- INFORMATION WE MAY COLLECT
2.1 We may collect personal information about you when you use our website, and otherwise interact with us. The information we collect falls into three categories:
(a) information you provide us; and
(b) information we collect through automated methods, and
(c) information we collect from other sources.
2.2 We may combine the information you provide us, with information that is collected through automated methods, and with information we receive from other sources.
2.3 We collect information you provide us. You may provide the following information to us:
(a) Personal details, such as your name, postal and email addresses, phone number, date of birth and other contact information, when you register with our Website, log-in to Wi-Fi, or contact us by phone or through our online services;
(b) Profile information, including products and services you like, or times you prefer to visit us; and
(c) Other personal information you choose to give us when you interact with us.
2.4 We collect information through automated methods
(a) We may use automated technology to collect information from your computer system or mobile device when you visit our restaurants, use our online services, or in-restaurant technology. Automated technology may include cookies, local shared objects, and web beacons. There is more information below about cookies and other technologies.
2.5 We may collect information about your:
(a) Internet protocol (IP) address;
(b) Computer or mobile-device operating system and browser type;
(c) Advertising identifiers (for example, IDFAs and IFAs) or similar identifiers;
(d) Referring website (a site that has led you to ours) or application;
(e) Online activity on other websites, applications, or social media;
(f) Communications to us or regarding us on social media; and
(g) Activity related to how you use our online services, such as the pages you visit on our sites or in our mobile apps.
2.6 We collect information from other sources we may collect information about you from other companies and organisations. We may also collect information that is publicly available. For example, we may collect information about you when you interact with us through social media.
- TYPES OF CLIENTS’ PERSONAL DATA
3.1 We will ask you to fill the registration form during registration/check-in at our properties and provide us with certain information about yourself. We will also collect your Personal Data on various other occasions during your interaction with us and your stay at our hotels, including:
(a) Booking a room with us;
(b) Checking – in and paying;
(c) Using the facilities of our hotels during your stay;
(d) Lodging a request/complaint during your stay;
(e) Participation in customer surveys;
(f) Subscription to newsletters and other types of direct marketing communication;
3.2 In order to administer your accommodation at our hotel and to meet our obligations towards you, as a customer/guest of ours, we will collect the following information about you, including:
(a) Contact details (for example, last name, first name, father’s name, telephone number, email, nationality, gender, place and date of birth, postal address, national identification number, tax identification number);
(b) Information relating to your children (for example, first name, date of birth, age);
(c) Information related to your reservation, stay or visit to a property;
(d) Information related to the purchase and receipt of products or services;
(e) Transaction and billing information, such as your payment card number and other card information;
(f) Guest preferences;
(g) Marketing and communication preferences;
(h) And other types of information that you choose to provide to us or that we may obtain about you.
3.3 The information collected in relation to children and minors is limited to which can only be provided to us by their legal guardian and/or any person legally authorised to do so.
- USES MADE OF THE INFORMATION
5.1 We use information held about you in the following ways:
(a) To ensure that content from our site is presented in the most effective manner for you and for your computer;
(b) Meeting our obligations to our customers;
(c) Managing the reservation of rooms and accommodation requests;
(d) Managing your stay at the hotel
(e) Improving our hotel service, especially processing your personal data in our customer marketing program in order to carry out marketing operations, understand better your wishes, adapt our products and services to better meet your requirements, customise commercial offers and the promotional messages we send to you, inform you of special offers and any new services of our hotels;
(f) Managing our relationship with you as a customer before, during and after your stay, especially: developing statistics and carrying out reporting; identifying and managing preferences of our customers; directly communicating with you for marketing purposes (newsletters, promotions, hotel offers) satisfaction surveys; managing requests to unsubscribe from receiving communication from us; managing the data subjects’ requests with regard to the processing of their personal data; analysing your Personal Data, in order to determine your interests and your customer profile, and to allow us to send you personalised offers
(g) Conforming to local legislation (for example, storing of accounting documents).
5.2 We may also use your data, or permit selected third parties to use your data, to provide you with information about goods and services which may be of interest to you and we or they may contact you about these. We do not disclose-information about identifiable individuals to our advertisers, but we may provide them with aggregate information about our users. We may make use of the personal data we have collected from you to enable us to comply with our advertisers’ wishes by displaying their advertisement to that target audience.
- MARKETING COMMUNICATIONS
6.1 If you have agreed to receive marketing communications from us, you can later opt out by following the opt-out instructions in the marketing communications we send you. You can also opt out by contacting us at the address, phone number or email address below. If you do opt out of receiving marketing communications from us, we may still send communications to you about your transactions, any accounts you have with us, and any contests, competitions, prize draws or sweepstakes you have entered. Opting out of one form of communication does not mean you’ve opted out of other forms as well. For example, if you opt out of receiving marketing emails, you may still receiving marketing text messages if you’ve opted in to receiving them.
6.2 We do not share your Personal Data with third parties for their own direct marketing purposes, unless you give us permission to do so. When we give you notice, and you consent, we will share your Personal Data as you direct us to.
6.3 We keep your information for the length of time needed to carry out the purposes outlined in this privacy statement and to adhere to our policies on keeping records (unless a longer period is needed by law).
6.4 If at any time you would like to correct the personal information we have about you, please contact us at the address, phone number or email address below (see par. 14 below).
- WHERE WE STORE YOUR PERSONAL DATA
7.1 The data that we collect from you shall not be transferred to, and stored at, a destination outside the European Union.
7.2 All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted.
- INFORMATION SECURITY
8.1 Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
- RETENTION OF PERSONAL INFORMATION
- DISCLOSURE OF YOUR INFORMATION
10.2 We may share your information with vendors who provide services to us, such as fulfilling orders, providing data processing and other information technology services, managing promotions, contests, carrying out research and analysis, and personalising individual customer experiences. We do not allow these vendors to use this information or to share it for any purpose other than to provide services on our behalf.
10.3 There may be times where we may share information when it does not directly identify you. For example, we may share anonymous, aggregated statistics about your use of our Website. Or we may combine information about you with other customers and share the information in a way that does not identify you.
10.4 We have the right to use or share information as necessary to keep to any law, regulation or legal request or requests of any embassy regarding your stay at our hotels, to protect our Website, to bring or defend legal claims, to protect the rights, interests, safety and security of our organisation and our employees, or users of the Website, or in connection with investigating fraud or other crime, or violations of our policies.
- YOUR RIGHTS
11.1 Under the applicable legislation you have the right to request access to the personal data we hold about you, i.e. to be informed upon your request whether your personal data are subject to processing and to receive further information on such processing, including information on eventual transfers of personal data outside the EU and the appropriate or suitable safeguards we have in place for such transfer.
11.2 As long as the requirements under the applicable legislation are met, you may also request the correction of any inaccurate information we hold about you or the deletion of the same or restriction of the processing concerning your personal data. If such a request places us or our affiliates in breach of its obligations under applicable laws, regulations or codes of practice, then we may not be able to comply with your request but you may still be able to request that we block the use of your personal information for further processing. You may also have a right to data portability to another data controller under certain circumstances.
11.3 You may withdraw your consent at any time. The withdrawal of your consent will not affect the lawfulness of processing based on consent before its withdrawal.
11.4 You may also lodge a complaint with the competent Data Protection Supervisory Authority, if you feel that the processing contravenes the law.
- LINKS TO OTHER WEBSITES AND SOCIAL MEDIA
12.1 Our Website may, from time to time, contain links to and from the websites of our partner networks, and advertisers. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
12.2 We may also have providers of other apps, tools, widgets and plug-ins on our online services, such as Facebook “Like” buttons, which may also use automated methods to collect information about how you use these features. These organisations may use your information in line with their own policies.
- HOW TO CONTACT US