A.D. Management and Holdings in Eilat Ltd., an Israeli company, company number 51531003, with its address at Gan Binyamin St 20, Eilat, 8801429, Israel (the "Complex," "we," or "us"), respects your right to privacy. Your ability to make informed decisions regarding the use of your Personal Data (as defined below) is important to us. The purpose of this Privacy Notice (the "Privacy Notice") is to explain the Complex's practices regarding the Personal Data collected when you use our Site (as defined below) and how the Complex collects, uses, transfers, and secures the Personal Data it collects.
Our Site (the "Site") is intended to provide a convenient and secure platform for booking and purchasing accommodation and vacation packages at the Complex. Your use of the Site of any kind, including leaving your details to contact the Complex, constitutes your consent and approval of the terms of this Privacy Notice. Terms in this document that are not explicitly defined shall be interpreted according to the definitions provided in the Terms and Conditions of the Site, published at takanon-en.html (the "Terms"). The terms "you" or "your" in this document refer to any user of the Site. For any questions or issues regarding this Privacy Notice, including exercising your rights, please contact us at hospitality@cphotel.co.il. The Complex has appointed a Data Protection Officer (DPO), Mr. Asif Dayan, who oversees our privacy practices; he may be reached at 050-5554208 and by email at asif@cphotel.co.il.
Please note that this Privacy Notice applies to the Personal Data collected on our Site, and not to your use of the Simple Booking platform through which bookings are made. The Privacy Notice published by Simple Booking applies separately to the Personal Data collected via that platform.
"Personal Data" means information relating to an individual, such as name, address, phone number, or email address, or as defined by law. You are not legally required to provide us with Personal Data; any provision of Personal Data is made solely with your consent. If you do not agree to provide some or all of the Personal Data, some or all of the Site and its Services may not be available to you.
1. Personal Data We Collect
1.1. Communications: When you contact us (e.g., via WhatsApp or by email) or request information, we collect the data you provide, such as your name, contact details (phone, email), and the content of your message or question. If you upload User Content to the Site, we will also receive such Personal Data.
1.2. Registration for Newsletter and/or Loyalty Program (if applicable): If you register to receive our publications or join a loyalty program the Complex may operate, we may collect your first and last name, email address, postal address, date of birth, and anniversary date, to the extent you provide them.
1.3. Activity and System Data: When you use the Site, we may automatically gather certain information about your device, such as your browser, operating system, IP address, mobile device identifiers, and/or data about your usage of the Site.
2. How We Use Your Personal Data
You agree and acknowledge that the Complex may store the information you provide, as well as any additional Personal Data that may be collected about you, in its databases. The Complex shall be entitled to manage such databases in accordance with applicable law as the database controller and to use the Personal Data in the manner described in this Privacy Notice, including for the following purposes:
2.1. Services and Adaptations. We and our third-party service providers use the Personal Data we collect for the following purposes: (1) to provide you with access to the Site and provision of Services at the Complex; (2) granting rights and benefits related to participation in a loyalty program, if operated; (3) providing support and assistance in resolving issues you or other users may encounter; (4) contacting you if necessary; (5) addressing inquiries, including those submitted via the Site, and responding accordingly; (6) preventing fraud attempts and safeguarding the security of the Site, as well as addressing any issues related to the Site; and (7) managing the Complex and its business operations, including customer retention, analyzing usage patterns on the Site, forecasting customer needs (including potential cancellations), and identifying market and customer trends and preferences.
2.2. Internal Needs. We may use your Personal Data for internal purposes, including diagnosing operational issues, improving the Site or our Services and adapting them to our needs and/or those of the users, analyzing activity volumes, performing business assessments and forecasts, and using certain Personal Data for research, development and testing purposes.
2.3. Statistical Information and Analytics. As of the date of this Privacy Notice, the Site does not use third-party analytics tools (such as Google Analytics). If we implement such tools in the future, we will update this Notice accordingly and detail what data is collected and for what purposes.
2.4. Marketing. Subject to your consent, we may use your Personal Data to send you updates and offers. If you no longer wish to receive such emails, you may request to be removed from our mailing list by clicking the unsubscribe link included in the message and/or by following any other instructions provided in the communication.
3. Sharing the Personal Data We Collect
3.1. Access-Holders at the Complex: Access-holders are Complex personnel who are allowed access to Personal Data. As of the date of this Privacy Notice, typical access-holders include, among others: reservations staff, front-desk staff and management, and housekeeping staff. The identity and/or type of access-holders may change over time according to our business needs; if there is a material change, we will use commercially reasonable efforts to update you.
3.2. Affiliates: We may share information, including your Personal Data, with our parent and/or subsidiary and affiliated companies where necessary to provide you with the Services, Site, and/or to manage our business.
3.3. Service Providers and Third Parties: We may share information, including Personal Data, with service providers and other third parties ("Third-Party Providers"), who may use the information to: (1) assist us in operating the Site and/or provide the Services; (2) help us understand the use of the Site; and (3) provide you with direct marketing based on your personal preferences, where you have consented to this. The table below details the categories of Third-Party Providers relevant to the Complex as of the date of this Notice:
| Type of Service | Description | Personal Data Shared |
|---|---|---|
| Cloud Computing | We use cloud service providers who offer us space on their servers to store our files and programs, including your Personal Data. | All Personal Data we collect is stored on third-party servers. |
| Booking Engine (Simple Booking) | We use the Simple Booking platform to receive bookings directly on the Site. | Name, email address, phone number, booking and payment details, and any additional Personal Data you provide for the booking. |
| Payment Processors | When you make a payment, the transaction is processed by an external payment processor (via the booking engine and/or on site). | Your payment details. |
| We use WhatsApp Business for direct communication with guests regarding bookings, changes, and inquiries. | Name, phone number, and the content of the correspondence. | |
| Bookkeeping Services | We use a third-party bookkeeping service provider to manage our financial transactions and records. | Name, address, and transaction details. |
| Email Marketing | If we send marketing communications, we do so via an external vendor. | Name and email address. |
3.3.1. Third-Party Providers may be located in countries other than the State of Israel. All authorized third parties will be subject to confidentiality obligations and restrictions on the unlawful use of Personal Data. Nevertheless, some of these countries may provide levels of protection for Personal Data that are not equivalent to the level of protection in the State of Israel, and you hereby consent to the transfer of your Personal Data to such countries.
3.4. Business Transfers. Our databases (which include your Personal Data) may be disclosed and/or transferred as part of, or during negotiations of, any merger, sale of the Complex's assets, or acquisition (including in cases of liquidation), including after the consummation of any of the above. In such case, your Personal Data shall continue being subject to the provisions of this Privacy Notice, subject to applicable law.
3.5. Advertisers. When you click on an ad, whether or not it's on our Site or on another website, the relevant advertiser will be alerted that someone has visited the page on which the relevant advertisement was displayed, and may be able to identify that it was you by using certain mechanisms, like cookies (as detailed in Section 7 below).
3.6. Transfer of Personal Data for Law Enforcement Purposes. We will cooperate with law enforcement authorities or any judicial order requiring us to disclose the identity, behavior, digital content, or any other Personal Data of any user suspected of engaging in actions that appear to be unlawful. We may also share your Personal Data with third parties if we believe in good faith that such disclosure is appropriate and intended to protect our rights, property, or safety (including the enforcement of this Privacy Notice and/or the Terms), or to protect the rights, property, or safety of third parties.
3.7. Additional Disclosures. We will transfer your Personal Data to relevant third parties in cases where: (1) the Complex determines that any of your actions on the Site violate the Terms or were carried out to commit fraud of any kind; or (2) the Complex is subject to legal proceedings (administrative, criminal, or civil) as a result of actions you performed through the Site.
4. How We Protect Personal Data
We follow industry-standard practices to protect Personal Data, both during its transmission and once it is received. However, the transmission of Personal Data over the internet or its electronic storage can never be fully secure. Accordingly, we cannot guarantee the absolute security of your Personal Data.
5. Inspection and Correction Rights
You may request to review the Personal Data processed by the Complex about you, in accordance with Section 13 of the Privacy Protection Law, 5741–1981 (the "Privacy Protection Law"). If you find that such Personal Data is incorrect, incomplete, unclear, or not up to date, you may request that we correct or delete it, in accordance with Section 14 of the Privacy Protection Law. The Complex will act within a reasonable time to respond to your request, subject to the provisions of the law. In addition, in certain cases, you may request the deletion of your Personal Data from the Complex's databases in accordance with Section 3 of the Privacy Protection Regulations (Provisions Regarding Data Transferred to Israel from the European Economic Area), 5783–2023. If we decide, at our discretion, to deny your request, we will notify you in the manner prescribed in the regulations, and you may appeal our decision to the Magistrates' Court as prescribed therein.
6. Retention of Personal Data
We will retain your Personal Data for as long as necessary to: (1) fulfill the purposes of use of the Personal Data described above; (2) comply with our legal obligations; (3) resolve disputes; (4) enforce our agreements; or (5) for a longer period as required under applicable law. We may delete your Personal Data without notifying you if we determine that it is no longer necessary to retain it for the purposes described above.
7. Cookies and Similar Technologies
Cookies are small text files that are sent to your device through your browser. We may use cookies and similar technologies (collectively, "Cookies"). A "session cookie" remains on your device only until you leave the Site. We may also use a "persistent cookie" to store your settings and preferences from visit to visit, which will remain on your device for longer periods. Most web browsers are initially set to accept cookies, but you can change this setting to block certain cookies, and you can delete existing cookies at any time. Please note that some features of the Site may not function properly if you disable or remove cookies.
The main categories of cookies we may use:
| Type of Cookie | Why We Use These Cookies |
|---|---|
| Necessary | Necessary to allow the Site to work correctly and cannot be disabled. |
| Functionality | Remember your preferences from one visit to the next. |
| Security | Help us recognize you and prevent unauthorized security-related actions by other users. |
| Analytics | Help us understand how users interact with our Site, so we can improve it. |
| Advertising | Help us display relevant advertisements and measure their effectiveness, if such advertising is activated. |
8. Third-Party Applications and Services
Part of the Site includes the use of third-party services, chiefly the Simple Booking reservation engine. All use of such services is at your own risk and subject to that third party's terms and privacy policy.
9. Children
We do not knowingly collect Personal Data directly from children under the age of eighteen (18). If you become aware that an individual under the age of eighteen (18) is using the Site without parental permission, please advise us immediately.
10. Communications
We reserve the right to send you communications related to the Site or your booking via email, WhatsApp, and/or any other communication channel known to us, including service and administrative messages, without offering an opt-out, except for marketing messages, which you may unsubscribe from at any time.
11. Changes to this Privacy Notice
We may update this Privacy Notice from time to time. If we make material changes, we will update the date at the top of this page and post a prominent notice on the Site.
12. Contact
Email: hospitality@cphotel.co.il
WhatsApp: +972505551930
Address: Gan Binyamin St 20, Eilat, 8801429, Israel