PRIVACY POLICY OF WWW.MYFRONTO.COM

What does the following Privacy Policy consist of?

The Administrator takes the data protection of your personal information very seriously. We process your personal data in compliance with the statutory privacy and data protection legislation. If you use this website, different parts of your personal data will be collected. Personal information is any kind of data that can identify you. This policy explains who and how will process your personal data, how long your personal data will be stored, what protection measures are taken in connection with the processing of your personal information, etc.
When you choose to provide your personal information, you declare that you have become aware of this privacy policy.

Who processes your personal data and is responsible for it?

Your personal data is processed by FRONTO B.V., Address: Teleport Towers, Kingsfordweg 151, Amsterdam, the Netherlands(hereinafter referred to as "the Administrator"). Administrator is a subject who decides on its own or togetherwith others the purposes and ways in which the data will be processed (names, emails, addresses, etc.).

How is data collected on our website?

Some of the data we collect is collected only when you provide it to us. Such a case, for example, is the collection of your data when you fill in the "Contact Form" on our website. Another part of the data is collected automatically by our IT systems when you visit our site. That data is mainly technical in nature, for example - the browser and operating system you are using or the time you visit our website. This data is collected automatically as soon as you visit our website.

What rights do you have regarding your personal data?

You are always free to request information about the collected data, its origin, recipients and the purpose for which it is used. You also have the right to request that data to be corrected, blocked, or deleted. You may contact us at any time if you have any further questions regarding the privacy and data protection. Of course, you can complain to the competent authorities, if necessary. More information about your rights and how to exercise them can be found below in this policy.

Are third-party analysis methods and tools used?

When visiting our website, statistical analyses may be made of your surfing behavior. This happens primarily through the use of cookies and analytics. The analysis of your surfing behavior is usually anonymous, i.e. we will not be able to identify you from this data. You can object to this analysis or prevent it by not using certain tools. You can object to this analysis. Detailed information can be found in the following Privacy Policy.

How do we process your personal data?

Cookies:

Cookies do not harm your computer and do not contain any viruses. They help make our website more user-friendly, efficient, and secure. Cookies are small text files that are stored on your computer and saved by your browser. Most of the cookies we use are so-called “session cookies”. They are automatically deleted after your visit. Other cookies remain in your device’s memory until you delete them. These cookies make it possible to recognize your browser when you next visit the site. You can configure your browser to inform you about the use of cookies so that you can decide on a case-by-case basis whether to accept or reject a cookie. Alternatively, your browser can be configured to automatically accept cookies under certain conditions or to always reject them, or to automatically delete cookies when closing your browser. Disabling cookies may limit the functionality of www.myfronto.bg. FRONTO B.V., AMSTERDAM, has a legitimate interest in the storage of cookies to ensure an optimized and free of technical errors service. If other cookies (such as those used to analyze your surfing behavior) are also stored, they will be treated separately in the corresponding Cookie Policy on the website.

Server Log Files:

The website www.myfronto.com automatically collects and stores information that your browser automatically transmits to us in "server log files". These are:

• Browser type and browser version
• Operating system used
• Host name of the accessing computer
• Time of the server request
• IP address

These data will not be combined with data from other sources.

Email subscribtion

Fronto is an innovative service, which provides solutions for hotels. It gives your guests easy access to your hotel services and information. Suitable for every hotel - city, business, conference, holiday, spa or apart hotel. When you use www.myfronto.com, you can choose to subscribe to our newsletter, and then keep track of up-to-date news and promotions in relation to the platform. For this you will need to provide us with the following information:

• E-mail;

After you provide your email, the latter will be used for the so-called direct marketing operations, to the extent permitted by law. When we use your personal data for direct marketing purposes, trade newsletters, and marketing communications for new products and services, or other offers that we believe may be of your interest, we, also, include a connection and/or special termination functionality that can be used when you no longer want to receive messages when using the future. This can be done by pressing the Unsubscribe button. In this case, we will stop processing your personal data and erase it from our data base.
You can unsubscribe from receiving our newsletter by sending an email to team@myfronto.com.

Contact Form:

In the "Contact Us" section on www.myfronto.com or by referring from another section of the website, you can contact us and we will be happy to answer your inquiry. We will need the following information in such case:

• Two or three names;
• Email;

If you send us questions through the contact form, we will collect the data entered in the form, including the contact details you provide to answer your question and any subsequent questions. We do not share this information without your permission.
We will store the data, which you provide to us in the contact form, until you request its deletion, cancel your consent for storage, or the storage purpose no longer applies (for example, after your request has been executed). Any mandatory legal provisions, especially those concerning mandatory retention periods, remain unaffected by this provision.
You can revoke your consent at any time. Data processed before we receive your revocation will still be legally processed.

Social media.

Facebook:

Our website includes plugins for the social network Facebook, Facebook Inc., 1 Hacker Way, Menlo Park, California 94025, USA. The Facebook plugins can be recognized by the Facebook logo or the Like button on our site. For an overview of Facebook plugins, see https://developers.facebook.com/docs/plugins/. When you visit our site, a direct connection between your browser and the Facebook server is established via the plugin. This enables Facebook to receive information that you have visited our website from your IP address. If you click on the Facebook "Like button" while you are logged into your Facebook account, you can link the content of our site to your Facebook profile. This allows Facebook to associate visits to our site with your user account. Please note that, as the operator of this site, we have no knowledge of the content of the data transmitted to Facebook or of how Facebook uses these data. For more information, please see Facebook's privacy policy at https://de-de.facebook.com/policy.php. If you do not want Facebook to associate your visit to our site with your Facebook account, please log out of your Facebook account.

Twitter:

Functions of the Twitter service have been integrated into our website. These features are offered by Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA. When you use Twitter and the “Retweet” function, the websites you visit are connected to your Twitter account and made known to other users. In doing so, data will also be transferred to Twitter. We would like to point out that, as the provider of these pages, we have no knowledge of the content of the data transmitted or how it will be used by Twitter. For more information on Twitter's privacy policy, please go to https://twitter.com/privacy. Your privacy preferences with Twitter can be modified in your account settings at https://twitter.com/account/settings.

Instagram:

Our website www.myfronto.com contains functions of the Instagram service. These functions are offered by Instagram Inc., 1601 Willow Road, Menlo Park, CA 94025, USA.

If you are logged into your Instagram account, you can click the Instagram button to link the content of our pages with your Instagram profile. This means that Instagram can associate visits to our pages with your user account. As the provider of this website, we expressly point out that we receive no information on the content of the transmitted data or its use by Instagram.

For more information, see the Instagram Privacy Policy: https://instagram.com/about/legal/privacy/.

Bulletins

In case you have given your consent to receive an invitation when Fronto launches its work, and then be kept informed with any other up-to-date news and promotions regarding the platform by periodically receiving newsletters in the form of email, then we require you have a valid email address.

This website uses the services of MailChimp to send newsletters. This service is provided by Rocket Science Group LLC, 675 Ponce De Leon Ave NE, Suite 5000, Atlanta, GA 30308, USA.

MailChimp is a service which organizes and analyzes the distribution of newsletters. If you provide data (e.g. your email address) to subscribe to our newsletter, it will be stored on MailChimp servers in the USA. MailChimp is certified under the EU-US Privacy Shield. The Privacy Shield is an agreement between the European Union (EU) and the US to ensure compliance with European privacy standards in the United States.

We use MailChimp to analyze our newsletter campaigns. When you open an email sent by MailChimp, a file included in the email (called “web beacon”) connects to MailChimp's servers in the United States. This allows us to determine if a newsletter message has been opened and which links you click on. In addition, technical information is collected (e.g. time of retrieval, IP address, browser type, and operating system). This information cannot be assigned to a specific recipient. It is used exclusively for the statistical analysis of our newsletter campaigns. The results of these analyses can be used to better tailor future newsletters to your interests.

If you do not want your usage of the newsletter to be analyzed by MailChimp, you will have to unsubscribe from the newsletter through the means described above in this policy.

The data provided when registering for the newsletter will be used to distribute the newsletter until you cancel your subscription when said data will be deleted from our servers and those of MailChimp. Data we have stored for other purposes (e.g. email addresses for the members area) remains unaffected.

For details, see the MailChimp Privacy Policy at https://mailchimp.com/legal/terms/.

On what legal basis do we process your data?

We process the personal data you have provided us exclusively on the basis of your explicit consent to submit your personal data. In certain cases, we may process your personal data in connection with legal obligations we have or in order to protect our legitimate interest. In any case, we will process your personal data, on the grounds provided in Art. 6 of Regulation (EC) 2016/679 of the European Parliament and of the Council of 27 April 2016.

What rights do you have as a subject of personal data?

You have the following rights for which we will assist at any time:

• Get information from the time of collection of your personal data;
• Withdraw your consent to the processing of your personal data;
• Require access to your personal data;
• Require your personal data to be corrected;
• Require your personal data to be deleted;
• Restrict the processing of your personal data;
• Oppose the processing of your personal information;
• Take use your right to portability of your personal information;
• To seek protection of your rights by means of a complaint to the Supervisory authority on a national level or by court order.

How can you enforce your rights?

• Any of the above rights may be exercised by sending a written notice to the following address FRONTO B.V., Address: Teleport Towers, Kingsfordweg 151, Amsterdam, the Netherlands, addressed to the Administrator. The application may also be made electronically. The application is submitted personally by you or by a person authorized by you unless a special law provides otherwise.
• The application must contain the name, address and other identification data of the individual concerned, description of the request, preferred form of communication and actions under Art. 15-22 of Regulation (EC) 2016/679, signature, date of filing of the application and address for correspondence. If the application is filed by an attorney, an explicit power of attorney should also be attached.
• You can download a blank application here .

If you have any questions about how to exercise your rights, please contact us at team@myfronto.com.

What if you do not consent to processing your personal data or withdraw your consent?

If you do not agree to processing your personal data or withdraw your consent, you will not be able to use the services offered by www.myfronto.com for which providing data is required.

What if I am not 16 years old?

We process personal data only of persons who have reached the age of 16. By providing us with your personal data, you declare that you are over 16 years of age.

What measures have we taken to protect your personal data?

We understand how important it is your personal data to be properly processed and protected. The Administrator's team has put in place adequate technical and organizational measures to protect your personal data. These measures ensure compliance with the principles underlying the processing of personal data by ensuring that your personal data is:

• Processed in a lawful, conscientious and transparent manner with respect to the data subject ("lawfulness, good faith and transparency");
• Collected for specific, explicit, and legitimate purposes and not processed in a way inconsistent with these goals ("Goal limitation").
• Relevant, related and limited to what is necessary in relation to the purposes for which they are being processed ("Data minimization");
• Accurate and up-to-date. We have taken all reasonable steps to ensure the timely erasure or correction of inaccurate personal data, having in mind the purposes for which they are being processed ("accuracy");
• Stored in a form that allows the data subject to be identified for a period no longer than is necessary for the purposes for which the personal data are processed; ("Storage limitation");
• Processed in a way that ensures an appropriate level of security of personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, by applying appropriate technical or organizational measures ("integrity and confidentiality");
• The Administrator bears the responsibility and is able to demonstrate compliance with the basic principles of data processing ("accountability").

When can we change our current policy?

The Administrator reserves the right to modify this policy at any time by updating, supplementing, and amending it. For changes to this policy, you can get informed via www.myfronto.com.