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Carmelo Privacy Statement
We at CARMELO B.N. LTD, 516445400 (“Carmelo”, “Company”, “we”, “us”, “our”) respect your privacy. This Privacy Statement (“Policy”) explains the privacy practices for the Carmelo Website and mobile application (“Website” and “App”). It also describes the rights and options available to you with respect to your information
Personal Data We Process
To set up your account on Carmelo we will collect your email address, password and full name, or collect such information from your Google account.
Initial Account Sign-up. To sign up to Carmelo, you will be asked to provide your email address, password and full name. Alternatively, you can connect through your Google account and we will collect your account information, such as name and email address, from this service.
To make a reservation on Carmelo we will collect your booking information directly from you or from third parties that you have made your reservation through.
Booking Information. To make a reservation on Carmelo you will be asked to provide your full name, telephone number, e-mail address, home address, payment information, number of guests, destination, transportation arrangements, check-in and checkout dates. Alternatively, we may collect such information from third parties that you have made your reservation through. We also receive your ground transportation arrangement information through third party partners that you’ve made arrangements with.
When you check-in, we will collect your own and your guests’ passport information and take a copy of it.
Identity Documents. When you check-in to your accommodation, we will collect and process your own and your guests’ passport information and take a photocopy of it, including name, passport number, issuance and expiry date, country and nationality, place of issuance, and photograph.
We collect information relating to technical and customer support requests you contact us with.
Support. When you contact us for technical and customer support requests, we collect the information included in your request and in follow-up interactions we have with you.
If you subscribe to our newsletter, we will use your email address for marketing purposes.
Newsletter Subscription. To subscribe to our newsletter and receive promotional materials and special offers, we will collect your email address (“Promotional Emails”).
You may opt-out of our promotional emails by sending an email to firstname.lastname@example.org
You may 'opt-out' of using your information for Promotional Emails at any time by sending an email to: email@example.com
You are not legally required to provide us your information.
You do not have a legal duty to provide the above information. However, you will not be able to sign up to and use Carmelo, and make reservations, without providing the above information.
We automatically collect information about the locking and unlocking of the apartment door when using the App’s smart lock feature.
Smart Lock Information. When you use App’s Smart Lock feature for locking and unlocking your apartment door, we collect the date and time of lock or unlock, the property in question, the lock id, the action taken and who has taken it.
We will automatically collect information about your personal computer and mobile device.
Device Information. We collect information about your personal computer or mobile device (“Device”), including language preferences, the Device model, its operating system, browser you use, its version and language preferences, mobile network information and the Internet Protocol (IP) address through which you accessed the App and Website.
We also collect analytics information about your use of Carmelo.
Analytics Information. We record and collect aggregated (statistical) analytics information, including your session durations, the content you accessed, your interactions and user-interface clicks, and the frequency and scope of your use of Carmelo.
The overall personal information outlined above will be referred to as the "Information" or “Personal Information”.
How We Process And Use Personal Data
We process your data for the following purposes:
To operate Carmelo and provide its services and features.
We process your Initial Account Sign-up information, Booking Information, Device information and Smart Lock Information to operate Carmelo and provide you and all other users with its services, features and functionality.
To send you administrative notifications relating to Carmelo.
We process your ground transportation arrangement information for timely preparation and availability of your accommodation.
We process your Initial Account Sign-up information and Booking Information to send you administrative notifications relating to Carmelo. You can control your notification settings and preferences through your account on Carmelo.
To send you promotional messages relating to Carmelo.
We process your Initial Account Sign-up information and Booking Information or your Newsletter Subscription information to send you promotional emails relating to Carmelo, unless you have indicated your desire not to receive promotional emails from us (either during your sign-up or at any later time).
To develop and enhance Carmelo.
We process your Analytics Information and Device information to understand how users interact with Carmelo so that we can further develop and enhance Carmelo.
To provide user technical or customer support.
We process your Initial Account Sign-up information, Booking Information and Support information to provide you technical or customer support in response to inquiries on these topics.
When Your Personal Data Is Shared With Others
We will not share your information with third-parties, except in the events listed below or when you provide us your explicit and informed consent
We share your information with our service providers helping us operate our business.
We will share your personal information with our service providers who assist us with the internal operations of Carmelo. These companies are authorized to use your personal information only as necessary to provide these services to us and not for their own promotional purposes. We do not sell your personal information to third parties.
The service providers we use include Isracard, Amazon, Google, TreeBase, SafeCharge, Nuki, Intercom, Matrix, and AutoPilot.
If you violated the law, we will share your information with competent authorities.
If you violated any applicable law, your information will be shared with competent authorities and with third parties (such as legal counsels and advisors), for the purpose of handling of the violation.
We will share your information if we are legally required.
If we are required to disclose your information by a judicial, governmental or regulatory authority. For example, authorities often require us to collect guests’ Identity Document information and share it with them.
We do not knowingly or intentionally collect information about children who are under 13 years of age.
Carmelo is not intended for children under the age of 13. We do not knowingly or intentionally collect information about children who are under 13 years of age.
IF YOU ARE UNDER THE AGE OF 13 YOU MAY NOT USE THE APP IN ANY WAY.
Security And Data Retention
We retain personal data as needed to support Carmelo and thereafter for compliance and legal purposes.
We implement measures to secure your Information
We implement measures to reduce the risk of damage, loss of information and unauthorized access or use of information. However, these measures do not provide absolute information security. Therefore, although efforts are made to secure your personal information, it is not guaranteed, and you cannot expect that Carmelo will be immune from information security risks.
When you use Carmelo, other parties may collect personally identifiable information about your activities over time and across different websites or online services.
The following disclosure is made pursuant to California Online Privacy Act (CA Civil Code § 22575): When you use our service, other parties, such as Google, may collect personally identifiable information about your activities over time and across different websites or online services.
Cookies And Other Trackers
What are cookies?
Cookies are text files, comprised of small amount of data, that are saved on your computer or other device (e.g. smartphone, tablet, etc.) when you use the internet and visit various websites.
The information that the cookies maintain is read by the website you visit, during the session of your visit to the website (these are called ‘session’ cookies), and when you return to visit it again (these are called ‘persistent’ cookies).
Necessary. Cookies that are strictly necessary for the functioning of Carmelo. Carmelo cannot operate properly without these cookies. You can set your browser to block or alert you about these cookies, but some parts of Carmelo may not function properly.
Preferences. Cookies that remember your choices when you use Carmelo and allow Carmelo to operate by reflecting your preferences.
Statistics. Cookies that help us understand how you and other users interact with Carmelo by collecting data that does not directly identify you.
Marketing. Cookies that track your use of Carmelo and allow us to tailor content, both on and off Carmelo, that we believe is relevant to you.
You can always delete or disable cookies
You can always delete the cookies saved on your device through your browser or device settings. You can also disable cookies for future uses through the settings options of your browser or device.
Additional GDPR Information
The joint data controllers of your personal data.
The following are the joint data controllers for the purposes of the personal data we process about you:
Carmelo, which may be contacted at: Yehuda HaMakkabbi St 53, Tel Aviv-Yafo, Israel.
When you make a reservation through Carmelo, the following are additional joint data controllers for the purposes of the personal data we process about you, based on the location of the accommodations you reserved:
For booking an apartment in Israel: Carmelo, which may be contacted at: firstname.lastname@example.org
Legal bases for processing your information.
The legal basis under EU law for processing your information for the purpose of sending you administrative and promotional notifications relating to Carmelo is our legitimate interests in informing users of administrative issues and promoting Carmelo’s business.
The legal basis under EU law for collecting and processing your information for Promotional Emails is your explicit consent.
The legal basis under EU law for processing information to provide you technical or customer support is our legitimate interests in assisting our users on issues relating to their use of Carmelo.
The legal basis under EU law for processing Analytics Information and Device Information to further develop and enhance Carmelo is our legitimate interests in understanding Carmelo’s business performance and enhancing Carmelo’s business.
The legal basis for sharing your information with competent authorities and with third parties for the purpose of handling violations is our legitimate interests in enforcing our legal rights.
The legal basis for disclosing your information at the request of a judicial, governmental or regulatory authority is our compliance with legal obligations to which we are subject.
The legal basis for processing your information for the purpose of notifying you or providing you with updates to this Policy is our legal obligation under the GDPR.
We will transfer your Information internationally only in accordance with applicable data protection laws.
Information we collect from you will be processed and the EU and in Israel, that is recognized by the European Commission as having adequate protection for personal data.
When we transfer your Information from within Europe to other jurisdictions outside Europe, we will do so by using adequate safeguards determined by the EU Commission.
You have certain rights to access, update or delete your information, obtain a copy of your Information, withdraw your consent and object or restrict certain data processing activities.
You have the following rights under the GDPR:
Right to Access your personal data that we process and receive a copy of it.
Right to Rectify inaccurate personal data we have concerning you and to have incomplete personal data completed.
Right to Data Portability, that is, to receive the personal data that you provided to us, in a structured, commonly used and machine-readable format. You have the right to transmit this data to another service provider. Where technically feasible, you have the right that your personal data be transmitted directly from us to the service provider you designate.
Right to Withdraw Consent to processing your personal data, at any time. If you do that, we will still process certain information on legal basis other than consent, as described in this Policy. Withdrawing your consent will not affect the lawfulness of data processing we carried out based on your consent before such withdrawal.
Right to Object, based on your particular situation, to using your personal data on the basis of our legitimate interests. However, we may override the objection if we demonstrate compelling legitimate grounds, or for the establishment, exercise or defense of legal claims. You may also object at any time to the use of your personal data to send you promotional emails.
Right to be Forgotten. Under certain circumstances, such as when your right to object overrides our legitimate interests, you have the right to ask us to erase your personal data. However, we may still process your personal data if it is necessary to comply with a legal obligation we are subject to under laws in EU Member States or for the establishment, exercise or defense of legal claims.
If you wish to exercise any of these rights, contact us at email@example.com.
We reserve the right to ask for reasonable evidence to verify your identity before we provide you with information. Where we are not able to provide you with information that you have asked for, we will explain the reason for this.
You have a right to submit a complaint to the relevant supervisory data protection authority.
Subject to applicable law, you have the right to lodge a complaint with your local data protection authority. If you are in the EU, then according to Article 77 of the GDPR, you can lodge a complaint to the supervisory authority, in particular in the Member State of your residence, place of work or of an alleged infringement of the GDPR. For a list of supervisory authorities in the EU, click here.
Changes To This Privacy Statement
If we change this Statement, we will provide you notice of such change through Carmelo.
From time to time, we may change this Policy, in which case we will inform you of the updated Policy by emailing you.
You can contact us at firstname.lastname@example.org.
Should you have any inquiries, complaints or suggestions, you may contact us at email@example.com. We will do our best to resolve your issue in a timely manner.
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