Privacy Policy

The Houben Hotel and its affillates (collectively, “The Houben Hotels”, “we, “our’ or “us”) have prepared this Privacy Policy to inform “You” ( the reader of this privacy policy notice occupying the role(s) of hotel guest and / or user of Our Hotel websites, mobile applications or any web based programs ) with respect as to how we collect, use, disclose, transfer and safeguard your personal data. This Privacy Policy applies to all websites, mobile applications and all web based programs including official social media profiles which link to this Policy and are published by The Houben Hotels and describes the personal data collected or processed when You use The Houben Hotel services, facilities, websites, mobile applications and social media official profiles or any other mechanism operated by The Houben Hotels that tracks and processes your personal data.

Our websites contain links to third party websites which are not subject to this privacy policy. We are not responsible for their content, use of your personal information, or security practices.

For the purpose of this Privacy Policy, “Personal Data’ means any information relating to an identified or identifiable natural person.

  1. What Personal Data do we collect?

Your Personal Data collected by The Houben Hotels can be classified into the following:

Type of Personal DataDetails
1. Personal detailsSuch as full name, ID number, facial photo, gender, date of birth, nationality, country of residence – all information pertaining to your official documents such as your passport or national ID – as well as other identification numbers such as identification numbers of family members and children, ages of children.
2.Contact detailsSuch as Addresses, phone numbers, fax numbers, email addresses, LINE IDs, Facebook accounts, Instagram accounts, Facebook IDs, Twitter ID, Tiktok ID, Google IDs, and any other social media platform IDs that are affiliated to your online accounts which may be used to contact you.
3.Financial detailsSuch as bank account number, credit card number and debit card number, and any form of payment information that we may have to process when welcoming You as a guest or customer.
4.Membership detailsSuch as account details, membership card numbers, reward points, member type, customer type, member join/registration date and month, membership period, bank account and payment details, service and product applications (e.g.membership application, insurance application) or any other form of personal information related to our membership system and programs.
5.Technical detailsSuch as IP address of computer, type of browser, cookies data, time zone setting, operational system, platform and all other aspects of the technology of the equipment used to access the website and online application systems that belong to Our Hotels.
6.Profile DetailsSuch as username and password, purchase history, interests, likes and information from survey responses. This also includes any personal characteristics that may be indicated from your profile information which You provide us with or / and has been processed by our systems.
7.Sensitive DetailsSuch as ethnicity, beliefs, religion, health information (including food and general allergies) and biometric data including criminal history data. In the event that we have unintentionally receired It and have no intention of collecting such data, and the data is not intended to be used to faciltate your stays at our hotels, we will not process your sensitive data.
  1. Purposes and legal ground for processing personal data

We will use your Personal Data for a number of different purposes. In all case we must have a reason and a legal ground for processing your personal data. Some of the most common legal grounds we rely on are briefly described as follows:

1. CONSENTWe process Personal Data based on consensual basis. In the event that you have provided us with explicit consent, we will process your Personal Data within the scope of the purpose of which we have informed you such as: To communicate and provide marketing and promotion material to you such as Promotions, special offers, loyalty programs, reward programs, prize draws, and other offer promotions. Marketing and Communications: To develop and improve our services to you – such as performing market research, analytics and/or profiling, developing new products and services, improving the effectiveness of our website, your hotel experience, our various types of communications, advertising campaigns, and promotional activitiesPersonalisation, profiling and data analytics: recommending products and services that might be of interest to you, identifying your preferences and personalising your experience; maintaining, safeguarding and improving the quality of our products and services, in particular by performing and analysing satisfaction surveys and guest comments, by processing your personal data in our centralised guest database enabling us to recognise you as a returning guest, to better appreciate your expectations and wishes, to improve the quality and individual character of our communication with you and to create offerings tailored to you.
2. PERFORMANCE OF CONTRACTTo provide products and services to you – such as completing your reservations, sending you reservation confirmations, carrying out financial transactions and registering you for programme membership, fulfilling a request for information, customising our services to your preferences, earning and redeeming rewards, keeping proper records of your transactions with us.
3. LEGAL OBLIGATIONWe process personal data in accordance with any applicable law, regulation, legal process or enforceable governmental request.
4. VITAL INTERESTWe process personal data under the necessity of emergency medical situations to protect your life or that of another natural person.
5. LEGITIMATE INTERESTWe process Personal Data under the necessity of taking steps for our legitimate interests or those of other individual or juristic persons who are not overriding your interests or your fundamental rights and freedoms. For the creation of a database for analysing and proposing services or products of The Houben Hotel.To enforce applicable Terms of Use, including investigation of potential violations.To detect, prevent, or otherwise address fraud, security or technical issues.To protect against harm to the rights, property or safety of The Houben Hotel, our users or the public as required or permitted by law.
  1. Period of storage of personal data and criteria for defining such period

We process and store your personal data for as long as required for us to fulfil the purpose for which we obtained it, and to comply with our legal and regulatory obligations. We will then erase and destroy your Personal Data except as may be required, by applicable laws or for protection of our interest. However, we may have to retain your Personal Data for a longer duration, as required by applicable law.

  1. Sharing & Disclosure

As reasonably necessary for us in delivering our products and services to you and for the purposes set out in this Privacy Policy, we may share your personal information with the parties below. The specific kind of information we share will depend on your activities with us and only to the extent as required or permitted by law, and/or with your consent.

  • Our group entities, hotels and residences managed and operated by us.
  • Our business partners and third parties involved in the delivery of our products and services to you – including those involved in the sale of all or part of our business operations or assets and those for business, operational and general administration
  • Our marketing and advertisement partners
  • Third party services providers which process data (including personal information) for us, based on our instructions and in compliance with our Privacy Policy and any other appropriate confidentiality and security measures.
  • Our agents, advisors, consultants, other third-party suppliers and/or services providers to assist us to operate effectively and provide you with the best experiences with our services.
  • Social Media Platforms: Where you choose to interact with us through social media e.g. Facebook, Google, Instagram, your interaction with these programs typically allows the social media company to collect some information about you through digital cookies they place on your device and other tracking mechanisms.
  • International transfers of your Personal Data we may outsource the processing of certain functions and/or information to third parties, which may be located in countries other than the country where your information is collected or your country of residences. When we do outsource the processing of your personal information to third parties or provide your personal information to third-party services providers, we oblige those third parties to protect your personal information with appropriate security measures.
  • Other third parties when we have your consent or are otherwise permitted by law to do so.
  1. How we protect your Personal Data?

We take appropriate technical and organizational measures pursuant to applicable laws to protect your personal data against illegal or accidental destruction, loss or alteration as well as unauthorized disclosure and access. We implement appropriate technical and organizational measures that seek to ensure a level of security appropriate to the risk, taking into account technological reality, cost, the scope, context and purposes of processing weighted against the severity and likelihood that the processing could threaten individual rights and freedoms.

  1. Data Subject Rights

6.1 Right to Access Personal Data: You have the right to request access and to obtain a copy of your Personal Data that we collect, use or disclose related to You under our responsibility.

6.2 Right to Rectification: You have the right to request modification of the data, Including the correction or errors and the updating of incomplete information.

6.3 Right to Erasure: You have the right to request that we ‘erase”‘ your Data in certain circumstances.

6.4 Right to Restrict Data Processing: You have the right to have your Personal Data restricted in some circumstances as permitted by applicable law.

6.5 Right to be notified: You have the right to be notified about the uses of personal data in a clear manner and be told the actions that can be taken if You feel your rights are being impeded. You also have the right to be informed of any rectification or erasure of your personal data.

6.6 Right to Data Portability: You have the right to request that we transfer your Data to another third party. This right of data portability only applies to certain types of Data.

6.7 Right to withdraw consent: You have the right to withdraw your consent on which the collection, storage, use, or disclosure is based at any time. As a result, we will stop the processing of your information as soon as possible and if we do not have other lawful basis which allows us to process your Personal Data, we will then delete your information.

6.8 Lodge a complaint: You have the right to lodge a complaint with the relevant supervisory authority where You believe our collection, use or disclosure of your Personal Data is unlawful or noncompliant with applicable data protection law.

  1. Cookies

Our websites use cookies to distinguish you from other users of the relevant website. This helps us provide you with a good experience when you browse our websites and also allows us to improve our websites. For detailed information on the cookies we use and the purposes for which we use them, please see our Cookies Policy.

  1. Changes to the Privacy Notice

We reserve the right to make changes to this Notice from time to time to ensure that it is appropriate and in accordance with the applicable laws. Please check frequently to see any updates or change to our Privacy Notice.

  1. Other sites

The website may contain links to other third-party websites. If you follow a link to any of those third-party websites, please note that they have their own privacy policies and that we do not accept any responsibility or liability for their policies or processing of your personal information. Please check these policies before you submit any personal information to such third-party websites.

  1. To contact us

If you wish to exercise data subject rights or if you have any questions or complaints, you can contact us via [email protected]

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