Sechi Group Hotels as following Companies:

Marcos Fin Let.LLC, reg. No. 40003647259 (hereinafter - the Company), legal address: Pils street 18-1, LV-1050, Riga, Latvia, T.: +371 722133, e-mail address: info@sechigroup.lv

Rezidence Autosole Marbella SL, reg. No. B29898889 (hereinafter – the Company), legal address: Calle Juan Ramon Jimenez 9, floor 4, office 1, 29601 Marbella, Malaga, Spain, T.: XXX, email address:

info@sechigroup.es

Motel Autosole2 – S.R.L., reg. No. 12612690151 (hereinafter – the Company), legal address:

Via Roberto Sarfatti 5, CAP 20136 Milano, Italia. T.: XXX, email address: info@sechigroup.it

If you have any questions regarding the processing of your personal data, please contact us using the communication channels indicated above.

When processing personal data, the company complies with the requirements of the General Data Protection Regulation No. 2016/679 (hereinafter - the Regulation), as well as other requirements of the regulatory acts in force in Latvia, and also protects personal data using technical and organizational means that meet modern requirements.

This privacy policy explains how the Company processes the data of natural persons (customers, cooperation partners, representatives/contact persons of cooperation partners, job candidates, employees and other persons whose data may come within the scope of the Company's data commercial activities), the procedure for exercising the subject's rights and personal data defense related issues. The Company's privacy policy applies to all types of personal data processing by the Company.

We are aware that personal data is your value and will process it in compliance with confidentiality requirements as well as taking care of the security of your personal data we have.

PURPOSES OF PERSONAL DATA PROCESSING AND LEGAL BASIS OF PERSONAL DATA PROCESSING

The Company's personal data processing purposes are related to the Company's functions. The company processes personal data for the following purposes:

• for the provision of services – so that you can reserve a hotel room, so that you can change or cancel your order, so that you can receive a reservation confirmation to your e-mail address, so that the company can verify your age (reservations cannot be made by persons under the age of 18) ;
• for ensuring/maintaining the operation of services;
• for settlement administration;
• for the preparation, conclusion and administration of the contract - within the scope of this purpose, we would need to identify you, provide an appropriate payment calculation and ensure the payment process, contact you in matters related to the provision of the service and/or the performance of the contract - also for sending invoices;
• for personnel selection and management;
• to ensure an effective company management process;
• for customer service;
• for sending information to customers;
• for business planning and analytics;
• for the provision of information to state administrative institutions and subjects of operational activity in the cases and to the extent specified in external regulatory acts;
• for the protection of the property of the company and third parties, for the safety of employees and third parties, to prevent, control and detect illegal activities and in case of such activities to carry out an effective investigation, record the fact of committing a criminal offense (video surveillance).

THE COMPANY PROCESSES PERSONAL DATA ONLY IN SUCH CASES WHEN IT HAS A LEGAL BASIS:

• FULFILLMENT OF LEGAL OBLIGATIONS DETERMINED BY REGULATORY ACT.

The company processes personal data in order to fulfill the obligations set out in the regulatory acts, for example, the requirements of the accounting regulatory acts, the requirements of the Archives Law, etc. The main legal basis for the fulfillment of this purpose is a legal obligation.

• PROVISION OF LEGITIMATE INTEREST.

The Company processes personal data in order to carry out commercial activities, the protection of the property of the Company and its customers, as video surveillance may be carried out at the Company's legal address, at the place of performance of economic activity, to apply to state administrative and operational institutions and to the courts to protect their legal interests in order to realize from the Company and the customer between the existing obligations or the legitimate (legal) interests of the Company resulting from the concluded contract or law.

• CONTRACT OR PERFORMANCE

The company processes personal data in order to conclude contracts, monitor their implementation, a contractual agreement is concluded, as well as to fulfill the requirements set by the applicable legal acts.

• DATA SUBJECT CONSENT

For example, by applying for vacancies advertised by the Company, you agree to the processing of the data of the persons indicated in your CV, application letter or questionnaire (name, surname, contact information, education, experience and skills meet the requirements of the position, etc.). The company processes personal data to evaluate the application and determine whether you are suitable for a vacant position.

DURATION OF PERSONAL DATA STORAGE

The company stores personal data in accordance with the defined purposes (objectives) of personal data processing and the requirements of regulatory acts, as long as at least one of the following criteria exists:

• as long as the Company can realize its legitimate interests (for example, submit objections or file a claim in court) in accordance with the procedures specified in external regulatory acts;
• while the Company has a legal obligation to store data;
• as long as the data subject's consent to the processing of personal data is valid, and there is no other legal basis for data processing.

Below we indicate the most common retention periods for personal data:

• personal data necessary for the fulfillment of contractual obligations - the Company keeps with it will be fulfilled and other storage terms will be fulfilled (see below);
• personal data that must be stored in order to fulfill the requirements of regulatory acts, we store the relevant regulatory acts within the time limits set by the law, for example, the Law "On Accounting" stipulates that justification documents must be kept until the day they are needed to start each economic transaction and track it . for development, but not less than 5 years;
• In order to prove the fulfillment of our obligations, we will store the data in accordance with the general requirements for the limitation period, the limitation periods for claims determined by regulatory enactments - 10 years in the Civil Law 3 years in the Commercial Law and other periods, taking into account also the period for bringing claims set by the Civil Procedure Law;
• The Company stores the data obtained from video surveillance for 3 months in order to detect possible criminal offenses.

If your personal data is no longer needed for the specified purposes, the Company will delete or destroy them.

RECIPIENTS OF PERSONAL DATA

The company takes appropriate measures to ensure that the data of the affected person is in accordance with the applicable legislation and that the employees do not request third parties who do not have a relevant legal basis for processing the data of a specific person.

Personal data, if necessary, could:

• Employees of the company or directly authorized persons who are necessary for the performance of work duties;
• In order to fulfill the obligations set forth in the regulatory acts, the Company may transfer data in the cases specified in the state and local government legislation, for example to law enforcement authorities, municipalities, tax administration court, sworn bailiff);
• For the provision of certain services, the Company's personal data can be transferred to cooperation partners - plants in accordance with the services provided and only to the necessary extent, which perform the necessary data processing on behalf of the Company, for example, auditors, the technical maintainer of the database and other persons who ensure the provision of services to the Company;
• Third parties, after carefully assessing whether there is an appropriate legal basis for a specific transfer of data, such as courts, out-of-court dispute resolution institutions, insolvency administrators.

Personal data is not transferred to a larger responsibility (outside the European Union and the European Economic Area).

PERSONAL DATA PROCESSING OF COOPERATION PARTNERS OR CHOICE OF PERSONAL DATA PROCESSORS

The company takes appropriate measures to ensure the processing, protection and transfer of personal data to databases in accordance with applicable legislation. The company wants to choose the collection of data and, when transferring, evaluate the persons who are needed and the amount of data to be transferred. The transfer of data to food is carried out in compliance with the requirements of confidentiality and safe processing of personal data.

ACCESS TO YOUR PERSONAL DATA AND OTHER DATA SUBJECT RIGHTS

In order to receive information about persons whom the Company processes as a data subject, the data subject must submit an application:

• in person or in writing, by submitting the Company's legal address and presenting an identity document;
• electronically with a secure electronic signature, by sending to the e-mail address (MAINĪTS!)

The data subject has the right to request his data (submit to the Company), request the deletion of personal data, restriction of personal data processing, portability of personal data, object to the processing of personal data, or request the correction of personal data resulting from the provisions of the Regulation.

The company communicates with the data subject using the contact information provided by the data subject (phone number, e-mail address, address). If it appears to the data subject that the data subject's right to the protection of personal data has been violated, the data subject has the right to file a complaint with the authority.

The company does not use your data in making automated decisions.

RIGHT TO WITHDRAW CONSENT

If the processing of personal data has started and takes place in accordance with the consent of the data subject, the data subject has the right to withdraw, in person or in writing, by submitting an application to the Company's legal address (by presenting a personal identification document) or by secure electronic signature by sending electronically to the e-mail address

Withdrawal of consent may not data processing carried out during the period when the data subject's consent was valid.

By withdrawing the consent, data processing carried out by the Company based on other legal grounds cannot be excluded.

TERMS & CONDITIONS:

• Terms and Conditions – these Terms and Conditions are applicable to all bookings, agreements through different channels for Accommodation and property services which may be reffered to.

All reservations made by the Customer indicates acceptance of these Terms and Conditions. These terms may be subject to change at any time and without notice.

Prior to your self check in online, please cosult the website for the most up-to-date amendments.

• Property Conditions – please be aware that we do have fully automazation features in the all Countries for all our properties.

• Booking Conditions and Process– all bookings are made and paid online.

The guests are making the booking and pay at any convenient day or timebefore Arrival date. Booking Confirmation letter will be sent to You via e-mail accordingly.

On arrival date you will receive via e-mail Pre-arrival automated Invitation e-mail with “Online Check in is now available” with PIN code to enter your room.

• Booking Process additional Requirements – via booking process you are able to select Additional Services as following:

Upgrade Your Room – are subject upon availablity. Additional charges will apply

Early Check In & Late Check Out – are subject upon availability. Additional charges will apply

Cot or Extra bed – are subject upon availability. Additional charges may apply

Parking – additional charges may apply

• Check-In & Check-Out – apartments will be made available from 3PM on the day of arrival and must be vacated by 12AM on the day of departure.

Please be so kind and check out yourself after depart and we would appreciate Your feedback by receiving e-mail afterwards.

• In-House Communication – you are able to use Chat option anytime for connecting with apartment staff remotely.

• Price policy – all Rates are offered included taxes and charges. Please read carefully chosed Rate terms and conditions prior booking.

• Payments – guests will be asked for full payment during online self check in process. We accept major Credit or Debit cards. Card transactions will be charged at the local currency rate and we does not accept responsibility for additional costs that may be incurred.

• Cancellation policy – Cancellations has been made only via e-mail by selecting the appropriate Country by Contact Us.

Semi flexible – free cancellation 3 days prior to arrival date till 3PM

Non-refundable - will not be entitled to a refund if need to be cancelled.

Confirmation of the cancellation will be sent to You via e-mail. Please note that the funds will be refunded as per the issuing bank’s policy.

• No-Show policy – If the guest does not cancell within the Cancellation policy time, the fully amount has been charged and is non-refundable.

• Child policy – All children under the age of 18 years must be accompanied by at least one adult per apartment.

Following accommodating options are:

*Children 0-2 – free of charge

*Children 3-12 – 15.00 EUR per person/ per night

*Children up to 18 – 30.00 EUR per person/ per night

*Children 18 and above – will be accounted and charged as Adults

All Cots and extra beds are subject to availability

• Pet policy – we do accept only small Pets.Additional charge apply.

• Non-smoking policy – our property are non-smoking property in all private and public area. Smoking is strongly prohibited. If smoking occurs during Your stay, the penalty fee will be charged from You - 250.00 EUR per time without any additional warning.

• Facility policy – all apartment Prices include Apartment amenities and facilities.

The apartment cleaning service has been done after Your depart, however the full service or fresh up might be requested through our Chat option or by Contact us.

For long stay guests conveniences, full cleaning services has been provided for the stays of 7 nights and more and is included on the 4th day of your stay.

• Damages or Violations - Each customer is taking own responsibility of the Apartment all equipment and furniture. The Guest is financially responsible for any demage to the apartment rooms during their stay. Any demage in case must be reported immediately to Management by option Contact us.

In case of delay, The Customer hereby gives consent to the Management team to apply to the Customer’s credit card all reasonable charges what may occur with a written notice to the Customer via e-mail.

• Security Policy – please note that all property premises and the public areas has been video surveillance. All violations has been noticed and can be used as evidence in case of dispute.

• Apartment Management Policy – based on fully automated Properties, the Management or its authorised personnel may at any time access the apartment for the purpose of inspection of the apartment and to carry out any repair or maintenance work.

• Law – these Terms and Conditions shall be interpreted under ? - (Spanish Properties: Spanish/ Italian Properties: Italian/ Latvian Properties: Latvian - ?) law except as otherwise provided by convention or applicable law shall be subject to the jurisdiction of the XXXCourts. If any of the provisions of the Terms and Conditions are invalid under any applicable law, then the other provisions shall neverthless remain valid to the extent that the remaining provisions are capable of standing without the provision or provisions ruled invalid.