We respect the privacy of all our customers and business partners, and treat personal information provided by you to us as confidential.
In order for us to operate effectively, we may collect information about you, whether as hotel guests, loyalty programme members, web site visitors or contact for any other purposes, where personal information is provided to us that can identify you as an individual.
Your personal information can come to us via various channels, including but not limited to:
Personal information provided directly by you
Data we collect when you use our Websites and Apps
Information we receive from third parties or public sources
We may collect, use, store and transfer different kinds of personal information about you depending on our relationship with you and where you are located, this information may include:
Identity details: such as your name, gender, date of birth, nationality, passport and visa information
Contact Details: personal and work contact details (addresses, emails and telephone numbers)
Payment and credit card information: such as bank accounts, name of cardholder, credit card number, credit card billing address and expiry date
Guest stay information and lifestyle information: such as hotels where you have stayed, arrival and departure dates, room preferences, leisure activities, names and ages of children, observation of your services preference, and other information necessary to fulfil special requests. Information, feedback or content you provide regarding your interests and preferences
Profile Information: includes loyalty program member information, online account details, profile or password details
Technical Information: includes information from our security systems such as from our closed-circuit television system, card key, internet login and firewalls
Usage data: includes information about how you use and interact with our website and mobile apps and the services you use.
Sensitive Personal Information: some of the personal information which you provide to us may be considered “sensitive personal information” under the privacy and data protection laws in specific jurisdictions – such as personal information from which we can determine or infer an individual’s racial or ethnic origin, health or biometric data. We only process sensitive personal information to the extent permitted or required by applicable law.
Please note that, in respect of children’s personal information, except where required by local laws, we do not knowingly collect personal information from our websites from any children or minors. As a parent or legal guardian, please do not allow your children or minors to submit personal information without your permission.
We may collect, process and/or use the personal information which we collect in order to:
We will only collect, process and/or use the personal information where we are satisfied that we have an appropriate lawful basis to do so.
We will keep your personal information in line with our data retention notice for no longer than is necessary to fulfil the purposes we collected it for, unless we have a lawful ground for holding it for longer.
To determine the appropriate retention period for your personal information we consider the amount, nature and sensitivity of the information, the risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
We will safely and securely delete, dispose of or anonymise personal information when we no longer need it.
We endeavour to protect your personal information we maintain and have implemented reasonable technical, organizational and administrative measures to keep your personal information safe and secure and to protect it against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties that have a business need to know. They will only process your personal information on our instructions, and they are subject to a duty of confidentiality.
When we 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.
We do business globally. In order for us to operate effectively and provide you with the best experiences with our services, we may centralize certain aspects of our information processing activities and may have databases in different countries (some of which are operated by our local group company and some of which are operated by third parties on our behalf). We may therefore have to share and transfer your personal information from one country to another, or even across multiple jurisdictions, such as:
Your personal information may therefore be subject to privacy laws that are different from those in the country where the personal information is collected or those in your country of residences. We will endeavour that the transfer of your personal information is carried out in accordance with applicable privacy laws and that appropriate technical, organizational and administrative measures are in place for its safeguard.
You may always choose what personal information (if any) you wish to provide to us. Please note, however, some of our products and services to you may be affected if you choose not to provide certain details, for example, we cannot reply to you without a name or contact details.
European Union (EU) or United Kingdom (UK) data protection law applies to the processing of information of residents of the European Union and United Kingdom.
We have appointed IT Governance Europe Ltd to act as our EU representative. If you wish to exercise your rights under the EU General Data Protection Regulation (EU GDPR), or have any queries in relation to your rights or general privacy matters, please contact us in the first instance via email firstname.lastname@example.org or, alternatively, you can contact our EU Representative directly via email email@example.com (please ensure you include our company name, YNF Hotels Management & Services (HK) Limited in any correspondence you send to our representative).
The table below describes the ways we plan to use your Personal information, and which Lawful Basis we rely on to do so. We have also identified what our legitimate interests are where appropriate.
We use your Personal information on the basis that it is necessary for us to fulfil a contract with you.
When you register as a new client, or supplier and we interview and onboard you.
In order to be able to deliver our products and services to you
To be able to contact you regarding updates or informative communications
Managing our business
Developing and improving our services to you – such as performing market research, analytics and/or profiling, developing new products and services, improve the effectiveness of our website, your hotel experience, our various types of communications, advertising campaigns, and promotional activities
Cooperation with third parties
Recommendations, communications and marketing
Safety and security
We use data analytics to improve our website, products/services, marketing, customer relationships and experiences.
Rights and claims
Including verifying your identity when you exercise your data subject rights.
We may use your Personal information to comply with any laws or regulatory requirements applicable to us. An example might be to detect fraudulent or criminal activity, whereby we may share information with forces such as the police.
We may have to get your consent to use your Personal information, such as when we collect and use Special Category Personal information about you or when we want to send you electronic marketing.
Where we rely on your consent for processing, it can be withdrawn at any time.
To measure and analyze the effectiveness of the advertising we serve you.
We may collect IP addresses and store Cookies on visitors’ devices.
Sending third-party direct marketing communications to you via email, letters or phone calls.
Special Category Personal information
Express consent for collecting and processing sensitive data also known as special category personal information (such as biometric data or data concerning health).
You have several rights under UK and EU data protection law. The rights available to you depend on our reason for processing your information and are set out in the below.
Right to be informed
We have a legal obligation to provide you with concise, transparent, intelligible, and easily accessible information about your personal information and our use of it.
Right of access
You have the right to ask us for copies of your personal information. This right always applies. There are some exemptions, which means you may not always receive all the information. When you request this data, this is known as making a data subject access request (DSAR). In most cases, this will be free of charge; however, in some limited circumstances, for example repeated requests for further copies, we may apply an administration fee.
Right to rectification
You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
Right to erasure
You have the right to ask us to erase your personal information in certain circumstances. We have the right to refuse to comply with a request for erasure if we are processing the personal information for one of the following reasons:
· To exercise the right of freedom of expression and information.
· To comply with a legal obligation.
· To perform a task in the public interest or exercise official authority.
· For archiving purposes in the public interest, scientific research, historical research or statistical purposes.
· For the exercise or defence of legal claims.
Right to restriction of processing
You may ask us to stop processing your personal information. We will still hold the data but will not process it any further. This right is an alternative to the right to erasure. If one of the following conditions applies, you may exercise the right to restrict processing:
· The accuracy of the personal information is contested.
· Processing of the personal information is unlawful.
· We no longer need the personal information for processing, but the personal information is required for part of a legal process.
· The right to object has been exercised and processing is restricted pending a decision on the status of the processing.
Right to object to processing
You have the right to object to processing in certain circumstances. You can also object if the processing is for a task carried out in the public interest, the exercise of official authority vested in you, or your legitimate interests (or those of a third party).
Right to data portability
This right only applies if we are processing information based on your consent or for the performance of a contract and the processing is automated.
To exercise your rights or get more information about exercising them, please contact us using the contact details provided in “HOW TO CONTACT US”, giving us enough information to identify you.
You have the right to lodge a complaint with a supervisory authority in the EEA member state where you work or normally live, or where any alleged infringement of data privacy legislation occurred.
The supervisory authority in the UK is the ICO, which may be contacted at https://ico.org.uk/concerns or by telephone on 0303 123 1113.
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“We”, “us”, “ourselves” and “our Group” refers to YNF Hotels Management & Services (HK) Limited and its affiliates involved in the management, operations, franchising, licensing, or provision of services to or in connection with our properties around the world, including hotels, residences, outlets, local management entities and sales offices worldwide. Members of the Langham Hospitality Group are affiliates in our Group.
In addition to our rights of disclosure as mentioned hereinabove, we may also disclose your personal information when required by law or court order, or as requested by other government or law enforcement authorities, or in the good faith that disclosure is otherwise necessary or advisable including and without limitation to protect the rights or properties of our Group. This also applies when, in compliance with applicable laws, we have reason to believe that disclosing the personal information is necessary to identify, contact or bring legal action against someone who may be causing interference with our rights or properties, whether intentionally or otherwise, or when anyone else could be harmed by such activities.
The information and material contained in this site are for general references only. Our Group disclaims any warranty or representation of any kind, express or implied, as to any matter whatsoever relating to this site or any linked site. To the fullest extent allowed by law, our Group shall accept no responsibility or liability in respect of any loss or damage howsoever arising.
Use of or visit this site does not constitute any binding contract over any goods and services provided by our Group, nor does it constitute an offer of any goods and services provided by our Group. Goods and services may only be available in certain countries and any offer to purchase goods or to retain services from our Group are subject to acceptance by our Group and in accordance with specific terms and conditions on which they are offered.
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