Privacy Policy

Privacy Policy
This privacy policy has been adopted by the Lavi Guest Hotel in the Galilee ("the Hotel") regarding the collection and dissemination of information (the "Privacy Policy").
The Privacy Policy details the types of personal information as well as other information ("the Information") that the hotel collects about the users of the hotel's services (as defined below) the method of their collection, use, storage and processing and their conveyance to third parties.
The Privacy Policy is formulated in the masculine for convenience purposes only, but is intended for both women and men.
The hotel collects the information through:

1. The website operated by the hotel at www.hotel.lavi.co.il, and other websites owned or controlled by the hotel
2. The applications that the company makes available to guests on computers or mobile devices ("the Applications");
3. Social media pages owned and controlled by the hotel (collectively: "Social Media Pages");
4. Other offline interactions with the hotel (such as a call to the call center).

The websites, Applications and Social Media Pages will be hereinafter jointly referred to as the "Online Services" and together with the offline channels – the "Services".
By using the Services, guests agree to the terms of the Privacy Policy. Please read the Privacy Policy carefully.
The hotel serves as the data controller of the personal information about the guests or people who contact the hotel through one of the means of communication listed above in sections 1-4.
The information that has been or will be given to the hotel, whether orally or in writing, is contingent on the consent of the guests and their wishes and is not given due to a legal obligation.
Should no information be provided to the hotel or if it is not possible for the hotel to collect such information, the hotel will not be able to provide its services to parties of interest.
Collection of personal and other information

1. "Personal information" means data that identifies the owner of the information.
   The hotel collects personal information such as:
   1. Contact details (name, e-mail address, mailing address, telephone number, fax number, passport number, ID number).
   2. Payment information – menas of payment (payment card: number and expiration date according to PCI DSS rules, billing address and bank account number).
   3. Demographic data (such as age, sex, residential address, citizenship, and preferred language).
   4. Information about family members and companions (such as names and ages of the children or spouse).
   5. Information on family events: birthdays, anniversaries.
   6. Information regarding reservations at the hotel, a stay or visit to the hotel (date of arrival and departure, goods and services purchased at the hotel, personal preferences (as defined below), phone calls made, etc.).
   7. Information required to fulfill special requests or special conditions of stay (preferences, leisure activities, name of companion, number of children and their ages, etc.);
   8. Guest preferences ("personal preferences"), such as interests, activities, hobbies, food and beverage choices, services and requests of which the guest informed the hotel or preferences that were gathered about the guest during his visit to the hotel.
   9. Information related to members of the customer club program.
   10. Information based on geographic or other location.
   11. Photos, video and audio collected through security cameras located in public areas of the hotel, such as in the corridors and lobby of the hotel (CCTV).
2. "Other information" - means data that does not reveal the personal and specific identity and does not refer to a specific person such as browser and mobile device data, including IP address and data collected by "cookies", pixel tags and other technologies, aggregate data regarding the stay of guests at the hotel as well as responses to promotional offers and surveys.
3. In some cases, the hotel integrates personal information with other information (such as the guest's name and location). In such case, the hotel deems such integrated information as personal information.
4. In case information is provided to the hotel or to the hotel's service provider that includes personal information about a third party (for example - in the event that a reservation is made for another person), then the applicant represents that they have obtained the third party's consent to provide said information and the applicant is authorized to do so and the third party allows the hotel to use said information in accordance with the provisions of the Privacy Policy.

Methods of collecting the personal information and other information
Personal and other information is collected as follows:

1. Online services: when placing an order, purchasing goods or services, contacting the company and its representatives in any way, posting on social media pages, joining a mailing list or participating in surveys, feedback, contests or marketing offers, as well as when applying for a job at the Kibbutz Lavi Guest Hotel.
2. Visits and offline interaction: when visiting the hotel, Kibbutz Lavi Guest Hotel, when staying as a guest at the Kibbutz Lavi Guest Hotel and when using the services it offers. Likewise, personal information is also collected when participating in sales promotion marketing events as guests of the Kibbutz Lavi Guest Hotel and/or in promotional events hosted by the Kibbutz Lavi Guest Hotel or when providing personal information as part of the promotion of a sales event. Personal information about the providers of the information is also collected through a closed circuit camera system placed for security purposes in the public areas of the hotel (CCTV), and through other means of security.
3. Other sources: personal information is also obtained from third parties, including information from travel agents, customer clubs, credit card companies, government agencies (in order to comply with legal provisions), survey companies, service providers of the Kibbutz Lavi Hotel.
4. Automatic information: when you make use of the websites and/or the Applications as defined above, the Kibbutz Lavi Guest Hotel obtains and saves information regarding activity on the aforementioned websites and Applications, and additional automatic information is collected from the browser and mobile device. For example, as is customary on other websites, we obtain certain information when a browser accesses the website, including information regarding IP address, browser type, operating system, mobile network data, pages viewed and browsing times. This information is used by us in contacting and providing services to customers.
5. Customer service centers: When making a reservation by phone, contacting the Kibbutz Lavi Guest Hotel via e-mail, fax, online chat or through customer service. This communication may be documented for the purpose of guaranteeing the quality of service and training.
6. Gathered information: information that does not identify the website user or any other user personally.

Use of personal and other information:

1. The Kibbutz Lavi Guest Hotel uses personal information and other information for one or more of the following purposes:
   1. Making orders and purchases of services and products: Kibbutz Lavi Guest Hotel processes the information regarding the transactions you entered into with Kibbutz Lavi Hotel, including through the websites ("Transaction Data"). The Transaction Data is processed for the purpose of completing the order, providing products and services, tailoring services provided by Kibbutz Lavi Guest Hotel to your preferences, receiving feedback about the stay at Kibbutz Lavi Guest Hotel and keeping records of such transactions.
   2. Contact with the guests: in order to offer services based on your preferences, the information is collected before and during a stay in the Kibbutz Lavi Guest Hotel, the information may be used for "regular customers" events which we may organize from time to time separately or with partners or by our partners. Responses to inquiries: Kibbutz Lavi Hotel processes information in connection with inquiries by users of the services ("Data Regarding Inquiries"). The Data Regarding Inquiries includes contents of the inquiry and metadata related to the inquiry (such as groups, meetings and events). Data Regarding Inquiries will be processed for the purpose of communication with the guests and record keeping.
   3. Business purposes: the Kibbutz Lavi Guest Hotel processes the information for business purposes including, developing new products, improving the website, improving our services, identifying usage trends and visiting patterns of guests, determining the effectiveness of sales promotions, performance evaluations of third parties (such as travel agents) , expected yield and occupancy of Kibbutz Lavi Hotel and compliance with obligations.
   4. Administrative and other communications: sending information to you regarding the website, changes to the terms of use, changes to the Privacy Policy or other administrative information (for example - information about orders placed such as e-mails to confirm orders and more).
   5. Marketing and sales promotion: sending marketing and sales promotion messages regarding Kibbutz Lavi Guest Hotel and products and services that we think will be of interest to the party providing the information, including spa and gym services, bars, restaurants and more.
   6. Safety and security: maintaining the health and safety of the vacationers as well as other guests and the staff of the Kibbutz Lavi Guest Hotel during their stay at the Kibbutz Lavi Guest Hotel.
   7. Our legal obligations: to comply with the provisions of law, including laws, regulations, guidelines and legal procedures.
   8. Kibbutz Lavi Guest Hotel uses the personal information and other information, all or some, to perform certain statistical calculations, some of which will be displayed in Applications, websites and/or other services; provided such these do not include identifying information.
2. The legal basis for processing personal information is one or more of the following:
   1. Consent.
   2. Providing the services.
   3. Compliance with any law, including laws, regulations, injunctions, guidelines, court rulings and more.
   4. Legitimate and business interest of the Kibbutz Lavi Guest Hotel.

Disclosure and transfer of personal and other information

1. The Kibbutz Lavi Guest Hotel may disclose and transfer the personal and other information as detailed below:
   1. To another hotel under the same ownership as detailed in this Privacy Policy, in order to provide a better hospitality experience based on personal preferences and experience gained in the context of using the services provided to Kibbutz Lavi hotel guests in previous stays.
   2. To a representative or travel agent who provided us with personal information about guests (for example - travel agent, compnaion, employer or spouse).
   3. To service providers who provide services to Kibbutz Lavi Guest Hotel. Examples of service providers are IT service providers, legal advisors, accountants, payment service providers and more.
   4. To business partners of the Kibbutz Lavi hotel in the field of marketing and advertising, in order to post relevant advertisements to the users of the website and to encourage users to come back and revisit the website. These partners will not use the personal information for any other purpose except for the aforementioned direct marketing and in any event the users are given the right to object to the said actions.
   5. The Kibbutz Lavi Guest Hotel may provide personal information and other information to third parties in the event of a reorganization, merger, sale of property or shares of any of the hotels listed in this Privacy Policy, joint venture, assigning of rights and/or obligations of any of the hotels listed in this Privacy Policy, transfer or other disposition of Kibbutz Lavi Guest Hotel business and its assets, all or in part (including liquidation and other similar procedures).
   6. The Kibbutz Lavi Hotel may disclose personal and other information if this is deemed is necessary: (a) to comply with the provisions of the law; (b) to comply with injunctions as part of legal proceedings; (c) for the purpose of responding to requests and inquiries from public or government authorities; (d) to enforce the terms of use; (e) to protect the business of Kibbutz Lavi Guest Hotel; (f) to protect the rights, privacy, safety or property of Kibbutz Lavi Guest Hotel, its guests, the users of the services and others; and (g) in order to enable the Kibbutz Lavi Guest Hotel to take action for the obtainment of remedies to which it is entitled under law and/or agreement as well as to reduce its damages.

Transfer of information across borders

1. As a general rule, information processing is carried out within the borders of the State of Israel. Information processing, which is carried out by third parties or cloud services, can and will be carried out on servers around the world such as Microsoft's Azure servers or Microsoft's 365 servers, etc.
2. Concurrently, it is possible that some of the information will be held in cloud outside the territory of the State of Israel or the European Union. The operator of these services has undertaken to comply with the provisions of the GDPR. In a specific case as mentioned, the Kibbutz Lavi Guest Hotel ensures that adequate measures are taken to secure the personal information at an adequate level of protection.

How the party providing the information can access, modify or limit the use of the personal information
If they reside within the EU, the following provisions will apply to them:

1. The right to receive information about the processing of personal information: We strive to provide concise, transparent, clear, simple and easy-to-access information about the conditions of the processing of personal information.
2. The right to access, correct or delete personal information: We allow the providers of information to receive confirmation from us as to whether the personal information is being processed as well as details about the terms of such processing of said information, as well as to receive an electronic copy of the aforementioned information.
3. The right to correct personal data.
4. The right to request deletion of personal information subject to the provisions of any law and provided that the following conditions are met:
   1. The personal information is no longer necessary for the purpose for which it was collected, stored and processed.
   2. You seek to rescind your consent on the basis of which the personal information was processed and there is no longer grounds to justify the processing of the personal information as said.
   3. The party providing the information believes and can substantiate the claim that the personal information was processed unlawfully.
   4. The personal information will be deleted in accordance with the obligation of Kibbutz Lavi Guest Hotel under the provisions of the law.
   5. The right to limit the processing of the personal information: you shall be able to enjoy this right in a number of cases and in particular in the following cases:
      1. In the event of a dispute about the accuracy of the personal information.
      2. To the extent that a party believes and can substantiate the claim that the processing of the personal information is unlawful, but opposes to the deletion of the personal information and demands instead that the processing be limited.
      3. When the company no longer requires the personal information but the personal information is required in order to exercise, establish or protect your rights.
      4. When the decision about the legitimate interest of the Kibbutz Lavi Hotel prevails over your interests as the subjects of the information.
5. The right to transfer information:
   1. If the basis for the processing of personal information is consent or an agreement, the subjects of the information are entitled to receive the personal information provided to Kibbutz Lavi Guest Hotel in an acceptable format and transfer this information to another controlling shareholder.
6. The right to withdraw consent:
   1. When the basis for the processing of personal information is consent, the applicants may withdraw their consent as stated at any time by any means provided for that purpose (as detailed in this Privacy Policy). We note that such opt-out applies only to the future and does not apply to information processed before the opt-out. For the avoidance of doubt, it is clarified that the withdrawal of consent will not put in question the legality of the processing of the personal information that was carried out prior to the withdrawal of the said consent.
7. The right to decide regarding the personal information after death:
   1. The owners of the information may decide about the fate of the personal information after their death by providing general or specific instructions. Kibbutz Lavi Guest Hotel is committed to respecting such instructions. In the absence of instructions, Kibbutz Lavi Hotel recognizes the possibility that heirs will exercise certain rights and in particular the right to access the personal information, if required, the rights of the deceased's estate; the right to object to the closing of the user accounts of the deceased; and the right to object to the processing of the deceased's information.
8. The right to file a complaint with the relevant Privacy Protection Authority:
   1. In case despite the efforts by Kibbutz Lavi Guest Hotel to maintain the confidentiality and privacy of personal information, the providers of information feel that their rights have been violated, they have the right to file a complaint with the relevant Privacy Protection Authority. A list of authorities is available on the website of the European Commission.
   2. If the place of residence of the providers of the information is outside the European Union (including Israel), they have the right to review and amend the information stored in the Kibbutz Lavi Hotel databases in accordance with the provisions of Israeli law, including the provisions of the Privacy Protection Law 1981.

Data Security

1. Kibbutz Lavi Guest Hotel takes reasonable organizational and technical measures in order to protect the personal information with regards to unauthorized access and disclosure of the information, deletion or modification of the information, random loss of the information, misuse or damage. Kibbutz Lavi Guest Hotel performs reviews and monitoring with appropriate frequency of the aforementioned protection and security measures.
2. When required to disclose or transfer personal information to third parties and parties granted access, Kibbutz Lavi Guest Hotel will ensure that such third parties commit to an adequate and appropriate level of data protection. Kibbutz Lavi Guest Hotel requires contractual commitments from third parties to ensure that the personal information will be processed only for the purposes for which you have given your consent and in accordance with the required level of confidentiality and security.
3. If you have reasons to believe that the communication with Kibbutz Lavi Guest Hotel is not secure (for example - if you believe that your personal account at Kibbutz Lavi Guest Hotel has been hacked) contact us immediately.

The information retention period

1. Subject to the provisions of any law, Kibbutz Lavi Guest Hotel will keep the personal information for a period of time as required for the implementation of:
   1. The purposes for which the personal information was provided.
   2. The business interest of kibbutz Lavi hotel including data retention.
   3. A requirement to retain information that may be relevant in regulatory investigations or legal proceedings.
   4. Compliance with the provisions of any law, regulation, legal process, including injunctions and/or disclosure required by government and other authorities.
   5. To realize a legitimate interest of Kibbutz Lavi Guest Hotel and third parties, including defense in legal proceedings and more.

Sensitive information

1. Unless this is specifically requested, the Kibbutz Lavi Hotel requests not to provide or disclose any sensitive personal information (for example, National Insurance numbers, data relating to race or ethnicity, political opinions, religion, ideology or other beliefs, health, biometric data or genetic data, criminal record, administrative or criminal proceedings and sanctions imposed with regards to the aforementioned) as part of the use of the services or in any other way.

Use of the services by minors

1. The Kibbutz Lavi Guest Hotel does not knowingly collect personal data from anyone under the age of 18.
2. The Kibbutz Lavi Guest Hotel collects personal data from people under the age of 18 as part of the guest's registration procedure, but this is always subject to obtaining the consent of the minor's parent or guardian.

Updates

1. The company may amned and update this Privacy Policy from time to time at its absolute discretion without notice. Users are solely responsible for learning the amendments, if any, made to the Privacy Policy.

Cookies

1. Like many other websites, and in order to improve the users’ experience of the website and web pages, the Kibbutz Lavi Guest Hotel uses "cookies". "Cookies", in and of themselves, do not provide the Kibbutz Lavi Guest Hotel with personally identifiable information unless the user has elected to provide such information (for example by registering for one of the services). However, if you elect to provide personally identifiable information on the website, this information will be linked to the data stored in the "cookie".
2. A "Cookie" is a small text file containing small amounts of information that the website places on a computer or mobile device. "Cookies" are designed to help the computer or device remember something the user did on the website, for example to remember that the user logged into the account or which and how many buttons were clicked.
3. The Kibbutz Lavi Guest Hotel uses "cookies" as a tool for understanding the use of the website and for the purpose of improving the content and offers on the website. This use is made to customize the user experience on the web pages of Kibbutz Lavi Hotel by offering relevant products, programs and services as well as targeted advertising.
4. Deactivation of cookies - it is possible that the browser used by the provider of information allows control of "cookies"; some browsers have optional settings that prevent the collection of "cookies". In case of no consent to the use of "cookies", the use of "cookies" must be disabled according to the instructions of the browser settings as detailed here. Please note that after disabling "cookies", certain features on the website may not work properly.
5. There are third parties who operate certain types of "cookies" that provide a tool to automatically disable their "cookies", you may see a list of "cookies" operated by third parties and a link to their automatic disabling. In other cases, the "cookies" may be disabled using a third-party management tool like here.
6. The company uses a variety of "cookies":
   1. “Session cookies” - these "cookies" are stored temporarily during the browsing activity and are deleted from the mobile device once the browser is closed. We use session cookies to support the functioning of the website and to understand your use of the website, for example the pages you visited, which links you used and how long you spent on each page.
   2. Essential cookies - these "cookies" are necessary for the operation of the website and, for example, allow members of the Kibbutz Lavi Guest Hotel club to connect and enjoy member benefits.
   3. Functional cookies - we use functional "cookies" for the purpose of saving website settings – settings such as your preferred currency for viewing hotel prices on the website. The Kibbutz Lavi Hotel also uses functional "cookies" to store data so that this data can be easily found on the next visit to the website. Certain functional "cookies" are essential for viewing maps or videos on the website. The company uses Flash "cookies" for certain animated content.
   4. Persistent cookies - these "cookies" are not deleted when the browser is closed, but are kept on the device for a fixed period or until they are deleted. On each visit to the website, the server that placed the "cookie" will recognize the persistent "cookie" saved on the personal device. The company uses persistent "cookies" to store your preferences so that they are available for the guests on the next visit. For example, if you have already a logged-in to the club, these "cookies" will skip the login step on the next visit to the website.
   5. Targeting and advertising cookies - the use of these "cookies" is for the purpose of collecting information in order to help Kibbutz Lavi Guest Hotel improve its products and services as well as to display targeted ads that Kibbutz Lavi Hotel believes will be relevant for the user. The Kibbutz Lavi Guest Hotel uses targeting "cookies" on its websites for various marketing initiatives and campaigns. The Kibbutz Lavi Hotel also uses "analytics cookies" (see below) and other technologies to promote advertising.
   6. "Analytics cookies" - these "cookies" collect information about the use of the website and allow Kibbutz Lavi Guest Hotel to improve the activity of the website. - These "cookies" provide Kibbutz Lavi Guest Hotel with aggregate information that the hotel uses to monitor the website's performance, count visits to each page, detect technical errors, check how users reach the website and measure the effectiveness of advertising and targeted ads.
7. The website uses third parties cookies:
   1. "Google Analytics cookies" - are used to collect information about how users use the website. The Kibbutz Lavi Hotel uses the information to create reports and improve the website. These "cookies" collect information anonymously, for example determining the number of visitors, how the users accessed the website and which buttons the user clicked. Click here to read Google’s privacy policy with regards to "Google Analytics". Click here to disable "Google Analytics" cookies. "Google cookies" include the Google AdWords & DoubleClick cookies for marketing, advertising and remarketing. These enable visitors to our advertising partners' websites to be identified and targeted with interest-based ads and information. To learn more about Google AdWords & DoubleClick cookies, click here.
   2. "Facebook cookies" - the use of these "cookies" is for advertising based on the user’s interest, that is - ads that the user might be interested in based on his activity on websites other than "Facebook". These "cookies" collect information from visits to the website and enable the promotion of ads through "Facebook" platforms. Click here to read more about interest-based ads from "Facebook".
   3. In order to disable "Facebook" interest-based ads, follow Facebook’s instructions here. More information about Facebook's privacy policy can be found here.
   4. "Bing/Microsoft cookies" - "Bing cookies" are used to collect information about the way visitors use the company's website as well as for marketing, advertising or remarketing. These "cookies" enable to identify visitors to the websites of our advertising partners and to direct them to interest-oriented information or ads. Click here to read more about the "Bing/Microsoft" privacy policy.