1. THE WINNREWARDS COMMITMENT TO PROTECTING PRIVACY
Because we consider you an important customer, our priority is to offer
you exceptional times and stays throughout the world.
Your complete satisfaction and confidence in WinnRewards are
essential to us.
That's why, as part of our commitment to meeting your expectations, we
have set up a customer privacy protection policy. This Charter formalizes
our commitments to you and describes how WinnRewards uses your personal data.
The main rules applicable within the WinnRewards worldwide (WinnRewards
and its subsidiaries) are founded on seven principles.
"Personal data" means any information collected and logged in a format
that allows you to be identified personally, 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 read this document describing our customer privacy protection
This Personal Data Protection Charter forms part of the terms and
conditions that govern our hotel services. By accepting these terms and conditions, you
expressly accept the provisions of this Charter.
3. WINNREWARDS SEVEN PRINCIPLES
FOR PROTECTING YOUR PERSONAL DATA
The seven principles below are applicable within the WinnRewards
throughout the world.
- Transparency: When collecting and processing your personal data, we will
communicate all information to you and inform you of the purpose and recipients of the data.
- Legitimacy: We will collect and process your personal data only for the
purposes described in this Charter
- Relevance and accuracy: We will only collect personal data that is
necessary for data processing. We will take all reasonable steps to ensure that the personal
data we hold is accurate and up to date.
- Storage: We will hold your personal data for the period necessary for
processing the same in compliance with the provisions of the law.
- Access, rectification, opposition: You may access, modify, correct or
delete your personal data. You may also oppose the use of your personal data, particularly
to avoid receiving sales and marketing information. The details of the department to contact
in this respect are shown below (13) in the clause Access and
- Confidentiality and security: We will ensure reasonable technical and
organizational measures are in place to protect your personal data against alteration or
accidental or unlawful loss, or unauthorized use, disclosure or access.
- Sharing and international transfer: We may share your personal data within
the WinnRewards or with third parties (such as commercial partners and/or service providers)
for the purposes set out in this Charter. We will take appropriate measures to guarantee
security when sharing or transferring such data.
For any questions concerning the seven principles of WinnRewards Data
Protection, please contact the Data Privacy department whose details appear in the clause
Access and modification.
4. SCOPE OF APPLICATION
This Charter applies:
- To all data processing implemented in our subsidiary and managed hotels, i.e. those
operating under WinnRewards. This list is regularly updated.
- To all WinnRewards reservation websites.
WinnRewards will do its utmost to promote the seven principles set out
in this Charter so that our subsidiaries comply with the applicable laws in relation to the
processing of your personal data
5. WHAT PERSONAL DATA IS
At various times, we will be obliged to ask you, as a WinnRewards
customer, for information about you and/or members of your family, such as:
- Contact details (for example, last name, first name, telephone number, email)
- Personal information (for example, date of birth, nationality)
- Information relating to your children (for example, first name, date of birth, age)
- Your credit card number (for transaction and reservation purposes)
- Your membership number for the WinnRewards loyalty program (WinnRewards) or another partner
program (for example, the airline loyalty program)
- Your arrival and departure dates
- Your preferences and interests (for example, smoking or non-smoking room, preferred floor,
type of bedding, type of newspapers/magazines, sports, cultural interests)
- Your questions/comments, during or following a stay in one of our establishments.
The information collected in relation to persons under 18 years of age
is limited to their name, nationality and date of birth, which can only be supplied to us by
an adult. We would be grateful if you could ensure that your children do not send us any
personal data without your consent (particularly via the Internet). If such data is sent,
you can contact the Data Privacy department (Access and
modification clause) to arrange for this information to be
We do not deliberately collect sensitive information, such as
information concerning race, ethnicity, political opinions, religious and philosophical
beliefs, union membership, or details of health or sexual orientation.
Moreover, depending on applicable local laws, other information could
be considered sensitive, such as your credit card number, your leisure activities, personal
activities and hobbies, and whether you are a smoker. We may be obliged to collect such
information to meet your requirements or provide you with an appropriate service, such as a
In this case, depending on the laws in force in certain countries, your
prior consent may be required about the collection of sensitive information.
6. WHEN IS YOUR PERSONAL DATA
Personal data may be collected on a variety of occasions,
- Hotel activities:
- Booking a room
- Checking-in and paying
- Eating/drinking at the hotel bar or restaurant during a stay
- Requests, complaints and/or disputes.
- Participation in marketing programs or events:
- Signing up for the loyalty programs
- Participation in customer surveys (for example, the Guest Satisfaction Survey)
- Online games or competitions
- Subscription to newsletters, to receive offers and promotions via email.
- Transmission of information from third parties:
- Tour operators, travel agencies, review management system, GDS reservation systems,
- Internet activities:
- Connection to WinnRewards websites (IP address, cookies)
- Online forms (online reservation, questionnaires, WinnRewards pages on social
networks, network login devices such as Facebook login etc.).
7. FOR WHAT PURPOSES?
We collect your personal data for the purposes of:
- Meeting our obligations to our customers.
- Managing the reservation of rooms and accommodation requests:
- Creation and storage of legal documents in compliance with accounting standards.
- Managing your stay at the hotel:
- Monitoring your use of services (telephone, bar, pay TV etc.)
- Managing access to rooms
- Internal management of lists of customers having behaved inappropriately during
their stay at the hotel (aggressive and anti-social behavior, non-compliance with
the hotel contract, non-compliance with safety regulations, theft, damage and
vandalism, or payment incidents).
- Improving our hotel service, especially:
- Processing your personal data in our customer marketing program to carry out
marketing operations, promote brands and gain a better understanding of your
requirements and wishes
- Adapting our products and services to better meet your requirements
- Customizing commercial offers and the promotional messages we send to you
- Informing you of special offers and any new services created by WinnRewards or one
of its subsidiaries.
- Managing our relationship with customers before, during and after your stay:
- Managing the loyalty program
- Providing details for the customer database
- Segmentation operations based on reservation history and customer travel preferences
with a view to sending targeted communications
- Predicting and anticipating future behaviors
- Developing statistics and commercial scores, and carrying out reporting
- Providing context data for the offer push tool when a customer visits a Group
website or makes a reservation
- Knowing and managing the preferences of new or repeat customers
- Sending you newsletters, promotions and tourist, hotel or service offers, or offers
from WinnRewards partners, or contacting you by telephone
- Managing requests to unsubscribe from newsletters, promotions, tourist offers and
- Considering the right to object
- Using a dedicated telephone service to search for persons staying in WinnRewards in
the event of serious events affecting the hotel in question (natural disasters,
terrorist attacks etc.).
- Use a trusted third party to cross-check, analyze and apply certain devices to your
collected data at the time of booking or at the time of your stay, to determine your
interests and your customer profile, and to allow us to send you personalized offers.
- Improving WinnRewards services, especially:
- Carrying out surveys and analyses of questionnaires and customer comments
- Managing claims/complaints
- Offering you the benefits of our loyalty program.
- Securing and enhancing your use of WinnRewards websites, especially:
- Improving navigation
- Implementing security and fraud prevention.
- Conforming to local legislation (for example, storing of accounting documents).
8. CONDITIONS OF THIRD-PARTY
ACCESS TO YOUR PERSONAL DATA
As we have many sister organizations and subsidiaries, we endeavor to
provide you with the same services for all. Thus, to guarantee you the right of access and
amendment (Access and modification clause), we have
to share your personal data with internal and external recipients subject to the following
- Within the WinnRewards Group, to offer you the best service, we can share your personal data
and give access to authorized personnel from the Group, including:
- Hotel staff
- Reservation staff using WinnRewards reservation tools
- IT departments
- Commercial partners and marketing services
- Medical services if applicable
- Legal services if applicable
- Generally, any appropriate person within WinnRewards entities for certain specific
categories of personal data.
- With service providers and partners: your personal data may be sent to a third party for the
purposes of supplying you with services and improving your stay, for example:
- External service providers: IT sub-contractors, international call centers, banks,
credit card issuers, external lawyers, dispatchers, printers.
- Commercial partners: WinnRewards may, unless you specify otherwise to the Data
Privacy department, enhance your profile by sharing certain personal information
with its preferred commercial partners. In this case, a trusted third party may
cross-check, analyze and apply certain devices to your data. This data processing
will allow WinnRewards and its privileged contractual partners to determine your
interests and your customer profile and will allow us to send you personalized
- Social networking sites: To allow you to be identified on the website without the
need to fill out a registration form, WinnRewards may use the social network log in
ID such as Facebook/Google login system. If you log in using a social network login
system, you explicitly authorize WinnRewards to access and store the public data on
your social network account, as well as the other data mentioned during use of the
social network login system. WinnRewards may also communicate your email address to
your social network to identify whether you use the specified social network, in
order to post personalized and relevant ads on your social network account if
- Local authorities: We may also be obliged to send your information to local authorities if
this is required by law or as part of an inquiry and in accordance with local regulations.
9. PROTECTION OF YOUR PERSONAL
DATA DURING INTERNATIONAL TRANSFERS
For the purposes set out in Clause 7 of this Charter, we may transfer
your personal data to internal or external recipients who may be in countries offering
different levels of personal data protection.
Consequently, in addition to implementation of this Charter,
WinnRewards employs appropriate measures to ensure secure transfer of your personal data to
a WinnRewards entity or to an external recipient located in a country offering a different
level of privacy from that proposed in the country where the personal data is
Other than those that are required to carry out your reservation,
dataflows to countries having different levels of personal data protection are regulated by
standard contractual manager-to-subcontractor clauses defined by the European Commission.
Dataflows to the United States are made to entities that belong to Safe Harbor.
10. DATA SECURITY
WinnRewards takes appropriate technical and organizational measures, in
accordance with applicable legal provisions, to protect your personal data against illicit
or accidental destruction, accidental alteration or loss, and unauthorized access or
disclosure. To this end, we have taken technical measures (such as firewalls) and
organizational measures (such as a user ID/password system, means of physical protection
When you submit credit card data when making a reservation, SSL (Secure
Socket Layer) encryption technology is used to guarantee a secure transaction.
tracers on its online booking sites www.winnrewards.com ("WinnRewards Websites").
These tracers may be installed on your device depending on the
preferences that you expressed or may express at any time in accordance with this
12. STORAGE OF DATA
We retain your personal data only for the period necessary for the
purposes set out in this Charter or in accordance with the provisions of applicable
13. ACCESS AND
You have the right to access your personal data collected by
WinnRewards and to modify it subject to applicable legal provisions.
You may also exercise your right to object by writing to the address
In the event of difficulty exercising your rights, please contact the
Data Privacy department for the WinnRewards directly by sending an email to
[email protected] or by writing to the address below:
T.a.v. Afdeling Privacy
1033 RW Amsterdam
For the purposes of confidentiality and personal data protection, we
will need to identify you in order to respond to your request. You will be asked to include
a copyof an official piece of identification, such as a driver's license or passport, along
with your request.
If your personal data is inaccurate, incomplete or not up to date,
please send the appropriate amendments to the Data Privacy department as indicated
All requests will receive a response as swiftly as possible and in
accordance with applicable law.
You may also exercise your rights in respect of your personal data that
is stored and processed by a hotel following a stay. To do this, you must contact the hotel
We may modify this Charter from time to time. Consequently, we
recommend that you consult it regularly, particularly when making a reservation at one of
15. QUESTIONS AND
For any questions concerning the WinnRewards personal data protection
policy, please contact the Data Privacy department (Access
and modification clause).