Last Updated: May 25, 2018

Kupeli Hotel (“Kupeli Hotel”, “we”, “us” and “our”) takes the issue of safeguarding your privacy seriously. Our Privacy Notice describes what information we collect from hotel guests, as well as visitors to the Kupeli Hotel website and mobile App, and the way in which Kupeli Hotel uses this information to better serve your needs.

This Privacy Notice has been adopted by all of the distinct legal entities that manage and operate Kupeli Hotel branded hotels, resorts and residential properties. Those entities include Kupeli Hotel Limited and its direct and indirect subsidiaries and affiliates, and all of the separate and distinct legal entities that manage Kupeli Hotel managed hotels, resorts and residential properties worldwide. References to “we”, “us”, “our” and “Kupeli Hotel” throughout this Privacy Notice, depending on the context, refer collectively to those separate and distinct legal entities.

What is Personal Information?

Personal information is any information about you as an identifiable individual. The personal information that we process includes:

• Basic information – such as name, age, gender, passport information and publicly available photograph; 
• Contact information – such as your home address, zip/postal code, email address and phone number; 
• Financial information – such as your credit card details, itemized spending and transaction history; 
• Health information where disclosed and relevant to the provision of services; 
• Preferences – such as special requests, service issues and other preferences for your stay; 
• Technical information – such as information about the device you use to interact with us (including the unique device identifier, hardware model, operating system and version, and mobile network information, in the case of our mobile App); and 
• Correspondence – when you contact us, such as to send an enquiry or make a request, any correspondence or application may be kept and added to your personal information.

How do we use your personal information?

We use your personal information for the following purposes:

• to enable you to use our website and our mobile App;
• to help us identify you and any accounts you hold with us;
• to provide superior customer service to you;
• to assist us in making your reservation and providing the services you request at any of our properties;
• to process transactions through our website (including taking payment for purchases you may make through our website) and to assist in any inquiries about your transaction;
• for billing purposes in relation to your stay with us;
• to confirm prior transactions and reconcile statements or invoices;
• to contact you in relation to matters that arise from your stay with us;
• to send you newsletters regarding our properties and to advise you of promotions or to inform you of offers or other information that may be of interest to you (if, where required, you separately provide your consent for us to do so);
• to conduct surveys or focus groups to receive your views of our properties and service delivery (if, where required, you separately provide your consent to this);
• to respond to a specific "Information Request" from you about one of our hotels, resorts or residential properties and deal with any other enquiries, correspondence, concerns or complaints you have raised;
• for you to participate in one of our on-line promotions;
• if you become a Private Residence or Residence Club owner, to create an owner profile that is stored in our property management systems;
• to analyse customer trends and insights; and
• to operate our business, including for internal purposes such as auditing, data analysis, statistical and research purposes and troubleshooting to help us improve our services.

Occasionally we will combine information from a number of Guests and Owners to better understand trends and your expectations. When this occurs, all identifiers are removed and the aggregate, anonymized information cannot be linked to any specific individual.

On what basis do we use your personal information?

We use your personal information on the following basis:

• to comply with legal and regulatory obligations, including financial reporting requirements imposed by government regulators and our auditors;
• to enter into agreements with you, and to perform our agreement to provide services to you when you stay with us;
• for legitimate business purposes – using your personal information helps us to operate and improve our business and minimise any disruption to the services that we may offer to you. It also allows us to make our communications with you more relevant and personalised to you, and to make your experience of our services more efficient and effective;
• because you have given your consent – at times we may ask for your consent to allow us to use your personal information for one or more purposes. See the Your Rights section for more information about the rights that you have if we process your information on the basis of your consent; or
• for the establishment, exercise or defence of legal claims or proceedings.

How is personal information collected?

We collect your personal information while monitoring our technology tools and services, including comment cards and email communications sent to and from Kupeli Hotel.

Otherwise, we gather information when you provide it to us, or interact with us directly, for example:

• when you create a profile or sign in to access an existing profile on our website or App;
• when you make a purchase through our website;
• when you make a reservation online, by calling one of our Worldwide Reservation Offices or by contacting a particular hotel or resort directly; and
• during your stay at a hotel, resort, Residence Club property or Private Residence, including information provided during check-in.

We also receive information about you from other sources, such as our business partners and publicly available sources. We combine information that we have about you from various sources, including the information that you have provided to us.

We may also collect information from you through the use of cookies, when you visit our website. For more information about our use of cookies, please see our Cookie Notice. Finally, we may collect your photograph from publically available sources so that we can recognize you in order to provide you with superior customer service.

How do we protect personal information?

We use a variety of security measures and technologies to help protect your personal information from unauthorised access, use, disclosure, alteration or destruction, consistent with applicable data protection and privacy laws. For example, we allow only encrypted communications from all of our web forms, including when you provide your credit card information through our website.

Each Kupeli Hotel property stores personal information in a secure location and we take steps to ensure that only designated individuals have access to this information.

What information is not secure?

We endeavor to protect the privacy of your account and other personal information that we hold in our records, but unfortunately, we cannot guarantee complete security. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information.  Also, while we endeavor to put adequate contractual protections in place, we cannot guarantee the security of any personal information in databases hosted by third parties.

It is important to note that any e-mail communication is not secure. This is a risk inherent in the use of e-mail. Please be aware of this when requesting information or sending forms to us by e-mail (for example, from the “Contact Us” section of our website). We recommend that you do not include any confidential information (i.e. credit card information) when using e-mail. For your protection, our e-mail responses to you will not include any confidential information.

Finally, to be prudent, please be sure to always close your browsers when you are done using a form or the reservation site. Although the session will terminate after a short period of inactivity, it is best to close your browsers immediately upon completion, especially when using a public computer.

What personal information may be provided to third parties?

We may share certain of your personal information with:

• agents, contractors or third party service providers of Kupeli Hotel who provide services to Kupeli Hotel to better serve your needs as a Guest or Owner; 
• analytics and search engine providers that assist Kupeli Hotel in the improvement and optimisation of the website and our mobile App; 
• our professional advisors and auditors; and 
• local or foreign regulators, governments, courts, law enforcement and national security authorities. 

You may advise the hotel if you do not want personal preferences shared.

Where a third party is engaged by Kupeli Hotel to provide services on our behalf, Kupeli Hotel ensures these parties protect your Personal Information in a manner consistent with the principles articulated in this Privacy Notice.

In the case of third party residential property developers, the particular developer's website can be consulted for the developer's policy on the collection, storage and use of your personal information.

If you have chosen to join a subscription list, please note that they are only used for internal purposes and we do not sell or rent our subscription lists to anyone.

If Kupeli Hotel suspects any unlawful activity is taking place, it may investigate and/or report its findings or suspicions to the police or other relevant law enforcement agency.

Transfers of your personal information outside your home country

Your personal information may be processed by Kupeli Hotel and its trusted third party suppliers anywhere in the world, including in countries where data privacy laws may not be equivalent to, or as protective as, the laws in your home country.

We will implement appropriate measures to ensure that your personal information remains protected and secure when it is transferred outside of your home country. These measures include data transfer agreements implementing standard data protection clauses. You can find out more about data transfer agreements here.

Your rights

Accessing your personal information

We understand that you may like to know what personal information we hold about you. We are happy to assist you with your request. To protect your personal information, however, we require that you prove your identity to us at the time your request is made.

When you make a request in person, we will require you to produce some form of photo identification such as a passport or a driver's license and you will be asked to sign a request form.

Where you make a request by other means, we request you contact us in writing via email, fax or letter including a copy of a government issued identification and signature. We require home and business addresses and phone numbers so we can check them with our files and satisfy ourselves as to your identity.

The above information is required to create an audit trail of how the request has been handled.

Kupeli Hotel reserves the right to decline access to your personal information under certain circumstances as permitted by law. If your personal information is not disclosed to you, you will be provided with the reasons for this non-disclosure.

Other rights

You may also be entitled to:

• request the correction and/or deletion of your personal information;
• request the restriction of the processing of your personal information, or object to that processing;
• opt out from processing of your personal information for direct marketing purposes;
• withdraw your consent to the processing of your personal information (where Kupeli Hotel is processing your personal information based on your consent); and
• request the receipt or transmission to another organisation, in machine-readable form, of the personal information you have provided to Kupeli Hotel.

Where you are given the option to share personal information with Kupeli Hotel, you can always choose not to do so.

If you do not wish to receive marketing information from Kupeli Hotel, you may indicate your wishes on your registration card when you stay with us or send an e-mail to: info@hotelkupeli.com . You will always have the ability to accept or decline any form of communication from Kupeli Hotel. You may unsubscribe from electronic marketing communications at any time by selecting the “unsubscribe” link included in such communications.

If you object to the processing of your personal information, or if you have provided your consent to processing and you later choose to withdraw it, we will respect that choice in accordance with our legal obligations.

This could mean that we are unable to perform the actions necessary to achieve the purposes of processing described above (see ‘How do we use your personal information?’) or that you are unable to make use of the services offered by us.

After you have chosen to withdraw your consent Kupeli Hotel may be able to continue to process your personal information to the extent required or otherwise permitted by law.

How long is my Personal Information retained?

Your personal information will be stored for the period of time required by law in the jurisdiction of any hotel holding the information. This may involve retaining information following your stay. We will delete your personal information once it is no longer required for any of the purposes described above.

We will also keep your personal information where we need to do so in connection with a legal action or an investigation involving Kupeli Hotel.

Any financial information Kupeli Hotel retains will be protected under the terms of this Privacy Notice. 

How is personal information affected by business transactions and/or transfers?

Kupeli Hotel manages properties on behalf of third party property owners. Kupeli Hotel may disclose to such a property owner certain Guest or Owner information as required to implement business transactions between the property and a particular Guest or Owner. All other personal information is considered to be proprietary to Kupeli Hotel, and is not shared with property owners. If we cease to manage a particular property, guest information required to process pending reservations and information that is historically shared with the property owner is retained by the property owner. All other personal information remains with Kupeli Hotel.

If you have any questions or concerns regarding this Privacy Notice, please contact our Chief Privacy Officer by writing to the following address:

Chief Privacy Officer
Kupeli Hotel
E-mail: info@hotelkupeli.com