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Leonardo Hotels Benelux - Privacy statement

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18 Aug-19 Aug
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PRIVACY STATEMENT LEONARDO HOTELS BENELUX

INTRODUCTION

Welcome to the Leonardo Hotels Benelux Privacy Statement.

This privacy statement applies to all services of the companies forming part of Leonardo Hotels Benelux except for services where reference is made to a privacy statement applying specifically to that service.

Leonardo Hotels Benelux respects your privacy and is committed to protecting your personal data. This privacy statement informs you about how we collect and process your personal data. This includes when you, or someone on your behalf, makes a booking or reservation, requests information from us, contacts us (or we contact you), uses our websites or apps, links to our websites or apps, connects with us via social media, through our contact centre or hotels, apply for a job or any other engagement we have with you (regardless of where you are based). It also tells you about your privacy rights and how the law protects you.

 

1. IMPORTANT INFORMATION AND WHO WE ARE
2. THE DATA WE COLLECT ABOUT YOU
3. HOW IS YOUR PERSONAL DATA COLLECTED?
4. HOW WE USE YOUR PERSONAL DATA
5. DISCLOSURES OF YOUR PERSONAL DATA
6. INTERNATIONAL TRANSFERS
7. DATA SECURITY
8. DATA RETENTION
9. YOUR LEGAL RIGHTS
10. WEBSITE COOKIES AND TRACKING

 

1. IMPORTANT INFORMATION AND WHO WE ARE

PURPOSE OF THIS PRIVACY STATEMENT

This privacy statement aims to give you information on how Leonardo Hotels Benelux collects and processes your personal data in our dealings with you, including in providing accommodation and other services to you, including any data you may provide through our website, including by cookies.

This general privacy statement may be supplemented by other special notices, we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data (such as for the AdvantageCLUB members, where you find a special notice here). This privacy statement supplements our other special notices and is not intended to override them.

 

CONTROLLER

Leonardo Hotels Benelux is made up of different legal entities which are operated by Fattal Netherlands Opcos B.V., Fattal Hotels Management (Belgium) and Leonardo Opco Overamstel B.V. Leonardo Hotels Benelux is part of Fattal Hotels Group. This privacy statement is issued on behalf of Leonardo Hotels Benelux so when we mention "Leonardo Hotels Benelux", "we", "us" or "our" in this privacy statement, we are referring to the relevant company in the Leonardo Hotels Group responsible for processing your data. All companies of Leonardo Hotels Benelux are listed here.

The Leonardo Hotels Benelux’ affiliates operating the hotels in which you stay or receive our services is the controller for the data processing of such accommodation service or other services’ receipt. You can book on this website other hotels of the Fattal Hotels Group which are not operated by Leonardo Hotels Benelux. The companies operating these hotels are listed here.

If you have any questions about this privacy statement, including any requests to exercise your legal rights, please contact the Data Protection Officer using the details set out below:

CONTACT DETAILS
E-mail address:
privacy@leonardo-hotels.nl / privacy@leonardo-hotels.be

Postal address:
Leonardo Hotels Benelux
Attn. Data Protection Officer
Staalmeesterslaan 410
1057 PH AMSTERDAM
The Netherlands

You have the right to make a complaint at any time to the data protection authority supervising us, by informing the Dutch Data Protection Authority (Dutch DPA); postal address: Autoriteit Persoonsgegevens, PO Box 93374, 2509 AJ Den Haag, The Netherlands Autoriteitpersoonsgegevens.nl/en

For Belgium, please inform the Belgium Data Protection Authority (Belgium DPA); postal address: Gegevensbeschermingsautoriteit, Drukpersstraat 35, 1000 Brussels, Belgium. Dataprotectionauthority.be

We would, however, appreciate the chance to deal with your concerns before you approach the Authority so, please contact us or our Data Protection Officer in the first instance.

This version was last updated on March 2, 2022. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

 

2. THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. Data where the identity has been removed (anonymous data) is therefore not personal data.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

 

Identity data includes first name, last name, username, or similar identifier, title, date of birth, place of birth, nationality, passport or ID card number, gender, and car number plate.

Contact data includes billing address, home address, e-mail address, and fax and telephone numbers.

Special requirements data includes health, disability and religious or dietary requirements only if you notify us of any special needs and provide this information.

Booking and transaction data includes bank account or payment card details and details about payments, purpose of stay and other details of your bookings, stays and other services you have purchased from us, and comments and responses to surveys you provided relating to our service.

Technical data of your visit to this website includes your internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.

AdvantageCLUB and other profile data include your e-mail address registered for the AdvantageCLUB and password, AdvantageCLUB membership number used for any partner programs (e.g., Miles & More) services provided to you, your interests and preferences, feedback, and survey responses. If you are an AdvantageCLUB member, please also see the Leonardo AdvantageCLUB membership Data privacy statement, which covers more detailed all aspects of our data processing relating to the AdvantageCLUB and which prevails over this privacy statement for AdvantageCLUB issues.

Usage data includes information about how you use our services or link with us via social media and our website.


We will not collect all the data referred to above in each case, but only such data required for the specific legal grounds.

Under normal circumstances, we will only collect special categories of personal data about you (this includes details about your religious beliefs or information about your health needs and disabilities ("special requirements data") to the extent that it is volunteered by you or on your behalf and is needed to cater to your requirements during your stay with us or other use of our facilities or services. We may also, however, need to process such information in the event of an accident or a medical or other emergency during your stay or your other use of our facilities.

We obtain limited information about children who are booked to stay at our hotels (number, age, and where legally required, other data such as name, date of birth, place of birth).

IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with accommodation or our other services). In this case, we may have to cancel a booking or other service you have with us, but we will notify you if this is the case at the time.

 

3. HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

Direct interactions

You may give us your Identity, Contact, Booking and Transaction data by filling in forms or by corresponding with us by post, phone, e-mail, via our websites, on social media or otherwise. This includes personal data you provide when you:

  • make a booking at one of our hotels – for overnight stays, restaurant reservations, health club treatments & subscriptions, functions or conferences
  • check in to one of our hotels
  • attend a function, conference, or otherwise use the facilities at one of our hotels
  • subscribe to our Promenade Healthclub or book treatments at the healthclub
  • subscribe to our parking services
  • sign up for our AdvantageCLUB
  • subscribe to our newsletter and/or other publications
  • request a brochure or other promotional or marketing materials to be sent to you
  • enter a competition, or respond to a promotion or survey
  • give us some feedback
  • apply for a job or traineeship via our jobs website
     

Automated technologies or interactions
As you interact with our websites or via social media, we may automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, e-mails, server logs and other similar technologies. Please see our Cookie Policy for further details.

Travel agencies or other third parties acting on your or your employer's behalf
We may receive personal data about you if a booking is made for you by a travel agency, online portal or another third person. This may be a family member or travelling companion, agent or other intermediary working for you or, if you are travelling on business, your employer or other third party acting on your behalf (tour operators, online travel agencies, global distribution systems) including reservation systems, and contact, booking, and transaction data from providers of technical, payment and delivery services.

Other third parties or publicly available sources
We may receive personal data about you from third parties and public sources as set out below:

  • Web and social media analytics providers
  • Advertising networks
  • Web interaction technology providers
  • Identity and contact data from publicly available sources such as trade registers of EU member states

Monitoring
We may monitor and/or record:

  • transactions and activities at all points of contact
  • web, social media and app traffic and activities

These are to ensure that we carry out your instructions accurately, for training purposes and to improve our services, and to ensure security and prevent fraud. For the greater security of our guests and patrons, and to prevent and detect crime, we use CCTV in and around our premises.

Business Contacts
If you are a business contact of Leonardo Hotels, we may receive your data as you interact with our websites, from trade fair visits, workshops, personal meetings, corresponding with you through e-mails and phone calls, through contractual negotiation and agreements.
 

4. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to do so. Most commonly, we will use your personal data in the following circumstances (each a "Legal Ground"):

Performance of contract:
Where we need to provide the booked accommodation and services, or otherwise perform the contract we have entered into with you (or are about to enter).

Consent:
Where you provide us your explicit consent to use your personal data.

Legitimate interests:
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

Comply with obligations:
Where we need to comply with a legal or regulatory obligation.

Vital interests:
In the case of an accident or a medical or another emergency, to protect your or another individual's vital interests, where you or they are not able to give consent.

For any processing that is based on your consent (mainly applying to online advertising to you), you have the right to withdraw such consent at any time by contacting us.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We collect and process your personal data for purposes such as:

  • To make a booking including reserving disability adapted accommodation, to provide accommodation and other services to you including meeting your specific health, disability, dietary and religious requirements, to manage your stay at the hotel and to monitor the use of our services, and to collect and recover money owed to us.

Legal Grounds: Performance of Contract, Consent (for meeting your specific health, disability, dietary and religious requirements), Legitimate interest (to improve our services)

  • To deal with issues, complaints or disputes arising from our relationship with you, and to prevent or detect crime, including fraud, to manage our relationship with you which will include:
  • Asking you to leave a review or take a survey to help us improve our service to you
  • Asking you to participate in a prize draw or competition

Legal grounds: Legitimate interest (to monitor and improve our services, to prevent crime and fraud, to keep our documents up to date)

  • To administer and protect our business including our websites (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data), to deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you, and to make suggestions and recommendations to you about our services that may be of interest to you

Legal grounds: Legitimate interest (to develop our business and do marketing), Performance of Contract (where website is used to book or deliver service or manage AdvantageCLUB membership)

  • To use data analytics to improve our websites, services, marketing, customer relationships and experiences

Legal grounds: Consent (for use of cookies and analytics); Legitimate interest (to develop our business and do marketing)

  • To deal with an accident or medical other another emergency

Legal grounds: Vital Interest

  • To comply with local legislation (for example, storing of accounting documents or registration cards)

Legal grounds: Comply with obligation

We do not undertake automated decision making using your personal data.

MARKETING/PROMOTIONAL OFFERS

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Where you have agreed to receive it and have provided your consent, we may use your identity, contact, technical, usage and AdvantageCLUB or other profile data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant to you.

You can revoke your consent and unsubscribe from our marketing communication at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

COOKIES
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.

CHANGE OF PURPOSE

We will only use your personal data for the purposes for which we collected it, unless we consider that we need to use it for another reason and that reason is compatible with the original purpose.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
 

5. DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the categories of parties set out below for the purposes set out above.

  • Other companies in the Leonardo Hotels group and Fattal Hotels Group based within the European Economic Area, Switzerland, United Kingdom, or Israel involved in providing services to you, whether directly or for providing underlying infrastructure services on our behalf and instruction.

External third parties, including:

  • Business partners, suppliers, and sub-contractors for the performance of any contract we enter into with them or you; these include contractors who provide services to you in their own name such as the third-party provider offering Wi-Fi services, as well as our other providers acting as processor on our behalf and as instructed by us (such as the providers of our IT and CCTV infrastructure).
  • Analytics and search engine providers that assist us in the improvement and optimisation of our services and website (as processor acting on our behalf and as instructed by us).
  • Professional advisers, including lawyers, banks, auditors, and insurers.
  • Tax and customs authorities, public registry authorities, regulators and other authorities.
  • Entities involved in credit checking and anti-fraud activities, crime prevention/detection, risk assessment and management and dispute resolution.

Where these third parties are our processors, we require them to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party processors to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions. Some of the third parties mentioned above, for example many professional advisers and authorities, are controllers who, like us, are subject to specific obligations under data protection law, and who will have their own privacy statements setting out how they deal with personal data.
 

6. INTERNATIONAL TRANSFERS

We share your personal data within the Leonardo Hotels group. All companies in the Group are currently based in the European Economic Area (EEA), and in countries that have been recognised by the European Commission to offer an adequate level of data protection (notably the United Kingdom, Switzerland, and Israel).

Though we do not seek actively to transfer personal data outside the EEA or countries with an adequate data protection, some of the external third parties we deal with are based outside the EEA or process personal data outside the EEA, so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we look to ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • Transferring your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission (as set out above, this especially applies to Switzerland, United Kingdom, and Israel).
  • Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. We do this for example in connection with our providers for booking through travel agents in the US.

Please Contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
 

7. DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorised way, altered, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. Processors we appoint will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
 

8. DATA RETENTION

HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

In some circumstances, we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
 

9. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws regarding your personal data. You can:

  • Request access of your personal data
  • Request correction of your personal data
  • Request erasure of your personal data
  • Object to processing of your personal data
  • Request restriction of processing your personal data
  • Request transfer of your personal data
  • Right to withdraw consent

If you wish to exercise any of the rights set out above, please Contact us via privacy@leonardo-hotels.nl or privacy@leonardo-hotels.be

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to enable us to deal with your request or to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or we have received several requests. In this case, we will notify you and keep you updated.

You have the right to:

  • Request access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law.

Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

  • Object to processing of your personal data where we are relying on our legitimate interest (or that of a third party) and there is something about your situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
     
  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following situations:
  1. if you want us to establish the accuracy of your data;
  2. where our use of your data is unlawful but you do not want us to erase it;
  3. where you need us to hold your data even if we no longer require it as you need it to establish, exercise or defend legal claims;
  4. you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
     
  • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
     

10. WEBSITE COOKIES AND TRACKING

The Leonardo Hotels Group, represented by Sunflower Management GmbH & Co. KG ("Leonardo Hotels", "we" or "our") operates this website (www.leonardo-hotels.com / www.leonardo-hotels.nl / www.leonardo-hotels.be) (the "Website"). Leonardo Hotels respects the right to privacy of every individual who access and navigate our website. Leonardo Hotels takes the protection of users and follows the legally valid regulations regarding data protection. This privacy statement outlines how we use any personal information we collect about you and your rights to access and correct the personal information we hold about you.

CONSENT

By using this website, you consent to the use of cookies in accordance with this privacy statement. You will have seen a pop up to this effect on your first visit to this website; although it will not usually appear on subsequent visits you may withdraw your consent at any time by following the instructions below.

DISABLING COOKIES

If you do not agree to the use of these cookies, please disable them by following the instructions for your browser. Please note that some of the services will not function so well if cookies are disabled.

Where the organisation setting the cookie provides an automated disabling tool in respect of its cookies, we list the name of that organisation, the category of cookies it sets together with a link to its automated disabling tool. In all other cases, we list the names of the cookies themselves and their source at the date of this privacy statement so that you can easily identify and disable them if you want through your browser controls.

Some browsers make it possible for you to indicate that you do not want your internet browsing activity to be tracked. Disabling tracking may interfere with some uses of the website and the services provided on the website.

After your initial visit to the website, we may change the cookies we use. The page https://www.leonardo-hotels.com/privacy-notice-and-cookie-policy, will always inform you of who is placing cookies and for what purpose, and gives you the means to disable cookies, so we recommend you check it from time to time.

WHAT IS A COOKIE?

A cookie is a small text file containing small amounts of information which is placed by a website onto a computer or device. Cookies are designed to assist a computer or device to remember something the user has done within that website, e.g., remembering that the user has logged in, or which buttons have been clicked. Cookies cannot carry viruses or install malware.

WHY DOES LEONARDO HOTELS USE COOKIES AND HOW LONG DO WE STORE THEM?

Leonardo Hotels uses cookies with technologies to recognise customers and to understand and facilitate your browsing and booking behaviour. We use this information to improve our websites to offer the best experience for our guests. Our website also uses cookies and similar technologies placed by our carefully selected third party partners.

Cookies are useful because they allow a website to recognise a user’s device. Cookies allow you to navigate between pages efficiently, remember preferences and generally improve the user experience. They can also be used to tailor advertising to your interests through tracking your browsing across websites.

Session cookies are deleted automatically when you close your browser and persistent cookies remain on your device after the browser is closed (for example to remember your user preferences when you return to the site).

WHAT TYPES OF COOKIES DOES LEONARDO HOTELS USE?

Below, we describe the categories of cookies used by Leonardo Hotels, its affiliates and contractors.

  • Strictly Necessary Cookies

These cookies are essential to enable you to move around the website and use its features. Without these cookies, services you have asked for (such as navigating between pages) cannot be provided.                        

  • Performance Cookies

We make use of analytic cookies to analyse how our visitors use our website and to monitor website performance. This allows us to provide a high-quality experience by customising our offering and quickly identifying and fixing any issues that arise. For example, we might use performance cookies to keep track of which pages are most popular, which method of linking between pages is most effective, and to determine why some pages are receiving error messages. We might also use these cookies to highlight articles or site services that we think will be of interest to you based on your usage of the website. The information collected by these cookies is not associated with your personal information by us or by our contractors.

  • Website Functionality Cookies

We make use of cookies to provide you with certain functionality. For example, to remember choices you make (such as your username, language, or the region you are in), or to recognise the platform from which you access the site, and to provide enhanced and more personal features. These cookies are not used to track your browsing on other sites.

  • Advertising Cookies

Advertising cookies (or targeting cookies) collect information about the browsing habits associated with your device and are used to make advertising more relevant to you and your interests. They are also used by services provided by third parties on this website, such as ‘Like’ or ‘Share’ buttons in addition to providing the requested functionality. Third parties provide this service in return for recognising that you (or more accurately your device has) have visited a certain website. These third parties place advertising cookies when you visit our website as well as when you use their services and navigate away from our website.

  •  HTML e-mail web beacons

Our e-mails may contain a single, campaign-unique “web beacon pixel” to tell us whether our e-mails are opened and verify any clicks through to links within the e-mail. We may use this information for purposes including determining which of our e-mails are more interesting to you, to query whether users who do not open our e-mails wish to continue receiving them. The pixel will be deleted when you delete the e-mail. If you do not wish the pixel to be downloaded to your device, you should select to receive e-mails from us in plain text rather than HTML.

  • Use of IP addresses and web logs

We may also use your IP address and browser type to help diagnose problems with our server, to administer our website and to improve the service we offer to you. An IP address is a numeric code that identifies your computer on the internet. Your IP address might also be used to gather broad demographic information.

We may perform IP lookups to determine which domain you are coming from (e.g., google.com) to gauge our users’ demographics more accurately.
 

PRIVACY STATEMENT DOES NOT COVER THIRD PARTY WEBSITES

Please note that this privacy statement does not apply to, and we are not responsible for, the privacy practices of third-party websites which may be linked to this website.