Privacy Policy

This Privacy Policy has been adopted by AM Leshem Group Ltd and/or Leshem Tourism and Recreation Ltd and/or Leshem Telephone Center, Ramada Netanya, Ramada Nazareth, Days Tiberias (the companies and hotels listed above will hereinafter be collectively referred to as “Leshem Hotels” or “We”) in all that pertains to collection and distribution of information (“Privacy Policy”).
The Privacy Policy describes the types of Personal Information as well as Other Information (as defined below), which Leshem Hotels collect on Users of its Services (as these terms are defined below), the manner Leshem Hotels collect the Information and the use Leshem Hotels makes of the Information, including storage, processing, transfer to third parties and more.
Where the words “you” or “your” appear in this Privacy Policy, it refers to all the Users of the Services (as defined below) and the Personal Information and Other Information (as defined below) referring to such users.
Leshem Hotels collects Personal Information and Other Information (as defined below) through the following:
(1) websites operated by Leshem Hotels for which you are accessing this Privacy Policy at www.leshemhotels.co.il, and other sites owned or controlled by Leshem Hotels (the websites will hereinafter be referred to, together, as the “Sites”);
(2) through apps that the Company makes available for your use on computers or mobile devices (hereinafter: the “Apps”);
(3) through social media pages owned and controlled by Leshem Hotels (hereinafter collectively: “Social Media Pages”);
(4) when you visit or stay as guests at one of the Hotels listed above or through another offline interaction with Leshem Hotels (such as when you phone the call center).
The Sites, Apps and Social Media Pages will be hereinafter be referred to, together, as the “Online Services” and together with the offline channels: the “Services”.
By using the Services, you agree to the terms of this Privacy Policy. Please read the Privacy Policy thoroughly.
Leshem Hotels serves as the Data Controller of the Personal Information about you.
The information that you have provided or will provide to Leshem Hotels, whether orally or in writing, depends on your consent and desire and does not derive from a legal obligation.
However, if you do not provide the Information to Leshem Hotels, or if you do not allow Leshem Hotels to collect such Information, Leshem Hotels will not be able to provide the Services to you.
Collection of Personal Information and Other Information

1. “Personal Information” means data that identify you as individuals or refer to a specific person. Leshem Hotels collects Personal Information such as:
1.1. Contact details (name, e-mail address, mailing address, telephone number, fax number, passport number, identity card number);
1.2. Payment information (payment card: digits and expiration date according to PCI DSS rules, billing address and bank account number);
1.3. Demographics (age, sex, home address, nationality, preferred language);
1.4. Information about family members and companions, such as children’s names and ages;
1.5. Information in connection with your reservation, with your stay or visit at Leshem Hotels (dates of arrival and departure, goods and services you purchased, personal preferences (as defined below), telephone calls made);
1.6. Information required to fulfill your special requests and/or special accommodation conditions (preferences, leisure activities, name of companion, number of children and their age);
1.7. Guest preferences (“Personal Preferences”), such as areas of interest, activities, hobbies, preferred food and beverage, services and requests about which you informed Leshem Hotels or preferences learned about you during your visit;
1.8. Information based on geographic location or other location;
1.9. Photos and video and audio files collected using security cameras located in public areas in Leshem Hotels, such as in corridors and lobbies of Leshem Hotels (CCTV systems and electronic key cards).

2. “Other Information” is data that do not reveal your personal and specific identity and do not pertain to a particular person. Leshem Hotels collects Other Information such as browser and mobile device data including IP address and data collected by “cookies”, pixel tags and other technologies, aggregate data regarding guests’ stay in Leshem Hotels and responses to promotional offers and surveys.

3. In some cases, Leshem Hotels combines Personal Information with Other Information (such as combining the guest’s name and location). In such a case, Leshem Hotels will treat the information as Personal Information as long as the information is combined.

4. If you provide information to Leshem Hotels and/or to Leshem Hotels’ service providers that includes Personal Information about third parties (for example, if you book for another person), you declare that you have received the third party’s consent to provide such information and that you are authorized to do so, and that the third party authorizes Leshem Hotels to use the information in accordance with the provisions of this Privacy Policy.
How Personal Information and Other Information are Collected in the Company
Personal Information and Other Information is collected as follows:

5. Online services: when making a reservation, purchasing goods or services, contacting the Company and its representatives in any manner, advertising on social media pages, enrolling in a mailing list or participating in surveys, giving feedbacks, participating in contests or responding to marketing offer, and when applying for a job at Leshem Hotels.

6. Visits and offline interaction: when visiting Leshem Hotels, while staying as a guest in Leshem Hotels and when using the services offered by Leshem Hotels. In addition, Personal Information is also collected when you participate in promotional marketing events as guests of Leshem Hotels and/or in promotional events hosted by Leshem Hotels or when you provide Personal Information in a sales promotion event. Personal information about you is also collected through a closed-circuit
camera system installed for security purposes in public areas in Leshem Hotels (CCTV), through electronic key cards and through other security systems.

7. Other sources: Personal Information is also obtained from third parties, including information from travel agents, frequent customer programs, credit card companies, state authorities (to comply with provisions of law), survey companies, Leshem Hotels’ service providers.

8. Automatic information: when you use Sites and/or use Apps (as defined above), Leshem Hotels receives and stores information in connection with the activity on such Sites and Apps, and additional automated information is collected from the browser and mobile device. For example, as is the case with other websites, we receive certain information when your browser accesses the Site, including information of your IP address, browser, operating system, mobile network data, pages viewed and browsing times. This information is used by us in contracting and in providing services to customers.

9. Customer service centers: when you make a reservation by phone, contact Leshem Hotels by e-mail, fax, online chat or through customer service, the communication may be documented to ensure quality of service and for training purposes.
10. Accumulated information: information that does not personally identify you or any other user.
Use of Personal Information and Other Information

11. Leshem Hotels uses Personal Information and Other Information for one or more of the following purposes:
11.1. Fulfilling reservations and purchases of services and products: Leshem Hotels processes information pertaining to the transactions you have entered into with Leshem hotels, including on the Sites (hereinafter: “Transaction Data”). The Transaction Data will be processed for completion of the reservation, provision of products and services, adapting services according to your preferences, receiving feedback about your stay at Leshem Hotels and keeping records of such transactions.
11.2. Contact with guests: to offer services that are based on your preferences – the information was collected prior to your stay and during your stay in any Leshem Hotel. The information may be used for frequent customer events which we may hold from time to time by ourselves or with partners, or that may be held by our partners.
11.3. Responses to inquiries: Leshem Hotels processes information upon receipt of inquiries for Users of its Services (hereinafter: “Inquiry Data”). Inquiry Data include the inquiry content plus metadata related to the inquiry (such as groups, meetings, and events). Inquiry Data are processed for communicating with you and keeping records.
11.4. Business purposes: Leshem Hotels processes the information for business purposes, including development of new products, Site improvement, Services improvement, identification of trends and visit patterns of guests, examining effectiveness of promotions, evaluating third party (such as travel agents) performance, forecasting yield and occupancy rates of Leshem Hotels, and meeting obligations.
11.5. Administrative and other communication: sending information about the Site to you, notification of changes in the Terms of Use, in the Privacy Policy or other administrative information (for example, emails confirming reservations you made).
11.6. Marketing and promotions: sending marketing and promotional messages about Leshem Hotels and about products and services that we think will interest you, including spa and gym services, bars, restaurants, etc.
11.7. Safety and security: maintaining health and safety for you, other guests and Leshem Hotels personnel during your stay in Leshem hotels.
11.8. Our legal obligations: for compliance with provisions of law, including acts, regulations, directives and legal proceedings.
11.9. Leshem Hotels uses Personal Information and Other Information, in whole or in part, for certain statistical computations, some of which are to be displayed on Apps, Site and/or other Services, provided they do not include identifying information.

12. The legal basis for the processing of Personal Information is one or more of the following:
12.1. Consent.
12.2. Provision of the Services.
12.3. Compliance with the law, including acts, regulations, orders, directives, judgments, etc.
12.4. Legitimate business interest of Leshem Hotels.
Disclosure and Transfer of Personal Information and Other Information

13. Leshem Hotels may disclose and transfer Personal Information and Other Information as follows:
13.1. To each of the Hotels listed above in this Privacy Policy – to provide a better experience to you as a guest, based on your personal preferences and the experience accumulated in connection with the use of the Services Leshem Hotels provided to you in your previous visits.
13.2. To the representative or travel agent who provided us with Personal Information about guests (for example, the travel agent, companion, employer or spouse).
13.3. To providers of services to Leshem Hotels. Service providers are, for example, IT service providers, legal counsels, accountants, payment service providers, etc.
13.4. To Leshem Hotels’ business partners in marketing and advertising – in order to publish ads that are relevant to users of the Site and for encouraging Users to visit the Site again. These partners will not use Personal Information for any other purpose other than direct marketing. In any case, you always have the right to object to such use of the information.
13.5. Leshem Hotels may forward Personal Information and Other Information about you to third parties upon a restructuring, merger, property sale or sale of shares in any of the Hotels listed above in this Privacy Policy, as well as in a joint venture, assignment of right and/or liabilities of any of the Hotels listed above in this Privacy Policy, and other transfer or disposition in the business and assets of Leshem Hotels, all or some thereof (including liquidation and similar proceedings).

14. Leshem Hotels may disclose Personal Information and Other Information if it is found to be necessary: (a) to comply with the provisions of law; (b) to comply with court orders in legal proceedings; (c) to respond to requests and inquiries from public or governmental authorities; (d) to enforce the Terms of Use; (e) to protect the business of Leshem Hotels; (f) to protect the rights, privacy, safety or property of Leshem Hotels, guests, Users of the Services and of others; and (g) to enable Leshem Hotels to act for reliefs to which it is entitled by law and/or agreement and to mitigate damages.
Transferring Information across Borders

15. In general, information processing is performed within the borders of the State of Israel. Processing of information carried out by third parties or cloud services can be performed on servers worldwide, such as Microsoft Azure servers or Microsoft 365 servers, Amazon servers, etc.

16. However, some of the information may be stored in a cloud outside the borders of the State of Israel or the European Union. The operator of these services has undertaken to comply with the EU’s General Data Protection Regulation (GDPR) provisions. In such a specific case, Leshem Hotels ensures that appropriate measures are taken to secure the Personal Information at an adequate level of protection.
How to access, modify or restrict the use of your Personal Information
If you are an EU resident, the following provisions will apply to you:

17. The right to receive information about processing Personal Information: we strive to provide you with concise, transparent, clear, unambiguous, simple and easily accessible information about the terms of processing of Personal Information.

18. The right to access, correct or delete Personal Information: we enable you to receive from us confirmation as to whether your Personal Information is processed and also details about the terms of processing such information, and to receive an electronic copy of such information.

19. The right to request correction of Personal Information.

20. The right to request deletion of Personal Information, subject to the provisions of any law and subject to the following conditions:
20.1. The Personal information is no longer needed for the purpose for which it was collected, stored and processed;
20.2. You request to withdraw your consent on which basis the Personal Information was processed and there is no longer a basis that justifies the processing of such Personal Information;
20.3. You believe and can substantiate the claim that the Personal Information was processed illegally;
20.4. The Personal Information will be deleted in accordance with Leshem Hotels’ obligation under the provisions of law;
20.5. The right to restrict processing of Personal Information: this right is available to you in several instances, and in particular –
20.5.1. upon disputing the accuracy of Personal Information;
20.5.2. if you believe and can substantiate the claim that processing the Personal Information is illegal but you object to deletion of the Personal Information and instead request that processing be restricted;
20.5.3. when the company no longer needs the Personal Information but you need the Personal Information to exercise, establish or protect your rights;
20.5.4. when the decision about the legitimate interest of Leshem Hotels outweighs your interests as the subject of the information.

21. The right to transfer information:
21.1. If the basis for processing the Personal Information is consent or an agreement, you are entitled to receive the Personal Information you provided to Leshem Hotels in a standard form and transfer this information to another stakeholder.

22. The right to withdraw consent:
22.1. When the basis for processing the Personal Information is consent, you may withdraw your consent at any time by the means provided for this purpose (as described below in this Privacy Policy). It is noted that withdrawal of such consent applies only to the future and does not apply to information that was processed prior to withdrawing the consent. For the avoidance of doubt, it is clarified that the withdrawing the consent will not call into question the legality of processing the Personal Information that was carried out prior to withdrawing the consent.

23. The right to decide on Personal Information after death:
23.1. You may decide what will be done with the Personal Information after death by giving general or specific instructions. Leshem Hotels is committed to respect these instructions. If no instructions were given, Leshem Hotels acknowledges the possibility that heirs may exercise certain rights, and in particular the right to access the Personal Information, as the case may be, for the rights of the estate of the deceased; the right to object to closing the deceased’s user accounts; and the right to object to processing the information of the deceased.

24. The right to complain to the relevant privacy protection authority:
24.1. If, notwithstanding Leshem Hotels’ efforts to maintain the confidentiality and privacy of your Personal Information, you feel that your rights have been breached, you have the right to file a complaint to the relevant privacy protection authority. A list of authorities is available on the European Commission’s website.

25. If your place of residence is outside the European Union (including Israel), you have the right to review and correct the information stored in Leshem Hotels’ databases in accordance with the provisions of Israeli law, including the provisions of the Protection of Privacy Act, 5741-1981.
Data Security

26. Leshem Hotels implements reasonable organizational and technical measures to protect Personal Information in all that pertains to unauthorized access, disclosure and exposure of the information, deletion or alteration of the information, accidental, misuse of the information or damage. Leshem Hotels reviews and monitors these protection and security measures at appropriate frequency.

27. When it is required to disclose or transfer Personal Information to third parties and to authorized parties, Leshem Hotels ensures that these third parties undertake to maintain an adequate and appropriate standard of information protection. Leshem Hotels require contractual obligations from third parties that the Personal Information be processed solely for the purposes for which you gave your consent and in accordance with the required level of confidentiality and security.

28. If you have reason to believe that your communication with Leshem Hotels is not secure (for example, if you believe that your personal hotel account has been breached) please contact us immediately as described in the “Contact Us” section below.
Information retention period

29. Subject to the provisions of any law, Leshem Hotels will retain the Personal Information for the period required for the implementing the following:
29.1. The purposes for which the Personal Information was provided;
29.2. Business interest of Leshem Hotels, including information retention;
29.3. A requirement to retain information that may be relevant to regulatory investigations or legal proceedings;
29.4. Compliance with the provisions of any law, regulation, legal proceeding, including court orders and/or disclosure required by government and other authorities;
29.5. To fulfill a legitimate interest of Leshem Hotels and of third parties, including defense against legal proceedings, and more.
Sensitive information

30. Unless specifically requested, Leshem Hotels requests not to provide or disclose within the use of the Services or in any other way any sensitive Personal Information (e.g. Social Security numbers, race or ethnicity data, political opinions, religion, ideology or other beliefs, health data, biometric data or genetic data, criminal record, administrative or criminal proceedings and sanctions imposed in connection with the foregoing).
Use of services by Minors

31. Leshem Hotels does not knowingly collect personal data from any person under the age of 18.

32. Leshem Hotels collects personal data from persons under the age of 18 as part of the guest registration process, but always subject to the consent of the minor’s parent or custodian.
Updates

33. The Company may amend and update this Privacy Policy from time to time at its sole discretion without notice. The Users only are responsible for knowing the changes, as the case may be, that will be made to the Privacy Policy.
Cookies

34. Like many other sites, Leshem Hotels uses “cookies” in order to improve the user experience on the Site and web pages. Cookies do not provide hotels with personally identifiable information, unless the User chooses to provide such information (for example, by registering for one of the Services). However, if you elect to provide personally identifiable information on the Site, that information will be linked to data stored in a cookie.

35. A cookie is a small text file that contains small amounts of information that the site places in the User’s computer or mobile device. Cookies are designed to help the computer or device remember something the User did on the Site; for example, remember that the User logged into the account or which and how many keys were pressed.

36. Leshem Hotels uses cookies as a tool for understanding the use of the Site and for improving the content and offers on the site. This use is made in order to customize the user experience on Leshem Hotels web pages, to offer relevant products, programs and services and for targeted advertising.

37. Disabling cookies – your browser may enable you to control cookies; some browsers can enable settings that prevent storing cookies. If you do not agree to the use of cookies, please disable the cookies in the browser settings. Please note that after disabling cookies, certain features on the Site may not work properly.
There are third parties that activate certain types of cookies that provide automatic deactivation tools for their cookies: a list of cookies activated by third parties may be viewed with a link to their automatic deactivation. In other cases, the cookies can be disabled using third-party management tools.

38. The Company uses a variety of cookies, as follows:
38.1. Session cookies – these files are temporarily stored during the browsing activity and are deleted from the mobile device after the browser is closed. We use temporary cookies to support the operation of the Site and to understand your use of the Site; for example, the pages you visited, the links you used and the time you spent on each page.
38.2. Essential cookies – these cookies are necessary for the operation of the site.
38.3. Functional cookies – we use functional cookies to save the Site settings, such as the preferred currency in checking hotel prices on the Site. Leshem Hotels also uses functional cookies to store data such that they can be easily found on your next visit to the Site. Certain functional cookies are essential for viewing maps or videos on the site. The company uses Flash cookies for certain animated content.
38.4. Persistent cookies – these cookies are not deleted when the browser is closed, but are stored on the device for a limited period or until they are deleted. Each time you visit the site, the server that set the cookie will recognize the persistent cookie stored on your device. The company uses persistent cookies to store your preferences so that they will be available for you on your next visit. For example, if you have already logged in to the website, these cookies will skip the log in step in your next visit to the site.
38.5. Targeting and Advertising Cookies – the use of these cookies is for gathering your information to help Leshem Hotels improve the products and Services and to display targeted ads that Leshem Hotels believes are of interest to you. Leshem Hotels uses targeting cookies on the Sites for various marketing initiatives and campaigns. Leshem Hotels also uses “analytics cookies” (see below) and other technologies to promote advertising.
38.6. Analytics cookies – these cookies collect information about your use of the Site and allow Leshem Hotels improve Site’s functionality. Analytics cookies provide Leshem Hotels with aggregate information used by Leshem Hotels to monitor the Site performance, count visits to each page, detect technical errors, check how users reach the site and measure the effectiveness of advertising and targeted ads.

39. The Site uses third party cookies as follows:
39.1. Google Analytics cookies – these are used to collect information about how users use the Site. Leshem Hotels uses information derived from these cookies to create reports and improve the Site. These cookies collect information anonymously; for example, to count the number of visitors, from where Users reached the site and which buttons the User pressed. Read Google’s Privacy Policy at _____ in connection with Google Analytics for how to disable Google Analytics cookies. Google cookies include Google Doubleclick & AdWords for marketing, advertising and remarketing, which enable identifying visitors to our advertising partners and addressing them with ads and information based on interest. To learn more about Doubleclick & Google AdWords cookies, see _______.
39.2. Facebook Cookies – the use of these cookies is for interest-based advertising, that is, ads that you may like based on your activity on non-Facebook websites. These cookies collect information from your visit to the Site and enable promotion of ads through Facebook platforms. For more information about interest-based Facebook ads, see __________.
See ____________ for more information about Facebook’s Privacy Policy.
39.3. Bing/Microsoft cookies – Bing cookies are used to collect information about how visitors use the Company’s Site as well as for marketing, advertising or remarketing. These cookies allow identification of visitors to websites of our advertising partners and are used to direct to them targeted information or ads. See _____________ for more information about Bing/Microsoft Privacy Policy.
Contact Us
If you have any questions regarding this Privacy Policy or Leshem Hotels’ practices in privacy matters, please contact our information security officer Oren Rochman by e-mail at: [email protected]
Version updated as of October 1, 2020