Customer data privacy and security policy

Terhills Hotel’s commitment to protecting privacy

Because we consider you an important customer, our first priority is to provide you with a great stay. Your complete satisfaction with and trust in Terhills Hotel are essential to us. Therefore, as part of our determination to meet your expectations, we have established a customer data privacy and security policy. This policy formalises our commitment to you and describes how Terhills Hotel NV uses your personal data. The main rules apply within Terhills Hotel (Terhills Hotel NV) are based on seven principles.

Consent

‘Personal data’ means any information collected and recorded in a format that allows you to be personally identified, 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 first read this document containing our customer data privacy and security policy. This customer data privacy and security policy forms part of the terms and conditions governing our hotel services. By accepting these terms, you expressly agree to the provisions of this policy.

Terhills Hotel’s seven principles for protecting your personal data

The seven principles below apply within Terhills Hotel around the world.

1.  Transparency: when collecting and processing your personal data, we communicate all information to you and inform you of the purpose and recipients of the data.
2. Legitimacy: we collect and process your personal data only for the purposes described in this policy.
3. Relevance and accuracy: we only collect personal data that is necessary for the processing of that data. We take all reasonable steps to ensure that the personal data we hold is accurate and up to date.
4.  Storage: we retain your personal data for the time necessary for processing in accordance with the provisions of the law.
5. Access, rectification and opposition: you may access, modify, correct or delete your personal data. You may also object to the use of your personal data, in particular to avoid receiving advertising and marketing information. Details of the department you can contact in this regard are given below (§12) in the clause ‘Access and modification’.
6.  Confidentiality and security: we ensure that reasonable technical and organisational measures are in place to protect your personal data against alteration or accidental or unlawful loss or unauthorised use, disclosure or access.
7. Sharing and international transfer: we may share your personal data with third parties (such as commercial partners and/or service providers) for the purposes of this policy. We take appropriate measures to ensure security when sharing and transferring such data.

For any queries regarding the seven principles of Terhills Hotel’s Customer Data Privacy and Security Policy, please contact the department dealing with personal data protection, as recorded in the clause ‘Access and modification’.

Scope

This policy applies:

1. For all data processing carried out at Terhills Hotel.
2. For all Terhills Hotel N. booking websites

What personal data is collected?

At various times we are required to ask you, as a customer of Terhills Hotel N., for information about you and/or your family members, such as:

• Contact details (e.g. surname, first name, telephone number, e-mail)
• Personal data (e.g. date of birth, nationality)
• Information relating to your children (e.g. first name, date of birth, age)
• Your credit card number (for transactions and reservations)
• Your membership number of Terhills Hotel loyalty programme or other partner programme (e.g. airline loyalty programme)
• Your arrival and departure dates
• Your preferences and interests (e.g. smoking or non-smoking, preferred flooring, type of bedding, type of newspapers/magazines, sports, cultural interests)
• Your questions/comments during or after a stay at one of our establishments.

The information collected regarding persons under 18 years of age is limited to their name, nationality and date of birth. This data can only be provided to us by an adult. We would appreciate it if you could ensure that your children do not send us personal data without your consent (especially over the internet). If this data is sent, please contact the department dealing with personal data protection (clause ‘Access and modification’) to delete this information.

We do not knowingly collect sensitive information, such as data on race, ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health or sexual orientation.

In addition, depending on applicable local laws, other information may also be considered sensitive, such as your credit card number, your leisure activities, personal activities and hobbies, and whether or not you smoke. We may well be required to collect this information to meet your requirements or provide you with an appropriate service, such as a specific diet. In this case, depending on the legislation in force in certain countries, your prior consent may be requested with regard to the collection of sensitive information.

When will your personal data be collected?

Personal data may be collected on various occasions, including:

1. Hotel activities: * Booking a room * Check-in and payment * Dining/drinking at the hotel bar or restaurant during a stay * Requests, complaints and/or disputes
2. Participation in marketing programmes or events: * Signing up for loyalty programmes * Participation in customer surveys (e.g. customer satisfaction survey) * Online games or competitions * Subscription to newsletters to receive offers and promotions via e-mai
3. Transfer of information from third parties: * Tour operators, travel agents, GDS booking systems and others
4. Internet activities: * Connection to Terhills Hotel website (IP address, cookies) * Online forms (online booking, questionnaires, Terhills Hotel pages on social media, network logins such as Facebook sign-in, and so on).

For what purposes?

We collect your personal data for the following purposes:

1. To fulfil our obligations to our customers.
2. To manage room reservations and accommodation requests: * To create and store legal documents in accordance with accounting standards.
3. To manage your stay at the hotel: * Control of your use of services (telephone, bar, pay TV, etc. ) * Management of access to rooms * Internal management of lists of guests who have behaved inappropriately during their stay at the hotel (aggressive and anti-social behaviour, breach of contract with the hotel, violation of safety regulations, theft, damage and vandalism, or payment problems).
4. To improve our hotel service, in particular: * Processing your personal data in our customer marketing programme to carry out marketing activities, to promote brands and to get a better understanding of your requirements and wishes * Adapting our products and services to better meet your needs * Tailoring commercial offers and the advertising messages we send you * Informing you about special offers and new services from Terhills Hotel NV.
5. To manage our relationships with guests before, during and after your stay: * Managing the loyalty programme * Providing data for the guest database * Segmentation based on the guest’s reservation history and travel preferences for the purpose of sending targeted communications * Predicting and anticipating future behaviour * Developing statistics and commercial scores, and implementing reporting * Providing context data for offering a push tool when a guest visits a website or makes a reservation * Knowing and managing the preferences of new or returning guests * Sending you newsletters promotions and tourist offers or offers from the hotel, or offers from Terhills Hotel NV, or contact you directly by telephone * Manage requests to unsubscribe from newsletters, promotions, tourist offers and satisfaction surveys * Take into account the right to object * Use a dedicated telephone service to search for people staying overnight at Terhills Hotel in the event of serious events relating to the hotel in question (natural disasters, terrorist attacks, and so on).
6. To use a trusted third party to cross-check, analyse and apply 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 enable us to send you personalised offers.
7. To improve the Services, in particular: * Conduct surveys and analysis of questionnaires and guest feedback * Manage claims/complaints * Allow you to enjoy the benefits of our loyalty programme.
8. To secure and improve your use of Terhills Hotel websites, in particular: * Improve navigation * Implement security and fraud prevention measures
9. To comply with local legislation (e.g. storage of accounting documents)

Conditions of access by third parties to your personal data

To provide you with the best service, we may share your personal data and give access to it to authorised personnel of Terhills Hotel , including:

• Hotel staff
• Reservations staff using Terhills Hotel’s reservation tools
• IT departments
• Commercial partners and marketing agencies
• Medical services, if applicable
• Legal services, if applicable

a. With service providers and partners: your personal data may be sent to a third party for the purpose of providing services and improving your stay, for example:

1. Externe serviceproviders: IT-onderaannemers, internationale callcenters, banken, creditcardbedrijven, externe advocaten, dispatchers en printers.
2. Commercial partners: Terhills Hotel NV may, unless you indicate that you do not want this to the department in charge of personal data protection, enhance your profile by sharing certain personal data with its commercial partners. In this case, a trusted third party may be used to cross-check, analyse and apply certain equipment to your collected data. This processing of data allows Terhills Hotel NV and its privileged contractual partners to determine your interests and your guest profile, and allows us to provide you with personalised offers.
3. Social networking sites: in order to identify you on the website without filling in a registration form, Terhills Hotel NV has activated Facebook’s sign-in procedure. If you sign up through Facebook’s procedure, you expressly consent to Terhills Hotel NV accessing and retaining the public data on your Facebook account, as well as the other data mentioned during the use of Facebook’s sign-up procedure. Terhills Hotel NV may also communicate your email address towards Facebook to determine whether you are already a user of Facebook, for the purpose of placing personalised and relevant advertisements on your Facebook account, if applicable.

b. Local authorities: We may be required to send your data to local authorities if required by law, or as part of an investigation and in accordance with local regulations.

Data security

Terhills Hotel NV takes appropriate technical and organisational measures, in accordance with applicable legal provisions, to secure your personal data against unlawful or accidental destruction, inadvertent modification or accidental loss and unauthorised access or disclosure. To this end, we have implemented technical measures (such as firewalls) and organisational measures (such as a username/password system, physical security, and so on).

When you submit credit card details when making the reservation, Secure Socket Layer (SSL) encryption technology is used to ensure a secure transaction.

Cookies

Use of cookies by Terhills Hotel

The company Terhills Hotel NV.uses cookies or other trackers on its online booking sites: https://www.terhills.be/activiteiten/terhills-hotel/; http://www.terhillshotel.com/ (‘Terhills Hotel websites’).

These trackers may be installed on your device depending on the preferences you have indicated or may indicate at any time, in accordance with this policy.

Why a cookie policy?

Terhills Hotel has drafted this policy with a view to providing information and ensuring transparency so that you can learn more about:

• The origin and purpose of the data processed when you visit Terhills Hotel websites
• Your rights in relation to cookies and other trackers used by Terhills Hotel

Wat is een cookie?

Cookies and other similar trackers are data packets used by servers to send status data to the user’s browser, and to send status data back to the originating server via the same browser.

Status data may include a session identifier, a language, an expiry date, a response field or other types of data.

Cookies are used during their validity period to store status data when a browser opens various pages of a website or when the browser returns to this website at a later time.

There are different types of cookies:

• Session cookies are deleted as soon as you close the browser or leave the website
• Persistent cookies remain present on your device until their expiry date as long as you do not delete them using your browser

Why are cookies used?

We use cookies and other trackers primarily for the following purposes:

Cookies strictly necessary for browsing Terhills Hotel websites and the use of all functions of these websites, in particular for:

• Managing authentication of website visitors and related security measures, and ensuring the proper functioning of the authentication module
• Optimising the user experience and facilitating website browsing, in particular for determining ‘technical routes’ for browsing
• Storing data relating to the ‘cookie information banner’ displayed to website visitors, who continue on the website after accepting cookies on their device
• Implementing security measures (for example, when you are prompted after a certain time to sign up again for content or a service, or for enabling basic functions of Terhills Hotel websites and the use of important technical functions of these sites, such as tracking website performance and errors, managing user sessions, etc.).

Cookies for functions particularly aimed at:

• Customising Terhills Hotel websites according to the display settings of your device (language, currency, screen resolution, operating system, configuration and settings of the display of web pages based on the device you are using and the location of the device, etc.).
• Storing specific data you enter on Terhills Hotel websites to facilitate and customise your subsequent visits (including display of the visitor’s first and last name if they have a user account)
• Allowing you to access your personal pages faster by saving the login details or data you have previously entered

Visitor tracking cookies are aimed at increasing usability by helping us better understand your interactions with Terhills Hotel websites (most visited pages, applications used, etc.); these cookies may collect statistical data or test different ways of displaying information to improve the relevance and usability of our services.

Advertising cookies are designed to (i) offer you relevant, targeted content in advertising space that may be of interest to you (best offers, other destinations, etc.) based on your interests, browsing behaviour, preferences and other factors, and (ii) reduce the number of times the ads appear.

Partner cookies identify which external website has redirected a visitor to Terhills Hotel websites.

Social network cookies, which are set by third parties, enable you to share your views about Terhills Hotel websites and the content on them on social networks (e.g. the ‘Share’ and ‘Like’ social network application buttons).

The social networking applications on Terhills Hotel websites named above may in some cases identify you even if you have not clicked on the application button. This type of button may allow a social network to track your browsing behaviour on Terhills Hotel websites simply because your social network account is enabled on your device (open session) while you are browsing.

We recommend that you read the policies of these social networks to become familiar with how they use any browsing data they may collect, particularly in relation to advertising. These policies should specifically enable you to make choices regarding these social networks, particularly by configuring your user account of these networks.

Consent

The installation of certain cookies is subject to your consent. When you first visit the Terhills Hotel websites, you will be asked if you agree to the installation of this type of cookie. This type of cookie is activated only after you have given your consent.This process is supported through an information banner on the home page of the Terhills Hotel websites, which informs you that you agree to the installation of cookies that require your consent on your device if you continue browsing the website.You can change your settings at any time using the various methods in the ‘Deleting and/or blocking cookies’ section.

Deleting and/or blocking cookies

U kunt op verschillende manieren cookies en andere trackers verwijderen.

Browser settings

Although most browsers are set to accept cookies by default, if you wish, you can choose to accept all cookies, always block cookies or decide which cookies to accept based on their senders.You can also set your browser to accept or block cookies based on specific cases.Your browser can also periodically delete cookies from your device. Remember to configure the browsers of all your different devices (tablets, smartphones, computers, etc.).

Managing cookies and your preferences varies from one browser to another. This is described in your browser’s help menu. Here you can also read how to adjust your preferences regarding cookies. For example:

• For Internet Explorer™: https://windows.microsoft.com/en-US/windows-vista/Block-or-allow-cookies
• For Safari™: https://www.apple.com/legal/privacy/en-ww/cookies
• For Chrome™: https://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™: https://help.opera.com/Windows/10.20/en/cookies.html

Storing a cookie on your device depends on your preferences, which you can determine and change for free at any time using your browser software settings.

If your browser is set to accept cookies on your device, cookies embedded in pages and content you view are temporarily stored in a designated place on your device.They can only be read by their issuer.

However, you can set your browser to block cookies. Please remember that if you set your browser to block cookies, this means that some features, pages and spaces on Terhills Hotel websites may not be accessible, and we cannot be held liable in this case.

Specialised advertising platforms

Several professional advertising platforms also allow you to accept or block cookies used by member companies. These centralised mechanisms do not block the display of ads, but simply prevent the installation of cookies for personalised ads.

For example, you can visit the website http://www.youronlinechoices.com to prohibit the installation of cookies on your device. This website is provided by digital advertising professionals brought together in the European Digital Advertising Alliance (EDAA), which is run from France by the Interactive Advertising Bureau France.

Storage of data

We store your personal data only for the period necessary for the purposes of this policy or in accordance with the provisions of applicable law.

Access and modification

You have the right to access and amend your personal data as collected by Terhills Hotel NV in accordance with applicable legal provisions.

You may also exercise your right to object by writing to the address below.

In case of difficulties in exercising your rights, you should contact the Terhills Hotel personal data protection department . Send an e-mail to management@terhillshotel.com or write to the address below:

Terhills Hotel NV, Departement of Personal Data Protection (Data Privacy) – Zetellaan 68, 3630 Maasmechelen, Belgium

For confidentiality and protection of personal data, we will need to identify you in order to respond to your request. You are requested to send a copy of an official identification document, such as a driving licence or passport, with your request.

If your personal data is inaccurate, incomplete or not up to date, please send the relevant changes to the department in charge of personal data protection, as indicated above.

All requests will be answered as soon as possible and in accordance with applicable legislation.

You can also exercise your rights with regard to your personal data stored and processed by a hotel after a stay. To do so, please contact the hotel.

Updates

From time to time, we may update this policy. This means that we advise you to consult it regularly.

Questions and contact details

For any queries regarding the Terhills Hotel customer data privacy and security policy, please contact the personal data protection department (clause ‘Access and change’).