China Privacy Policy

English | 中文

Last Updated: 15 December 2023

Introduction

This privacy policy applies to the mainland People’s Republic of China (the “Policy” or “Privacy Policy”) and is provided to inform you of how Capella Hotel Group, and its direct and indirect affiliates (“Affiliates”) which provide services to various locations operating under or in connection with the Capella and Patina brands (collectively, “Capella,” “us,” or “we”), collect, use, save, share, and transfer your Personal Information (i.e., any personal data that can be used to identify you as an individual) when you use our online service and the related websites, features and contents (collectively, ‘Online Service’ or ‘Website’) products or services, and the ways we provide you with access to update, correct, delete, and protect your Personal Information.

Capella respects your right to privacy and places the utmost importance in safeguarding your Personal Information. Please read this Privacy Policy carefully. By providing your Personal Information and other information through our services, you acknowledge that your Personal Information will be processed pursuant to the terms of this Privacy Policy. If any term in this Privacy Policy is unacceptable to you, please do not use the services or provide any Personal Information.

DATA PROTECTION OFFICER

If after reviewing this privacy statement you have any privacy questions or concerns, would like to request access to the Personal Information we have stored, or would like to correct or object to the processing of your data for legitimate or other purposes, please contact our Data Privacy Officer:

BY EMAIL: [email protected]

BY MAIL: Capella Hotel Group, 3 Temasek Avenue, #23 02 Centennial Tower, Singapore 039190

BY PHONE: + 65 6887 9388

Please allow up to fifteen (15) business days for us to process any data access requests. Where the request involves complex information gathering, we will advise you of the additional time needed to process your request.


This Privacy Policy describes how your Sensitive Personal Information will be Processed for the purposes and by the means described in this Privacy Policy. We shall Process such Sensitive Personal Information upon obtaining your separate consent via a consent form. You need to carefully consider whether your Sensitive Personal Information should be disclosed through our services. However, for many of our operations, it is necessary for you to provide us with such Sensitive Personal Information so that we can provide certain services to you. Accordingly, if you do not provide us with your separate consent, we may not be able to provide certain services to you.

This Policy contains general information and technical details about the steps we take to respect your privacy concerns. We have organized and composed this Privacy Policy by major processes within the scope of information processing so that you can easily browse the information of most interest to you:

  1. How Do We Collect Your Personal Information?
  2. What Are the Purposes and Legal Basis for Processing Your Personal Information?
  3. How Do We Utilize Cookies or Other Technologies?
  4. How We Share your Personal Information?
  5. How Do We Protect Your Personal Information?
  6. Where is Your Personal Information Stored and Cross-Border Data Transferred?
  7. How Long Do We Retain your Personal Information?
  8. How Do You Exercise Your Data Subject Rights?
  9. Age Limits
  10. Links to Third-Party Websites
  11. Privacy Policy Modifications
  12. How to Contact Us
  13. Definitions

1. How do We Collect Your Personal Information?

  1. Capella will collect and use the following types of Personal Information in accordance with your stay at a Capella or Patina-branded property:
    1. Contact information: e.g., your name, address, telephone number, e-mail address, and credit card information in order to facilitate hotel bookings and guest services;
    2. Photo identification to facilitate video surveillance, guest verification, and property protection;
    3. Web data such as location, movements, site visits, IP address, cookie data, and RFID tags in relation to a guest’s browsing history and interaction with Capella’s website and social media channels in order to analyse and improve Capella’s services, advertising, marketing, and overall reach;
    4. Health information, as necessary under permanent or temporary local or global laws and regulations, in order to ensure the health and safety of guests on the property, as well as provide suitable accommodations for guests with any disability or other ailments; and
    5. Information about your stay e.g., comments, satisfaction surveys, preferences, ratings, and other communications, to provide valuable feedback and facilitate improvement of our services.
  2. We also collect Personal Information from other sources. This includes:
    1. When using our Online Service, information may be transferred automatically from the browser of the user to us, e.g., the name of the accessed website, file, date and time of the access, amount of data transferred, notification about successful access, browser type and version, the user's operating system, referrer URL (the previously visited page), IP address and the requesting provider, in order to optimize the Online Service, as well as to ensure the security of processing (e.g., for the defense and clarification purposes of cyberattacks);
    2. When using a contact form or contacting us via E-Mail, where the data provided by the user will be processed exclusively for processing an inquiry and handling and any other use of the data will only take place based on the given consent from the user; or
    3. Information about you from other sources, such as public databases, joint marketing partners, and other third parties mentioned in this Policy, to improve targeted advertising and facilitate bookings.
  3. If you provide us with Personal Information about other individuals (e.g., family members or travel companions), regardless of whether you are travelling together, you must obtain such individuals’ authorization or consent to provide us with their details and let them know where they can find a copy of this Privacy Policy.

2. What Are the Purposes and Legal Basis for Processing Your Personal Information?

  1. We may Process the personal information you supply to us via our website or at our hotels for one or more of the following purposes:
    1. To Process and facilitate bookings, including verifying your identity, taking payments and communicating with you (legal basis: performance of the contract);
    2. To provide you with services at our hotels under the accommodation agreement, including execution of your stay at our hotels and payment processing (legal basis: performance of a contract);
    3. To make contact or interact with you and to handle your requests, remarks or complaints, which you have submitted via our website, during your stay or after your departure (legal basis: consent or legitimate interests);
    4. To execute and manage your participation in our loyalty programme (legal basis: consent);
    5. To maintain, safeguard and improve the quality of our products and services, in particular by performing and analysing satisfaction surveys and guest comments, by Processing your personal data in our centralised guest database enabling us to recognise you as a returning guest, to better appreciate your expectations and preferences, to improve the quality and individual character of our communication with you and to create offerings tailored to you (legal basis: legitimate interests);
    6. To ensure compliance with house rules, to prevent and investigate criminal activities (in particular also by video monitoring), to establish, exercise and defend against legal claims and to safeguard our interests in legal disputes, to ensure IT security and IT operation and to identify credit risks, in accordance with applicable law (legal basis: legitimate interests);
    7. To provide you with information relating to Capella or promotional information about products and services that may be of interest to you, as well as personalized mailings (electronic or otherwise) or other communications (legal basis: consent or legitimate interests);
    8. To place cookies and to use similar technologies as further set out below to analyse and track Online Service performance and activity, as well as view the information provided to us when those technologies are used (legal basis: legitimate interests);
    9. To comply with obligations imposed by local laws or regulations such as the police and tax authorities (legal basis: legal obligation); and
    10. In certain circumstances when it is not possible to obtain your consent, it may be necessary for us to Process your personal data, including Sensitive Personal Information you provided through our services, where it is in your vital interest or in the interest of others, for example in the event of a medical emergency (legal basis: vital interest);
  2. On other occasions where we ask you for consent, we will use the Personal Information for the purpose explained at the individual time. In certain circumstances when it is not possible to obtain your consent, it may be necessary for us to Process your Personal Information, including Sensitive Personal Information, as permitted under the Personal Information Protection Law (“PIPL”).
  3. Wherever we rely on your consent, you can withdraw your consent at any time. However, we may have independent legal grounds for Processing your personal data for other purposes, such as those set out above and permitted under the PIPL.

3. How do We Utilize Cookies and Other Technologies?

3.1 General Information

  1. When you interact with us on our websites, we automatically receive and record information on our server logs from your browser. We may employ cookies in order for our server to recognise a return visitor as a unique user including, without limitation, monitoring information relating to how a visitor arrives at the website, what kind of browser a visitor is on, what operating system a visitor is using, a visitor's IP address, and a visitor's click stream information and time stamp (for example, which pages they have viewed, the time the pages were accessed and the time spent per web page).
  2. Cookies are small text files stored in your computer or other electronic devices which allow us to remember you. The cookies placed by our server are readable only by us. Cookies are not programs and therefore cannot access, read or modify any other data on an electronic device. All web-browsers offer the option to refuse any cookie, and if you refuse our cookie then we do not gather any information on that visitor.

3.2 Cookie Overview

  1. We use the following categories of cookies for the following purposes:
    1. Necessary cookies: To ensure our websites function properly, we use these cookies to enable you to move around the website and to use its features. You do not need to consent for the use of strictly necessary cookies. These cookies usually expire when you end your browsing session or shortly afterwards.
    2. Functionality cookies: These cookies allow Us to remember choices you make (such as your language or your log in details when you return on restricted areas of our Website) and provide enhanced, more personal features. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customise. The information these cookies collect cannot track your browsing activity on other websites.
    3. Performance cookies: To analyse and improve your browsing experience, We use these cookies, such as Google Analytics cookies, to analyse usage of the website and interaction with our content and communication, as well as enable Us to measure and improve performance.
    4. Advertising cookies: To show adverts that are relevant to your interests, third parties serve ads on our behalf through cookies to assist with selecting the ads that are displayed to you and ensuring that you do not see the same ads repeatedly. These To Process and facilitate bookings, including verifying your identity, taking payments and communicating with you (legal basis: performance of the contract); cookies are used only with your consent.

3.3 Cookie Management Options

  1. You may accept or reject cookies (apart from necessary cookies, which are always required and are not subject to your consent). You can manage your cookie preferences and provide or withdraw your consent at any time through our Cookie Consent Management Platform, available at our webpage.
  2. Please bear in mind that if you restrict or disable cookies, this can limit functionality and prevent our websites from working properly.
  3. You may object to the use of cookies that are used for measuring the range of coverage and promotional purposes via:
    1. Deactivation page of the Network Advertising Initiative: http://optout.networkadvertising.org/;
    2. The US-American website: http://www.aboutads.info/choices; or
    3. The European website http://www.youronlinechoices.com/uk/your-ad-choices/.
    4. We promise not to use cookies for any purpose other than those stated in this Privacy Policy.

4. How We Share Your Personal Information?

  1. To facilitate the purposes mentioned under this Privacy Policy, and without prejudice to relevant laws and regulations, we may transfer and/or disclose your Personal Information to any Affiliates of Capella (and other organizations which own the hotels and residences managed by us) and/or third parties who will Process your Personal information according to their own purposes and methods of Processing (together, “Third Party Personal Information Handlers”).
  2. The specific kind of information we share will depend on the context of your interactions with Capella, and the services you use. These Third-Party Personal Information Handlers may be located within or outside the Chinese Mainland. We will only transfer and/or disclose such Personal Information upon obtaining your separate consent, and in accordance with applicable Chinese Mainland data protection laws. For information regarding Capella’s interaction with these Handlers, please see our Third-Party Personal Information Shared List attached below as Annex 1.
  3. Furthermore, we may transfer and/or disclose your Personal Information to third parties appointed/entrusted by us who only Process your Personal Information on our behalf, including any agent, contractor, data intermediary, professional advisor, or third-party service provider who provides administrative, marketing and research, distribution, data processing, telemarketing and communications, payment, transportation, or normal services for hotel operation (e.g. such as online reservation providers, payment providers, tour operators, email communication providers, market research analysts, IT service providers, postal mailing providers, accountants, auditors, lawyers, or other third parties assisting with storage, archival, payroll, or information technology needs), or other services to support the operation of Capella’s business (including its direct marketing activities).
  4. Other than those stated in herein, we will not share your Personal Information with any other third parties, except that we may share data or statistics (which are not Personal Information) with third parties in aggregated or anonymized form.
  5. When we share your Personal Information with any third parties, we will strive to ensure (including but not limited to sharing this Policy, using contractual measures, and adopting encryption for transfer measures) that such third parties comply with this Privacy Policy and other appropriate confidentiality and security measures that we require them to comply with when using your Personal Information, except for the Personal Information you provide directly to the third parties through the use of their services.
  6. With the continuous development of our business, we may engage in mergers, acquisitions, dissolution, liquidation, transfer of assets or similar transactions, and in such cases, we shall inform you all such information that is required under applicable Chinese Mainland data protection laws. Under such situations, your Personal Information may be transferred to any actual assignee or purchaser of all or any part of our Capella business and/or assets, as well as our service providers.
  7. We shall not be required to obtain your consent to Process your Personal Information if any of the following situations apply:
    1. Where the Processing of Personal Information is necessary for the conclusion or performance of a contract to which you are a contracting party, or where it is necessary to carry out human resources management according to lawfully formulated labour rules and lawfully concluded collective contracts;
    2. Where it is necessary to perform a statutory responsibility or obligation, for example, making disclosures when required by law, regulation, or court order of any jurisdiction and/or as requested by any government, regulatory or law enforcement authority or administrative organisation, which may be within or outside the Chinese Mainland;
    3. If the Processing of Personal Information is necessary to respond to a public health emergency, or to protect the life, health or property safety of an individual in case of an emergency;
    4. Where Personal Information is processed within a reasonable scope to carry out news reporting, public opinion supervision or any other activity for public interest purposes;
    5. Where the Processing relates to Personal Information disclosed by you or otherwise already lawfully disclosed, within a reasonable scope in accordance with applicable laws; or
    6. If the Processing of Personal Information is directly related to national security and national defence; public safety, public health and major public interest; or criminal investigations, criminal prosecutions, adjudication or enforcement of judgments, or other related matters.

5. How Do We Protect Your Personal Information?

  1. We have implemented reasonable, feasible, and state-of-the-art technical and organisational security measures (TOMs) and practices which comply with national and industry standards and have established reasonable institutional norms to prevent unauthorized access, public disclosure, use, modification, damage or loss of your personal information, including, but not limited to:
    1. The utilization of virus and malware protection;
    2. The incorporation of data encryption across platforms;
    3. The application of the principle of least-privilege access;
    4. Ensuring secure settings for hardware and software;
    5. Maintaining systems up to date with the latest protection tools;
    6. Conducting regular testing to safeguard the security of systems and networks;
    7. Organizing various back-up procedures for essential data;
    8. Implementing multifactor authentication processes; and
    9. Equipping employees with the know-how to be the first line of defense against any potential security or technological threats.

6. Where Is Your Personal Information Stored and Cross-Border Data Transferred?

  1. We store your Personal Information within Mainland China. Your Personal Information may be transferred and processed outside of Mainland China.
  2. If we need to transfer your Personal Information outside Mainland China, we will fulfil the procedures specified in the relevant laws and regulations, including, but not limited to: we will conduct data exit security assessments, obtain personal information protection certification from professional institutions, or sign data exit standard contracts with overseas data recipients, in order to comply with laws, administrative regulations, and regulations of the national cybersecurity regulatory authorities.
  3. In some cases, the recipients are based in countries in countries outside Mainland China that do not have an adequate level of data protection. We have taken measures to ensure suitable and adequate safeguards to make sure your personal data remains adequately protected. We will inform overseas data recipients of this Policy, and to protect your personal information and fulfill corresponding personal information protection obligations in accordance with security and confidentiality measures no lower than those required by Chinese laws.

7. How Long Do We Retain Your Personal Information?

  1. We retain your Personal Information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by applicable law.
  2. Please note that we may need to retain certain information for recordkeeping purposes and/or to complete transactions, and you may not be able to change or delete the Personal Information you provided until after completion of such transaction.

8. How Do You Exercise Your Data Subject Rights?

  1. You are conferred by the applicable laws and regulations in Mainland China with the following rights related to our Processing of your Personal Information:
    1. Right to rectification. We take reasonable steps to ensure that the information we hold about you is accurate and complete. However, if you believe this is not the case, you have the right to request that any incomplete or inaccurate Personal Information that we Process about you is amended.
    2. Right to deletion. You have the right to ask us to delete your Personal Information, for example where the Personal Information we collected is no longer necessary for the original purpose, where the Personal Information has become obsolete or where you withdraw your consent (if we are Processing your Personal Information based on your consent). However, this will need to be balanced against other factors. For example, we may not be able to comply with your request due to certain legal or regulatory obligations.
    3. Right to restriction of processing. You are entitled to ask us to stop using your Personal Information.
    4. Right to data portability. You have the right to ask us to transfer your Personal Information that you have provided to us to a third party of your choice. This right can only be exercised in certain circumstances as provided by Chinese laws.
    5. Rights relating to automated decision-making. You have the right not to be subjected to automated decision-making, including profiling, which produces legal effect for you or has a similar significant effect. If you believe you have been subject to an automated decision and do not agree with the outcome, you can ask us to explain, and you also have the right to refuse the decisions made only through automated decision-making methods.
    6. Right to withdraw consent. We may ask for your consent to Process your Personal Information in specific cases. When we do this, you have the right to withdraw your consent at any time. We will stop the further Processing as soon as possible after the withdrawal of your consent. However, this does not affect the lawfulness of the Processing before your consent was withdrawn.
  2. You can exercise your above rights through contacting the Data Protection Officer via the channels provided at the beginning of this Policy.
  3. 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 data protection laws.

9. Age Limit

  1. Our services target those who are above the age of fourteen (14). If you have not reached fourteen (14) years of age, please ensure that you have obtained your guardian’s consent before providing us with your Personal Information.
  2. We will not collect, use or otherwise Process Personal Information of individuals who are under fourteen (14) years of age without separate consent from their parents or guardians.
  3. Where we have obtained separate consent from parents or guardians for Processing their minors’ Personal Information, we will only Process, retain and protect those minors’ Personal Information in the same manner and in the same locations as set out in this Privacy Policy. If the parents or guardians refused to provide separate consent for our Processing of their minors’ Personal Information which are necessary, we may not be able to provide certain services to their minors. To exercise any data subject rights for minors, please refer to “How do you exercise your data subject rights” section.

10. Links to Third-Party Websites?

  1. While using some of our services (e.g. in section ‘Discovery’ / ‘Sign up for Capella loyalty programme‘ or in section ‘Book your Stay‘) you will be automatically redirected to other websites.
  2. Please note that this Policy is not valid there. The privacy policy of the linked website may differ significantly from this one.
  3. This Privacy Policy applies only to any information we collect and does not apply to any of your Personal Information that any third party collects during the process of providing service to you, and we do not take any responsibility for the use of Personal Information by any third party to whom you provide the information directly.

11. What About Privacy Policy Modifications?

  1. We reserve the right to change this Data Privacy Policy with regard to the data processing in order to adapt it to changes in the legal situations, changes of the Online Service, or changes related to the procedure of our data Processing.
  2. If a user’s consent is required or if elements of the Privacy Policy contain provisions in regard to the contractual relationship with the users, the changes will only be made with the consent of the users.
  3. Users are requested to keep themselves informed about the content of this Privacy Policy on a regular basis.

12. How to Contact Us?

If you have any questions, complaints, or requests to withdrawal related to Capella’s processing of your Personal Data, you can contact Capella’s Data Protection Officer at: [email protected], or mail to address: Capella Hotel Group, 3 Temasek Avenue, #23 02 Centennial Tower, Singapore 039190.

Without prejudice to any other administrative or judicial remedy, you shall have the right to complain to a supervisory authority: file complaints or reports with regulatory authorities such as consumer rights protection, internet communication, telecommunications, public security, and industry and commerce in the place where the hotel located, or file a lawsuit with a court with jurisdiction in our place of hotel residence, if you believe that the processing of your personal data violates data protection laws.

13. Definitions

  1. Personal Information
    “Personal Information” means any type of information (recorded via electronic means or otherwise) associated with an identified or identifiable natural person, but excluding information after anonymization handling. Personal Information may include Sensitive Personal Information (defined below).
  2. Consent
    We will collect, store, use, process, transmit, provide, disclose or delete (together, “Process” or “Processing”) your Personal Information in accordance with this Privacy Policy, and we may only do so with your consent. Where the applicable Chinese Mainland data protection laws and regulations require us to provide separate consent under certain circumstances, we will only Process such Personal Information upon obtaining your separate consent.
  3. Sensitive Personal Information
    Certain Personal Information may be considered “sensitive” Personal Information due to their particularity. “Sensitive Personal Information” means Personal Information which, if leaked or used illegally, may easily cause harm to the dignity of natural persons, or cause harm to personal or property safety, including biometric information; religious belief; specific identity information; health and medical information; financial account information; individual location tracking information and Personal Information of minors under the age of fourteen (14).
  4. Affiliates
    Capella Affiliates includes following entities:
    1. Patina Hotels & Resorts (“Patina”) and
    2. Other hotels which may be introduced to the Capella Hotel Group.

Annex 1
Third Party Personal Information Shared List

  1. Google Inc.
    Google Analytics - To track and analyse Online Service traffic
    https://www.google.com/intl/en/policies/privacy
  2. Google Inc.
    Tag Manager - To track and analyse Online Service traffic
    https://www.google.com/intl/en/policies/privacy
  3. YouTube LLC.
    Youtube Videos - To provide visual support to a guest’s decision to stay at a Capella or Patina-branded property
    https://www.google.de/intl/de/policies/privacy
  4. LinkedIn Ireland Unlimited Company
    LinkedIn Analytics - To improve individual functions and offers, as well as user experience
    https://www.linkedin.com/legal/privacy-policy
  5. New Relic Inc.
    New Relic - To analyse and improve the speed of access to our website
    https://newrelic.com/privacy
  6. Google Inc.
    Google Ads Conversion - To analyse the effectiveness of advertisements and improve marketing
    https://www.google.com/intl/en/policies/privacy
  7. Google Inc.
    Google Ads Remarketing - To improve target marketing and advisements according to the desires of guests
    https://www.google.com/intl/en/policies/privacy
  8. Facebook Ireland Ltd.
    Facebook Custom Audiences (“Facebook Pixel”) - To assist in displaying interest-based advertisements and to remarket following a guest’s stay at a Capella or Patina-branded property
    https://www.facebook.com/about/privacy
  9. Triptease Group
    Triptease.io - To assist in analysing guest behavior and needs specific to booking rooms, rates, and amenities
    https://www.triptease.com/privacy-policy/

Please see below for additional useful information in relation to each business partner above and:

  1. The types of Personal Information processed;
  2. Possible application scenarios; and
  3. The respective methods of sharing.

1. Google Analytics

  1. This website uses Google Analytics, a web analysis service of Google Inc., 1600 Amphitheatre Parkway Mountain View, CA 94043, USA. (“Google”). Google Analytics uses a specific form of cookie, which is stored on your computer and enables an analysis of your use of our website. The information about your use of this website generated by the cookie is generally transmitted to a Google server in the USA and stored there.
  2. We would like to point out that Google Analytics has been expanded on this website to include the code “gat._anonymizeIp()” ; to ensure the anonymized recording of IP addresses (so-called IP masking). Due to the IP anonymization on this website, your IP address is shortened by Google. Only in exceptional cases the full IP address is transmitted to a Google server in the USA and shortened there.
  3. Google uses this information on our behalf to analyse your use of this website in order to compile reports on website activities and provide additional services related to website and internet use. Google may also transfer this information to third parties as required by law or if said third parties process this data on behalf of Google. The IP address transmitted by your browser in the context of Google Analytics is not merged with other Google data.
  4. You can prevent the storage of cookies by making the proper setting using your browser software. In addition, you can prevent Google from recording the data related to your use of the website generated by the cookie (including your IP address) and from processing this data by downloading and installing the browser plugin available at https://tools.google.com/dlpage/gaoptout?hl=en.
  5. Google Analytics Terms of Service: https://www.google.com/analytics/terms/gb.html
  6. General overview on Google Analytics security and privacy principles: https://support.google.com/analytics/answer/6004245?hl=en
  7. This website also uses Google Analytics for a device-independent analysis of visitor flows, which is carried out via a user ID. You can disable cross-device tracking of your usage in your Google Account under “My information”, “Personal information”.
  8. Legal Basis: Legitimate Interest.

2. Google Tag Manager

  1. Our Online Service uses the Google Tag Manager. This tool allows website tags to be managed through an interface. The Google Tool Manager only implements tags, does not set cookies and does not collect any personal data. The Google Tag Manager triggers other tags that may collect personal information. However, the Google Tag Manager does not access this data.
  2. If deactivated at domain or cookie level, it will remain valid for all tracking tags implemented with Google Tag Manager.
  3. Legal basis: legitimate interest.

3. YouTube Videos

  1. Our site uses YouTube plugins from the Google-owned video portal service. The operator of these pages is YouTube, LLC, 901 Cherry Ave., San Bruno, CA 94066, USA ("Youtube").
  2. We have integrated YouTube videos into our website, which are stored on http://www.YouTube.com and can be played directly from our website. These are all integrated in the “extended data protection mode ”, i.e. no Personal Information about you as a User will be transmitted to YouTube, if you do not click on the videos to start playing them. Only when you play the videos the data referred to in the next paragraph will be transferred to YouTube. We have no influence on this data transfer.
  3. By visiting the website, YouTube receives the information that you have accessed the corresponding subpage of our website. In addition, other data specified in this privacy policy will be transmitted. This is independent of whether YouTube provides a user account through which you are logged in or whether no user account exists. If you are logged in to Google, your information will be directly associated with your account. If you do not wish to be associated with your profile on YouTube, you must log out before activating the button. YouTube stores your data as user profiles and uses them for purposes of advertising, market research and/or demand-oriented design of its website. Such evaluation takes place in particular (even for unlogged-in users) to provide demand-oriented advertising and to inform other users of the social network about your activities on our website. You have the right to object to the creation of these user profiles, whereby you must contact YouTube to exercise this right.
  4. For more information on the purpose and scope of data collection and processing by YouTube, please refer to the privacy policy linked above. There you will also find further information about your rights and setting options to protect your privacy.
  5. Legal Basis: consent.

4. LinkedIn Analytics

  1. We use "LinkedIn Analytics" on our website, a service of LinkedIn Ireland Unlimited Company, Wilton Plaza, Wilton Place, Dublin 2, Ireland (hereinafter referred to as: "LinkedIn"). LinkedIn Analytics stores and processes information about your user behavior on our website. LinkedIn Analytics uses cookies for this purpose, among other things, which enable an analysis of your use of our website.
  2. We use LinkedIn Analytics for marketing and optimization purposes, in particular to analyse the use of our website and to continuously improve individual functions and offers as well as the user experience. By statistically evaluating user behavior, we can improve our offer and make it more interesting for you as a user.
  3. In addition to the privacy policy linked above, further information from the third-party provider on data protection can be found at: https://www.linkedin.com/psettings/guest-controls.
  4. Legal basis: consent.

5. New Relic

  1. We use the web analysis service “New Relic” on our website, a service of New Relic Inc, 101 Second Street, 15th Floor, San Francisco, CA 94105, USA (hereinafter referred to as: "NewRelic").
  2. This service allows statistical analysis of the speed of access to our website. Through the plugin, New Relic receives the information that you have accessed the corresponding page of our website. If you are logged in as a user at New Relic, New Relic can assign the visit to your account. If you are not a member of New Relic, there is still the possibility that New Relic will find out and save your IP address.
  3. Legal basis: consent.

6. Google Ads Conversion

  1. We use the services of Google Ads to draw attention to our attractive offers with the help of advertising materials (so-called Google Ads) on external websites. We can determine in relation to the data of the advertising campaigns how successful the individual advertising measures are. We are interested in showing you advertisements that are of interest to you, to make our website more interesting for you and to achieve a fair calculation of advertising costs.
  2. The advertising materials are delivered by Google via so-called “Ad Servers”. For this purpose, we use ad server cookies, through which certain parameters for measuring success, such as the insertion of ads or clicks by users, can be measured. If you access our website via a Google ad, Google Ads stores a cookie on your device. These cookies are not intended to identify you personally. For this cookie, the unique cookie ID, number of ad impressions per placement (frequency), last impression (relevant for post-view conversions) and opt-out information (mark that the user no longer wishes to be addressed) are usually stored as analysis values.
  3. These cookies enable Google to recognize your Internet browser. If a user visits certain pages of an Ads customer's website and the cookie stored on their device has not expired, Google and the customer can recognize that the user has clicked on the ad and has been redirected to this page. Each Ads customer is assigned a different cookie. Cookies cannot therefore be traced via the websites of Ads customers. We do not collect and process any personal data in the aforementioned advertising measures. We only receive statistical evaluations from Google. On the basis of these evaluations, we can recognize which of the used advertising measures are particularly effective. We do not receive any further data from the use of advertising material; in particular, we cannot identify users on the basis of this information.
  4. Due to the marketing tools used, your browser automatically starts a direct connection to the Google server. We have no influence on the extent and the further use of the data which are raised by the use of this tool by Google and inform you therefore according to our knowledge: By the integration of Ads conversion Google receives the information that you called the appropriate part of our Internet appearance or clicked an announcement of us. If you are registered with a Google service, Google may associate your visit with your account. Even if you are not registered with Google or have not logged in, it is possible that the providers may obtain and store your IP address.
  5. Legal basis: consent.

7. Google Ads Remarketing

  1. We use the remarketing function within the Google Ads service. The remarketing function allows us to present to users of our website advertisements based on their interests on other websites within the Google advertising network (in Google search or on YouTube, so-called "Google ads" or on other websites). For this purpose, the interaction of users on our website is analysed, e.g., which offers the user was interested in, in order to be able to display targeted advertising to users even after visiting our website on other pages. To do this, Google stores cookies in the browsers of users who visit certain Google services or websites in the Google Display Network. This cookie is used to record the visits of these users. The number is used to uniquely identify a web browser on a particular device. Used Cookies: Type C. For further information, see section “How Do We Utilize Cookies or Other Technologies?” of this Policy.
  2. Legal basis: consent.

8. Facebook Custom Audiences (“Facebook Pixel”)

  1. This website uses the so-called "Facebook Pixel" of the social network "Facebook" for the following purposes:
    1. Facebook (website) Custom Audiences
      We use the Facebook pixel for remarketing purposes to be able to contact you again within 180 days. This allows Us to display interest-based advertisements ("Facebook Ads") to Users of the website when they visit the social network "Facebook" or other websites also using this tool. In this way, We pursue the interest in displaying advertisements that are of interest to you in order to make our website or offers more interesting for you.
    2. Facebook conversion
      We also use the Facebook Pixel to ensure that our Facebook Ads match the potential interest of Users and are not annoying. With the help of the Facebook Pixel, We can track the effectiveness of Facebook ads for statistical and market research purposes by seeing whether Users were redirected to our website after clicking on a Facebook ad (so-called "conversion").
  2. Due to the marketing tools used, your browser automatically establishes a direct connection with the Facebook server as soon as you have agreed to the use of cookies requiring your consent. Through the integration of the Facebook pixel, Facebook receives the information that you have called up the corresponding website of our internet presence or clicked on an advertisement from us. If you are registered with a Facebook service, Facebook can assign the visit to your account.
  3. The processing of this data by Facebook takes place within the framework of Facebook's data policy. Special information and details about the Facebook pixel and its functionality can also be found in the Facebook help area. For further information, see section “How Do We Utilize Cookies or Other Technologies?” of this Policy.
  4. We are jointly responsible with Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (Facebook) for the collection and transfer of data in this process. This applies to the following purposes:
    • The creation of individualized or suitable ads, as well as for their optimization
    • Delivery of commercial and transaction-related messages (e.g. via Messenger)

    The following processes are therefore not covered by joint controllership:

    • The process that takes place after the collection and transmission is within the sole responsibility of Facebook.
    • The preparation of reports and analyses in aggregated and anonymized form is carried out as a Processor and is therefore within our responsibility.
  5. The contact details of the Controller and the data protection officer of Facebook can be found at the privacy policy link for Facebook above.
  6. We have agreed with Facebook that Facebook can be used as a contact point for the exercise of data subject rights. Without prejudice to this, the jurisdiction of the Rights of Data Subjects is not limited.
  7. Further information on how Facebook processes personal data, including its legal basis and further information on the rights of data subjects can be found at the privacy policy link for Facebook above.
  8. Information on the data security conditions can be found here: https://www.facebook.com/legal/terms/data_security_terms.
  9. Legal basis: consent.

2.12 Triptease.io

  1. We use the Triptease service to analyse User behaviour. The operating company in Europe is Triptease Ltd, WeWork Bishopsgate, 15 Bishopsgate, London.
  2. We may share a limited amount of your information (such as room search, email, and name if you provide it) with the Triptease Group (“Triptease”) and use Triptease to collect data for analysis purposes when you visit our website to book a stay with us.
  3. As our shared data controller, Triptease analyses your use of our website and tracks it through cookies and similar technologies so that we can improve our services.
  4. Further information on the use of cookies by Triptease can be found at https://www.triptease.com/cookie-policy/.
  5. Legal basis: consent.
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