Privacy Policy
We are pleased that you are visiting our homepage and thank you for your interest in our company.
Dealing with our customers and interested parties is a matter of trust. The trust placed in us is very
important to us and therefore the importance and obligation to handle your data carefully and to pro-
tect them from misuse.
With these notes on data protection, we inform you about when we store which data and how we use
it - naturally in compliance with the applicable legislation. Data protection at AZIMUT Hotels is based
in particular on the European General Data Protection Regulation (GDPR) and the Federal Data Protec-
tion Act (BDSG).
Overview
Responsible
Data Protection Officer
Legal basis of the data processing
Providing the website
Contact/E-Mail contact
Online booking via the website
Online booking via other websites
Newsletterservice
AZIMUT Loyalty-Program
Business customers
Online evaluation and surveys
Application for a job advertisement
Cookies
Webanalysis
Use of Social Plugins
Facebook-Fanpage
Integration of third-party services and content
Purposes of the processing of personal data
Voluntary information
Recipient / transfer of data
Data processing outside the European Union
Protection of minors
Rights of the data subject
Deletion of data
Security
Right of appeal to a supervisory authority
Amendment of this privacy policy
Responsible
Responsible for this website is:
AZIMUT Hotels Company LLC, Olympiyskiy prospect 18/1, Moscow, 129110 Russia
Tel: +7(495)994 44 50, Mail: info@azimuthotels.com
Data Protection Officer
The data protection officer of the Responsible is:
Berit Schubert, DataSolution LUD GmbH, Isarstr. 13, D-14974 Ludwigsfelde, Germany,
Tel.: +49 (0) 3378 205729, Mail: mail@hoteldatenschutz.de
Legal basis of the data processing
In order to be able to oer you our website and the associated services, we process personal data on
the basis of the following legal basis:
– consent (Art. 6 Abs. 1 lit. a) GDPR)
– for the fullment of contracts (Art. 6 Abs. 1 lit. b) GDPR)
– on the basis of legimate interest (Art. 6 Abs. 1 lit. f) GDPR)
– for the fullment of legal obligaons (Art. 6 Abs. 1 lit. c) GDPR)
We will refer to the relevant terms in connecon with the respecve processing, so that you can clas-
sify on which basis we process personal data.
If personal data are processed on the basis of your consent, you have the right to revoke this consent
at any me with eect for the future.
If we process data on the basis of a legimate interest, you as the data subject have the right to object
to the processing of personal data, taking into account the provisions of Art. 21 DSGVO.
Providing the website
Personal data is processed when you visit our website in order to be able to display the contents of
the website on your terminal device.
In order for the pages to be displayed in your browser, the IP address of the terminal device used by
you must be processed. Addional informaon about the browser of your mobile device is also re-
quired.
We are obliged under data protecon law to also guarantee the condenality and integrity of the
personal data processed with our IT systems.
For this purpose and out of this interest, the following data is recorded on the basis of a weighing of
interests:
– IP address of the calling computer (for maximum 7 days)
– Operang system of the calling computer
– Browser version of the calling computer
– Name of the retrieved le
– Date and me of retrieval
– data volume transferred
– Referring URL
The IP address will be deleted aer 7 days at the latest from all systems used in connecon with the
operaon of this website. We can then no longer establish a personal reference from the remaining
data. The data is also used to idenfy and correct errors on the website.
Contact/E-Mail contact
We offer a contact form on our website, which you can use to request information about our prod-
ucts or services or to contact us in general. We have marked the data that is absolutely necessary for
you to answer an inquiry as mandatory. Information on other data fields is voluntary.
We need this information in order to process your request, to address you correctly and to send you
an answer. The data processing is carried out in the case of concrete inquiries for the fulfilment of a
contract or the initiation of a contract. In the case of general enquiries, the processing is based on
our legitimate interest.
Enquiries received via the contact form on our website are processed electronically by us in order to
respond to your request. In this context, other persons or departments and possibly third parties
may also become aware of the contents of the form you have sent. Die Übermittlung der Formular-
Daten über das Internet erfolgt über verschlüsselte Verbindungen.
Online booking via the website
When enquiries/bookings are made and during the stay in the hotel, inventory data required for mu-
tual, proper fulfilment of the contract. These include: Salutation, first name and surname, address,
street and city, date of birth, telephone numbers and/or e-mail addresses, payment data (credit card),
data on services.
When you make a booking, it will be processed through the TravelClick, Inc. online reservation system,
address: 7 Times Square, 38th Floor, New York, USA. All the booking data you enter is transmitted in
encrypted form. Our contract partner has committed itself to handling your transmitted data in ac-
cordance with data protection laws. It takes all organizational and technical measures to protect your
data.
The data is used exclusively for the processing of the booking and for communication.
In order to increase our services, we manage all received data in the CRM system of Hotels-BI. The
hotel in which the booking is made is responsible for this. The respective booking data is transferred
from the hotel software to the CRM system and can only be viewed by the responsible party and cen-
tral functionalities. Together, the access to the master data of a guest is used, for example, to make a
reservation for another hotel at a later date, to rebook or to carry out marketing activities centrally.
Central services such as reservation and marketing access this data.
Online booking via other websites
AZIMUT Hotels gives interested parties the opportunity to book rooms and arrangements through ho-
tel reservation portals (third-party providers). If a user takes advantage of this opportunity, the data
entered in the input mask is transmitted to us and stored to the extent permitted by the respective
hotel reservation portal in accordance with its own data protection regulations. Data can be: first
name, surname, e-mail address, telephone, address, number of fellow travellers, estimated time of
arrival, requests, payment data (credit card).
The data provided is transferred to our hotel software via a so-called channel manager. All received
booking data are transmitted encrypted. TravelClick, Inc., address: 7 Times Square, 38th Floor, New
York, USA as provider of the channel manager has committed itself to handling the transmitted
personal data in a data protection-compliant manner. It takes all organizational and technical
measures to protect your data.
The data will be used exclusively for processing the booking and, if necessary, for communication.
In order to increase our services, we manage all received data in the CRM system of Hotels-BI. The
hotel in which the booking is made is responsible for this. The respecve booking data is transferred
from the hotel soware to the CRM system and can only be viewed by the responsible party and cen-
tral funconalies. Together, the access to the master data of a guest is used, for example, to make a
reservaon for another hotel at a later date, to rebook or to carry out markeng acvies centrally.
Central services such as reservaon and markeng access this data.
Newsletterservice
On our website you have the possibility to register for our newsletter service in different ways. If a user
takes advantage of this option, the data entered in the input mask will be transmitted to us and stored.
These data are: E-mail address, form of address, first name, surname.
If you register for a newsletter from our websites, the data will be stored in our newsletter tool of
Revinate Inc, 1 Letterman Drive Building C, Suite CM 100, 94129 San Francisco, California, USA.
Revinate Inc. has committed itself to handling your transmitted data in accordance with data protec-
tion laws. It takes all organisational and technical measures to protect your data.
Should we otherwise receive an e-mail address where the recipient clearly informs us that he/she
wishes to receive our newsletter, we will collect his/her data via the input mask on our website.Die
Daten werden ausschließlich für das Versenden von Newsleern verwendet.
The recipient has the possibility to object to the processing of his personal data at any time. With each
newsletter the recipient can unsubscribe from the newsletter service.
AZIMUT Loyalty-Program
On our website there is the possibility to register for our loyalty program. If a user takes advantage of
this opportunity, the data entered in the input mask is transmitted to us and stored. These data are:
E-mail address, form of address, first name, surname. In addition, customer number, day and time of
registration, private address, date of birth, reservation history including the collected bonus points and
special requests are stored. Legal basis is the consent of the user.
For the implementation of the loyalty programme we use the service provider HotelsBI, Friedrichstra-
sse 68, D-10117 Berlin. Your data will be stored in our CRM system in a computer centre in Frank-
furt/Main, which is managed by HotelsBI. The loyalty program is operated by AZIMUT Hotels Com-
pany LLC at 18/1, Olympiyskiy Avenue, 129110 Moscow, Russia, and is used for central promotional
activities (such as newsletters for subscribers to the loyalty program).
The data will be deleted as soon as you have logged out of the loyalty programme and as soon as na-
tional, commercial, statutory or contractual retention requirements are fulfilled.
Business customers
For the support, advice and advertising of corporate customers, we collect and use the contact per-
son, telephone number and postal address in addition to the business partner or potential business
partner. We obtain the information from various sources, either through an inquiry (e-mail or tele-
phone), but also through events, trade fairs, business cards received by our sales staff, etc.
We use these contact details exclusively for our own purposes and for the needs-based design of our
own sales activities. You can object to the use of your e-mail address for direct advertising at any time.
Online evaluation and surveys
Former guests can give a rating to our hotel after check-out or participate in a survey. For this purpose,
we would like to send you an e-mail within 14 days after departure to ask you to submit a hotel rating
or to participate in a survey. For this purpose we use the service provider Revinate Inc, 1 Letterman
Drive Building C, Suite CM 100, 94129 San Francisco, California, USA. Each rating can be published
anonymously if desired. If you did not feel comfortable in one of our hotels, we would like to take the
opportunity to contact you.
We have also integrated the hotel rating software from tripadvisor on our own hotel websites. Former
guests can submit an anonymous rating to our hotel after check-out. For this purpose, we would like
to send you an e-mail within 14 days after departure to ask you to submit a hotel rating.
We use the service provider Revinate Inc. to send the evaluation e-mail. Every evaluation can be pub-
lished anonymously if desired. If you did not feel comfortable in one of our hotels, we would like to
take the opportunity to contact you.
In this context, the data will not be passed on to third parties. The data will be used exclusively for the
publication of the evaluation and for arbitration in case of bad evaluations.
You can object to the use of your data for the online evaluation at any time.
Application for a job advertisement
On our website and via internet portals, there is the possibility to apply for advertised positions. If an
applicant takes this opportunity, the data transmitted to us can be processed electronically. These
data are among others:
• Form of address, first name, surname
• Contact details (e-mail address, telephone)
• Cover letter
• File attachment with the detailed application
In this context, the data will initially not be passed on to third parties. However, should an applicant fit
the profile of another job advertisement published by one of our affiliated companies, we will gladly
forward the application documents. We will obtain the consent of the applicant in advance. The data
will otherwise be used exclusively for the processing of the application by the specialist department
and for communication purposes.
Cookies
Cookies are used on our Internet pages. Cookies are small pieces of text informaon that are stored in
your terminal device via your browser. The cookies are required to enable certain funcons of our
website.
We use the following cookies on our site:
Name
Purpose
Expiry
Type
BITRIX_SM_SEL-
ECTED_CUR-
RENCY
This cookie remembers the currency of the user
1 year
HTTP
_hbi widget hb
HBI widget is from HotelsBI - the provider of the loy-
alty program
1 year
HTTP
Google G_ENAB-
LED_IDPS
Webanalysis
unrestricted
HTTP
In addion, we use the Seekda Metasearch Interface of the company Kogniv, 92 King St. S., Unit 201,
Waterloo, Ontario Canada N2J 1P5 on our website. The service connects our website with numerous
search engines and booking portals to target our web services.
All the above-menoned cookies are absolutely necessary for the operaon of our website. The use of
cookies that are not absolutely necessary is only possible with your consent. In these cases, a
corresponding consent form will be displayed on the website.
You have the opon of prevenng the seng of cookies by making the appropriate sengs in your
browser. However, we would like to point out that the use of our website may then only be possible
to a limited extent. No programs or other applicaons are installed or started on your computer by
cookies.
The use of cookies is based on a weighing of interests. Our interest is the user-friendly visit of our
website.
Webanalysis
Use of Google Analytics
Our offer uses Google Analytics, a web analysis service of Google Inc. ("Google"). Google Analytics
uses so-called "cookies", text files that are stored on the user's computer and which enable an analy-
sis of their use of the website. The information generated by the cookie about the use of the website
by the user is usually transferred to a Google server in the USA and stored there. However, if IP anon-
ymisation is activated on this website, the IP address of Google's users within member states of the
European Union or in other signatory states to the Agreement on the European Economic Area will
be shortened beforehand. Only in exceptional cases will the full IP address be transferred to a Google
server in the USA and shortened there.
IP anonymization is active on this website. On behalf of the operator of this website, Google will use
this information to evaluate the use of the website by the user, to compile reports on the website
activities and to provide further services to the website operator in connection with the use of the
website and the Internet. The IP address transmitted by your browser within the framework of
Google Analytics is not combined with other data from Google. Users can prevent the storage of
cookies by adjusting their browser software settings accordingly; however, this offer points out to
users that in this case they may not be able to use all the functions of this website to their full extent.
Furthermore, users can prevent the collection of the data generated by the cookie and related to
their use of the website (including their IP address) to Google and the processing of this data by
Google by downloading and installing the browser plugin available at the following link:
Google in the USA is cered according to the so-called "Privacy Shield" (list entry). An adequate level
of data protecon is guaranteed by Google.
You can prevent the collecon of the data generated by the cookie and related to your use of the
website (including your IP address) to Google and the processing of this data by Google by downloading
and installing the browser plugin available at the following link
(hp://tools.google.com/dlpage/gaoptout?hl=de).
You can nd more informaon on the terms of use of Google Analycs and on privacy noces at:
hps://policies.google.com/privacy
Use of Yandex Metrica (Yandex LLC)
Our oer uses Yandex Metrica, a web channel system service of Yandex LLC ,16 Lva Tolstogo str.,
Moscow, 119021, Russia (www.yandex.com). With the help of Yandex Metrica pseudonymized visitor
data is collected, evaluated and stored on the basis of our legimate interest in stascal analysis of
user behavior for opmizaon and markeng purposes in accordance with Art. 6 paragraph 1 leer f
DSGVO. Pseudonymised user proles can be created and evaluated from this data for the same
purpose. Yandex Metrica uses so-called "cookies", i.e. small text les that are stored locally in the cache
of the Internet browser of the site visitor. These cookies serve, among other things, to recognize the
browser and thus enable a more precise determinaon of stascal data. The user's IP address is part
of the informaon collected, but is pseudonymised immediately aer the collecon and before it is
stored, in order to exclude the possibility of a personal reference.
The informaon generated by the cookie (including the pseudonymized IP address) is transferred to a
Yandex server in the Russian Federaon and stored there to protect the above interests.
The data collected using Yandex technologies will not be used at any me to personally idenfy the
visitor to this website without the separate consent of the person concerned, and will not be merged
with personal data about the bearer of the pseudonym.
Wenn Sie die Auswertung des Nutzerverhaltens via Cookies deakvieren möchten, können Sie Ihren
Browser so einstellen, dass Sie über das Setzen von Cookies informiert werden und einzeln über deren
Annahme entscheiden oder die Annahme von Cookies für besmmte Fälle oder generell ausschließen.
Use of Triptease
On our web site we use the service of the Triptease Group (Triptease Ltd., based in the UK, Triptease
Inc., based in the USA). With the help of Triptease, pseudonymous visitor data is collected, evaluated
and stored based on our legimate interest in the stascal analysis of user behavior for opmizaon
and markeng purposes. With the help of the Triptease service you will be shown oers and
promoons, among other things. From this data, pseudonymized user proles can be created and
evaluated for the same purpose. The user's IP address is part of the collected informaon, but is
pseudonymised immediately aer the collecon and before it is stored in order to exclude the
possibility of personal reference. We collect further personal data such as your e-mail address only
with your consent.
Further informaon on how Triptease processes your data can be found here:
hps://www.triptease.com/en/privacy-policy/
Use of Social Plugins
Facebook-Button
On our pages we have integrated a button of the social network Facebook, 1601 South California Ave-
nue, Palo Alto, CA 94304, USA. The Facebook button leads the user via a link to our Facebook fan page.
No data is transferred from our website to Facebook when the user visits our website.
If you click on the Facebook button while you are logged in to your Facebook account, you can link the
contents of our pages on your Facebook profile. This allows Facebook to associate visits to our Pages
with your user account. We would like to point out that we, as the provider of the Pages, have no
knowledge of the content of the transmitted data or its use by Facebook.
You can find more information on this in the Facebook privacy policy at de-de.facebook.com/pol-
icy.php If you do not want Facebook to be able to assign visits to our pages to your Facebook user
account, please log out of your Facebook user account.
Instagram-Button
On our pages we have included a button of the service Instagram. These functions are offered by In-
stagram Inc, 1601 Willow Road, Menlo Park, CA, 94025, USA. If you are logged into your Instagram
account, you can link the content of our site to your Instagram profile by clicking the Instagram button.
This allows Instagram to associate your visit to our site with your account. We would like to point out
that we, as the provider of the pages, have no knowledge of the content of the transmitted data and
its use by Instagram.
For more information, please see the Instagram Privacy Policy: http://instagram.com/about/legal/pri-
vacy/
VK.com Button
On our pages we have a button of the service vk.com (LLC "V contacts" prem. 1-N, bld. 12-14, Lit. A,
Khersonskaya st., 191024 St. Petersburg, Russian Federation). When you access our pages with vk.com
plug-ins, a connection is established between your browser and the vk.com servers. In the process,
data is already transferred to vk.com, which enables vk.com to assign visits to our pages to your user
account. We would like to point out that we, as the provider of the pages, have no knowledge of the
content of the transmitted data or of the use of such data by vk.com.
If you do not wish this data to be allocated to your vk account, please log out of vk.com before visiting
our site. You can find out more at https://vk.com/terms
Facebook-Fanpage
On our Facebook fan page we use plugins from the provider Facebook.com, which are provided by the
company Facebook Inc. 1601 S. California Avenue, Palo Alto, CA 94304 in the USA. By using the fan
page, data is forwarded to the Facebook servers, which contain information about your visits to our
fan page. For logged in Facebook users this means that the usage data is assigned to their personal
Facebook account. As soon as you as a logged in Facebook user actively use the Facebook plugin (e.g.
by clicking the "Like" button or using the comment function), this data is transferred to your Facebook
account and published. You can only avoid this by logging out of your Facebook account first.
We do not know exactly what data Facebook stores and uses. As a user of the fan page, you must
therefore expect that Facebook will also store your actions on the fan page without any gaps.
Facebook receives your IP address, processor type and browser version by clicking on the "Like" but-
ton. Using your IP address, Facebook could, together with other data and your real name, if you have
entered it in your Facebook profile, determine your identity and habits under this profile. If you always
log in to Facebook via this user profile, Facebook could find out your preferences, contacts and lifestyle
in particular.
Furthermore, the General Terms of Use of Facebook Ireland Limited, Hanover Reach, 5-7 Hanover
Quay, Dublin 2, Ireland apply at https://www.facebook.com/terms.php
Regarding data protection on Facebook, please note the following privacy policy of Facebook Ireland
Limited: https://www.facebook.com/about/privacy/
Integration of third-party services and content
Within our online offer, we use content or service offers from third parties on the basis of our legiti-
mate interests in order to integrate their content and services, such as videos or fonts (hereinafter
uniformly referred to as "content"). This always presupposes that the third party providers of these
contents are aware of the IP address of the users, as without the IP address they would not be able to
send the contents to their browsers. The IP address is therefore necessary for the display of this con-
tent.
The following contents are used on this website:
• External Fonts from Google, LLC., https://www.google.com/fonts ("Google Fonts"). Google
Fonts are integrated by a server call to Google (usually in the USA). Privacy policy: https://pol-
icies.google.com/privacy, Opt-Out: https://adssettings.google.com/authenticated.
• Maps of the service "Google Maps" provided by the third-party provider Google LLC, 1600 Am-
phitheatre Parkway, Mountain View, CA 94043, USA. Privacy Policy:
https://www.google.com/policies/privacy/, Opt-Out: https://www.google.com/settings/ads/.
Purposes of the processing of personal data
We process the aforemenoned data for the operaon of our website and for the fullment of
contractual obligaons to our customers or for the protecon of our legimate interests.
In the case of enquiries from you outside an acve customer relaonship, we process the data for the
purposes of sales and adversing. You can object to the use of your personal data for adversing pur-
poses at any me.
Voluntary information
If you provide us with data voluntarily, e.g. in forms, and this data is not required for the fullment of
our contractual obligaons, we process this data on the jused assumpon that the processing and
use of this data is in your interest.
Recipient / transfer of data
Data that you provide to us will not be passed on to third pares. In parcular, your data will not be
passed on to third pares for their adversing purposes.
However, we may use service providers for the operaon of this website or for further products or
services from us. Here it can happen that a service provider gets knowledge of personal data. We select
our service providers carefully - especially with regard to data protecon and data security - and take
all measures required by data protecon law for permissible data processing.
Data processing outside the European Union
Insofar as personal data is processed outside the European Union, this can be seen from the
above explanations.
Protection of minors
This service is mainly aimed at adults. We do not currently market special areas for children. Accord-
ingly, we do not knowingly collect age verification information, nor do we knowingly collect personal
information from children under the age of 16. However, we remind all visitors to our website under
the age of 16 not to disclose or provide any personally identifiable information through our service. In
the event that we discover that a child under the age of 16 has provided us with personal information,
we will delete the child's personal information from our files to the extent technically feasible.
Rights of the data subject
You have the right of access to personal data concerning you. You can contact us for information at
any time.
In the case of a request for information that is not made in writing, we ask for your understanding that
we may require you to provide proof that you are the person you claim to be.
Furthermore, you have a right to correction or deletion or to restriction of processing, insofar as you
are legally entitled to this.
Finally, you have a right of objection against the processing within the framework of the legal require-
ments.
A right to data transferability also exists within the framework of data protection regulations.
If you have any questions regarding your rights and the exercise of your rights, please contact the
responsible body or our data protection officer.
Deletion of data
As a matter of principle, we delete personal data when there is no need for further storage. A require-
ment can exist in particular if the data is still needed to fulfil contractual services, to check and grant
or ward off warranty and, if applicable, guarantee claims. In the case of legal storage obligations, de-
letion is only possible after the expiry of the respective storage obligation..
Security
AZIMUT Hotels uses technical and organizational security measures in accordance with Art. 32 DSGVO
to protect your data managed by us against accidental or intentional manipulation, loss, destruction
or access by unauthorized persons. Our security measures are continuously improved in line with tech-
nological developments. Access to this data is only possible for a few authorized persons who are re-
sponsible for the technical, administrative or editorial maintenance of data and who are obliged to
observe data protection regulations.
Right of appeal to a supervisory authority
You have the right to complain to a data protection supervisory authority about the processing of per-
sonal data by us.
Amendment of this privacy policy
We will revise this privacy policy whenever changes are made to this website or other reasons that
make this necessary. You will always find the current version on this website.
Version | 05‘2020
