This document sets out the Swiss-Belhotel Group Privacy Policy (privacy policy) and will answer your questions regarding how we respect and treat the information you provide to us. Swiss-Belhotel Group comprises of Swiss-Belhotel International Limited Unit 904, 9/F AXA Centre 151-159 Gloucester Road, Wanchai, Hong-Kong and Swiss-Belhotel International UK limited Suite 250, 162-168 Regent Street, London W1B 5TD, United Kingdom.
Collection Of Personal Information
There are two categories of information we collect:
- General Information: General Information is anonymous data that we use to analyse trends, gather broad demographic information for general use and to help us understand your needs and wants so we can improve the quality of your stay with us. General information includes the number of room nights booked and used, guest's gender, age, where guests are from, room rate, etc.
- Personal Information: Personal Information is any information that personally identifies you.
When you either make a reservation or just check in, we will ask you for personal details such as your name, home address, work telephone number and how the account will be settled. We will also take a copy of your Driver’s Licence or Passport. We may also obtain from your credit card details, whether you have any room preferences, disabilities or other lifestyle information. Personal Information may also be collected from information you provide to us if you enter a competition run by or on behalf of Swiss-Belhotel or you reply to a survey conducted by or on behalf of Swiss-Belhotel.
We may also collect certain Personal Information if the law requires us to collect it or receive it from other sources.
Sensitive Information
Where sensitive information is concerned, Swiss-Belhotel takes greater precautions as to who has access to it and what they use it for. Generally speaking, except as stated in this privacy policy, sensitive information will not be used or disclosed for a purpose other than the purpose for which it was collected without your consent. Where we collect sensitive information from you, we will disclose to you the reason for seeking it. If we are to disclose it to an entity outside the Swiss-Belhotel Group (including its associated companies and security contractors), we will seek your consent. However, we may disclose sensitive information to the police or where required by law, without your consent.
Consequences of not providing Personal Information
If you do not provide us with Personal Information that we consider essential or necessary, we regret the inconvenience, but may have no choice other than to decline your reservation. In addition we reserve the right to request and be provided with Personal Information or Identification (eg in the form of a Driver’s Licence) by people who visit you or who claim to be visiting you at our property. Further we reserve the right to remove or exclude any person who is visiting or claims to be visiting you who is unable or unwilling to provide us with identification to show that they are registered.
Anonymity
If you wish to stay in one of our luxury hotels or resorts on an anonymous basis, we may be able to accommodate your request, but we do not guarantee it. If we do accept your stay with us on an anonymous basis, you will not be able to make a booking in advance, you will need to pay for your accommodation at the time you check-in, and leave with us an amount of money we specify as a security bond (which will be refunded to you on your departure if your room is left in order and you have paid for all services or facilities provided to you or requested by you during your stay).
Primary purpose for which we collect information
Some of the information that we ask for is essential such as your name and billing details. These are used so we can contact you during your stay for reasons such as security, transferring incoming calls to you, letting you know if a facsimile arrives, if a visitor is waiting for you in the lobby, and so we can ensure we are paid for goods or services provided to you or requested by you.
If you make a reservation, we may also request your contact details, credit card details or the like. This information is used to pay the deposit, a security bond and so we can identify you when you check-in.
If you supply lifestyle information it may be used for two primary purposes. The first helps us to try and meet or exceed your expectations. For example, if we know which room you prefer or that you would like connecting rooms when you check-in to one of our hotels, we can hopefully provide you with the room and facilities you prefer.
The second is to make your stay as comfortable as possible by giving you peace of mind. For example, by providing us with information regarding a disability, our friendly staff can take this into consideration when selecting your room. This information may also be used by our staff, contractors or emergency services in the event of an emergency to assist with your well being.
Secondary purpose for which we collect information
Although we may use Personal Information while you are staying with us for the purposes described above, we may also use Personal Information for other purposes. We may use your Personal Information to update you on news, events, and special deals or if we believe we have something to offer you which may be of interest. This will usually be done via a mail out, however, if you have supplied an e-mail address you may be contacted by e-mail. Personal Information may also be used if we need to contact you in relation to matters that arose from your stay with us.
Who information is disclosed to and why
We may share General Information with our partners, associated companies, advertisers, government agencies, travel agencies or the media. Other than as stated in this policy, we will not share your Personal Information with a third party outside of government agencies or the Swiss-Belhotel Group (and its associated companies).
You have the right to take your name off our mailing lists at any time without charge. You may apply to add your name to a mailing list at any time should you desire.
We may send you information on behalf of our advertisers and partners. We will not give them your Personal Information without your express permission unless the advertisers are also Swiss-Belhotel associate companies bound by this or a similar privacy policy.
If we have provided credit to you or you do not pay your account on time, or you act in an unlawful manner, we may provide this information to credit reporting agencies, government agencies, other hotels in the area, hotel association bodies, or to any hotel operating under the Swiss-Belhotel banner. We may also use the information for recover action against you.
Except as stated in this privacy policy, we will not disseminate any Personal Information about you outside of the Swiss-Belhotel (and its associate companies) without your consent unless we believe it is necessary:
- because it is required or authorised by law;
- to provide you with a service which you have requested;
- to assist a law enforcement agency or agency responsible for national security in the performance of its functions;
- to protect our rights or property or those of any member of the public; or
- to lessen a serious threat to a person's health or safety.
We may retain the content of any document (including electronic documents such as e-mails and other similar forms of communication) that you send to us. Any Personal Information contained within those documents will only be used or disclosed in the ways set out in this privacy policy.
If Swiss-Belhotel or any of its associated companies becomes aware of, or suspects any unlawful activity taking place, it may instigate an investigation and/or report its findings or suspicions to the police or other relevant enforcement agency.
Contracting out services involving the disclosing of personal information
Where Swiss-Belhotel is contracting with a company who may receive or have access to Personal Information, it will make reasonable efforts to keep your information secure by contracting with companies who have either:
• adopted or are bound by the National Privacy Principles under the Act;
• implemented a privacy policy acceptable to us; or
• included in their contract for services:
o clauses setting out obligations on how to treat Personal Information;
o clauses stating the reasons for having access to the Personal Information;
o clauses setting out the primary purpose of collecting Personal Information;
o clauses regarding confidentiality to prevent disclosure of Personal Information to third parties;
o clauses stating the purpose for which they may use the Personal Information;
o clauses setting out how they will keep the information secure from unauthorised access, modification, use or disclosure;
o positive obligations on them to take measures to prevent the loss and misuse of information;
o procedures to enable us to meet obligations of disclosure;
o procedures whereby we may audit the information the contractor holds; and
o procedures to keep Personal Information held by both parties up to date.
Requests for access to personal information
We understand that you may like to know what Personal Information we hold about you or the type of such information we hold. We are happy to assist you with your request (subject to exceptions where relevant), but before we do, we may require that you prove your identity to us
Correction of information
If at any time you wish to update any of the Personally Identifiable Information you have provided to us (or add some information you haven't provided before), you can do it by contacting
hk@swiss-belhotel.com
How we store information
Precautions to protect the security of your Personal Information include protection of passwords using industry standard encryption, provisions to preserve the security of the information stored on computers or in offices or archives and to prevent unauthorised access, modification, use or disclosure, and back-up systems to prevent accidental or malicious loss of data or information.
Our employees who have access to your Personal Information are obliged to respect the confidentiality of any Personal Information held by us.
What we mean by Swiss-Belhotel
Each entity within the Swiss-Belhotel Group that has access to your Personal Information has either adopted this privacy policy, a similar privacy policy or the principles that govern this privacy policy.
Acceptance of our privacy policy
By making a booking, staying with us or using our services and not providing us with a written objection, you agree to our using Personal Information in accordance with our privacy policy. If at any time you do not agree to our privacy policy, please immediately advise us in writing. Swiss-Belhotel reviews its privacy policy periodically and reserves the right, at its discretion, to modify or remove portions of this privacy policy at any time subject to any applicable law. You should review this policy every time you stay with us so that you are up to date with any changes to this privacy policy.
Questions or comments regarding our privacy policy
Questions or comments regarding this privacy policy should be directed in the first instance to the General Counsel at Swiss-Belhotel.
Application of Act, Complaints
This policy and our actions are subject to the applicable laws in the country of the relevant hotel. If you feel that Swiss-Belhotel has not treated your Personal Information in accordance with either our privacy policy or the relevant law, we invite you to contact us by directing your complaint to the General Counsel at Swiss-Belhotel by writing to us at
hk@swiss-belhotel.com