Privacy Policy
Hotel St George by Nina Privacy Policy
Last Revised on January 30th 2020
Outlook Of This Policy
This Privacy Policy applies globally but depending on where you live, some specific provisions of this Privacy Policy may not apply to you.
For the purposes of EU Privacy Law, depending on the type of Personal Data processing described in this Privacy Policy, Hotel St George by Nina may be operating as a sole or joint Controller. If operating as joint Controllers, both entities jointly determine the means and purposes of the processing of your Personal Data. What this means for you is that you can exercise your rights against either of the joint Controllers by contacting either company as set out below.
In some of the situations described in this Privacy Policy, the hotel where you made a booking and/or stay will also process your data as a (joint or sole) Controller.
We are committed to protecting the privacy of our users and customers.
Hotel St George by Nina is committed to protecting and respecting your privacy. We adhere to the Privacy Policy (the “Policy”) together with any disclaimers sets out the basis on which any personal data we collect from you or that you provide to us, or that is provided to us relating to you (“Data”) by any means will be processed. Please read the following carefully to understand our use of personal data. Please note that the Policy relates only to living individuals in relation to personal data relating directly to themselves, and not to persons in any other capacity.
This Privacy Policy is intended to inform you how we gather, define, and use Personal Data that you provide to us when using our websites and mobile applications or when relying on our hospitality services. Please take a moment to read this Privacy Policy carefully. Please note that if you plan to submit someone else’s Personal Data to us, for instance when making a booking on their behalf, you may only provide us with that person’s details with their consent and after they have been given access to information about how we will use their details, including the purposes set out in this Privacy Policy.
Definitions
Affiliates and Subsidiaries: Any corporation, firm, partnership or other entity which directly or indirectly controls, is controlled by, or is under common control with Hotel St George by Nina.
Controller: The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data.
EU Privacy Law: Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of Personal Data and on the free movement of such data (the “GDPR”), as well as any legislation and/or regulation implementing or created pursuant to the GDPR and the e-Privacy legislation, or which amends, replaces, re-enacts
or consolidates any of them, and all other national applicable laws relating to the processing of Personal Data and privacy.
Processor: A natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the controller.
Recipient: A natural or legal person, public authority, agency or another body, to which the Personal Data are disclosed, whether a Third Party or not.
Third Party: A natural or legal person, public authority, agency or body other than the data subject, controller, Processor and persons who, under the direct authority of the controller or processor, are authorized to process Personal Data.
Supervisory Authority: An independent public authority which is established by a Member State pursuant to Article 51 of the GDPR.
Personal Data: Any information relating to an identified or identifiable natural person (“Data Subject”). An identifiable natural person is one who can be identified, directly or indirectly, by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
Processing: Any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Standard Contractual Clauses: Sets of standard contractual clauses for transfers as adopted by the European Commission for the international transfer of Personal Data.
Personal Data Breach: A breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, Personal Data transmitted, stored or otherwise processed.
Hotel Booking Process
In the context of the hotel booking process – whether this takes place online on one of our brand websites, through an online booking channel, through our call centre or directly at the hotel – we process your Personal Data for the purpose of (i) enabling you to reserve a room in the hotel of your choice; (ii) verifying the availability of the hotel and to administer the booking; (iii) sending you a booking confirmation; and (iv) sending you non-commercial pre-arrival emails. You may unsubscribe from pre-arrival emails at any time by clicking on the unsubscribe link in the emails sent to you.
Processed data categories
Address, Date of arrival and departure, Email address, First name / Last name, First name / Last name of adult co-guest(s), Payment card type, number and expiration date, Phone number, Title
Source of data
Depending on the booking mechanism used:
Directly from you through the online booking form
Through the online booking channel, you used to make the booking
Ground for processing
Processing is necessary to take steps to enter into and perform a contract.
Recipients of data
IT service providers involved in the (online) booking process
Email communications service provider
Interrupted or Incomplete Online Booking Process (Abandoned Cart)
When you are booking online but for some reason are not able to finalise the booking process, we process your Personal Data for the purpose of enabling you to easily continue the online booking process by sending you an email with a link to the online booking form, which is pre-filled on the basis of the data you had already provided in the form.
Processed data categories
Address, Date of arrival and departure, Email address, First name / Last name, First name / Last name of adult co-guest(s), Payment card type, number and expiration date, Phone number, Title
Source of data
Directly from you through the online booking form
Ground for processing
It is in Hotel St George by Nina’s legitimate interest as a business to re-market an interrupted or incomplete booking process. In this context, Hotel St George’s business interests prevail over yours.
Recipients of data
Email communications service provider
Provider of targeted advertisements
IT service providers involved in the (online) booking process
Guest Satisfaction Surveys
We may send you guest satisfaction surveys by email during or after your stay to enable us to measure the performance of our guesthouse. You may unsubscribe from our guest satisfaction survey emails at any time by clicking on the unsubscribe link (OPT OUT) in the emails sent to you
Processed data categories
Country of residence, Date of arrival and departure, Email address, first name / Last name, Nationality, Stay details
Source of data
Depending on the booking mechanism used:
Directly from you through the booking form
Through the online booking channel, you used to make the booking
IT service providers involved in the (online) booking process
Ground for processing
Processing is necessary to ensure and follow up on the good performance of the contract you have with us.
Recipients of data
Guest satisfaction survey provider
Service Emails Analytics
In the context of service emails, which includes guest satisfaction survey emails and any non-commercial pre-arrival emails concerning your booking, we may process and collect your Personal Data, and notably whether you have opened and actioned a service email, for analytical purposes in order to measure the click-through rate and improve the content of our service emails. You may unsubscribe from our service emails at any time by clicking on the unsubscribe link in the service emails sent to you.
The information below describes the types of data we process for this purpose, where we get your data from, the ground we rely on to carry out the processing, and who we may share your data with.
Processed data categories
Email address, Email clicking behaviour, Email opening behaviour, First name / Last name,
Source of data
From our email analytics service provider
Ground for processing
It is in Hotel St George by Nina’s legitimate interest as a business, to understand the email clicking behaviour of its guests in order to determine whether improvements are needed. In this context, Hotel St George’s business interests prevail over yours.
Recipients of data
Other Hotel St George by Nina entities involved
IT service providers
Email analytics service provider
Hotel Guests
Hotel Check-In and Check-Out
When staying at the hotel of your choice, we will collect and process your Personal Data for the purposes of (i) registering your arrival and departure at the hotel; (ii) assigning you a key card to your room; (iii) obtaining a credit card guarantee or hotel deposit to ensure payment of your stay; (iv) managing (and archiving) your hotel registration card; (v) creating or updating your profile in our hotel management system; (vi) assessing your eligibility for a room upgrade and managing this if applicable; (vii) managing payment of your stay; (viii) establishing, printing or sending an invoice for your stay; and (ix) paying a commission to your travel agent (if applicable).
In the event you have booked a room in one of our hotels but do not show up – without cancelling – on the date of arrival communicated, we will process your Personal Data for the purposes of (i) cancelling your stay and any other reservation you may have made; and (ii) managing, processing and settling any outstanding payment that may be due.
Processed data categories
Address, Bookings (hotel etc.), Date of arrival and departure, Email address, First name / Last name, First name / Last name of adult co-guest(s), Payment card type, number and expiration date, Phone number, Title
Source of data
Depending on the booking mechanism used:
Directly from you through the booking form
Through the online booking channel, you used to make the booking
Directly from you through the hotel registration card
Ground for processing
Processing is necessary to perform the contract you have with us.
Recipients of data
Other entities involved
IT service providers
Credit Limit Reports
To ensure payment for all guests staying in a hotel room, each hotel guest is asked for a credit card or deposit upon arrival. In order to ensure that you do not exceed your credit limit during your stay, we produce a credit limit report multiple times a day for the purposes of verifying whether your credit limit has been exceeded. These credit limit reports may contain your Personal Data. Please note that in limited circumstances these credit limit reports may be subject to one of our internal financial audits and may therefore be accessed by members of our internal audit department, in order to ensure that our hotels follow guidelines and policies.
Processed data categories
Date of arrival and departure, First name / Last name, Payment card type, number and expiration date
Source of data
Depending on the booking mechanism used:
Directly from you through the booking form
Through the online booking channel, you used to make the booking
Directly from you through the hotel registration card
Ground for processing
Processing is necessary to ensure the performance of the contract you have with us.
Recipients of data
Other Hotel St George by Nina entities involved
IT service providers
Hotel Stay
When you stay in our guesthouse, we endeavour to make your stay as pleasant as possible. This requires processing your Personal Data for the purposes of providing specific services during your hotel stay. These services include (i) housekeeping and maintenance; (ii) returning lost or forgotten items to you; and/or (iii) managing your and your co-guests’ preferences, in order to provide you with a better service during your stay with us.
Processed data categories
Address, Date of arrival and departure, Email address, First name / Last name, First name / Last name of adult co-guest(s), Other preferences, Telephone number
Source of data
Depending on the booking mechanism used:
Directly from you through the booking form
Through the online booking channel, you used to make the booking
Directly from you during your stay at the hotel
Ground for processing
It is in Hotel St George by Nina’s legitimate interest as a business to organise its day-to-day hotel maintenance activities, to personalise the services it provides, and/or to be able to identify the owner of a lost or forgotten item. Taking into account the limited Personal Data processed and shared for such purpose(s), Hotel St George’s business interests prevail over yours.
Recipients of data
Hotel personnel, including housekeeping, maintenance, front desk, and/or other hotel personnel concerned
IT service providers
Hotel Guest Additional Services and Facilities
In many of our hotels you can benefit from additional services and facilities, such as breakfast, taxi requests, free Wi-Fi, etc. In the event you make use of additional services or facilities at one of our hotels, your Personal Data may be processed to (i) manage the booking and use of such additional hotel services and/or facilities; (ii) administer any advance bookings of additional services and/or facilities to your file; (iii) personalise returning guests’ arrival to the hotel and the choice of room amenities and room features; and (iv) manage the expenses incurred for such additional services and/or facilities.
Processed data categories
Date of arrival and departure, Email address, First name / Last name, First name / Last name of adult co-guest(s), Payment card type, number and expiration date, Title
Source of data
Directly from you through the online booking form
Through the online booking channel, you used to make the booking
Directly from you through the hotel registration card
Directly from you when making your additional service/facility request with the hotel front desk
Ground for processing
Processing is necessary to take steps with a view to entering a contract and/or to perform the contract.
Recipients of data
Hotel personnel, including front desk, room service, and/or other hotel personnel concerned
IT service providers
Marketing Communications Analytics
In the context of our newsletters and marketing communications, we may also process and collect your Personal Data, and notably whether you have opened and interacted with one of our communications, for analytical purposes in order to measure the click-through rate and improve the content of our newsletters and marketing communications.
Processed data categories
Email address, Email clicking behaviour, Email opening behaviour, First name / Last name
Source of data
From our email analytics service provider
Ground for processing
It is in Hotel St. George by Nina's legitimate interest as a business to understand the click-through rate of its emails in order to determine whether improvements are needed. In this context, Hotel St. George by Nina's business interests prevail over yours.
Recipients of data
Other entities involved
IT service providers
Email analytics service provider
Should you have a query or feedback, including the exercise of one of your rights under the GDPR, you may contact us through the contact forms available on our website(s). In such context, we may process your Personal Data for the purposes of handling and providing an answer to your query or request or to follow up on your feedback. We also provide other forms on our websites which may assist you in requesting a service from us, such as the best online rate guarantee form.
The information below describes the types of data we process for these purposes, where we get your data from, the ground we rely on to carry out the processing, and who we may share your data with.
Processed data categories
Address, Email address, first name / Last name, stay details, phone number, and any other data you may decide to share with us in open comment boxes.
Source of data
Directly from you through the form
Ground for processing
Ad hoc consent obtained through the contact form
Recipients of data
Other entities involved
IT service providers
Source of data
From our email analytics service provider
Ground for processing
It is in Hotel St George by Nina’s legitimate interest as a business to understand the click-through rate of its emails in order to determine whether improvements are needed. In this context, Hotel St George by Nina’s business interests prevail over yours.
Recipients of data
IT service providers
Email analytics service provider
Analytics
We may use any data you provide to us for analytical purposes to optimise your experience, enhance our marketing, business and operational efficiency, create segments of our customers based on their Personal Data and tailor our offers and promotions to your preferences and consumption habits. In the context of such analytics, we analyse and may combine different data we hold about our guests, including (i) responses to guest satisfaction surveys; (ii) communications guests have with us; (iii) click-through rates for our marketing communications; (iv) our guests’ behaviour on our websites; (v) bookings
Processed data categories
Hotel stay details, Address, Bookings (hotel, etc.), Date of arrival and departure, Title, First name / Last name, First name / Last name of adult co-guest(s), Email address, Telephone number, Payment card type, number and expiration date
Source of data
Directly from you through the online booking form
Through the online booking channel, you used to make the booking
From our email analytics provider
Directly from you when making your additional service/facility request with the hotel front desk
Ground for processing
It is in Hotel St George by Nina’s legitimate interest as a business to understand its guests’ preferences. In this context, Hotel St George by Nina business interests prevail over yours.
Recipients of data
IT service providers
Analytics service provider
Social Media and Online Reviews
We may process your Personal Data obtained through social media platforms (i.eTripAdvisor) concerning our brand for the purposes of (i) addressing your questions or complaints; (ii) monitoring our online reputation; and (iii) improving our services and identifying opportunities on which we can focus.
Some of our social media pages allow users to submit their own content. Please remember that any content submitted to one of our social media pages can be viewed by the public, and you should be cautious about providing certain personal information (e.g., financial information or address details) via these platforms. We are not responsible for any actions taken by other individuals if you post personal information on one of our social media platforms (e.g., Facebook or Instagram). Please also refer to the respective privacy and cookie policies of the social media platforms you are using.
Processed data categories
Any Personal Data you may decide to share with us or published on social media or in other online reviews about us
Source of data
Directly from you through publicly accessible social media pages, online booking channels or other (review) websites
From our online reputation monitoring service provider
Ground for processing
It is in Hotel St George by Nina’s legitimate interest as a business to understand its guests’ preferences. In this context, Hotel St George by Nina’s business interests prevail over yours.
Recipients of data
Online reputation monitoring service provider
Your Rights - Under EU Privacy Law
If you are in the EU, EU Privacy Law grants specific rights, summarised below, which you can in principle exercise free of charge, subject to statutory exceptions. These rights may be limited, for example if fulfilling your request would reveal Personal Data about another person, or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping. To exercise any of your rights, you can file a request via email at hsg@bynina.ie
Should you have unresolved concerns, you have the right to lodge a complaint with a Supervisory Authority where you live or where you believe a breach may have occurred. We encourage you to come to us in the first instance but, to the extent that this right applies to you, you are entitled to complain directly to the relevant Supervisory Authority.
1. Right to withdraw consent
Wherever we rely on your consent, you will be able to withdraw that consent at any time you choose and at your own initiative by logging in to your account on our website (if you have one) or by contacting us at hsg@bynina.ie The withdrawal of your consent will not affect the lawfulness of the collection and processing of your data based on your consent up until the moment where you withdraw your consent. Please note that we may have other legal grounds for processing your data for other purposes, such as those set out in this Privacy Policy.
2. Right to access and rectify your data
You have the right to access, review, and rectify your Personal Data. You may be entitled to ask us for a copy of your information, to review or correct it if you wish to rectify any information like your name, email address, or any other preferences, you can easily do so by contacting us at hsg@bynina.ie. You may also request a copy of the Personal Data processed as described in this Privacy Policy.
3. Right to erasure
In accordance with EU Privacy Law, you have the right to erasure of your Personal Data processed by us as described in this Privacy Policy in case it is no longer needed for the purposes for which the Personal Data was initially collected or processed or in the event you have withdrawn your consent or objected to processing as described in this Privacy Policy and no other legal ground for processing applies. Should you wish to have your Personal Data erased, please file a request via email at hsg@bynina.ie
4. Right to restriction of processing
Under certain circumstances described in EU Privacy Law, you may ask us to restrict the processing of your Personal Data. This is for example the case when you contest the accuracy of your Personal Data. In such event, we will restrict the processing until we can verify the accuracy of your data.
5. Right to object to processing
Under certain circumstances described in EU Privacy Law, you may object to the processing of your Personal Data, including where your Personal Data is processed for direct marketing purposes.
6. Right to data portability
Where you have provided your data directly to us and where the processing is carried out by automated means and based on your consent or the performance of a contract between you and us, you have the right to receive the Personal Data processed about you in a structured, commonly used and machine-readable format, and to transmit this data to another service provider.
Your Rights - Non-Eu Users
Depending on where you are located you will have different rights in respect of your Personal Data, and we will comply with the relevant requirements of applicable laws and this Privacy Policy.
Security Measures
Appropriate technical and organisational measures are implemented in order to ensure an appropriate level of security of your Personal Data, including but not limited to encryption techniques, physical and IT system access controls, obligations of confidentiality, etc.
In the event Personal Data is compromised as a result of a Personal Data Breach we will make the necessary notifications, as required under applicable laws.
What Rules Apply to Children?
We do not knowingly collect or solicit Personal Data from anyone under the age of 18 or knowingly allow such persons to book a room in one of our hotels.
In the event we learn that we have collected Personal Data from a child under the age of 18 without verification of parental consent, steps will be taken promptly to remove that information. If you believe that we have or may have information from or about a child under 18 years of age, please contact us at hsg@bynina.ie
How Is Your Personal Data Shared with Third Parties?
We only share or disclose information as described herein, including with Third Parties.
Your Personal Data will also be shared with government authorities and/or law enforcement officials if required for the purposes above, if mandated by law or if required for the legal protection of the Controller(s) legitimate interests in compliance with applicable laws. In addition, we may share your Personal Data and other information with a successor to all or part of our business, where this is in our legitimate interests in facilitating a business sale and in this context our business interests prevail over yours. For example, if parts of our business or assets are sold, we may disclose user information as part of that transaction, subject to applicable law.
How Long Will We Keep Your Personal Data?
We retain your Personal Data for as long as is required to fulfil the activities set out in this Privacy Policy, for as long as otherwise communicated to you or for as long as is permitted by applicable law. For example, we may retain your Personal Data if it is reasonably necessary to comply with any legal obligations, meet any regulatory requirements, resolve any disputes or litigation, or as otherwise needed to enforce this Privacy Policy and prevent fraud and abuse.
To determine the appropriate retention period for the information we collect from you, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of the data, the purposes for which we process the Personal Data, and whether we can achieve those purposes through other means, and the applicable legal requirements.
Does This Privacy Policy Apply to Third Party Websites?
If you click on a link to a Third-Party website, you will be taken to a website we do not control, and our Privacy Policy will no longer be in effect. Your browsing and interaction on any other website are subject to the terms of use and privacy and other policies of such Third-Party website. Read the privacy policies of other websites carefully. We are not responsible or liable for the information or content on such Third-Party websites.
What Happens If We Make Modifications to this Policy?
We reserve the right to modify and update this Privacy Policy from time to time. We will bring these changes to your attention should they be indicative of a fundamental change to the processing or be relevant to the nature of the processing or be relevant to you and impact your data protection rights.
How to Contact Us
Questions, comments, remarks, requests or complaints regarding this Privacy Policy are welcome and should be addressed to hsg@bynina.ie