An important step in promoting trust and confidence with hotel guests in the ways we collect and use their personal information is to prepare a Privacy Statement. The purpose of a Statement is to be open and transparent and it is essential for a Privacy Statement to accurately represent the hotel practices. As a best practice, prepare a Privacy Statement for your guests and include it in your Guest Services information provided in guest rooms.
Before you prepare a Privacy Statement, refer to the guide in this series to conduct a privacy assessment. Also, consult your legal counsel concerning requirements that are specific to your local country, province or State and request legal review before you publish a Privacy Statement to your guests.
To aid you in this effort, a sample privacy statement is provided below. This sample is only an example and includes language that is typical for the hotel industry.
At Holiday Inn Golden Mile Hong Kong we are committed to protecting your privacy, and support a general policy of openness about how we collect, use and disclose your personal information.
The purpose of this Privacy Statement is to inform you about Holiday Inn Golden Mile Hong Kong’s practices relating to the collection, use and disclosure of personal information that may be provided through access to or use of our websites or hotel services and related products or that may otherwise be collected by us. By staying at our hotel and using related products and services, or by visiting our website, you consent to the collection, use and disclosure of your personal information (as defined below) in accordance with the following terms and conditions.
This Privacy Statement also explains how you can contact us if you have a question about, want to make a change to or delete any personal information that Holiday Inn Golden Mile Hong Kong may be holding about you. We strongly recommend that you take the time to read this Privacy Statement and retain it for future reference.
For the purpose of this Privacy Statement, “personal information” means information about an identifiable individual.
What Personal Information We Collect
The personal information collected may include at least some of the following:
§ Contact information (such as name, address, e-mail address and telephone number in a non-business capacity);
§ Proof of identity (such as a signature or passport number);
§ Financial and billing information (such as credit card number/expiration date and credit history); and
How We Use Your Personal Information
We use your personal information to:
§ Book and confirm your hotel reservations;
§ Provide you with personalized interactive communication;
§ Provide you with timely and reliable services;
§ Do all the things necessary to administer those services;
§ Register you as a member of Priority Club® Rewards;
§ Research, develop, manage, protect and improve those services;
§ Advise you about new products and services that may be of interest to you;
§ Develop and maintain our relationship with you and communicate with you;
§ Bill you for our products and services;
§ Collect outstanding debts;
§ Assist in the investigation of a contravention of a law; and
§ Act in respect of an emergency that threatens the life, health or security of an individual.
When We Disclose Your Personal Information
Except with your consent, we will not sell, license, trade or rent your personal information to or with others.
We may share personal information with third parties and/or business associates (including, InterContinental Hotels Group PLC and its affiliates) engaged to assist us in providing services to you or to carry out one or more of the purposes described above.
Holiday Inn Golden Mile Hong Kong reserves the right to disclose personal information to a third party if a law, regulation, search warrant, subpoena or court order legally requires or authorizes us to do so.
Holiday Inn Golden Mile Hong Kong also reserves the right to disclose and/or transfer personal information to a third party in the event of a proposed or actual purchase, sale (including a liquidation, realization, foreclosure or repossession), lease, merger, amalgamation or any other type of acquisition, disposal, transfer, conveyance or financing of all or any portion of Holiday Inn Golden Mile Hong Kong or of any of the business or assets or shares of Holiday Inn Golden Mile Hong Kong or a division thereof in order for you to continue to receive the same products and services from the third party.
Knowledge and Consent
We collect personal information about you only when you voluntarily provide it. Typically, we will seek consent for the use or disclosure of your personal information at the time of collection. In certain circumstances, consent may be sought after the information has been collected but before use (for example, when we want to use information for a purpose not previously identified).
The form of consent that we seek, including whether it is express or implied, will largely depend on the sensitivity of the personal information and the reasonable expectations of the individual in the circumstances.
You may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. If you wish to withdraw your consent at any time, please contact our [Manager on Duty] at [852 2369 3111 Ext. 1393] or [email@example.com]. We will inform you of the implications of withdrawing consent.
We will not, as a condition of the supply of a product or service, require you to consent to the collection, use or disclosure of information beyond that required to fulfill the explicitly specified and legitimate purposes for which the information is being provided.
Use or Disclosure for Marketing Purposes
If you have not opted out of receiving marketing materials, we may also use (but will not disclose) your personal information to promote and market additional goods, services and special offers from us, our affiliates and/or our business associates (including, InterContinental Hotels Group PLC and its affiliates), including by means of direct marketing. If you have provided your consent for us to do so, we may also disclose your personal information (including name, mailing address and e-mail address) to these affiliates and/or third party business associates so that they can send you promotional materials directly.
You can choose not to allow us to use or disclose your personal information for direct marketing purposes by indicating your preference by contacting us as outlined below (see “Contacting Us”).
Our customers should be aware that information and data may be automatically collected through the standard operation of our internet servers and through the use of “cookies”. The information collected in such ways is not personal information.
How We Protect Your Personal Information
We make commercially reasonable efforts to ensure that personal information collected from you is protected against loss and unauthorized access. This protection applies in relation to information stored in both electronic and hard copy form. Access to your personal information is restricted to selected employees or representatives. In addition, we employ generally accepted information security techniques, such as firewalls, access control procedures and cryptography, to protect personal information against loss and unauthorized access.
Links to Third Party Sites
Retention and Storage of Your Personal Information
We retain your personal information for as long as necessary to fulfill the purpose(s) for which it was collected and to comply with applicable laws, and your consent to such purposes(s) remains valid after termination of our relationship with you.
Changes to this Privacy Statement
We reserve the right to modify this Privacy Statement at anytime without notice. The Privacy Statement posted at any time or from time to time via this website shall be deemed to be the Privacy Statement then in effect.
Correcting or Updating Your Information
You can help us maintain the accuracy of your personal information by notifying us of any changes to this information. You may contact us in any one of the following ways to request access to or correction or update of your personal information:
E-mail: l firstname.lastname@example.org
Send Mail: l Manager on Duty, 50 Nathan Road, Tsim Sha Tsui. Kowloon, Hong Kong
Telephone: l 852 2369 3111 Ext. 1393
Fax: l 852 2369 8016
In the event that you have any questions about this Privacy Statement or if you have reason to believe that we may have failed to adhere to this Privacy Statement, you may contact us at:
Attention: Manager on Duty
Or call us at 852 2369 3111 Ext.1393
Or send an e-mail to l email@example.com