I. What is Personal Data?
II. When is what kind of data stored and processed for what reason?
1. Use of the Website
Whenever you navigate our Website, data about you is collected and processed. We collect the following data:
· Information related to the browser or device you use to access our website
· IP address
· Country you are browsing from
· Browsing habits, including sites visited
· Marital status, and
· Other demographics and statistical information
The data is collected through the session cookies (with regard to cookies see also below) we use on our Website. It is anonymised before we use it to build anonymous utilisation profiles, for marketing purposes and to optimise our Website and the services we provide. This data shall not be used in order to identify the visitor of this Website personally.
2. Interacting with us
Every time you interact with us (e.g. booking a room through our Website, by phone or through a third party provider, posting a comment on our blog, signing up for our newsletter) we may collect and process the Personal Data you provide to us.
a. Booking a room
When you book a room, we collect Personal Data, which includes:
· Your selected hotel
· Your selected dates
· Number of rooms in the reservation
· Number of people in the reservation (adults and children)
· Age of children
· The rate/special offer selected
· Any add-on packages selected
· Your full name
· Your address, including city and country
· Your e-mail address, and
· Your credit card details
· Frequent Flyer Information
· Arrival Information
· Room, Bed type and/or other preferences
· Option to join the DISCOVERY loyalty programme
We use this Personal Data to handle your reservation and to establish and fulfil our contract with you. This includes verifying your identity, taking guarantee and/or payment information, and sending stay-related and/or marketing communication.
We take the protection of your Personal Data very seriously and therefore have kept the mandatory required fields to a minimum.
b. Newsletter and special offers
If you provide your contact information to us (e.g. when booking a service with us or when signing up for our newsletter via our Website), we may use this Personal Data to send you our newsletters and details of other special offers which may be of interest to you, based on previous interactions with us (e.g. bookings).
If you sign up for our newsletter via our Website, you are required to provide your email address only. When you sign up for the newsletter via our website, you will receive an email to reconfirm your interest in staying in touch (double opt-in). Any additional information is voluntary and will be used solely for a personalisation of the newsletter.
By providing your email address and subsequent confirmation via the double opt-in, you consent to receive our newsletter. You can revoke your consent and opt out of receiving the newsletter at any time by clicking on the unsubscribe link included in every newsletter. Moreover, you also have the possibility of unsubscribing in your personal profile under “data protection”. For any further objections, kindly address the contact stated at the end of this policy.
We also include web beacons in HTML-formatted e-mail newsletters in order to count how many newsletters (or particular articles, links, etc.) are being accessed, and on our website to count users who have visited these pages.
c. DISCOVERY membership/user account
You can create a DISCOVERY membership/user account with us, which gives you added benefits, such as updating personal information and preferences; summary of past/future stays in any NUO Hotel; member discounted rates in any NUO Hotel*; special benefits and discounts in any NUO Hotel* (varies by DISCOVERY membership level); and local experiences* which can be redeemed at any Global Hotel Alliance hotel brand. If you set up a DISCOVERY membership/user account, we ask you to provide the following Personal Information:
· Your full name and email address
· Your date of birth
· Your home address and phone number
· Your language preference for email communication
· Your email marketing preferences
We use your Personal Data to send you newsletters and special offers.
*For further information on DISCOVERY, please see point 4.
For DISCOVERY, you can deactivate your account via the discoveryloyalty.com website.
If you deactivate your account, your account will be set to inactive.
d. “Contact Us” functionality
You can get in contact with us via our Website by using the “Contact Us” functionality, or by telephone. To contact us you are required to provide the following information:
· Your full name
· Your e-mail address
· Your telephone number and
· Your enquiry
We use your information to reply to your enquiry.
3. Processing of Personal Data to personalise your stay at NUO
We may collect and process Personal Data about you, if it is relevant for your stay in a NUO hotel or if it is in your interest. We may collect and process certain additional data to personalise your stay upon your express request and consent (please below under 3.a.).
a. Your consent to our ‘Personalise your Stay’ option
You have the option to enable NUO to find out more about you to improve your unique and personal experience by opting for the “personalise your stay” option. Only if you have expressly consented to this option we are permitted to conduct further research on you, in particular on publicly available social media entries and the internet. We do not undertake any research, in particular on social media or the internet if we have not obtained your express consent for this option.
If you consent to the “personalise your stay” option we may undertake additional research and record and use the respective information to make your stay more personal. For example, we may collect information on
· your sports preferences such as in relation to golf or football to provide you, in our sole discretion, with relevant information in this regard (e.g. a golf course next to the hotel or a football match in proximity to the hotel), or
· your social media profiles to find out your favourite flowers or wine to allow us to provide you, in our sole discretion, with comforts or other conveniences tailored to you
We will not collect any information which is embarrassing to you or inappropriate under, or not compliant with, local standards, conventions and habits or which are incorrect.
You may withdraw your consent at any time for the future by contacting us under the details of the contact section XII below.
b. Personal data collection without your express consent
If you have not provided your express consent to the “personalise your stay” option, we do not undertake additional research and do not record and use respective information. In such cases, the Personal Data we collect is limited to information we have gained from you personally or by hotel personnel during your stay at the hotel and to information which is relevant for the stay at a NUO hotel (e.g. preferences to rooms, beds, food, and wine if obtained at the hotel). We do not undertake any additional research on you in this case, in particular, no research on social media or the internet.
4. Loyalty programme; NUO hotels
III. Sharing Personal Data
Your Personal Data may be shared:
· Within the NUO group and with our NUO hotels to establish and fulfil our contract with you or to the extent you consented to such sharing of data, for example. This includes verifying your identity, taking payments getting in contact and communicating with you.
· With our commercial partners in the event that you book an event or an activity organised by such commercial partners.
· With our third party service providers who process your data on our behalf. NUO’s third party service providers hosting providers, and providers of data analysis, IT services, and other similar services requested by NUO to provide the Website and other business-related services to you. Any data processing on our behalf complies with the applicable laws.
We will not transfer your personal data to third-party recipients unless you consent to such transfer of data or such transfer is permitted under applicable law.
IV. Transfer of Personal Data to a third country
Where information is transferred outside the European Economic Area, we will ensure that appropriate safeguards are implemented. If your Personal Data is transferred to a country that is not subject to an adequacy decision by the EU Commission, data is adequately protected by EU Commission approved standard contractual clauses, an appropriate Privacy Shield certification or a third party’s Binding Corporate Rules.
V. Social Media Buttons
On our Website we use the following social media plug-ins: Facebook, Twitter, Instagram, Weibo, WeChat. The plug-ins can be identified by the social media buttons marked with the logo of the provider of the respective social media networks.
We have implemented these plug-ins using the so-called 2-click solution. This means that when you navigate on our Website, Personal Data will initially not be collected by the providers of these social media plug-ins. Only if you click on one of the plug-ins will your Personal Data be transmitted: By activating the plug-in, data is automatically transmitted to the respective plug-in provider and stored by them (in the case of US providers your Personal Data will be stored in the USA). We neither have influence on the collected data and data processing operations conducted by the providers, nor are we aware of the full extent of data collection, the purposes or the retention periods.
Information on the purpose and scope of data collection and its processing by the plug-in provider can be found in the respective data protection policies of these providers, where you will also find further information on your rights and options for privacy protection.
Facebook Inc., 1601 S California Ave, Palo Alto, California 94304, USA: https://www.facebook.com/privacy/explanation
Twitter, Inc., 1355 Market St, Suite 900, San Francisco, California 94103, USA; https://twitter.com/privacy.
Instagram LLC., 1601 Willow Road, Menlo Park, CA 94025, USA:
Weibo Corporation, No.8 Sina Plaza, Courtyard 10, the West, XiBeiWang E. Road, HaiDian District, Beijing 100080, China:
Tencent International Service Pte. Ltd., 10 Anson Road, #21-07 International Plaza, Singapore 079903:
We use the following categories of cookies on our Website:
Category 1: Strictly Necessary Cookies
These cookies are essential in order to enable you to move around the Website and use its features. Without these cookies, services you have asked for such as remembering your login details or data provided for a booking cannot be provided.
Category 2: Performance Cookies
These cookies collect information on how people use our website. For example, we use Google Analytics cookies to help us understand how users arrive at our site, browse or use our site and highlight areas where we can improve areas such as navigation, booking experience and marketing campaigns. The data stored by these cookies never shows personal details from which your individual identity can be established.
Category 3: Functionality Cookies
These cookies remember choices you make such as the country you visit our Website from, language and search parameters such as number of guests, hotel, time of stay. These can then be used to provide you with an experience more appropriate to your selections and to make the visits more tailored and pleasant.
Current versions of web browsers offer enhanced user controls regarding the placement and duration of both first and third-party cookies. Search for "cookies" under your web browser's “Help” menu for more information on cookie management features available to you. You can enable or disable cookies by modifying the settings in your browser. You can also find out how to do this, and find more information on cookies at www.allaboutcookies.org. However, if you choose to disable cookies in your browser, you may be unable to complete certain activities on our websites or to correctly access certain parts of it. If you would like more information about interest-based advertising, including how to opt-out of these cookies, please visit http://youronlinechoices.eu/.
VIII. Google Analytics
Our Website uses Google Analytics, which is a web analytics service provided by the third party provider Google, Inc. (“Google”). Google Analytics is used for the purpose of evaluating your use of our Website, compiling reports on Website activity and other services relating to Website activity and internet usage. The information generated by the cookie about your use of the Website is usually transmitted to and stored by Google on servers in the United States. This transfer is covered by Google’s Privacy Shield certification and a separate data processing agreement that we have concluded with Google :
https://support.google.com/analytics/answer/6004245?hl=de&ref_topic=2919631 (information on Google Analytics and data privacy).
IX. What kind of security measures for the compliance with data protection?
We strive to maintain the appropriate standards of security and we have put in place robust technical and organisational measures for the protection of your Personal Data in accordance with the current state of the art technologies, especially to protect the data against loss, falsification or access by unauthorised third persons. For the transfer of particularly sensible Personal Data via the internet, such as for example credit card details, we exclusively use encrypted transmission routes and we comply with the Payment Card Industry Data Security Standards (PCI DSS) which is a set of policies and procedures intended to optimise the security of credit, debit and cash card transactions and protect cardholders against misuse of their personal information. However, the transmission of information via the internet is not completely secure. So, whilst we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Website. Any transmission is at your own risk. Once we have received your personal data we will use strict procedures and security features to prevent unauthorised access. Our internal processing takes place inside a VPN which is firewalled against the open internet and inside of which any kind of communication is processed in an encrypted way. As far as third parties (i.e. external companies) are rendering data processing services for us, we have committed them to the compliance with our data privacy regulations. The external service providers are supervised by our Global Data Protection Manager in terms of compliance with these regulations.
X. Your Rights
In respect of the collection and use of your personal data, you may:
· withdraw your consent at any time for example by unsubscribing from the newsletter under “data protection”,
· ask us whether we process Personal Data about you, for which purposes, the categories of Personal Data concerned, to which categories of recipients the information has been disclosed, where possible, the envisaged period for which the personal data will be stored (or, if not possible, the criteria used to determine that period),
· inquire with us about the appropriate safeguards relating to the transfer to a third party,
ask us for a copy of the Personal Data undergoing processing and ask to receive your Personal Data in a structured, commonly used and machine-readable format and to transmit those data to another controller without any hindrance from us. Via the link “My Profile”, you will be displayed all stored data relating to your person. In addition to that, you can also view your stored reservations via the link “My Bookings”. We guarantee that no unauthorised persons are able to have access either to your profile or to your reservations,
· have inaccurate data rectified,
· object against the further processing and request erasure of your Personal Data,
· request that the processing of your personal data is restricted by NUO,
· request not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.
XI. Retention and deletion of Personal Data
We will retain your personal data only for a limited period of time needed to fulfil the purposes of processing mentioned above. After that time your personal data will be erased. If we process your personal data based on your consent we will retain your personal data for a limited period of time needed to fulfil the purposes of processing it.
Where we enter into a contract with you, we will keep your information for the duration of the contractual relationship you have with us, and, to the extent permitted, after the end of that relationship for as long as necessary to perform the purposes set out in this notice. The criteria to determine the storage period are statutory and contractual requirements, the nature of our relationship with you, the nature of the data concerned and the technical requirements. Laws may require us to hold certain information for specific periods.
Where we process personal data for marketing purposes or with your consent, we process the data until you ask us to stop and for a short period after this (to allow us to implement your requests). We also keep a record of the fact that you have asked us not to send you direct marketing or to process your data so that we can respect your request in future.
In other cases, we may retain data for an appropriate period after any relationship with you ends, to protect ourselves from legal claims, or to administer our business.