1. OBLIGATIONS OF THE WAWELBERG HOTEL MANAGEMENT IN THE PROTECTION OF PERSONAL INFORMATION
We highly value our collaboration with you and our priority is to ensure that your stay in the Wawelberg Hotel is as pleasant as possible.
It is also important to us that you have full confidence in us in every respect.
We realize that we have an obligation to meet your expectations and have therefore compiled a Policy for guaranteeing the security of the personal information of clients of the Wawelberg Hotel.
Personal information is any information that we collect and register in a format that enables us to identify you directly (your name, for instance) or indirectly (your phone number, for example).
Our Policy for guaranteeing the security of personal information sets out our obligations to you as our client, the means and purposes of using your personal information and the basic principles and rules for the protection of that information.
We recommend that you read this document before providing us with this information.
By accepting the provisions in this document, you agree with the Policy for guaranteeing the security of the personal information of clients of the Wawelberg Hotel.2. BASIC PRINCIPLES AND RULES
The basic principles and rules for guaranteeing the security of personal information at the Wawelberg Hotel are:
Transparency. When we collect and process your personal information, we advise you for what purposes it is necessary and who will have access to it.
Legality. We are obliged to collect and process your personal information only for the purposes set out in this Policy.
Actuality and Accuracy. We are obliged to collect only the information that is necessary in accordance with the provisions of Russian Federation legislation. We are obliged to take all reasonable measures to ensure that the personal information provided to us is accurate and up-to-date.
Retention. We are obliged to keep your personal information for the period necessary for its processing in accordance with Russian Federation legislation.
Access, Corrections and Objections. You can check, alter, correct or delete your personal information, particularly in order to decline to receive communications about sales and advertising promotions. Detailed information about the department to be contacted in this case is set out below in Paragraph 11 (‘Access and Alteration’).
Security. We are obliged to take reasonable technical and organizational measures to protect your personal information from alteration or accidental loss, deliberate illegal obliteration and illegal use, disclosure to and access by unauthorized persons.
Confidentiality. We may forward your personal information within the confines of the Wawelberg Hotel or to third parties (for example, business partners and/or service providers), but only for the purposes described in this Policy. In this case we are obliged to take appropriate measures to guarantee the security of your personal information.
If you have any questions relating to the seven principles for guaranteeing the security of your personal information at the Wawelberg Hotel, please contact our Department for the Protection of Personal Data, details of which can be found in Paragraph 11 (‘Access and Alterations’).3. RANGE OF USE OF THE POLICY FOR GUARANTEEING THE SECURITY OF PERSONAL INFORMATION
This Policy applies to:
Any processing of personal information at the Wawelberg Hotel.
Any reservation websites of the Wawelberg Hotel.
The Wawelberg Hotel will do everything in its power to observe the seven principles set out in this Policy.4. WHAT PERSONAL INFORMATION DO WE COLLECT?
We may request you, as a client of the Wawelberg Hotel, to provide information about yourself and/or members of your family, in particular:
Contact details (name and surname, phone number, email address)
Personal information (date of birth, citizenship)
Information about your children (names, dates of birth, ages)
Your credit card number (for transactions and reservations)
Your membership number of the ‘Wawelberg Welcome Rewards’ loyalty programme or other partnership programme (for example, an airline’s loyalty programme)
Dates of your arrival and departure
Your preferences and interests (for instance, whether you prefer a smoking or non-smoking room, your preferred floor, type of bed, preferred newspapers and magazines, sports and cultural interests)
Questions and comments that arise during or after your stay at the Wawelberg Hotel.
The information we collect concerning children under 18 is confined to their name, citizenship and date of birth – only adults may provide this information. We will be grateful if you ensure that your children do not provide us with personal information without your permission, in particular via the Internet. If you think that your child has provided us with personal information, please inform our Department for the Protection of Personal Data (see Paragraph 11 – ‘Access and Alteration’), so that it can be deleted.
We intentionally do not collect confidential information such as race and ethnicity, political persuasions, religious and philosophical views, membership of trade unions, information about state of health and sexual orientation.5. IN WHAT INSTANCES DO WE COLLECT PERSONAL INFORMATION?
We may collect personal information in a number of instances, including the following:
· Operations relating to a stay in the Wawelberg Hotel:
· Reservation of rooms
· Registration on arrival and payment
· Ordering of food and/or drink in a hotel bar or restaurant during a stay
· Enquiries, complaints and/or disputes.
· Participation in advertising promotions and events:
· Registration in loyalty programmes
· Participation in client polls (e.g. ‘Client Satisfaction’)
· Participation in competitions
· Subscription to news distribution for receiving offers or advertising promotions by post.
· Information forwarded by third parties:
· Tour operators, travel agents, GDS reservation systems, etc.
· Operations on the Internet:
· Connection to the Wawelberg Hotel website (IP address, cookies)
· Completion of online forms (online reservation, participation in polls, visits to the Wawelberg Hotel’s pages in social networks, means of entry to various networks, e.g. entry via Facebook, etc.).6. FOR WHAT PURPOSES DO WE COLLECT PERSONAL INFORMATION?
We collect personal information for the following purposes:
· To fulfil our obligations to clients of the Wawelberg Hotel.
· To manage reservation of rooms and applications for accommodation:
· To draw up and retain legal documents in accordance with accounting standards.
· To guarantee your stay at the Wawelberg Hotel:
· To monitor the use of services (restaurants, laundry, etc.)
· To guarantee access to rooms in the Wawelberg Hotel
· To draw up a list of clients whose behaviour during their stay at the Wawelberg Hotel is unseemly (aggressive and antisocial behaviour, non-fulfilment of the conditions of staying in the hotel, non-observance of the safety rules, theft, injury to the hotel’s staff and/or its guests, intentional damage to hotel property or infringements in payment for services).
· To improve the quality of our services, in particular:
· To process your personal information in creating marketing programmes for clients with the aims of pursuing marketing activity, the promotion of brands and a better understanding of your requirements and wishes.
· To improve our products and services in accordance with your requirements.
· To personalize the commercial offers and marketing circulars that we will be sending you.
· To inform you of special offers and any new services.
· To regulate our relations with clients before, during and after their stay in the hotel:
· To manage the loyalty programme.
· To provide the information necessary for compiling a database of clients.
· To conduct operations on segmentation based on a client’s history of reservations and preferences in the choice of destinations, with the aim of distributing personalized communications.
· To forecast and evaluate a client’s future behaviour.
· To compile statistics and commercial estimates and for accounting purposes.
· To understand and manage the preferences of new and regular clients.
· To distribute news, information about advertising promotions, offers of tourist, hotel and other services by partners of the Wawelberg Hotel and in order to contact clients by phone.
· To deal with requests to cancel subscriptions for news, advertising promotions, offers of tourist services and polls on service quality.
· To record a client’s use of the right to objection.
· To use special services of telephonic communication with the aim of tracking down a client staying in the Wawelberg Hotel in the event of alarms (natural calamities, terrorist attacks, etc.).
· To verify, analyse and use special means in relation to the information collected by you on reservation or during your stay in the hotel, with the aim of establishing your interests and creating your characteristics as a client of the hotel in order to send you personalized offers.
· To improve the quality of the Wawelberg Hotel’s services, in particular:
· To conduct polls and analyse questionnaires received and comments by clients.
· To deal with complaints and claims.
· To inform you of the advantages of our loyalty programme.7. CONDITIONS FOR ACCESS TO YOUR PERSONAL INFORMATION BY THIRD PARTIES
In order to guarantee you the right to access and alter your personal information (see Paragraph 11 – ‘Access and Alteration’), we may forward your personal information to recipients within this country or in other countries in accordance with the following conditions:
a. In order to provide you with the best standard of services, we may forward your personal information and grant access to it to authorized staff and partners of the Wawelberg Hotel, including:
· Service personnel.
· Staff of the IT department.
· Commercial partners and marketing services.
· Medical services (if necessary).
· Legal services (if necessary).
· Staff of the Wawelberg Hotel with right of access to certain categories of personal data.
b. We may forward your personal information to third parties (service providers and partners) in order to offer you their services and to improve the quality of service in our hotel, for example:
· Outside service providers: contractors in the IT field, international telephone centres, banks, issuers of credit cards, independent lawyers, freight forwarders and printers.
· Commercial partners: if our Department for the Protection of Personal Data has received no other enquiries from you, the Wawelberg Hotel may supplement your characteristics as a client by providing certain personal information to preferred commercial partners. In this event, trusted third parties may verify, analyse and use certain means of processing your information. This processing of information enables the Wawelberg Hotel and privileged contracted partners to determine your interests and supplement your characteristics as a client, enabling us to send you personalized offers.
· Social network websites: so that you can access a website without completing a registration form, the Wawelberg Hotel has established a system of access via Facebook. You can give the Wawelberg Hotel your clearly expressed permission to access and save generally available information in your Facebook account and other information mentioned when accessing sites via Facebook. The Wawelberg Hotel may also forward your email address to Facebook with the aim of publishing a personalized and appropriate advertisement in your account if necessary.
c. We may also provide your personal information to local authorities if required under Russian Federation legislation or where necessary for an investigation conducted in accordance with Russian or international legislation.8. SECURITY GUARANTEE
The Wawelberg Hotel takes the appropriate technical and organizational measures in accordance with the applicable legal regulations to protect your personal information from accidental loss or deliberate illegal destruction, accidental alteration or loss, as well as from unlawful disclosure to and access by unauthorized persons. We currently use technical measures such as the use of firewalls and organizational measures such as the use of systems of identifiers and passwords, physical protection, etc.
When you provide information about your credit card in making a reservation, SSL (Secure Socket Layer) enciphered technology is used to guarantee the security of the transaction.9. COOKIES
In accordance with this Policy, you may at any moment express the desire to retain our tracking tools on your device or to remove them.Why is a Policy regarding cookies necessary?
The Wawelberg Hotel has compiled this Policy with the aim of providing you with essential information and guaranteeing the transparency of our actions. From the Policy you will learn:
What information is processed when you view the hotel’s website and the purpose of its processing.
What rights you have with regard to cookies and other tools used by the hotel for tracking information.What is a cookie?
Cookies and other similar tools are small fragments of information that are used by a server for exchanging data about the condition of a user’s browser.
This data may contain information about the identifier of a session, language and the date of the expiry of validity, details from the reply field, etc.
This data is kept in cookie files when a user views the website.
There are several types of cookie:
· Session cookies (deleted immediately when you exit your browser or leave the website).
Cookies are necessary for viewing the Wawelberg Hotel website and for access to all their functions. In particular, they are used:
· To authenticate visitors to the website, to guarantee their security and the correct operation of the authenticating module.
· To optimize the website for users and to simplify working with it (in particular, by means of determining ‘technical routes’).
· To employ security measures (for example, in cases where after some time we request that you repeat your user name and password in order to obtain access to a content or service; or with the purpose of guaranteeing the standard operating processes of the Wawelberg Hotel website and enabling important functions such as the tracking of productiveness and errors, control of a user’s sessions, etc.).
Cookies used for technical functionality are designed:
· To display the Wawelberg Hotel website on your device in accordance with your preferences concerning language, currency, screen resolution, the operational system used, the configuration and settings of the website display taking into account your device, location, etc.
· To retain the information that you put on the Wawelberg Hotel website in order to simplify your subsequent visits (this includes the user’s name and surname if he or she has an account).
· To guarantee faster access to personal pages by saving your account details or previously supplied information.
Cookies for tracking visitors’ actions are created with the aim of making it simpler to use the website. With the aid of cookies we can analyse your actions on the Wawelberg Hotel website (for instance, we can obtain information about the most frequently visited pages, the apps used, etc.). In order to improve the quality of our services, we can use these cookies to compile statistics and to check various methods of displaying information.
Marketing cookies enable us (i) to provide you with up-to-date advertising content (best offers, other promotions, etc.) taking into account your interests, your way of working with the website, your preferences and other factors, and (ii) to reduce the number of advertisements.
Partnership cookies enable us to determine from which website a visitor has been redirected to the Wawelberg Hotel website.
Side cookies from social networks enable you to share your opinion about the Wawelberg Hotel website by clicking on ‘Share’ or ‘Like’.
Social network apps on the Wawelberg Hotel website may in some cases allow social networks to identify you, even if you have not clicked on them. A social network can track your transfer to the Wawelberg Hotel website if you have an active account with it on your device as part of an open session and you are on our website at that time.
We advise you to study the rules of these social networks. They will show how they use the information they collect about a visit to a website (for example, whether they use it for advertising purposes), and also how to alter the confidentiality settings of social networks, particularly your user account for each of these networks.Consent.
Certain cookies may be saved only with your permission. In addition, when a user first visits the Wawelberg Hotel website, we ask his or her permission to save specific cookies and do not save them without this permission.
The home page of the Wawelberg Hotel website features an information banner informing you that if you remain on the website you are giving your consent for certain cookies to be saved on your device.
Having given your consent, you can revoke it at any time by one of the methods set out in the section ‘Deletion and/or Blocking of Cookies’.Deletion and/or Blocking of Cookies
Cookies and other tools for tracking information can be deleted by several methods:
Via the settings of a browser:
Most browsers accept cookies by default, but you can alter their settings and select one of the following alternatives: always accept all cookies, always block cookies or accept cookies only from certain senders.
In addition, you can choose a mode in which for every new type of cookie you will be asked whether you wish to accept it. You can also periodically delete cookies from your device with the aid of your browser settings. If you wish to delete cookies from a device on which several browsers are installed; do not forget to do this for all of them.
The method of setting preferences with regard to cookies depends on the browser.
Detailed information about this is available in the following reference articles:
· For users of Internet Explorer™ : http://windows.microsoft.com/en-US/windows-vista/Block-or-allow-cookies
For users of Safari™ : http://www.apple.com/legal/privacy/en-ww/cookies
· For users of Chrome™: http://support.google.com/chrome/bin/answer.py?hl=en&amp;amp;amp;hlrm=en&amp;amp;amp...
· For users ofFirefox™: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences
· For users ofOpera™: http://help.opera.com/Windows/10.20/en/cookies.html
If you give permission for cookies to be saved, they can be placed in an assigned temporary catalogue on your device. Data from cookies is revealed only for the websites that created them.
If you so wish, you can block cookies. In this case, certain functions and pages of the Wawelberg Hotel website will be inaccessible. Responsibility for the blocking of cookies rests with you.10. DATA RETENTION
We will retain your personal information only for the period necessary for the purposes outlined in this Policy or in accordance with the applicable law. 11. ACCESS AND ALTERATION
You have the right of access to your personal information collected by the Wawelberg Hotel and the right to alter it in accordance with the applicable provisions of the law.
You may also exercise your right to object to the use of your personal information. For this purpose, you will have to submit your objection in writing to the address below.
If you encounter difficulties in exercising your rights, please contact the Wawelberg Hotel’s Department for the Protection of Personal Data directly by email to firstname.lastname@example.org
or to the address below:
191186, Russia, St. Petersburg, 7-9 Nevsky Prospekt, Letter A, Wawelberg Hotel.
In the interests of protecting your privacy and your personal information, we will have to establish your identity before replying to your enquiry. We may request that you send in addition a copy of an official document certifying your identity, e.g. passport or driving licence.
If your personal information is incorrect, not stated in full or out of date, please forward the appropriate corrections to our Department for the Protection of Personal Data at the above address.
All enquiries will be considered as promptly as possible and in accordance with the requirements of the applicable law.
You may also exercise your rights in relation to the personal data collected and processed by the Wawelberg Hotel during your stay. For this purpose, you will have to contact the Hotel direct.12. UPDATES
We may make alterations to this Policy from time to time, so we recommend that you look through them regularly, especially when reserving rooms in our hotel.13. QUESTIONS
For any questions relating to the Policy for guaranteeing the security of personal information at the Wawelberg Hotel, please contact our Department for the Protection of Personal Data (see Paragraph 11: ‘Access and Alteration’).