THE OZEN COLLECTION (“TOC”) respects the privacy of all its customers, business clientele, and treats personal information provided by you as confidential. We pledge to fully comply with the requirements of the International Personal Data (Privacy) Ordinance. We use your personal data and information in order to fulfil our commitment to provide you with distinctive OZEN standards of hospitality service. This Privacy Policy explains our practices regarding the personal information we collect from you or about you on this site or via our apps, through written or verbal communications with us, when you visit one of our properties, or from other sources.

Resident of the European Economic Area (EEA), please view additional information regarding AHR’s use of your personal information in the ADDITIONAL INFORMATION RESIDENTS IN EUROPEAN ECONOMIC AREA (EEA) section.

CAPTURING PERSONAL INFORMATION

We collect personal information at every touchpoint or guest interaction, and in conducting every aspect of our business. This personal information may include: your name, mailing address, billing address, email address, phone number, information related to your reservation, stay or visit to a property; information related to the purchase and receipt of products and/or services; nationality, passport number and date and place of issue; travel history; payment information, such as your payment card number and other card information, as well as authentication information and other billing and account details associated with mobile billing; guest preferences; marketing and communication preferences; reviews and opinions about our Portfolio of Brands or properties; and other types of information that you choose to provide to us or that we may obtain about you.

Furthermore, we collect other personal information in certain cases, such as;

Surveys: We may request demographic data or other personal information in customer surveys.

On-property Collection: We collect additional personal information during registration/check-in at our properties, including such information as may be required by local laws. We may also use closed-circuit television and other security measures at our properties that may capture or record images of guests and visitors in public areas, as well as information related to your location while on our properties (via keycards and other technologies). We may also use closed-circuit television and other technologies that record sound or video for the protection of our staff, guests and visitors to our properties where permitted by law. In addition, we may collect personal information in connection with on-property services, such as concierge services, spas, activities, child care services and equipment rental.

Social Media: If you choose to participate in AHR sponsored social media activities or offerings, we may collect certain information from your social media account consistent with your settings within the social media service, such as location, check-ins, activities, interests, photos, videos, status updates and friend list. We may also allow you to enter competitions to provide photos, videos relating to your stay with us, which you may share with your connections on social media for votes, shared offers or other promotions.

In addition to the information we collect from you directly, we may also infer or collect information about you based on the information you provide to us or from the information we collect or infer from any other sources.

APPLICATION OF PERSONAL INFORMATION

We use captured personal information in multiple ways to personalise the services you request and expect from Atmosphere Hotels & Resorts, conduct direct marketing and sales promotions and as set forth below in more detail. We will collect your consent prior to processing your data where required by applicable law. We are obligated to collect certain data, including your name, address, payment information, and, in certain countries, travel document information, in order to process your reservation. Failure to provide this information will result in our inability to process your reservation.

Marketing and Communications: Where permitted or reasonably applicable, we may use your personal information to provide or offer you newsletters, promotions and featured specials, as well as other marketing messages in accordance with any communications preferences you have expressed. We use your information to provide in-stay messaging, account alerts, and reservation confirmations; to send you marketing messages; to conduct surveys and other activities. We may provide these communications via email, postal mail, online advertising, social media, telephone, text message, push notifications, messaging applications, in-room television and other means. With your consent, we also use user-generated content from social media services to deliver display advertising or on our website and apps.

Service Enhancements: We may use your personal information to improve Atmosphere Hotels & Resort’s services and to ensure that our site, products, and services are of interest to you. We also use your personal information to provide you with the expected level of hospitality in-room and throughout our properties.

Data Accuracy, Analytics, and Personalization: We may aggregate your personal information with data from third-party sources for purposes of keeping information up to date and analytics. We also rely on information from third parties in order to provide better and more personalised service. For example, if you connect your social media services or other accounts to our services, we may use this information to make your experiences with us more personal.

DISTRIBUTE PERSONAL INFORMATION

In order to offer you the expected level of hospitality and to provide you with the best level of service, we may share your personal information among our service providers, and other third parties as set forth in detail below:

On-property Services: We may share personal information with third-party providers of on-property services such as concierge services, WiFi access providers, transport service providers, spa treatments, diving and watersports centres, golf, or dining experiences.

Service Providers: We rely on third parties to provide services and products on our behalf and may share your personal information with them as appropriate. Generally, our service providers are contractually obligated to protect your personal information and may not otherwise use or share your personal information, except as may be required by law. However, our fraud detection service providers may use, but not share, your personal information for fraud detection purposes. We may use service providers to communicate news and deliver promotional and transactional materials to you on our behalf, including personalized online and mobile advertising in accordance with your preferences and applicable law. Please see our Policy on Cookies and Other Technologies for more information. Atmosphere Hotels & Resorts will only work with parties that offer a method to opt-out of such advertising. We may also share information with service providers to allow you to create itineraries by selecting sites, activities, and restaurants from lists that we have personalized for you based on your preferences and third-party data.

 Other: In addition, Atmosphere Hotels & Resorts may disclose personal information in order to:

OTHER INFORMATION

When you visit and interact with Atmosphere Hotels & Resorts websites and apps, we collect other information that does not directly identify you about your use of the site, such as a catalogue of the site pages you visit, and the number of visits to our sites (“Other Information”). We use Other Information, as well as data received from third parties, to deliver you email, online (on our sites and other sites) and mobile advertisements.

We use cookies and other technologies (such as “pixel tags,” “web beacons,” “clear GIFs”, links in emails, JavaScript, device IDs assigned by Google or Apple, or similar technologies) to collect this information. If you want to remove or block Cookies from your device at any time, you can update your browser settings (consult your browser’s “help” menu to learn how to remove or block Cookies). Atmosphere Hotels and Resorts is not responsible for your browser settings.

We may use the information we have collected and aggregated, or anonymized personal information received from third parties, to understand more about our users, customers or clientele (for example, we may use the aggregated information to calculate the percentage of our users who have a particular telephone area code). This includes demographic data, such as date of birth, gender and marital status, inferred commercial interests, such as favourite products or hobbies, and other information we may collect from you or from third parties.

SENSITIVE INFORMATION

The term “sensitive information” refers to information related to your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, sex life or sexual orientation, genetic information, criminal background, and any biometric data used for the purpose of unique identification. In some jurisdictions, mobile phone numbers, location data, and information contained on identity documents also are considered sensitive information. We do not generally collect sensitive information unless it is volunteered by you or unless we are required to do so pursuant to applicable laws or regulations. We may use health data provided by you to serve you better and meet your particular needs (for example, the provision of disability access).

PERSONAL INFORMATION FROM CHILDREN

We do not knowingly collect personal information from individuals under 18 years of age. As a parent or legal guardian, please do not to allow your children to submit personal information without your permission.

LINKS TO THIRD-PARTY WEBSITES AND SERVICES

Our site may contain links to third parties’ websites. Please note that we are not responsible for the collection, use, maintenance, sharing, or disclosure of data and information by such third parties. If you provide information on and use third-party sites, the privacy policy and terms of service on those sites are applicable. We encourage you to read the privacy policies of websites that you visit before submitting personal information.

PROTECTING PERSONAL INFORMATION

Atmosphere Hotels and Resorts will take reasonable measures to: (i) protect personal information from unauthorized access, disclosure, alteration or destruction, and (ii) keep personal information accurate and up-to-date as appropriate. Atmosphere Hotels and Resorts maintains a PCI compliance program and an IT compliance program. In the event of a security incident, we will notify regulators and/or consumers as required by applicable laws or regulations.

We also seek to require our affiliates and service providers with whom we share personal information to exercise reasonable efforts to maintain the confidentiality of personal information about you. For online transactions, we use reasonable technological measures to protect the personal information that you transmit to us via our site. Unfortunately, however, no security system or system of transmitting data over the Internet can be guaranteed to be entirely secure.

For your own privacy protection, please do not send payment card numbers or any other confidential personal information to us via email. We will not contact you by mobile/text messaging or email to ask for your confidential personal information or payment card details. We will only ask for payment card details by telephone when you are booking a reservation or promotional package. If you receive this type of request, you should not respond to it. We also ask that you please notify us at [email protected]

CHANGING AND ACCESSING YOUR PERSONAL INFORMATION

To the extent required by applicable law, you may be able to request that we inform you about the personal information we maintain about you and, where appropriate, withdraw your consent for certain data processing activity and/or request that we update, correct, delete, and/or stop processing your personal information. We will make all required updates and changes within the time specified by applicable law and as required by law. When permitted by law, we may charge an appropriate fee to cover the costs of responding to the request. Such requests may be submitted in writing to [email protected] or THE OZEN COLLECTION Data Protection Officer, 3rd Floor, Aage’, 12 Boduthakurufaanu Magu, Henveiru, Male’ 20094, Republic of Maldives. To protect your confidentiality, we can only respond to such requests to the email address that you have registered or otherwise provided to us.

In addition, in some circumstances based on applicable law, you may request that we cease sharing personal information about you with our business partners and service providers or that Atmosphere Hotels and Resorts cease using personal information about you by contacting us using the email or mailing address above. We will seek to honour those requests consistently with applicable law.

RETAINING PERSONAL INFORMATION

We retain personal information about you for the period necessary to fulfil the purposes outlined in this policy unless a longer retention period is required or permitted by applicable law. We retain personal information collected in order to fulfil guest reservations for seven years after the stay is completed. We retain other personal information for shorter periods of time if possible and if permitted by law.

We will destroy your personal information as early as practicable and in a way that the information may not be restored or reconstructed.

If printed on paper, the personal information will be destroyed in a secure manner, such as by cross-shredding or incinerating the paper documents or otherwise and, if saved in electronic form, the personal information will be destroyed by technical means to ensure the information may not be restored or reconstructed at a later time.

CHOICES – MARKETING COMMUNICATIONS

If you have given us your contact information (mail address, fax number, email address or phone number), we may want to inform you in accordance with any preferences you have expressed, and with your consent where required, about our products and services or invite you to events via email, online advertising, social media, WeChat, WhatsApp, Telegram, telephone, text message (including SMS and MMS), push notifications, in-app alerts, postal mail, our customer service call centre, and other means (including on-property messaging, such as your in-room television). If you prefer not to receive email marketing materials from us, you may opt-out at any time by writing in to [email protected] . Opt-out requests can take up to ten business days to be effective.

PRIVACY POLICY MODIFICATIONS

We may modify this policy from time to time. When changes to this policy are made we will post a link to the revised Statement on the homepage of our site, and if you have registered for any of your products or services, will may also inform you though a communications channel that you have provided. Any changes to our policy will become effective upon posting of the revised policy on the site. Use of the site, any of our products and services, and/or providing consent to the updated Statement following such changes constitutes your acceptance of the revised policy then in effect.

CONTACT US

If you have any questions about this policy or how Atmosphere Hotels and Resorts processes your personal information, or if you wish to either provide a compliment or a complaint, please contact us by email at [email protected] or by postal mail to THE OZEN COLLECTION Data Protection Officer, 3rd Floor, Aage’, 12 Boduthakurufaanu Magu, Henveiru, Male’ 20094, Republic of Maldives. We will respond within 30 days or sooner if practicable.

ADDITIONAL INFORMATION RESIDENTS IN EUROPEAN ECONOMIC AREA (EEA)

For individuals residing in the EEA, this section outlines certain additional information that Atmosphere Hotels and Resorts are obligated to provide to you, as well as certain rights you have with respect to the processing of your personal information, pursuant to applicable laws.

Data Protection Officer: Atmosphere Hotels and Resorts’ Data Protection Officer may be contacted by email at [email protected] , or at the following address: Attn: Data Protection Officer THE OZEN COLLECTION 3rd Floor, Aage’ 12 Boduthakurufaanu Magu Henveiru Male’ 20094 The Republic of Maldives.

Purposes and Legal Basis for Processing: Atmosphere Hotels and Resorts processes your personal information for the purposes set forth in the Privacy Policy. The legal bases for Atmosphere Hotels and Resorts’ processing activities include processing such information as necessary or reasonably required to comply with our contractual obligations, compliance with our legal obligations, protecting the safety of our employees, guests and others, for our legitimate business interests, pursuant to your consent. The particular legal basis for the processing of your personal information is based on the purpose for which such information was provided or collected:

Surveys: Completion of surveys is voluntary – we process the information obtained from surveys on the basis of your consent and in furtherance of our business interests, including marketing, service improvements, and analytics.

On-property Collection:

Social Media: Participation in Atmosphere Hotels and Resorts’ sponsored social media activities and offerings is voluntary – we process information obtained from social media participation on the basis of your consent and in furtherance of our related business interests, including for marketing, service improvements, and analytics and service personalization, as described in the Privacy Policy.

Direct Marketing: We use your personal information to send you marketing messages on the basis of your consent. You may withdraw your consent for direct marketing communications at any time by contacting us at [email protected]

Retention: We retain personal information about you for the time necessary or reasonably required to accomplish the purpose for which such information was collected, usually for the duration of any contractual relationship and for any period thereafter as legally required or permitted by applicable law. Our retention policies reflect the applicable statute of limitation periods and legal requirements.

Data Subject Rights: Residents of the EEA have the following rights:

Right to Object to Processing: You have the right to request that we cease processing of your personal information:

Right to Restrict Processing: You have the right to request that Atmosphere Hotels and Resorts limit the processing of your personal information:

Data Portability Requests: You have the right to request that we provide you or a third party that you designate with certain of your personal information in a commonly used, machine-readable format. Please note, however, that data portability rights apply only to personal information that we have obtained directly from you and only where our processing is based on consent or the performance of a contract.

Submitting Requests: your requests may be submitted by accessing the Data Subject Rights Request Portal or in writing to [email protected] or the THE OZEN COLLECTION Data Protection Officer, 3rd Floor, Aage’, 12 Boduthakurufaanu Magu, Henveiru, Male’ 20094, Republic of Maldives. You may also update your personal information as mentioned on the Privacy Policy. We will respond to all such requests within 30 days of our receipt of the request unless there are extenuating circumstances, in which event we may take up to 60 days to respond.

We will inform you if we expect our response to take longer than 30 days. Please note, however, that certain personal information may be exempt from such rights pursuant to applicable data protection laws. In addition, we will not respond to any request unless we are able to appropriately verify the requester’s identity. We may charge you a reasonable fee for subsequent copies of data that you request.

If you have concerns about our data practices or the exercise of your rights, you may either contact AHR at [email protected], or the supervisory authority in the Member State of your residence.

Right to Withdraw Consent: You have the right to withdraw your consent to any processing that we conduct solely based on your consent (such as sending direct marketing materials to your personal email account). You may withdraw your consent to marketing activities by following the instructions on any marketing emails or contacting [email protected].

Segmentation (also referred to as profiling) and Automated Decision Making: We use personal information to divide large groups of consumers into sub-groups of consumers (known as segments) based on some type of shared characteristics such as geography, behaviour, or demographics. With your consent, we make automated decisions, meaning without human interference, using segmentation and/or your specific personal information to offer you certain benefits based on your characteristics (such as discounted room rates or other special offers based on your geography, behaviour, or demographics).

International Data Transfers: We may transfer the personal information we collect about you pursuant to the purposes described in this Statement to countries that have not been found by the European Commission to provide adequate protection. In particular, we transfer your personal information to the Maldives.