Vinodirect s. r. o. (Monarch Hospitality) Privacy Statement

About us

The owner and operator of this Vinodirect s.r.o. (Pohostinec Monarch) website and mobile website (the "Platforms") is Vinodirect s.r.o. (Pohostinec Monarch), whose principal place of business is located at Na Perštýně 15, 110 00 Prague 1. This privacy statement applies to the www.monarch.pohostinec.cz website and our other Platforms, our operations and our loyalty programs and explains how we use the personal information we may collect about you. We are part of a broader group of companies, Premier Wines & Spirits Group s.r.o., which includes the following entities and/or divisions: Premier Wines & Spirits s.r.o., Grand Cru Restaurant & Bar s.r.o. (Grand Cru Restaurant and Lodecká 4 Wine Bar), Vinodirect s.r.o. (Monarch Hospitality) and Premier Food s.r.o. (Karlín Hospitality), some of their related brands and/or companies.

What this privacy statement covers

By visiting our Platforms or using our products or services, you consent to the use and disclosure of your personal information in the manner described in this Privacy Statement. We will not collect personal information about you unless you provide us with your express consent or permission (for example, by agreeing to this Privacy Statement or through an electronic checkbox or other measure as required by local privacy and data protection laws).

Personal data we collect

When you use our Platforms, we automatically collect certain information, such as your browser type and IP address (which is a series of numbers identifying your Internet connection). This collection may occur through cookies (see "Cookies" below) or analytics services (see "Data Collection, Data Analytics and Social Media Features" below). We may collect personal information directly from you when you use our Platforms, contact us by phone, email or in person (e.g. your phone number or email). We may also collect Personal Data from third parties to whom you have authorized that they may transfer your Personal Data to us (e.g., restu.com). We will combine the data we collect from you automatically with any other data we collect directly from or about you. We also collect and store certain personal information as set out below.

Using platforms

1. When you create an account with us, we collect the following information: salutation, first name, last name, loyalty program number (if applicable), date of birth (if required), phone number, email address;
2. when you sign up for Premier Club and Premier Gold Club, we collect the same information as when you sign up, plus the following information: password and physical address. Other conditions set out in the Premier Club and Premier Gold Club rules also apply;
3. when you sign up for Premier Club and Premier Gold Club, we collect the same information as when you sign up plus the following information: the name of the organisation, the address of the organisation and its telephone number;
4. if you make a payment, we will collect different information depending on the method of payment. For example, for credit card payments, we collect the following information: credit card holder's name, address, card number, expiration date and CVC code.
5. to add new information and preferences to your Premier Club or Premier Gold Club profile. For example, information about your favorite beverage or food or allergy.

We may occasionally update the collection methods and data fields above. If there are material changes, we will notify you in accordance with the "Notification of Changes to this Privacy Statement" section below.

Information about other persons

You may provide us with information about other people, for example:

1. 1.if you ask us to inform them or allow them to manage your booking on your behalf; or
2. 2. if you make or manage a booking for or on behalf of another person who has authorised you to do so. We need to know the names of all passengers. If you make a restaurant reservation on behalf of someone else, you must obtain their consent to use their personal information, including sensitive personal information as described below. In our business, we assume that such consent has been given to you. If required by local law, we encourage you to retain proof of that person's consent and provide them with a copy of or link to this Policy. This is especially true if you provide us with sensitive information of the person concerned. You may also provide us with information about other people for purposes such as referring a friend so that we can offer them our products or services. You may only contact individuals through our Platforms who you know would be happy to hear from you, and you may not use our products or services to send unsolicited messages ("spam").

How do we use personal data?

We use the data we collect as follows:

• for the purpose or processing of your booking or intended booking, including processing your booking, sending you an itinerary or other information related to your booking or contacting you if there are any problems with your booking (for example, a message informing you that your booking has not been completed);
• personalising the services we provide, for example, if we know your profile and your previous bookings or preferences, we can tailor our products and services to you;
• sharing data with loyalty programmes and promoters, including Premier Club and Premier Gold Club (and in each case their affiliated programmes for which you have an account);
• We may use location data for our mobile website and mobile app to enable us to offer the most useful format and content, provided you have consented to the use of your location data;
• to register you on our platforms and administer our products or services on the platforms you have registered to subscribe to. You may unsubscribe from these products and services on the Platforms at any time (see Choice/Opt-out below);
• for the purposes of administering competitions, prize draws or your acceptance of any other promotional offer that you may enter and notification of winners, as further specified in the relevant General Terms and Conditions;
• to customize the look and feel and use of our Platforms and our communications with you, and to meet your preferences that you have informed us about or that we have inferred from your use of our Platforms, market research and (if you have consented) social media and networking;
• to respond to any enquiries you may have made to us by email or other means of communication and we may keep records of these contacts, including records of telephone calls (to the extent permitted by local law);
• for the purposes of conducting customer satisfaction surveys and improving our product and service offerings or creating new products and services;
• for the purposes of complying with our legal obligations or for accounting or auditing purposes, including the prevention of fraud in online payments and the use of loyalty programmes;
• to protect our property, our rights and interests and the property, rights and interests of others;
• for purposes required by law, such as to respond to a valid subpoena or regulatory order;
• for auditing and creditworthiness purposes;
• for the purpose of protecting against criminal activity;
• for direct marketing purposes, as detailed below in the section "How do we use your personal data for marketing purposes?"; and
• for such other purposes as you may subsequently consent to from time to time.

What sensitive personal data can you request or retain?

Sensitive personal data includes information about an individual's health and religion and other categories of personal data that are strictly protected. We do not usually collect this information from you (or from the people for whom you are making a booking), but if we do, we try to limit the collection and use of it. If you tell us about a health problem you or another person on your booking has:

• Requires special assistance
• suffers from special allergies

then you acknowledge that you have voluntarily provided this information to us and you agree (and the persons for whom you are making the booking agree) that we may use this information to provide you with those products or services and/or to decide whether it is appropriate for us to provide you with our products or services. If we can infer your religious beliefs or health status from your dietary preferences, we will not use this information other than to fulfill your dietary preferences. In any event, you expressly consent (for yourself and for those for whom you are making a booking) that we may use and transfer the information outside your country to anywhere in the world where you have travelled or from where we provide our products or services (or Premier Wines & Spirits Group Ltd or our service providers do so) (see "Who we disclose your personal information to" section below). How do we use your personal data for marketing purposes?

Where you have indicated that you would like to receive updates from us:

• We may send you marketing communications to keep you informed of developments in products and services available through our Platforms and products and services from our carefully selected partners (provided that we keep you informed in accordance with our own marketing);
• where we are able to identify, or where you have informed us that you wish to receive relevant information, other entities within Premier Wines & Spirits Group Ltd and/or other third parties may also send you marketing communications or updates relating to their products and services; and
• we will use information about your personal preferences that you have informed us about, that we have derived from cookies (see our Cookie Policy) and/or that we have derived from your use of our services (see Data Collection, Data Analytics and Social Media Features below) or from market research. We will use this information to tailor the advertising and communications you receive to be relevant and interesting to you.

You may opt-out of receiving specific electronic messages at any time (see "Withdrawing Consent" below).

Who do we disclose your personal data to?

We may disclose information about you as follows:

• We may disclose information to other entities within Premier Wines & Spirits Group Ltd (as defined above) in order to achieve the purposes set out above;
• to our external service providers and processors as set out below;
• external advertising and social media platforms for the purpose of offering advertising and information requested by social media platforms in order to provide users with the requested functionality;
• in operating our loyalty programs and recommending other loyalty programs as set out in their terms and conditions;
• We may also disclose your personal information to the extent permitted or required by law. For example, we may disclose your personal information to government authorities that are authorized to receive it, to comply with a warrant or order issued by a court of competent jurisdiction, and to comply with recordkeeping requirements;
• if all or substantially all of the assets of Vinodirect s.r.o. or a member of Premier Wines & Spirits Group s.r.o. are sold or the business is sold or transferred, such member of Premier Wines & Spirits Group s.r.o. may transfer the personal information under its control to a third party purchaser who agrees to use the personal information for the same purposes as set out in this privacy statement;
• to anyone to whom we transfer or may transfer our rights and obligations under the contract with you;
• to your friends if you ask for a "friend referral" or similar;
• where you have instructed another person to manage your booking;
• to customs and/or immigration authorities or other regulatory authorities in the country of departure and/or destination (or in the countries through which you will be flying during your trip) in order to comply with the laws in force in those countries;
• where it is our duty to do so or where the law allows us to do so; and
• our employees and agents to carry out any of the above activities on our behalf, now or in the future.

Cooperation with other service providers and companies within the Premier Wines & Spirits Group s. r. o.

For operational reasons, we transfer personal data to service providers and companies within Premier Wines & Spirits Group s.r.o. that help us manage our systems and processes and deliver our products or services to users. These may include: banks and credit card verification service providers, our data warehouse and customer relationship management centre, marketing organisations (who may provide marketing and promotional communications support); internet service providers who manage our platforms and provide access to internet services and host our facilities; drivers, handling and assistance teams, IT service providers and consumer research companies who help us to identify consumer interests by conducting surveys. We have security measures in place to ensure that our service providers handle personal information in a manner that complies with the terms of this privacy statement and applicable laws, and that such information is not used other than for the purpose of delivering products or services to our company, or where we believe there are legitimate reasons associated with the products or services we offer, or as set out in the section "What sensitive personal information may you request or retain?" above.

Storage

We retain data for as long as necessary for the purposes of administering bookings and providing other relevant products or services as contemplated in this privacy statement, including providing you with updates on our marketing offers, and including where required by law or for record keeping purposes. We also retain your information to facilitate our future cooperation and to personalize the products and services we provide to you and our communications with you.

Consent

If you choose to provide us with your personal data, this means that you consent to the use of that data in accordance with the principles set out in this privacy statement at the time you are asked for that personal data. We and other members of the Premier Wines & Spirits Group Ltd may contact you by telephone or email, by text or messaging or mobile device notifications (and obtain your consent where required) to provide you with product or service updates as well as information about other offers, products, services or events that we think may be of interest to you.

Withdrawal of consent

You do not have to provide us with your personal data. However, if you choose not to disclose any of your personal information that we request and/or need, or you do not consent to our use and disclosure, you may still be able to visit our Platforms, but you may not be able to access certain features, products or services and in some cases we may not be able to process your reservation. For any marketing communications we send you, you will have the option to withdraw your consent to receive them in the future. If you no longer wish to receive promotional material, you can unsubscribe from these communications by clicking here or by changing your account settings. Your address will then be removed from the Vinodirect s.r.o. mailing list. To opt-out of receiving messages or notifications on mobile devices from Vinodirect s.r.o. apps, go to "settings" on your device and turn off notifications from the relevant Vinodirect s.r.o. apps. Keep in mind that if you unsubscribe from our marketing communications altogether, we may not be able to keep you informed or tailor offers to meet your needs. Please note that if you unsubscribe from marketing communications, you will continue to receive operational and service messages from us regarding your booking and responses to your enquiries and that we may keep your details on an unsubscribe list so that we do not send you marketing communications in the future. You also have the option to change your cookie settings to block certain types of cookies - please see our Cookie Policy for a detailed explanation.

Security

We will take appropriate steps to ensure that the personal information you share with us is protected. We have implemented technology and security features to protect the confidentiality of your personal information. We invest significant resources to protect your personal information from loss, misuse, unauthorized access, alteration or disclosure. However, no website is 100% secure and we cannot be held responsible for unauthorized or unintended access outside of our control.

Protecting your information and protecting you from internet fraud

Here are some simple measures you can take to make sure your information is kept safe:

• Keep your Premier Club and Premier Gold Club number and customer login details confidential. You should not share your login details with anyone else. You should log out when you have finished working on our platforms. This is particularly important if you are using a publicly accessible computer.
• Be aware of 'phishing', which is where someone tries to pose as someone else in order to extract information from you - always check that emails actually come from the sender and if in doubt, go to their website directly and do not click on any links in emails as these may take you to 'cloned' websites that use your information in an illegal way.

Data collection, data analysis and social media features

We may collect personal information and remove any identifying elements from it in order to analyze patterns and improve our marketing and promotional practices, analyze the use of the Platforms, improve content and product offerings, and customize the content and layout of the Platforms and the products and services offered, and we may designate third parties to perform these activities on our behalf. We collect certain user information, such as the number and frequency of visits to our Platforms. This information may include information about which websites you just came from, which websites you go on to, what browser you use, and information about your device and IP address. We use this data only in the aggregate. This aggregate data helps us determine the extent to which our customers use different parts of the Platforms and to conduct research related to our users' demographics, interests, and behaviors so that we can better understand and accommodate them. If you use buttons associated with social media or similar sites on our Platforms (for example, "Like" and/or "Share" buttons), content from our Platforms may be sent back to those other websites or services and, depending on your settings, may be privately or publicly visible (for example, by your friends, people who follow you, or generally anyone who has access to your profile page).

Cookies and other tracking technologies

A "cookie" is a small computer file that is downloaded to your device. It collects information about how you move around our Platforms and the Internet and helps us provide you with better services and tailor certain content on the Platforms. For more information on how we use cookies, please see our Cookie Policy, which also includes information on how to delete cookies or block specific types of cookies. However, you should note that this may affect our ability to provide you with services on the Platforms. Please also see the section "Data collection, data analytics and social media features" above.

Unfollowing

Our systems do not accept requests from browsers for do not track in a timely manner. However, you can delete cookies and other tracking technologies through the processes specified in our Cookie Policy.

Statement under the "Shine the Light" law in California

We may transfer your information to carefully selected third parties for those third parties' own marketing purposes. If you are a California resident, you may contact us once a year to request the names of these third parties and the categories of data we share with them. To do so, please submit a request as set forth below, along with valid proof of your California residency. Please note that it may take up to 30 days to process your request.

Links

Our Platforms may contain links to other websites. We would like to advise you that for websites not operated by us or any of the Premier Wines & Spirits Group Ltd. entities, we are not responsible for the privacy practices employed. We encourage you to read the privacy statements of all sites that collect personally identifiable information. This privacy statement applies solely to information collected by our platforms.

Correction/updating of personal data

If your personally identifiable information changes or is inaccurate or you no longer wish to use our services, we will allow you to correct, update or delete the personal information you have provided to us. If you believe that any information we hold about you is incorrect, please contact us. These rights apply without prejudice to any other rights you may have under applicable law, including your right to refuse the processing of certain data.

Access to your personal data

You have the right to a copy of the personal data we hold about you, including its sources, purposes and methods of processing, electronic decision making and the parties with whom we share your data. We will endeavour to make the information you request available to you within a reasonable time. Depending on what information you request, we may charge you a small fee to the extent permitted by applicable law.

Transfer of your personal information

However, we will only do this if required to do so by applicable law.

Notification of changes to this privacy statement

If we decide to change our privacy statement, we will post information about those changes on our platforms. If at any time we decide to use personally identifiable information in a manner significantly different from that stated at the time of collection (and/or if required by applicable law), we will notify you. You will be able to decide whether we will use your information in this different manner. We will use the information in accordance with the principles set out in the privacy statement under which it was collected, unless you consent to a different practice. However, if you do not accept the modified privacy statement, please stop using our platforms. Each version has a version number and date so that you can easily verify everything.