Notice of Privacy

This privacy notice governs the processing of personal data by AVIFIN Inc. that operates the hotel ORCHID HOUSE VILLAS TULUM, in the terms provided for by the Federal Law for the Protection of Personal Data in Possession of Individuals (FLPPDPI) and by the regulations and/or administrative provisions derived or related to the Law.

A. Identity of the responsable

AVIFIN Inc. and its affiliated and/or subsidiaries (hereinafter, ORCHID HOUSE), with address at Aldea Zama 77760, Tulum, Q.R, is a company committed to protecting your privacy. Our Data Protection Manager is the Personal Data Department and is located in the same address, you can contact in the email: [email protected]

This Privacy Notice also corresponds to the following websites belonging to ORCHID HOUSE:

www.orchidhousehotels.com

B. Personal Data

For the purposes indicated in this Privacy Notice, ORCHID HOUSE may collect your personal data in various ways: when the information is provided directly by you; when you visit the ORCHID HOUSE websites; when you use the services offered by ORCHID HOUSE online, for the data that you authorize ORCHID HOUSE to take from your social networks (Facebook, twitter, LinkedIn, google, etc.) or by connecting to the Wi-Fi that ORCHID HOUSE might offer you; and when we obtain information through other means than those indicated above and that are permitted by applicable laws.

The personal data obtained by the aforementioned means are:

C. Sensitive Personal Data

Sensitive personal data is considered personal data that affects the most intimate sphere of its owner, or in case of misuse may give rise to discrimination or entail a serious risk to it. In particular, those who can reveal aspects such as racial or ethnic origin, current and future health status, genetic information, religious, philosophical and moral beliefs, union affiliation, political opinions, sexual preferences are considered sensitive. In case of staying at any of our hotels, the sensitive personal information that we will request will be those related to health or different capacities, which will be used only to provide a better service and meet your specific needs.

D. Purpose and Treatment of Personal Information

The personal information you provide will be used by ORCHID HOUSE to provide the services you request. Additionally it can also use the information to offer promotions, newsletters, surveys, etc.

The main purposes of the treatment of personal data is:

1. Integrate and maintain a database of clients;

2. Confirm the identity of the client and/or his legal representative;

3. Comply with the legal requirements applicable;

4. Provide information on: conditions, policies and provisions for the contracting and use of services and facilities; payment methods; rates for services and modalities;

5. Send promotional material of ORCHID HOUSE

6. Manage the entry and exit of guests;

7. Monitoring and control of physical and logical access to hotel facilities;

8. Manage the services of courtesy food, room service, cleaning and maintenance of the rooms and telephone attention, among others.

9. Manage security;

10. Develop internal statistics that indicate the services and products most appreciated by customers;

11. Manage charges and collection via bank cards, credits and cash;

12. Send invoices;

13. Use the different services of the ORCHID HOUSE website;

14. Any other activity of a nature analogous to those described in the aforementioned paragraphs.

E. Limitation on the Use or Disclosure of Personal Information

At any time you can express your refusal to the treatment of the finalities that do not give rise to the legal relationship or are necessary for the provision of the service, which may be requested to the email [email protected], indicating the electronic email(s) and/or telephone number(s) to which send notifications; likewise you may revoke consent in the terms indicated in paragraph F.

F. Of the Exercise of the Rights of Access, Rectification, Cancellation and Objection.

Access, rectification, cancellation or opposition on respect to the information you provide to ORCHID HOUSE indicated in the Federal Law on Protection of Personal Data Held by Private Parties, or the revocation of the consent that you have given us to the processing of your personal data , may be done so by submitting the request in writing to the Department of Personal Data to the following address: Aldea Zama 77760, Tulum, Q.R, on a schedule of 9:00 hours to 14:00 hours from Monday to Friday or via email [email protected].

Said request must contain at least the following: (i) Name of the Owner of the Personal Data; (ii) Email to receive notifications; (iii) Documents proving your identity or, where appropriate, the legal representation of the owner; (iv) Clear and precise description of the personal data with respect to which the right is sought to be exercised and the right to be exercised. (v) Any other element or document that facilitates the location of personal data. In case the application does not satisfy any of the requirements indicated above, the Personal Data Department may request within 5 days of receipt to present the elements or documents necessary to process it. You will have 10 days to respond to the request, in case you do not answer within that period, the corresponding request will be deemed not submitted.

The period of attention will be a maximum of 20 days from the date on which the request is received to communicate the adopted decision, so that, if it is appropriate, make it effective within 15 days after the issuance of the response. In order to protect your confidentiality, ORCHID HOUSE will send the response to your request to the email address you have provided for this purpose and keep it available to the applicant at the address indicated in the previous paragraph.

G. Measures to protect personal data

The personal data processed by ORCHID HOUSE is protected by adequate administrative, technical and physical security measures against damage, loss, alteration, destruction or unauthorized use, access or processing, in accordance with the provisions of the FLPPDPI and the administrative regulation action that derives from it. All personal data stored in electronic format, is maintained in confidential and secure data banks. However, no security or data transmission system of which the company does not have absolute control and/or is dependent on the Internet can guarantee that it is completely secure.

H. Electronic means and cookies

In the event that you use electronic means in relation to your personal data, cookies will be generated in order to provide a better service.

Cookies are small pieces of information that are sent by the website to your browser. Cookies are stored on your computer’s hard drive and used to determine your preferences when you connect to the services of our sites, as well as to track certain behaviors or activities carried out by you within our sites.

In some sections of our site we require that the client has cookies enabled since some of the functionalities require them to work. Cookies allow us to: a) recognize it when entering our sites and offer a personalized experience, b) know the personal settings of the site specified by you, for example, cookies allow us to detect the bandwidth you have selected at the moment of entering the homepage of our sites, so that we know what kind of information it is advisable to download, c) calculate the size of our audience and measure some traffic parameters, since each browser that accesses our sites acquires a cookie that is used to determine the frequency of use and the sections of the visited sites, reflecting their habits and preferences , information that is useful to us to improve the content, the headlines and the promotions for the users. Cookies also help us track some activities, for example, in some of the surveys we launch online, we can use cookies to detect if the user has already filled out the survey and avoid deploying it again, if it has been done. The “help” button found in the toolbar of most browsers will tell you how to avoid accepting new cookies, how to make the browser notify you when you receive a new cookie or how to disable all cookies. However, cookies allow you to take advantage of the most beneficial features that we offer, so we recommend that you leave them activated.

I. Transfers

ORCHID HOUSE only transfers personal data in the cases established in article 37 of the Federal Law on Protection of Personal Data Held by Private Parties.

J. Changes to this Privacy Notice

ORCHID HOUSE may at any time update this privacy notice. In the event of substantial changes to this notice, we will communicate it through our internet pages indicated in subsection A of this Privacy Notice. Therefore, we suggest you periodically visit this privacy notice to be aware of any updates.

I acknowledge and accept the terms and conditions established in this Privacy Notice, and otherwise I will inform Posadas in terms of what is indicated in paragraphs E. and F. of this Privacy Notice.

In case of any disagreement or complaint about the processing of your personal data, you can go to the National Institute of Transparency, Access to Information and Protection of Personal Data.

K. Manifestation of Consent

I, HOLDER OF THE PERSONAL DATA, expressly agree to accept without reservation or limitation the content of this Privacy Notice through the handwritten signature of this document. Likewise, the act of completing the printed, electronic formats, supposes my full and express acceptance of this Privacy Notice and of any modification and/or update thereof and I accept that ORCHID HOUSE, its affiliates, subsidiaries and suppliers, that you find in Mexico and abroad, process my personal data in the terms and conditions of this Privacy Notice.

Name and signature of the owner of the data owner

Updates to the privacy notice. Last revision: Noviembre 2018