TERMS and CONDITIONS & privacy policy

We, Elkonin Hotel (hereinafter collectively: the “Hotel” or “we”), respect the privacy of our guests and customers and attach great importance to protecting their privacy and the security of their information.

We undertake to comply with the policy set out below (hereinafter: the “Privacy Policy”). The purpose of this Privacy Policy is to explain how we handle matters relating to your privacy and how we collect, use and process personal data (as defined by law; hereinafter: “Personal Data”) that you provide to us or that we collect during our engagement with you and during your stay at the Hotel.

This Privacy Policy constitutes an appendix to the General Terms and Conditions applicable to reservations and stays at the Hotel; it supplements them, does not derogate from them, and forms an integral part thereof.

To complete a reservation or receive services from the Hotel, you will be required to give your express consent to this Privacy Policy. Your express consent constitutes the legal basis for the collection and processing of your Personal Data as set out below.

1. Who We Are and How to Contact Us

Elkonin Hotel, through Afin Israel Ltd., 9 Lilienblum Street, Tel Aviv-Jaffa, Israel, is the owner and operator of the databases in which your details are stored. The Hotel is the “database controller” as defined in the Protection of Privacy Law and Amendment No. 13 thereto.

You may contact us with any question, any request to access, rectify or delete information, or any other matter relating to your Personal Data:

Email: Eva.BENSOUSSAN@accor.com
Telephone: +972-3-548-4000
Address: 9 Lilienblum Street, Tel Aviv 6513113, Israel
The Hotel will endeavor to respond to every inquiry within 30 days.

2. Notice of Data Processing – Duty of Disclosure

Pursuant to Section 11 of the Protection of Privacy Law, as amended by Amendment No. 13, we hereby notify you as follows:

Provision of information – mandatory or voluntary: Most information is provided of your own free will; however, basic details (such as full name, contact details and dates of stay) are required to process the reservation.
Consequences of not providing information: Failure to provide the required information may prevent us from completing the reservation or providing the requested services.
Purposes of collection: Set out in Section 4 below.
Identity of the controller: Afin Ltd. (see Section 1).
Transfer of information to third parties: Set out in Section 6 below.
Rights of access and rectification: Set out in Section 8 below.

3. Information About You That We Collect and Retain

We collect and retain information about you when we provide services at your request, in the ordinary course of operating the Hotel. Among other things, we collect and retain information that you provide when browsing our websites, during the booking process, at check-in, during your stay and at check-out.

Information may also be collected when you call our call center, make a purchase or reservation on our website, or visit the Hotel as a guest or visitor, or through travel agents, consumer clubs, survey companies and various service providers with whom we work.

We may collect the following information about you:

3.1 Information You Provide

Identification details: your full name, nationality, ID card / driver’s license / passport details, and date of birth.
Contact details: residential address, email address, telephone number and other contact details.
Financial details: credit card details and other financial information required for reservations and payments, which are transmitted through encrypted and secure channels and are not retained in full after the transaction is completed.
Reservation and stay history: data on previous reservations and on activities purchased during previous stays.
Family details: information about your family members, including children, and persons who stayed with you at the Hotel.
Special requests: room preferences and special requirements relating to your stay.
Sensitive information (as defined in Amendment No. 13): medical information, food allergies and disabilities, which is collected solely with your express consent and for a specific purpose disclosed to you at the time of collection.

3.2 Information Collected Automatically

Surveillance footage (CCTV): public areas of the Hotel are recorded by closed-circuit cameras to ensure your safety and that of the Hotel staff. Footage is retained for no longer than 30 days, in accordance with applicable law.
Browsing and network data: when you connect to the Hotel’s Wi-Fi or to our website, our systems may collect information about your IP address, browser type, time of access, pages viewed and the referring URL.
Cookies: by type; for details, see Section 5.

4. Use of Information

We may use your Personal Data solely for the following purposes:

To contact you to provide services and coordinate your stay at the Hotel, including changes or updates regarding your reservation.
To provide better service to you and your family members during your current stay and any future stay.
To respond to your inquiries and questions regarding your information.
To safeguard your security and that of other guests and Hotel staff.
To comply with legal obligations and disclose information to authorities in accordance with applicable law.
To inform you of changes to our Privacy Policy.
For statistical and aggregated use, combined with information from other guests, in order to improve our service and streamline operations, while minimizing the use of personal details to the extent possible.
To send marketing offers, promotions, special events and newsletters, subject solely to your express consent, which may be withdrawn at any time.

The Hotel will not use your Personal Data for any purpose not listed above without first obtaining your express consent.

The legal basis for collecting and processing your information may be one or more of the following: the existence of a contract between us and the provision of services at your request; the need for proper management of the Hotel’s operations in accordance with applicable law; compliance with a legal obligation; or your express consent.

5. Use of Cookies

Our websites use “cookies” and similar technologies for their proper ongoing operation and to improve the services provided through them. Cookies are small files placed in the user’s browser or device that are used to identify the user and to collect information about the user’s activity on the website.

We use the following types of cookies:

Essential (technical) cookies: required for the secure and proper functioning of the website (e.g., session management and security). These cookies operate without requiring your consent.
Functional cookies: store your settings on the website, such as your preferred interface language, previous reservation details and the last hotel you searched for. These cookies operate subject to your approval.
Session cookies: stored only temporarily and deleted when you close your browser. They are used to understand your browsing patterns on the website.
Marketing, tracking and advertising cookies (e.g., Google Analytics, social plug-ins and advertising pixels): collect information for targeted advertising and content tailored to your preferences. These cookies operate solely with your express consent.

You can manage your cookie preferences through your browser settings or via the cookie consent banner on our website. Please note that blocking essential cookies may impair the proper functioning of the website. In addition, third parties advertising on the website may use cookies that are not under our direct control, in accordance with their own privacy policies.

6. Transfer of Information to Third Parties

The Hotel will not sell, rent or transfer your Personal Data to third parties, except in the following circumstances:

Service providers acting as “holders” on our behalf (as defined in Amendment No. 13), such as credit card companies, hotel management software providers, mail services and reservation systems, subject to data processing agreements and to their undertaking to maintain the confidentiality and security of the information.
Government authorities, where disclosure of the information is required by law (e.g., the Israel Tax Authority, the Israel Police and the Privacy Protection Authority).
Subject to your express consent.

In any case of transfer to a third party, we take steps to ensure that the recipient applies appropriate security measures and receives only the information necessary to carry out the actions you requested.

7. Data Security and Retention

We are committed to protecting your information and apply appropriate technological and organizational security measures in accordance with the Protection of Privacy Regulations (Data Security), 5777-2017, in order to preserve the integrity and confidentiality of the information stored in our systems.

The Hotel operates at the level of data security required under the Regulations, in accordance with the classification of its databases. Nevertheless, as with any system, we cannot guarantee absolute protection against unauthorized access or intrusion.

In the event of a security incident (such as a data breach) affecting your information, the Hotel will report the incident to the Privacy Protection Authority in accordance with applicable law and will act to notify you as soon as possible.

7.1 Retention Periods

Your Personal Data will be retained only for as long as necessary, according to the following categories:

Financial records and reservation records: at least 7 years, in accordance with tax legislation.
CCTV footage: up to 30 days, unless otherwise required by law.
Marketing data and mailing lists: until you withdraw your consent.
Reservation and stay history: for the purpose of providing better service during future stays, in accordance with the need for proper management of the Hotel’s operations and with applicable law.

Information that is no longer required will be deleted securely and irreversibly.

8. Access, Rectification and Additional Rights

Under the Protection of Privacy Law, 5741-1981, and Amendment No. 13, you have the following rights:

Right of access (Section 13 of the Law): to inspect the Personal Data held about you in the Hotel’s databases. The Hotel will respond to your request within 30 days of receiving it.
Right to rectification (Section 14 of the Law): if, upon inspecting the information, you find that it is incorrect, incomplete, unclear or outdated, you are entitled to contact us and request its rectification. If the Hotel refuses to make the correction, it will notify you in writing and allow you to attach a statement on your behalf to the record.
Withdrawal of consent to marketing communications: at any time and unconditionally, by contacting us or by clicking the “unsubscribe” link in any marketing message.
Right to lodge a complaint: you may contact the Privacy Protection Authority (gov.il/privacy) if you believe that the processing of your information does not comply with the requirements of the law. You also have the right to file a claim with the Local Affairs Court in accordance with applicable law.

Such requests may be submitted to us by email at Reservations@thenorman.com. We will respond to your request as soon as possible, and no later than 30 days.

9. Database

The Personal Data you provide is stored in the Hotel’s databases in accordance with the Protection of Privacy Law. The Hotel is defined as a “database controller” (data controller) as defined in Amendment No. 13.

Under Amendment No. 13, the obligation to register a database applies only to public bodies and to entities that trade in the Personal Data of more than 10,000 individuals. The Hotel complies with all legal requirements applicable to it.

10. Updates to This Policy

We reserve the right to amend and update this Privacy Policy from time to time in response to changes in the law, technology or business operations. Material changes will be published on the Hotel’s website at least 30 days before they take effect. Guests whose information we already hold will be notified personally of any material change.