www.americancolony.com is the official website of the American Colony Hotel(hereinafter: “The Website” and “The Hotel”, respectively), The Website displays various information regarding The Hotel, and allows you the user (hereinafter: “The User”) to make a reservation for staying at The Hotel and order a variety of related services.
The Hotel takes privacy as a tremendously important issue and recognizes the extent of what this means. We as an entity strive to deliver outstanding products, services, and experiences to you while processing your personal information.
1: IMPORTANT INFORMATION AND WHO WE ARE
By using any of our products or services and/or by agreeing to this Statement, e.g. in the context of registering for any of our products or services you understand and acknowledge that we will collect and use personal information as described in this following Statement.
The Hotel is the main controller in regard to the information we receive. This entity operates as the “data controller” and this means a regulated group who (either alone or jointly or in common with other groups) determines the purposes for which and the manner in which any personal data are to be processed. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us using the details set out below.
There is a Data Processing Agreement that is properly disclosed. This agreement revolves around processing of personal data and regulates the Data Processor (whoever that party may be) who carries out the role of processing personal data on behalf of Hotel(the ”Data Controller”) and is most importantly GDPR compliant as well.
Postal address/Telephone number:
1) Address: Louis Vincent St. Jerusalem 1
You have the right to make a serious complaint at any time to the relevant data protection authority. We would, however, appreciate the chance to deal with your concerns before you approach the Authority so please contact us in the first instance.
Last updated: 29 October 2019.
Our website may also include links to third-party websites, plug-ins, and applications. By clicking on those links, you may enable third parties to collect or share data about you. It is your responsibility to understand hotel does not control these third-party websites nor their data processing. When you leave our website, we encourage you to read the privacy notice of every third-party website you visit as well to understand how they process data.
2: THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, is any information about an individual from which that individual can be identified. Personal data does not include anonymous data, data where the identity has been removed.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
- Identity Data includes first name, last name, username or similar identifier, marital status, title, date of birth, place of birth, nationality, passport or ID card number, gender and vehicle registration plate.
- Contact Data includes home address, billing address, email address, and phone numbers
- Booking and Transaction Data includes bank account or payment details and other details, including reason of stay, 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 internet protocol address, your login information, browser type and version, time zone setting and browser, location plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
- Special Requirements Data includes disability, health, religious, or dietary requirements if you notify us of any special needs and provide this information.
- Usage Data includes information about how you use our services and social media platforms.
We will not collect all the data referred to above in each case, but only such data required for the specific legitimate interest.
We will only collect Special Categories of Personal Data about you to the extent that it is voluntarily submitted by you or on your behalf and is needed to satisfy your requirements during your stay with us or other use of our facilities or services. However, we may also 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 in 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
If you fail to provide personal data when requested, we may not be able to follow through with the contract we have or are trying to construct with you. In this case, we may not be able to proceed with the booking or other service you have with us, however 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 and Booking Data, and Transaction Data by filling in forms or by corresponding with us by mail, phone, email, via our website, on social media or otherwise. This includes personal data you provide when you:
- 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; or
- give us some feedback.
- make a booking at one of our three hotels, whether for overnight stays or conferences;
- check in to one of our hotels;
- attend a function, conference, or otherwise use the facilities at one of our hotels;
- Third parties. We may collect personal data about you if a booking is made for you by a travel agency, online portal or another third person, who may be a family member or travelling companion, or agent or other intermediary, working for you or, where you are travelling on business, your employer or other third party on your behalf, such as tour operators, booking engines, travel agencies, and Global Distribution Systems or other similar, Contact, Booking and Transaction Data from providers of technical, payment and delivery.
- Business Contacts. If you are a business contact of Asrtal Hotel, we may receive your data as you interact with our website, from trade fair visit/ workshops, personal meetings, corresponding with you through emails and phone, through contractual negotiation and agreements
- Other third parties or publicly available sources. We may receive personal data about you from third parties and public sources as set out below:
- Social Media Analytics providers
- Advertising networks
- Web interaction technology providers
- Monitoring. We may monitor and/or record:
- phone calls (incoming calls to our hotel)
- transactions at all points of contact
- social media and web traffic
These steps are to ensure that we carry out your instructions properly, for training purposes and to improve our services, and to guarantee security and prevent fraud. For the greater security of our guests and patrons, and to prevent and detect crime, we use CCTV (a TV system in which signals are not publicly distributed but are monitored, primarily for surveillance and security purposes) in and around our premises.
4: HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law permits us to. Most commonly, we will use your personal data in the following circumstances (each a "Legal Ground"):
- Consent: Where you willing give us your explicit consent to do so.
- 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 obligation: Where we need to comply with a legal or regulatory obligation.
- 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 in the process of entering with you.
- Vital interests: In the case of any accident emergency, to protect your or another individual's interests, where you or they are not able to give consent.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We collect and process your personal data for the purpose of:
- To protect and administer our business including our website, including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data, to deliver more relevant content and advertisements on our website to you and understand or measure the effect of the advertising we offer to you, and to make 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.
- Making 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 or complaints arising out of 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, or participate in competition
- To better our service to you
Legal grounds: Legitimate interest (to monitor and improve our services, to prevent crime and fraud, to keep our documents up to date)
- To use data analytics to improve our website, services, marketing, customer relationships and experiences
- To deal with an accident or medical or other 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 make automated decisions by processing your personal data.
We may use your contact information (mail address, fax number, email address or phone number) according to our legitimate interests, to inform you in accordance with any preferences you have expressed, about our products, services, offers via email, online advertising, social media, WhatsApp, telephone, text message (including SMS and MMS), push notifications, in-app alerts, postal mail, our customer service call center, and other means. (will not share your e-mail address with third parties for promotional purposes, except by permission.)
Where you have agreed to receive it and provided your consent, we may use your Identity, Contact, Technical, Usage 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 for 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.
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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please Contact us.
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.
- Tax and customs authorities, public registry authorities, regulators and other authorities;
- Our 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 services, as well as our other providers acting as processor on our behalf and as instructed by us;
- analytics and search engine providers that assist us in the improvement and optimization of our services and website (as processor acting on our behalf and as instructed by us);
- banks, lawyers, auditors and insurers;
- entities involved in payment processing, 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 carefully selected third-party processors to use your personal data for their own purposes and only permit them to process your personal data for specific 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 notices setting out how they deal with personal data.
6: PROTECTING PERSONAL INFORMATION
Hotel will take reasonable measures to: (i) protect personal information from unauthorized access, disclosure, alteration or destruction, and (ii) keep personal information accurate and up-to-date as appropriate. Hotel maintains a PCI compliance program and an IT compliance program. This compliance program generates audit reports concerning the adequacy and effectiveness of Hotel's IT internal controls, including a PCI Attestation of Compliance report addressing the IT general controls over systems that support certain accounting and financial reporting. In the event of a security incident, Hotel will notify regulators and/or consumers as required by applicable laws or regulations.
We also seek to require our affiliates and service providers with whom we share personal information to exercise reasonable efforts to maintain the confidentiality of personal information about you. For online transactions, we use reasonable technological measures to protect the personal information that you transmit to us via our site. Unfortunately, however, no security system or system of transmitting data over the Internet can be guaranteed to be entirely secure.
For your own privacy protection, please do not send payment card numbers or any other confidential personal information to us via email.
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.
7: INTERNATIONAL TRANSFERS
Though we do not seek actively to transfer personal data outside the EEA (The European Economic Area is the area in which the Agreement on the EEA provides for the free movement of persons, goods, services and capital within the European Single Market) or countries with an a