1. THE HÔTEL KOENER
SÀRL’ COMMITMENT TO PROTECTING PRIVACY
Hôtel Koener
Sàrl
14, Grand-Rue
L-9710 Clervaux
Grand-Duché de Luxembourg
Because we consider you an important customer, our
first priority is to offer you exceptional times and stays in Clervaux. Your
complete satisfaction and confidence in Hôtel Koener’ are absolutely essential
to us.
That's why, as part of our commitment to meeting your expectations, we have set
up a customer privacy protection policy. This Charter formalizes
our commitments to you and describes how Hôtel Koener Sàrl uses your personal data.
2. CONSENT
"Personal data" means any information
collected and logged in a format that allows you to be identified personally,
either directly (e.g. name) or indirectly (e.g. telephone number) as a natural
person. Before providing us with this information, we recommend that you read
this document describing our customer privacy protection policy.
This Personal Data Protection Charter forms part of the terms and conditions
that govern our hotel services. By accepting these terms and conditions, you
expressly accept the provisions of this Charter.
3. HÔTEL KOENER SÀRL PRINCIPLES
FOR PROTECTING YOUR PERSONAL DATA
The seven principles below are applicable within Hôtel Koener Sàrl Transparency: When
collecting and processing your personal data, we will communicate all
information to you and inform you of the purpose and recipients of the data.
- Legitimacy: We will collect and process your personal data only
for the purposes described in this Charter.
- Relevance
and accuracy: We will only collect
personal data that is necessary for data processing. We will take all
reasonable steps to ensure that the personal data we hold is accurate and up to
date.
- Storage: We will hold your personal data for the period
necessary for processing the same in compliance with the provisions of the law.
- Access,
rectification, opposition: You may access, modify, correct or delete your
personal data. You may also oppose the use of your personal data, particularly
to avoid receiving sales and marketing information. The details of the
department to contact in this respect are shown below (§13) in the clause "Access
and modification".
- Confidentiality
and security: We will ensure reasonable technical and organizational measures
are in place to protect your personal data against alteration or accidental or
unlawful loss, or unauthorized use, disclosure or access.
- Sharing
and international transfer: We may share your personal data within the Hôtel Koener Sàrl or with third
parties (such as commercial partners and/or service providers) for the purposes
set out in this Charter. We will take appropriate measures to guarantee
security when sharing or transferring such data.
For any questions concerning the seven principles of Hôtel Koener Sàrl’ Data Protection,
please contact the Data Privacy controller whose details appear in the
clause "Access and modification".
4. SCOPE OF APPLICATION
This Charter applies to
all data processing implemented in our subsidiary and managed hotels, i.e.
those operating under an Hôtel Koener
Sàrl’ Group brand name
5. WHAT PERSONAL DATA IS
COLLECTED?
At various times, we will be obliged to ask you, as an
Hôtel Koener Sàrl’ customer, for
information about you and/or members of your family, such as:
- 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)
- 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)
- Your questions/comments, during or following a stay in one of our
establishments.
The information collected in relation to persons under
18 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 Data
Privacy department (
"Access and modification" clause) to
arrange for this information to be deleted.
We do not deliberately collect sensitive information, such as information
concerning race, ethnicity, political opinions, religious and philosophical
beliefs, union membership, or details of health or sexual orientation.
Moreover, depending on applicable local laws, other information could be
considered sensitive, such as your credit card number, your leisure activities,
personal activities and hobbies, and whether or not you are a smoker. We may be
obliged to collect such information in order to meet your requirements or
provide you with an appropriate service, such as a specific diet.
In this case, depending on the laws in force in certain countries, your prior
consent may be required with regard to the collection of sensitive information.
6. WHEN IS YOUR PERSONAL
DATA COLLECTED?
Personal data may be collected on a variety of
occasions, including:
1. Hotel
activities:
- Booking a
room
- Checking-in
and paying
- Eating/drinking
at the hotel bar or restaurant during a stay
- Requests,
complaints and/or disputes.
2.
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.
3.
Transmission
of information from third parties:
- Tour
operators, travel agencies, reservation systems, and others
4. Internet
activities:
- Connection
to any of Hôtel Koener Sàrl’
websites (IP address, cookies)
- Online
forms (online reservation, questionnaires, Hôtel Koener Sàrl pages on social networks, network login devices
such as Facebook login etc.).
7. FOR WHAT PURPOSES?
We collect your personal data for the purposes of:
1.
Meeting
our obligations to our customers.
2.
Managing
the reservation of rooms and accommodation requests:
- Creation
and storage of legal documents in compliance with accounting standards.
3.
Managing
your stay at the hotel:
- Monitoring
your use of services (telephone, bar, pay TV etc.)
- Managing
access to rooms
- Internal
management of lists of customers having behaved inappropriately during their
stay at the hotel (aggressive and anti-social behavior, non-compliance with the
hotel contract, non-compliance with safety regulations, theft, damage and
vandalism, or payment incidents).
4.
Improving
our hotel service, especially:
- Processing
your personal data in 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
- Customizing
commercial offers and the promotional messages we send to you
- Informing
you of special offers and any new services created by Hôtel Koener Sàrl or one of its subsidiaries.
5.
Managing
our relationship with customers before, during and after your stay:
- Providing
details for the customer database
- Segmentation
operations based on reservation history and customer travel preferences with a
view to sending targeted communications
- Predicting
and anticipating future behaviors
- Developing
statistics and commercial scores, and carrying out reporting
- Providing
context data for the offer push tool when a customer visits a Group website or
makes a reservation
- Knowing
and managing the preferences of new or repeat customers
- Sending
you newsletters, promotions and tourist, hotel or service offers, or offers
from Hôtel Koenes, partners, or
contacting you by telephone
- Managing
requests to unsubscribe from newsletters, promotions, tourist offers and
satisfaction surveys
- Taking
into account the right to object
6.
Use
a trusted third party to cross-check, analyze and apply certain devices to your
collected data at the time of booking or at the time of your stay, in order to
determine your interests and your customer profile, and to allow us to send you
personalized offers.
7.
Improving
Hôtel Koener Sàrl services,
especially:
- Carrying
out surveys and analyses of questionnaires and customer comments
- Managing
claims/complaints
8.
Securing
and enhancing your use of Hôtel Koener
Sàrl websites, especially:
- Improving
navigation
- Implementing
security and fraud prevention.
9.
Conforming
to local legislation (for example, storing of accounting documents).
8. CONDITIONS OF
THIRD-PARTY ACCESS TO YOUR PERSONAL DATA
To guarantee you the right of access and amendment ("Access
and modification" clause), we have to share your personal data
with internal and external recipients subject to the following conditions:
A: Within the Hôtel Koener Sàrl in
order to offer you the best service, we can share your personal data and give
access to authorized personnel from the Group, including:
- Hotel staff
- Reservation staff using Hôtel
Koener Sàrl reservation tools
- IT departments
- Commercial
partners and marketing services
- Medical services
if applicable
- Legal services
if applicable
Generally, any appropriate person within Hôtel Koener Sàrl entities for certain specific categories of
personal data.
B: 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 centers, banks,
credit card issuers, external lawyers, dispatchers, printers.
- Commercial
partners: Hôtel Koener Sàrl may,
unless you specify otherwise to the Data Privacy department, enhance your
profile by sharing certain personal information with its preferred commercial
partners. In this case, a trusted third party may cross-check, analyze and
apply certain devices to your data. This data processing will allow Hôtel Koener Sàrl and its privileged
contractual partners to determine your interests and your customer profile, and
will allow us to send you personalized offers.
C: Local authorities: We may also be obliged to send
your information to local authorities if this is required by law or as part of
an inquiry and in accordance with local regulations.
9. PROTECTION OF YOUR
PERSONAL DATA DURING INTERNATIONAL TRANSFERS
For the purposes set out in Clause 7 of this Charter,
we may transfer your personal data to internal or external recipients who may
be in countries offering different levels of personal data protection.
Consequently, in addition to implementation of this Charter, Hôtel Koener Sàrl employs appropriate
measures to ensure secure transfer of your personal data to an Hôtel Koener Sàrl entity or to an
external recipient located in a country offering a different level of privacy
from that proposed in the country where the personal data is collected.
Other than those that are required to carry out your reservation, dataflows to
countries having different levels of personal data protection are regulated by
standard contractual manager-to-subcontractor clauses defined by the European
Commission. Dataflows to the United States are made to entities that belong to
Safe Harbor.
10. DATA SECURITY
Hôtel Koener Sàrl takes appropriate technical and organizational
measures, in accordance with applicable legal provisions, to protect your personal
data against illicit or accidental destruction, accidental alteration or loss,
and unauthorized access 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.). When you submit credit
card data when making a reservation, SSL (Secure Socket Layer) encryption
technology is used to guarantee a secure transaction.
11. COOKIES
Use of cookies by Hôtel Koener Sàrl
You are advised that the company Hôtel
Koener Sàrl uses cookies or other tracers on its online booking sites:
hotelkoener.lu, These tracers may be installed on your device depending on the
preferences that you expressed or may express at any time in accordance with
this policy.
1. Why have a cookies policy?
With a view to provide information and ensure transparency, Hôtel Koener Sàrl established this
policy so that you can learn more about:
- The origin and purpose of the information processed when you browse
Hôtel Koener Sàrl Websites
- Your rights with regard to cookies and other tracers used by Hôtel Koener Sàrl
2. What is a cookie?
Cookies and other similar tracers are packets of data used by servers to send
status information to a user's browser and return status information to the
original server through this same browser.
The status information can be a session identifier, a language, an expiration
date, a response field or other types of information. During their validity
period, cookies are used to store status information when a browser accesses
various pages of a website or when the browser returns to this website at a
later point. There are different types of cookies:
- Session cookies, which are deleted as soon as you exit the browser
or leave the website
- Persistent cookies, which remain on your device until their
expiration or until you delete them using the features of your browser
3. Why use cookies?
We use cookies and other tracers primarily for the following purposes: Cookies
strictly necessary for browsing the Hôtel
Koener Sàrl Websites and the ability to use all of their features, and
intended in particular
- Manage authentication of website visitors and the associated
security measures, and ensure proper functioning of the authentication
module
- Optimize the user experience and facilitate browsing, in particular
determining "technical routes" for browsing
- Store information regarding the "cookies" information
banner seen by website visitors who then continue to browse the website
after agreeing to accept cookies on their device
Implement security measures (for example, when you are asked to log
in again for content or a service after a certain period of time, or to
ensure basic operation of Hôtel
Koener Sàrl Websites and use of their major technical features,
such as monitoring of performance and browsing errors, management of user
sessions, etc.)
Cookies for features intended in particular:
- Adapt Hôtel Koener Sàrl
Websites to the display preferences of your device (language, currency,
display resolution, operating system used, configuration and settings of
the display of web pages based on the device you are using and its
location, etc.)
- Store specific information that you enter on Hôtel Koener Sàrl Websites in
order to facilitate and customize your subsequent visits (including
displaying the visitor's first and last names if the visitor has a user
account)
- Allow you to access your personal pages more quickly by storing the
login details or information that you previously entered
Cookies for visitor tracking are aimed at improving
the comfort of users by helping us understand your interactions with Hôtel Koener Sàrl Websites (most
visited pages, applications used, etc.); these cookies may collect statistics
or test different ways of displaying information in order to improve the
relevance and usability of our services.
Advertising cookies are intended to (i) offer you, in
advertising spaces, relevant, targeted content that may be o interest to you
(best offers, other destinations, etc.) based on your interests, browsing
behavior, preferences, and other factors, and (ii) reduce the number of times
that the advertisements appear.
Affiliate cookies identify the third-party website
that redirected a visitor to Hôtel
Koener Sàrl Websites. Social network cookies, set by third parties, allow you to share your opinion
about and content from Hôtel Koener
Sàrl Websites on social networks (for example, the "Share" or
"Like" application buttons for social networks).
The social network applications on Hôtel
Koener Sàrl Websites as mentioned above can in some cases allow the
social networks concerned to identify you even if you did not click on the
application button. This type of button can allow a social network to track
your browsing on Hôtel Koener Sàrl
Websites, simply because your account in the social network concerned is
enabled on your device (open session) while you are browsing.
We recommend that you read the policies of these social networks to familiarize
yourself with how they use the browsing information they may collect,
especially with regard to advertising. These policies must specifically allow
you to make choices on these social networks, particularly by configuring your
user accounts for each of them.
4. Consent
The installation of certain cookies is subject to your consent. Also, when you
first visit the Hôtel Koener Sàrl.
Websites, you are asked whether you agree to the installation of this type of
cookie, which is only activated after your acceptance.
This process is supported by means of an information banner on the home page of
the Hôtel Koener Sàrl Websites,
which informs you that by continuing to browse, you are agreeing to the
installation of cookies that require consent on your device. You can change
your mind at any time using the various methods described in section
"Deleting and/or blocking cookies".
5. Deleting and/or blocking cookies
You have several options for deleting cookies and other tracers.
Browser settings
Although most browsers are set by default to accept cookies, you can, if you
desire, choose to accept all cookies, always block cookies, or choose which
cookies to accept based on their senders. You can also set your browser to
accept or block cookies on a case-by-case basis before they are installed. Your
browser also allows you to regularly delete cookies from your device. Remember
to configure all the browsers in your different devices (tablets, smartphones,
computers, etc.).
Regarding management of cookies and your preferences, configuration varies for
each browser. This is described in the Help menu of your browser, as well as
how to edit your preferences with regard to cookies. For
example:
For
Internet Explorer™:
http://windows.microsoft.com/en-US/windows-vista/Block-or-allow-cookies
For
Safari™:
http://www.apple.com/legal/privacy/en-ww/cookies
For
Chrome™:
http://support.google.com/chrome/bin/answer.py?hl=en&hlrm=en&answer=95647
For
Firefox™:
https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences
For
Opera™:
http://help.opera.com/Windows/10.20/en/cookies.html
Saving a cookie to your device depends on your wishes,
which you can exercise and change at any time and free of charge using the
settings offered by your browser software.
If your browser is set to accept cookies on your device, the cookies embedded
in the pages and content that you view may be temporarily stored in a dedicated
space on your device. They can only be read by their issuer.
However, you can set your browser to block cookies. Keep in mind that if you
set your browser to block cookies, some features, pages and spaces on Hôtel Koener Sàrl Websites will not be
accessible, and we cannot be held responsible in this case.
Specialized advertising platforms
Several professional advertising platforms also give you the option to accept
or block cookies used by companies that are members. These centralized
mechanisms do not block the display of ads; they simply prevent the
installation of cookies that tailor ads to your interests.
For example, you can visit the website http://www.youronlinechoices.com to prohibit the installation of these cookies on
your device. This website is offered by digital advertising professionals
brought together within the European Digital Advertising Alliance (EDAA) and
managed in France by Interactive Advertising Bureau France.
12. STORAGE OF DATA
We retain your personal data only for the period
necessary for the purposes set out in this Charter or in accordance with the
provisions of applicable law.
13. ACCESS AND
MODIFICATION
You have the right to access your personal data
collected by Hôtel Koener Sàrl and
to modify it subject to applicable legal provisions.
You may also exercise your right to object by writing to the address below.
In the event of difficulty exercising your rights, please contact the Data
Privacy department for the Hôtel Koener
Sàrl directly by sending an email to unsubscribe@koenerclervaux.lu or
by writing to the address below:
Hôtel Koener Sàrl
Département Protection des Données Personnelles
(Data Privacy)
Grand-Rue 14
L-9710 Clervaux
Grand Duchy of Luxembourg
For the purposes of confidentiality and personal data
protection, we will need to identify you in order to respond to your request.
You will be asked to include a copy of an official piece of identification,
such as a driver's license or passport, along with your request.
If your personal data is inaccurate, incomplete or not up to date, please send
the appropriate amendments to the Data Privacy department as indicated above.
All requests will receive a response as swiftly as possible and in accordance
with applicable law.
You may also exercise your rights in respect of your personal data that is
stored and processed by a hotel following a stay. To do this, you must contact
the hotel directly.
14. UPDATES
We may modify this Charter from time to time.
Consequently, we recommend that you consult it regularly, particularly when
making a reservation at one of our hotels.
15. QUESTIONS AND
CONTACTS
For any questions concerning the Hôtel Koener Sàrl personal data
protection policy, please contact the Data Privacy department ("Access
and modification"clause).