accept or block
cookies used by companies that are members. These centralized mechanisms do not block
the display of ads; they simply prevent the installation of cookies that tailor ads to your
interests.
For example, you can visit the website http://www.youronlinechoices.com to prohibit the
installation of these cookies on your device. This website is offered by digital advertising

professionals brought together within the European Digital Advertising Alliance (EDAA) and
managed in France by Interactive Advertising Bureau France.

12. STORAGE OF DATA

We retain your personal data only for the period necessary for the purposes set out in this
Charter or in accordance with the provisions of applicable law.

13. ACCESS AND MODIFICATION

You have the right to access your personal data collected by SC NEOCONSTRUCT
COMSERV SRL and to modify it subject to applicable legal provisions.
You may also exercise your right to object by writing to the address below.
In the event of difficulty exercising your rights, we have designated responsibility for data
protection compliance to a suitable individual within the organization. Mr. Athanasios Tzakos has
been appointed as Data Protection Officer (DPO). If you have any questions about our
preparation for the GDPR, please contact gdpr@athinasuiteshotel.com
Or mail at the following address:
Athina Suites Hotel
Mihai Eminescu Street Nr. 92-94,Bucharest,Romania
Tel: +40311019067
For the purposes of confidentiality and personal data protection, we will need to identify you
in order to respond to your request. SC NEOCONSTRUCT COMSERVSRL ’s may request a
copy of your national ID card, driving license, passport, birth certificate and a utility bill not
older than three months. A minimum of one piece of photographic ID listed above and a
supporting document is required. If SC NEOCONSTRUCT COMSERV SRL is dissatisfied
with the quality, further information may be sought before personal data can be released.
If your personal data is inaccurate, incomplete or not up to date, please send the appropriate
amendments to the Data Privacy representative as indicated above.
You can request the following information:
– Contact details of the data protection officer, where applicable.
– The purpose of the processing as well as the legal basis for processing.
– If the processing is based on the legitimate interests of SC NEOCONSTRUCT COMSERV
SRL or a third party such as one of its clients, information about those interests.
– The categories of personal data collected, stored and processed.
– Recipient(s) or categories of recipients that the data is/will be disclosed to.
– How long the data will be stored.
– Details of your rights to correct, erase, restrict or object to such processing.
– Information about your right to withdraw consent at any time.
– How to lodge a complaint with the supervisory authority (Data Protection Regulator).
– Whether the provision of personal data is a statutory or contractual requirement, or a
requirement necessary to enter into a contract, as well as whether you are obliged to provide
the personal data and the possible consequences of failing to provide such data.
– The source of personal data if it wasn’t collected directly from you.
– Any details and information of automated decision making, such as profiling, and any

meaningful information about the logic involved, as well as the significance and expected
consequences of such processing.
All requests will receive a response as swiftly as possible and in accordance with applicable
law.
Under GDPR you have ‘The Right to be Forgotten’ where you as a customer can, at any
time, request that we remove all your personal information from our system. However it is
important to remember that any Right to be Forgotten request does not override requirement
to hold information under any other legislation, for example, you cannot request for financial
records to be destroyed that you undertook in the last 7 years within SC NEOCONSTRUCT
COMSERV SRL’s hotels.
At any point whilst SC NEOCONSTRUCT COMSERV SRL is in possession of or processing
your personal data, all data subjects have the following rights:
Right of access – you have the right to request a copy of the information that we hold about
you.
Right of rectification – you have a right to correct data that we hold about you that is
inaccurate or incomplete.
Right to be forgotten – in certain circumstances you can ask for the data we hold about you
to be erased from our records.
Right to restriction of processing – where certain conditions apply you have a right to
restrict the processing.
Right of portability – you have the right to have the data we hold about you transferred to
another organisation.
Right to object – you have the right to object to certain types of processing such as direct
marketing.
Right to object to automated processing, including profiling – you also have the right
not to be subject to the legal effects of automated processing or profiling.
You may also exercise your rights in respect of your personal data that is stored and
processed by a hotel following a stay. To do this, you must contact the hotel directly.

14. UPDATES

We may modify this Charter from time to time. Consequently, we recommend that you
consult it regularly, particularly when making a reservation at our hotel.

15. QUESTIONS AND CONTACTS

For any questions concerning the SC NEOCONSTRUCT COMSERV SRL ’s personal data
protection policy, please contact gdpr@athinasuiteshotel.com