ONLINE PRIVACY STATEMENT

This Privacy Statement sets out the online privacy policy of the Conservatorium Hotel B.V.

General information

Conservatorium Hotel B.V., (“Conservatorium Hotel”), processing controller, has its registered office in Amsterdam, the Netherlands, and its place of business at Van Baerlestraat 27, 1071 AN Amsterdam, NL.

This Statement explains what personal data we collect, how we use it, and how this can benefit your experience of our web site. Conservatorium Hotel collects and uses your personal data in accordance with the General Data Protection Regulation, in Dutch the ‘Algemene Verordening Gegevensbescherming’ (“AVG”) and other applicable laws and regulations. Personal data refers to any information about a person. Data that indirectly says something about someone is also personal data.

This Privacy Statement applies to all parties whose personal data we process (including but not limited to clients, counterparties, website visitors, suppliers and job applicants), with the exception of employees, contractors and/or other data subjects who perform work for Conservatorium Hotel. We maintain a separate privacy statement for the latter data subjects.

Please take a moment to read the sections below.

1. WHAT INFORMATION ABOUT YOU DO WE COLLECT?

We only collect adequate, relevant and limited personal data, to is the extent necessary in relation to the purposes for which data are processed (‘data minimisation’);

We therefore collect your information only to operate effectively and provide you with the best experiences with our services. The specific kind of information collected will depend on the context of your interactions with us, and the services you use.

We process the following personal data:

• Contact information (name, email address, mailing address, phone number, fax number, and passport number);
• Payment information (payment card: numbers and expiry date, billing address, and bank account information);
• Information related to your reservation, stay, or visit at the Conservatorium Hotel (document identification number (i.e. number of passport o ID), date of arrival and departure, and goods and services purchased);
• Information necessary to fulfil your special requests and/or specific accommodations (preferences, leisure activities, accompanying guest name, and number of children and ages);
• Loyalty program member information: name, loyalty program number, level of loyalty;
• Information collected through security systems (video footage, closed circuit television systems – CCTV and electronic card key);
• The use and interaction with our websites, communication preferences, aggregated data relative to your stays, and responses to promotional offers and surveys.

We collect this information in the following way:

Information provided by you:

We receive and store information you enter on our website or give us in any other way, including: use our online reservations stay as a guest at hotels subscribe to our newsletters or request a brochure submit enquiries and feedback forms correspondence with us – interaction with our employees limited to legitimate interest respond to surveys, promotions and other communications submit a job application You decide how much information to share with us in most cases, but not sharing required information may limit your ability to engage in certain activities, such as payment information required to complete your reservation. If you submit any personal information relating to another person (e.g., if you make a reservation for another individual), you represent that you are authorized by that person to do so and to permit us to use the information in accordance with this Privacy Policy. You also represent that the information you provide is accurate.

Automatic Information:

When you use or interact with our website and/or use any apps that we may make available on our website, we receive and store information generated by your activity and information automatically collected from your browser or mobile device. For example, like many websites, we obtain certain information when your web browser accesses our website including your IP address, browser type, operating system, mobile network data, pages viewed and access times. This information helps us to communicate with our customers and better understand them.

Security Systems:

When you visit our properties, information may be collected about you through such properties’ closed circuit television systems (CCTV), electronic key cards and other security systems.

Information from other sources:

We may receive information about you from other third parties. This may include information from your travel agent, loyalty program, credit card, and other third parties.

Age Limitations:

Conservatorium Hotel does not knowingly collect personally identifiable information from any person under the age of 18.

Conservatorium Hotel may collect personally identifiable information from people under the age of 18 as part of the guest registration process, but always with the consent of such person’s parent or guardian.

2. HOW DO WE USE YOUR INFORMATION?

We collect your information only to operate effectively and provide you with the best experiences with our services.

We collect, use, and disclose the information it collects for the following purposes:

• Fulfilment of reservation and other purchases:

We may process information relating to transactions that you enter into with us at our premises and/or through our website (“transaction data”).

The transaction data may be processed for the purpose of completing your room reservation, supplying the purchased goods and services, customizing our services to your preferences, seeking your feedback on your stay at our properties, and keeping proper records of those transactions.

• Guest Relations:

To offer hospitality services and goods based on your preferences and prior stays at one of our properties. The information may be used for future voluntary loyalty programs operated by us if you signed up for those programs.

• Response to inquiries:

We may process information contained in or relating to any communication that you send to us (“correspondence data”). The correspondence data may include the communication content and metadata associated with the communication (such as groups, meetings and events). The correspondence data may be processed for the purposes of communicating with you and record-keeping.

• Internal Business Purposes:

For our internal business purposes, developing new products, enhancing the website, improving our services, identifying usage trends and visiting patterns, determining the effectiveness of our promotions, evaluating third parties performance (such as Travel Agencies), predicating our yield and occupancy, and meeting contractual obligations.

• Administrative and other communications:

To send you important information regarding our website, changes to our terms, conditions, and policies, or other administrative information (e.g., information about your travel reservations, such as confirmation emails).

• Marketing and promotions:

To communicate news and promotions to you regarding Conservatorium Hotel related products and services we think may be of interest to you; including Akasha Spa & Gym, Bars and Restaurants.

• Safety and security:

To maintain your safety and security as well as that of other guests and staff, while you visit Conservatorium Hotel.

• Other purposes:

Such as, keeping our administration, collecting invoices, complying with legal and statutory obligations, communication with third parties and suppliers, ensuring the security of our IT systems, recruitment and selection (job applications), defense against legal claims, and other justified business interests.

Basis for processing personal data:

Personal data may only be processed if there is a basis for the processing. The bases are listed in Article 6 AVG. The bases on which we process personal data are:

• Your consent.
• Performance of an agreement, for example the booking made with us to make use of certain services.
• Compliance with applicable laws, regulations or other legal process.
• To pursue a legitimate interest.

3. WHAT ABOUT COOKIES?

To enhance your experience on our web site, some of our web pages may use “cookies”. Cookies are small text files containing small amounts of information that are downloaded and can be stored on your user device, for example your computer, smartphone or tablet. Cookies, by themselves, do not tell us your personally-identifiable information unless you choose to provide this information to us (by, for example, registering for one of our services). However, once you choose to furnish the site with your personally-identifiable information, this information may be linked to the data stored in the cookie. We use cookies to understand site usage and to improve the content and offerings on our sites. We may use cookies to personalize your experience at our web pages and to offer you relevant products, programs, or services as well as interest-based or targeted advertising. Your browser may give you the ability to control cookies, certain browsers can be set to avoid cookies collection. You can refuse the use of these cookies at any time, although this will affect the functionality and may limit the ease of use of the website(s). Our marketing and advertisement partners can use cookies to provide you with more-relevant ads on our site and to encourage you to return to our site. These partners will not use your data for any other purpose than our legitimate interest of direct marketing and you will always have the right to object.

Use of Third-Party Cookies
Our website uses third-party cookies to enhance your browsing experience and provide tailored content. This includes cookies from partners such as Rakuten, which help us analyze website traffic and user behavior to offer relevant promotions and advertisements. By continuing to use our website, you consent to the use of these cookies in accordance with our cookie policy. You can manage your cookie preferences at any time through your browser settings.

For more information on the cookies that we use, please see our separate cookie statement.

4. WHO ARE THE RECIPIENTS OF YOUR PERSONAL DATA?

Your personal data being confidential, only persons duly authorized by us can access your personal data, apart from their possible transmission to the bodies in charge of a control or inspection in accordance with the applicable regulations. Data can only be accessed by two-factor authentication and visibility and access rights are limited to the authorized people. All persons who have access to your personal data are bound by an obligation of confidentiality. These persons include the staff authorized within the company and its affiliates. Conservatorium Hotel only shares your personal data to the extent necessary for the sale or provision of services in accordance with the purposes mentioned above. These include (amongst others): the use of our administration system, electronic and postal dissemination, logistics and catering, direct marketing etc.

In addition, Conservatorium Hotel may provide personal data to a third party, such as a supervisor or other source with public authority, to the extent that there is a legal instruction or obligation to do so.

Third parties who process personal data for us, will do so according  to our instructions and any other appropriate confidentiality and security measures. A data processing agreement will be concluded for these purposes in order to ensure compliance of the Dutch AVG and/or the GDPR by that third party.  By Conservatorium Hotel engaged third parties who offer services as controllers, are themselves responsible for compliance with the (further) processing of your personal data and compliance with the AVG.

5. DOES CONSERVATORIUM HOTEL TRANSFER INFORMATION OVERSEAS?

Any data processing is held within EU borders including processing by third parties we engage. If any of our third parties will require, for any reason, to transfer information outside EU borders; the request will be examined by us. In this specific case, we will ensure that appropriate measures have been put in place to ensure that your personal data benefits from an adequate level of protection.

6. HOW SECURE IS YOUR INFORMATION?

We implement reasonable administrative, organizational and technical safeguards and security measures to protect personal information from unauthorized access, disclosure, destruction or alteration, accidental loss, misuse or damage, taking into account the state of art. We regularly review and monitor such safeguards and security measures. We do this according to the applicable legal requirements and guidelines. When disclosure of data to third parties is necessary and authorized, we ensure that these third parties guarantee the same level of data protection as that offered to them by us and requires contractual guarantees, and with the required confidentiality and security.

7. HOW LONG WILL CONSERVATORIUM HOTEL KEEP YOUR INFORMATION?

We will only keep your personal data for as long as we need to fulfil the purposes we collected it for, including for satisfying any legal, accounting, or reporting requirements. To decide how long we should keep your personal data for, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or sharing of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

By law we have to keep basic information about our guests and customers (including names, contact information, financial and transaction Data) for seven years after your stay. This data is deleted after expiration of that period.

Complaints, requests, questions (through our website or in person in our facility) and responses thereto will be retained for seven years after your stay with us or after the question or complaint has been solved or the inquiry was closed. Upon expiration of this period, the data will be deleted.

The IP addresses collected during a website visit are kept by Google during a period of 50 months (or a different period as set by Google). If and to the extent that data are forwarded to Google (or to Google’s servers) in the United States, Google has been certified on the basis of the EU-US Privacy Shield and provides an appropriate level of protection on that basis.

Camera footage is in principle deleted after 28 days, or in case of an incident, once it is resolved.

Job applications are deleted 4 weeks after the application period has ended.

The above-mentioned periods apply, unless there are compelling reasons for keeping the personal data longer (e.g. in pending or expected legal disputes), or unless the data are still needed for purposes other than those mentioned in this Privacy Statement.

In some circumstances we may remove your identity from your personal data (so that it can no longer be associated with you) for statistical purposes, in which case we may use this information indefinitely without further notice to you.

8. WHAT CAN YOU DO IF YOU HAVE ANY QUESTIONS OR CONCERNS OR WANT TO ACCESS YOUR PERSONAL DATA?

Our Data Protection Officer will be happy to answer any concerns or queries you may have relating to the use or storage of your personal data. Your principal rights under the AVG are:

• The right to information on the processing of your personal data
  We strive to provide you with concise, transparent, understandable and easily accessible information on the conditions for processing your personal data, in clear and simple terms.
• The right to access, rectify, or delete your personal data
• The right to restrict the processing of your personal data
• The right to object to the processing of your personal data
• The right to data portability; i.e., to receive your personal data in a structured format so that you can transfer the personal data or instruct us to transfer the personal data to another organization.

If you have consented to the processing of your personal data, you have the right to withdraw your consent at any time. However, in some cases the processing of personal data by Conservatorium Hotel is also based on a different basis, in which case Conservatorium Hotel will continue the processing of personal data.

Complaints

You can also file a complaint with us if you disagree with the way we process your personal data.

Requests or complaints can be submitted by email to mr. Lionel Robin at [email protected]. Before we can process your request, we will need to verify your identity. If we cannot verify your identity, we cannot provide you with any data or give you access to it. We will respond to your request within one month.

The right to lodge a complaint with a supervisory authority

If, despite our effort to preserve the confidentiality of your personal data, you feel that your rights are not respected, you have the right to lodge a complaint with the supervisory authority ‘Autoriteit Persoonsgegevens’ at www.autoriteitpersoonsgegevens.nl.

Refusing to provide personal data to us

Refusing to provide personal data may result in you no longer or not being able to use our services or products. Providing personal data will also be necessary if you wish to apply for a job with us. Refusing to provide certain personal data will thus be able to hinder the possibility of doing business with you, contacting you and/or proceeding with an application process.

9. HOW TO CONTACT US

You may exercise any of these rights in relation to your personal data by contacting our Data Protection Officer – mr. Lionel Robin.

Our Data Protection Officer can be contacted by email at [email protected] and by post at Conservatorium Hotel, Van Baerlestraat 27, 1071 AN Amsterdam, NL.

Please also contact us if you have any questions about our privacy policy.

10. WHAT ABOUT LINKED WEBSITES?

The linking of third party websites to this website does not indicate any association with or endorsement by us.

We do not assume responsibility or liability for any content presented by or contained on any independent web site, including, but not limited to, any advertising claims or marketing practices.

11. CHANGES TO THIS PRIVACY POLICY

Conservatorium Hotel has the right to change this privacy policy from time to time, without prior notice. Amendments to the Privacy Statement will be published on our website. The effective date of this current privacy policy is set out at the end of this document.

Effective Date: 26th September 2024