Privacy Policy

GKE Limited. is the processor and controller of the Personal Information (“Data Processor”/”Data
Controller”) in accordance with the applicable EU General Data Protection Regulation on personal
data protection.

About this Privacy Notice

This Privacy Notice (herein referred to as the “Notice”) explains what We do with your
Information, whether We are in the process of helping you with your business or personal request,
continuing Our relationship with you once We have entered an agreement with you and offered
You our services, received a service from You or You are visiting our website.
In essence, this Notice applies to the Information collected of all the parties we have dealings
with: Our website users, on-site visitors, guests, service providers, clients, (either directly engaged
or independent third party service providers, sponsors and other people browsing for
Presidence’s property accommodation or utilizing Presidence’s Services, herein referred to as
“You / Your / User/ Client / Guest / Sponsor / Third Party Provider” whom We may contact. It also
applies to Our staff (“Staff”).

This relates with Information collected, by all means, both online and offline; through Our website,
including but not limited to (herein the “Website”); through the software
applications, channel managers and booking tracking software made available by Us for use on or
through computers or mobile devices (the “Apps”); through Our social media pages and Apps to
which the Website links (collectively, Our “Social Media Pages”), through HTML-formatted email
messages that We send to You the link of this Notice, through Third Party Providers’ online
systems (e.g., online booking services and boards) (collectively, including the Website, Apps, Our
Social Media Page and Third Party Providers’ online systems, the “Online Systems”) and through
Information collected directly from You. This Notice also covers all other means than Our Online
Systems by which We collect Information (e.g., assessments, online booking systems, channel
management software, telephone or in person discussions, internal and external communication

This Notice is regularly reviewed and may be updated from time to time to reflect changes in Our
business or legal or commercial practice. Where an update is relevant to Our processing of Your
data We will notify You.

How do We collect Information?

We may collect Information in a variety of ways in order to support Our Services and carry on Our
business activity.
If you are a Guest or a Visitor, Personal Information might be contained in email, telephone,
booking or registration forms either directly or from any Third Party Providers to which we
subscribe (e.g., online booking engines, advertisements, social media, travel agencies), or direct
conversations you have with Us, on the ground of the legal basis of processing. From time to
time, We may also receive Personal Information about You from Third Party Service Providers, on
the grounds of quality assurance and feedback.

Where We have collected Personal Information by independent Third Party Providers without Your
knowledge, You may find specific Information regarding the source within the relevant sections of
this Notice or by directly contacting the Third Party Provider.

If You are a Third Party Provider or a Client with whom We have dealings, We may obtain Your
Personal Information from various sources like directly by You, including where Your have
provided Us with Your contact details or other Information for the purposes of using Your services
or rendering Our Services to You, Staff or other representatives of the organisation You represent,
Marketing databases, Social media, The public domain, Conversations with You or Others, on the
telephone or video conferencing (which may be recorded if you expressly agree) or in meetings,
Notes following a conversation, with You or others, or meetings You attend etc. If you are a Client/
Guest to whom We are engaged to, You should also refer to the relevant to the data protection
relevant sections on the service agreement You sign with Us.

Anywise, it is our obligation to advise You of the source We have obtained Your Personal
Information when We first communicate with You.

What Personal Information do We collect?

Presidence collects a range of Personal Information about You on legitimate purposes in the
course and pursuance of Our Services, as prescribed in this Notice.
This may indicatively include:
Your name, address, date of birth and contact details, including email address and telephone

Details of Your stay
● Credit/Debit Card Number
● Visa, passport and other documents to verify Your identity
● Contact details for guests other than You
● Other sensitive personal Information such as food and accommodation requests as long as
these are needed to make reasonable adjustments during the accommodation process
● Other data collected through online platforms of Third Party Providers
● Future travel plans, special requests, itinerary Information, and other private Information
● Information relating to Our relationship with You or the party for whom You work including
records of any meetings or discussions
● Your marketing preferences

Do We Collect Other Information collected through Our Sites and Apps?
Presidence’s and its Partners, Subsidiaries, Associates and Our Third Party Providers collect
Other Information that does not reveal Your specific identity in a variety of ways, including:
Using Cookies

From You

Information such as Your preferred means or time of communication is collected when You
voluntarily provide this Information. Unless combined with Personal Information, this Information
does not personally identify You or any other User of the Online Systems.
By aggregating Information

Aggregated Information does not personally identify You or any other User of the Online Systems.
For example, We may aggregate Information to gain analytics insights such as analyzing the
geographic distribution of the market segment of Our Services, market data etc. You are welcome
to search further Information regarding these matters within the relevant sections of this Notice.
As long as Other information is a non-identifier of Your personal identity, We lawfully may treat
them for any purpose.

How do We handle Your Social Logins

If You choose to register or log in to Our Website using a social media account, We may have
access to certain Information about You.

Our Online Systems offers You the ability to register and login using Your social media Third Party
Provider account details (like Your Facebook login). Where You choose to do this, We will receive
certain profile Information about You from Your social media Third Party Provider. The profile
Information We receive may vary depending on the social media provider concerned, but will
often include Your name, e-mail address, friends list, profile picture as well as other Information
You choose to make public. If You log in using Facebook, We may also request access to other
permissions related to Your account, such as friends and likes, and You may choose to grant or
deny Us access to each individual permission.

We will use the Information We receive only for the purposes that are described in this Notice or
that are otherwise made clear to You on the Online Systems. Please note that We do not control,
and are not responsible for, other uses of Your Personal Information by Your social media Third
Party Provider. We recommend that You review their privacy policy to understand how they
collect, use and share Your Personal Information and how You can set Your privacy preferences
on their sites and apps.

Why and How does Presidence process Information?

Presidence has legitimate purposes in processing Personal information for rendering its Services
and for keeping records of the process. We collect and use the Information from You which is
necessary for the purpose of Our legitimate interests as described in this Notice, in order to
support Our Services and Our related commercial activity. We use Your Information for:
Short and Long Term Real Estate Rental, Accommodation, Travel, Tourism, Leisure & HR Activities
We use Personal Information for rendering to You Services, using Your services for meeting our
engagements and fulfill Our contractual obligations.

We may use and process Information on the following legitimate basis:

In the course of providing Our Services, We use Information that We have collected concerning
Guests to identify and provide relevant Services that We think may be of interest. After explicit
consent, We may contact potential Guests from time to time regarding such Services.

Processing Information from Guests allows Us to manage the accommodation process, assess
and confirm Our Services. We may also collect Information about whether or not Guests need to
make reasonable adjustments to Our Services. We also use Information to confirm booking
requests and conduct quality and loyalty checks, as appropriate.

In this context, processing Information of Our Guests, allow us to take steps to fulfill Our
contractual obligations to them related to the Services we have been engaged to render and to
serve Our legitimate interests. We also use Information from Our Third Party Providers to support

Our activity.

We also need to process data to take steps for the purposes of Our internal recruitment purposes
(internal usage) preparing for Our Staff employment contracts, payrolling etc.
Importantly, for responding to Our obligations in respect to Our commercial activity and the
provision of Our Services, We may use Personal Information to respond and fulfill Your inquiries
and Your requests in regard both to Our Services and business activity. If You contact Us, We may
keep a record of Your contact Information and correspondence, and We may use any Information
You provide to respond to Your inquiry.

Business Activity

As part of carrying on Our business activity, we are called to use Personal Information to support
Our business activities, such as running internal audits, communicating internally regarding You,
determining the effectiveness of Our promotional activities, administering Our Services,
maintaining and securing Our infrastructure, and for procurement and financial transactions.

Marketing activities

After explicit consent, We may use your Personal Informational material such as Your e-mail from
time to time to conduct campaign and marketing campaign e-mails and to send informational
materials, such as articles, market trends, booking offers and other information regarding Our
Services. Also, by seeking and receiving Your consent, We may use Your Personal Information in
press releases and marketing materials. Please see the “Your Consent” section in this Notice
regarding how you can withdraw Your consent from being contacted for marketing purposes at
any time.

Administrative Purposes

We may from time to time use Information regarding the Online Systems, changes to Our terms,
conditions, and policies and/or other administrative Information. We may also contact You from
time to time to verify that the Personal Information We have collected about You is accurate and

Analytics, Aggregating & Historical Information

We may retain and use Information about You for market trend analyses purposes, generating
norms by level, geography etc., for monitoring accommodation statistics, conducting validation
studies, compiling reports, publishing articles, to generate norms by geography, level, etc. or for
purposes of improving Our Services, strengthening the knowledge base of Our market intelligence
or developing new services. We may further use Personal Information that We collect for purposes
of aggregating and disclosing diversity statistics and other statistical Information regarding the
hospitality market, on a lawful and legitimate interests basis as described in this Notice. We may
also process special categories of Information, such as ethnic origin, to monitor vacancy
statistics. For these purposes, We may also use Your name and other identifiers to associate and
combine Information about You that is collected from one Service with Information about You
collected through other Service. Any published end product will refer only to larger aggregations
of individuals and will not identify You personally or include any results attributable to You; such
aggregated or de-identified Information is considered Other Information for the purposes of this
Notice and We may use it for any purpose. Please see the related section of this Notice for further
details on Other Information we collect and process.

We may also process Personal Information that forms historical data for purposes of monitoring
and recording Our past business and recruitment activity on the lawful basis of Our legitimate
interests as prescribed and in accordance with this Notice.

Law compliance

We may use or disclose Your Personal Information in order to:
comply with applicable laws respond to inquiries or requests from public or government authorities, including those outsides of Your country of residence comply with valid legal process
protect the rights, privacy, safety or property of Presidence, Users of the Online Systems or the
public help us to establish, exercise or defend legal claims

We cannot and do not assume any responsibility for the actions or omissions of either Third Party
Providers or Clients, including the manner in which they use Personal Information received either
from Presidence or from other independent Third Party Provider.

Where do We collect and maintain the Information?
Your Information may be collected, used, processed, disclosed and transferred to any country
where We have commercial activity, facilities or in which We engage service providers. Even
though We will assess, monitor and pursue GDPR compliance for the service provider, By using
our Services or Online Systems, You consent to the transfer of Information to countries outside of
Your country of residence, which may have different data protection rules than in Your country.

Who has access to Information?

Your Information may be shared internally with Our Staff and externally with Our Subsidiaries,
Partners, Affiliates, Clients and Third Party Providers for the purposes of rendering Our Services.
External categories with whom We may share Your Personal Information for the provision of Our
Services include:

Subsidiaries, Partners, Affiliates, Third Party Service Providers
We may disclose Your Personal Information to Clients who have engaged Our Services:
In the course of Our Services, this includes members of Presidence and Hospitality teams and/or
interviewers involved in the assessment process. In the course of delivering Our Services, Your
Personal Information, including results of related data, can be shared with a Client/Partner that
have engaged Presidence to fulfill accommodation requests. In any case, We inform You who the
Client is and seek for Your consent before We forward You Personal Information to the Client.
Anonymized profiles and accommodation data may be sent to a Client without informing the
Guest or seeking their consent. This will only be done for statistical, quality assurance or historical

Assessment results and other Information collected by our Staff or provided by Our Client may be
maintained in Presidence database, to which our Client, and certain personnel designated by Our
Client will have access both during and after the conclusion of Our assignment. If You have
completed an assessment at Our Client’s request as part of our HR Services or related to a
Recruitment Service, We will not share Your assessment results with other Clients without
obtaining the appropriate consent.

We may contact former employers or any other source to obtain references for You and to make
necessary background checks

Any Affiliates, subsidiaries and strategic alliance partners, about which You are informed in this

Third Party Providers which We obtain support and services (e.g., hotel management services,
real estate agents, travel agencies, training institutions, technical online testing providers) and
process data on Our behalf, which may include:

– Outsourced software providers
– IT staff if access to the data is necessary for the performance of their role
– Legal and professional advisers
– Online technical testing providers

Any regulatory authority or statutory body pursuant to a request for Information or any legal
obligation which applies to Us

How do We Protect Your Information?

We take Our obligations in respect of the privacy of Your Information very seriously and will only
process Information for specified, explicit and legitimate purposes as detailed in this Notice
unless We inform You otherwise. In order to ensure that the Personal Information We hold about
You is accurate and up to date, We kindly request that You inform Us of any relevant changes.
We have internal policies and controls in place to ensure that Your Information is not lost,
accidentally destroyed, misused or disclosed, and is not accessed except by Our Staff in the
proper performance of their duties. We process Personal Information lawfully, fairly and in a
transparent manner in relation to You.

Information data will be stored in a range of different places, including on Your accommodation
record and on other Online systems (including email software, hotel channel management
systems and booking engines). Presidence has reasonable organizational, technical and
administrative measures in place to protect against the loss, misuse and alteration of Personal
Information about Users of the Online Systems which is under Our control. However please note
that, no security system, or system of transmitting Personal Information over the Internet,
cordless or mobile telephone and similar telecommunication and computer equipment can be
guaranteed to be 100% secure. Therefore, unless You utilize encryption and other forms of
security protection, You waive any action legal or otherwise against Presidence and hold the latter
harmless for any interception of Your Information resulting from the use of the above-mentioned

Nonetheless, If You have reason to believe that Your interaction with Us is no longer secure (for
example, if You feel that the security of any account You might have with Us has been
compromised), please immediately notify Us of the problem by contacting Us in accordance with
the “Q&A” section below

For how long does Presidence keep Personal Information?

Presidence will keep Your Personal Information for two (2) years from the last point of contact.
You can request to have Your data deleted earlier, which We will comply subject to the applicable
law. It is our policy to only store Your Personal Information for as long as is reasonably necessary
for Us to comply with Our legal obligations and for Our legitimate business interests. However, We
may retain data for longer than a two (2) year period where We have a legal or contractual
obligation to do so, or We form the view that there is otherwise a continued basis to do so, for
example where Your Personal Information identifies special requests, extraordinary feedback,
form historical or reporting Information about past business activity or We are subject to a legal
obligation which applies for a longer period. Such Information will not be used for any other
purposes and any wise their processing will comply with this Notice.

If Your application for direct employment (internal usage) is successful for becoming Our Staff,
Personal Information gathered during the search, selection & assessment process will be
transferred to Your Human Resources file (electronic and paper-based) and retained during Your
employment in Us. If you are a member of Our Staff, you should also refer to the Our Staff Data
Protection section which is available on the employment contract you sign with Us.

Where Information from Third Party Provider sources is of no use to Us We shall discard it,
however, We may maintain a limited record in order to avoid the duplication of process.
Where We consider that Information may be of use to Us in the process of providing of Our
Services, any processing will be in accordance with this Notice.