The Key Collections Group Privacy Policy

Last Revised on Febuary 6th 2019 

Outlook Of This Policy 

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, The Key Collections Group 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.

We are committed to protecting the privacy of our users and customers.

Roomyield Hospitality Limited & Roomyield Hospitality UK Limited T/A The Key Collection is committed to protecting and respecting your privacy. We adhere to the Privacy Policy (the “Policy”) together with any disclaimers sets out the basis on which any personal data we collect from you or that you provide to us, or that is provided to us relating to you (“Data”) by any means will be processed. Please read the following carefully to understand our use of personal data. Please note that the Policy relates only to living individuals in relation to personal data relating directly to themselves, and not to persons in any other capacity.

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.

Definitions

Affiliates and Subsidiaries: Any corporation, firm, partnership or other entity which directly or indirectly controls, is controlled by, or is under common control with The Key Collections.

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, 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.

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 Process

In the context of the hotel booking process – whether this takes place online on one of our brand websites, through an online booking channel, through our call centre 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, Phone 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

Interrupted or Incomplete Online Booking Process (Abandoned Cart)

When you are booking online but for some reason are not able to finalise 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, Phone number, Title

Source of data

Directly from you through the online booking form

Ground for processing

It is in The Key Collections legitimate interest as a business to re-market an interrupted or incomplete booking process. In this context, The Key Collections business interests prevail over yours.

Recipients of data

Guest Satisfaction Surveys

We 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 (OPT OUT) in the emails sent to you

Processed data categories

Country of residence, Date of arrival and departure, Email address, first name / Last name, Nationality, 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

Service Emails Analytics

In 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 behaviour, Email opening behaviour, First name / Last name,

Source of data

From our email analytics service provider

Ground for processing

It is in The Key Collections legitimate interest as a business, to understand the email clicking behaviour of its guests in order to determine whether improvements are needed. In this context, The Key Collections business interests prevail over yours.

Recipients of data

Hotel Guests

Hotel Check-In and Check-Out

When 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; (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 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, Phone 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

Credit Limit Reports

To 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 Key Collections 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

Hotel Stay 

When you stay in one of our hotels, we endeavour 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, in order to provide you with a better service during your stay with us.

Processed data categories

Address, Date of arrival and departure, 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 The Key Collections legitimate interest as a business to organise its day-to-day hotel maintenance activities, to personalise 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), The Key Collections business interests prevail over yours.

Recipients of data

Hotel Guest Additional Servces and Facilities

In many of our hotels you can benefit from additional services and facilities, such as breakfast, 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) personalise 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

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, 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

Marketing Communications Analytics 

In 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 behaviour, Email opening behaviour, First name / Last name

Source of data

From our email analytics service provider

Ground for processing

It is in Key Collections Group 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, The Key Collections Group’s business interests prevail over yours.

Recipients of data

Should 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, stay details, phone 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

Source of data

From our email analytics service provider

Ground for processing

It is in The Key Collections 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, The Key Collections Group’s business interests prevail over yours.

Recipients of data

Analytics 

We may use any data you provide to us for analytical purposes to optimise 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 analyse 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’ behaviour on our websites; (v) bookings

Processed data categories

Hotel stay details, Address, Bookings (hotel, 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

Source of data

Ground for processing

It is in The Key Collections legitimate interest as a business to understand its guests’ preferences. In this context, The Key Collections business interests prevail over yours.

Recipients of data

Social Media and Online Reviews 

We may process your Personal Data obtained through social media platforms (i.eTripAdvisor) concerning our Key Collections brand 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 The Key Collections legitimate interest as a business to understand its guests’ preferences. In this context, The Key Collections Group’s business interests prevail over yours.

Recipients of data

Your Rights - Under EU Privacy Law

If you are in the EU, EU Privacy Law grants specific rights, summarised 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 dataprotection@thekeycollections.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 dataprotection@thekeycollections.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, or any other preferences, you can easily do so by contacting us at dataprotection@thekeycollections.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 dataprotection@thekeycollections.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 Users 

Depending 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.

Security Measures

Appropriate technical and organisational 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 dataprotection@thekeycollections.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.

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 unauthorised 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 Hapens 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 Us

Questions, comments, remarks, requests or complaints regarding this Privacy Policy are welcome and should be addressed to dataprotection@thekeycollections.com.