WEBSITE PRIVACY NOTICE AND TERMS OF USE
This document applies to www.sunterrahotels.com ("Website"), operated by Sunterra Hotel Management & Touristic Investments, a company established in the Arab Republic of Egypt ("Company", "we", "us"). Sunterra is the name used to present the hotel management activities described on the Website. The Company's registered address is Building No: 3, First Floor Unit A, El Kawthar District, Hurghada, Red Sea / EGYPT.
Part A explains how personal data is handled in connection with the Website. Part B describes the conditions for using the Website and its content. Part A is a privacy notice, not a request for consent. Reading this document or using the Website does not by itself constitute consent to personal data processing.
PART A WEBSITE PRIVACY NOTICE
1. Scope and Contact Details
The Website presents the Company, its hotel management services and associated brands. It does not offer online purchases, hotel reservations, registration, newsletter subscriptions or a contact form.
If you contact us separately using Contact and Get in Touch display contact details, the information you send is processed as explained below. This notice does not replace any separate notice required for hotel guests, employees or other distinct activities.
2. Personal Data and Sources
Cookie and similar technology information: The categories actually used, their data, providers, purposes, lawful bases, durations and transfers are set out in our Cookie Policy at [Cookie Policy link]. The presence of a cookie category in a general explanation does not mean that we use it.
Separate correspondence: if you email, telephone or write to us, we may receive your name, business role, organisation, contact details, message content and related correspondence. We obtain these from you, your representative or the organisation on whose behalf you contact us. Please avoid sending sensitive data or unnecessary information about other people.
3. Purposes and Lawful Bases
Technical operation and security: We use necessary technical information to deliver Website pages, maintain availability, investigate errors, prevent misuse and protect systems. We rely on our legitimate interest in operating and securing the Website, where the processing is necessary and does not override your fundamental rights and freedoms. We limit the information and retention to what is needed for these purposes.
Correspondence and business enquiries: We use information to answer your enquiry and manage the related communication, relying on our legitimate interest in responding to business contacts, subject to your fundamental rights and freedoms. Where processing is necessary to perform a contractual obligation involving you as an individual, we rely on that contractual basis.
Legal and regulatory matters: Where necessary, we use information to comply with applicable legal obligations and competent authority or court orders, and to establish, exercise or defend legal rights in connection with Website misuse, enquiries or other disputes. We rely on the corresponding lawful basis under Egyptian law and limit processing to the relevant obligation or claim.
We do not use the Website for automated processing that produce legal or similarly significant effects. We do not use your enquiry details for unrelated marketing without satisfying the applicable legal requirements.
4. Recipients and Service Providers
Authorised Company personnel access information only where needed for the purposes described above. External recipients may include maintenance, communications providers and professional advisers, to the extent actually engaged for the relevant activity. Any sharing with a group company must have a specific purpose and lawful basis.
We may disclose relevant information to courts, regulators or other competent authorities where lawfully required. Where a provider processes personal data on our behalf, we require appropriate processing instructions, confidentiality, security and deletion or return arrangements. A provider acting for its own purposes must be assessed separately.
5. Retention and Security
We delete or irreversibly anonymise information when it is no longer lawfully required.
We apply technical and organisational measures appropriate to the nature of the information and the risks, including measures governing access, confidentiality and service providers. No website or communication channel can be guaranteed completely secure. This does not limit our obligations under applicable law.
6. Your Rights and How to Exercise Them
Subject to the applicable legal conditions, you may request information about your personal data, access to or a copy of it, correction, completion or updating, deletion, withdrawal of consent, limitation of processing to a specified purpose, and objection to processing or its results where they conflict with your fundamental rights and freedoms. You also have the right to be informed of personal data breaches in the applicable circumstances.
You may exercise your rights through Data Subject Application Form accessible from [DATA SUBJECT APPLICATION FORM LINK] We may request information reasonably necessary to verify your identity or authority. Please do not send sensitive information unless necessary and specifically requested.
We will reply within the time frames provided under applicable law and explain any lawful limitation or refusal. Withdrawal does not affect the lawfulness of earlier processing, and a separate lawful basis may permit necessary processing to continue.
7. Children and Changes to This Notice
The Website is directed to business audiences. If you believe that an irrelevant data subject has provided personal information to us, please contact with us so that we can assess and address the matter under the applicable rules.
We publish updates with a revised effective date and provide further notice where required. Where a proposed change requires fresh consent or another legal step, we complete that step before undertaking the new processing.
PART B TERMS OF USE
1. Purpose of the Website
The Website provides general information about Sunterra, the Company's hotel management activities and the brands and properties described. No sale, booking, payment or other transaction is concluded through the Website.
Content is not a binding offer, investment solicitation, professional advice or commitment to provide management services. Any business engagement requires a separate agreement with the relevant legal entity.
These Terms do not vary existing hotel management, brand licence or other signed agreements, which govern the relationships they cover.
2. Brands and References to Properties
References to brands, hotels and group companies describe the relationships presented. They do not by themselves establish ownership, operation of every listed property, a guarantee of another entity's obligations or authority to bind another company. The relevant agreement identifies the contracting entity and services.
3. Intellectual Property and Permitted Use
Website text, photographs, logos, trademarks and other materials belong to the Company or their respective owners, or are used with permission. You may view and make reasonable copies for internal assessment of a potential business relationship, retaining ownership notices. Website access grants no trademark, image, franchise or management licence.
Unless authorised by the rights holder or permitted by law, you must not republish, commercially exploit, materially alter or use Website materials in a misleading manner. Requests to use a name, logo, image or other protected material should be directed to the Company.
4. Acceptable Use and External Links
You must not interfere with Website security or availability, seek unauthorised access, introduce malicious code, impersonate the Company, or use the Website for unlawful activity. We may take proportionate protective measures, including restricting access where necessary to address misuse or a security threat.
Links to external websites are provided for convenience. Those websites are operated under their own terms and privacy arrangements. A link does not by itself constitute an endorsement or guarantee. We remain responsible for any data processing that we undertake in connection with an embedded service or link under applicable law.
5. Accuracy Availability and Liability
We take reasonable care in presenting information, but descriptions, projects and relationships may change. Confirm material information directly with the Company before relying on it for a business decision. We may update content or temporarily suspend access for maintenance or security.
To the extent permitted by law, we do not guarantee uninterrupted or error-free access or accept liability for reliance solely on general Website content.
6. Updates and Amendments
We may update or amend these Terms prospectively by publishing on the Website.