Hotel Sabot d’Or – Privacy Statement
Latest Update – June 18, 2018
Hotel Sabot d’Or values you as our guest and recognizes that privacy is important to you. We want you to be familiar with how we collect, use and disclose data.
This Privacy Statement describes the privacy practices of Hotel Sabot d’Or for data that we collect:
- through the website operated by us from which you are accessing this Privacy Statement, including www.sabotdor.com
- through the software applications made available by us for use on or through computers and mobile devices (the ‘Apps’)
- through our social media pages that we control from which you are accessing this Privacy Statement (our ‘Social Media Pages’)
- through HTML-formatted email messages that we send you that link to this Privacy Statement and through your communications with us
- when you visit or stay as a guest at our property, or through other offline interactions
Collectively, we refer to the website, the Apps and our Social Media Pages, as the ‘Online Services’ and, together with offline channels, the ‘Services’. By using the Services, you agree to the terms and conditions of this Privacy Statement.
Collection of Personal Data
‘Personal Data’ are data that identify you as an individual or relate to an identifiable individual.
At touchpoints throughout your guest journey, we collect Personal Data in accordance with law, such as:
- Postal address
- Telephone number
- Email address
- Credit and debit card number or other payment data
- Financial information in limited circumstances
- Language preference
- Date and place of birth
- Nationality, passport, visa or other government-issued identification data
- Important dates, such as birthdays, anniversaries and special occasions
- Employer details
- Travel itinerary, tour group or activity data
- Prior guest stays or interactions and services purchased, special service and amenity requests
- Geolocation information
In more limited circumstances, we also may collect:
- Data about family members and companions, such as names and ages of children
- Biometric data, such as digital images
- Images and video and audio data via security cameras located in public areas, such as hallways and lobbies in our property
- Guest preferences and personalized data (‘Personal Preferences’), such as your interests, activities, hobbies, food and beverage choices, services and amenities of which you advise us or which we learn about during your visit
If you submit any Personal Data about other people to us or our Service Providers (e.g., if you make a reservation for another individual), you represent that you have the authority to do so and you permit us to use the data in accordance with this Privacy Statement.
How We Collect Personal Data
We collect Personal Data in a variety of ways:
- Online Services.We collect Personal Data when you make a reservation, purchase goods and services from our Website or Apps, communicate with us, or otherwise connect with us or post to social media pages, or sign up for a newsletter or participate in a survey, contest or promotional offer.
- Property Visits and Offline Interactions.We collect Personal Data when you visit our properties or use on-property services and outlets, such as the restaurant, concierge services, child care services, bar and wellness.
- Customer Care Centers. We collect Personal Data when you make a reservation over the phone, communicate with us by email, fax or via online chat services or contact customer service.
- Strategic Business Partners. We collect Personal Data from companies with whom we partner to provide you with services or offers. Examples of Strategic Business Partners include travel and tour partners, rental car providers and travel booking platforms. Strategic Business Partners are independent from Hotel Sabot d’Or.
- Other Sources.We collect Personal Data from other sources, such as public databases, joint marketing partners and other third parties.
Collection of Other Data
‘Other Data’ are data that generally do not reveal your specific identity or do not directly relate to an individual. To the extent Other Data reveal your specific identity or relate to an individual, we will treat Other Data as Personal Data. Other Data include:
- Browser and device data
- App usage data
- Data collected through cookies, pixel tags and other technologies
- Demographic data and other data provided by you
- Aggregated data
How We Collect Other Data
We collect Other Data in a variety of ways:
- Your browser or device.We collect certain data through your browser or automatically through your device, computer type (Windows or Macintosh), screen resolution, operating system name and version, device manufacturer and model, language, internet browser type and version and the name and version of the Online Services (such as the Apps) you are using. We use this data to ensure that the Online Services function properly.
- Your use of the Apps.We collect certain data when you download and use an App, such as App usage data, the date and time the App on your device accesses our servers and what data and files have been downloaded to the App based on your device.
- We collect certain data from cookies, which are pieces of data stored directly on the computer or mobile device that you are using. Cookies allow us to collect data such as browser type, time spent on the Online Services, pages visited, referring URL, language preferences, and other aggregated traffic data. We use the data for security purposes, to facilitate navigation, to display data more effectively, to collect statistical data, to personalize your experience while using the Online Services and to recognize your computer to assist your use of the Online Services. We also gather statistical data about use of the Online Services to continually improve design and functionality, understand how they are used and assist us with resolving questions. If you do not want data collected with cookies, you can learn more about controlling cookies at http://www.allaboutcookies.org/manage-cookes/index.htm. You can choose whether to accept cookies by changing the settings on your browser. If, however, you do not accept cookies, you may experience some inconvenience in your use of the Online Services. For example, we will not be able to recognize your computer, and you will need to log in every time you visit.
- Your IP Address.We collect your IP address, a number that is automatically assigned to the computer that you are using by your Internet Service Provider (ISP). An IP address is identified and logged automatically in our server log files when a user accesses the Online Services, along with the time of the visit and the pages that were visited. We use IP addresses to calculate usage levels, diagnose server problems and administer the Online Services.
- Aggregated Data. We may aggregate data that we collected and this aggregated data will not personally identify you or any other user.
Use of Personal Data and Other Data
We use Personal Data and Other Data to provide you with Services, to develop new offerings and to protect Hotel Sabot d’Or and our guests as detailed below. In some instances, we will request that you provide Personal Data or Other Data to us directly. If you do not provide the data that we request, or prohibit us from collecting such data, we may not be able to provide the requested Services.
We use Personal Data and Other Data for our legitimate business interests, including the following:
- Provide the Services you request.We use Personal Data and Other Data to provide Services you request, including:
- To facilitate reservations, payment, send administrative information, confirmations or pre-arrival messages, to assist you with meetings and events and to provide you with other information about the area and the property at which you are scheduled to visit
- To complete your reservation and stay, for example, to process your payment, ensure that your room is available and provide you with related customer service
- To support our electronic receipt program. When you provide an email address in making a reservation, we use that email address to send you a copy of your bill. If you make a reservation for another person using your email address, that person’s bill will be emailed to you, as well. You can opt out of receiving your bill via email and instead receive a paper copy by contacting the front desk
We will use Personal Data and Other Data to manage our contractual relationship with you, because we have a legitimate interest to do so and/or to comply with a legal obligation.
- Personalize the Services according to your Personal Preferences.We use Personal Data and Other Data to personalize the Services and improve your experiences, including when you contact our hotel or use the Online Services, to:
- Customize your experience according to your Personal Preferences
- Present offers tailored to your Personal Preferences
We will use Personal Data and Other Data to provide personalized Services according to your Personal Preferences either with your consent or because we have a legitimate interest to do so.
- Communicate with you about services according to your Personal Preferences. We use Personal Data and Other Data to:
- Send you marketing communications and promotional offers, as well as periodic customer satisfaction, market research or quality assurance surveys
We will use Personal Data and Other Data to communicate with you with your consent, to manage our contractual relationship with you and/or because we have a legitimate interest to do so.
- We use Personal Data and Other Data to allow you to participate in promotions and to administer these activities.
- Business Purposes. We use Personal Data and Other Data for data analysis, audits, security and fraud monitoring and prevention (including with the use of closed circuit television, card keys, and other security systems), developing new services, enhancing, improving or modifying our Services, identifying usage trends, determining the effectiveness of our promotional campaigns and operating and expanding our business activities.
We use Personal Data and Other Data in this way to manage our contractual relationship with you, comply with a legal obligation and/or because we have a legitimate interest to do so.
Disclosure of Personal Data and Other Data
Our goal is to provide you with the highest level of hospitality and Services, and to do so, we share Personal Data and Other Data with the following:
- Strategic Business Partners.We disclose Personal Data and Other Data with select Strategic Business Partners who provide services and offers that enhance your experience at our property or that we believe will be of interest to you. By sharing data with these Strategic Business Partners, we are able to make personalized services and unique travel experiences available to you.
- Service Providers.We disclose Personal Data and Other Data to third-party service providers for the purposes described in this Privacy Statement. Examples of service providers include companies that provide website hosting, data analysis, payment processing, order fulfillment, information technology and related infrastructure provision, customer service, email delivery, marketing, auditing and other services.
Other Uses and Disclosures
We will use and disclose Personal Data as we believe to be necessary or appropriate: (a) to comply with applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including authorities outside your country of residence and to meet national security or law enforcement requirements; (d) to enforce our terms and conditions; (e) to protect our operations; (f) to protect the rights, privacy, safety of Hotel Sabot d’Or, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.
We may use and disclose Other Data for any purpose, except where we are not allowed to under applicable law. In some instances, we may combine Other Data with Personal Data (such as combining your name with your location). If we do, we will treat the combined data as Personal Data as long as it is combined.
Non-Hotel Sabot d’Or Entities
This Privacy Statement does not address, and we are not responsible for the privacy, data or other practices of any entities outside Hotel Sabot d’Or, including Strategic Business Partners or any third party operating any site or service to which the Services link, payment service or website that is the landing page of the high-speed Internet providers at our properties. The inclusion of a link on the Online Services does not imply endorsement of the linked site or service by us. We have no control over, and are not responsible for, any third party’s collection, use and disclosure of your Personal Data.
In addition, we are not responsible for the data collection, use, disclosure or security policies or practices of other organizations, such as Facebook, Apple, Google, Microsoft or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including with respect to any Personal Data you disclose to other organizations through or the Apps or our Social Media Pages.
We seek to use reasonable organizational, technical and administrative measures to protect Personal Data. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account has been compromised), please immediately notify us in accordance with the ‘Contact Us’ section, below.
Links to other websites
In order to anticipate your needs, our website provides links to other web sites and third parties for your convenience and information. We are not responsible for the collection, use, maintenance, sharing or disclosure of data (including personal data) by such third parties. We encourage you to contact these third parties to ask questions about their privacy practices, policies and security measures before disclosing any personal data. We recommend that you review the privacy statements and policies of linked web sites to understand how those web sites collect, use and store information.
Choices, Access and Retention
You have choices when it comes to how we use your data and we want to ensure you have the information to make the choices that are right for you.
If you no longer want to receive marketing-related emails, you may opt out by our unsubscribe function or by following the instructions in any such email you receive from us.
We will try to comply with your request as soon as reasonably practicable. If you opt out of receiving marketing emails from us, we may still send you important administrative messages, from which you cannot opt out.
How You Can Access, Change or Suppress Your Personal Data
If you would like to review, correct, update, suppress, restrict or delete Personal Data that you have previously provided to us, or if you would like to receive a copy of your Personal Data, you can contact us via mail – email@example.com.
In your request, please make clear what Personal Data you would like to have changed, whether you would like to have your Personal Data suppressed from our database, or other limitations you would like to put on our use of your Personal Data. For your protection, we only fulfill requests for the Personal Data associated with the particular email address that you use to send us your request, and we may need to verify your identity before fulfilling your request. We will try to comply with your request as soon as reasonably practicable.
Please note that we often need to retain certain data for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion (e.g., when you make a purchase or reservation, or enter a promotion, you may not be able to change or delete the Personal Data provided until after the completion of such purchase, reservation, or promotion). There may also be residual data that will remain within our databases and other records, which will not be removed. In addition, there may be certain data that we may not allow you to review for legal, security or other reasons.
We will retain your Personal Data for the period necessary to fulfill the purposes outlined in this Privacy Statement unless a longer retention period is required or permitted by law.
The criteria used to determine our retention periods include:
- The length of time we have an ongoing relationship with you and provide the Services to you (for example, for as long as you have an account with us or keep using the Services)
- Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them)
- Whether retention is advisable considering our legal position (such as, for statutes of limitations, litigation or regulatory investigations)
Unless specifically requested, we ask that you not send us, and you not disclose, on or through the Services or otherwise to us, any Sensitive Personal Data (e.g., social security numbers, national identification number, data related to racial or ethnic origin, political opinions, religion, ideological or other beliefs, health, biometrics or genetic characteristics, criminal background, trade union membership, or administrative or criminal proceedings and sanctions).
Updates to This Privacy Statement
The ‘LATEST UPDATE’ at the top of this page indicates when this Privacy Statement was last revised. Any changes will become effective when we post the revised Privacy Statement on the Online Services. Your use of the Services following these changes means that you accept the revised Privacy Statement. If you would like to review the version of the Privacy Statement that was effective immediately prior to this revision, please contact us.
If you have any questions about this Privacy Statement, please contact us by mail at firstname.lastname@example.org com or in writing:
Hotel Sabot d’Or
You also can:
- Contact our data protection officer you are contacting us
- Lodge a complaint with a data protection authority for your country or region or where an alleged infringement of applicable data protection laws occurs at http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.
At Hotel Sabot d’Or, we respect your privacy and want to provide you with information and choices. The options provided below allow you to express your preferences: what and how much you share with us and when and how you hear from us.
We want to learn what is relevant to you and ensure you have a personalized experience. As described in more detail in our Global Privacy Statement, we use digital tools like cookies and tags on our webpages. Cookies also help us provide, protect and improve our services.
We want to engage with you in a way that is meaningful to you. We recognize that you may only want to hear from us in a limited way. To adjust your preferences, you may choose to ‘unsubscribe’ by clicking the link at the bottom of one our communications.
*Please note that even if you choose to opt-out of communications with us, we will continue to send you transactional messages about your specific reservation or stay with us, such as pre-arrival, confirmation and guest satisfaction surveys.
If you have other preferences, or are looking to exercise your rights under the GDPR, please email us at email@example.com or mail us at:
Hotel Sabot d’Or
We will work with you to understand and process your request. Please note that we may ask you to verify your identity before taking further action on your request.
Use of Personal Data
Any Personal Data sent to us may be used by Hotel Sabot d’Or and its Service Providers for the purposes indicated in our Privacy Statement. If we intend to use your Personal Data for a purpose that is materially different from these purposes or if we intend to disclose it to a third party not previously identified, we will notify you and offer you the opportunity to opt-out of such uses and/or disclosures where it involves Personal Data or opt-in where Sensitive Personal Data is involved.
Disclosures to Third Parties
Your Personal Data may be disclosed to the following:
- To Service Providers
- To third parties offering travel, hospitality and other services to enhance your experience, such as Strategic Business Partners
- To your credit card company
Disclosures to Service Providers
We sometimes contract with other companies to perform services on our behalf such as catering within our hotel, website hosting, data analysis, payment processing, order fulfillment, information technology and related infrastructure provision, customer service, email delivery, auditing and other services. They may have access to Personal Data needed to perform their functions, but are restricted from using the Personal Data for purposes other than providing services for us or to us. We are responsible for ensuring that our Service Providers process the Personal Data in a manner consistent with our obligations under the Principles.
We use reasonable physical, electronic, and administrative safeguards to protect your Personal Data from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the nature of the Personal Data and the risks involved in processing that information.
Data Integrity and Purpose Limitation
We limit the collection and use of Personal Data to the information that is relevant for the purposes of processing and will not process Personal Data in a way that is incompatible with the purposes for which the information has been collected or subsequently authorized by you. We take reasonable steps to ensure the Personal Data is reliable for its intended use, accurate, complete, and current to the extent necessary for the purposes for which we use the Personal Data.
Access to Personal Data
You can ask to review, correct, or delete Personal Data that we maintain about you by sending a written request to firstname.lastname@example.org
Disclosures Required By Law
We may need to disclose Personal Data in response to lawful requests by public authorities for law enforcement or national security reasons or when such action is necessary to comply with a judicial proceeding or court order, or when otherwise required by law.
Hotel Sabot d’Or
This Policy may be changed from time to time, consistent with the requirements of the Privacy Shield. You can determine when this Policy was last revised by referring to the “LATEST UPDATE” at the top of this page. Any changes to our Policy will become effective upon our posting of the revised Policy on the Site.