1. Information We Collect

We only collect personal data that you voluntarily provide to us.

Personal Information

We may collect the following information:

• First name and last name
• Country and/or state/province

Contact Information

• Email address
• Phone number

Business Information

• Company name and related company information

2. How We Collect Information

We collect personal data when you:

• Contact us via email
• Submit information through contact forms
• Communicate with us for business, partnership, or inquiry purposes

3. Purpose of Processing

Business purposes

We use collected information solely for legitimate business purposes, including:

• Responding to inquiries and requests
• Business communication and relationship management
• Providing information about KVARK services and updates
• Internal record-keeping and operational purposes

We do not use personal data for automated decision-making or profiling.

New Offers

We also use your personal data to inform you about the latest offers, special deals, and other products or services that we believe may be of interest to you. The legal basis for processing is your consent, which you may withdraw at any time.

Marketing Activities

We use your data for marketing purposes. These activities include the following: Using your contact details to regularly send you updates about products and services. You may quickly and easily unsubscribe from marketing emails at any time by simply clicking the "Unsubscribe" link. The legal basis for processing is your consent, which you may withdraw at any time.

Based on your data, you may be shown personalized offers on the Website, in mobile applications, or on third-party websites/applications (including social networks), and the content of the Website displayed to you may be personalized. These may include offers that you can book directly through the Website or advertisers' websites, as well as offers or products from third parties that we believe may be of interest to you.

Communication with you

From time to time, we may contact you through other channels as well, such as email, postal mail, telephone or SMS, as well as other specialized communication applications (Viber, WhatsApp, Telegram). The method we choose will depend on the contact information you have previously shared with us. The legal basis for processing is your consent.

Legal Purposes

Finally, in certain cases we may use your data to process and resolve legal disputes, for investigation and compliance purposes, to enforce the terms of use of the online reservation service, or to respond to lawful requests from public authorities. The legal basis for processing is our legitimate interest.

Exceptionally, we may retain your data even after the withdrawal of consent or the fulfillment of the purpose, in situations where this is necessary for the performance of our legal obligations or for the establishment, exercise, or defense of legal claims.

4. Legal Basis for Processing

Where applicable under data protection laws (such as GDPR), we process personal data based on:

• Your consent
• Performance of a contract to which you are party or in order to take steps at the request of the data subject prior to entering into a contract
• Legitimate business interests (e.g. responding to inquiries, maintaining business communication)
• Compliance with legal obligations

5. Recipient or group of recipients

Your personal data is shared internally within the company for the purpose of providing the services we offer. By accepting the Terms and Services, you acknowledge and agree that our partners may also use certain of your personal data.

We may also share your personal data with the following recipients:

• Subcontractors, external consultants, lawyers, accountants, business banks, courier services, research and marketing agencies
• Information technology service providers, such as cloud providers, hosting companies, customer support services, chat services, or software companies
• A newly established entity or an acquiring entity, in the event the KVARK is involved in a merger, acquisition, sale of shares, or any other corporate restructuring
• Any other recipient where we are required to do so by law or by a court decision
• Any other recipient where reasonably necessary, for example in cases involving a threat to life

All recipients are required to implement appropriate technical, organizational, and personnel measures to protect your personal data. The Company has concluded data processing agreements with all recipients.

6. Transfer of personal data to other countries

Certain processors that may have access to personal data are located in foreign countries, primarily in Member States of the European Union or in countries that are parties to the Council of Europe Convention 108. The transfer of data to these countries is carried out on the basis of the presumed adequate level of protection of personal data in those countries, in accordance with the law.

If certain processors are located outside the aforementioned group of countries, the transfer of data would be possible only in accordance with Article 46 of the GDPR, which regulates transfers subject to the application of appropriate safeguards.

7. Data Retention

We retain personal data only for as long as necessary to fulfill the purposes described in this Privacy Policy or to meet legal requirements. When data is no longer needed, it is securely deleted or anonymized.

8. Data Security

We implement appropriate technical and organizational measures to protect personal data against unauthorized access, loss, misuse, or alteration. While no system can be guaranteed to be completely secure, we continuously improve our security practices.

KVARK continuously undertakes appropriate security measures in order to protect your personal data in accordance with the GDPR. We implement appropriate physical, procedural, technical, organizational, and personnel measures in order to achieve an adequate level of protection of the personal data we process. KVARK, together with its partners, applies the best industry standards in data protection. This protection covers the loss of data, use contrary to the intended purpose, unauthorized access and disclosure, alteration, and destruction of such personal data. However, no security measure can guarantee that personal data will be 100% protected. Nevertheless, KVARK continuously improves all security measures through controlled processes and a high level of responsibility in order to ensure the protection of your personal data.

Certain processors that may have access to personal data are located in foreign countries, primarily in Member States of the European Union or in countries that are parties to the Council of Europe Convention 108. The transfer of data to these countries is carried out on the basis of the presumed adequate level of protection of personal data in those countries, in accordance with the law. If certain processors are located outside the aforementioned group of countries, the transfer of data would be possible only in accordance with Article 46 of the GDPR, which regulates transfers subject to the application of appropriate safeguards.

9. Your Rights

Depending on your jurisdiction, you may have the right to:

• Access your personal data
• Request correction of inaccurate data
• Request deletion of your data
• Object to or restrict processing
• Withdraw consent at any time

Requests can be submitted using the contact details below.

We will respond to your request as soon as possible, and no later than within 30 days from the date of receipt of the request. In the event of complexity or a large number of requests, we may require additional time to respond. This period may not exceed 90 days, and you will be informed accordingly.

If your request is manifestly unfounded or excessively repetitive, we may refuse to act on the request or charge a fee for fulfilling it. A request is considered repetitive if you submit a request to exercise the same right more than once within a single year. If you contact us two or more times within one year regarding the same right, we will respond to your request only if you have a justified reason.

10. Children's Privacy

KVARK does not knowingly collect personal data from individuals under the age of 16. If such data is identified, it will be promptly deleted.

11. Third-Party Links

The Website may contain links to third-party websites. We are not responsible for their privacy practices and encourage you to review their privacy policies independently.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. Any changes will be posted on this page with an updated revision date.