WHAT PERSONAL DATA IS COLLECTED?
At various times, we will be obliged to ask you for information about you and/or members of your family, such as:
- Contact details
- Personal information (for example, date of birth, nationality)
- Information relating to your children (for example, first name, date of birth, age)
- Your credit card number (for transaction and reservation purposes)
- Your membership number for any loyalty program or another partner program
- If applicable, your booking/travel dates including future travel plans
- Your preferences and interests to assist in providing an enjoyable service
- Your questions/comments, during or following a visitation to one of our establishments.
We do not deliberately collect sensitive information, such as information concerning race, ethnicity, political opinions, religious and philosophical beliefs, union membership, or details of health or sexual orientation.
Moreover, depending on applicable local laws, other information could be considered sensitive, such as your credit card number, your leisure activities, personal activities and hobbies, and whether or not you are a smoker. We may be obliged to collect such information in order to meet your requirements or provide you with an appropriate service. In this case, depending on the laws in force in certain countries, your prior consent may be required with regard to the collection of sensitive information.
WHEN IS YOUR PERSONAL DATA COLLECTED?
Personal data may be collected on a variety of occasions, including:
- Business activities:
- Checking-in and paying
- Correspondence, communications and messages
- Eating/drinking at the hotel bar or restaurant during a stay
- Requests, complaints and/or disputes.
- Participation in marketing programs or events:
- Account, registration or loyalty information
- Participation in customer surveys (for example, a Guest Experience Survey)
- Online promotions or competitions
- Subscription to newsletters, in order to receive offers and promotions via digital formats
- Transmission of information from third parties:
- Reservation systems, tour operators, travel agencies, and others
- Internet activities:
- Connection to Leftfield Group websites (IP address, cookies, etc.)
- Online forms (online reservation, questionnaires, pages on social networks, etc.).
FOR WHAT PURPOSES?
We collect your personal data for the purposes of:
- Meeting our obligations to our customers, including: operating website facilities and functions, reservation systems, managing accounts/registrations, reviews, forums and other services such as making changes to your bookings and profile at your request.
- Conforming to local legislation through management of the creation and storage of legal documents in compliance with standards relating to bookings, payments, and other contracts
- Managing your stay at the properties (hotel, hostel, restaurant, etc)
- Monitoring your use of services (Wi-Fi, telephone, bar, pay TV etc.)
- Managing access to rooms/areas
- Internal management of lists of non-compliant customers across any Leftfield Group property
- Improving our services, especially:
- Adapting our products and services to better meet your requirements
- Processing your personal data in our customer marketing program in order to carry out marketing operations, promote brands and gain a better understanding of your requirements and wishes
- Customising commercial offers and the promotional messages
- Informing you of special offers and any new services created by the Leftfield Group or one of its related group Companies
- Carrying out surveys and analyses of questionnaires and customer comments
- Managing claims/complaints
- Offering you the benefits of our loyalty programs.
- Managing our relationship with customers
- Managing our loyalty programs
- Providing details for the customer database
- Segmentation operations based on history and customer preferences with a view to sending targeted communications
- Developing statistics and reports to predict and anticipate future behaviours and needs
- Managing the preferences of new or repeat customers
- Managing requests to unsubscribe from any marketing/advertising
- Securing and enhancing your use of Leftfield Group websites, especially:
- Improving navigation
- Implementing security and fraud prevention.
DISCLOSURE OF YOUR PERSONAL DATA
As we utilise the services of reservation systems and agencies, your data is shared with internal and external recipients subject to the following conditions:
Within the Leftfield Group, in order to offer you the best service, we can share your personal data and give access to authorised personnel, including:
- Property management
- Reservation staff using reservation tools
- IT departments
- Commercial partners and marketing services
- Medical or emergency services if applicable
- Legal services if applicable
- Generally, any appropriate person within the Leftfield Group entities for certain specific categories of personal data.
With third-party service providers and partners: your personal data may be sent to a third party for the purposes of supplying you with services and improving your stay, for example:
- External service providers to carry out a service/reservation request
- Commercial partners: the Leftfield Group may, unless you specify otherwise to the Data Privacy department, enhance your profile by sharing certain personal information with its preferred commercial partners. In this case, a trusted third party may cross- check, analyse and apply certain devices to your data. This data processing will allow the Leftfield Group and its privileged contractual partners to determine your interests and your customer profile, and will allow us to send you personalised offers.
- Social networking sites in order to target personalised and relevant ads or offers to you where appropriate.
- Local authorities: We may also be obliged to send your information to local authorities if this is required by law or as part of an inquiry and in accordance with local regulations.
HOW LONG DO WE RETAIN YOUR DATA
Personal data is only retained for as long as it is necessary for the identified purposes, to the extent necessary for purposes reasonably related to those identified purposes (for example, resolving disputes) or as required by law.
If you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognise and approve any follow-up comments automatically instead of holding them in a moderation queue.
For users that register on our website (if any), we also store the personal data they provide in their user profile. Website administrators can also see and edit that personal data.
STORAGE OF YOUR PERSONAL DATA
The personal information we collect from you online or in person is stored by us and/or our service providers on databases protected through a combination of physical and electronic access controls, firewall technology and other reasonable security measures.
Your security measures
For your own privacy protection, we encourage you to maintain anti-virus and other malware protection software on your computers and other devices, and to maintain your own measures to protect your personal information. Please do not include sensitive personal information in any e-mails you may send to us, including payment card information.
We also encourage you to be careful about who you give personal information to. We never contact you to ask you for sensitive personal information, such as payment card information, or sensitive personal information such as passport numbers or log-in details, and we will only ask you for such information in person or through our website, or by telephone in connection with a booking you are making or have made. Please let us know if you someone purports to contact you in our name.
You are advised that we utilise cookies and other analytics programs collect information about your visits to, browsing of, and use of our websites and social networks, unless your web browser blocks this. The range of data we collect will depend on how you interact with our website.
By visiting and using our websites you or your computer may provide personal information. This includes: information which is automatically provided by your browser to our servers; information record on our web servers about your interaction with our website and pages viewed; information we capture or place on your computer or generate using cookies or other technologies on our website; and information you input into forms and fields on our website.
This information may include: your IP address (a unique identifier allocated to your computer for your connection to the internet); your computer device details (PC, tablet, smartphone, watch etc.); the make and version of web browser (Such as, yet not limited to, Internet Explorer, Firefox, Safari, Opera, Chrome) you are using; your operating system (Such as, yet not limited to, Windows, Windows Phone, OSX, iOS, Android, Linux etc); your time-zone; your browser plug-ins; any web-page you came from, identified as the referrer web page address by your web browser; cookies; page response times; download error; pages and parts of pages you visit; usage you make of our website, including enquiries and searches undertaken, and registrations for accounts, forums etc.; services and products you viewed; length of visit to website and pages; page interaction information (such as scrolling, keys pressed, mouse clicks, touches, and mouse-overs). This will normally be collected and used anonymously to optimise user experience, implement security measures, and improve user experiences.
Cookies are employed to optimise your experience when using our website, including but not limited to:
- Authentication of website visitors and the associated security measures, and to ensure proper functioning of the authentication module
- Optimisation of the user experience and to facilitate browsing, in particular determining “technical routes” for browsing
- Providing statistical data to improve the comfort of users by helping us understand interactions with our websites (most visited pages, applications used, site usability, etc.);
- Implementation of security measures
- Adapting Leftfield Group websites to the display preferences of your device (language, currency, display resolution, operating system used, configuration and settings of the display of web pages based on the device you are using and its location, etc.)
- Third party cookies allowing internal and external referrals, including social network applications. In some cases the social networks may identify you even if you did not click on the application button. We recommend that you read the policies of these social networks to familiarise yourself with how they use the browsing information they may collect, especially with regard to advertising.
CONSENT OF COOKIE USE
Although most browsers are set by default to accept cookies, you can, if you desire, choose to accept all cookies, always block cookies, or choose which cookies to accept based on their senders.
You can also set your browser to accept or block cookies on a case-by-case basis before they are installed. Your browser also allows you to regularly delete cookies from your device. Remember to configure all the browsers in your different devices (tablets, smartphones, computers, etc.).
Regarding management of cookies and your preferences, configuration varies for each browser. This may be described in the Help menu of your browser, as well as how to edit your preferences with regards to cookies.
Saving a cookie to your device depends on your wishes, which you can exercise and change at any time and free of charge using the settings offered by your browser software.
If your browser is set to accept cookies on your device, the cookies embedded in the pages and content that you view may be temporarily stored in a dedicated space on your device. They can only be read by their issuer.
However, you can set your browser to block cookies. Keep in mind that if you set your browser to block cookies, some features, pages and spaces on our websites will not be accessible, and we cannot be held responsible in this case.
THIRD PARTY LINKED SITES
Occasionally, at our discretion, we may include or offer third party products or services on our website. These third party sites have separate and independent privacy policies. We therefore have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our site and welcome any feedback about these sites.
EMBEDDED CONTENT FROM OTHER WEBSITES
Articles on this website may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.
ACCESS AND MODIFICATION
You have the right to access your personal data collected by the Leftfield Group and to modify it subject to applicable legal provisions. You may also exercise your right to object by writing to the address below. In the event of difficulty exercising your rights, please contact the Data Privacy officer directly by sending an email to firstname.lastname@example.org or by writing to the address below:
Leftfield Group ATTN: PRIVACY OFFICER
Level 8, 333 George St, Sydney
NSW Australia 2000
For the purposes of confidentiality and personal data protection, we will need to identify you in order to respond to your request. You will be asked to include a copy of an official piece of identification, such as a driver’s license or passport, along with your request.
If your personal data is inaccurate, incomplete or not up to date, please send the appropriate amendments to the Data Privacy officer as indicated above.
All requests will receive a response as swiftly as possible and in accordance with applicable law.
We may modify this Policy from time to time without notice. Consequently, we recommend that you consult it regularly, particularly when using any of our services.
The last update to this policy was on 21/05/2019.
QUESTIONS AND CONTACTS
For any questions concerning the Leftfield Group’s personal data protection policy, please contact the Data Privacy officer as listed in “Access and Modification”.
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