SINAE Phuket Luxury Hotel

1. Purpose and scope of this Notice

TRAVELHUBX respects your privacy

and is committed to protecting your personal data. This notice regarding the

processing of personal data (hereinafter referred to as "Notice") is

intended to provide you with relevant information on how we process your personal

data when:

• you access the dinamix.thx.ro

Website.

• you book travel packages.

• you provide us, in any other

way, with your personal data (such as phone number, e-mail, WhatsApp, Facebook,

Instagram, or other accounts on social networks).

• you subscribe to our

newsletter.

• you travel with us

This Site is intended for adults

only and the only situations in which we collect data relating to minors are

when you book travel and children’s packages.

This Notice informs you about the

processing operations of personal data (as defined by the relevant legislation,

including the General Data Protection Regulation 2016/679 - hereinafter

referred to as "GDPR") carried out by TRAVELHUBX, in the capacity of

the personal data controller.

The controller of your personal

data is TRAVELHUBX S.R.L. and is responsible for your personal data

(hereinafter referred to as "TRAVELHUBX", "we" or

"our" in this Notice).

2. The controller of your

personal data and the contact details of the Data Protection Officer

The operator of your personal

data is TRAVELHUBX S.R.L., having its registered office in Piatra Neamț, str. 1

Decembrie 1918, nr. 60, Neamț, having the serial number in the Trade Register

J27/4/2021, unique registration code RO 43512519 (hereinafter referred to as

"TRAVELHUBX", "we" or "our" in this

Notification).

Given the applicable legal

provisions, TRAVELHUBX has appointed a Data Protection Officer.

If you have any questions about

this Notice or any other request regarding the processing of your personal data

or the exercise of your legal rights, please contact our Data Protection

Officer using the following contact details:

• (1) Email: dpo@TRAVELHUBX.ro

• (2) Mailing address: Piatra

Neamț Municipality, str. 1 Decembrie 1918, nr. 60, Neamț, Romania.

The personal data we hold must be

accurate and current. Please let us know if any of the details you provide us

will change during your relationship with us.

3. External links

This Site may include links to

third-party websites or applications. If you click on those links or enable

these apps, third parties may allow data about you to be collected or shared.

We do not control these third-party websites and are not responsible for their

Personal Data Processing Policies. When you leave circuiterra.net Site, please

review the Policies of each site you visit.

4. Personal data collection

According to the legislation in

force, "personal data" means any information relating to an

identified or identifiable person. An identifiable person is one who can be

identified, directly or indirectly, in particular by reference to an identifier

such as a name, an identification number, location data, an online identifier,

or to one or more elements specific to their physical, physiological, genetic,

mental, economic, cultural or social identity.

When you access the dinamix.thx.ro

Site or communicate with us or we provide travel or any other type of services

for you, we may process the following categories of personal data:

Contact and/or identification data, including name

and surname, address (domicile or residence), telephone number, e-mail,

series and the number of the identification document (ID card/passport),

personal numerical code as well as the information contained in these

documents, voice, call history.

Data related to the services requested, including

details of services booked or provided, details of payments to and from

you, including bank account, contact details and identification for people

who travel with you, chat history on WhatsApp or social media accounts

(Facebook, Instagram, etc.).

Data regarding candidates (in case of recruitment

processes), including candidate details, e-mail address, address, current

employer, job history, education, licenses/certifications, information

regarding studies as well as other information included in the curriculum

vitae.

Data used for advertising, marketing, and publicity

purposes, including name, surname, image, voice, feedback transmitted, ID

(username/name used on the social network), and social network account

images (in case of ID and images published on social media accounts, TRAVELHUBX

will mention the presence of that person in pictures and videos published

on social media accounts or websites belonging to TRAVELHUBX).

Special categories of personal data, such as

dietary requirements that may reveal your religious or philosophical

beliefs and health data

We collect and process the above

data only if it’s strictly necessary to provide the travel services you have

purchased. In addition, we will collect and process the special categories of

personal data mentioned above, only if you have provided us with your explicit

consent in this regard. 

You have no obligation to give

your consent to process your special categories of personal data unless it is

necessary for the provision of booked tourist services. However, without your

consent, we cannot take the necessary steps to provide the travel services you

have booked or are trying to book. Only if this information is necessary for

the provision of tourist services, if you do not provide us with that data and

we do not have your consent, we will not be able to provide the booked tourist

services

5. Source of personal data

Personal data can be obtained

from the following sources:

• directly from you when: you

book a package of travel services on circuiterra.net Site, when you subscribe

to newsletters or other publications, send testimonials, communicate feedback,

and participate in organized contests.

• through the activities you

carry out during the period you benefit from the travel services offered, such

as photos, WhatsApp chat history

• from third parties, such as

when we receive your personal data from third parties requesting the provision

of travel services (people traveling with you).

6. Purpose of personal data

processing

TRAVELHUBX collects, processes,

and uses personal data:

• for purposes that allow the

provision of tourist services booked on the dinamix.thx.ro Website;

• for purposes that enable TRAVELHUBX

to fulfill its purposes relating to its business and its legal obligations;

• to enable the initiation or

performance of a contractual relationship with you;

• for advertising, marketing, and

publicity purposes;

• for purposes that allow you to

participate in competitions and events organized by TRAVELHUBX for the dinamix.thx.ro

project;

• to exercise the rights and

obligations of the parties resulting from the contracts signed by the parties

or in connection with the services provided;

• to protect the interests of the

parties in promoting legal actions and defending against any claims and

lawsuits;

• to ensure compliance with the

legal provisions regarding the storage and archiving of data/documents;

• to exercise TRAVELHUBX’s rights

in accordance with the legal provisions and comply with legal obligations;

• for purposes subsumed to the

general purpose of providing tourist services.

To avoid doubt, TRAVELHUBX will

not use your personal data for advertising, marketing, and publicity purposes

unless you expressly consent to do so.

7. Disclosure of personal data

Your personal data will only be

disclosed within TRAVELHUBX to managers and other persons who need access to

your personal data ("need to know basis") to perform their specific

duties for the purposes listed in point 6 above or where required or permitted

by applicable law.

TRAVELHUBX may also provide your

personal data to third parties providing services in connection with booked

travel services, IT support services, or technical and organizational services

(in connection with activities related to TRAVELHUBX’s activity) or to legal,

audit consultants, or other consultants or suppliers of TRAVELHUBX, only for

the purposes mentioned in this Notice

TRAVELHUBX will exercise due

diligence in selecting third-party service providers and will require that such

providers maintain appropriate technical and organizational security measures

to protect your personal data and process it in accordance with applicable legal

provisions.

TRAVELHUBX may also disclose your

personal data to authorities as required or permitted by law, insurance

entities, external consultants, and/or courts. Your personal data will only be

disclosed to such third parties to the extent necessary in connection with the performance

of contracts, TRAVELHUBX’s activities, and/or the purposes listed in point 6

above

8. Transfer of personal data

outside the EU or EEA

Many of our external travel

providers are located outside the European Union (EU) or the European Economic

Area (EEA), so the processing of your personal data will involve a transfer of

data outside the EU or EEA.

If you have booked a package

travel that is located or to be fulfilled outside the EU or EEA, we are obliged

and authorized to transfer your personal data to the service provider outside

the EU or EEA, in order to fulfill the contract we have with you.

If personal data is processed for

advertising, marketing, or advertising purposes and is posted on social

networks or transmitted via WhatsApp, the transfer of personal data will take

place on servers of social networks that may also be located outside the

territory of the European Union, including the United States of America.

Please contact us if you would

like further information on the specific mechanism used by us when transferring

your personal data outside the EU or EEA.

9. Legal basis for processing

personal data

The legal bases of the personal

data processing operations described in this Notice are:

• performance of a contract to

which you are a party or to take steps before concluding a contract;

• our legitimate interests and/or

the need to enter into or execute a contract, in accordance with the legal

provisions on data confidentiality.

• your consent

Our legitimate interests or those

of a third party include our requirements to use your personal data in

litigation, investigations by authorities, data processing for advertising,

marketing, or advertising purposes, or for other lawful purposes involving TRAVELHUBX.

10. Data security

TRAVELHUBX maintains physical,

technical, and organizational security measures to protect personal data

against accidental, unlawful, or unauthorized destruction, loss, alteration,

disclosure, restriction, or access, wherever processed.

Our security policy governs how

we protect your personal data. A copy of this security policy can be obtained

from our Data Protection Officer.

11. Duration of personal data

storage

We intend to keep your personal

data accurate and up to date. We also strive to retain your personal data no

longer than necessary to fulfill the purposes listed in this Notice or as

required by law.

In this regard, we inform you

that TRAVELHUBX keeps your personal data for the entire duration of your

contract with TRAVELHUBX, as well as a period provided by applicable law after

the date of termination of the relationship between you and TRAVELHUBX.

In addition, please note that

certain personal data may also be included in certain accounting documents of TRAVELHUBX,

therefore an extended retention period must be observed in accordance with

applicable law.

If you are a candidate for a

position offered by TRAVELHUBX (without formalizing any relationship with TRAVELHUBX),

your personal data made available to TRAVELHUBX will be kept for a period of 1

year.

As for personal data obtained by

means of video surveillance, they will be maintained for a maximum of 30

calendar days from the date of registration, unless there are good reasons to

store them for a longer period.

In certain circumstances, we may

anonymize your personal data (so that it can no longer be associated with you)

for research or statistical purposes, in which case we may use this information

indefinitely without prior notice to you.

12. Processing of personal

data for advertising, marketing, and publicity purposes

Image capture (photography,

video) or image use (photo, video) are allowed only with your prior consent,

and in the case of minors only with the prior consent of their parents. It

should be mentioned that the right to image is not absolute, and photographing

and using a person’s image is allowed even in the absence of prior consent when

they are done in good faith in exercising other fundamental rights such as, for

example, the right to freedom of expression or our legitimate interest in

ensuring the security and security of persons and property.

In case of consent, TRAVELHUBX

will restrict the use of the image only on its website(s) and only on its main

social media, such as Facebook, Twitter, Instagram, WhatsApp, or on websites

associated with TRAVELHUBX, or when displayed for advertising, marketing and

advertising purposes at premises, events or presentations.

There are situations or trips

where such collections of images or videos are possible, to be announced in

advance and if the collection and processing is not desired, the event

organizer or the Personal Data Protection Officer can be notified.

If you no longer want us to

process your personal data for advertising, marketing or advertising purposes,

you can unsubscribe from receiving the newsletter by clicking on the link at

the end of the newsletter or you can request this from the Data Protection

Officer or leave the WhatsApp group to which you belonged.

13. Your rights regarding

personal data collection

Following the applicable

provisions regarding personal data, we inform you that you have the following

rights, which can be exercised by addressing a request to this effect using the

contact details indicated in Section 2 above:

The right of access to processed personal data,

meaning your right to obtain from TRAVELHUBX a confirmation of whether or

not personal data concerning you are processed and, if so, access to such

data and the conditions under which they are processed (including the

purpose of the processing, the categories of data processed, the

recipients of the data).

The right to request the rectification or deletion

of personal data, meaning your right to request the rectification of

inaccurate personal data or the completion of incomplete data.

The right to the erasure of your personal data may

be exercised in certain circumstances provided by applicable law,

including the situation in which the personal data are no longer necessary

for the purposes of the processing, the situation in which the data

subject opposes the processing and no other legitimate interests are

prevailing for the processing, the situation where personal data have

been processed unlawfully.

The right to request the restriction of processing,

meaning your right to obtain from TRAVELHUBX restriction of processing in

the following cases: (i) you dispute the accuracy of the data (the

restriction will last as long as TRAVELHUBX must verify the accuracy of

the personal data); (ii) the processing is unlawful and you oppose the

erasure of the data by requesting instead the restriction of their use;

(iii) TRAVELHUBX no longer needs the personal data for the purposes

mentioned above, but you request the personal data to establish, exercise

or defend a right in court; or (iv) you have objected to the processing,

for the time during which TRAVELHUBX verifies whether TRAVELHUBX’s

legitimate rights prevail over your rights.

The right to object to processing, meaning your

right to object to processing on grounds relating to your particular

situation, when the processing (i) is based on the legitimate interests of

TRAVELHUBX or a third party, or (ii) to the extent applicable, is carried

out for direct marketing communications, involving profiling.

The right not to be subject to an automatic

decision, including profiling.

The right to data portability, meaning your right

to request the move, copying, or transfer of your existing data in TRAVELHUBX’s

database to another database, in a structured, commonly used, and

machine-readable format, if the processing is based on a contract and is

carried out by automated means.

The right to file a complaint with the National

Supervisory Authority for Personal Data Processing and to address the

competent courts.

14. Changes to the Notice

If we drastically change our

personal data practices or this Notice, we will issue a revised Notice and/or

take other steps to notify you of the changes, in accordance with applicable

law.