Last updated June 15, 2018
We are a Data Controller and therefore we are responsible for, and control the processing of, your personal data in accordance with applicable law. “Personal data” has a legal definition but, in brief, it refers to information it refers to information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier.
1. Information We Collect
Our goal is to provide you with an Internet experience that delivers the information, resources and services that are most relevant to you and your needs. To achieve this goal, part of the operation of the Site includes the gathering of certain types of information.
We collect both “Personal Information” and “Anonymous Information” from our Users. "Personal Information" refers to data that can identify you, including your first and last name, e-mail address, phone number and physical address, as well as information that is linked to such information. "Anonymous information" refers to information that cannot be used to contact or identify you and is not linked to information that can be used to do so. It includes passively collected information about your device and activities on the Site, such as your hardware model, browser type and operating system, to the extent that information is not linked to your Personal Information.
We also use third party services, such as Google Analytics to collect, track and analyze online behavior data of Users. These services may help inform, optimize, target and serve ads based your visits to our Site. We do this to better understand how you use the Site, with a view to offering improvements for all Users, and to tailor our business and marketing activities accordingly. If you would like to opt out of Google Analytics, please download and install the browser plugin at http://tools.google.com/dlpage/gaoptout?hl=en. Users can also opt out of third party interest based advertising by visiting the Network Advertising Initiative’s deactivation website at www.networkadvertising.org/choices/.
2. How We Use Your Information
We may use your Personal Information for the following representative purposes:
- Fulfill reservation or information requests;
- Initiate and respond to communications (e.g., surveys, promotional offers or reservation confirmations);
- Accommodate your personal preferences;
- Fulfill requests for services or recommendations;
- Update your contact information; and
- Improve the quality of your visit to the Site.
We may use Anonymous Information to improve the Site and customize the user experience, such as by providing targeted useful features and promotions based on the type of services you seek. We may also aggregate the information collected via Cookies and similar technologies to use in statistical analysis to help us track trends, evaluate the effectiveness of our ads and analyze patterns.
We may also ask your permission to use your information to send you direct marketing messages and communications in relation to the services offered by us, our strategic marketing partners, and other trusted third parties and to perform market research (e.g. surveys) to determine how to better serve your needs, improve the effectiveness of the Site, your hotel experience, our communications, advertising campaigns, and/or promotional activities.
All of our forms and messages will provide an opt-out option to allow you to elect not to participate in our email lists and future online marketing. Please note that these lists are only used for Hotel purposes or in joint undertakings with trusted partners who operate on our behalf, including those that send confirmation letters prior to your arrival at the Hotel and those that send surveys after your departure.
We may only process your information as set out above if we have a “legal basis” (i.e. a legally permitted reason) for doing so. Our legal basis for processing your information is set out in the table below.
Use of your information
The legal basis for which is...
Fulfill reservation or information requests;
Fulfill requests for services or recommendations;
Accommodate your personal preferences; and
Initiate and respond to communications (e.g., surveys, promotional offers or reservation confirmations).
This is processing can occur for the performance of the contract between us and information is processed to enable us to provide services. Outside of this, it can also be necessary for the legitimate interests we pursue, subject to you raising an objection (as set out below), requiring us to check that our interest in the processing is not overridden by the resulting risk to your rights and freedoms.
Update your contact information.
This is necessary to comply with our legal obligations, including obligations relating to the protection of personal data.
Improve the quality of your visit to the Site.
This processing is necessary for the legitimate interests we pursue, subject to you raising an objection (as set out below), requiring us to check that our interest in the processing is not overridden by the resulting risk to your rights and freedoms.
Direct marketing messages and communications in relation to the services offered by us, our strategic marketing partners, and other trusted third parties and to perform market research
This type of processing will only occur further to us obtaining your informed consent.
3. Your consent to processing
Please note that if we need to process your information in order to operate the Site and/or provide our services, and you object or do not consent to us processing your information, the Site and/or those services may not be available to you.
4. Marketing and your choices
Where you have previously ordered products or services from us we may contact you by telephone and email and post about similar or related products, services, promotions and special offers that may be of interest to you. We will inform you (during the purchase process) if we intend to use your information for such purposes and give you the opportunity to opt-out of receiving such information from us. In addition, and if you have given permission, we may also contact you by mail, telephone and email about our other products, services, promotions and special offers that may be of interest to you. We will inform you (before collecting your data) and seek your permission if we intend to use your data for such additional marketing purposes. If you prefer not to receive any direct marketing communications from us, or you no longer wish to receive them, you can opt out at any time.
If you have given permission, we may share your personal data with carefully selected third party organisations and business partners and they may contact you directly (unless you have asked them not to do so) by mail, telephone and email about products, services, promotions and special offers that may be of interest to you. We will inform you (before collecting your data) and seek your permission if we intend to disclose your data to third parties for such purposes. If you prefer not to receive direct marketing communications from our business partners, or you no longer wish to receive them, you can opt out at any time.
You have the right at any time to ask us, or any third party, to stop processing your information for direct marketing purposes. If you wish to exercise this right, you should contact us by sending an email to firstname.lastname@example.org, or contact the relevant third party using their given contact details, giving us or them enough information to identify you and deal with your request. Alternatively you can follow the unsubscribe instructions in emails you receive from us or them.
5. How We Share and Disclose Information
In addition to using the information collected by us for the purposes described in Section 2 above, we may also share your information as described below. Please review our sharing policy closely, especially with respect to your Personal Information. Your ability to make changes to the information is shared is also described below.
a. Service Providers
b. Compliance with Laws, Law Enforcement and Safety
We may disclose information we have collected about you if required to do so by law or if we, in our sole discretion, believe that disclosure is reasonable to comply with the law, requests or orders from law enforcement, or any legal process (whether or not such disclosure is required by applicable law), or to protect or defend Hotel’s, or a third party's, rights or property.
c. Anonymous information
Aggregated Anonymous Information is the combination of your Anonymous Information with the Anonymous Information of other Users (“Aggregated Anonymous Information”). Aggregated Anonymous Information does not allow you to be identified or contacted. We may share such Aggregated Anonymous Information with third parties.
d. Business transactions
6. Secure Reservations
7. Updating Your Personal Information
You may revise your Personal Information by contacting us at email@example.com. However, please note that we may be required to maintain certain Personal Information, or to maintain certain Personal Information for a period of time, in which case we will comply with your deletion request only after we have fulfilled such requirements. When we delete any information, it will be deleted from our active database, but may remain in our archives. We may retain your information for fraud detection or similar purposes. Note that if we have already disclosed some of your Personal Information to third parties, we cannot access that Personal Information any longer and cannot compel the deletion or modification of any such information by the parties to whom we have made those disclosures.
This Site is not directed to or intended for children under 13 years of age. We do not knowingly solicit, collect or maintain information from those we actually know are under 13, and no part of our Website is targeted to attract anyone under 13. We also do not send e-mail correspondence to anyone who advises that they are under the age of 13. If we later obtain actual knowledge that a User is under 13 years of age we will take steps to remove that User’s Personal Information from our systems. If you are the parent or guardian of a child whom you believe has disclosed Personal Information to us, please contact us at firstname.lastname@example.org so that we may delete and remove such information from our system.
9. Security and Data Retention
Subject to the requirements to retain information set out above, we will keep your personal data for the purposes set out in Section 2 for as long as 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) or until you withdraw your consent to our processing (where relevant). Thereafter we will only retain your information for a further period where we have a legitimate interest to do so or are subject to a legal obligation to do so (for example, it is customary to retain records of transactions for tax purposes for up to 7 years from the date of the transaction).
10. Changes to this Policy
11. California Privacy Rights
Under California’s “Shine the Light” law, California residents have the right to request in writing from businesses with whom they have an established business relationship: (i) a list of the categories of Personal Information, such as name, address, e-mail address, and the type of services provided to that customer, that a business has disclosed to third parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third parties’ direct marketing purposes, and (ii) the names and addresses of all such third parties. To request the above information, California residents can email us at email@example.com.
12. European Privacy Rights
Anyone accessing the Site from the European Economic Area, the United Kingdom or Switzerland has the following rights:
(a) You have the right to request access to information about personal data that we may hold and/or process about you, including: whether or not we are holding and/or processing your personal data; the extent of the personal data we are holding; and the purposes and extent of the processing.
(b) You have the right to have any inaccurate information we hold about you be corrected and/or updated. If any of the Information that you have provided changes, or if you become aware of any inaccuracies in such information, please let us know in writing giving us enough information deal with the change or correction.
(c) You have the right in certain circumstances to request that we delete all personal data we hold about you (the ‘right of erasure’). Please note that this right of erasure is not available in all circumstances, for example where we need to retain the personal data for legal compliance purposes. If this is the case, we will let you know.
(d) You have the right in certain circumstances to request that we restrict the processing of your personal data, for example where the personal data is inaccurate or where you have objected to the processing.
(e) You have the right to request a copy of the personal data we hold about you and to have it provided in a structured format suitable for you to be able to transfer it to a different data controller (the ‘right to data portability’). Please note that the right to data portability is only available in some circumstances, for example where the processing is carried out by automated means. If you request the right to data portability and it is not available to you, we will let you know.
(f) You have the right in certain circumstances to object to the processing of your personal data. If so, we shall stop processing your personal data unless we can demonstrate sufficient and compelling legitimate grounds for continuing the processing which override your own interests. If, as a result of your circumstances, you do not have the right to object to such processing then we will let you know.
(g) You have the right in certain circumstances not to be subject to a decision based solely on automated processing, for example where a computer algorithm (rather than a person) makes decisions which affect your contractual rights. Please note that this right is not available in all circumstances. If you request this right and it is not available to you, we will let you know.
If you wish to exercise any of your legal rights you should put your request in writing to us (using our contact details set out below) giving us enough information to identify you and respond to your request.
You may also have the right to lodge a complaint with the data protection authority in your country should you have any concerns about the manner in which we use your information. Before doing so, however, we would encourage you to first contact us directly to allow us an opportunity to resolve any concerns you may have.
13. Contact Us
Mr. C Hospitality LLC
110 East 42nd Street
New York, NY 10017
© 2018 Mr. C Seaport. All rights reserved.