Definition of Non-Identifiable Information: Personal information that is
de-identified and/or aggregated and cannot be associated with an identifiable individual is not
considered to be personal information. The Hotel reserves the right to conduct statistical
analyses through the use of personal information and/or data collected, including the data
collected from individuals who enter our property, through our websites, Wi-Fi or entertainment
services on an anonymous and/or aggregated basis in order to understand users’ interests,
improve our services and measure interest in and use of our websites and/or mobile app. The
Hotel reserves the right to provide its analyses based on such anonymous and/or aggregated data
to third parties.
Definition of Personal Information: When used in this Privacy Policy, personal
information means any information about an identifiable individual.
The Hotel generally collects personal information from or about our guests and other individuals
with whom we deal for general business‑related purposes such as to help
prevent fraud, unauthorized activities, claims and other liabilities and to ensure the security
of our properties. We may also use personal information to authenticate the identity of
individuals contacting us by telephone, electronic means or otherwise, for internal training and
quality assurance, to manage our business and ensure the efficiency, reliability and security of
our systems and networks, and to ensure the security of our guests and of our hotels.
We may also collect and use, to the extent permitted by law, guests' personal information to
understand the interests and changing needs of our guests so we may provide personalized
products, recommendations and services.
Other uses include processing payments, verifying creditworthiness if applicable, opening and
managing accounts, delivering requested products and services, guaranteeing a reservation,
ensuring a high standard of service, meet regulatory requirements, and enrolling you in a
loyalty program in cases in which you clearly outlined your consent orally or in writing.
More specifically, the Hotel collects and uses personal information in the following manner:
I. Information Collected from or About You. In many cases, we collect personal
information directly from you when you visit our premises, make a reservation, use our services,
make a complaint, submit an inquiry, contact us in person or through our websites, and use our
websites to log in to our Wi-Fi. You will therefore know when we collect this information. We
also may receive personal information about you from third party intermediaries and service
providers when you make your reservation through them, from our customers, such as your employer
or from any other third party through which your visit at our hotel is administered or organized
(for instance if you attend a conference organized by a professional association), but at all
times, with your prior consent and/or as authorized by law either orally or in writing, before
or at the time of collection, unless the purpose for the collection is obvious and is done so
voluntarily by you.
- Guests. We may collect information such as your name, contact information,
email address, payment information, gender, date and place of birth, home address, telephone
number, language preference, membership or loyalty program information, employer details,
travel itinerary, prior stays, stay preferences, and other similar type of information in
relation to your reservation or under your broader hotel stay, including the use of onsite
outlets such as restaurants, concierge services, health clubs and spas, only in cases in
which these hotel amenities are run and maintained by hotel staff. If hotel amenities are
run by third-parties, we recommend that you check their privacy policy if applicable. We
usually collect this personal information to provide you with our products and services or
to provide you with the information requested or to contact you to answer your questions,
requests or inquires or to administer the contest or promotions which you have entered. In
applicable cases, we also collect information related to the security of the premises and
well-being of our guests, such as companion information, and names and ages of accompanying
children.
- Customers, suppliers and other business partners, as individuals. We may
collect the name, address, telephone numbers (office, cell), email addresses, and in certain
circumstances, personal information collected in the context of a background check (such as
employment records, credit records and criminal records) from employees of our customers,
suppliers or business partners. We collect this personal information to evaluate and select
customers, suppliers and other business partners, to initiate orders, process payments,
establish and maintain responsible business relations, provide ongoing service and manage
risk.
- Employment Applications. We may collect the information which you have
included in your resume when you submit a job application or when you apply for employment
with the Hotel, for recruitment and other customary human resources purposes. For example,
we may send you information about new job opportunities within the Hotel as well as other
career development resources. We may also collect personal information in the context of a
background check (such as employment records, credit records and criminal records).
II. Information Collected Automatically. In some cases, we may collect
information automatically which may not necessarily identify you as an individual. For instance,
we may collect the following type of information:
- CCTV. As a security measure and in order to ensure the
safety of our guests and employees, we may use Closed Circuit Television (CCTV) at various
locations on our premises in order to maintain the security of our properties. This
collection is subject to applicable privacy laws and may be shared in limited circumstances,
as detailed in Section 6 Sharing of Personal Information of this
Privacy Policy.
- Lock Information. As a security measure, we may collect information through
our door lock system. This information includes the time when room doors were opened and
closed. This information may be shared in limited circumstances, as detailed in Section 6 Sharing of Personal Information of this Privacy Policy.
- Browser, Device, Behaviour, Demographic and Technical Information. When you visit our
websites and use our Wi-Fi, we may collect technical information, using electronic means
such as cookies. This information may include information about your visit or usage,
including the IP address of your device/computer and which browser you used to access our
websites or Wi-Fi, your operating system, resolution of screen, location, language settings
in browsers, the site you came from, keywords searched (if arriving from a search engine),
the number of page views, as well as information you entered and advertisements you have
seen. We may also collect your gender, age group and interests, but such information is
always aggregated and is not associated with any identifiable individual. We use this
information to measure, to monitor traffic to our websites and improve the effectiveness of
our websites or enhance the experience of our guests. Moreover, we may use the personal
information collected from our guests to assess their interests and changing needs with a
view to improving our products and services and developing new ones, as well as to evaluate
potential improvements or other modifications to the functionality of our websites. For
information on how you can limit the type of information that we collect, use or share about
you when you visit and/or use our websites or Wi-Fi, please refer to Section 5 Right to Withdraw Consent of this Privacy Policy. We may
also collect and use the following type of information:
- Google Analytics: We use Google Analytics which allows us to see
information on user online activities including, but not limited to, page views,
source and time spent on our websites and/or mobile app. This information is
depersonalized and is displayed as numbers, meaning that it cannot be tracked back
to individuals. You may opt-out of our use of Google Analytics by visiting the
Google Analytics opt-out page.
- Google Ads, previously known as Google AdWords: We use Google Ads
to reach potential new clients or existing ones. Remarketing on Google Ads is also
used to advertise the Hotel across the Internet and to advertise on third party
websites (including Google) to previous visitors to our websites. Google Ads
remarketing will display ads to you based on what parts of the Hotel website you
have viewed by placing a cookie on your web browser. It could mean that we advertise
to previous visitors who haven’t completed a task on our site or this could be in
the form of an advertisement on the Google search results page, or a site in the
Google Display Network. This cookie does not in any way identify you or give access
to your computer or mobile device. The cookie is only used to indicate to other
websites that you have visited a particular page on our websites, so that they may
show you ads relating to that page. If you do not wish to participate in our Google
Ads Remarketing, you can opt out by visiting Google’s Ads Preferences Manager.
- Pixel Tags: We may use pixel tags (which are known as web beacons
and clear GIFs) on our websites to track actions of users on our websites. Unlike
cookies, which are stored on the hard drive of your computer or mobile device by a
websites, pixel tags are embedded invisibly on webpages. Pixel tags measure the
success of our marketing campaigns and compile statistics about usage of our
websites so we can manage our content more effectively. Information we collect using
pixel tags is usually not linked to our users’ personal data. You may choose to stop
pixel tags by going to your browser settings.
- Geolocation Information. When you use our Wi‑Fi or utilize
internet-connected devices on our premises, we, or our third-party providers, may gather
location data, and any other personal information that would be clearly indicated on the
devices themselves.
- Traffic and Device Count. In some cases, we may track the number of
individuals who enter our hotel or monitor foot traffic patterns within our hotel, without
identifying guests in order to assist us in predicting information about our
guests during their visit to our property. We may also track devices which have accessed
and/or visited our hotel or used our services, websites and/or Wi‑Fi for similar
purposes, as well as ensuring we do not exceed our capacity to deliver reliable internet
services to our guests.
- Social Media. If you interact with us through a third party social media
platform (such as Facebook or Twitter or a similar platforms) through which you allow us to
collect (or the third party to share) information about you, (including personal
information) such as details of your friends/connections, “likes”, comments you have shared,
groups and location. In addition, we may receive information about you (including your
personal information) if other users of a third party websites give us access to their
profiles and you are one of their friends/connections or information about you is otherwise
accessible through your friends’/connections’ web page, profile page, or similar page on a
social media platform or other third party websites or interactive service. We may
supplement the information we collect about you directly with the information we receive
from third parties in order to enhance our ability to serve you, to tailor our content to
you and send you details of promotions and/or offers which we believe may be of interest to
you, although at all times, in compliance with applicable privacy laws.
- Vehicle Information. If you park at our Hotel, we may collect information
about your vehicle for the purposes of managing our parking facility, providing parking
services to you, and enforcing our parking regulations.
We may use your information to contact you regarding future services and/or to conduct surveys on
the quality of our products, services or customer service or to provide you with offers for
additional products and services that we feel may be of interest to you. For more details on the
type of commercial electronic messages that you may receive from us, please refer to Section 3 Electronic Communications and Notifications of this Privacy
Policy. Unless required or authorized by law, the Hotel will not collect or use personal
information for any other or new purpose without obtaining further consent.