Privacy Notice and Terms of Use for WiFi Connection Users

1. PRIVACY NOTICE

Data Controller:

Company name: art'otel berlin city center west GmbH
Address of the registered seat: Märkisches Ufer 10, 10179 Berlin, Germany
VAT ID: DE217181410
Registration number: HRB94819B
(hereinafter: the “Data Controller”, “Company”)

Data protection contact:

If you have any questions related to the processing and protection of personal data or want to exercise the rights guaranteed by the General Data Protection Regulation (“GDPR”), you can contact us via privacy@arenahospitalitygroup.com

Purpose of data processing:

Data related to the access to the WiFi network may be temporarily processed for the purpose of:

• Providing access to Internet via WiFi connection
• Maintaining network security
• Detecting and preventing network misuse
• Ensuring technical functionality of the network

Types of data being processed

When using the WiFi network, we may log the following data: device MAC address, assigned local IP address, timestamps of access (connection and disconnection timeframe), amount of data transmitted (download, upload), URL reached by device.

Legal basis for processing

Data processing is based on the Data Controller’s legitimate interest for the purpose of protecting the network system and preventing misuse.

In certain circumstances processing is necessary for compliance with a legal obligation to which Data Controller is subject (e.g. taking reasonable measures to prevent illegal activities, cooperating with competent authorities and provide them relevant information in case of illegal activities).

Processing is necessary for the performance of a contract – providing additional content (WiFi connection) as part of the hospitality service.

Recipients

art'otel berlin city center west GmbH is the provider of the Wi‑Fi network service to the users and is responsible for the local processing, communication with guests and the technical implementation of the processing.

Park Plaza Germany Holdings GmbH Märkisches Ufer 10, 10179 Berlin, Germany, VAT ID: DE813598998, Registration number: HRB95934B, performs management, support, administrative and supervisory functions within the Arena Group companies based in Germany.

Depending on the distribution of responsibilities within the group to which the Data Controller belongs, data may be shared with the parent company and affiliated companies in certain circumstances. In that case, the listed companies may act as joint controllers for the purposes of day‑to‑day operations, service provision, and the coordination of business processes. In case that Data Controller engages service providers for data processing, Data Controller shall conclude appropriate contract with these service providers pursuant to GDPR to ensure suitable level of privacy and data security.

Company is part of a group led by Arena Hospitality Group d.d. (“AHG”) which is joint stock company established in Pula, Smareglina ulica 3, Republic of Croatia, VAT ID: 47625429199. AHG is an international hospitality company which owns, co-owns, leases, operates and develops full-service upscale, upper upscale and lifestyle hotels, self-catering holiday apartment complexes and campsites primarily in Croatia, Germany, Austria, Hungary and Serbia (‘Arena Group’). In addition to operating and developing its own brands, Arena Hotels & Apartments® and Arena Campsites®, through its majority shareholder PPHE Hotel Group Limited (‘PPHE Hotel Group’ or ‘PPHE’) AHG has the exclusive right to operate and develop the international Park Plaza® brand in 18 countries in the Central and Eastern European region (the ‘CEE region’) and to manage certain art’otel® branded properties, enabling us to further grow our presence. As part of the expanded cooperation with the Radisson Hotel Group, PPHE has secured access to the entire range of Radisson Hotel Group brands, including the Radisson Collection and Radisson RED, and has the right to sublicense them to AHG.

AHG implements group IT and security standards and standards for the processing of personal data within the Arena Group. Data Controller has entrusted certain personal data processing activities with AHG and guarantees appropriate personal data protection measures in accordance with the GDPR and other applicable data protection regulations.

For more information on how AHG and PPHE process personal data, please see AHG Privacy Notice https://www.arenacollection.com/en/legal/privacy-notice and PPHE Privacy Policy https://www.pphe.com/site-services/privacy-policy

User (data subject) rights

Users have right to: (a) access to their personal data, (b) request rectification of inaccurate personal data, (c) request erasure of the personal data, (d) restrict processing, (e) object to data processing, (f) lodge a complaint with a supervisory authority.

The exercise of certain rights may be limited if the processing of personal data is necessary, for example, to comply with the Data Controller's legal obligations, to establish, exercise or defend legal claims, and in other cases in accordance with applicable regulations.

To exercise these rights, please contact us via privacy@arenahospitalitygroup.com.

Storage period

Collected data will be stored as long as necessary for the respective purpose as defined by this Privacy Notice and Terms of Use for WiFi Connection Users. Storage period may be extended if there is a legal or security-related reason for longer storage period (e.g. investigation of security incident, investigation carried out by the competent authority in case of illegal activities, legal disputes).

2. TERMS OF USE

By using or free WiFi network, the user agrees to the following terms of use:

Purpose of use

The WiFi network is intended solely for lawful use within the normal usage limits. Any use that may cause harm to the network, other users, or third parties is strictly prohibited.

Prohibited activities

Users are not allowed to:

• Access, transmit, download, or share illegal, threatening, obscene, profane content (e.g. hate speech, abusive, violent, pirated content, gambling, spreading malware)
• Violate intellectual property rights or other third-party rights (e.g. images, audio and video files)
• Engage in hacking, phishing, port scanning, or similar activities
• Attempt to access protected areas of the network or other user’s devices
• Access WiFi network services in such a way as to deny reasonable access to the network for other users (e.g. by excessive use of network bandwidth - use of FTP servers, file-sharing software and video streaming etc.)

Privacy and security

We recommend users to use additional protection (e.g. VPN) when accessing sensitive services. Company is not responsible for potential security vulnerabilities on user devices.

Monitoring and logging

In accordance with applicable laws (e.g. GDPR, German Telecommunications Digital Services Data Protection Act (TDDDG)), certain usage data (e.g. IP address, MAC address, time of access) may be temporarily stored to prevent misuse and ensure system security.

Limitations and availability

Company reserves right to: a) restrict or block access to specific websites or services; b) suspend access to the network for maintenance, security, or suspected misuse.

User responsibility

Users are responsible for their own use of the network. In case of violation of these Terms of Use, access may be terminated and in the case of serious infringements, further legal actions may be taken.

Indemnity

The user agrees to indemnify, defend and hold harmless Company, its parent company and affiliates (if applicable), their employees, partners and service providers from and against any and all claims, liabilities, damages, losses, costs or expenses (including reasonable legal fees) arising out or in connection with: (a) user’s unlawful or improper use of the WiFi network; (b) any violation of these Terms of Use; (c) any infringement of third-party rights, including but not limited to intellectual property rights; (d) any damage to the network, systems or services resulting from the user’s actions or the use of the user’s device.

Company is not responsible for loss of any data due to service interruptions, technical reasons or negligence on part of the user or for any commercial transactions undertaken by a user while using the WiFi connection.

Under no circumstances shall the PPHG, its parent company and affiliates (if applicable), their employees, partners and service providers, be liable for any direct, indirect, incidental, special, punitive or consequential damages that result in any way from the user's use of or inability to use the WiFi connection.

Service provided “as is” and “as available”

The WiFi service is provided on an “as is” and “as available” basis, without any warranties or guarantees of any kind, either express or implied. Company makes no representations or warranties regarding the availability, reliability, security or performance of the WiFi network.

The user assumes all risks associated with the use of the WiFi network.

Changes to Terms of Use

Company reserves the right to change these Terms of Use at any time. Users are encouraged to review them regularly when using the WiFi connection.

Last updated: 07 April 2026