ARBANY HOTELS SA place great importance on the fact that the data provided by its customers must be processed according to the law and in particular the European General Data Protection Regulation and that only data which is required for the smooth running of the bookings and activities of ARBANY HOTELS SA shall be collected. ARBANY HOTELS SA also does its utmost to guarantee the security of the collected data.
ARBANY HOTELS SA has drawn up the following personal data charter in order to provide you with further information in the way in which we process your personal data.
1. Identity and personal details of the data controller
The data controller for the data referred to in this charter is the company ARBANY HOTELS SA, whose registered offices are located at Rue du Marché aux Herbes 78-80, 1000 Brussels, entered in Banque Carrefour des Entreprises under number 0682.620.474. The latter shall be entered in this charter under the name of ARBANY HOTELS SA.
All requests relating to your data must be sent to the following email address: email@example.com.
2. Purposes and legal basis for processing
ARBANY HOTELS SA essentially processes the personal information required for the enforcement of the contract signed by the customer. The data could, however, be processed due to the legitimate interests of ARBANY HOTELS SA.
Moreover, the customer's consent is required when data is collected for direct marketing purposes.
The customer’s personal data shall therefore be collected for the following purposes:
For the enforcement of the contract:
- Management of room bookings:
- Management of the customer's stay (refreshments, monitoring of any uncivil behaviour, etc.);
- Invoicing and payment;
- Management of the hotel service provided.
For legitimate reasons:
- Better understanding of the customer's requirements;
- Offering products and services linked to the customer's requirements;
- Management of customer relations and loyalty;
- Establishment of statistics;
- In general, the improvement of ARBANY HOTELS SA services such as managing complaints, conducting satisfaction surveys, protecting and improving browsing activity on the ARBANY HOTELS SA Websites, protecting and preventing potential fraud, etc.).
For direct marketing purposes:
- Sending special offers and potential new services offered by ARBANY HOTELS SA.
- Sending newsletters, promotions and tourist, hotel and service offers as well as partners’ offers.
3. The personal data processed
Personal data shall be processed in a lawful, loyal, transparent manner with respect to the data subject.
Only data required for the purposes outlined above shall be collected. This data shall be collected from the point at which the customer makes a booking with ARBANY HOTELS SA or stays at one of our residences. This information may also be provided when a booking is made by a third party such as a travel agency.
The processed data consists of information which concerns you, members of your family or individuals for whom you have made a booking such as:
- Full name;
- Telephone number and email address;
- Date of birth;
- IP address:
- Information relating to a credit card or any other means of payment or guarantee;
- Departure and arrival times;
- Preferences in term of room type or other personal requirements;
- Hobbies and interests;
- Information collected for statistical purposes;
- Any comments made during or after a stay in a ARBANY HOTELS SA.
4. Recipient of personal data
The processed, collected data is intended essentially for ARBANY HOTELS SA.
ARBANY HOTELS SA may, however, share your data with third parties in order to provide you with services relating to your activities and requirements during your stay in one of our residences. ARBANY HOTELS SA may also share your data with third parties in order to improve our products and the services provided. ARBANY HOTELS SA may, therefore, share your data with a third party to enable the latter to carry out statistical studies or market research on behalf of ARBANY HOTELS SA or so that you can receive offers, promotions or newsletters from third parties on behalf of ARBANY HOTELS SA.
Contracts shall be signed with said third parties so that the obligations concerning your personal data are also respected both during and after the entrusted assignment.
ARBANY HOTELS SA may also be required to share the personal data in its possession with the authorities if this is required by law or if it is essential for the prevention, detection or tracking of criminal acts or fraud.
5. Transferral of personal data to a third country
ARBANY HOTELS SA does not currently transfer any personal data to countries outside the European Union.
Should this situation change, ARBANY HOTELS SA shall only transfer data to a country outside the European Union if said country offers an equivalent level of protection to that provided within the European Union for which a decision on adequacy has been reached by the European Commission in accordance with Article 45 of the GDPR or within the limits specific by this law, for example by guaranteeing the protection of data by means of suitable contractual provisions.
6. Data retention period
ARBANY HOTELS SA shall retain the collected personal data for as long as is necessary, notably with regard to the purposes outlined above, the applicable legislation (such as tax legislation) and in order to defend ARBANY HOTELS SA in the context of any disputes which may arise.
7. Protection and confidentiality of data
ARBANY HOTELS SA shall do its utmost to ensure that the collected data is treated with a suitably high level of protection. Technical, physical and organisational security measures shall be established in order to prevent all unauthorised access, abusive use, disclosure or loss of information. Restrictions shall also be introduced to ensure that the use and accessing of your personal data on our servers are limited. Moreover, only authorised staff shall be permitted to access your personal data within the framework of their activities. Although the collection, transmission and storage of data can never be totally guaranteed, ARBANY HOTELS SA shall ensure that suitable precautions are taken in order to protect the latter.
8. Rights of the data subjects
Customers may access their personal data collected by ARBANY HOTELS SA at any time and ask for it to be corrected or deleted. Customers may also request that ARBANY HOTELS SA limits the processing of their data and may assert their right to opposition. ARBANY HOTELS SA shall only be permitted to process this data within the limits provided for by law.
If a customer requests the deletion of their data and, due to security requirements imposed by the authorities, ARBANY HOTELS SA is not able to delete all the customer's data, it shall retain the customer's full name and address for a period of three years following their last stay on a ARBANY HOTELS SA establishment.
If personal data has been collected on the basis of the consent of the data subject, the latter may withdraw their consent at any time. This withdrawal of consent shall only apply to the future, which means that it cannot infringe upon the legality of processing based on previous consent.
The data subject shall send all requests in writing to the following email address: firstname.lastname@example.org.
In the interests of the confidentiality and protection of your data, the individual making a request shall enclose a copy of an official identity document such as their identity card of passport.
These requests shall be processed as soon as possible in line with the applicable regulations in force governing the protection of data.
9. Right to present claims to the data protection authority
Any individual who considers that their personal data may have been violated by ARBANY HOTELS SA may present a claim to the data protection authority which monitors the respect of the privacy of citizens and the protection of their personal data.
10. Consequences in the event of failure to provide personal data
Due to the fact that most of the personal data collected by ARBANY HOTELS SA is necessary for the enforcement of the contract with individuals staying in one of our residences, no contract shall be concluded with ARBANY HOTELS SA and no bookings or stays shall be confirmed in any of our residences in the event of a refusal to provide the personal data requested.
If personal data is collected for direct marketing purposes, the data subject may at any time refuse to provide the data requested or withdraw any consent previously provided.
11. Children on the Website
The ARBANY HOTELS SA Website is not intended for children under the age of 16 and ARBANY HOTELS SA shall not request or collect any personal data concerning the latter. If ARBANY HOTELS SA discovers that personal data relating to children under the age of 16 has been collected without the consent or authorisation of a parent or guardian, ARBANY HOTELS SA shall take all the necessary steps in order to delete said data.
12. Enforcement date and subsequent amendments
This charter relating to the use of personal data shall come into force as of May 2018.
ARBANY HOTELS SA nevertheless reserves the right to amend it for future use in accordance with legal developments of for the purposes of its activities.