Informativa sulla privacy

1. THE COMPANY

This Cookie and Privacy Policy is issued by Constance Hospitality Management Ltd (CHML) and applies to CHML and all the distinct legal entities operated by CHML under any brand names; all the aforementioned entities being direct or indirect subsidiaries of the holding company Constance Hotels Services Ltd (CHSL)
References to the “Company”, “we”, “us” or “our” in this Policy, refer to the relevant company (a subsidiary of CHSL) that processes your personal data.
You will obtain more information about us from our websites: www.constancehotels.com, www.constancehospitality.com, www.c-resorts.com, www.constancehrg.com

2. SCOPE OF APPLICATION

This Policy covers all personal data that we collect and use in the course of our business, whether though our websites, mobile applications, booking channels, social media pages, or that you provide when subscribing, booking or using our products, services and facilities. Personal data may be collected in any form, including oral, electronic and/or written.

3. TERMS AND CONDITIONS

The Company values your privacy and processes your personal data in accordance with the data protection principles listed below:

• Lawfulness, fairness and transparency
• Purpose limitation
• Data minimization
• Accuracy Integrity and confidentiality (security)
• Accountability
• Storage limitation

By subscribing, booking or using our products, services or facilities, you confirm that you have read, understand and acknowledge that we will collect and use your personal information as described in this policy.

4. PERSONAL DATA WE COLLECT

At various touch points, we may collect information about you and/or members of your family, such as:

• • Identity and Contact information: your name, gender, contact details, address, date of birth, anniversary date, nationality, profession and passport details
  • Guest stay information: including previous stays in our hotels, dates of arrival and departure, special interests, specific requests made, observations about your service preferences (including room and vacation preferences, preferred floor, sports, special interests)
  • Special requirements and any information necessary to fulfil these requirements (e.g. allergies, dietary preferences/restrictions or health conditions requiring specific accommodation or service)
  • Payment information: including your credit card details, payment method, bank account details
  • Feedback: content you provide in guest satisfaction surveys, complaints or requests
  • Images: such as CCTV or other images captured at events in our resorts during your stay or that you share on our social media pages
  • Website and online: information captured while you access our websites, participate in sweepstakes, contests or promotional offers, or our third-party partners
  • Job application: information supplied when you apply for a job and through the use of our recruitment software
  • Third parties: contact and other relevant details of our suppliers, contractors and other business partners
• The information collected in relation to persons under 16 years of age is limited to their name, nationality, address, date of birth, which can only be supplied to us by a parent or guardian. We request that your children, aged less than 16 years, do not send us any personal data without your consent (particularly via the Internet). If such data is sent, please notify our Privacy Team via contact details stated at section 14, to arrange for this information to be deleted.
  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 or character certificate.
  However, you can also provide us with sensitive information if you consider that by providing such information we will be able to give you a better service.

5. PURPOSE OF DATA COLLECTION

We collect your personal data for the purposes of:
5.1 Meeting our obligations to our customers
5.2 Managing your booking and other services requested
5.3 Managing your stay at the hotel:

• Monitoring your use of services (telephone, bar, etc.)
• Updating your account and processing payment
• Managing access to rooms
• Handling requests, feedback and any complaints/incidents

5.4 Improving our products and services:

• Managing complaints and feedback
• Analysing results from guest satisfaction surveys to gain better understanding of guests requirements and wishes
• Predicting and anticipating future behaviours
• Adapting our products and services to better meet your requirements
• Developing statistics and commercial scores, and carrying out reporting

5.5 Managing our relationship with customers before, during and after your stay:

• Segmentation operations based on reservation history and customer travel preferences with a view to sending targeted communications
• Knowing and managing the preferences of new or repeat customers
• Sending you newsletters, promotions and informing you of special offers and any new services created by our organisation
• Managing subscription to our newsletters
• Managing data subject requests to access, modify, restrict or delete their data

5.6 Analyzing your collected data in order to determine your interests and your customer profile and to allow us to send you personalised offers
5.7 Securing and enhancing your use of our websites, especially:

• Improving navigation
• Implementing security measures

5.8 Conforming to local legislations (for example, storing of accounting documents)

6. DISCLOSURE OF PERSONAL INFORMATION

As we operate in many countries, we endeavour to provide you with the same personalised services at all locations. We disclose personal data in limited circumstances and mainly in connection with services that you request including to manage your access and amendment requests or for our business purposes.
For example, we share the required information:
6.1 Internally, with the authorised personnel, in order to manage your stay and offer you the best service
6.2 To third parties retained by the Company for the processing of data on our behalf, for example for the handling of guest satisfaction surveys, mailing of newsletters and campaigns, data analysis, statistics, or data storage
6.3 With commercial partners or third-party service providers, e.g. for booking of transfers or activities as requested by yourself
6.4 The Company does not routinely disclose personal information to other organisations unless:

• It is required by law, for example to local authorities or as part of an enquiry and in accordance with local regulations
• It is in your own interests, for example for providing medical services
• To protect the rights, property or personal safety of a customer or any member of the public, or the Company’s interests.
• As permitted by this Policy
• You give your consent

7. LINKS TO THIRD-PARTY WEBSITES

Our websites include links to a number of third-party websites. The Company assures you that it does not share any of your information with third-party websites. The inclusion of these links on our websites does not imply endorsement of these sites or services by the Company or its affiliates. When you click on one of these links, you are leaving our websites and entering other sites, over which we have no control. We, therefore, recommend that you refer to the third party’s privacy policy before you provide any personal information while visiting those websites. The Company is not responsible for the privacy practices of such websites.

8. INTERNATIONAL TRANSFERS

For the purposes set out in this policy, we may transfer your personal data internally to an affiliated company or a third-party processor in countries offering different levels of personal data protection. The Company employs appropriate measures to ensure secure transfer of your personal data to the other country. We ensure that the recipient of this data commits to safeguard and keep your data confidential by signing appropriate contractual clauses or a data processing agreement.

9. DATA SECURITY

The Company has implemented appropriate technical and organizational measures to protect your personal data against illicit or accidental destruction, alteration or loss, and from unauthorized access or disclosure.

10. OTHER INFORMATION COLLECTED

In addition to your personal data, we may collect other information that does not directly identify you, such as browser and device information, app usage data, and demographic information.

• Using cookies
  The Company uses cookies or other tracers which may be installed on your device when you access our websites: www.constancehotels.com, www.constancehospitality.com, www.constancehrg.com and www.c-resorts.com.
  
  Cookies are pieces of information stored on your computer or mobile device that allow us to collect information such as browser type, pages visited, language preferences, and other aggregated traffic data. This information does not generally identify you directly but recognizes your device in order to facilitate navigation and personalize your experience when using our online services. The overall purpose of our use of cookies is to improve the functionality of our websites and deliver the best user experience.
  
  When visiting our websites, you may “Accept Cookies” or select the type of cookies you wish to allow from the “Cookies Settings”. If, however, you do not accept cookies, you may experience some inconvenience in your use of the online services. For example, we may not be able to recognize your computer, and you may need to log in every time you visit. You also may not receive advertising or other offers from us that are relevant to your interests and needs.

• Using pixel tags and other similar technologies
  Pixel tags (also known as web beacons and clear GIFs) may be used in connection with some online services to, among other things, track the actions of users of the online services (including email recipients), measure the success of our marketing campaigns and compile statistics about usage of the online services and response rates. We also use Google Analytics, which uses cookies and similar technologies to collect and analyse information about the use of the Services and report on activities and trends. These services may collect information regarding the use of other websites, apps, and online resources. You can learn about Google’s practices by going to www.google.com/policies/privacy/partners and opt-out by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout

• IP Address:
  Your IP address is a number that is automatically assigned to the computer that you are using by your Internet Service Provider (ISP). Your IP address may be identified and logged automatically in our server log files whenever you access our online services, along with the time of the visit and the page(s) that were visited. Collecting IP addresses is standard practice and is done automatically by many websites, applications and other services. We use IP addresses for purposes such as calculating usage levels, diagnosing server problems and administering online services. We may also derive your approximate location from your IP address.
  
  
• By aggregating information
  We also aggregate personal information to generate statistical data that does not identify you or any other individual user. This helps us analyze user demographics, such as the percentage of users with a particular telephone area code.

11. DATA RETENTION

We retain your personal data only as long as necessary for the purposes set out in this Policy and in accordance with the provisions of applicable laws.

12. YOUR RIGHTS

You have the right to access the personal data that the Company holds on you. You also have the right to request rectification or erasure of the data held, or to restrict the processing of your data, subject to applicable legislations.

You may exercise these rights by sending us a written request by email or letter to the following address,
Email
Postal: Constance Hospitality Management, 40609 Centre De Flacq, Mauritius, Indian Ocean

To ensure efficient processing of your request, please provide your full name, address, and telephone number when submitting your inquiry. To ensure confidentiality and security of your data, we will also require a proof of identity (such as an ID card or passport) before taking any action on your request.
Where you make more than one request in quick succession, we may respond to your subsequent request by referring to our earlier response and only identifying any items that have changed materially. In some cases, we may also request an administrative fee to cover the cost of access.
All requests will receive a response as swiftly as possible and in accordance with applicable law.

13. UPDATES

The Company operates in a dynamic business environment. Over time, aspects of our business may change and this may require our policies to be reviewed and updated. CHML reserves the right to update this Cookie and Privacy Policy at any time without prior notice. Consequently, we recommend that you periodically review this Policy to be updated on how we collect, use and protect your personal data.