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.

1. Legitimacy: We will collect and process your personal data only for the purposes described in this Charter.
2. 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.
3. Storage: We will hold your personal data for the period necessary for processing the same in compliance with the provisions of the law.
4. 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".
5. 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.
6. 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.