Effective

Date: January 28, 2026

This Privacy Policy explains how LUKABA Hospitality Group (“LUKABA”, “we”,

“us”, or “our”) collects, uses, stores, discloses, and protects personal

information obtained through our hotels, resorts, restaurants, event venues,

websites, mobile applications, booking systems, loyalty programs, and all

related services (collectively, the “Services”).

By using our Services, you acknowledge that you have read and understood this

Privacy Policy.

1. INFORMATION WE COLLECT

1.1 Personal Information

We may collect personal information that you voluntarily provide, including but

not limited to:

- Full name

- Email address

- Phone number

- Postal address

- Identification details where legally required

- Payment and billing information

- Reservation details and preferences

- Communications with our staff

1.2 Automatically Collected Information

When you interact with our digital platforms, we automatically collect:

- IP address

- Device and browser information

- Operating system

- Access times and pages visited

- Cookies and tracking technologies data

1.3 Information from Third Parties

We may receive information from:

- Travel agencies and booking platforms

- Payment processors

- Marketing partners

- Social media platforms

Such information is handled in accordance with this Privacy Policy.

2. PURPOSE OF DATA COLLECTION

We collect and use personal information for the following purposes:

- Processing reservations, payments, and guest services

- Managing customer accounts and loyalty programs

- Communicating service updates, confirmations, and promotions

- Improving our services, websites, and customer experience

- Ensuring safety, security, and fraud prevention

- Complying with legal and regulatory obligations

3. LEGAL BASIS FOR PROCESSING

Where applicable, we process personal data based on:

- Your consent

- Performance of a contract

- Legal obligations

- Legitimate business interests

4. DATA SHARING AND DISCLOSURE

We do not sell your personal information. We may share data with:

- Service providers and contractors under confidentiality agreements

- Affiliates and subsidiaries within LUKABA Hospitality Group

- Legal authorities when required by law

- Business partners solely to deliver requested services

5. INTERNATIONAL DATA TRANSFERS

Your information may be transferred to and processed in countries outside your

country of residence. We ensure appropriate safeguards are in place for such

transfers.

6. DATA RETENTION

We retain personal data only for as long as necessary to fulfill the purposes

outlined in this Policy, comply with legal obligations, resolve disputes, and

enforce agreements.

7. DATA SECURITY

We implement administrative, technical, and physical security measures to

protect personal data against unauthorized access, alteration, disclosure, or

destruction. Despite these efforts, no system is completely secure.

8. YOUR RIGHTS

Depending on applicable laws, you may have the right to:

- Access your personal data

- Request correction or updates

- Request deletion of your data

- Restrict or object to processing

- Withdraw consent

Requests may be submitted to privacy@lukabagroup.com.

9. COOKIES AND TRACKING TECHNOLOGIES

We use cookies and similar technologies to enhance functionality, analyze

usage, and personalize content. You may manage cookie preferences through your

browser settings.

10. CHILDREN’S PRIVACY

Our Services are not directed to individuals under the age of 16. We do not

knowingly collect personal data from children without parental consent.

11. THIRD-PARTY LINKS

Our platforms may contain links to third-party websites. We are not responsible

for their privacy practices or content.

12. POLICY UPDATES

We reserve the right to modify this Privacy Policy at any time. Updates will be

posted with a revised effective date.

13. CONTACT INFORMATION

For questions, concerns, or requests related to privacy, contact:

LUKABA Hospitality Group

Email: contact@lukabagroup.com