1. INTRODUCTION

Azmont Investments is a Montenegro based company committed to apply its most adequate resources to achieve its mission: to create an efficient and sustainable investment portfolio focusing on accountability, environmental sustainability and corporate social responsibility, while developing and managing «Portonovi resort».

The purpose of this privacy policy is to explain how we use your personal data, our personal data practices and of course choices and possibilities you have and that you can make about the way your personal data is used.

Azmont Investments respects your privacy and we are committed to the protection of the privacy and confidentiality of the personal data that you provide to us or that we collect about you when you use our websites, social media pages we control, software applications available on computers and mobile devices that include a link to this Privacy Policy as well as when you provide your information on the telephone via our call centers or in person (collectively the Sites).

Our privacy policy may vary among different countries that we operate in – in order to reflect our dedication to be a responsible company and to legally comply with requirements of different countries.

You may be asked to consent to the terms of this Privacy Policy when you are interacting with us, for example through our Website or when calling us, or data is collected about you through your use of our Website and allowing you to be identified personally, either directly (e.g. your name) or indirectly, because the data references an identifier such as your name, an identification number, location data, an online identifier (e.g. telephone number) as an individual person. Otherwise your continued use of the Sites will constitute your deemed consent to the terms of this Privacy Policy.

2. WHAT ARE PERSONAL INFORMATION AND WHICH PERSONAL INFORMATION WE COLLECT

Personal data (personal information) are all data relating to a physical person whose identity is determined or can be determined, directly or indirectly, on the basis of such data, alone or in combination with other information, including but not limited to: first and last name, address of residence, phone 1 number, e-mail address, bank / credit card number, location data, network identifier.

PERSONAL INFORMATION YOU PROVIDE

When using our Sites, you may voluntarily provide and we may collect certain information (“Personal Information”) about yourself or others. Such information includes (but is not limited to):

Contact Data. We collect your first and last name, e-mail address, postal address, phone number, company name, job title, and other similar contact data,

Credentials. We collect passwords, password hints, and other information for authentication and account access,

Demographic Data. We collect demographic information including your country and size of your company

Contacts. We collect data you provide about your contacts, including information about other employees at your company. By supplying data about your contacts, you acknowledge and agree that you have your contacts’ consent for us to use their contact information in accordance with this Privacy Policy,

Content. We collect the content of communications you send to us, such as feedback, questions, or information you provide to us.

AUTOMATICLLY COLLECTED INFORMATION

We and our third-party service providers use a variety of technologies, now and hereafter devised, that automatically collect information about your device and how your device interacts with the Sites. This information does not constitute Personal Information. If we combine anonymized or aggregated data with Personal Information, we will treat the combined information as Personal Information.

3. HOW DO WE COLLECT YOUR PERSONAL INFORMATION, PURPOSE OF COLLECTION AND THE USE OF THE PERSONAL DATA

We may use your Personal information and automatically collected information, for our business use and for the purposes envisaged under this Policy, including but not limited to:

- to establish and maintain a responsible commercial relationship with you and to provide ongoing service.
- to understand your needs and preferences. We maintain a record of the products and services you receive from us and we may ask for additional information so that we can serve you better. (For example, we may record your preference for a type of room.)
- to develop, enhance, market or provide products and services. (For example, we look at our guests' use of our services so that we can better understand how to improve our services.)
- to manage and develop our business and operations.
- to meet legal and regulatory requirements.

Please note that as an international touristic resort, we may need to share information to other countries/third parties in order to provide you with service in line with our standards and practices – so your Personal Information may be shared for mentioned purposes and in the manner set out in this Privacy policy, as follows:

3. HOW DO WE COLLECT YOUR PERSONAL INFORMATION, PURPOSE OF COLLECTION AND THE USE OF THE PERSONAL DATA

We may use your Personal information and automatically collected information, for our business use and for the purposes envisaged under this Policy, including but not limited to:

- to any entity managed by Azmont,  to third parties which we have received your consent;
- to trusted third partners to process it for us, based on our instructions and in compliance with our Privacy Policy and any other appropriate confidentiality and security measures including;
- to third parties not affiliated with us if we have a good-faith belief that it is reasonably necessary to: (1) meet any applicable law, regulation, legal process or enforceable governmental request; (2) enforce applicable terms of service, including investigation of potential violations; (3) detect, prevent, or otherwise address illegality, fraud, security or technical issues; and (4) protect against harm to the rights, property or safety of Azmont, our users or the public as required or permitted by law,
- to our marketing and advertising partners, to provide you with more relevant ads on our Sites and to encourage you to return to our Sites and to Mail Chimp, who securely hosts emails and acts as a supplier to distribute our email communications. We contractually require these service providers to keep your Personal Information safe and secure and they are only permitted to use your Personal Information for the purposes we specify. Whenever we collect or process your Personal Information, we will only keep it for as long as is necessary for the purpose for which it was collected, active legal proceedings, an identifiable and ongoing legal business need (such as record keeping) and to the extent permissible by applicable law.

4. CHILDREN'S PRIVACY

We do not knowingly collect Personal Information from children under the age of 18, though we may collect Personal Information about a child as part of the guest registration process or to participate in activities on the Sites or at the resorts but always with the consent of a parent or guardian.

5. LEGAL BASES FOR PROCESSING PERSONAL INFORMATION

- CONSENT– this envisages your approval for processing personal data (by ticking boxes),
- LEGAL REQUIREMENTS– as and if required by applicable law.
- LEGITIMATE INTEREST– to pursue our legitimate interest for the purposes of providing our services and conducting our businesses in a manner which doesn’t impact your rights.

You don’t have to provide us with your Personal information. In this case, if this is your choice please note that you will still be able to visit the Sites, but we cannot guarantee that you will be able to access certain options, products or services, so we may not be able to deliver i.e. your booking or any other service and/or product where use of your personal information may be directly connected to fulfillment of related services.

6. YOUR RIGHTS FOR PROTECTION OF PERSONAL INFORMATION

Regarding your data we process, you are entitled to:
- Request confirmation that your data is processed,
- Request information on how your personal data is processed, what is the term of such processing and measures implemented for the purpose of safeguarding thereof, - Request correction of personal data,
- Withdraw consent and request deletion of your personal data. At any time you can implement any of your legally given rights by contacting us by e-mail:data.privacy@portonovi.com.

Please be sure to include your full name, address and telephone number and a copy of a document evidencing your identity (such as an ID card or passport) so we can ascertain your identity and whether we have any Personal Information regarding you, or in case we need to contact you to obtain any additional information, we may require to make that determination.

We may permit third parties to link to our Sites or to post a link to their site on ours. We do not endorse these sites and are not responsible for other sites or their privacy practices. We do not assume responsibility or liability of any nature whatsoever for the activities conducted or information contained in the third-party websites.

Yacht Club Privacy Policy

1. INTRODUCTION