AITKEN SPENCE HOTELS GLOBAL PRIVACY STATEMENT
This Global Privacy declaration applies to AITKENSPENCE HOTELS (PVT) LTD, its subsidiaries and all of the hotels within the Aitken Spence Portfolio of Brands. At Aitken Spence, we attempt to deliver remarkable service and experience around the world. We highly value your business and the loyalty. We perceive that privacy is an important factor. This Privacy Statement describes the privacy practices of Aitken Spence (PVT) LTD for data that we collect:
By utilizing any of our services as well as by agreeing to this Statement, you comprehend and recognize that we will gather and utilize personal data as described in this Statement.
You may use this Web Site in accordance with these terms and conditions for lawful and proper purposes complying with all applicable laws, regulations and codes of practice in Sri Lanka or other jurisdictions from which you are accessing the Web Site.
In particular you agree you will not,
- Post, transmit or disseminate any information via this Web Site which is or may be harmful, obscene or otherwise illegal.
- Use this Web Site in a manner which causes or may cause infringement of the rights of another.
- Use any software, routine, procedure or device to interfere or attempt to interfere with the operation or functionality of this Web Site including but not limited to making available corrupt data, viruses via whatever means or interfere with its availability to others.
- Deface, alter or interfere with the look and feel of this Web Site or underlying software code.
Take any action that imposes an unreasonable or disproportionately large load on the Web Site or related infrastructure.
- Obtain or attempt to obtain unauthorized access by whatsoever means to any of our networks.
Where Aitken Spence Hotels believe in its absolute discretion that you are in breach of any of these terms and conditions, without prejudice to any of our rights at law or otherwise, we reserve the right to deny you access to this Web Site.
COPYRIGHT AND RESTRICTIONS ON USE
All trademarks, service marks, copyright, database rights, and other intellectual property rights in materials on this Web Site as well as the organization and layout of this Web Site together with the underlying software belong to Aitken Spence Hotels or its licensors. The trade mark, service mark and logos of Aitken Spence Hotels and its licensors must not be used, modified or adapted in any way without the prior written authorization. The material on this Web Site and the underlying software codes may not be copied, modified, altered, published, broadcast, distributed, linked to another Website, sold or transferred whole or in part without an express written permission. However, the information contained here may be downloaded, printed or copied for your personal non-commercial use.
DISCLAIMER, LIMITATION OF LIABILITY AND INDEMNITY
This Web Site has been compiled in good faith by Aitken Spence Hotels. No representation is made or warranty given, either express or implied as to the completeness or accuracy of the information that it contains, that it will be uninterrupted or error free or that any information is free of bugs, viruses, worms, trojan horses or other harmful components.
To the maximum extent permitted by law, Aitken Spence Hotels disclaims all implied warranties with regard to information, products, services and material provided through this Web Site. All such information, products, services and materials are provided “as is” and “as available” without warranty of any kind.
This Web Site may contain links to Web Sites operated by third parties. Such links are provided for your reference only and your use of these sites may be subject to terms and conditions posted on them. Aitken Spence Hotels’ inclusion of links to other Web Sites does not imply any endorsement of the material on such Web Sites and Aitken Spence Hotels accepts no liability for their contents.
By accessing this Web Site you agree that Aitken Spence Hotels will not be liable for any direct, indirect or consequential loss or damages of any nature arising from the use of this Web Site, including information and material contained in it, from your access of other material on the internet via web links from this Web Site, delay or inability to use this Web Site or the availability and utility of the products and services.
You further agree to indemnify, hold Aitken Spence Hotels harmless from and covenant not to sue Aitken Spence Hotels for any claims based on using this Web Site.
MODIFICATION OF TERMS
Aitken Spence Hotels may make improvements and/or changes in the products, services and prices described in this Web Site at any time without notice. Changes are periodically made to the Web Site. Aitken Spence Hotels may amend these terms by posting the amended terms on this Web Site. Continued use of this Web Site following such changes shall constitute your acceptance of such changes.
AGE AND RESPONSIBILITY
You represent you are of sufficient legal age to use this Web Site and you possess the legal right and ability to enter into this Agreement and use this site in accordance with all of the applicable terms and conditions and create binding legal obligations for any liability you may incur as a result of the use of this Web Site under your name or account including, without limitation, all use of your account by others including minors living with you.
Aitken Spence Hotels is using a secured Web Site for transaction of personal data communicated. We do not capture personal information without your knowledge or your permission. You will only be asked to provide personal information when you are taking advantage of this site’s interactive products and services.
Aitken Spence Hotels is free to use, reproduce, disclose and or distribute the information, ideas, know-how in your feedback to others without limitation and for any purpose whatsoever.
This Agreement constitutes the entire terms governing your access to dealings with and use of this Web Site. Separate arrangements may attach to products or services you obtain, purchase or use from the site. You can find details of these terms under those particular products or services, or from the service providers.
The laws of the Democratic Socialist Republic of Sri Lanka govern the use of this Web Site and you irrevocably submit to the non exclusive jurisdiction of the courts of Sri Lanka. Aitken Spence Hotels reserves the right to bring proceedings against you in the country of your residence.
THE PRINCIPLES OF DATA PROTECTION
The Aitken Spence Hotels takes the protection of your privacy and your personal data very seriously. We would therefore like to explain what data we collect, what we use it for and how we protect your data. These data protection principles do not apply to Websites that may be accessed by clicking on hyperlinks on main web pages.
PERSONAL DATA COLLECTION
“Personal Data” will be information that recognize you as an identifiable individual.
We gather Personal Data as per law, for example,
- Postal address
- Phone number
- Email address
- Credit and Debit card number or other payment information
- Money related data in constrained conditions
- Language preference
- Date and place of birth
- Nationality, travel permit (passport) , visa or other government issued identification information
- Critical dates, for example, birthday celebrations, anniversaries and special events
- Travel schedule.
- Earlier visitor stays, or communications, merchandise and special services acquired, and amenity requests
- Employer data
- Online networking account ID, profile photograph and other information freely accessible, or information made accessible by connecting your web-based social networking and loyalty accounts
- Surveys: We may request demographic data or other personal information in customer surveys.
In more restricted conditions, we likewise may gather:
- Information about relatives and companions, for example, names and ages of children
- Biometric information, for example, digital images
- Pictures and video and sound information through: surveillance cameras
If you submit any Personal Data about other people to us or our Service Providers (e.g., if you make a reservation for another individual), you represent that you have the authority to do so and you permit us to use the data in accordance with this Privacy Statement.
PERSONAL INFORMATION COLLECTED FROM 3RD PARTIES
We may gather data about you from 3rd parties, including data from payment card, and different partners from your web-based social networking services and from other 3rd party sources that are legitimately qualified to share your information with us. We utilize and share this data (and may attach this data to the next data we have on file for you) for the reasons described in this Statement.
USE OF PERSONAL DATA COLLECTED ABOUT YOU
We utilize Personal Data and Other Data to give you Services, to grow new contributions and to ensure protection of Aitken Spence and our guests as described below;
Service Administration: We use your personal information to administer programs in which you participate.
Meeting and Event Planning: We may use your personal information to provide you with information about meeting and event planning.
Marketing and Communications: Send you marketing communications and promotional offers, as well as periodic customer satisfaction, market research or quality assurance surveys.
Administration & Service Improvements: We may utilize your own data to enhance Aitken Spence’s administration and service and to guarantee that our site, products, and services are important to you.
We utilize personal data and other data to manage our contractual relationship with you, follow a lawful commitment and because we have a legitimate enthusiasm to do so.
SHARING OF PERSONAL DATA
To provide our valued guest with the highest level of hospitality and to provide the best service, we may share personal data with the following;
Aitken Spence Portfolio of Brands & Managed Hotels & Resorts: We may share personal information within the Aitken Spence Portfolio of Brands as well as with owners and operators of franchised hotels, owners of hotels that we manage In addition, when we cease managing a hotel that we do not own we may provide the hotel’s owner with certain information about past or future guests of that hotel.
Business Partners: We may partner with other companies to provide you with products, services, or offers based upon your experiences at our properties and may share your information with our business partners accordingly.
Service Providers: We may share gathered personal data to third-party service providers for the purposes described in this Privacy Statement. Service providers include companies that provide website hosting, data analysis, payment processing, order fulfillment, information technology and related infrastructure provision, customer service, email delivery, marketing, auditing and other services.
Linked Accounts and Promotional Activity. We partner with certain third parties that allow you to enroll in their services or participate in their promotions.
Authorized Licensees. We uncover Personal Data and Other Data to our Authorized Licensees for the reasons depicted in this Privacy Statement, for example, giving and customizing the Services and satisfying your requests.
We may share and use Personal Data when you visit and interact with Aitken Spence websites and apps, we collect other information that does not directly identify you about your use of the site. We use Other Information, as well as data received from third parties, to deliver you email, online and mobile advertisements.
What are cookies?
Cookies are small pieces of information that your browser stores on your computer’s hard disk. They simplify reservation by automatically calling up frequently used data on sites you have already visited. You can set your computer to not store any cookies on your computer. However, this may prevent you using some of the functions we offer.
Sensitive information is referred to as information that is protected against unwarranted disclosure. This could include religious beliefs, political options, ethnic origin, criminal background, social security numbers, health, biometric data etc.
We don’t usually gather sensitive data unless it is volunteered by you or unless we are required to do as such compliant with laws or controls. We may utilize certain information given by you to serve you better and meet your specific needs.
PERSONAL INFORMATION FROM CHILDREN
We don’t purposely gather personal information from individuals under 18 years old. As a parent or legal guardian, kindly don’t allow your kids to submit personal data without your authorization.
MOBILE AND LOCATION-BASED SERVICES
In the event that you permit our mobile or web applications to get to your area data on your device, our mobile applications may utilize your device’s Global Positioning System (GPS) and other technology innovations such as remote transmitters known as signals to grant you with data and offers which is exclusive for your location. Beacons enable us to gather data about your location inside partaking hotels by communicating to devices that are in range. We may utilize this area data to improve your on-property encounter by conveying pop-up messages and other substance to your devices, giving route help as you move around our areas, and sending you data and offers about products and services, or activities we accept might hold any importance with you. We may impart this data to outsiders, including business accomplices and specialist co-ops, to give data, offers, and services that might hold any importance with you. You may forestall or restrain accumulation of area data by changing the settings in the Aitken Spence applications, or by changing your device’s settings.
We offer these versatile and area based administrations just to the degree allowed by pertinent local laws.
RETENTION OF PERSONAL INFORMATION
We hold personal information about you for the period necessary to fulfill the purposes outlined in this Privacy Statement unless a longer retention period is required or permitted by law. We usually hold personal information gathered for a period of 50 months We hold other personal data for shorter timeframes if possible and if allowed by law.
In an event that personal data is printed on paper, the personal data will be destroyed in a safe way, by cross-shredding or incinerating the paper documents, if saved in electronic form, the personal data will be decimated by specialized technical means to guarantee the data may not be reestablished or reproduced at a later time.
LINKS TO 3RD PARTY WEBSITES
CHOICES – MARKETING COMMUNICATIONS
On the off chance that you have given us your contact data (mail address, fax number, email address or telephone number), we might need to advise you as per any inclinations you have communicated, and with your assent where required, regarding our products and services or welcome you to occasions through email, web based promoting, online networking, WeChat, WhatsApp, phone, instant message (SMS or MMS), notifications, in-application notifications, postal mail, our customer service call center, and other different means (counting on-property informing, for example)
You may control whether our mobile apps send you push notifications by changing your notification settings on your mobile device. If we engage in sending you in-app messages, we will allow control for those in our apps’ settings
PROTECTION OF PERSONAL INFORMATION
Aitken Spence take required measures to ensure the protection/security of personal information from unauthorized access and also ensures to keep this information accurate and up-to-date. The Aitken Spence Information Security Team (Group IT) monitors our systems for potential intrusions, provide property level information security, frequently review and update security controls in order to protect data, provides relevant training programs etc. All personal data are secured in compliance with Aitken Spence cooperate information technology guidelines.
However, in an event of a security incident, the relevant party will take necessary action as applicable by laws and regulations.
We also put effort to maintain the confidentiality of the data shared among the service providers. For online transactions also, we use required technological measures to maintain the personal information. It is to be noted that, we are unable to guarantee the security of data transmitted over the internet. Therefore, please do not send payment card numbers or any other confidential information via email.
TRANSFER OF PERSONAL INFORMATION INTERNATIONALLY
Sharing information across borders is essential to the services so that you as the guest receive the best service wherever you are in the world. Therefore, we will, subject to law, exchange Personal Data and Other Data gathered regarding the Services, to entities in countries where data protection standards may differ from those in the country where you stay, we will take appropriate steps to ensure that your personal information is handled as described in this Statement and in accordance with the law.
REQUIREMENT TO CHANGE AND ACCESS YOUR PERSONAL INFORMATION
If required to access, review, modify, update, restrict or delete Personal Information that you have given to us, or in the event that you might want to get an electronic duplicate of your Personal Data for reasons for transmitting it to another organization, you can get in touch with us at email@example.com , or via mail:
Aitken Spence PLC,
315, Vauxhall Street,
Tel: (+94 11) 2308308
When requesting any modification, please make clear what Personal Data you would like to have changed. For your protection, we only fulfill requests for the Personal Data associated with the particular email address that you use to send us your request, and we may need to verify your identity before fulfilling your request. We will try to fulfil your request as soon as possible.
Furthermore, it is to be noted that there may also be certain data that will remain within our databases and other records, which will not be removed. In addition, there may be certain data that we may not allow you to review for legal, security or other reasons.
This statement is subjected to change/update from time to time. Any modification will become effective when we post the revised Privacy Statement on the Online Services. Use of the Services following these changes means that you accept the revised Privacy Statement.
If you have any questions regarding this privacy statement, you may reach us at firstname.lastname@example.org or by mail;
Aitken Spence PLC,
Tel: (+94 11) 2308308