Privacy Policy

We respect your privacy. We are committed to safeguarding the privacy of our website visitors. www.gostels.com/ge/ website administration (hereinafter – «Website») is obliged to maintain your privacy on the Internet. Please read this document carefully as it sets out our «Privacy Policy» which informs you what we do with your Personal Data, whether we are providing you with news alerts or using your Personal Data as part of the research that we conduct for or statistical purposes. We pay great attention to securing the Data you provided to us. Our Privacy Policy is based on the Law of the Republic of Georgia of June 14, 2023, No. 3144- XIმს-Xმპ «On Protection of Personal Data» (Law No. 3144) (may for certain types of Personal Data processing, be subject to laws from other jurisdictions), and similar laws. The purposes, for which we collect your Personal Data are: improvement of our service, communication with visitors to this site, newsletters, presenting the information requested by the user, and for other actions listed below.

This Privacy Policy applies to the Personal Data of visitors anywhere in the world who access or use this Website.

The company responsible for your Personal Data is: ALFABET LABS FZCO, Unit №: O5-PF-CWC126, Detached Retail O5, Plot No: Level No 1, Jumeirah Lakes Towers, Dubai, United Arab Emirates (hereinafter – «us», «the Company»).

Personal Data storage and processing

We collect and process your Personal Data on the legal bases specified below. We obtain your consent where required by the Law No. 3144, including for newsletters and non- essential cookies involving the processing of Personal Data. Depending on the relevant circumstances and the laws and obligations that apply in your location, we may collect some or all of the information below:

• Name and surname;
• Contact details (such as your e-mail address or mobile number);
• Category to which you belong (consumer, supplier / company, or other);
• Date of birth;
• Additional information that you provide us voluntarily;
• Technical Data (e.g. the IP address, device information, log information, location information).

We do not knowingly collect information from visitors to this Website under the age of eighteen. If we become aware that a minor has provided information, it will be immediately deleted from ours databases.

How do we collect your Personal Data?

We collect your Personal Data largely in three ways:

1) Personal Data that you provide us with. You can share your Personal Data with us in multiple ways, such as:

• By proactively contacting us, usually by phone, e-mail, through our contact form or through social media; and / or
• Because we contact you, either by phone or by e-mail.
• By collecting information through the intervention of the (your) our representative.

We usually receive Personal Data such as your contact details, your name, the country of residence, your date of birth, etc.

2) Personal Data that we obtain from other sources. We may use other sources to obtain additional information about you, e.g. from third parties. An example of this is the information we via the Google Analytics tool. For example, Google Analytics Opt-out Browser Add-on can be found here. Usually, we so receive Personal Data such as information via a unique identifier (e.g. information about your activity on the Website).

3) Personal Data that we collect automatically. When you visit our Website, we collect technical Data by means of cookies such as the IP address your computer uses to connect to the internet, the type and version of your browser, your time zone setting, types and version of browser plugins, operating system and platform, including the type of mobile device you use, a unique device identifier, traffic Data, weblogs and other communication Data, and the resources that you access, and other technical information is saved in the database when you visit Website.

Purposes of processing Personal Data

We process the information submitted through our contact form to respond to your enquiry and discuss potential cooperation, based on our legitimate interests in managing business enquiries and developing business relationships, provided that these interests do not override your rights and interests. We process support requests to respond to your application for assistance. Technical Personal Data necessary for the operation and security of the Website are processed based on our legitimate interests in maintaining a functioning and secure Website. Newsletter subscriptions and non-essential cookies involving Personal Data are processed on the basis of your consent. Providing Personal Data through our forms is voluntary. However, without the information marked as required, we may be unable to respond to your enquiry or provide the requested subscription.

Principles for processing Personal Data

• The processing of Personal Data is carried out on a legal and fair basis.
• The processing of Personal Data is limited to the achievement of specific, pre-defined and legitimate purposes. Processing of Personal Data that is incompatible with the purposes of collecting Personal Data is not permitted.
• It is not allowed to combine databases containing Personal Data, the processing of which is carried out for purposes that are incompatible with each other.
• Only Personal Data that meets the purposes of their processing are subject to processing.
• The content and volume of Personal Data processed correspond to the stated purposes of processing. Redundancy of the processed Personal Data in relation to the stated purposes of their processing is not allowed.
• When processing Personal Data, the accuracy of Personal Data, their sufficiency, and, where necessary, relevance in relation to the purposes of processing Personal Data are ensured. The operator takes the necessary measures and/or ensures that they are taken to delete or clarify incomplete or inaccurate data.
• The storage of Personal Data is carried out in a form that makes it possible to identify the subject of Personal Data, no longer than required by the purposes of processing Personal Data, unless the period for storing Personal Data is established by Law No. 3144, an agreement to which the subject of Personal Data is a party, beneficiary or guarantor. The processed Personal Data is destroyed or anonymized upon achievement of the processing goals or in the event of the loss of the need to achieve these goals, unless otherwise provided by Law No. 3144.

The actions performed by the Company with received Personal Data

The Company collects, records, systematizes, accumulates, stores, refines (updates, changes), extracts, uses, transfers (distribute, provide, access), depersonalizes, blocks, deletes and destroys Personal Data.

The Company carries out automated processing of Personal Data with or without receiving and/or transmitting the received information via information and telecommunication networks.

The Company and other persons who have access to Personal Data are obliged not to disclose to third parties or distribute Personal Data without the consent of the subject of Personal Data, unless otherwise provided by Law No. 3144.

The Company's Sharing of Personal Data

We will share your Personal Data primarily to ensure we provide you with the most relevant and up to date news, content and events, or to ensure we can respond to any query quickly and expeditiously. The Company may share Personal Data with affiliated companies, service providers who act on our behalf, or others at your direction.

• Service Providers. The Company may engage third parties to act as our service providers and perform certain tasks on our behalf, such as processing or storing Data, including Personal Data, in connection with your use of our services and delivering products to customers (including external consultants, investor relations service providers and professional advisers such as lawyers, auditors and accountants, technical support functions and IT consultants carrying out testing and development work on our business technology systems). The Company service providers are obligated to handle Personal Data consistent with this Privacy Policy and according to our instructions.
• Tax, audit, or other authorities, when we believe that the law or other regulation requires us to share this Data (for example, because of a request by a tax authority or in connection with any anticipated litigation) or in order to help prevent fraud or to enforce or protect the rights and properties of the Company or its subsidiaries; or protect the personal safety of the Company employees, third party agents or members of the public.
• If the Company entity merges with or is acquired by another business or company in the future, we may share your Personal Data with the new owners of the business or company (and provide you with notice of this disclosure); and
• Circumstances may arise where, whether for strategic or other business reasons, the Company decides to sell, buy, merge or otherwise reorganise businesses in some countries. Such a transaction may involve the disclosure of your personal information to prospective or actual purchasers, or the receipt of it from sellers. It is the Company’s practice to seek appropriate protection for personal information in these types of transactions.

We do not share, rent or trade yourinformation with third parties for marketing or promotional purposes.

We may also disclose information about you where there is a lawful basis for doing so, if we determine that disclosure is reasonably necessary to enforce our terms and conditions or to protect our operations or users, or in the event of a reorganization, merger, or sale.

Data storage, alteration, and removal

The user, who has provided to the Company with their Personal Data, has the right for their alteration and removal, as well as the right to recall the agreement to Data processing. Time, during which your Personal Data will be stored is: time the Personal Data is used that is necessary for the Website’s main activity. We will not keep your Personal Data for longer than is necessary for the purposes for which we collect it unless we believe that the law or other regulation requires us to preserve it (for example, because of a request by a tax authority or in connection with any anticipated litigation). After finishing with the processing of your Personal Data, the Website’s administration will permanently delete it. To access your Personal Data, you can contact the administration on:support@gostels.com. We disclose Personal Data on the legal bases and for the purposes described in this Privacy Policy. Where required by the Law No. 3144, we notify recipients to whom we have disclosed your Personal Data of its rectification, update, completion, termination of processing, erasure or destruction, subject to the exceptions provided by the Law No. 3144.

Processing of visiting technical Data

Each time you use our Website, we may and often will automatically record your IP address, time of visit, browser settings, operational system, including the type of mobile device you use, a unique device identifier (for example, mobile network information, your mobile operating system, the type of mobile browser you use, device token, device type, time zone setting), traffic Data, weblogs and other communication Data, and the resources that you access, and other technical information is saved in the database when you visit Website. This Data is necessary for the correct display of the Website’s content and help us to better understand user behavior. Technical Data may constitute Personal Data where it relates to an identified or identifiable individual, including where identification is possible by combining it with other information.

Children’s personal information

If you are a parent or a legal guardian of an underage child, and you know that the child has provided us with their personal information, please contact us on: support@gostels.com. It is forbidden to enter Personal Data of underage users.

Marketing

We use your e-mail address to send newsletters and information about our products only if you subscribe and consent to receiving these communications. Submitting a business enquiry does not subscribe you to marketing communications.

You may withdraw your consent at any time, free of charge, by clicking the unsubscribe link in any marketing e-mail or by contacting us at support@gostels.com.‍We will stop processing your Personal Data for direct marketing as soon as reasonably possible and no later than 7 (seven) working days after receiving your request.

We retain your subscription data until you withdraw your consent or we discontinue the newsletter, whichever occurs first. We retain a record of the date and fact of your consent and its withdrawal throughout the direct marketing activity and for 1 (one) year after it ends, as required by the Law No. 3144.

Cookies processing

We use cookie files for the correct display of the Website’s content and for the convenience of browsing Website. They are small files, that are stored on your device. They help the Website to remember information about you, such as in which language you use the Website and which pages have you already opened. This information will be useful in the next visit. Thanks to cookie files, the Website’s browsing becomes much more convenient. You can set up cookies reception and blocking in your browser yourself. Inability to receive cookie files may limit the functionality of the Website.

Alternatively, you may wish to visit an independent source of information, www.aboutcookies.org, which contains comprehensive information on how to alter settings or delete Cookies from your computer as well as more general information about Cookies. For information on how to do this on the browser of your mobile phone, you will need to refer to your handset manual or network operator for advice.

What are the different types of cookies?

• Strictly Necessary.

These cookies are essential in order to enable you to move around the Website and use its features, such as accessing secure areas of the Website. They allow you to navigate back and forth between pages without losing your previous actions from the same session. Since these cookies are necessary for the functionality of our Website, we do not need to ask for your consent to use them.

• Functional.

Functional cookies remember your preferences, such as your selected language or region. Where these cookies are not strictly necessary and involve the processing of Personal Data, we use them only with your prior consent.

• Performance.

Performance and analytics cookies help us understand how visitors use the Website and improve its performance. These cookies may involve the processing of Personal Data, including online identifiers and information about your activity on the Website. Where they involve Personal Data, we use them only with your prior consent.

• Persistent cookies.

These cookies remain on your device when you close your Internet browser, and they are reactivated each time you visit the Website that originally generated this type of cookie.

• Session cookies.

These cookies are not permanently stored on your device. They are used to enhance your browsing experience on a Website, for example by enabling you to switch between websites without needing to log back in. Closing your Internet browser deletes all session cookies from your computer.

• Flash cookies.

These cookies are installed by websites that feature multimedia content; this requires Adobe Flash to be displayed. These speeds up the rate at which you can download content and save information.

Most browsers accept and maintain Cookies by default. Check the «Help» or «Setting» menu of your browser to learn how to change your Cookie preferences. You can choose to alter Cookies settings related to the use of our Website, but this may limit your ability to access certain areas of the Website.

Links to other websites

Our Website may contain links to other websites, which are not under our control. We are not responsible for the content of these websites. We recommend you familiarize yourself with the privacy policy of every website that you visit, if such policy exists.

If you decide to access the linked third-party websites, you do so at your own risk. We do not accept liability, and shall not be liable to you for any loss or damage arising from or as a result of your acting upon the contents of another website to which you may link from the Website.

Changes to the Privacy Policy

We may change this Privacy Policy from time to time and without notice. If we make significant changes in the way we treat your Personal Data, or to the Privacy Policy, we will endeavour to provide you notice through the Website or by some other means, such as e-mail. Your continued use of the Website after such notice constitutes your understanding of the changes. We encourage you to periodically review this Privacy Policy for the latest information on our privacy practices.

If your Personal Data, and more specifically, your contact information was entered incorrectly, we will not be able to contact you.

Security Precautions

We care about protecting your information. That's why we put in place appropriate measures that are designed to prevent unauthorised access to, and misuse of, your Personal Data.

We are committed to taking all reasonable and appropriate steps to protect the personal information that we hold from misuse, loss, or unauthorised access. We do this by having in place a range of appropriate technical and organisational measures, including encryption measures and disaster recovery plans.

Unfortunately, there is always risk involved in sending information through any channel over the internet. You send information over the internet entirely at your own risk. Although we will do our best to protect your Personal Data, we cannot guarantee the security of your Data transmitted over the internet and we do not warrant the security of any information, including Personal Data, which you transmit to us over the internet.

If you suspect any misuse or loss of or unauthorised access to your personal information please let us know immediately. Please raise your concern by contacting us using the Contact us section of the Website, in the first instance, and we will investigate the matter and update you as soon as possible on next steps.

Your rights

You have several rights regarding the Data that we process about you. These are explained in more detail below.

• Right to object.

You can always inform us of the special reasons why you wish to object to the processing of your Personal Data that is based on the public interests or legitimate interests. If these reasons outweigh these interests, we can stop processing. If we process your Personal Data to send e- mail notifications, you can always ask us to stop doing so without having to provide a special reason.

• Right to withdraw consent.

If the processing of your Personal Data for certain activities is based on your consent, you can withdraw this consent at any time. We will stop using your Data for that purpose.

• Right of access.

You can ask us at any time to obtain information about whether or not to process your Personal Data and, if necessary, request a copy of the relevant categories of Personal Data that we process about you, as well as the other information. We will respond to your request for information, access or copies within 10 (ten) working days of receiving it. In special cases, where duly justified, this period may be extended by up to a further 10 (ten) working days, and we will notify you immediately of the extension. Information about the processing of your Personal Data is provided free of charge. Access and copies are also provided free of charge, except where a fee is permitted by the Law No. 3144.

• Right to erasure.

In certain circumstances you have the right to request that we «delete» your Personal Data. This is described in more detail in the Law No. 3144.

• Right to restriction ofprocessing.

You have the right to request us to restrict your Personal Data in certain circumstances in line with the relevant articles providing for such right set out in the Law No. 3144 or other applicable laws, e.g. if you dispute the accuracy of the Personal Data we hold about you. A restriction of processing means that we may only temporarily store your Data unless you give permission to process your Data, in the context of a legal claim or in the public interests and legitimate interests. A restriction can be lifted afterwards. We will of course notify you before we lift any restrictions on the processing of your Personal Data.

• Right to rectification.

You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.

• Right to Data portability.

In some cases, you can legally transfer your Personal Data to other service providers. In essence, this means that you can transfer the Data we hold about you to another third party. To this end, we provide you with your Data in a common and machine-readable format that enables you to transfer the Data. Another option is that we transfer the Data directly for you if this is technically possible. For more information about this right, see the Law No. 3144.

• Right to file a complaint.

If you believe that the processing of your Personal Data violates the Law No. 3144, you have the right to lodge a complaint with the State Audit Office of Georgia and/or seek judicial protection before a competent court. You do not have to contact us before exercising these rights.

Feedback and final clauses

You can contact the Website administrationregarding any questions related to Privacy Policy on: www.gostels.com/ge/privacy, or by filling a contact form specified in a corresponding section of this Website. If you do not agree with this Privacy Policy, you cannot use the Website. In this case you should avoid visiting our Website.