Data Protection Policy

Our privacy is paramount to Columbia Hotels & Resorts LTD. This privacy policy demonstrates our firm commitment to your privacy and the protection of your information.

Personal intormation and data is collected wen vou access and use our weste, make a booking on our weese, or realster win us. Il

proceaures ana protocols wnent comes tolne storade ara disciosure or sala personal intonation.

Here below, you can tina information about our policy regarding the protection or personal data, our use or cookies, and the security policy that we tollow in sateguarding your privacy.

To protect your privacy and personal information, Columbia Hotels & Resorts LTD confirms that:

Columbia Hotels & Resorts LTD will not loan, rent or sell to any third parties any personal details that have been passed on to us without

. wnat intormaton do we collect and now is it used or snared

If you have registered to receive our newsletter your e-mail address is only available to us for the distribution of the newsletter and not forwarded to any other third parties. Personal information provided by you when making an online reservation on our website, is shared only with our reservations department to facilitate the process (hereinafter referred to as "personal data") which includes:

•Your name, email address, physical address, phone number, date of birth, country location, and payment card information (to the extent this information is provided by you;

• InTormation relatine to vour memoersnio in one or our services or oroorammes.

• Information about how you use our website, products, and services; and
• Information made during the course of your reservation, such as your preferred suite type and specific requests to the Resort.

2. For what purpose might this personal data be used?

i. Registering you as a new user of our services and managing our relationship with you as a registered user; il. Providing our reservation services for our Resort and facilities to you;

ili. Internal analysis purposes;

iv. To the extent that you have consented to being contacted for marketing purposes, we will use your personal data to provide you with email newsletters, surveys, and any other communication for the purposes of advertising and marketing of our services as well as providing you with targeted advertisements on our website or third-party websites; for a list of these, please email dpo@columbiaresort.com

v. Maintaining legal records and accounts for the time periods required by European/Cyprus law or where needed to comply with a legal or

regulatory obligation, and

vI. wnere is necessary. to establish ana/or exercise our leamate interests or nose or a tira-parv. and vour interests and tundamenta

rants do not override inose interests.

3. How might your personal data be disclosed?

We may have to share your personal data internally to the extent that is necessary for the purposes for which the personal data was collected, and with some third-party companies under specific contract terms in accordance with the applicable laws, whose services we employ to conduct our business or in relation to any supply of products and services by us; for a list of these, please email dpo@columbiaresort.com.

Disclosure of your personal data may also be required in order to comply with any applicable laws.

In the instances where you have consented to the use of your personal data tor the purposes of advertising and/or marketing, we may share your personal data with third-party online service providers* who may be located outside of the EEA.

Whenever we transfer your personal data outside of the EEA, we ensure a similar degree of protection is afforded to it, and that all third parties respect the security of your personal data and treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

4. Is personal data used for marketing communications?

Yes, as previously mentioned, but we will only send you marketing emails that you have signed up for. You can opt out of our advertising and

marketine communications al any time ov any or ine tollowine meinods.

i. Selecting the UNSUBSCRIBE link included in our emails;

ii. Editing your Columbia Hotels & Resorts LTD website account profile to change your communication preferences;

i. Contact our Data Protection Unricer via emal at apol@columblaresort.com

5. How long is personal data retained?

We will only retain your personal data for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements. Information you provide to us will remain in our records for a period not less than 2 years and not more than 6 years in accordance to the Data Protection Act (DPA) REGULATION (EU) 2016/679.

6. Are changes to the data protection and privacy policy made available for review?

Definitely. If we decide to change our data protection and privacy policy, we will post any details of said changes on our website, and we will notify you, to ensure that you always know how we use the information we collect and under what circumstances we disclose it to others.

7. What are your legal rights?

Duty to inform us or changes

It is important that the personal data that we hold about you is accurate and current. Please keep us informed if your personal data changes at any time.

Rights in connection with personal data:

Under certain circumstances, you nave the rignt by law to:

• Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data that we hold about you and to check that we are lawfully processing it;
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected;

• Request erasure or your personal data. Inis enables you to ask us to delete or remove personal data where there is no good reason tor us to continue processina it. you also nave tne rant to ask us to delete or remove vour personal data were vou nave exercised vour rant to

ob ecuto processing (see below).

• Object to processing of your personal data. In some cases, we may demonstrate that we have compelling legitimate grounds to process your intormation, which override your rights and treedoms;
• Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal information about you if we no longer require it to establish, exercise, or defend legal claims; and

• Request the transfer of your personal data to another party.

It you want to review, verity, correct or request erasure of your personal data, object to the processing of your personal data, or request that we transfer a copy of your personal data to another party, please contact our Data Protection Officer at dpo@columbiaresort.com.

8. Our Data Protection Officer

We have a data protection officer (DPO) to oversee compliance with this privacy policy. If you have any questions about this privacy notice or how we handle your personal information, please contact the Data Protection Officer at dpo@columbiaresort.com. You have the right to make a complaint at any time to the Data Protection Commissioner's Office, the Republic of Cyprus' supervisory authority for data protection issues

9. Cookies

What is a cookie? A cookie is a small amount of data that a website places on your computer.

Why do websites use cookies? Web pages have no memory. If you are surfing from page to page within a website, you will not be recognised as the same user across pages. Cookies enable your browser to be recognised by the website. So cookies are mainly used to remember the choices you have made - choices such as the language you prefer and the currency you use. They will also make sure you are recognised when you return to a website.

Do all cookies do the same thing? No, there are different types of cookies and different ways of using them. Cookies can be categorised

cocorn to unem danction, ten mesoan and accorame to wno places tem on a weesile

How does Columbia Hotels & Resorts LTD use cookies? We try to give our visitors an advanced and user-friendly website that adapts automatically to their needs and wishes. lo achieve this, our website uses the tollowing types of cookie:

• Technical cookies: We use technical cookies to show you our website, to make it function correctly, to create your user account, to sign you in and to manage your bookings. Absolutely necessary for our website to operate properly.
• Functional cookies: We also use functional cookies to remember your preferences and to help you to use our website efficiently and effectively, for example by remembering your preferred currency and language, your searches and the accommodation you viewed earlier.
  Not strictly necessary for the functioning of our website, but are extra functionalities that enhance your experience.

• Analvtics cookies: We use these cookies to aain insiaht into how our visitors use the website. to find out what works and what doesn't, to optimise and improve our website and to ensure we continue to be interesting and relevant. The data we gather includes which web pages

information and details such as the number of clicks you make on a given page, your mouse movements and scrolling activity, the search

words use dna tre text you lyde wale using bur wewsile.

• Commercial cookies: We use these to show you Columbia Beach Resort advertisements on other websites. This is called "retargeting" and it aims to be based on the destinations you have been searching for and the accommodation you have viewed.

How long do Columbia Hotels & Resorts LTD cookies stay active? The cookies we use have varying lifespans. The maximum lifespan we set on some of them is tive years trom your last visit to our website. You can erase all cookies trom your browser any time you want to. lo remove columbiaresort.com cookies from your browser, go to the following link (please note that when you click on this link, all Columbia Beach Resort

cookles will de removed immediatelv)

How can you recognise Columbia Hotels & Resorts LTD cookies? You can find our cookies in your browser settings.

Does Columbia Hotels & Resorts LTD use third-party cookies? Yes, Columbia Hotels & Resorts LTD uses the services of trusted and recognised online advertising and marketing companies. Columbia Hotels & Resorts LTD may also use third-party providers for analytical purposes. To enable their services, these companies need to place cookies. The providers we use are committed to building consumer awareness and establishing responsible business and data management practices and standards.

Who has access to Columbia Hotels & Resorts LTD cookie data? Only Columbia Hotels & Resorts LTD has access to www.columbiaresort.com cookies. Cookies placed by third parties can be accessed by these third parties.

How can you manage your cookie preferences? Using your browser settings in, for example, Internet Explorer, Safari, Firefox or Chrome, you

can ser which cookies to accept and wich to relect. where vou tina tnese settinas depends on which browser vou use. Use the HelD function in your browser to locate the settings you need. If you choose not to accept certain cookies, you may not be able to use some

Tuncuons on our weste. And opting out or an online aversing network does not mean tat you wil no tonger receive or be suprect to online advertising or marketing analysis. It means that the network from which you opted out will no longer deliver ads tailored to your web prelerences dna Drowsine dallels

Does Columbia Hotels & Resorts LID use web beacons! As well as using cookies, Columbia Beach Resort sometimes uses web beacons. A web beacon is a tiny graphic image of just one pixel that's delivered to your computer either as part of a web page request or in an HTML

emal message. arner airectv or nroan service providers, we use inese pixes as part or our online advertisements ener on our wepsite o on third-party websites to learn whether a user who is being shown an online advertisement also makes a reservation; to track conversion

win partner weosites ana to analyse une tame pallems or users to opumise une wavel-relalea services we brine lo you

10. Security Policy

Your security is of paramount importance. Columbia Hotels & Resorts LTD and its partners use recognised SL (secure socket layer) encryption technology to safeguard your information. We review our information collection, storage, and processing practices, including physical security measures, to guard against unauthorised access to systems; and we restrict access to personal data to Columbia Hotels & Resorts LTD employees, contractors, and agents on a need-to-know basis for processing purposes, who are subject to strict contractual confidentiality obligations, using the latest encryption technology.

This Privacy Policy was created on: Friday, July 19th, 2015 and updated 23rd May 2018. Should we update, amend or make any changes to our privacy policy, those changes will be posted here.

* Processors:

Newsletter service: Mailchimp

Hotel Management System: Fidelio

Online reservations system: Profitroom