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Privacy Policy

Last Updated: 24 June 2022

1. The Ennismore Group’s commitment to protecting privacy.

We consider you an important customer. Our first priority is to offer you exceptional stays and experiences throughout the world.

Your complete satisfaction and confidence in Ennismore Group is absolutely essential to us.

This policy formalizes our commitments to you and describes how the Ennismore Group uses your personal data.

2. Scope of application

In this policy, “Ennismore Group” means:

  • Ennismore Holdings Limited is a private limited company, registered with Companies House of the United Kingdom under company number 13348771, whose registered office is located at 10 Hammersmith Grove, London, United Kingdom, W6 7AP (“Ennismore“);
  • subsidiary or “family” companies of Ennismore involved in the hotel businesses of the Ennismore Group;
  • Accor SA, with its registered office at 82 rue Henri Farman, 92130 Issy-les-Moulineaux, France, and, as applicable, its subsidiary or “family” group of companies (“Accor”); and
  • hotels operated under one of the Ennismore Group brands throughout the world. These brands can be viewed on ennismore.com.

Good to know!

You probably don’t know this, but the hotel you are booked to stay in is probably not owned by Ennismore Group. Most Ennismore Group branded hotels are operated under a franchise or management agreement between the hotel’s owner and Ennismore Group. This is why, when staying in one of these hotels, your personal data will be dealt with by Ennismore Group and the hotel, both acting as Data Controllers for their own, separate, purposes.

Accor

When staying in one of our hotels, your personal data will also be dealt with by Accor S.A. (an Ennismore Group partner company) and the hotel, both acting as Data Controllers for their own, separate, purposes.

In summary:

  • Accor S.A. will be an independent controller of your data. This is because Accor S.A. manages a central booking engine for the Ennismore Group hotels, which allows Accor to collect the data necessary to organise your stay in hotels under an Ennismore Group brand, manage loyalty programmes and communicate this data to the hotels.
  • Each hotel is also an independent controller of your data. The hotel will process your data to manage its contractual relationship with you (invoicing, payment, booking management etc.), to perform marketing activities and to comply with its legal obligations.
  • Ennismore Group is also a controller of your data, which is used to contact you for marketing purposes, if you have chosen to keep in touch with us.

To understand how Accor and its subsidiary of “family” group of companies processes your data – please refer to https://all.accor.com/information/legal/data-protection.en.shtml.

Summary

  • Ennismore Group will process your data because it manages a booking engine, which allows Ennismore Group to collect the data necessary to organise your stay in hotels under an Ennismore Group brand and to communicate this data to the concerned hotels. Ennismore Group also manages a global database of clients who stay in hotels under an Ennismore Group brand;
  • Each hotel will process your data to manage its contractual relationship with you (invoicing, payment, booking management etc.), to perform marketing activities and to comply with its legal obligations; and
  • Ennismore Group has communicated the principles set out in this policy to all of the Ennismore Group branded hotels and their respective owners. We will do our upmost to ensure that all hotels comply with the applicable data protection laws and this policy in relation to the processing of your personal data.
3. Ennismore Group’s Ten Principles for Protecting your Personal Data

In accordance with applicable regulations, in particular the United Kingdom and European General Data Protection Regulations, we have instituted the following ten principles throughout the Ennismore Group:

  1. Lawfulness: We use personal data only if:
    • we obtain the consent of the person; OR
    • it is necessary to do so for the performance of a contract to which the person is a party; OR
    • it is necessary for compliance with a legal obligation; OR
    • it is necessary in order to protect the vital interests of the person; OR
    • we have a legitimate interest in using personal data and our usage does not adversely affect the persons’ rights.
  1. Fairness: We can explain why we need the personal data we collect.
  2. Purpose limitation and data minimisation: We only use personal data that we really need. If the result can be achieved with less personal data, then we make sure we use the minimum data required.
  3. Transparency: We inform people about the way we use their personal data.
  4. We facilitate the exercise of the people’s rights: access to their personal data, rectification and erasure of their personal data and the right to object to the use of their personal data.
  5. Storage limitation: We retain personal data for a limited period.
  6. We ensure the security of personal data, i.e. its integrity and confidentiality.
  7. If a third party uses personal data, we make sure it has the capacity to protect that personal data.
  8. If personal data is transferred outside Europe, we ensure this transfer is covered by specific legal tools.
  9. If personal data is compromised (lost, stolen, damaged, unavailable…), we notify such breaches to the respective country’s responsible authority and to the person concerned, if the breachis likely to cause a high-risk in respect of the rights and freedoms of this person.

For any questions concerning the ten principles of Ennismore Group data protection policies, please contact the Ennismore Group by writing to data@ennismore.com.

4. What personal data is collected?

Depending on how we interact with you, we may collect information about you and/or the persons accompanying you, including the following:

  • Contact details (for example, last name, first name, telephone number, email).
  • Personal information (for example, date of birth, nationality).
  • Information relating to your children (for example, first name, date of birth, age).
  • Your credit card number (for transaction and reservation purposes).
  • Information contained on a form of identification (such as ID card, passport or driver licence).
  • Your arrival and departure dates.
  • Your preferences and interests (for example, smoking or non-smoking room, preferred floor, type of bedding, type of newspapers/magazines, sports, cultural interests, food and beverages preferences, etc.).
  • Your questions/comments, during or following a stay in one of our Ennismore Group branded establishments.
  • Technical and location data you generate as a result of using our websites and applications.
  • The information collected in relation to persons under 16 years of age is limited to their name, nationality and date of birth, which can only be supplied to us by an adult. We would be grateful if you could ensure that your children do not send us any personal data without your consent (particularly via the Internet). If such data is sent, you can contact the Ennismore Group to arrange for this information to be deleted.
  • In order to meet your requirements or provide you with a specific service (such as dietary requirements), we may have to collect sensitive information, such as information concerning race, ethnicity, political opinions, religious and philosophical beliefs, union membership, or details of health or sexual orientation. In this case, we will only process this data if you provide your explicit prior consent or where it is necessary to protect your wellbeing.
5. When is your personal data collected?

Personal data may be collected on a variety of occasions, including:

  • Hotel activities:
    • Booking a room.
    • Checking-in and paying.
    • Hotel stays and services provided during a stay.
    • Eating/drinking at the hotel bar or restaurant during a stay.
    • Requests, complaints and/or disputes.
  • Participation in marketing programs or events:
    • Signing up for loyalty programs.
    • Participation in customer surveys (for example, the Guest Satisfaction Survey).
    • Online games or competitions.
    • Subscription to newsletters, in order to receive offers and promotions via email.
  • Transmission of information from third parties:
    • Tour operators, travel agencies (online or not), GDS reservation systems and others.
  • Internet activities:
    • Connection to Ennismore Group websites (IP address, cookies in accordance with the Ennismore Cookies Policy.
    • Online forms (online reservation, questionnaires, Ennismore Group pages on social networks, social networks login devices such as Facebook login, conversations with chatbot, etc.).
6. What purposes is your data collected for and for how long do we retain it?

The table set out in Annexure A why we process your data, the lawful basis for the processing and the associated retention period.

7. Conditions of third-party access to your personal data.

Ennismore Group operates in many countries and we endeavour to provide you with the same services throughout the world. Thus, we may share your personal data with internal and external recipients.

In particular, the data related to your stays, preferences, satisfaction and, if the case may be, your loyalty program membership are shared between the hotels operating under the Ennismore Group brands. This data is used to improve the quality of service and your experience in each of these hotels. In this context, your data is processed jointly by Ennismore Group and these hotels. In order to pursue this legitimate interest, whilst safeguarding your rights and liberties, a specific joint controllership agreement describes the obligations and responsibilities of Ennismore Group and these hotels.

You may, at any time, object to the sharing of this data between the hotels and Ennismore Group by writing to data@ennismore.com. You can also request a summary of the key points of the joint controllership agreement.

As such, we may share your personal data with internal and external recipients subject to the following conditions:

  • We share your data with a number of authorised people and departments in the Ennismore Group in order to offer you the best experience in our hotels. The following teams may have access to your data:
    • Hotel staff.
    • Reservation staff using Ennismore Group reservation tools.
    • IT departments.
    • Commercial partners and marketing services.
    • Medical services if applicable.
    • Legal services if applicable.
    • Generally, any appropriate person within Ennismore Group entities for certain specific categories of personal data.
  • With service providers and partners: your personal data may be sent to a third party for the purposes of supplying you with services and improving your stay, for example:
    • External service providers: IT sub-contractors, international call centres, banks, credit card issuers, external lawyers, dispatchers, printers.
    • Commercial partners: Ennismore Group may, unless you specify otherwise to the Ennismore Group, enhance your profile by sharing certain personal information with its preferred commercial partners. In this case, a trusted third party may cross-check, analyse and combine your data. This data processing will allow Ennismore Group and its privileged contractual partners to determine your interests and customer profile to allow us to send you personalized offers.
    • Social networking sites: In order to allow you to be identified on the Ennismore Group website without the need to fill out a registration form, Ennismore Group has put in place a social network login system. If you log in using the social network login system, you explicitly authorize Ennismore Group to access and store the public data on your social network account (e.g. Facebook, LinkedIn, Google, Instagram…), as well as other data stated during use of such social network login system. Ennismore Group may also communicate your email address to social networks in order to identify whether you are already a user of the concerned social network and in order to post personalized, relevant adverts on your social network account if appropriate.
  • With local authorities: We may be obliged to send your information to local authorities if this is required by law or as part of an inquiry. We will ensure that any such transfer is carried out in accordance with local regulations.
8. Protection of your personal data during international transfers

For the purposes set out in clause 6 of this policy, we may transfer your personal data to internal or external recipients who may be in countries or regions offering different levels of personal data protection.

Consequently, in addition to implementation of this policy, Ennismore Group employs appropriate measures to ensure secure transfer of your personal data to an Ennismore Group entity or to an external recipient located in a country or region offering a different level of privacy from that in the country or region where the personal data was collected.

Your data may be sent, in particular as part of the reservation process, to Ennismore hotels located outside of the United Kingdom or European Union, in particular in the following countries/regions: Saudi Arabia, Argentina, Australia, Bahrain, Brazil, Cambodia, Canada, Chile, China (including Taiwan Region, Hong Kong Special Administrative Region and Macau Special Administrative Region), Colombia, South Korea, Cuba, Egypt, United Arab Emirates, Ecuador, United States of America, Fiji, Indonesia, Israel, Japan, Jordan, Kuwait, Laos, Lebanon, Malaysia, Morocco, Mauritius, Mexico, New Zealand, Oman, Uzbekistan, Panama, Paraguay, Peru, Philippines, Qatar, Democratic Republic of Congo, Dominican Republic, Russia, Singapore, Switzerland, Thailand, Turkey, Ukraine, Uruguay, Vietnam, Yemen.

When we do this, we ensure it receives additional protection as required by law.

To keep this privacy policy as short and easy to understand as we can, we haven’t set out the specific circumstances when these protection measures are used. You can contact us at data@ennismore.com for more detail on this.

9. Data security

Ennismore Group takes appropriate technical and organizational measures, in accordance with applicable legal provisions, to protect your personal data against illicit or accidental destruction, alteration or loss misuse and unauthorized access, modification or disclosure.

To this end, we have taken technical measures (such as firewalls) and organizational measures (such as a user ID/password system, means of physical protection etc.) to ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services. In relation to the submission of credit card data when making a reservation, SSL (Secure Socket Layer) encryption technology is used to guarantee a secure transaction. Organizational measures ensure the security of the processing.

10. Cookies

Ennismore Group uses cookies and other tracking technologies on its websites. To find out more about how Ennismore Group uses these trackers and how to configure them, please see our cookies policy.

11. Your rights

You have the right to obtain information about and access your personal data collected by Ennismore Group, subject to applicable legal provisions. Also you have the right to have your personal data rectified, erased or have the processing of it restricted. Furthermore you have the right to data portability and to issue instructions on how your data is to be treated after your death (hopefully as late as possible!). You can also object to the processing of your personal data, in particular to the sharing of the data related to your stays, preferences and satisfaction between the hotels operating under the Ennismore Group brands.

In the event that you wish to exercise any of your above rights, please contact Ennismore Group by writing to data@ennismore.com. All requests will receive a response as swiftly as possible.

For the purposes of confidentiality and personal data protection, we will need to check your identity in order to respond to your request. In case of reasonable doubts concerning your identity you may be asked to include a copy of an official piece of identification, such as an ID card or passport, along with your request. A black and white copy of the relevant page of your identity document is sufficient.

You may also exercise your rights in respect of your personal data that is stored and processed by a hotel as a data controller. To do this, you must contact the hotel directly.

If you need any assistance, please contact Ennismore Group by writing to data@ennismore.com.
You can contact the Ennismore Group data protection officer by writing to data@ennismore.com.

If you are in Australia or New Zealand and have a complaint about how we collect, hold, use or disclose your personal data, you can also contact privacy.au@accor.com.

You also have the right to lodge a complaint with a data protection authority.

12. Updates

We may modify this policy from time to time. Consequently, we recommend that you consult it regularly, particularly when making a reservation at one of our hotels.

13. Questions and contacts

For any questions concerning The Ennismore Group’s personal data protection policy, please write to data@ennismore.com.

14. Notices related to local laws and regulations

The Ennismore Group complies with both the UK and European General Data Protection Regulations when providing our services in the UK and EU markets.

There are other laws and regulations which, depending on your specific situation, may also govern the use of your personal data. You will find below additional information that may apply to you.

14.1.     PRIVATE NOTICE FOR CALIFORNIA RESIDENTS

This “Privacy Policy for California residents” is part of the Ennismore Group Privacy Policy  and should therefore be read in conjunction with it.

The California Consumer Privacy Act 2018 (“CCPA”) requires that we provide California residents with a privacy policy that contains a comprehensive description of our online and offline practices regarding the collection, use, disclosure, and sale of personal information and of the rights of California residents regarding their personal information.

The CCPA defines “Personal Information” as information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household. In the context of this “Privacy Policy for California residents” section, the term “Personal Information” will refer to this information.

Ennismore Group may collect the categories of Personal Information as described in section 4 of the Ennismore Group Privacy Policy.

If you would like more details about when your Personal Information is collected, what purposes it is collected for and how long we retain it, please see the Ennismore Group Privacy Policy – including section 5 and section 6 of the Ennismore Group Privacy Policy.

In addition to the purposes set forth in the Ennismore Group Privacy Policy, we currently collect and have collected and “sold” (see section “Do Not Sell” below) Personal Information for the following business or commercial purposes:

  • Auditing related to a current interaction with you and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.
  • Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
  • Debugging to identify and repair errors that impair existing intended functionality.
  • Performing services, including maintaining or servicing accounts, providing customer service, processing reservations, verifying customer information, processing payments, providing advertising or marketing services, or providing analytic services.
  • Undertaking activities to verify or maintain the quality or safety of our services, and to improve, upgrade, or enhance same.
  • Commercial purposes, such as by inducing another person to buy, join, subscribe to, provide, or exchange property or information, or enabling or effecting, directly or indirectly, a commercial transaction.

We may share your Personal Information with internal and external recipients subject to the conditions set forth in section 7. Conditions of third-party access to your personal data of the Ennismore Group Privacy Policy. The categories of third parties to whom your Personal Information may be disclosed or “sold” (see section “Do Not Sell” below) on a need-to-know basis are:

  • Service Providers: external Service Providers;
  • Other Third Parties: appropriate persons within hotels and Ennismore Group entities; commercial partners; social networking sites; local authorities (if and as legally required).

We do not knowingly “sell” (see section “Do Not Sell” below) the Personal Information of minors under 16 years of age. For more information on data collected in relation to persons under 16 years of age and to arrange for this information to be deleted, see section 4. What personal data is collected? of the Ennismore Group Privacy Policy.

Right to know about personal information

As a California resident, you have the right to request that we disclose what Personal Information we have collected about you in the 12-month period preceding your request, and more specifically the following:

  • The categories of Personal Information we have collected about you.
  • The categories of sources from which the Personal Information was collected.
  • The business or commercial purpose for collecting Personal Information, and if applicable, for “selling” Personal Information.
  • The categories of Personal Information that we “sold” (if applicable) or disclosed for a business purpose.
  • The categories of third parties to whom we have “sold” (if applicable) or disclosed Personal Information.
  • The specific pieces of Personal Information we have collected about you.

Right to request deletion of personal information

As a California resident and subject to certain exemptions, you have the right to request the deletion of your Personal Information that we collect.

How to submit a request to know or to delete

You may submit a request to know or to delete by writing to data@ennismore.com.

When you submit your request, we will need to verify your identity pursuant to regulations adopted by the Attorney General and ask you to provide sufficient information in order to allow us to reasonably verify you are the person about whom we have collected information.

As part of our verification method, we will seek to verify the information in your request with the Personal Information we maintain about you. We will verify your identity either to a “reasonable degree of certainty” or a “reasonably high degree of certainty” depending on the sensitivity of the Personal Information and the risk of harm to you by unauthorized disclosure or deletion as applicable. In addition, you may be required to submit a signed declaration under penalty of perjury stating that you are the individual whose Personal Information is being requested.
We will respond to your request to know or to delete within 45 days, unless additional time is needed, in which case we will let you know.

Authorised Agents

The CCPA allows California residents to designate an authorized agent to exercise their rights. If you submit a request via an authorized agent acting on your behalf, we will require this authorized agent to provide proof that you gave the agent signed permission to submit the request.

“Do Not Sell My Personal Information”: Right to Opt-Out of the Sale of Personal Information

Under the CCPA, the disclosure of Personal Information to a third party for monetary or other consideration of value can be considered as a “sale”, the term “sale” being broadly defined.

The CCPA defines a “sale” as selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a California resident’s Personal Information to another business or a third party for monetary or other valuable consideration.

The CCPA gives residents of California the right to opt out of the “sale” of their Personal Information.

We do not “sell” customers’ personal data in the strictest sense of the term. However, we offer Californian residents the opportunity to exercise this right, should one of our business practices be considered a “sale” within the meaning of the CCPA.

To opt-out of our use of third-party advertising cookies, see our cookies policy.

You may submit a request to opt-out of the sale of your Personal Information by writing to data@privacy.com.

Cookies

On the Ennismore Group websites, Ennismore Group and its partners store or retrieve information on your device in order to: operate the websites and provide you with the services you request (these cannot be rejected), enhance and customize website functionalities, measure website audience and performance, profile your interests to provide you with relevant advertising and allow you to interact with social networks.

You can modify your choices at any time by clicking on the “Cookies” link at the bottom of the respective website.

Some internet browsers incorporate a “Do Not Track” feature that signals to websites you visit that you do not want to have your online activity tracked. Given that there is not a uniform way that browsers communicate the “Do Not Track” signal, the websites do not currently interpret, respond to or alter their practices when they receive “Do Not Track” signals.

Financial Incentives and Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights.

Unless permitted by the CCPA, we will not:

  • Deny you goods or services;
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
  • Provide you a different level or quality of goods or services;
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, as permitted by and in compliance with the CCPA, we may offer you certain financial incentives that can result in a different price, rate, level, or quality of services. Any financial incentive we offer will be reasonably related to the value of your Personal Information and your participation will be subject to any applicable terms. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.

Shine the Light Law

If you are a California resident, California Civil Code § 1798.83 permits you to request information regarding the disclosure of your personal information by us to third parties for the third parties’ direct marketing purposes (as those terms are defined in that statute).

This information is as follows: in accordance with European regulations, we will only disclose your personal information to third parties for the third parties’ direct marketing purposes with your express prior consent and a prior information on the third parties your information will be disclosed to.

14.2      PRIVACY NOTICE FOR NEVADA RESIDENTS

Nevada law allows Nevada residents to opt-out of the sale of certain types of personal information. Subject to several exceptions, Nevada law defines “sale” to mean the exchange of certain types of personal information for monetary consideration to another person.  We do not currently sell personal information as defined in the Nevada law.  However, if you are a Nevada resident, you still may submit a verified request to opt-out of sales.  Opt-out requests may be sent to data@ennismore.com.

14.3      PRIVACY NOTICE FOR RESIDENTS OF CHINA

14.3.1   Introduction

This Privacy Notice for China is part of the Ennismore Group Privacy Policy  and should be read in conjunction with it.

This notice is made pursuant to the Personal Information Protection Law of the People’s Republic of China (“PIPL“) and applies to our personal information processing activities:

  • in the People’s Republic of China (which, for the purposes of this notice only, excludes the Hong Kong SAR, Macau SAR and Taiwan China) (“China“); and
  • outside China for the purposes of providing products and services to people in China.

For the above personal information processing activities, if there is any inconsistency between this Privacy Notice for China and the Ennismore Group Privacy Policy, this Privacy Notice for China prevails.

14.3.2   Collection, Use and Retention of Personal Information

The PIPL defines “Personal Information” as any kind of information related to an identified or identifiable natural person as electronically or otherwise recorded, excluding information that has been anonymized. Processing activities include the collection, storage, use, processing, transmission, provision, disclosure, and deletion of personal information.

To know more about how we collect, use and retain your personal information, please read the following sections in the Ennismore Group Privacy Policy:

  • 4. WHAT PERSONAL DATA IS COLLECTED?
  • 5. WHEN IS YOUR PERSONAL DATA COLLECTED?
  • 6. WHAT PURPOSES IS YOUR DATA COLLECTED FOR AND HOW LONG DO WE RETAIN IT?

The PIPL gives “Sensitive Personal Information” extra protection and defines it as information that, once leaked or illegally used, will easily lead to the infringement of human dignity or harm to the personal or property safety of a natural person. Ennismore Group will only process Sensitive Personal Information if there is a specified purpose, necessity and strict measures for its protection. Sensitive Personal Information we collect may include information such as transaction information, ID card or passport related information, location information and stay records.

The Personal Information of minors under 14 is also Sensitive Personal Information in China, which we normally only collect from parents or guardians and is limited to their name, nationality and date of birth. We would be grateful if you could ensure that your children do not send us any personal information without your consent (particularly via the Internet). If such information is sent, you can contact the Ennismore Group to arrange for this information to be deleted.

14.3.3   Justification of Processing for China

We only process Personal Information if there is a “lawful basis”, including:

  • Your consent;
  • The processing is necessary for the conclusion or performance of a contract to which you are a contracting party;
  • The processing is necessary for performing a statutory responsibility or statutory obligation;
  • The processing is necessary for responding to a public health emergency, or protecting the life, health or property of a natural person in an emergency;
  • The personal information is processed within a reasonable manner to carry out any news reporting, supervision by public opinions or any other activity for public interest purposes;
  • The personal information has already been disclosed by the individual or otherwise legally disclosed and is processed within a reasonable scope and in accordance with the PIPL; or
  • Any other circumstance as provided by law or administrative regulations of China.

All our processing in China is conducted under one of the above lawful bases as described in section 6 of the Ennismore Group Privacy Policy except for the following activities which are conducted under the lawful bases described in the table below:

Purpose / ActivityLawful Basis for Processing
Use a trusted third party to cross-check, analyze and combine your collected data at the time of booking or at the time of your stay, in order to determine your interests and develop your customer profile and to allow us to send you personalized offers.Consent
Securing and enhancing your use of Ennismore Group websites, applications and services by:

  • Improving navigation;
  • Maintenance and support; and

Implementing security and fraud prevention.

The conclusion or performance of a contract to which you are a contracting party.
Internal management of lists of customers having behaved inappropriately during their stay at the hotel (aggressive and anti-social behaviour, non-compliance with safety regulations, theft, damage and vandalism or payment incidents).The conclusion or performance of a contract to which you are a contracting party.
  • Securing payments by determining the associated level of fraud risk. As part of this analysis, Ennismore SA and hotels may use the Ennismore Group risk prevention service provider to refine their analysis.
  • Depending on the results of the investigations carried out, Ennismore Group may take security measures, in particular Ennismore Group may request the use of a different booking channel or for the use of an alternative payment method. These measures will have the effect of suspending the execution of the booking or, if the result of the analysis does not guarantee the safety of the order, of cancelling it.
  • Fraudulent use of a means of payment leading to payment default may result in the entry of data in the Ennismore Group incident file, which may lead Ennismore Group to block future payments or carry out additional checks.
The conclusion or performance of a contract to which you are a contracting party.
Securing properties and persons and preventing non-payments.
For these reasons, some hotels have a feature that allow them to include in the category of “ineffective” customers, any customer whose behaviour has been inappropriate in the following ways: aggression and rudeness, non-compliance with the hotel contract, failure to observe safety rules, theft, damage and vandalism, or payment issues. The status of “ineffective” may cause the hotel where this listing originated to refuse a customer’s reservation when he/she returns to the same hotel.
The conclusion or performance of a contract to which you are a contracting party.
Using services to search for persons staying in Ennismore Group hotels in the event of serious events affecting the hotel in question (natural disasters, terrorist attacks, etc.).Responding to a public health emergency, or for protecting the life, health or property safety of a natural person in the case of an emergency.

14.3.4   System Permissions

When you use our App and Weixin Mini-program, we will seek system permissions on your device to ensure the functionality of our products/services and their safe and stable operation as follows:

Name of system permissionsDescriptionPurposesApplicable processes
android.permission
.ACCESS_NETWORK_STATE
View network statusAllows an application to view the status of all networks.Android
android.permission
.INTERNET
Full internet accessAllows an application to create network sockets.Android
android.permission
.WAKE_LOCK
Prevent phone from sleepingAllows an application to prevent the phone from going to sleep.Android
android.permission
.ACCESS_WIFI_STATE
View Wi-Fi statusAllows an application to view the information about the status of Wi-Fi.Android
com.google.android.c2dm
.permission.RECEIVE
C2DM permissionsPermission for cloud to device messaging.Android
android.permission
.RECEIVE_BOOT_COMPLETED
Automatically start at bootAllows an application to start itself as soon as the
System has finished booting.
Android
android.permission
.FOREGROUND_SERVICE
Allows a regular application to use service.startforegroundAllows a regular application to use service.startforeground.Android
com.google.android.finsky.permission.
BIND_GET_INSTALL_
REFERRER_SERVICE
Get APP installation information for notification pushingTo get information about the origin of the installation of the APP by the user in order for the push notification system to reach Google servers and push the notification on the right device.Android
android.permission
.VIBRATE
Control device vibrationAllows the application to control device vibration.Android
com.accor.appli.hybrid.inhouse.batch
.permission.INTERNAL_BROADCAST
Push notificationsTo request user authorization to send him/her push notificationsAndroid
android.permission
.READ_EXTERNAL_STORAGE
Read external storage contentsAllows an application to read external storage. Necessary to install the application on a device without internal memory.Android
android.permission
.WRITE_EXTERNAL_STORAGE
Read/modify/delete external storage contentsAllows an application to write to external storage. Necessary to install the application on a device without internal memory.Android
android.permission
.READ_PHONE_STATE
Read phone state and identityAllows the application to access the phone features of the device.  Feature to call Ennismore Group customer Help Center in the app.Android
android.permission
.BLUETOOTH
Create Bluetooth ConnectionsAllows applications to connect to paired Bluetooth devices. Necessary to have the Ennismore Group Hotel Keyless functionality (keyless door lock).Android
android.permission
.BLUETOOTH_ADMIN
Bluetooth AdministrationAllows applications to discover and pair Bluetooth devices.
Necessary to have the Ennismore Group Hotel Keyless functionality (keyless door lock).
Android
android.permission
.ACCESS_FINE_LOCATION
Fine (GPS) locationAccess fine location sources, such as the GPS on the phone, where available. Necessary for the geolocation hotel search feature (find a hotel around me).Android
android.permission
.ACCESS_COARSE_LOCATION
Coarse (networkbased) locationAccess coarse location sources, such as the mobile network database, to determine an approximate phone location, where available. Necessary to define the language to be displayed in the application.Android
NSCalendarsUsageDescriptionCalendarAdd booking to calendariOS
NSMicrophoneUsageDescriptionMicrophoneVoice Search featureiOS
NSLocationAlwaysUsageDescriptionLocationFind hotels + taxi or chauffeur-driven cariOS
NSLocationWhenInUseUsageDescriptionLocationFind hotels + taxi or chauffeur-driven cariOS
NSSpeechRecognitionUsageDescriptionSpeech recognitionVoice search featureiOS
NSUserTrackingUsageDescriptionTracking (IDFA/ATT)Tracking. Necessary because of mandatory IDFA / ATT Apple’s rule. Consent is needed prior sending identifier to partners.iOS
Push notificationPushiOS
Background app refreshAllow the application to be refreshed in background. Can be turned off in iOS settingsiOS
NSBluetoothAlwaysUsageDescriptionBluetoothNecessary to have the Ennismore Group Hotel Keyless functionality (keyless door lock)iOS
Share Profile (Nickname, Gender, region, Country, Image/Avatar)Avoid to fill the same information in a form in Mini-ProgramWeixin Mini-Program
Share Mobile numberAutomatically fill in the mobile phone number, which is used to send SMS notifications such as room information.Weixin Mini-Program
Share WeChat Chat featureActivation of chat notification.Weixin Mini-Program
Share WeChat PayPayment through WeChat.Weixin Mini-Program
Share Geo fencingGeo localization, necessary for the geolocation hotel search feature (find a hotel around me).

Please note that by turning on any of the permissions, you authorize us to collect and use the relevant personal information to provide you with the corresponding services, and by turning off any of the permissions, you cancel your authorization, and we will no longer collect and use the relevant personal information based on the corresponding permissions, nor can we continue to provide you with the services corresponding to the permissions. Your decision to cancel your authorization will not affect any previous collection and use of information based on your authorization. You can manage your authorizations through your device settings.

14.3.5   Conditions of Third-Party Access to Your Personal Information

Entrusted Personal Information Processing

In order to provide certain services to you, we may need to entrust a service provider to process some of your personal information. We will enter into strict confidentiality agreements and personal information protection clauses with such entrusted parties, requiring them to process and protect your personal information in accordance with our requirements, this Privacy Notice and any other relevant confidentiality and security requirements.

Providing Personal Information to Third-Party Service Providers

In order to give you a better service experience, we provide you with access to a variety of products or services provided by third party service providers. When you use these services, we may, with your explicit authorization or consent, provide or share your personal information for the purposes described in the Ennismore Group Privacy Policy among members of the Ennismore Group or third party service providers, including:

  • Any entity in the Ennismore Group;
  • Franchised and managed hotels;
  • Master franchisees;
  • Spa, restaurant, health club, concierge and other outlets at properties to provide you with services;
  • Loyalty programs partners;
  • AccorPlus loyalty program;
  • Travel agencies and distributions systems operators;
  • Payment services providers;
  • Travel insurance partners; and
  • Advertising network and analytics providers for Ennismore Group websites and mobile applications.

Third-Party SDKs We Use

Our website, App and Mini-program may have integrated third-party software development kits (SDKs) to ensure their stable operation and to provide relevant services to you.

If you want to know more information about the third-party SDKs we use, please see the following SDK list:

#Name of the SDKSDK service providerPurposes of processing personal informationPersonal information collected via SDKSDK service provider’s privacy policy
1FirebaseGoogle, Inc.User tracking and engagement.No personal information, only anonymous navigation data.https://firebase.google.com/support/privacy
2Firebase CrashlyticsGoogle, Inc.User crash monitoring.No personal information, only anonymous data about crash: device, OS versionhttps://firebase.google.com/support/privacy
3Firebase Remote ConfigGoogle, Inc.Enable feature without submitting a new app on the store.No personal information, only anonymous data: app versionhttps://firebase.google.com/support/privacy
4Firebase AnalyticsGoogle, Inc.User tracking and engagement.No personal information, only anonymous navigation data: screen view, click, time on each pagehttps://firebase.google.com/support/privacy
5GoogleAnalyticsGoogle, Inc.User tracking and engagement.No personal information, only anonymous datahttps://developers.google.com/analytics/devguides/collection/protocol/policy
6GoogleTagManagerGoogle, Inc.Managing tracking plan in the appNo personal information, only anonymous datahttps://marketingplatform.google.com/about/analytics/tag-manager/use-policy/#:~:text=If%20You%20have%203rd%20Party,responsible%20for%203rd%20Party%20Tags.&text=to%20upload%20any%20data%20to,such%20information%20by%20Google%2C%20or
7BranchBranch Metrics, Inc.Deeplink handling.No personal datahttps://branch.io/policies/privacy-policy/
8BatchIMEDIAPP SAUser push notification management.Device installation IDhttps://batch.com/privacy-policy
9BatchExtensionIMEDIAPP SACustom push notificationDevice installation IDhttps://batch.com/privacy-policy
10DynatraceDynatrace LLCApplication API call tracking, used for stats and API debugging.Anonymous data, except PMID (user id). With this PMID we can show:
-App version
-User actions
-User crashs
-Device
-OS version
-IP Adress
https://www.dynatrace.com/company/trust-center/privacy/
11One TrustOne Trust, LLC.User consent management platform.Cookie consent for one device / no user datahttps://www.onetrust.com/privacy-notice/
12AlamofireOpen Source (https://github.com/Alamofire/Alamofire)HTTP networking library for iOSNo personal informationNA
13ApolloMG Code EPEAndroid Graph QL API clientNo personal informationhttps://www.apollographql.com/privacy-policy/
14Content SquareContent Square, Inc.Web analytics featureNo personal information, only anonymous datahttps://contentsquare.com/privacy-center/privacy-policy/
15Materiel DesignGoogleUser Interface Design ToolNo personal informationNA
16KingfisherOpen Source (https://github.com/onevcat/Kingfisher/)Library for downloading and caching images from the webNo personal informationNA
17FSCalendarOpen source (https://github.com/onevcat/Kingfisher/FSCalendar)Library for downloading and caching images from the webNo personal informationNA
18Threat MatrixLexisNexis Risk Solutions Inc.Security analytics.No personal informationhttps://risk.lexisnexis.com/group/privacy-policy
19Cardinal CommerceVisa, Inc.PSD2 Banking authorisation management.No personal informationhttps://usa.visa.com/legal/privacy-policy.html
20ImpervaImperva, Inc.Bot detection / securityNo personal informationhttps://www.imperva.com/trust-center/privacy-statement/
21KarhooFlit Technologies LtdChauffeur driven car booking SDK.No personal informationhttps://www.karhoo.com/privacy-policy/
22Stay My WayStay My WayContactless door opening.PMID / Reservation IDNA
23Debug Tool KitOpen Source (https://github.com/dbukowski/DBDebugToolkit)Access to debugging logsNo personal information, only anonymous dataNA
24NimbleOpen Source (https://github.com/Quick/Nimble )Express the expected outcomes of Swift or Objective-C expressionNo personal informationNA
25FacebookMeta, Inc.User tracking, such as Firebase, for Facebook purposesPMID (user identifier)https://www.facebook.com/policy.php
26Baidu MapsBaidu, Inc.Mapping application for China.No personal informationhttp://privacy.baidu.com/policy
27Retrofit2Open source (https://square.github.io/retrofit/ )Android REST API client.No personal informationNA

14.3.6   Protection of Your Personal Data During International Transfers
We use central systems hosted in France and the United Kingdom to process your booking, stays and membership information.

 

Your data may be sent, in particular as part of the reservation process, to Ennismore Group hotels located in the following countries or regions: Austria, Belgium, Bulgaria, Croatia, Republic of Cyprus, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta, Netherlands, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden, Iceland, Liechtenstein, Norway, South Africa, Algeria, Andorra, Angola, Saudi Arabia, Argentina, Australia, Bahrain, Benin, Brazil, Cambodia, Cameroon, Canada, Chile, Colombia, South Korea, Ivory Coast, Cuba, Egypt, United Arab Emirates, Ecuador, United States of America, Fiji, Ghana, Guatemala, Equatorial Guinea, Hong Kong SAR, India, Indonesia, Israel, Japan, Jordan, Kuwait, Laos, Lebanon, Macao SAR, Madagascar, Malaysia, Morocco, Mauritius, Mexico, Monaco, Myanmar, Nigeria, New Zealand, Oman, Uzbekistan, Panama, Paraguay, Peru, Philippines, Qatar, Democratic Republic of Congo, Dominican Republic, Russia, Senegal, Singapore, Switzerland, Chad, Thailand, Togo, Tunisia, Turkmenistan, Turkey, Ukraine, United Kingdom Uruguay, Vietnam, Yemen, Taiwan China.

We will work with these personal information recipients located outside China through agreements and other means that require them to take necessary personal information security measures and clarify their personal information protection responsibilities to ensure that your personal information receives adequate and uniform protection in China and countries or regions outside China.

14.3.7   Data Security
We take appropriate technical and organizational measures, in accordance with applicable legal provisions, to protect your personal information against unlawful or accidental destruction, alteration, loss, misuse, access, modification or disclosure. For more information, please read 9. DATA SECURITY in the Ennismore Group Privacy Policy.

14.3.8   Your Rights
In addition to your rights under 11. YOUR RIGHTS in the Ennismore Group Privacy Policy, unless otherwise provided by law or administrative regulations of China, you also have the following rights:

  • the right to be informed about and the right to decide on the processing of your personal information, as well as the right to restrict or deny us from processing of your personal information;
  • the right to access or make copies of your personal information from us;
  • the right to have your personal information transferred to another entity that you designate, provided that the conditions prescribed by the national cybersecurity authority are met;
  • the right to ask us to correct or complete your personal information;
  • the right to withdraw your consent if our processing activities are based on your consent;
  • the right to ask us to explain the rules of processing your personal information; and
  • the right to ask us to explain decisions we make through automated decision-making, if the decision has a material impact on your rights and interests, as well as the right to refuse the making of decisions by us solely by means of automated decision-making.

As introduced in section 11 in the Ennismore Group Privacy Policy you may contact data@ennismore.com or the hotel directly in the event that you wish to exercise any of your rights.

In addition, if you use our App you can also correct, complete or delete some of your personal information by clicking on the “Account” button, then clicking on “Advanced settings” and then on “Request the deletion of your account”.

We will deal with your requests to exercise your rights under applicable Chinese laws or administrative regulations promptly and within 15 working days.

14.3.9   Questions and Contacts
In the event that you have any questions about your personal information or wish to exercise any of your rights, please contact the Ennismore Group directly by sending an email to data@ennismore.com.

Alternatively, if you wish to contact our team in China, please contact:
Email: China.DataPrivacy.Team@accor.com
Address: AAPC (Shanghai) Co., Ltd,
12F, Tower C, The PLACE, No.150 Zun Yi Road, Shanghai 200051, P R. China

Annexure A

WHAT PURPOSES IS YOUR DATA COLLECTED FOR AND HOW LONG DO WE RETAIN IT?

The table set out in why we process your data, the lawful basis for the processing and the associated retention period.

Purpose / ActivityLawful basis for processing including basis of legitimate interestRetention period
Meeting our obligations to our customers.

Managing the reservation of rooms and accommodation requests, in particular the creation and storage of legal documents in compliance with accounting standards.

  • Performance of a contract with you.
    Necessary to comply with a legal obligation.
  • Necessary for our legitimate interest in running our business and providing you with requested products and services.
10 years from the booking in accordance with legal obligations.
Managing your stay at the hotel:

  • Managing access to rooms.
  • Monitoring your use of services (telephone, bar, pay TV etc.).
  • Performance of a contract with you.
  • Necessary for our legitimate interest in running our business and providing you with requested products and services.
For the duration of your stay.
Managing our relationship with customers before, during and after your stay:

  • Managing the loyalty program.
  • Inputting details into the customer database.
  • Segmentation analysis based on reservation history and customer travel preferences with a view to sending targeted communications, subject to the requirements of applicable law.
  • Predicting and anticipating future customer behaviours.
  • Developing statistics, commercial scores and carrying out reporting of the same.
  • Providing context data for our marketing tools. This happens when a customer visits an Ennismore Group website or makes a reservation.
  • Understanding and managing the preferences of new or repeat customers.
  • Sending customers newsletters, promotions, tourist, hotel or service offers, offers from Ennismore or its commercial partners, or contacting you by telephone subject to the requirements of applicable law.
  • Performance of our contract with you and for the management of your membership in the loyalty program.
  • Necessary for our legitimate interests in promoting our services, performing direct marketing activities (taking into account your commercial relationship with one of the Ennismore Group’s entities) and improving our services.
  • 3 years from the last date on which you have interacted with us in any way, if you are not a member of the loyalty programme.
  • 6 years from the last date on which you have interacted with us in any way, if you are a member of the loyalty programme.
Improving our hotel service by:

  • Personalising your check-in, improving the quality of service and customer experience.
  • Processing your personal data through our customer marketing program in order to carry out marketing operations, promote brands and gain a better understanding of your requirements and wishes.
  • Adapting our products and services to better meet your requirements
  • Customising the commercial offers and promotional messages we send you.
  • Informing you of special offers and any new services created by Ennismore Group or one of its subsidiaries or commercial partners.
Performance of contract with you in relation to the management of your membership in the loyalty program.
Necessary for our legitimate interests in promoting our services, performing direct marketing activities (taking into account your commercial relationship with Ennismore Group) and improving our services.
  • 3 years from the last date on which you have interacted with us in any way, if you are not a member of the loyalty program.
  • 6 years from the last date on which you have interacted with us in any way, if you are a member of the loyalty program.
Use a trusted third party to cross-check, analyse and combine your collected data at the time of booking or at the time of your stay, in order to determine your interests and develop your customer profile and to allow us to send you personalized offers.Necessary for our legitimate interests in promoting our services, performing direct marketing activities (taking into account your commercial relationship with one of the Ennismore Group’s entities) and improving our services.
  • 3 years from the last date on which you have interacted with us in any way, if you are not a member of the loyalty program.
  • 6 years from the last date on which you have interacted with us in any way, if you are a member of the loyalty program.
Improving Ennismore Group services, in particular:

  • Carrying out surveys and analyses of questionnaires and customer comments.
  • Managing claims/complaints.
  • Offering you the benefits of our loyalty program.
  • Performance of contract with you (for the management of your membership in the loyalty program).
  • Necessary for our legitimate interests in promoting our services, performing direct marketing activities (taking into account your commercial relationship with one of the Ennismore Group’s entities) and improving our services.
  • 3 years from the last date on which you have interacted with us in any way, if you are not a member of the loyalty program.
  • 6 years from the last date on which you have interacted with us in any way, if you are a member of the loyalty program.
  • 6 years from the date of closure of your file in case of a claim or a complaint.
Securing and enhancing your use of Ennismore Group websites, applications and services by:

  • Improving navigation.
  • Maintenance and support.
  • Implementing security and fraud prevention.
Necessary for our legitimate interests in running our business, provision of administration and IT services and network security to prevent fraud13 months from the collection of the information.
Internal management of lists of customers having behaved inappropriately during their stay at the hotel (aggressive and anti-social behaviour, non-compliance with safety regulations, theft, damage and vandalism or payment incidents).Necessary for our legitimate interests in running our business and to prevent fraud and the abuse of our property and staff.Up to 122 days from the recording of an event.
Securing payments by determining the associated level of fraud risk. As part of this analysis, Ennismore and hotels may use the Ennismore Group risk prevention service provider to refine their analysis.

Depending on the results of the investigations carried out, Ennismore Group may take security measures, in particular Ennismore Group may request the use of a different booking channel or for the use of an alternative payment method.

These measures will have the effect of suspending the execution of the booking or, if the result of the analysis does not guarantee the safety of the order, of cancelling it.

Fraudulent use of a means of payment leading to payment default may result in the entry of data in the Ennismore Group incident file, which may lead Ennismore Group to block future payments or carry out additional checks.

Necessary for our legitimate interests in running our business and to prevent fraud.
  • 90 days to our database to allow for analysis and controls and then 2 years in a separated database used for improving the system.
  • In case of recording in the incident file, 2 years from recording or until regularization of the situation if earlier.
Securing properties and persons and preventing non-payments.

For these reasons, some hotels have a feature that allow them to include in the category of “ineffective” customers, any customer whose behaviour has been inappropriate in the following ways: aggression and rudeness, non-compliance with the hotel contract, failure to observe safety rules, theft, damage and vandalism, or payment issues.

The status of “ineffective” may cause the hotel where this listing originated to refuse a customer’s reservation when he/she returns to the same hotel.

Necessary for our legitimate interests in running our business, securing properties and persons and preventing non-payments.122 days from registration.
Using services to search for persons staying in Ennismore Group hotels in the event of serious events affecting the hotel in question (natural disasters, terrorist attacks, etc.).Protection of the vital interests of the guests.For the duration of the event.
Conforming to any applicable legislation (for example, storing of accounting documents), including:

  • Managing requests to unsubscribe from newsletters, promotions, tourist offers and satisfaction surveys.
  • Managing data subject’s requests regarding their personal data.
Necessary to comply with a legal obligation.As stipulated in the respective country’s legislation.