Privacy Notice & Cookie Policy

[Last Updated: April 10, 2023]

This Privacy Policy (“Privacy Policy”), is an integral part of our Terms of Use (“Terms”), and governs the processing of information by Fattal Hotels Ltd. (“Fattal”, “we”, “us” or “our”) while you (“you”) access, use or interact with our Website available at: https://www.fattal.co.il/ (“Website”) and when you sign up for and use any of our services, including, inter alia, booking a reservation to one of our hotels (“Services“).
Any capitalized terms not defined herein shall have the meaning ascribed to them in the Terms or in the applicable Privacy Laws.
Fattal may update or revise this Privacy Policy from time to time, modifications to this Policy will be posted on Fattal Website.
This Privacy Policy explains how the data is collect, used or shared with others, how it is safeguarded and how an individual may exercise their lawful rights related, among others, and where applicable, as required according to the applicable privacy regulation including the EU General Data Protection Regulation (“GDPR”) and the Israeli Privacy Protection Law, 1981 and the regulations promogulated under.

1) APPLICABILITY
The Privacy Policy applies to our Customers and Visitors (collectively “you”), as further detailed herein:
“Customer” shall mean an individual, business, or other legal entity purchasing the Fattal Services through the Website or through other means. Any and all Customers shall be over 18 years old.
“Visitor” shall mean any individual browsing the Fattal Website.

2) CONTACT DETAILS OF THE CONTROLLER
The “Fattal” shall mean:
Fattal Hotels Ltd. a company registered under the law of Israel, together with its subsidiaries and affiliated companies,
registration number 510678816,
Address: 94 Yigal Alon St., Tel-Aviv, Israel,
Email: info@fattal.co.il
Phone: 03-5110016/7
For GDPR purposes, Fattal is the Data Controller of the Personal Data collected from you (“Controller”);

EU Data Protection Representative “DPR” for EU data subjects:
Sunflower Management GmbH & Co KG
Address: Landsberger Allee 117A 10407 Berlin.
Phone number: +49 (0) 30 – 688 322 0
Email address: info@leonardo-hotels.com

Other:
If you have any questions or comments about this Privacy Policy, or any concerns with respect to how your privacy any information are handled, please contact our privacy team at: info@fattal.co.il or through the designated forms available on the Website.

3) WHICH DATA DO WE COLLECT AND FOR WHAT PURPOSE?
“Non-Personal Data”: means non-identifiable, aggregated data, that is mainly technical data which is transmitted to us by your device when you access and interact with our Website, such as the type of browser, type of operation system, type of device used, the time and date you access the Website, navigation, language preference, etc. Non-Personal Data is used mainly for click stream analysis in order to provide, maintain, develop and enhance our Website and the services that may be provided therein (if applicable), and is not used to identify individuals. Under this Privacy Policy, we can use any aggregated, statistical, and anonymized data, which can no longer be associated with any individual with no limitation, even if such anonymized data was derived from Personal Data. Such data may be included in our proprietary information and does not deem as Personal Data under the law.
“Personal Data”: means information which identifies or may identify, with reasonable effort, an individual, including, inter alia, your name, address, phone number, billing information and online identifiers (such as IP address or Cookie ID).
Please see below the table which specifies the Personal Data we collect and how we use it:

Please note that, the actual processing operation per each purpose of use and lawful basis detailed in the table above, may differ. Such
processing operation usually includes set of operations, made by automated means, such as collection, storage, use, disclosure by transmission, erasure or destruction. Transfer of personal data to third party countries as further detailed in the Data Transfer section is based on the same lawful basis as stipulated in the table above.
In addition, we may use certain Personal Data to prevent potentially prohibited or illegal activities, fraud, misappropriation, infringements, identity thefts and any other misuse of Website and to enforce the Terms, as well as to protect the security or integrity of our databases and Website, and to take precautions against legal liability. Such processing is based on out legitimate interests.

4) Cookies Usage
Like many other websites, the Website and parts of our System use cookies to improve your experience while you navigate the Website. We may use various types of Cookies:
• Essential Cookies – which are necessary for the site to work properly (usually appears under our name/cookie tag);
• Functional Cookies – designated to save your settings on the site – your language preference or other view preferences (also, under our name/cookie tag);
• Session Cookies – used to support the Website’s functionality – such Cookies are stored only temporarily during a browsing session and are deleted from your device when you close the browser.
• Targeting Cookies – these cookies are used to collect information from you to help us improve our products and services and serve you with targeted advertisements that we believe will be relevant to you (e.g., Google’s Cookies).
• Social networks Cookies – Social Plug-In Cookies (e.g., Facebook, Twitter, LinkedIn Cookies, or pixels, etc.) enable sharing your usage information with your social network’s accounts.
• Analytics Cookies – give us aggregated and statistical information to improve the Website and System and further developing it e.g., Google analytics, Google Firebase Catalytic, etc.
• Third-party services used by us – for example, an external service supporting our recruiting options through the Website (e.g., Comet or Workday), or an external service which allows us to screen short videos on our Website (e.g., YouTube or Vimeo).

Please note that the data collected by the use of Cookies may be linked to and combined with any other data, including Personal Data.

In addition, Cookie’s data is usually collected through the use of third-party services, like Google, Facebook, etc. In those cases, your Personal Data might be transferred to those third parties, which might link it and use it together with other information they have on you from other sources. Such data is “owned” and processed separately by those third-parties under their terms and conditions and the direct accounts or subscriptions you have with those third parties. For example, suppose you have a Facebook account, the Personal Data collected through Facebook’s Cookies on the Website might be linked to other data that Facebook collects from you as a Facebook user, and might be used by Facebook per the independent agreements between you and Facebook.

For additional information regarding Cookies usage please refer to our Cookies banner on the Website.

5) HOW WE COLLECT INFORMATION
According to the nature of your interaction with Website, we may collect information as follows:
• Automatically – we may use cookies and similar tracking technologies (as elaborated in the Cookies Section below) to gather some information automatically when you access the Website.
• Provided by you voluntarily – we will collect information if and when you choose to provide us with information, such as through a checkout process or when you contact us through the online form.
• Provided to us by third parties – as part of our digital marketing efforts as described hereunder.

6) DATA SHARING – CATEGORIES OF RECIPIENTS WE SHARE PERSONAL DATA WITH
We share your data with third parties, including with trusted partners or service providers that help us provide our Services and improve the Website:

Where we share information with service providers and partners, we ensure they only have access to such information that is strictly necessary in order for us to provide the Services. These parties are required to secure the data they receive and to use the data for pre-agreed purposes only, while ensuring compliance with all applicable data protection regulations.

7) DATA TRANSFER
Any information you provide us may be transferred to and processed in countries other than the country from which you accessed the Website. If you are a resident of the European Economic Area (“EEA”) we will take appropriate measures to ensure that your Personal Data receives an adequate level of data protection upon its transfer outside of the EEA. If you are a resident of a jurisdiction where the transferring of your Personal Data requires your consent, then your consent to this Privacy Policy includes your express consent for such data transfer.

8) USER RIGHTS
You may have certain rights regarding the Personal Data that Fattal has collected about you.
We acknowledge that different people have different privacy concerns and preferences. Our goal is to be clear about what information we collect, so that you can make meaningful choices about how it is used. We provide you with the ability to exercise certain choices, rights and controls in connection with your information. Depending on your relationship with Fattal (e.g., if you are a Visitor of our Website or a Customer), data protection and privacy laws provide you with some of the following principal rights regarding your Personal Data, including (and depending on your jurisdiction): The right to access your Personal Data that we process; The right to ensure your Personal Data is accurate, complete and up to date; The right to have your Personal Data amended (by correcting, deleting or adding information); The right to object to the processing of your Personal Data, to the extent applicable; The right to send or “port” your Personal Data; The right to file a complaint with a supervisory authority in your jurisdiction; The right to withdraw consent, subject to legal or contractual restrictions and reasonable notice; Right to Non-Discrimination, etc.
You may exercise any or all of your above rights in relation to your Personal Data by contacting us by mail: info@fattal.co.il.
Where we are not able to provide you with the information for which you have asked, we will endeavor to explain the reasoning for this and inform you of your rights, including the right to complain to the supervisor authority (in the event you are EEA resident). We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any such information in accordance with applicable law.

9) RETENTION
We retain Personal Data we collect as long as it remains necessary for the purposes set forth above, all in accordance with applicable laws or until an individual requests to opt-out of such collection. We may at our sole discretion, delete or amend information from our systems, without providing any notice to you, once we deem it is no longer necessary for our purposes.

10) SECURITY
We implement extensive security measures to reduce the risks of damage, loss of information and unauthorized access or misuse of Personal Data. We implement appropriate data collection, storage and processing practices and security tools to protect personal data against unauthorized access, alteration, disclosure or destruction. You should be aware that no security measures are completely fail-proof, and it is impossible to prevent any and all threats to the security of data and systems. Therefore, you should be aware that any processing of digital Personal Data holds certain inherent risks, and we cannot guarantee that our services and databases will be immune to any wrongdoings, malfunctions, unauthorized interceptions or access, malware attacks or other kinds of abuse and misuse.

11) CHILDREN
Our System and Website are not directed, nor is it intended for use by children (the phrase “child” shall mean an individual that is under age defined by applicable law which concerning the European Economic Area (“EEA “) is under the age of 16 and with respect to the U.S.A, under the age of 13) and we do not knowingly process a child’s information. We will discard any information that we receive from a user who is considered a “child” immediately upon our discovery that such a user shared information. Please contact us if you have reason to believe that a child has shared any information with us.