LAST UPDATED: 1 APRIL 2018
The Z Hotels Group values you as our guest and recognises that privacy is important to you. We want you to be familiar with how we collect, use and disclose information.
This Privacy Statement describes the privacy practices of The Z Hotel Group:
- in connection with information that we collect through websites operated by us from which you are accessing this Privacy Statement;
- 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 (collectively, our “Social Media Pages”);
- through HTML-formatted email messages that we send to you that link to this Privacy Statement; and
- through your communications with us and when you stay as a guest at one of our hotels or other properties (collectively, including the Websites, the Apps and our Social Media Pages, the “Online Services,” and together with offline channels, the “Services”).
By providing Personal and Other Information to us, you agree to the terms and conditions of this Privacy Statement.
“Personal Information” is information that identifies you as an individual or relates to an identifiable individual. We may collect Personal Information such as:
- Name, gender, home and work address, telephone number and email address, your business title, date and place of birth, nationality, passport, visa or other government-issued identification information;
- Guest stay information, including the hotels where you have stayed, date of arrival and departure, goods and services purchased, special requests made, information and observations about your service preferences (including room type, facilities, holiday preferences, amenities requested, ages of children or any other aspects of the Services used);
- Telephone numbers dialled, faxes sent/received or receipt of telephone messages when connected to the telephone services we may provide guests during their stay;
- Credit and debit card number;
- Employer or other relevant details if you are an employee of a corporate account, a vendor or other type of business partner (e.g., travel agent or meeting and event planner);
- Additional contact information about you that we may obtain through third parties with whom we do business (e.g. travel agents or similar providers);
- Profile picture;
- Social media account ID or user ID.
If you submit any Personal Information relating to other people to us or to our service providers in connection with the Services (e.g., if you make a reservation for another individual), you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Statement.
We and our service providers may collect Personal Information in a variety of ways, including:
- Through Our Online Services: We may collect Personal Information when you make a reservation or otherwise purchase goods and services from us, communicate with us via online chat services, inform us of any special requests or preferences you may have, or sign up for a newsletter or participate in a survey, contest, or promotional offer.
- Through Our Offline Services: We may collect Personal Information from you offline, such as when you visit one of our hotels or make a reservation in person.
- From Other Sources: We may receive your Personal Information from other sources, such as public databases, joint marketing partners, and other third parties. This may include information from your travel agent, airline, credit card, and other partners, and from social media platforms (including from people with whom you are friends or otherwise connected). For example, if you elect to login to, connect with or link to, the Online Services using your social media account, certain Personal Information from your social media account will be shared with us, which may include Personal Information that is part of your profile or your friends’ profiles.
We may use Personal Information in a variety of ways, including:
- To provide the services you request, such as to facilitate reservations, send confirmations or pre-arrival messages, to assist you with meetings, events or celebrations, and provide you with other information about the area and the hotel at which you are scheduled to stay.
- To complete and fulfil your reservation and stay, for example, to process your payment, ensure that your room is available, and provide you with related customer service.
- To send you administrative information, marketing communications, promotional offers, periodic customer satisfaction, market research or quality assurance surveys.
- To personalise your experience when you stay in one of our hotels and with respect to the Online Services by presenting products and offers tailored to you.
- For our business purposes, such as data analysis, audits, security and fraud monitoring and prevention (including through the use of closed circuit television, card keys, and other security systems), developing new products, enhancing, improving or modifying our Services, identifying usage trends, determining the effectiveness of our promotional campaigns and operating and expanding our business activities.
Your Personal Information may be disclosed in connection with the following services that we provide as a hotel company:
- Reservations: The Personal Information you provide to us for making a reservation is made available to the applicable hotel for the purpose of meeting your reservation request. After your stay we retain your Personal Information including details of your stay, preferences, room/accommodation type and amenities used.
- Within The Z Hotels Group: We may disclose your Personal Information to other companies within The Z Hotels Group for the purposes described in this Privacy Statement, such as providing you with services associated with your stay at one of our hotels and for the purpose of sending you marketing communications, consistent with your choices.
- To Service Providers: We may disclose Personal Information to our Third-Party service providers (as contracted at any point in time) who provide services such as website hosting, data analysis, Property Management System, payment processing, health and safety online monitoring, information technology and related infrastructure provision, customer service, email delivery, auditing and other services.
In addition, when you chose to post information on message boards, chat, profile pages and blogs and other services to which you are able to post information and materials (including, without limitation, our Social Media Pages such as Facebook or Instagram) any such information you post or disclose through these services will become public and may be available to other users and the general public. We urge you to be very careful when deciding to disclose any information on the Online Services.
- Corporate Reorganisation: We may disclose your Personal Information to a third party in the event of any reorganisation, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).
We may also use and disclose Personal Information as we believe to be necessary or appropriate: (a) under 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 public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.
“Other Information” is any information that does not reveal your specific identity or does not directly relate to an individual, such as:
- Browser and device information
- App usage data
- Information collected through cookies, pixel tags and other technologies
- Demographic information and other information provided by you
- Aggregated information
If we are required to treat Other Information as Personal Information under applicable law, then we may use it for the purposes for which we use and disclose Personal Information as detailed in this Statement. We and our Third-Party service providers may collect Other Information in a variety of ways, including:
- Through your browser or device: Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, 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 information to ensure that the Online Services function properly.
- Through your use of the Apps: When you download and use an App, we and our service providers may track and collect App usage data, such as the date and time the App on your device accesses our servers and what information and files have been downloaded to the App based on your device number.
- Using cookies: Cookies are pieces of information stored directly on the computer or mobile device that you are using. Cookies allow us to collect information such as browser type, time spent on the Online Services, pages visited, referring URL, language preferences, and other aggregated traffic data. We and our service providers use the information for security purposes, to facilitate navigation, to display information more effectively, to collect statistical information, to personalise your experience while using the Online Services and to recognise your computer in order to assist your use of the Online Services, such as for the online reservation process. We also gather statistical information about use of the Online Services in order to continually improve their design and functionality, understand how they are used and assist us with resolving questions regarding them.
- Using pixel tags and other similar technologies: Pixel tags (also known as web beacons and clear GIFs) may be used in connection with some Online Services to, among other things, track the actions of users of the Online Services (including email recipients), measure the success of our marketing campaigns and compile statistics about usage of the Online Services and response rates.
- Using Adobe Flash technology (including Flash Local Shared Objects (“Flash LSOs”)) and other similar technologies: We may use Flash LSOs and other technologies to, among other things, collect and store information about your use of the Online Services. If you do not want Flash LSOs stored on your computer, you can adjust the settings of your Flash player to block Flash LSO storage using the tools contained in the Website Storage Settings Panel . You can also control Flash LSOs by going to the Global Storage Settings Panel and following the instructions (which may include instructions that explain, for example, how to delete existing Flash LSOs (referred to as “information” on the Macromedia site), how to prevent Flash LSOs from being placed on your computer without your being asked, and (for Flash Player 8 and later) how to block Flash LSOs that are not being delivered by the operator of the page you are on at the time). Please note that setting the Flash Player to restrict or limit acceptance of Flash LSOs may reduce or impede the functionality of some Flash applications, including those used in connection with the Online Services. For more information, you may also wish to refer to https://helpx.adobe.com/flash-player/kb/disable-local-shared-objects-flash.html
- IP Address: Your IP address is a number that is automatically assigned to the computer that you are using by your Internet Service Provider (ISP). An IP address may be identified and logged automatically in our server log files whenever a user accesses the Online Services, along with the time of the visit and the page(s) that were visited. Collecting IP addresses is standard practice and is done automatically by many websites, applications and other services. We use IP addresses for purposes such as calculating usage levels, diagnosing server problems and administering the Online Services. We may also derive your approximate location from your IP address.
- Physical Location & Mobile Location-Based Services: We may collect the physical location of your device by, for example, using satellite, cell phone tower, WiFi signals, or other technologies. We may use your device’s physical location to provide you with personalised location-based services and content, including enabling you to find a hotel near you.
- By aggregating information: Aggregated Personal Information does not personally identify you or any other user of the Services (for example, we may aggregate Personal Information to calculate the percentage of our users who have a particular telephone area code).
We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. In some instances, we may combine Other Information with Personal Information (such as combining your name with your location). If we do, we will treat the combined information as Personal Information as long as it is combined.
- Third Party Services: This Privacy Statement does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including any third party operating any site or service to which the Services link, third party payment services, or any third-party website that is the landing page of the high-speed Internet providers at our hotels. The inclusion of a link on the Online Services does not imply endorsement of the linked site or service by us or by our affiliates. We have no control over, and are not responsible for, this third party’s collection, use and disclosure of your Personal Information.
In addition, we are not responsible for the information collection, use, disclosure or security policies or practices of other organisations, such as Facebook, Apple, Google, Microsoft, RIM 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 Information you disclose to other organisations through or in connection with the Apps or our Social Media Pages.
We seek to use reasonable organisational, technical and administrative measures to protect Personal Information within our organisation. 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 “Contacting Us” section below.
You should find it easy to access and amend the personal information that we hold on you, or request that we stop contacting you. It’s your data and we want to make sure you feel in control of it.
You can request full details of personal information we hold about you under the Data Protection Act 1998, or after 25 May 2018, The General Data Protection Regulation. Please send a description of the information you would like to see, together with proof of your identity to firstname.lastname@example.org
At any time you have the right to ask The Z Hotels Group to amend or stop how it uses your personal information including for marketing purposes. You also have the right to amend the information about you held by us. If you have any concern about the accuracy of your personal data or would like us to remove the personal information we hold about you, please contact us using the contact details below.
You also have the right to lodge a complaint with the supervisory authority, The Information Commissioner’s Office – www.ico.org.uk
If you no longer want to be included in automated marketing initiatives or profiling or receive marketing-related emails from us on a going-forward basis, you may opt-out by emailing email@example.com .
Within thirty days of receiving such a request, we will provide a list of the categories of personal information disclosed to third parties for third-party direct marketing purposes during the immediately preceding calendar year, along with the names and addresses of these third parties. This request may be made no more than once per calendar year. We reserve our right not to respond to requests submitted to addresses other than the addresses specified in this paragraph.
If you would like to access, rectify, erase, restrict processing, transfer your data to another party or object your Personal Information that you have previously provided to us, you may contact us at firstname.lastname@example.org, or
The Z Hotels Ltd
45 Monmouth Street
London WC2H 9DG, UK
In your request, please make clear what Personal Information you would like to have changed, whether you would like to have your Personal Information suppressed from our database, or other limitations you would like to put on our use of your Personal Information. For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request
Retention: We ask that you do not send us and you do not disclose, any sensitive Personal Information (e.g., social security numbers, national identification number, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Services or otherwise to us.
Please note that we may need to retain certain information 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 Information provided until after the completion of such purchase, reservation, or promotion). There may also be residual information that will remain within our databases and other records, which will not be removed. In addition, there may be certain information to which we are unable to enable you to review, for legal, security, or other reasons.
We will retain your Personal Information for the period necessary to fulfil the purposes outlined in this Privacy Statement unless a longer retention period is required or permitted by law.
The Services are not directed to individuals under the age of eighteen (18) and we request that they do not provide Personal Information through the Services.
We may change this Privacy Statement. The “LAST UPDATED” legend 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 have any questions about this Privacy Statement, please contact us at email@example.com or:
The Z Hotels Ltd
45 Monmouth Street
London WC2H 9DG, UK
Because email communications are not always secure, please do not include credit card or other sensitive information in your emails to us.