This Privacy Policy explains how we collect and manage your information, and the choices you can make about the way your personal data is used. We respect your privacy and commit ourselves to protect the privacy and security of the personal data you provide to us on the telephone via our call center or in person or that we collect about you when you visit our website and our social media pages, as well as when you use our software applications or book our room. We are aware of our responsibilities to protect your personal data, to keep it secure and comply with applicable privacy and data protection laws.

Please read this page carefully before you start to use our website. It may include links to other websites over which we have no control. Hanasa Puluong is not responsible for the privacy policies or practices of other websites. If you access these websites via our website, you should review the privacy policies of those websites so you can understand how they collect, use and share your information.

Your information we collect and process from you:

When you create an account or book a reservation, or when you use our website, your information (information that identifies you or relates to you as an identifiable person) that we may collect through the sites about yourself or others include:

• Your contact information (e.g. salutation, name, telephone number, email address, postal address, organisation);
• Your financial information (e.g. credit card number, security code, expiration date);
• Information related to your travel profile (e.g. accommodation and travel preferences, booking history, special health accommodations, any comment your note to us);
• Information related to your client profile (e.g. delivery address, country of residence, favourite currency);
• Your marketing preferences, including any consents you have given us;
• If you contact us or our agents, we may keep a record of that communication and any communications and correspondence with you; and
• Information related to the browser or device you use to access our sites, including where available, your IP address, operating system and browser type, for system administration and security reasons and to collect aggregate information.

Your information that we collect from third parties:

• Sometimes, we receive information about you from third parties. In particular: we may receive information about you from travel agents, tour operators and destination management companies, corporate companies whom you have direct contact with. The information we collect from such third parties include your contact information and information related to your travel profile.
• When you interact with us on social media platforms such as Facebook, Instagram and YouTube (depending on your privacy preferences on those platforms);
• Through cookies and related tracking technologies, such as Google.

We may use the personal data you supply to us via our site for the following purposes

To fulfil a contract, or take steps linked to a contract: this is relevant where you make bookings or place an order with us. This includes, for example:

• Processing and facilitating bookings, including verifying your identity, taking payments and communicating with you
• Providing customer services

As required by us to conduct our business and pursue our legitimate interests, in particular:

• Responding to requests which you have submitted via our site and to deal with on-going matters relating to such requests
• Presenting content from our site in the way that we consider most effective
• Providing you with highly-individualized service at our Retreat and presenting you with information relating to Avana Retreat
• If you provide a credit or debit card as payment, we use third parties to check the validity of the sort code, account number and card number you submit in order to prevent fraud
• Monitoring customer accounts to prevent, investigate and/or report fraud, terrorism, misrepresentation, security incidents or crime, in accordance with applicable law
• Using information you provide to investigate any complaints received from you or from others, about our website or our products or services
• Using data in connection with legal claims, compliance, regulatory and investigative purposes as necessary (including disclosure of such information in connection with legal process or litigation)

Where you give us consent:

• Providing you with travel-related information, information relating to Avana Retreat or promotional details about products and services that may be of interest to you, as well as personalised mailings (electronic or otherwise) or other communications
• Placing cookies and using similar technologies in accordance with the “Use of cookies and related tracking technologies” section and the information provided to you when those technologies are used
• Invite you to join our e-newsletter distribution
• On other occasions where we ask you for consent, we will use the data for the purpose which we explain at the time.

For purposes which are required by law, such as:

• In response to requests by government or law enforcement authorities conducting an investigation.

Wherever we rely on your consent, you will always be able to withdraw that consent, although we may have other legal grounds for processing your data for other purposes, such as those set out above. In some cases, we are able to send you direct marketing without your consent, where we rely on our legitimate interests. You have an absolute right to opt-out of direct marketing, or profiling we carry out for direct marketing, at any time. You can do this by following the instructions in the communication where this is an electronic message, or by contacting us using the details set out below.

• If there is a corporate sale, merger, reorganisation, insolvency event or other similar event.
• Our staff (including employees and external consultants), professional advisors and agents;
• Third party service providers which process your personal data on behalf of Hanasa Puluong and who are bound by contractual obligations to keep your personal data confidential and appropriately secure. In particular, we use third party providers of website hosting, backend service provider, analytics, crash reporting, and email marketing;
• Government authorities, regulatory agencies and law enforcement officials, if required for the purposes specified above, if mandated by law, or if required for the legal protection of our legitimate interests in compliance with applicable laws;
  If there is a corporate sale, merger, reorganisation, insolvency event or other similar event

We use reasonable technical, administrative and physical measures to protect Personal Information contained in our system against misuse, loss or alteration. While we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security. We cannot enforce or control the security of the computers, electronic devices, or electronic communication method that you use to send e-mails and submit Personal Information to us over the Internet. You are responsible for ensuring that the computers, electronic devices and electronic communication methods you utilize will provide adequate security for communicating with us. We are not responsible for the disclosure or interception of your Personal Information before we receive it.

Whenever we collect or process your Personal Information, we will only keep it for as long as is necessary for the purpose for which it was collected, active legal proceedings, an identifiable and ongoing legal business need (such as record keeping) and to the extent permissible by applicable law. Where there is no sufficient justification to retain such Personal Information, such Personal Information will be safely and securely deleted, disposed of, blocked and/or anonymised for example by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning.

Please be aware that the The Hanasa Puluong has not designed this site for, and does not intend for it to be used by, anyone under age 18. Accordingly, this website should not be used by anyone under the age of 18. Our privacy policy prohibits us from accepting users who are under the age of 18. The Hanasa Puluong specifically requests that persons under the age of 18 not use this Site or submit or post information to the Site. Should the The Hanasa Puluong inadvertently acquire personal information or other data from users under the age of 18, we will not knowingly provide this data to any third party for any purpose whatsoever, and any subsequent disclosure would be due to the fact the user under the age of 18 used the Site and submitted personal information without solicitation by or permission from The Hanasa Puluong.

Subject to applicable laws, you may have rights in relation to your personal data. Such rights include:

• You have the right to ask us for a copy of your personal data; to correct, delete or restrict (stop any active) processing of your personal data; and to obtain the personal data you provide to us for a contract or with your consent in a structured, machine readable format, and to ask us to share (port) this data to another controller.
• In addition, you can object to the processing of your personal data in some circumstances (in particular, where we don’t have to process the data to meet a contractual or other legal requirement, or where we are using the data for direct marketing).
• These rights may be limited, for example if fulfilling your request would reveal personal data about another person, where they would infringe the rights of a third party (including our rights) or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping. We will inform you of relevant exemptions we rely upon when responding to any request you make.
• To exercise any of these rights, or to obtain other information, such as a copy of a legitimate interests balancing test, you can get in touch with us using the details set out below.
• We will aim to respond to all legitimate requests as soon as we reasonably can and in any event within 30 days. If we think that it will take us longer than 30 days, we’ll let you know why and keep you updated. Where you make any requests, we might ask for specific information to confirm your identity as a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. This might include asking for further information in relation to your request to be able to speed up our response.

A cookie is a small file of letters and numbers that is sent to your computer by a website and automatically saved on your computer by your web browser. Each time you request a page from the website, your web browser sends this cookie back to the website server.

We use cookies to improve your experience on our websites and to recommend content that may be of interest to you. You can find out more below about what cookies are and the cookies we use.

What cookies do we use?

We uses the following cookies:

• Strictly Necessary Cookies
  These cookies are essential to the operation of our services. Without these cookies, the services in question would not work properly (e.g. you wouldn’t be able to navigate around the site or access certain types of content). These cookies cannot therefore be turned off.
• Functionality Cookies
  These cookies provide you with a better browsing experience based on the choices you make. These cookies allow our website to remember choices users make (such as the country you visit our website from, language, text size, fonts, currency, and search parameters) and provide enhanced, more personal features. These can then be used to provide you with an experience more appropriate to your selections and to make the visits more tailored and pleasant.
• Performance Cookies
  Performance cookies, which often include analytics cookies, collect information about your use of our services and enable us to improve the way they work. For example, performance cookies show us which are the most frequently visited pages on our website, allow us to see the overall patterns of usage, help us record any difficulties you have with our services. We also use cookies to help you navigate within our website and travel back to pages more efficiently.
• Social Media Cookies
  These cookies are used when users share information using social media accounts. These cookies are used when you share information using a social media sharing button or “like” button on our sites or apps, or when you engage with our content on or through a social media site such as Facebook, Instagram, LinkedIn and YouTube.

How do I turn cookies off?

If you do not wish us to install cookies or you don’t agree with how we use these cookies, you can change the settings on your internet browser to reject them. For more information please consult the “Help” section of your browser or visit www.aboutcookies.org, www.allaboutcookies.org or http://optout.aboutads.info/#/. Please note that if you do set your browser to reject cookies, you may not be able to use all of the features on our websites.

Any changes we make to our privacy notice in the future will be posted on this page and, where appropriate, notified to you by e-mail or otherwise. Regularly reviewing this page ensures that you are always aware of what information we collect, how we use it and under what circumstances, if any, we will share it with other parties If you have questions about The Retreat website policies, please contact:

• Hanasa Puluong Resort.
• Don Village, Thanh Lam Commune, Ba Thuoc, Thanh Hoa Province, Vietnam.