Privacy Policy
Data Privacy Policy
https://malta.intercontinental.com/
Contents
1.1 Objective and Responsibility. 3
1.4 Data Erasure and Duration of Storage. 4
1.6 Transfer of Data to Third Parties, Subcontractors and Third Party Providers. 4
2.1 Collection of information for the use of the online offer. 5
2.3 Contact form and contact by email 5
2.4 Links to other websites. 5
2.5 Information about Google Services. 6
2.6 Google Adsense for Youtube. 7
2.9 Meta Pixel (Facebook Custom Audience). 10
2.13 Google AJAX Search API / jQuery. 11
3 Processing for the purpose of carrying out our business processes. 13
4.2 Cookie overview, objection. 17
5 Changes to the Data Privacy Policy. 17
1 General Information
1.1 Objective and Responsibility
- This privacy policy informs you about the nature, scope and purpose of the processing of personal data in relation to our online offer https://malta.intercontinental.com/ and the associated websites, functions and content (hereinafter collectively referred to as ‘online offer’ or ‘website’). Details on these processing activities can be found in section 2.
- Details of data processing for the purpose of carrying out our business processes are described in section 3.
- Eden Hospitality Ltd. (St. George’s Bay, St. Julian’s, STJ 3310, Malta) – hereinafter referred to as ‘we’ or ‘us’ – is the provider of the online offer and responsible for data protection.
- Our online service is hosted by Hetzner Online GmbH (Industriestr. 25, 91710 Gunzenhausen, Germany). The server location is Germany.
- Questions regarding this privacy policy and questions regarding data protection can be directed to, among others, marketing@ihg.com.
- The term ‘user’ encompasses all customers, interested people, employees and visitors of our online service.
1.2 Legal Bases
In general, we collect and process personal data based on the following legal grounds:
- Consent in accordance with article 6 paragraph 1 lit. a General Data Protection Regulation (GDPR). Consent meaning any freely given, specific, informed and unambiguous indication of agreement, which could be in the form of a statement or any other unambiguous confirmatory act, given by the data’s subject consenting to the processing of personal data relating to him or her.
- Necessity for the performance of a contract or in order to take steps prior to entering into a contract according to article 6 paragraph 1 lit. b GDPR, meaning the data is required in order for us to fulfil our contractual obligations towards you or to prepare the conclusion of a contract with you.
- Processing to fulfil a legal obligation in accordance with article 6 paragraph 1 lit. c GDPR, meaning that e.g. the processing of data is required by law or other provisions.
- Processing for the purposes of legitimate interests in accordance with article 6 paragraph 1 lit. f GDPR, meaning that the processing is necessary to protect legitimate interests pursued by us or by a third party, unless such interests are overridden by your interests or fundamental rights and freedoms which require the protection of personal data.
The specific legal bases for the individual processing operations are listed in the following sections.
1.3 Data Subject Rights
You have the following rights with regards to the processing of your data through us:
- The right to lodge a complaint with a supervisory authority in accordance with article 13 paragraph 2 lit. d GDPR and article 14 paragraph 2 lit. e GDPR.
- Right of access in accordance with article 15 GDPR
- Right to rectification in accordance with article 16 GDPR
- Right to erasure (‘right to be forgotten’) in accordance with article 17 GDPR
- Right to restriction of processing in accordance with article 18 GDPR
- Right to data portability in accordance with article 20 GDPR
- Right to objection in accordance with article 21 GDPR
Notice: Users may object to the processing of their personal data in accordance with legal allowances at any time with effect for the future. The objection may in particular be made against processing for the purposes of direct marketing.
Without prejudice to any other administrative or judicial remedy, you shall have the right to complain to a supervisory authority, in particular in the Member State of your place of residence, employment or the place of the alleged infringement, if you believe that the processing of your personal data violates the GDPR.
1.4 Data Erasure and Duration of Storage
The personal data of the data subject will be erased or blocked as soon as the purpose of the storage is inapplicable. Storage of data beyond that may occur if such storage is required by the European or national legislator in EU regulations, laws or other regulations to which the controller is subject. Blocking or erasure of data also takes place when a retention period mandated by the standards mentioned expires, unless the continued storage of data is required for the conclusion of a contract or the fulfilment of contractual obligations.
1.5 Security of Processing
- We have implemented appropriate and state-of-the-art technical and organisational security measures (TOMs). Thus, the data that is processed by us is protected against accidental or intentional manipulation, loss, destruction and unauthorized access.
- These security measures include in particular the encrypted transfer of data between your browser and our server.
1.6 Transfer of Data to Third Parties, Subcontractors and Third Party Providers
- A transfer of personal data to third parties only occurs within the framework of legal requirements. We only disclose personal data of users to third parties, if this is required e.g. for billing purposes or other purposes, if the disclosure is necessary to ensure the fulfilment of contractual obligations towards the users.
- If we engage subcontractors for our online service, we have made appropriate contractual arrangements as well as adequate technical and organizational measures with these companies.
- If we use content, tools or other means from other companies (hereinafter collectively referred to as ‘third party providers’) whose registered offices are located in a third country, it is assumed that a transfer of data to the home countries of these third party providers occurs. The transfer of personal data to third countries takes place exclusively only, if an adequate level of data protection, the user’s consent or another legal permission is present.
2 Concrete Data Processing
2.1 Collection of information for the use of the online offer
- When using the online offer, information is automatically transmitted to us by the user’s browser; this includes the name of the website accessed, file, date and time of access, amount of data transferred, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page), IP address and the requesting provider.
- The processing of this information is based on legitimate interests pursuant to Article 6 (1) (f) GDPR (e.g. optimization of the online offer) and to ensure the security of the processing pursuant to Article 5 (1) (f) GDPR (e.g. for the defense and reconnaissance of cyberattacks).
- The information is automatically deleted latest 4 weeks after the end of the connection – i.e. use of the online offer – unless otherwise required by retention periods.
- The collection of data and the storage of data in log files is absolutely necessary for the provision of the online offer. Therefore, there is no deletion, objection or correction option on the part of the user.
2.2 Consent management
- Our website uses the cookie consent technology “CookieYes” / “Cookie Law Info” from WebToffee to obtain your consent to store certain cookies in your browser and to document this in accordance with data protection regulations. This technology is provided by WebToffee (Mozilor Limited 3 Warren Yard, Wolverton Mill, England).
- When you visit our website, a cookie from WebToffee is stored in your browser, in which the consents you have given or the revocation of these consents are stored. This data is not passed on to the provider of WebToffee.
- The data collected is stored until you request us to delete it, delete the WebToffee cookies yourself, or the purpose for storing the data no longer applies. Mandatory legal retention periods remain unaffected.
- Details on data processing by WebToffee can be found at https://www.webtoffee.com/privacy-policy/
- Consent technology is used to obtain the legally required consent for the use of cookies (Art. 6 (1) (c) GDPR).
2.3 Contact form and contact by email
- When contacting us (via online form or e-mail), the data provided by the user will be processed exclusively for the purpose of processing the enquiry and handling it.
- Any other use of the data will only take place on the basis of the user’s consent.
- The user’s data is stored in our customer relationship management system (‘CRM system’) or a comparable software/database. The statutory retention periods for business letters apply.
2.4 Links to other websites
- While using some of our services, you will be automatically redirected to other websites.
- Please note that this privacy policy does not apply there. The privacy policy of the linked website may differ considerably from this one.
2.5 Information about Google Services
- We use various services of Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland on our website.
For more information on the individual concrete services of Google that we use on this website, please refer to the further privacy policy.
- Through the integration of Google services, Google may collect information (including personal data) and process it. It cannot be ruled out that Google also transmits the information to a server in a third country.
The transmission to the USA depends on the function in which personal data is transmitted. As the responsible party, we ourselves may transfer data to Google in the USA for further use.
Google is registered in the data privacy framework. Furthermore, Google has committed to comply with the standard contractual clauses for the transfer of personal data to third countries (Standard Contractual Clauses – SCC).
More information about the Standard Contractual Clauses is available at
https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractuals-clauses-scc_de
and at
https://policies.google.com/privacy/frameworks?hl=de
- We ourselves cannot influence which data Google actually collects and processes. However, Google states that, in principle, the following information (including personal data) may be processed, among others:
- Log data (in particular the IP address)
- Location-related information
- Unique application numbers
- Cookies and similar technologies
Information on the types of cookies used by Google can be found at https://policies.google.com/technologies/types.
- If you are logged into your Google account, Google may add the processed information to your account depending on your account settings and treat it as personal data.
- Google states the following about this, among other things:
“If you are not signed into a Google Account, we store the data we collect with unique identifiers associated with the browser, app, or device you are using. This allows us to ensure, for example, that your language settings are maintained across all browser sessions.
If you are logged into a Google account, we also collect data that we store in your Google account and consider to be personal data.” (https://privacy.google.com/take-control.html)
- You can prevent this data from being added directly by logging out of your Google account or also by making the appropriate account settings in your Google account. Furthermore, you can change your cookie settings (e.g. delete cookies, block cookies, etc.).
- You can find more detailed information in the privacy notices of Google, which you can access here: https://www.google.com/policies/privacy/
- You can find notes on Google’s privacy settings at https://privacy.google.com/take-control.html.
2.6 Google Adsense for Youtube
- We use the “Google AdSense for YouTube” service on our website as part of the “YouTube” service. The provider is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Irland.
- The legal basis for the use of Google Adsense for Youtube is your consent pursuant to Art. 6 para. 1 lit. a GDPR. You can withdraw your consent at any time with effect for the future.
- The data processed by Google AdSense for YouTube includes your IP address, device information, viewing behavior, interaction data, and cookies are set to provide personalized advertising.
- If you are logged into a Google account, Google Adsense for YouTube may link data collected to your user profile in order to display personalized advertising.
- Google processes this data to display personalized advertising and analyze user interactions with advertisements.
- It cannot be ruled out that personal data may be transferred to unsafe third countries (United States) where the level of data protection is lower than in the EU. We have concluded a Data Processing Addendum with Google, which guarantees that personal data will only be processed in accordance with our instructions and in compliance with the GDPR. Google is certified under the EU-US Data Privacy Framework, which regulates the secure processing of EU citizens data in the US.
- Further information on the privacy policy of Google Adsense for Youtube can be found at: https://policies.google.com/privacy
2.7 Google Analytics
- We use “Google Analytics” on our website, a web analytics service provided by Google Ireland Limited, Google Building Gordon House, Barrow St, Dublin 4, Ireland (hereinafter referred to as “Google”). Google uses cookies, i.e. small text files that are stored on your terminal device and enable an analysis of your use of our website. The information generated by the cookie about the use of our website is usually transmitted to a Google server and stored there. If anonymisation of the IP address to be transmitted by the cookie is activated on the website (“IP anonymisation”), your IP address will be truncated beforehand by Google within member states of the European Union or in other contracting states to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server outside the EU and shortened there. Google will use this information for the purpose of evaluating your use of our website, compiling reports on website activity and providing other services relating to website activity and internet usage. In doing so, pseudonymous usage profiles can be created from the processed data. The IP address transmitted when using Google Analytics will not be merged with other Google data.
- We only use Google Analytics with the activated IP anonymisation described above. This means that your IP address is only processed by Google in a shortened form. This excludes the possibility of personal references.
- We use Google Analytics to analyse the use of our website and to continuously improve individual functions and offers as well as the user experience. Through the statistical evaluation of user behaviour, we can improve our offer and make it more interesting for you as a user. The legal basis is Art. 6 para. 1 p. 1 lit. a) GDPR (consent).
- You can also prevent the storage of cookies generated by Google Analytics by making the appropriate settings in your web browser. Please note that in this case you may not be able to use all the functions of our website. If you wish to prevent the collection of the data generated by the cookie and related to your user behaviour (including your IP address) as well as the processing of this data by Google, you can also download and install the web browser plugin available at the following link: https://tools.google.com/dlpage/gaoptout?hl=en.
- In order to oblige Google to process the transmitted data only in accordance with our instructions and to comply with the applicable data protection regulations, we have concluded an order processing agreement with Google.
- Information from the third-party provider: Google Ireland Limited, Google Building Gordon House, Barrow St, Dublin 4, Ireland.
- For further information on the use of data by Google, on setting and objection options and on data protection, please refer to the following Google web pages:
Terms of use: https://marketingplatform.google.com/about/analytics/terms/en/
Overview of data protection: https://support.google.com/analytics/answer/6004245?hl=en&ref_topic=2919631
Privacy policy: https://policies.google.com/privacy?hl=de&gl=en
Data use by Google when you use websites or apps of our partners: https://policies.google.com/technologies/partner-sites?hl=en
Data use for advertising purposes: https://policies.google.com/technologies/ads?hl=en
Settings for personalised advertising by Google: https://adssettings.google.com
- The data will be deleted as soon as it is no longer required to achieve the purpose for which it was collected.
- deletion of user and event level data linked to cookies, user identifiers (e.g. User ID) and advertising IDs (e.g. DoubleClick cookies, Android advertising ID, IDFA [Apple identifier for advertisers]) will take place no later than 50 weeks after collection.
2.8 Google Tag Manager
- We use the Google Tag Manager on our website. The Google Tag Manager is a service of Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.
- Through the Google Tag Manager, we can integrate various codes and services on our website in an orderly and simplified manner. The Google Tag Manager implements the tags or “triggers” the embedded tags. When a tag is triggered, Google may process information (including personal data) and process it. In doing so, it cannot be ruled out that Google also transmits the information to a server in a third country.
- Information on the standard contractual clauses and the transfer to the USA from us to Google and other relevant data on data processing by Google in the context of the use of Google services can be found in this data protection declaration under section 5 ‘Information about Google Services’.
- In particular, the following personal data is processed by the Google Tag Manager:
- Online identifiers (including cookie identifiers).
- IP address
- In addition, you can find more detailed information about the Google Tag Manager on the websites https://marketingplatform.google.com/about/analytics/tag-manager/use-policy/
as well as at
https://www.google.com/intl/de/policies/privacy/index.html (section “Data we receive based on your use of our services”).
- Furthermore, we have concluded an order processing contract with Google for the use of the Google Tag Manager (Art. 28 GDPR). Google processes the data on our behalf in order to trigger the stored tags and display the services on our website. Google may transfer this information to third parties if required by law or if third parties process this data on behalf of Google.
- If you have deactivated individual tracking services (e.g. by setting an opt-out cookie), the deactivation remains for all affected tracking tags that are integrated by the Google Tag Manager.
- By integrating the Google Tag Manager, we pursue the purpose of being able to carry out a simplified and clear integration of various services. In addition, the integration of the Google Tag Manager optimizes the loading times of the various services.
- The legal basis for the processing of personal data described here as part of the measurement process is consent expressly granted by you in accordance with Art. 6 Para. 1 lit. a GDPR.
- The legal basis for the processing of those data that are processed in the context of obtaining consent is our legitimate interest pursuant to Art. 6 (1) lit. f GDPR. We have a legitimate interest in being able to prove that you have given your consent to the measurement procedure (Art. 7 (1) GDPR).
2.9 Meta Pixel (Facebook Custom Audience)
- We use on our website Facebook Website Custom Audiences and have integrated the so-called Facebook pixel.
- This pixel is used to collect pseudonymous information about the use of this website (e.g. information about viewed content). The transmitted data of the pixel can be used to target you on Facebook with individualized advertising, provided you have a Facebook account.
- For more information about the scope and purpose of data collection, please see Facebook’s privacy policy at https://de-de.facebook.com/privacy/explanation. You can deactivate the data collection at any time under the following link: https://de-de.facebook.com/help/769828729705201/.
- The legal basis for the processing is your consent pursuant to Article 6 (1) (a) GDPR.
2.10 Google reCAPTCHA
- We use Google reCAPTCHA from Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland on our website.
- reCAPTCHA is a service that can distinguish between a human visitor and a robot/spam visitor. This makes it possible to either not tick or tick only one box when submitting a form – without having to solve a puzzle or similar.
- During the use of the service, the domain fonts.gstatic.com (Google Fonts) is called up.
- Legal basis is Article 6 para. 1 lit. f GDPR. There is a legitimate interest in protecting the website from bot and spam requests.
2.11 Google Fonts
- In order to display fonts uniformly, our website uses web fonts provided by Google. Google Fonts is a service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (“Google”). We also use Google APIs to use these web fonts.
- In order to display web fonts, the web browser you are using must connect to a Google server. This informs Google that our website is being accessed via your IP address. The IP address of the browser on the device you are using to access our website is also stored by Google. If your browser does not support web fonts, the website will be displayed with a standard font. With each request to Google Fonts, your IP address is automatically transmitted to a Google server, along with information such as your language settings, screen resolution, browser version, and browser name. The usage data collected by Google enables Google to determine the popularity of certain fonts. Google publishes these findings on internal analysis websites (e.g., Google Analytics).
- We use Google Fonts on the basis of our legitimate interest pursuant to Art. 6 (1) lit. f GDPR in order to offer you a user-friendly and appealing website.
- Further information about Google Fonts can be found at: https://developers.google.com/fonts/faq and in the Google Privacy Policy: https://policies.google.com/privacy
2.12 Google Maps
- This website uses Google Maps to display maps and create route plans. Google Maps is operated by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.
- By using this website, you consent to the collection, processing, and use of automatically collected data and data entered by you by Google, one of its representatives, or third-party providers.
- The terms of use for Google Maps can be found at https://policies.google.com/privacy?hl=en.
- The legal basis for this processing is your consent in accordance with Art. 6 (1) lit. a GDPR.
- By consenting to the use of Google Maps, the provider can load additional services, including Google Fonts in particular.
2.13 Google AJAX Search API / jQuery
- On our website we use the Javascript library jQuery (ajax.googleapis.com). To increase the loading speed of our website and thus provide you with a better user experience, we use Google’s CDN (content delivery network) to load this library. Chances are you have already used jQuery on another page from the Google CDN. In that case, your browser can access the cached copy and it does not need to be downloaded again. If your browser does not have a cached copy or downloads the file from the Google CDN for any other reason, data will again be transferred from your browser to Google Inc (“Google”).
- For further information on data processing by Google, please refer to Google’s privacy policy, currently available at: https://www.google.de/intl/de/policies/privacy/.
2.14 LinkedIn Insight Tag
- This website uses LinkedIn’s Insight Tag. This service is provided by LinkedIn Ireland Unlimited Company, Wilton Plaza, Wilton Place, Dublin 2, Ireland.
- With the help of the LinkedIn Insight Tag, we receive information about visitors to our website. If a website visitor is registered with LinkedIn, we can analyse the key professional data (e.g. career level, company size, country, location, industry and job title) of our website visitors and thus better tailor our site to the respective target groups. Furthermore, with the help of LinkedIn Insight Tags, we can measure whether visitors to our websites make a purchase or take other action (conversion measurement). Conversion measurement can also be carried out across devices (e.g. from PC to tablet). LinkedIn Insight Tag also offers a retargeting function that allows us to display targeted advertising to visitors to our website outside the website, whereby, according to LinkedIn, the advertising recipient is not identified.
- LinkedIn itself also collects log files (URL, referrer URL, IP address, device and browser properties, and time of access). IP addresses are truncated or (if used to reach LinkedIn members across devices) hashed (pseudonymised). The direct identifiers of LinkedIn members are deleted by LinkedIn after seven days. The remaining pseudonymised data is then deleted within 180 days.
- As the website operator, we cannot assign the data collected by LinkedIn to specific individuals. LinkedIn will store the personal data collected from website visitors on its servers in the USA and use it for its own advertising purposes. For details, please refer to LinkedIn’s privacy policy at https://www.linkedin.com/legal/privacy-policy#choices-oblig.
- If consent has been obtained, the use of the above-mentioned service is based exclusively on Art. 6 (1) lit. a GDPR. Consent can be revoked at any time. If consent has not been obtained, the use of this service is based on Art. 6 (1) lit. f GDPR; the website operator has a legitimate interest in effective advertising measures, including social media.
- Data transfer to the United States is based on the standard contractual clauses of the European Commission. Details can be found here: https://www.linkedin.com/legal/l/dpa and https://www.linkedin.com/legal/l/eu-sccs.
- You can object to the analysis of usage behaviour and targeted advertising by LinkedIn at the following link: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
- Furthermore, LinkedIn members can control the use of their personal data for advertising purposes in their account settings. To prevent LinkedIn from linking data collected on our website to your LinkedIn account, you must log out of your LinkedIn account before visiting our website.
2.15 WordPress
- We use WordPress for website development based on the balancing of interests pursuant to Art. 6 para. 1 lit. f GDPR.
- WordPress uses only necessary or functional cookies and similar technologies. No data is transferred to third parties.
2.16 YouTube
- We use the video portal “YouTube” of the company Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (hereinafter: “Google”) on our internet pages (videos) in order to achieve a smooth integration of the videos as well as an appealing design of our website. The legal basis for the data processing is your consent in accordance with Art. 6 (1) a GDPR.
- We use the “extended data protection mode” option provided by Google for this purpose.
- When you call up a page that has an embedded video, a connection is established to the Google servers and the content is displayed on the website by informing your browser.
- According to Google’s information, in “extended data protection mode” your data – in particular which of our web pages you have visited as well as device-specific information including the IP address – is only transmitted to the YouTube server in the USA when you watch the video. By activating a video, you consent to this transmission.
- If you are logged in to Google at the same time, this information will be assigned to your YouTube member account. You can prevent this by logging out of your member account before visiting our website.
- In some cases, information is transmitted to the parent company Google Inc. based in the USA, to other Google companies and to external partners of Google, each of which may be located outside the European Union. Google uses standard contractual clauses approved by the European Commission for this purpose and relies on adequacy decisions issued by the European Commission with regard to certain countries.
- For more information on data protection in connection with YouTube, please refer to Google’s privacy policy.
- During the use of the video portal, the domains ytimg.com („Youtube images“), youtube-nocookie.com („Youtube NoCookie“), googlevideo.com (“Google Video”), ggpht.com (“Google Photos”) and fonts.gstatic.com (Google Fonts) are called up.
2.17 Matterport
- Our website contains virtual tours of our rooms, which are integrated via the portal my.matterport.com. The operator of this portal is Matterport, Inc, 352 E. Java Dr. Sunnyvale, CA 94089, USA.
- The legal basis for data processing is your consent in accordance with Art. 6 Para. 1 lit. a GDPR.
- When you visit one of our pages that contains such a virtual tour, a connection to the servers of Matterport is established. In the process, the Matterport server is informed which of our pages you have visited. In addition, Matterport obtains your IP address. This also applies if you are not logged in to Matterport or do not have an account with Matterport. The information collected by Matterport is transmitted to the Matterport server in the USA. If you are logged into your Matterport account, you enable Matterport to assign your surfing behavior directly to your personal profile. You can prevent this by logging out of your Matterport account. The use of Matterport is in the interest of an appealing presentation of our online offers. This represents a legitimate interest within the meaning of Art. 6 para. 1 lit. f GDPR.
- For more information on how Matterport implements the GDPR and handles user data, please see Matterport’s privacy policy at the following link:
https://matterport.com/legal/privacy-policy/.
3 Processing for the purpose of carrying out our business processes
3.1 Guest registration
- We are required to maintain a guest register. This requirement is stipulated in the Travel and Tourism Services Act (Chapter 409) and the Accommodation Regulations (Legal Notice 351 of 2012).
- The following information must be entered in the guest register:
Full name
Year of birth
Nationality (from passport/ID card)
Address and contact details (telephone/email)
Date of arrival and departure
- All guests (regardless of age) must present a valid passport or identity card at check-in.
- Submission of guest registration to the police
Approved accommodation establishments in Malta are not required to routinely submit guest registers. Instead, in accordance with Legal Notice 351 of 2012, providers must keep guest registers and present them for on-site checks or hand them over to the Maltese police if formally requested to do so in accordance with Article 40 of the Travel and Tourism Services Act (Chapter 409).
- Storage of guest registration data
We must store guest registration data in accordance with the regulations for accommodation establishments (Legal Notice 351 of 2012) and the General Data Protection Regulation (GDPR). The data should only be kept for as long as necessary for regulatory checks and then securely deleted. We are obliged to implement technical and organisational security measures such as encryption, access control
3.2 Video surveillance
Below you will find our data protection notice within the meaning of Article 13 GDPR regarding the processing of personal data within the scope of our video surveillance.
- The processing of video recordings is based on Article 6 (1) (f) GDPR; the so-called legitimate interest.
- Our legitimate interests are:
- Protection of house rules
- Protection against theft, protection of property
- Investigation of burglary and theft
- Protection of guests and employees
- The video recordings are processed exclusively for the purposes stated.
- Any further use or disclosure of the video recordings will only occur if necessary for potential criminal prosecution. In this case, the recipients will be the relevant law enforcement authorities.
- We use external service providers to maintain the video surveillance system, although access to the video surveillance system or stored video recordings cannot be ruled out.
- Video recordings will be deleted no later than 3 days after recording, unless special incidents have occurred that justify or require further storage.
3.3 Table reservation
- If you reserve a table at our restaurant via the “OpenTable” booking portal, your personal data will be provided to us.
- The legal basis for processing is your consent in accordance with Article 6 (1) (a) GDPR in conjunction with Article 6 (1) (b) GDPR (necessity for the initiation and execution of the contract).
- The contact details of the booking portal provider are: Open Table International Limited (Alphabeta Building, 14-18 Finsbury Square, London, EC2A 1AH, United Kingdom).
- Details: https://www.opentable.ie/c/legal/corporate-contact-information/
3.4 Gift vouchers
- In our voucher shop you have the opportunity to purchase vouchers for different occasions. If a user realizes this option, the data entered in the input mask will be transmitted to us and processed by us. The processing includes the following data: salutation / title, first name, name, telephone number, e-mail address, date of birth, address, voucher value, wishes, payment data.
- The voucher shop is based on the voucher system of SK CHASE LTD., 31 Palmerston Place, Edinburgh, EH12 5AP; Scottland. We have concluded an order processing agreement with SK CHASE.
- A transfer of personal data to third parties, if this is necessary in the context of the contract, for example, to the commissioned with the payment transaction bank. Further transmission of data only takes place if you have expressly consented to the transmission.
- The legal basis for the processing of the data is the conclusion of a purchase contract with the user in accordance with article 6 paragraph 1 lit. b GDPR.
- The processing of the personal data provided by the user takes place solely for the processing of the voucher purchase and for the handling of payment transactions.
3.5 Booking
- When you use the “Book Now” function, you will automatically be redirected to the booking portal of the InterContinental Hotels Group.
- Please note that this privacy policy is not valid there. The privacy policy of the InterContinental Hotels Group applies, which can be accessed at https://www.ihg.com/content/gb/en/customer-care/tc.
- When you make a booking at our hotel, your personal data will be transmitted to us by the InterContinental Hotels Group. Please assert your rights in relation to the booking portal directly with the InterContinental Hotels Group.
3.6 Newsletter
- Our email newsletters are sent using “MailChimp”, a newsletter delivery platform of the US provider Rocket Science Group, LLC, 675 Ponce De Leon Ave NE #5000, Atlanta, GA 30308, USA.
- The email addresses of our newsletter recipients, as well as their other data described in this notice, are stored on the servers of MailChimp in the USA. MailChimp uses this information to send and evaluate the newsletter on our behalf.
- Furthermore, MailChimp may, according to its own information, use this data to optimize or improve its own services, e.g. for the technical optimization of the dispatch and the presentation of the newsletter or for economic purposes to determine from which countries the recipients come. However, MailChimp does not use the data of our newsletter recipients to write to them itself or to pass them on to third parties. The privacy policy of MailChimp can be found here:https://mailchimp.com/legal/privacy
- Statistical survey and analyses
The newsletters contain a so-called “web-beacon”, i.e. a pixel-sized file that is retrieved from the MailChimp server when the newsletter is opened. Within the scope of this retrieval, technical information, such as information about the browser and your system, as well as your IP address and the time of the retrieval are initially collected. This information is used for the technical improvement of the services based on the technical data or the target groups and your reading behavior based on the retrieval locations (which can be determined with the help of the IP address) or the access times. - Statistical surveys also include the determination of whether the newsletters are opened, when they are opened and which links are clicked. For technical reasons, this information can be assigned to the individual newsletter recipients. However, it is neither our intention nor that of MailChimp to observe individual users. The evaluations serve us much more to recognize the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users.
3.7 Hotel stay
- When you stay with us, we strive to make your stay as comfortable as possible. This requires the processing of your personal data for the provision of specific services during your hotel stay.
These services include
- housekeeping and maintenance;
- returning lost or forgotten items to you; and
- managing your preferences and those of your companions, such as diet requirements and pillow preferences
to provide you with a better service during your stay with us.
- For these purposes, we process in particular the following data: first and last name, postal address, consumption habits, arrival and departure dates, dietary requirements, email address, first and last name of adult roommates, other personal preferences, payment information (for the return of lost or forgotten items), telephone number
- This data is usually collected directly from you, during your stay at the hotel, or reaches us via your travel agency or, for example, through the booking system you use.
- The legal basis for the processing of this data is the balancing of interests in accordance with Article 6 (1) (f) GDPR. Our legitimate interest is to organize our hotel maintenance activities, to personalize the services offered and to be able to identify the owner of a lost or forgotten item.
- Possible recipients of the data are hotel staff (including housekeeping, maintenance, reception and other hotel staff), IT service providers, as well as delivery or courier service providers (for the return of lost or forgotten items).
- You can object to the use of the data at any time with effect for the future. An objection may result in a noticeable restriction of our services.
- We use several service providers to provide our services as part of order processing.
4 Cookies
4.1 General Information
- Cookies are information transmitted by our web server or third-party web servers to the users’ devices where they are stored for later retrieval. Cookies can be in the form of small files or any other types of information storage.
- In the case that users do not want that cookies are stored on their device, they will be asked to disable the corresponding option in their browser’s system settings. Saved cookies may be deleted in the system settings of the browser. The exclusion of cookies can lead to functional impairments of this online service.
4.2 Cookie overview, objection
- An up-to-date overview of the cookies and similar technologies used on this website can be found in the Consent Management Platform (see section 2).
- There you can also manage your individual consents and preferences.
5 Changes to the Data Privacy Policy
- We reserve the right to change this Data Privacy Policy with regards to the data processing, in order to adapt it to changed legal situations, to changes of the online service or of the data processing.
- If users’ consents are required or if elements of the Data Privacy Policy contain provisions in regards to the contractual relationship with the users, the changes will only be made with the consent of the users.
- Users are requested to keep themselves informed about the content of this Data Privacy Policy on a regular basis.
Version: November 2025