RADISSON HOTEL GROUP PRIVACY POLICYLAST REVISED ON MAY 25, 2018 Scope of this policy Scope of This PolicyThis Privacy Policy describes how the Radisson Hotel Group and its Affiliates and Subsidiaries (“we” or “us”) collects, uses, consults or otherwise processes an individual’s Personal Data. This Privacy Policy applies globally, but depending on where you live some specific provisions of this Privacy Policy may not apply to you. For the purposes of EU Privacy Law, depending on the type of Personal Data processing described in this Privacy Policy, Radisson Hospitality Inc., and/or Radisson Hospitality Belgium SPRL/BVBA may be operating as a sole or joint Controller. If operating as joint Controllers, both entities jointly determine the means and purposes of the processing of your Personal Data. What this means for you is that you can exercise your rights against either of the joint Controllers by contacting either company as set out below. In some of the situations described in this Privacy Policy, the hotel where you made a booking and/or stay will also process your data as a (joint or sole) Controller. The hotel will be solely responsible for the processing activities for which it is the sole Controller. Radisson Hospitality, Inc. is a company incorporated under US laws, having its registered seat and its offices at 701 Carlson Parkway, Minnetonka, MN 55305, United States, telephone number: +1 (763) 212-5000. Radisson Hospitality Belgium SPRL/BVBA is a company incorporated under Belgian laws, registered at the Belgian Crossroads Bank for Enterprises with company number 0442.832.318, having its registered seat and its offices at Avenue du Bourget 44, B-1130 Brussels, telephone number: +32 2 702 9200. We are committed to protecting the privacy of our users and customers. This Privacy Policy is intended to inform you how we gather, define, and use Personal Data that you provide to us when using our websites and mobile applications or when relying on our hospitality services. Please take a moment to read this Privacy Policy carefully. Please note that if you plan to submit someone else’s Personal Data to us, for instance when making a booking on their behalf, you may only provide us with that person’s details with their consent and after they have been given access to information about how we will use their details, including the purposes set out in this Privacy Policy. This policy includes a description of your data protection rights, including a right to object to some of the processing activities we carry out. Please note that your rights as a data subject may vary depending upon where you live. EU Privacy Law requires us to be specific about our reasons and legal grounds for using your Personal Data. Accordingly, for the purposes of EU Privacy Law only, the information below describes the types of data we process, where we get your data from, the grounds we rely on to carry out the processing, and who we may share your data with. Except for the “Processed Data Categories” sections set out in the information below, nothing is intended to bind us in respect of our non-EU users. Country-specific provisionsPlease note that there may be local variations to this Privacy Policy in order to comply with local legislation. In particular, there may be local deviations within the European Union in which case, please talk to your hotel’s front desk manager for more information or contact us at privacyquestion@radissonhotels.com. If you have questions about an individual hotel’s practices or the information provided by it, please contact the hotel directly. DefinitionsAffiliates and Subsidiaries: Any corporation, firm, partnership or other entity which directly or indirectly controls, is controlled by, or is under common control with Radisson Hospitality Inc. and/or Radisson Hospitality SPRL/BVBA. Controller: The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data. EU Privacy Law: Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of Personal Data and on the free movement of such data (the “GDPR”), as well as any legislation and/or regulation implementing or created pursuant to the GDPR and the e-Privacy legislation, or which amends, replaces, re-enacts or consolidates any of them, and all other national applicable laws relating to the processing of Personal Data and privacy. Processor: A natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the controller. Recipient: A natural or legal person, public authority, agency or another body, to which the Personal Data are disclosed, whether a Third Party or not. Third Party: A natural or legal person, public authority, agency or body other than the data subject, controller, Processor and persons who, under the direct authority of the controller or processor, are authorized to process Personal Data. Supervisory Authority: An independent public authority which is established by a Member State pursuant to Article 51 of the GDPR. Personal Data: Any information relating to an identified or identifiable natural person (“Data Subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. Processing: Any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction. Privacy Shield: The EU-U.S. and Swiss-U.S. Privacy Shield legal framework, designed by the U.S. Department of Commerce and the European Commission and Swiss Administration to provide companies on both sides of the Atlantic with a mechanism to comply with data protection requirements when transferring Personal Data from the European Union and Switzerland to the United States in support of transatlantic commerce. Radisson Hotel Group: Radisson administrative entities, including but not limited to Radisson Hospitality, Inc. and Radisson Hospitality Belgium SPRL/BVBA, but also to the hotels operating under the Radisson Hospitality brands (including but not limited to Radisson Blu, Radisson RED, Radisson Collection, and Park Inn). Standard Contractual Clauses: Sets of standard contractual clauses for transfers as adopted by the European Commission for the international transfer of Personal Data. Personal Data Breach: A breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, Personal Data transmitted, stored or otherwise processed. Hotel Booking Process1. Hotel booking processIn the context of the hotel booking process – whether this takes place online on one of our brand websites, through an online booking channel, via a travel agent, through our call center or directly at the hotel – we process your Personal Data for the purpose of (i) enabling you to reserve a room in the hotel of your choice; (ii) verifying the availability of the hotel and to administer the booking; (iii) sending you a booking confirmation; and (iv) sending you non-commercial pre-arrival emails. You may unsubscribe from pre-arrival emails at any time by clicking on the unsubscribe link in the emails sent to you. Processed data categories Address, Date of arrival and departure, Email address, First name / Last name, First name / Last name of adult co-guest(s), Payment card type, number and expiration date, Radisson Rewards membership number, Telephone number, Title Source of data Depending on the booking mechanism used:
Ground for processing Processing is necessary to take steps to enter into and perform a contract. Recipients of data
2. Interrupted or incomplete online booking process (abandoned cart)When you are booking online but for some reason are not able to finalize the booking process, we process your Personal Data for the purpose of enabling you to easily continue the online booking process by sending you an email with a link to the online booking form, which is pre-filled on the basis of the data you had already provided in the form. Processed data categories Address, Date of arrival and departure, Email address, First name / Last name, First name / Last name of adult co-guest(s), Payment card type, number and expiration date, Radisson Rewards membership number, Telephone number, Title Source of data Directly from you through the online booking form Ground for processing It is in Radisson Hotel Group’s legitimate interest as a business to re-market an interrupted or incomplete booking process. In this context, Radisson Hotel Group’s business interests prevail over yours. Recipients of data
3. Guest satisfaction surveysWe may send you guest satisfaction surveys by email during or after your stay to enable us to measure the performance of our hotels. You may unsubscribe from our guest satisfaction survey emails at any time by clicking on the unsubscribe link in the emails sent to you. Processed data categories Country of residence, Date of arrival and departure, Email address, First name / Last name, Nationality, Radisson Rewards membership number, Stay details Source of data Depending on the booking mechanism used:
Ground for processing Processing is necessary to ensure and follow up on the good performance of the contract you have with us. Recipients of data
4. Service emails analyticsIn the context of service emails, which includes guest satisfaction survey emails and any non-commercial pre-arrival emails concerning your booking, we may process and collect your Personal Data, and notably whether you have opened and actioned a service email, for analytical purposes in order to measure the click-through rate and improve the content of our service emails. You may unsubscribe from our service emails at any time by clicking on the unsubscribe link in the service emails sent to you. The information below describes the types of data we process for this purpose, where we get your data from, the ground we rely on to carry out the processing, and who we may share your data with. Processed data categories Email address, Email clicking behavior, Email opening behavior, First name / Last name, Radisson Rewards membership number Source of data From our email analytics service provider Ground for processing It is in Radisson Hotel Group’s legitimate interest as a business to understand the email clicking behavior of its guests in order to determine whether improvements are needed. In this context, Radisson Hotel Group’s business interests prevail over yours. Recipients of data
Hotel Guests1. Hotel check-in and check-outWhen staying at the hotel of your choice, we will collect and process your Personal Data for the purposes of (i) registering your arrival and departure at the hotel; (ii) assigning you a key card to your room or allowing you to use your mobile device as a room key; (iii) obtaining a credit card guarantee or hotel deposit to ensure payment of your stay; (iv) managing (and archiving) your hotel registration card; (v) creating or updating your profile in our hotel management system; (vi) assessing your eligibility for a room upgrade and managing this if applicable; (vii) managing payment of your stay; (viii) establishing, printing or sending an invoice for your stay; and (ix) paying a commission to your travel agent (if applicable). In the event you have booked a room in one of our hotels but do not show up – without cancelling – on the date of arrival communicated, we will process your Personal Data for the purposes of (i) cancelling your stay and any other reservation you may have made; and (ii) managing, processing and settling any outstanding payment that may be due. Processed data categories Address, Bookings (hotel, restaurant, event, theatre, etc.), Date of arrival and departure, Email address, First name / Last name, First name / Last name of adult co-guest(s), Payment card type, number and expiration date, Radisson Rewards membership number, Telephone number, Title Source of data Depending on the booking mechanism used:
Ground for processing Processing is necessary to perform the contract you have with us. Recipients of data
2. Credit limit reportsTo ensure payment for all guests staying in a hotel room, each hotel guest is asked for a credit card or deposit upon arrival. In order to ensure that you do not exceed your credit limit during your stay, we produce a credit limit report multiple times a day for the purposes of verifying whether your credit limit has been exceeded. These credit limit reports may contain your Personal Data. Please note that in limited circumstances these credit limit reports may be subject to one of our internal financial audits, and may therefore be accessed by members of our internal audit department, in order to ensure that our hotels follow the Radisson Hotel Group internal guidelines and policies. Processed data categories Date of arrival and departure, First name / Last name, Payment card type, number and expiration date Source of data Depending on the booking mechanism used:
Ground for processing Processing is necessary to ensure the performance of the contract you have with us. Recipients of data
3. Hotel stayWhen you stay in one of our hotels, we endeavor to make your stay as pleasant as possible. This requires processing your Personal Data for the purposes of providing specific services during your hotel stay. These services include (i) housekeeping and maintenance; (ii) returning lost or forgotten items to you; and/or (iii) managing your and your co-guests’ preferences, such as dietary requirements and pillow preferences, in order to provide you with a better service during your stay with us. Processed data categories Address, Consumption habits, Date of arrival and departure, Dietary requirements, Email address, First name / Last name, First name / Last name of adult co-guest(s), Other preferences, Telephone number Source of data Depending on the booking mechanism used:
Ground for processing It is in Radisson Hotel Group’s legitimate interest as a business to organize its day-to-day hotel maintenance activities, to personalize the services it provides, and/or to be able to identify the owner of a lost or forgotten item. Taking into account the limited Personal Data processed and shared for such purpose(s), Radisson Hotel Group’s business interests prevail over yours. Recipients of data
4. Hotel guest additional services and facilitiesIn many of our hotels you can benefit from additional services and facilities, such as breakfast, room service, minibar, pool, restaurants and bars, spa treatments, laundry services, parking, taxi requests, free Wi-Fi, etc. In the event you make use of additional services or facilities at one of our hotels, your Personal Data may be processed to (i) manage the booking and use of such additional hotel services and/or facilities; (ii) administer any advance bookings of additional services and/or facilities to your file; (iii) personalize returning guests’ arrival to the hotel and the choice of room amenities and room features; and (iv) manage the expenses incurred for such additional services and/or facilities. Processed data categories Consumption habits, Date of arrival and departure, Dietary requirements, Email address, First name / Last name, First name / Last name of adult co-guest(s), Payment card type, number and expiration date, Radisson Rewards membership number, Title Source of data
Ground for processing Processing is necessary to take steps with a view to entering into a contract and/or to perform the contract. Recipients of data
Loyalty Programs1. Radisson RewardsRadisson Rewards is a global hotel rewards program applicable throughout the hotels of the Radisson Hotel Group that is available to guests staying in our hotels, and to professional partners irrespective of whether the professional partners stay as guests or book on behalf of others. The Radisson Rewards program is managed by Radisson Hospitality, Inc. The Radisson Rewards program provides you with a number of benefits during your stay at our hotel, and enables you to collect Radisson Rewards points during your stay in our hotels and when purchasing from our selected partners. In such context, we may process your Personal Data in order to be able to i) create your online Radisson Rewards profile, including sending you an activation link by email; ii) provide you with information on your Radisson Rewards points; iii) register your bookings and award points to your membership card; iv) inform you about your rewards once you reach a certain points level; and v) inform you about any changes to the Radisson Rewards program. Processed data categories First name / Last name, Hotel stay details, Radisson Rewards Membership number, Booking details, email address, Title, Address, Telephone number, Country of residence, Language preference Source of data Directly from you when signing up to Radisson Rewards or claiming or redeeming Radisson Rewards points Ground for processing Processing is necessary to take steps at your request with a view to perform the contract you have with us. Recipients of data
2. Other loyalty programsApart from Radisson Rewards, we also offer our guests the possibility to earn miles or points in loyalty programs of our partners, such as frequent flyer programs, car rental programs and railway programs. In such context, we may process your Personal Data in order to be able to (i) award miles or points to your membership account with one of our recognized partners following your stay at our hotel; and (ii) assess and fulfil your request to redeem your miles or points of our recognized partners’ loyalty programs at our hotel. Processed data categories First name / Last name, Hotel stay details, Membership number of loyalty program of relevant partner company Source of data Directly from you when claiming or redeeming miles or points Ground for processing Processing is necessary to take steps at your request with a view to perform the contract you have with us as well as to perform the contract you have with our recognized partner(s). Recipients of data
3. RedemptionWe provide you with the opportunity to redeem your loyalty points for items such as gift cards, partner offers or charities. When you make a redemption, we process your and, if applicable, the gift card recipient’s Personal Data for the purpose of managing and successfully completing your redemption. In cases where you purchase a gift card for another person, we will process additional Personal Data for the purpose of delivering the gift card to the recipient by email or by post. Processed data categories First name / Last name, Payment card type, number and expiration date, your Address, Telephone number, Connection logs, Email address, and IP address If you purchase a gift card for someone else and depending on the mode of delivery, we will also process the Address of the recipient, Email address of the recipient, First name / Last name of the recipient, Telephone number of the recipient Source of data Directly from you when redeeming your points at the hotel or online Ground for processing Processing is necessary for the performance of the contract you have with us. Recipients of data
Gift CardsWe provide the opportunity to purchase physical or e-gift cards that can be redeemed at our hotels to pay hotel charges, restaurants and spa treatments. 1. Purchasing a gift cardWhen you purchase a gift card at one of our hotels or online, we process your and, if applicable, the gift card recipient’s Personal Data for the purposes of managing and successfully completing your purchase of the gift card. If you are purchasing the gift card for another person, we will process additional Personal Data for the purpose of delivering the gift card to the recipient by email or by post. Processed data categories First name / Last name, Payment card type, number and expiration date If a gift card is purchased online, in addition to the above, we will process your Address, Connection logs, Email address, and IP address If you purchase the gift card for someone else and depending on the mode of delivery, we will also process the Address of the recipient, Email address of the recipient, First name / Last name of the recipient, Telephone number of the recipient Source of data Directly from you when purchasing the gift card at the hotel or online Ground for processing Processing is necessary to take steps at your request with a view to enter into and perform a contract. Recipients of data
2. Registering your gift cardAs a recipient of one of our gift cards, you may choose to register your gift card online in order to protect the remaining value on the card in case it is lost or stolen. Should you decide to register your gift card, we will process your Personal Data for the purpose of processing such registration. Processed data categories Address, Date of birth, Email address, First name / Last name, Telephone number, Title Source of data Directly from you during the online registration of the gift card Ground for processing Ad hoc consent obtained during the registration of the gift card Recipients of data
Subscription to Our Newsletters1. Newsletters and marketing communicationsIf you have explicitly consented to receive our newsletters or marketing communications, including in relation to Radisson Rewards, we may, from time to time, contact you with information about our services and latest offers and process your Personal Data for this purpose. If you no longer want to receive our newsletters or marketing communications, please let us know by sending us an email at privacyquestion@radissonhotels.com. You can also unsubscribe from our marketing emails by clicking on the unsubscribe link in the emails sent to you. For Radisson Rewards, you may also unsubscribe by updating your profile. Processed data categories Address, Date of birth, Email address, First name / Last name, Gender, Hobbies and interests, Telephone number, Hotel stay history, Country of residence Source of data Directly from you when subscribing to our newsletter or later when completing your account Ground for processing Ad hoc consent obtained during the subscription to our newsletter Recipients of data
2. Newsletters and marketing communications analyticsIn the context of our newsletters and marketing communications, we may also process and collect your Personal Data, and notably whether you have opened and interacted with one of our communications, for analytical purposes in order to measure the click-through rate and improve the content of our newsletters and marketing communications. Processed data categories Email address, Email clicking behavior, Email opening behavior, First name / Last name, Radisson Rewards membership number Source of data From our email analytics service provider Ground for processing It is in Radisson Hotel Group’s legitimate interest as a business to understand the click-through rate of its emails in order to determine whether improvements are needed. In this context, Radisson Hotel Group’s business interests prevail over yours. Recipients of data
Mobile ApplicationsIn order to assist our guests in booking, planning and enjoying their stay, we offer mobile applications for our different hotel brands including but not limited to Radisson Blu, Radisson RED, Radisson Rewards, and Park Inn. These mobile apps can be downloaded through online app stores, including the Apple App Store or the Google Play store. Depending on how you use our mobile applications, your Personal Data may be processed for the purposes of (i) enabling you to reserve a room in the hotel of your choice (see also Hotel Booking Process); (ii) processing your online check-in; (iii) managing your room service order; (iv) booking reservations at your request at a local restaurant; (v) performing special services at your request such as wake up calls, late check-out, or turn down service; (vi) enabling you to book meetings and events in our hotels; (vii) processing your online check-out and your feedback on your stay; (viii) addressing the requests you have made through the mobile app, including through the chat; and (ix) view how many loyalty points you have collected. To avoid having us receive or use your real-time location, do not opt in to location services. If you did opt in and have changed your mind, you may opt out of location services through your device settings or by deleting the application. Equally, if you would like to no longer receive push notifications via one of our mobile applications, you can revoke push notification permission for the mobile application(s) in your device’s operating system settings. The information below describes the types of data we process in the context of our mobile applications, where we get your data from, the ground we rely on to carry out the processing, and who we may share your data with. For the Radisson Rewards mobile application, please consult the dedicated section on Radisson Rewards. Processed data categories Email address, First name / Last name, Location data, Stay details, Telephone number Source of data Directly from you when downloading our application(s) or when interacting with the application(s) Ground for processing Ad hoc consent obtained during the installation of the application or in the context of your use of the application Recipients of data
iBeacon iBeacons are electronic devices that broadcast signals that can be received by mobile devices on which one of our mobile apps is installed. If you have voluntarily installed one of our apps on your device, and if you have granted permission for the app to track your location, then iBeacons installed in our hotels may send a signal to the app on your device about the precise, real-time location of the device. The app may use this information to deliver special offers and promotions to you, at a time and place when the information is most relevant. For example, if you are in one of our hotels late in the afternoon, your mobile device may receive a signal from an iBeacon that causes the app to notify you about drink or dinner specials. As a convenience to you, receipt of the iBeacons signal and delivery of the special offer or promotion may occur even if you are not currently using the app. To make our mobile apps and services operate better, we may also collect other information based on iBeacon signals, for example, the strength of the signal between the iBeacon and your device, the duration your device is near the iBeacon, or the battery level of the iBeacon itself. To avoid having us receive or use your precise, real-time location, do not opt in to location services. If you did opt in and have changed your mind, you may opt out of location services through your device settings or by deleting the app. Website FormsShould you have a particular query or feedback, including the exercise of one of your rights under the GDPR, you may contact us through the contact forms available on our website(s). In such context, we may process your Personal Data for the purposes of handling and providing an answer to your query or request or to follow up on your feedback. We also provide other forms on our websites which may assist you in requesting a particular service from us, such as the best online rate guarantee form. The information below describes the types of data we process for these purposes, where we get your data from, the ground we rely on to carry out the processing, and who we may share your data with. Processed data categories Address, Email address, First name / Last name, Radisson Rewards membership number, Stay details, Telephone number, and any other data you may decide to share with us in open comment boxes. Source of data Directly from you through the form Ground for processing Ad hoc consent obtained through the contact form Recipients of data
Meetings and Events1. Meetings and events organization and feedbackIf you wish to organize a meeting or event in one of our hotels or if you would like more information on this possibility, you can reach out to us by filling in the Request a Proposal form or dedicated contact form on our website(s), by interacting with the online meetings and events chatbot, by directly contacting the hotel of your choice or by contacting us by other means. The Personal Data collected will be processed for the purposes of fulfilling your request to organize a meeting or event. We may also send you meeting satisfaction surveys after your meeting or event to enable us to measure the performance of our hotels as meeting venues. Processed data categories Address, Date of meeting or event, Email address, First name / Last name, Profession and employment, Radisson Rewards membership number, Telephone number Source of data Directly from you through
Ground for processing Depending on whether you contract directly with us or on behalf of your company:
Recipients of data
2. Meetings and events marketing communicationsIf you have opted in to receive commercial communications in the context of the organization of a meeting or event, we will also process your data to contact you with information about our services and latest offers. Processed data categories Address, Email address, First name / Last name, Profession and employment, Telephone number Source of data Directly from you through
Ground for processing Ad hoc consent obtained through
Recipients of data
3. Meetings and events marketing communications analyticsIn the context of our marketing communications concerning meetings and events, we may also process and collect your Personal Data, and notably whether you have opened and interacted with one of our communications, for analytical purposes in order to measure the click-through rate and improve the content of our marketing communications. Processed data categories Email address, Email clicking behavior, Email opening behavior, First name / Last name, Profession and employment, Radisson Rewards membership number Source of data From our email analytics service provider Ground for processing It is in Radisson Hotel Group’s legitimate interest as a business to understand the click-through rate of its emails in order to determine whether improvements are needed. In this context, Radisson Hotel Group’s business interests prevail over yours. Recipients of data
AnalyticsWe may use any data you provide to us for analytical purposes to optimize your experience, enhance our marketing, business and operational efficiency, create segments of our customers based on their Personal Data and tailor our offers and promotions to your preferences and consumption habits. In the context of such analytics, we analyze and may combine different data we hold about our guests, including (i) responses to guest satisfaction surveys; (ii) communications guests have with us; (iii) click-through rates for our marketing communications; (iv) our guests’ behavior on our websites; (v) bookings; and (vi) any information we receive via our Radisson Rewards program. Please see also our dedicated sections on Meeting and Events Marketing Communications Analytics and Newsletter and Marketing Communications Analytics. Processed data categories Hotel stay details, Address, Bookings (hotel, restaurant, event, theatre, etc.), Date of arrival and departure, Title, First name / Last name, First name / Last name of adult co-guest(s), Email address, Telephone number, Payment card type, number and expiration date, Radisson Rewards membership number, redemption history Source of data
Ground for processing It is in Radisson Hotel Group’s legitimate interest as a business to understand its guests’ preferences and consumption habits. In this context, Radisson Hotel Group’s business interests prevail over yours. Recipients of data
Social Media and Online ReviewsWe may process your Personal Data obtained through social media platforms (including Facebook, Instagram, LinkedIn, Weibo and Twitter) or online reviews (including on TripAdvisor) concerning our Radisson Hospitality brands for the purposes of (i) addressing your questions or complaints; (ii) monitoring our online reputation; and (iii) improving our services and identifying opportunities on which we can focus. Some of our social media pages allow users to submit their own content. Please remember that any content submitted to one of our social media pages can be viewed by the public, and you should be cautious about providing certain personal information (e.g., financial information or address details) via these platforms. We are not responsible for any actions taken by other individuals if you post personal information on one of our social media platforms (e.g., Facebook or Instagram). Please also refer to the respective privacy and cookie policies of the social media platforms you are using. Processed data categories Any Personal Data you may decide to share with us or published on social media or in other online reviews about us Source of data
Ground for processing It is in Radisson Hotel Group’s legitimate interest as a business to understand its guests’ preferences and consumption habits. In this context, Radisson Hotel Group’s business interests prevail over yours. Recipients of data
Social media contestsFrom time to time, we may organize a contest on one of our social media pages. If you choose to participate in such contest, we will process your Personal Data for the purpose of organizing and managing the social media contest and picking the winner(s). Processed data categories This depends on the data fields in the contest concerned, but almost always includes the following categories of data: Address, Email address, First name / Last name, Telephone number Source of data Directly from you through our social media pages Ground for processing Processing is necessary to take steps to enter into and perform a contract as you accept the terms and conditions of the contest. Recipients of data
Your Rights – Under EU Privacy LawIf you are in the EU, EU Privacy Law grants specific rights, summarized below, which you can in principle exercise free of charge, subject to statutory exceptions. These rights may be limited, for example if fulfilling your request would reveal Personal Data about another person, or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping. To exercise any of your rights, you can file a request via email at privacyquestion@radissonhotels.com. Should you have unresolved concerns, you have the right to lodge a complaint with a Supervisory Authority where you live or where you believe a breach may have occurred. We encourage you to come to us in the first instance but, to the extent that this right applies to you, you are entitled to complain directly to the relevant Supervisory Authority. 1. Right to withdraw consent Wherever we rely on your consent, you will be able to withdraw that consent at any time you choose and at your own initiative by logging in to your account on our website (if you have one) or by contacting us at privacyquestion@radissonhotels.com. The withdrawal of your consent will not affect the lawfulness of the collection and processing of your data based on your consent up until the moment where you withdraw your consent. Please note that we may have other legal grounds for processing your data for other purposes, such as those set out in this Privacy Policy. 2. Right to access and rectify your data You have the right to access, review, and rectify your Personal Data. You may be entitled to ask us for a copy of your information, to review or correct it if you wish to rectify any information like your name, email address, passwords and/or any other preferences, you can easily do so by logging in to your account on our website (if you have one) or by contacting us at privacyquestion@radissonhotels.com. You may also request a copy of the Personal Data processed as described in this Privacy Policy. 3. Right to erasure In accordance with EU Privacy Law, you have the right to erasure of your Personal Data processed by us as described in this Privacy Policy in case it is no longer needed for the purposes for which the Personal Data was initially collected or processed or in the event you have withdrawn your consent or objected to processing as described in this Privacy Policy and no other legal ground for processing applies. Should you wish to have your Personal Data erased, please file a request via email at privacyquestion@radissonhotels.com. 4. Right to restriction of processing Under certain circumstances described in EU Privacy Law, you may ask us to restrict the processing of your Personal Data. This is for example the case when you contest the accuracy of your Personal Data. In such event, we will restrict the processing until we can verify the accuracy of your data. 5. Right to object to processing Under certain circumstances described in EU Privacy Law, you may object to the processing of your Personal Data, including where your Personal Data is processed for direct marketing purposes. 6. Right to data portability Where you have provided your data directly to us and where the processing is carried out by automated means and based on your consent or the performance of a contract between you and us, you have the right to receive the Personal Data processed about you in a structured, commonly used and machine-readable format, and to transmit this data to another service provider. Your Rights – Non-EU UsersDepending on where you are located you will have different rights in respect of your Personal Data and we will comply with the relevant requirements of applicable laws and this Privacy Policy. California Privacy Rights If you reside in California, you have the right to ask us one time each year if we have shared Personal Data with third parties for their direct marketing purposes. To make a request, please send us an email at privacyquestion@radissonhotels.com or write to us at the address listed below. Indicate in your letter that you are a California resident making a “Shine the Light” inquiry. Russian Citizens In accordance with Russian Federal Law “On Personal Data” No. 152-FZ we collect, record, systematize, accumulate, store, update (renew and modify), and extract Personal Data about Russian citizens using databases located in the territory of the Russian Federation. If you indicate that you are a Russian citizen of the Russian Federation, we will process your Personal Data in compliance with this requirement and your profile will be maintained on databases in the Russian Federation. If you do not indicate that you are a citizen of the Russian Federation, we are not able to process and maintain your Personal Data under these requirements and will not be liable for that. You are solely responsible for indicating the country of your citizenship. Information containing Personal Data of Russian citizens may be transmitted from the Russian Federation to countries that ensure an adequate level of protection for Personal Data, including member states of the European Union and other countries which Russian law recognizes as ensuring adequate to protection, and also to other countries that may not ensure adequate level of protection for Personal Data. By submitting information to us on our sites and apps, submitting forms to us, or registering on our sites, programs and apps, or making reservations, you grant us consent to process your Personal Data. Security MeasuresAppropriate technical and organizational measures are implemented in order to ensure an appropriate level of security of your Personal Data, including but not limited to encryption techniques, physical and IT system access controls, obligations of confidentiality, etc. In the event Personal Data is compromised as a result of a Personal Data Breach we will make the necessary notifications, as required under applicable laws. What Rules Apply to Children?We do not knowingly collect or solicit Personal Data from anyone under the age of 18 or knowingly allow such persons to book a room in one of our hotels. In the event we learn that we have collected Personal Data from a child under the age of 18 without verification of parental consent, steps will be taken promptly to remove that information. If you believe that we have or may have information from or about a child under 18 years of age, please contact us at privacyquestion@radissonhotels.com. How Is Your Personal Data Shared with Third Parties?We only share or disclose information as described herein, including with Third Parties. Your Personal Data will also be shared with government authorities and/or law enforcement officials if required for the purposes above, if mandated by law or if required for the legal protection of the Controller(s) legitimate interests in compliance with applicable laws. In addition, we may share your Personal Data and other information with a successor to all or part of our business, where this is in our legitimate interests in facilitating a business sale and in this context our business interests prevail over yours. For example, if parts of our business or assets are sold, we may disclose user information as part of that transaction, subject to applicable law. International Data TransfersIf you are in the European Economic Area (EEA), the data that we collect from you as described in this Privacy Policy may be transferred to and stored at a destination outside the EEA, including for the purposes of processing that data by selected Processors, in order to facilitate the Radisson Hotel Group’s business. Countries outside the EEA may not have laws which provide the same level of protection to your Personal Data as laws within the EEA. Where this is the case we will put in place appropriate safeguards to ensure that such transfers comply with EU Privacy Law, either by putting in place Standard Contractual Clauses approved by the European Commission as ensuring an adequate protection or by ensuring that the transfer is done to an organization that complies with Privacy Shield in case the transfer is made to the United States of America. In this respect, please note that Radisson Hospitality, Inc. adheres to the E.U.-U.S. and Swiss-U.S. Privacy Shield Framework. In compliance with the E.U.-U.S. and Swiss-U.S. Privacy Shield Principles, Radisson Hospitality, Inc. commits to resolve complaints about your privacy and our collection or use of your Personal Data. Radisson Hospitality, Inc. has further committed to refer unresolved privacy complaints under the E.U.-U.S. and Swiss-U.S. Privacy Shields to the American Arbitration Association, http://go.adr.org/privacyshield.html. Finally, in certain limited circumstances and as a last resort, it may be possible for individuals to invoke binding arbitration before the Privacy Shield Panel to be created by the U.S. Department of Commerce and the European Commission. Please note that if you are not a European Union or Switzerland resident, then Privacy Shield requirements regarding the handling of complaints may not apply to you and Privacy Shield enforcement mechanisms may not be available to you. In case you wish to obtain more details about our data transfer safeguards and the mechanisms in place, you may contact us at privacyquestion@radissonhotels.com. How Long Will We Keep Your Personal Data?We retain your Personal Data for as long as is required to fulfil the activities set out in this Privacy Policy, for as long as otherwise communicated to you or for as long as is permitted by applicable law. For example, we may retain your Personal Data if it is reasonably necessary to comply with any legal obligations, meet any regulatory requirements, resolve any disputes or litigation, or as otherwise needed to enforce this Privacy Policy and prevent fraud and abuse. To determine the appropriate retention period for the information we collect from you, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of the data, the purposes for which we process the Personal Data, and whether we can achieve those purposes through other means, and the applicable legal requirements. Does This Privacy Policy Apply to Third Party Websites?If you click on a link to a Third Party website, you will be taken to a website we do not control and our Privacy Policy will no longer be in effect. Your browsing and interaction on any other website is subject to the terms of use and privacy and other policies of such Third Party website. Read the privacy policies of other websites carefully. We are not responsible or liable for the information or content on such Third Party websites. What Happens If We Make Modifications to This Policy?We reserve the right to modify and update this Privacy Policy from time to time. We will bring these changes to your attention should they be indicative of a fundamental change to the processing or be relevant to the nature of the processing or be relevant to you and impact your data protection rights. How to Contact UsQuestions, comments, remarks, requests or complaints regarding this Privacy Policy are welcome and should be addressed to privacyquestion@radissonhotels.com. If you have questions about an individual hotel’s practices or the information it has, please contact the hotel directly. You can also write us at: Radisson Hospitality, Inc. |