At Hotel Nikko Hai Phong (collectively “hotel”, “we”, “us” or “our”) we value you as our Guest and recognize privacy is important to you, therefore this statement developed. This privacy statement (policy) describes the privacy practices and applies to Hotel Nikko Hai Phong, its subsidiaries and all of hotels within the group.
By using any of our products, services, you agree to the terms and conditions of this privacy statement, you understand and acknowledge that we will collect and use personal information as described in this statement.
1 - DATA DEFINITIONS
a. Personal data:
At every touch point through your stay and interactions, we may collect personal information, such as:
Your name, gender, postal address, phone number, email address, card or other payment data, financial information, language preference.
Date of birth, place of birth, nationality, passport, visa or other government-issued identification
Special dates such as birthdays, anniversary and special occasion
Membership or loyalty program data, including co-branded, travel partner…
Travel itinerary, tour group or activity data
Prior stays or interactions, goods and services purchased, special service and amenity requests
Social media account ID, profile photo and other publicly data available, or linked accounts.
In some limited circumstances, we may collect images and videos data via security cameras in public areas in our properties or from our surveillance personnel for loss prevention. We may also collect data about family members and companions, such as names and ages of children for applicable laws requirement only. We never knowingly collect personal information from individuals under 18 years of age unless required by applicable laws. As a parent or legal guardian, we request you do not allow your children to submit personal information without your permission.
If you submit any personal data about other people to us, you represent that you have the authority to do so and you permit us to use the data in accordance with this privacy statement.
b. Sensitive data:
The sensitive data such as information related to your social security number, racial or ethnic origin, political opinions, religion, beliefs, sex life, health and biometric information, genetic information, criminal background. We do not generally collect sensitive data information from you and we ask that you not send us or disclose through our Services to us unless it is volunteered by you or unless we are required to do so by applicable laws or regulations. We may use health data provided by you to serve you better and meet your particular needs (for example, disability access).
c. Other data:
Refer to the information that generally do not reveal your specific identity or direct-relate to an individual, such as: browser and device data, app usage, data through cookies and other technology. If other data reveal your identity or relate to an individual, we will treat as personal data.
2 - HOW WE COLLECT YOUR DATA:
a. Online services
b. Offline interaction & property visit
We collect personal data when you visit our property, use our property services and outlets, such as restaurants, concierge services, health club & spa services. We also collect when you attend promotion event that we host or we participated.
c. Customer care & booking center
We collect personal data when you make a reservation over the phone, communicate, connect with us through email, fax. The communications may be recorded for purposes of quality assurance and training.
d. Owners & franchises
We collect personal data from Owners & franchises that we managed and/or independent owned with us.
e. Strategic business partners
We collect personal data from independent companies such as OTA (Online Travel Agent), Travel Agency and Tour Operator with whom we partner to provide you with goods and services.
f. Other sources
We collect personal data from other sources, such as public database, other third parties that does not address in this privacy statement.
3 – HOW WE USE DATA
We use your personal data and other data in variety ways, including to provide and personalize the Services you request, to offer you services, and where required by applicable laws and regulations.
In some circumstances, obligation personal data is required in order to provide you services. Failure to provide this information may prevent us to process your requested services.
More detail as below:
We use your personal data and other date to provide the services you request including reservations, payments, administrative information, meeting and event planning.
We use your email address to send you hotel e-invoice bill. It is your responsibility to ensure that we have the correct and preferred email address for you. If you make a reservation for another people using your email address, that person’s e-invoice will be sent to your email address as well. You can select to receive a paper copy of e-invoice URL by contact our front desk.
We use your personal data and other data with your consent to personalize the tailored services according to your preferences.
We use your personal data and other data with your consent to send you marketing communications, messages, promotion offers, customer satisfaction, research or quality assurance surveys.
We use your personal data and other data with your consent to offer and manage your Loyalty, membership programs, send you offers, promotions and information about your account status, benefits, rewards or points.
We use your personal data and other data with your consent for data analysis, audits, security and fraud check and prevention, developing our new goods and services, improving our services, performance and operating our business activities.
4 – DISCLOSURE, SHARE OF DATA
In order to provide you the highest level of hospitality & services, we may share your data with the following:
Okura Nikko Hotels Management, Owners and Franchises to provide and personalize the Services, Loyalty, membership programs
Strategic business partners, Service Providers to provide and personalize the Services, such as travel-related, airline, rental car, website hosting, email marketing, payment processing, e-invoice and other services.
Corporate Re-organization, merge, transfer, sale, joint venture, or other disposition of all or any portion of the Okura Nikko Hotels Management business, assets or stock (including any bankruptcy or similar proceedings).
We may use and disclose your data as we believe to be necessary as below, except where we are not allowed to under applicable laws:
To comply with applicable laws or regulations, including laws or regulations outside your country of residence
To comply with legal process
To respond to requests, to meet national security or law enforcement requirements from government authorities including authorities outside your country of residence
To enforce our terms and conditions, to protect our property and operations, to protect you and others
5 – YOUR RIGHTS OF DATA & RETENTION
a. Access, Change or Suppress your data
If you would like to review, correct, update, suppress, restrict or delete personal data that you have previously provided to us, or if you would like to receive a soft copy of your personal data for some purposes, you can contact us at our email: email@example.com or by postal mail:
Hotel Nikko Hai Phong
No. 1, Road 1, Waterfront City, Vinh Niem, Le Chan, Hai Phong, Viet Nam
In your request, please indicate specifically the personal information you would like to have changed or suppressed from our database, or any other limitations you would like to put on our use of your data.
For your protection, we only fulfill requests for the personal data associated with the particular email address that you use to send us the requests, and we may need to verify your identity before fulfilling your requests. We will try to comply with your requests as soon as reasonably practicable.
We may need to retain certain data for recordkeeping purposes and/or to complete any transactions or to comply with legal or accounting obligations. There may also be residual data that will remain within our databases and other records, which will not be removed. In addition, there may be certain data that we may not allow you to review for legal, security or other reasons.
We will retain your personal data for the period necessary to fulfill the purposes outlined in this privacy statement unless a longer retention period is required or permitted by law.
We use the following criteria to determine the applicable retention period, including: while we have an active relationship with you; as necessary to fulfill our contractual obligations; as necessary to fulfill a legal or accounting obligations to which we subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); when retention is advisable based on our legal position (such as for statutes of limitations, litigation or regulatory investigations).
6 – NON-HOTEL NIKKO HAI PHONG ENTITIES AND THIRD-PARTY LINK
Our Sites and Apps may contain links to other websites, including websites that collect data or allow others to send you such links. A link to a third-party website does not mean that we endorse it or that we are affiliated with it.
We do not exercise control over third-party websites and we are not responsible for the collection, use, disclose of privacy, data, practices of any entities outside the Okura Nikko Hotels Management including Owners, franchises, strategic partners or other entities this statement does not address.
We encourage you to be aware when access such third-party websites, contents and providing any information at your own risk.
7 – SECURITY
We try our best to use reasonable technical, services and administrative guards to protect the confidentiality and security of your data transmitted to us. However, no data transmission over Internet network or other network or storage system can be guaranteed to be 100% secure, you do so at your own risk.
If you have reason to be believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contact us” section.
8 – UPDATES
We reserve the rights to change this privacy statement in necessary to reflect changes in our practices or to comply with changes in the law.
Any changes will become effective when we post online. Your uses of the services following these changes means that you accept the revised privacy statement.
9 – CONTACT US
If you have any questions, concerns or complaint about this privacy statement, please contact us at our email: firstname.lastname@example.org or by postal mail:
Hotel Nikko Hai Phong
No. 1, Road 1, Waterfront City, Vinh Niem, Le Chan, Hai Phong, Viet Nam
1. INTRODUCTION AND GENERAL COMMITMENT
(i) The Company will clarify the purpose of use of the Personal Data the Company receives and only use it for the intended purpose.
(ii) The Company will not provide third parties with the Personal Data the Company receives without the customer's approval, except for cases mentioned in this Item 6 below.
(iii) The Company will make every effort to manage Personal Data in a safe and appropriate manner by implementing security measures to prevent exposing Personal Data to risks, such as the unauthorized access of Personal Data
from the outside or the loss, destruction, alteration, and leakage of information.
2. PERSONAL DATA
Personal Data is any information that is associated with a particular person or may lead to the identification of a particular person. Through the course of our business, the Company receives a wide range of Personal Data about your needs or circumstances which would allow us to identify you, including but not limited to:
(i) Personal details such as name, date of birth, gender, nationality, phone number, email address, VISA or permission for staying Vietnam, emergency contact and credit card information for deposits and payments.
(ii) Digital account information such as username, password, contact preference, or other authentication data.
(iii) Information relating to financial position, business activities, buying habits, and product preferences relevant to our products, services, and business activities.
(iv) Information about your commercial interests and requirements, products you may wish to purchase or services you may wish to engage us to perform.
(v) Information regarding our communication with you and your attendance at conferences or promotional events.
(vi) If you are a supplier or prospective supplier, information about your business skills, services, products, and prices.
The Company may also receive certain information relating health status and private information recorded in the health record which can be considered as ”sensitive personal data” pursuant to the law of Vietnam and under other applicable jurisdiction.
The Company receives this information directly from you through a variety of means, such as applications and requests, surveys, business negotiations, and executed contracts and agreements. The Company also receives Personal Data through publicly available media real estate registries, commercial registries, telephone directories. The Personal Data that comes into our possession will be used for the purposes mentioned in this Item 3 below.
3. PURPOSE OF USE OF PERSONAL DATA
The customer agrees that the Company will use the Personal Data in compliance with the data protection legislation to present information and proposals, execute and perform contracts and agreements, provide after-sales service, contact and
notify customers, develop new products and services, provide information deemed useful to customers, and perform other actions related to the businesses conducted by the Company or its group companies. These businesses include housing, renovation, rental housing, condominium, commercial store development, construction, real estate subdivision, real estate agency services, environment and energy, non-life insurance agency, hotel, interior, and other various businesses.
In addition to the above, Personal Data will also be used for the following purposes.
(i) Receive customer feedback and thoughts.
(ii) Respond to customer inquiries and requests for reference materials.
(iii) Conduct market research and development of new products and services.
(iv) Provide notice about various events, seminars, campaigns, membership services, and other activities.
(v) Offer electronic mail delivery services and deliver publications.
(vi) Provide information about the products and services offered by the Company or its business partners and affiliates.
(vii) Confirm matters for the purpose of audits.
(viii) Use for any other matters incidental and related to the businesses of the Company.
It should be noted that the Company may provide Personal Data to third parties as described in Item 6 and 7 below to the extent necessary to ensure smooth performance of the business operations it outsources to these third parties. In this case, the Company will enter into agreements with these third parties regarding handling the said information and implement other measures to supervise them.
4. BASE OF USE OF PERSONAL DATA
(i) Processing purposes (mentioned in Item 3 above).
(ii) Type of used Personal Data (mentioned in Item 2 above).
(iii) Method of processing Personal Data (mentioned in Item 5 below).
(iv) Information on any third party related to the processing purposes (mentioned in Item 6 and 7 below).
(v) Undesirable consequences and damage that may occur (mentioned in Item 10 below).
(vi) Time for starting and completing the processing of data (mentioned in Item 5 below).
Your consent may always be withdrawn at any time. In such case, be aware that the withdrawal of consent shall not affect the lawfulness of the processing based on your consent before the withdrawal. The Company hereto will stop processing your Personal Data and request related third parties to stop it.
If you refuse to provide us with any or all of Personal Data or if you provide us with incomplete or inaccurate information, please be aware that we may not be able to provide or deliver to you all or parts of our products and services, which you may have requested from us in full quality. Please keep in mind that we only ask for such information that can help us fully provide our products and services to you.
5. SECURING PERSONAL DATA
The security of information is very important to the Company and the Company has measures in place which are designed to prevent unauthorized access to your Personal Data, including but not limited to:
(i) Client files are stored on our secure client management systems. Access is restricted on client systems to those within the business who are required to have access to Personal Data for legitimate business purposes.
(ii) Hard copy documentation is stored in locked cabinets.
The Company ensures access to Personal Data is restricted to employees and workers or other persons working within the Company or its group companies on a need to know basis. Training is provided to any of those employees and workers who need access to Personal Data.
The Company will retain Personal Data for as long as the purpose for which the Company collected it continues. It is then destroyed unless further retention is required to satisfy a legal regulatory or accounting requirement or to protect Company’s interests or any other case the Company deems necessary.
6. PROVIDING PERSONAL DATA TO THIRD PARTY
The Company will not otherwise provide Personal Data to third parties unless we have your permission or we are under a legal or similar obligation in the following cases:
(i) When the Company provides Personal Data as statistical data in a way that makes it impossible to identify customers.
(ii) When the Company is required by laws and regulations to provide Personal Data.
(iii) When the provision of information is necessary to protect life, body, or property and the Company cannot obtain the customer's consent.
(iv) When the Company is required to cooperate with the administration of the national or local government and other authorities as stipulated by laws and regulations, and the acquisition of consent from customers may inhibit the administration of these bodies.
(v) When the Company provides Personal Data to the contractors, advisors, agents, subsidiaries, associates, owners and competent authorities for the same purpose as purpose of use as mentioned in Item 3 above.
(vi) When the Company provides Personal Data to any officer, employee, agent (including subsidiaries, affiliates, representatives and branch offices of the Company), professional advisers, third party service providers, agents or independent contractors providing services to support the Company's business operations under a duty of confidentiality to the Company.
7. TRANSFERRING PERSONAL DATA TO THIRD COUNTRIES
The Company may transfer your Personal Data to third parties located outside Vietnam’s boundaries. The Company will take reasonable steps to ensure these third parties handle the Personal Data in compliance with the laws and protect Personal Data regardless of which country it is transferred to.
By providing your Personal Data to us you consent to this transfer. If you do not wish for your Personal Data to be transferred to another jurisdiction then you should not provide us with your Personal Data.
The collection and use of Personal Data by these third parties may also be subject to separate privacy policies.
Your Personal Data may be disclosed to the following third parties, but not limited to:
(i) Investors of the Company
(ii) Travel agents of the Company
(iii) Operators of the Company
8. DISCLOSING, CORRECTING, OR SUSPENDING THE USE, ETC. OF PERSONAL DATA
Upon receiving one of the following requests from a customer, the Company will endeavour to take the necessary action within a reasonable period and to a reasonable extent after confirming the identity of the customer unless we are subject to confidentiality obligations or some other restriction on giving access to the information or permitted to refuse you access under the respective laws.
(i) When a customer requests the disclosure of its Personal Data.
(ii) When a customer requests to correct, add, or delete its Personal Data.
However, this only applies to cases in which Personal Data is factually incorrect.
(iii) When a customer requests to suspend the use or eliminate its Personal Data.
(iv) When a customer requests the restriction of processing of his/her personal data, unless otherwise provided by law.
(v) When a customer objects to processing of his/her personal data by the Company for the purposes of preventing or limiting the disclosure of personal data or its use for advertising or marketing, unless otherwise provided by law.
However, this does not apply to Personal Data the Company holds in accordance with applicable data protection legislation.
Inquiries about Personal Data and requests to disclose, correct, or suspend the use, etc. of Personal Data as described above will be accepted in accordance with the following procedures:
(a) Requests must be made by submitting a request by mail or Email via contact information as described at Item 13 below.
(b) When a customer submits a request, the identity of the customer will be confirmed by various means, such as by using the driver's license, passport, identity card or other forms of identification, information registered with the Company such as address, name, telephone number, and date of birth, or by calling back the telephone number registered with the Company.
When a proxy submits a request, in addition to confirming the identity of the customer as described above, the capacity of proxy will be confirmed by power of attorney, certificate of seal-impression, or other means.
(c) A prescribed fee may be charged to process a request to disclose Personal Data.
In addition, only for requests for disclosure of Personal Data, we will charge a fee of VND 200,000 per request item.
When we have no ongoing legitimate business need to process Personal Data or you request that we delete Personal Data, we will make reasonable attempts to delete it.
The customer can disable the cookie function by changing the configuration of the browser the customer use. Please note that disabling this function may prevent the customer from using all or some of the services on the website.
10. LIMITATION OF LIABILITY
The Company will apply appropriate technical and security solutions to effectively protect Personal Data. However, the customer should be noted that although the Company has taken reasonable measures to protect Personal Data, there is no website, internet connection, computer system or wireless connection which is safe absolutely. Therefore, the Company cannot make a commitment to ensure that Personal Data provided to the Company will be absolutely secure, and the Company cannot be responsible in case of having illegal access or leakage of Personal Data without fault of the Company. The Company excludes all liability for the consequences of any unauthorized access, disclosure of, misuse of or loss or corruption of Personal Data not due to our misconduct. If the customer does not agree to the terms described above, the Company recommends that customers should not send details of information to the Company.
11. RIGHTS AND OBLIGATIONS
By providing Personal Data for the Company, you have rights and obligations in accordance with respective laws, which may include:
(i) To be informed of your Personal Data handling procedures.
(ii) To give/withdraw consent to the processing of your Personal Data.
(iii) To access or to request the Company to provide you with Personal Data in order to disclose, correct or suspend.
(iv) To obtain restriction on or object to the processing of Personal Data, which is implemented within 72 hours after receiving your request, and all Personal Data that you request the restriction.
(v) To self-protection or request competent authorities to implement civil right protection methods, including but not limited to recognizing, respecting, protecting and guaranteeing your civil rights; order the termination of the act of violation; order a public apology and/or rectification; order the performance of civil obligations; order compensation for damage from the Company or cancellation of isolated unlawful decision of competent individuals and entities.
(vi) To comply with the relevant applicable laws.
(vii) To respect and protect your and others’ Personal Data.
(viii) To provide your Personal Data fully and accurately when you consent to the processing.
If the customer has any concerns or complaints about the way the Company uses Personal Data, please contact us at our Contact Information below. If the Company cannot resolve any issue, the customer has the right to complain to the data protection authority in Vietnam.
13. CONTACT INFORMATION
CHUO VIETNAM CO.,LTD
Address: No.412, HK10 Area, Waterfront City Project, Vinh Niem Ward, Le Chan Dist, Hai Phong City, Vietnam.
We will respond to your complaint or try to resolve the issue to your satisfaction within a reasonable period at our best effort.