Privacy Policy

Welcome to the Villa Lazuli's privacy policy.

Villa Lazuli respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

1.     Important information and who we are

Purpose of this privacy policy

This privacy policy aims to give you information on how Villa Lazuli collects and processes your personal data through your use of this website, including any data you may provide through this website when you make a booking, request any further information using our contact form or sign up to our newsletter.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

Controller

Villa Lazuli is the controller and responsible for your personal data (referred to as "Villa Lazuli", "we", "us" or "our" in this privacy policy).

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact us in the following ways:

Email address: charlotte@21centuryleaders.org

Telephone number: +971 (0)58 552 3765

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated on 8th December 2020.  

Third-party links

This website may include links to third-party websites. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

2.     The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

·       Identity Data includes you first name, last name or similar identifier, title and gender.

·       Contact Data includes your address, your email address and telephone numbers.

·       Financial Data includes you bank account and payment card details.

·       Transaction Data includes the details about payments to and from you and other details of services you have booked from us.

·       Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.

·       Usage Data includes information about how you use our website and our services.

·       Marketing and Communications Data includes your preferences in receiving information and marketing from us and our third parties and your communication preferences via Newsletters.

We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a booking you made with us but we will notify you if this is the case at the time.

3.     How is your personal data collected?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity, Contact and Financial Data by filling in our Occupation Agreement or Booking form on our website, or by corresponding with us by phone or email. This includes personal data you provide when you:

·       book a stay with us;

·       subscribe to our Newsletter; or

·       give us feedback or contact us.

Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.

Third parties or publicly available sources. We will receive personal data about you from various third parties, like Technical Data from analytics providers such as Google Analytics.

4.     How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

·       where we need to perform the contract we are about to enter into or have entered into with you;

·       where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; and

·       where we have you consent to do so (e.g. to send you information and marketing emails). You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one (1) lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one (1) ground has been set out in the table below.

Purpose/Activity

To register your booking

 

To manage our relationship with you which will include notifying you about changes to our terms or privacy policy

 

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

 

To use data analytics to improve our website, our services, our marketing, customer relationships and experiences

Type of data

(a) Identity

(b) Contact

(c) Financial Data

(d) Transaction Data

(a) Identity

(b) Contact

 

(a) Identity

(b) Contact

 

Technical

 

(a) Technical

(b) Usage

Lawful basis for processing including basis of legitimate interest

Performance of our contract with you; and

Necessary for our legitimate business interest

 

(a) Performance of our contract with you;

(b) Necessary to comply with our legal obligation; and

(c) Necessary for our legitimate interests (i.e. to keep our records updated and to study how customers use our services)

 

(a) Necessary for our legitimate interests (i.e. for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise).

 

Necessary for our legitimate interests (i.e. to define types of customers for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

Promotional offers from us

We may use your Identity, Contact, Technical and Usage Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you.

You will receive marketing communications from us if you have requested information from us provided you do not opt out of receiving that marketing information.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out

You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you OR by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of your booking with us.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy.