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- PERSONAL DATA WE COLLECT
- HOW WE USE PERSONAL DATA
- HOW WE SHARE PERSONAL DATA
- HOW WE TRANSMIT, PROTECT AND
- SAFEGUARD PERSONAL DATA
- YOUR RIGHTS
- CONTACT US
- OTHER WEBSITES
1. Personal data we collect
The terminology "Personal Data" refers to any personal data that can be used to identify you as an individual
1.1 We may collect the following personal data about you
(a) Your personal information: the personal data you entrust to us, namely name, telephone number, e-mail and postal address (residence address and/or delivery address);
(b) Your payment information: your payment information such as your credit card details (card number, cryptogram and expiry date) and your bank account details;
(a) Our correspondence: if you contact us in connection with any enquiry, we will keep a record of that correspondence;
(b) Survey Data: We may also ask you to complete a survey that we use for research purposes. In such circumstances, we will collect the data provided in the survey; and
(c) Your use of our website and mobile applications: data from your visits to our website, our mobile application and information collected through cookies and other tracking technologies, including but not limited to limited to, your IP address and domain name, browser version and operating system, traffic data, geolocation data, Internet access data and other communication data and the resources to which you access.
(d) Do Not Track: As there is not yet a consensus on how companies should respond to Internet browser-based "do-not-track" (DNT) mechanisms, at We do not currently respond to Internet browser-based DNT signals.
Only in connection with hotel services (for example, when you book a room or a spa treatment, or when you buy a gift card from us)
(e) Your travel data and preferences: We may collect information such as your travel data (including flight number, arrival and departure dates and times, country/point of origin and destination ), your frequent traveler data, your travel companion's data, your preferences regarding room, food, beverages, treatments, service requests, information relating to your dietary, mobility or care needs. We may also collect data required by local laws, such as passport numbers, type of entry visa and driving licence;
(f) Your transactions with us: We collect your itemized expenses to properly populate your file during your stay, which includes your room rate and other expenses charged to your room.
Only in connection with non-hotel services (e.g. residential and business address, and your operations at residential clubs, food and beverage outlets and transportation)
Your transactions with us: We may collect information such as identity card or passport data, location, employment and club membership data.
1.2 We may collect your personal data directly from you. We may also collect personal data from third parties, including travel agents and other online service providers who make hotel, spa or restaurant reservations on your behalf, facilitate online payment or the purchase of gifts or who are otherwise involved in the booking process or who provide our services to you.
Special categories of personal data
1.4 “Special Categories of Personal Data” is a subset of Personal Data which includes Personal Data relating to your health, political opinions, religious beliefs, ethnicity and race, sex life, trade union membership and, in some cases, your criminal activities
1.5 As a general rule, we are not interested in special categories of personal data. However, we may process medical/health data in order to manage medical incidents and/or complaints in accordance with paragraph 2.1(i) below. When we deal with special categories, in the context of medical incidents, we do so in order to protect your vital interests, or those of another person. When we process Special Categories to support complaints, we do so to establish, exercise, or defend against legal claims, or where courts exercise jurisdiction. In addition to paragraph 1.5 above, we may process special categories of personal data in limited circumstances where you have provided us with such special categories of personal data, including medical data (e.g. allergies, disabilities, dietary requirements) in order to that we can safely provide our services to you (for example, spa treatments and meals).
1.7 Where we need to process special categories of personal data referred to in paragraph 1.6 above, we will only do so if you have given us your explicit consent for the collection, processing and disclosure of the special categories of personal data. When you provide us with special categories of personal data about a travel companion, you agree that you have obtained their consent to the collection, processing and disclosure of their special categories of personal data.
2. How we use personal data
2.1 We may use your personal data in the following ways.
(a) Manage the administrative part of your reservations: your reservation requests, which can be made through our website, our mobile application, our customer service center (GCSC) or through the website of a third party service provider and to confirm your reservation. We may send you a booking confirmation by e-mail, SMS or any other means and in the context of room(s) bookings, a message before your arrival summarizing your confirmation details and your preferences. As part of the hotel-related services, such a pre-arrival message will contain other information, including hotel, area and weather information.
Justification for use: performance of the contract, legitimate interests (to enable us to carry out our obligations and to provide you with services);
(b) To provide our services to you: to provide and bill for (i) hotel services, including but not limited to accommodation, meals, beverages, spa treatments, and to facilitate any request or assistance special accommodation you have requested, and (ii) non-hotel services, including rental and transportation.
Justification for use: performance of contract, legitimate interests (to enable us to perform our obligations and provide services to you);
Justification for use: performance of the contract, legitimate interests (to enable us to carry out our obligations and to provide you with services and products);
(c) Targeting the offer of services and products that we offer to you: to ensure your future comfort and to pay attention to your personal needs, we collect and store specific information about you, such as your dietary preferences (food and drinks) and other special requests. For example, if you are a regular customer of our establishments (hotels and/or restaurants) or have completed our catering questionnaire (food and beverages), we may save your personal data in our system in order to better serve you the next time.
Justification for use: legitimate interests (to allow us to target the offer of services and products that we offer you);
(d) Send you marketing offers: to provide you with updates, offers and subscriptions when you have opted in to receive them. With your consent, we may send you information about the Sound's Hotels group, restaurants, including news, offers and promotions about our hotels and boutique galleries, catering, spa, products, tourist services and special events organized by us, or our partners, by post, e-mail, telephone or SMS. These offers, promotions and information are also available on the social media platforms you use to connect with us. Please note that this use is subject to the terms and conditions of the social media platform used. However, we wish to limit our communications to those that you wish to receive. We generally use third party email service providers to send emails. These service providers are contractually prohibited from using your email address for any purpose other than sending emails related to HSH Group operations and any other organized special events. Personal data will not be shared with third parties for their marketing purposes. We give you the opportunity to unsubscribe from all marketing communications. Each time you receive an email, you will be given the option to unsubscribe from future emails by following the instructions provided in the email.
Justification for use: Consent (which can be withdrawn at any time).
(e) Analytics and profiling: to tailor our marketing to you. As part of our marketing activities, we analyze the information we collect about customers to determine which offers are most likely to appeal to different categories of customers under different circumstances and at different times. To do this at the level of hotel services, we combine the personal data that we have collected on a customer in an establishment of the Sound’s Hotels group with the personal data that we have collected on the same customer in another establishment of the Sound’s Hotels group. This personal data includes information about customer behavior, such as transaction history, spending habits, preferences, service requests and their interactions with us. From time to time, we will assess the personal data we hold about you with the aim of tailoring our marketing communications to include offers and content of interest to you. We may also use this method to avoid sending you offers that are inappropriate or unlikely to interest you. You have the right to object to such analysis of your personal data at any time. You can exercise this right by contacting us as indicated in section 6 below.
Justification for use: consent (which can be withdrawn at any time - see section 5.1 below); legitimate interests (to enable us to target the offer of services and products that we offer you);
(f) Comply with our legal obligations: to comply with our legal obligations such as financial reporting requirements imposed by our auditors and governmental authorities, and to cooperate with law enforcement agencies , government authorities and/or courts in connection with proceedings or investigations anywhere in the world where we are compelled to do so.
Justification for use: legal obligations, legal requests, legitimate interests (to cooperate with law enforcement agencies and regulatory authorities);
(g) Manage incidents and deal with complaints we receive: to manage accidents and incidents such as liaison with emergency services, and to deal with customer complaints including personal injury claims. Please note that this may also require the processing of special categories of personal data - see section 1.6 for more details.
Justification for use: vital interests (in relation to special categories of personal data), legal requests, legitimate interests (to ensure that incidents and accidents are handled appropriately and to allow us to support our customers);
(h) Improve our services and products: assist in the development of new services and products and the improvement of our existing services and products.
Use justification: legitimate interests (to allow us to continuously improve and develop our services);
(i) Ensuring the proper functioning of our website and our mobile application: ensuring that the content of our website and our mobile application is optimized for both you and your computer.
Use justification: performance of contract, legitimate interests (to enable us to provide you with Internet content and services); and
(j) In the context of any restructuring of our business: Analyze or allow the analysis of any proposed sale or restructuring of our business.
Justification for use: performance of contract, legitimate interests (to enable us to continue to provide you with the content and services.
Only in the context of hotel services
Use justification: performance of the contract, legitimate interests (to allow us to count you among our users).
3. How we share personal data
3.1 We may share your personal data in the following ways.
(a) Third party service providers who process personal data on our behalf to assist us in undertaking the activities described in Section 2: We may allow certain third parties such as service providers, agencies, contractors, entities who may be the hotel owner, and any company within the HSH Group to use your personal data for the purposes set out in section 2, including direct mail companies and e-mailing providers that we engage to send and distribute promotional material for Sound's Hotels Group, data center providers that host our servers and third party agencies that process mailings, online reservations. These parties are contractually prohibited from using the personal data for purposes other than those specified in their respective contracts, and will be under an obligation to process the personal data in accordance with the same safeguards that we deploy. We do not authorize the sale of personal data to entities outside Sound’s Hotels Group for any use unrelated to our group operations or the use of personal data by third parties for their own purposes.
Justification for use: performance of contract, legitimate interests (to enable us to efficiently provide services to you and to operate and manage our business);
(b) Law enforcement agencies, government authorities, regulators and courts in order to comply with our legal obligations or to handle incidents/queries: We may disclose your personal data when required by law. or a court order requires it, or at the request of other government authorities or law enforcement agencies to facilitate proceedings or investigations. Where permitted, we will make such a request directly to you or notify you before responding, unless doing so would interfere with the prevention or detection of a crime. This also applies where we have reason to believe that disclosing the personal data is necessary to obtain legal advice, identify, investigate, protect, contact or bring legal action against someone who may cause inconvenience to our guests, visitors, associates, rights or establishments, or to others, whether intentionally or unintentionally, or where anyone else could be harmed by such activities.
Justification for use: legal obligations, legal requests, legitimate interests (to cooperate with law enforcement agencies and regulatory authorities); and
Justification for use: performance of contract, legitimate interests (to enable us to operate and manage our business).
Justification for use
The following are the main legal grounds that justify our use of your personal data:
Consent: where you have consented to us using your personal data (a consent form has been presented to you in relation to such use)
Performance of contract: where your personal data is necessary to enter into or perform our contract with you.
Legal obligations: where we need to use your personal data to comply with our legal obligations.
Legitimate interests: where we use your personal data to achieve a legitimate interest and our reasons for using it outweigh any prejudice to your data protection rights.
Legal requests: when your information is necessary for us to defend ourselves, sue or file a claim against you, us or a third party.
Vital interests: where we need to process your personal data to protect your vital interests or those of another natural person, for example, where you need urgent assistance.
The following are the main legal grounds that justify our use of your special categories of personal data:
Explicit consent: You have given your explicit consent to the processing of this personal data for one or more specific purposes. You are free to withdraw your consent by contacting us. If you do so, we may not be able to provide a service that requires the use of this data.
Protection of your vital interests, or those of another natural person, where you are unable to give your consent: Processing is necessary to protect your vital interests or those of another natural person where you are physically or legally incapable of giving your consent.
4. How we transmit, protect and safeguard personal data
4.1 It is important to note that no security system or system for transmitting information over the Internet is guaranteed to be secure. There is an inherent risk in submitting information online, sending email and faxing. Please be aware of this when requesting information or submitting forms to us online or by e-mail or fax, for example, in the “Contact Us” section. We recommend that you do not include sensitive information, including credit card data, when submitting information online, by email or fax, or when using a public computer or public Wi-Fi access. .
4.2 We maintain administrative, technical and physical safeguards designed to protect the personal data we maintain against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. Despite these efforts, please note that no company can completely eliminate risks or guarantee the security of personal data. Unauthorized entry or use, hardware or software failure and other factors may compromise the security of information about you at any time, and we assume no responsibility for the use or disclosure of personal data or other data in connection with information theft or other malicious actions
4.3 We save certain customer information and booking data in our customer information system and our reservation system on the secure servers of our sub-contractors. Our server is protected by firewalls to protect the personal data collected from you, against unauthorized or accidental access. Laws applicable to personal data vary from country to country, so our hotels and other businesses may implement additional measures depending on applicable legal requirements.
Transmission of personal data across international borders
4.5 Your personal data will be retained for the period of time required or permitted by law in the jurisdiction of the operations holding the information (for example, certain transaction and correspondence data may be retained until the expiry of the time limit for complaining about the transaction or in order to comply with regulatory requirements concerning the retention of this data). Thus, if the information is used for two purposes, we will keep it until the expiry of the last period; but we will stop using it for this purpose in a shorter period once this period has expired.
4.6 Our retention periods are based on business needs and your personal data that is no longer required is either irreversibly anonymized (and the anonymized information may be retained) or securely destroyed.
5. Your rights
Opt out of marketing
5.1 At any time, you have the right to ask us not to process your personal data for marketing purposes. You can exercise your right by checking certain boxes online or on data collection forms, by speaking to us in person, or by contacting us as set out in Section 6 below.
5.2 Subject to various exceptions and the data protection laws applicable in your country, you may have the following rights:
(a) Access: you can ask us to provide you with further details of our use of your personal data and a copy of the personal data we hold about you;
(b) Correction: you can ask us to correct any inaccuracies in the personal data we hold about you;
(c) Complaint: if you are not satisfied with our use of your personal data or our response to the exercise of these rights, you have the right to complain to the data protection authority from your country;
(d) Erasure: you can ask us to delete your personal data if we no longer have a legitimate reason for using it;
(e) Withdrawal of consent: where processing is based on consent (for example, marketing, or certain uses of special categories of personal data), you may withdraw your consent to the processing and we will terminate that particular processing;
(f) Object to processing: you have the right to object to other types of processing (for example, analytics and profiling activities carried out in relation to your personal data), unless the reasons for which we undertake such processing prevail over any infringement of your data protection rights;
(g) Restrictions: you can restrict how we use your personal data for any ongoing investigation, for example, while we verify the accuracy of your personal data or while we verify the purposes for which we are using your personal data;
(h) Portability: where technically feasible, you have the right to ask us to transmit the personal data you have provided to us to a third party in a structured, commonly used and machine-readable format.
5.3 We will do everything reasonably possible to ensure that your personal data is accurate. In order to help us in this task, you must inform us of any changes to your personal data that you have communicated to us, by updating your contact details or by contacting us as indicated in section 6 below.
Notifications in case of infringement
5.4 In the unlikely event of a data breach, we are prepared to comply with any laws and regulations that would require us to notify you of the disclosure of personal data.
California Privacy Rights
5.5 Under California Civil Code Sections 1798.83-1798.84, California residents have the right to request a notice from us identifying the categories of customer personal data we share with our group companies, affiliates and/or third parties for marketing purposes, and providing the contact details of such affiliates and/or third parties. If you are a California resident and would like a copy of this information, please submit a written request to the address listed in Section 6.
6. Contact us
Data Privacy Team
BP 325, Bemoko 207
Nosy Be, Madagascar
Tel. : +261 38 15 001 41
Email : firstname.lastname@example.org
9. Other websites
9.1 The website or mobile application may contain links to other third-party websites. If you follow a link to any of these third-party websites, please note that they have their own privacy policies and we cannot accept any responsibility for their policies or their processing of your personal data. Please review these policies before submitting any personal data to these third-party websites.