CAPTURING PERSONAL INFORMATION
We collect personal information at every touch point or guest interaction, and in conducting every aspect of our business. This personal information may include: your name, mailing address, billing address, email address, phone number, information related to your reservation, stay or visit to a property; information related to the purchase and receipt of products and/or services; nationality, passport number and date and place of issue; travel history; payment information, such as your payment card number and other card information, as well as authentication information and other billing and account details associated with mobile billing; guest preferences; marketing and communication preferences; reviews and opinions about our Portfolio of Brands or properties (including but not limited to: Atmosphere, OZEN, OBLU, OBLU Select and OBLU X); and other types of information that you choose to provide to us or that we may obtain about you.
Furthermore, we collect other personal information in certain cases, such as;
Surveys: We may request demographic data or other personal information in customer surveys.
On-property Collection: We collect additional personal information during registration/check-in at our properties, including such information as may be required by local laws. We may also use closed circuit television and other security measures at our properties that may capture or record images of guests and visitors in public areas, as well as information related to your location while on our properties (via keycards and other technologies). We may also use closed-circuit television and other technologies that record sound or video for the protection of our staff, guests and visitors to our properties where permitted by law. In addition, we may collect personal information in connection with on-property services, such as concierge services, spas, activities, child care services and equipment rental.
Social Media: If you choose to participate in AHR Sponsored social media activities or offerings, we may collect certain information from your social media account consistent with your settings within the social media service, such as location, check-ins, activities, interests, photos, videos, status updates and friend list. We may also allow you to enter competitions to provide photos, videos relating to your stay with us, which you may share with your connections on social media for votes, shared offers or other promotions.
In addition to the information we collect from you directly, we may also infer or collect information about you based on the information you provide to us or from information we collect or infer from any other sources.
APPLICATION OF PERSONAL INFORMATION
We use captured personal information in multiple ways to personalise the services you request and expect from Atmosphere Hotels & Resorts, conduct direct marketing and sales promotions and as set forth below in more detail. We will collect your consent prior to processing your data where required by applicable law.
We are obligated to collect certain data, including your name, address, payment information, and, in certain countries, travel document information, in order to process your reservation. Failure to provide this information will result in our inability to process your reservation.
Marketing and Communications: Where permitted or reasonably applicable, we may use your personal information to provide or offer you newsletters, promotions and featured specials, as well as other marketing messages in accordance with any communications preferences you have expressed. We use your information to provide in-stay messaging, account alerts, and reservation confirmations; to send you marketing messages; to conduct surveys and other activities. We may provide these communications via email, postal mail, online advertising, social media, telephone, text message, push notifications, messaging applications, in-room television and other means. With your consent, we also use user-generated content from social media services to deliver display advertising or on our website and apps.
Service Enhancements: We may use your personal information to improve Atmosphere Hotels & Resort’s services and to ensure that our site, products, and services are of interest to you. We also use your personal information to provide you with the expected level of hospitality in-room and throughout our properties.
Data Accuracy, Analytics and Personalization: We may aggregate your personal information with data from third-party sources for purposes of keeping information up to date and analytics. We also rely on information from third parties in order to provide better and more personalised service. For example, if you connect your social media services or other accounts to our services, we may use this information to make your experiences with us more personal.
DISTRIBUTE PERSONAL INFORMATION
In order to offer you the expected level of hospitality and to provide you with the best level of service, we may share your personal information among our service providers, and other third parties as set forth in detail below:
On-property Services: We may share personal information with third-party providers of on-property services such as concierge services, WiFi access providers, transport service providers, spa treatments, diving and watersports centres, golf, or dining experiences.
Service Providers: We rely on third parties to provide services and products on our behalf and may share your personal information with them as appropriate. Generally, our service providers are contractually obligated to protect your personal information and may not otherwise use or share your personal information, except as may be required by law. However, our fraud detection service providers may use, but not share, your personal information for fraud detection purposes. We may use service providers to communicate news and deliver promotional and transactional materials to you on our behalf, including personalized online and mobile advertising in accordance with your preferences and applicable law. Please see our Policy on Cookies and Other Technologies for more information. Atmosphere Hotels & Resorts will only work with parties that offer a method to opt-out of such advertising. We may also share information with service providers to allow you to create itineraries by selecting sites, activities, and restaurants from lists that we have personalized for you based on your preferences and third-party data.
Other: In addition, Atmosphere Hotels & Resorts may disclose personal information in order to:
Comply with applicable laws.
Respond to governmental inquiries or requests from public authorities.
Comply with valid legal process.
Comply with a court order or order from a Government agency.
Protect the rights, privacy, safety or property of AHR, site visitors, guests, employees or the public.
Permit us to pursue available remedies or limit the damages that we may sustain.
Enforce our websites’ terms and conditions.
Respond to an emergency.
When you visit and interact with Atmosphere Hotels & Resorts websites and apps, we collect other information that does not directly identify you about your use of the site, such as a catalog of the site pages you visit, and the number of visits to our sites (“Other Information”). We use Other Information, as well as data received from third parties, to deliver you email, online (on our sites and other sites) and mobile advertisements.
We may use information we have collected and aggregated, or anonymized personal information received from third parties, to understand more about our users, customers or clientele (for example, we may use aggregated information to calculate the percentage of our users who have a particular telephone area code). This includes demographic data, such as date of birth, gender and marital status, inferred commercial interests, such as favorite products or hobbies, and other information we may collect from you or from third parties.
The term “sensitive information” refers to information related to your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, sex life or sexual orientation, genetic information, criminal background, and any biometric data used for the purpose of unique identification. In some jurisdictions, mobile phone numbers, location data, and information contained on identity documents also are considered sensitive information.
We do not generally collect sensitive information unless it is volunteered by you or unless we are required to do so pursuant to applicable laws or regulations. We may use health data provided by you to serve you better and meet your particular needs (for example, the provision of disability access).
PERSONAL INFORMATION FROM CHILDREN
We do not knowingly collect personal information from individuals under 18 years of age. As a parent or legal guardian, please do not to allow your children to submit personal information without your permission.
LINKS TO THIRD-PARTY WEBSITES AND SERVICES
PROTECTING PERSONAL INFORMATION
Atmosphere Hotels and Resorts will take reasonable measures to: (i) protect personal information from unauthorized access, disclosure, alteration or destruction, and (ii) keep personal information accurate and up-to-date as appropriate. Atmosphere Hotels and Resorts maintains a PCI compliance program and an IT compliance program. In the event of a security incident, we will notify regulators and/or consumers as required by applicable laws or regulations.
We also seek to require our affiliates and service providers with whom we share personal information to exercise reasonable efforts to maintain the confidentiality of personal information about you. For online transactions, we use reasonable technological measures to protect the personal information that you transmit to us via our site. Unfortunately, however, no security system or system of transmitting data over the Internet can be guaranteed to be entirely secure.
For your own privacy protection, please do not send payment card numbers or any other confidential personal information to us via email.
We will not contact you by mobile/text messaging or email to ask for your confidential personal information or payment card details. We will only ask for payment card details by telephone when you are booking a reservation or promotional package. If you receive this type of request, you should not respond to it. We also ask that you please notify us at firstname.lastname@example.org
CHANGING AND ACCESSING YOUR PERSONAL INFORMATION
To the extent required by applicable law, you may be able to request that we inform you about the personal information we maintain about you and, where appropriate, withdraw your consent for certain data processing activity and/or request that we update, correct, delete, and/or stop processing your personal information. We will make all required updates and changes within the time specified by applicable law and as required by law. When permitted by law, we may charge an appropriate fee to cover the costs of responding to the request. Such requests may be submitted in writing to email@example.com or Atmosphere Hotels and Resorts Data Protection Officer, 3rd Floor, Aage’, 12 Boduthakurufaanu Magu, Henveiru, Male’ 20094, Republic of Maldives. To protect your confidentiality, we can only respond to such requests to the email address that you have registered or otherwise provided to us.
In addition, in some circumstances based on applicable law, you may request that we cease sharing personal information about you with our business partners and service providers or that Atmosphere Hotels and Resorts cease using personal information about you by contacting us using the email or mailing address above. We will seek to honor those requests consistently with applicable law.
RETAINING PERSONAL INFORMATION
We retain personal information about you for the period necessary to fulfill the purposes outlined in this policy, unless a longer retention period is required or permitted by applicable law. We retain personal information collected in order to fulfill guest reservations for seven years after the stay is completed. We retain other personal information for shorter periods of time if possible and if permitted by law.
We will destroy your personal information as early as practicable and in a way that the information may not be restored or reconstructed.
If printed on paper, the personal information will be destroyed in a secure manner, such as by cross-shredding or incinerating the paper documents or otherwise and, if saved in electronic form, the personal information will be destroyed by technical means to ensure the information may not be restored or reconstructed at a later time.
CHOICES – MARKETING COMMUNICATIONS
If you have given us your contact information (mail address, fax number, email address or phone number), we may want to inform you in accordance with any preferences you have expressed, and with your consent where required, about our products and services or invite you to events via email, online advertising, social media, WeChat, WhatsApp, Telegram, telephone, text message (including SMS and MMS), push notifications, in-app alerts, postal mail, our customer service call center, and other means (including on-property messaging, such as your in-room television).
If you prefer not to receive email marketing materials from us, you may opt-out at any time by writing in to firstname.lastname@example.org. Opt-out requests can take up to ten business days to be effective.
We may modify this policy from time to time. When changes to this policy are made we will post a link to the revised Statement on the homepage of our site, and if you have registered for any of your products or services, will may also inform you though a communications channel that you have provided. Any changes to our policy will become effective upon posting of the revised policy on the site. Use of the site, any of our products and services, and/or providing consent to the updated Statement following such changes constitutes your acceptance of the revised policy then in effect.
If you have any questions about this policy or how Atmosphere Hotels and Resorts processes your personal information, or if you wish to either provide a compliment or a complaint, please contact us by email at email@example.com or by postal mail to Atmosphere Hotels and Resorts Data Protection Officer, 3rd Floor, Aage’, 12 Boduthakurufaanu Magu, Henveiru, Male’ 20094, Republic of Maldives. We will respond within 30 days or sooner if practicable.
ADDITIONAL INFORMATION RESIDENTS IN EUROPEAN ECONOMIC AREA (EEA)
For individuals residing in the EEA, this section outlines certain additional information that Atmosphere Hotels and Resorts are obligated to provide to you, as well as certain rights you have with respect to the processing of your personal information, pursuant to applicable laws.
Data Protection Officer: Atmosphere Hotels and Resorts’ Data Protection Officer may be contacted by email at firstname.lastname@example.org, or at the following address:
Attn: Data Protection Officer
Atmosphere Hotels and Resorts
3rd Floor, Aage’
12 Boduthakurufaanu Magu
Republic of Maldives.
The legal bases for Atmosphere Hotels and Resorts’ processing activities include processing such information as necessary or reasonably required to comply with our contractual obligations, compliance with our legal obligations, protecting the safety of our employees, guests and others, for our legitimate business interests, pursuant to your consent.
The particular legal basis for the processing of your personal information is based on the purpose for which such information was provided or collected:
Surveys: Completion of surveys is voluntary – we process the information obtained from surveys on the basis of your consent and in furtherance of our business interests, including marketing, service improvements, and analytics.
We collect certain additional personal information during registration/check-in at our properties (such as national ID or passport information), as necessary to comply with our legal obligations.
We use closed circuit television and other security measures at our properties that may capture or record images of guests and visitors in public areas, as well as information related to your location while on our properties (via keycards and other technologies) for the protection of our staff, guests and visitors to our properties.
Direct Marketing: We use your personal information to send you marketing messages on the basis of your consent. You may withdraw your consent for direct marketing communications at any time by contacting us at email@example.com
Retention: We retain personal information about you for the time necessary or reasonably required to accomplish the purpose for which such information was collected, usually for the duration of any contractual relationship and for any period thereafter as legally required or permitted by applicable law. Our retention policies reflect applicable statute of limitation periods and legal requirements.
Data Subject Rights: Residents of the EEA have the following rights:
Ask us to confirm whether we are processing your personal information.
Receive information on how your data is processed.
Obtain a copy of your personal information.
Request that we update or correct your personal information.
Request that we delete personal information in certain circumstances.
Right to Object to Processing:
You have the right to request that we cease processing of your personal information:
For marketing activities, including profiling.For statistical purposes.
Where such processing is based on our legitimate business interests, unless we are able to demonstrate a compelling legitimate basis for such processing or we need to process your personal information for the establishment, exercise or defense of a legal claim.
Right to Restrict Processing: You have the right to request that Atmosphere Hotels and Resorts limit the processing of your personal information:
While Atmosphere Hotels and Resorts’ evaluate a request by you to update or correct your personal information.
Where such processing is unlawful, and you do not want Atmosphere Hotels and Resorts to delete your data.
Where Atmosphere Hotels and Resorts no longer requires such data, but you want us to retain the data for the establishment, exercise or defense of a legal claim.
Where you have submitted an objection to processing based on our legitimate business interests, pending our response to such request.
Where we limit the processing of your personal information pursuant to your request, we will inform you prior to re-engaging in such processing.
Data Portability Requests: You have the right to request that we provide you or a third party that you designate with certain of your personal information in a commonly used, machine readable format. Please note, however, that data portability rights apply only to personal information that we have obtained directly from you and only where our processing is based on consent or the performance of a contract.
We will respond to all such requests within 30 days of our receipt of the request, unless there are extenuating circumstances, in which event we may take up to 60 days to respond. We will inform you if we expect our response to take longer than 30 days. Please note, however, that certain personal information may be exempt from such rights pursuant to applicable data protection laws. In addition, we will not respond to any request unless we are able to appropriately verify the requester’s identity. We may charge you a reasonable fee for subsequent copies of data that you request.
If you have concerns about our data practices or the exercise of your rights, you may either contact AHR at firstname.lastname@example.org , or the supervisory authority in the Member State of your residence.
Right to Withdraw Consent: You have the right to withdraw your consent to any processing that we conduct solely based on your consent (such as sending direct marketing materials to your personal email account). You may withdraw your consent to marketing activities by following the instructions on any marketing emails, or contacting email@example.com.
Segmentation (also referred to as profiling) and Automated Decision Making: We use personal information to divide large groups of consumers into sub-groups of consumers (known as segments) based on some type of shared characteristics such as geography, behavior, or demographics.
With your consent, we make automated decisions, meaning without human interference, using segmentation and/or your specific personal information to offer you certain benefits based on your characteristics (such as discounted room rates or other special offers based on your geography, behavior, or demographics).
International Data Transfers: We may transfer the personal information we collect about you pursuant to the purposes described in this Statement to countries that have not been found by the European Commission to provide adequate protection. In particular, we transfer your personal information to the Maldives.
POLICY ON COOKIES AND OTHER TECHNOLOGIES
This policy describes the different types of Cookies and Other Technologies that may be used in connection with the websites owned or controlled by Atmosphere Hotels and Resorts.
We may update this Statement at any time. Any changes in this Statement will become effective when we make the revised Statement available on or through the Site, or when the updated policy is uploaded on the Site.
If you have any questions, please contact us by email at firstname.lastname@example.org or by postal mail at Atmosphere Hotels and Resorts Data Protection Officer, 3rd Floor, Aage’, 12 Boduthakurufaanu Magu, Henveiru, Male’ 20094, Republic of Maldives.
COLLECTION AND APPLICATION OF OTHER INFORMATION
Remember your user name and password for future visits so that log-in is easier and faster;
Remember your language and other preferences;
Ensure you obtain all requested information;
Provide a safe and secure service for online transactions;
Track your response to advertisements and website or app content for analysis and the number of times we send you the same advertisement;
Measure how many people use the Site, and how they use it, so that we may keep it running quickly and efficiently; and
Help us and others deliver communications and content to you that are relevant and responsive to your interests and location.
Following are the different types of Cookies that may be used on the Site:
Essential Cookies. Essential Cookies are necessary for the Site to work and enable you to move or navigate around it and use its services and features. Disabling these Cookies may make the services and features unavailable.
Functional Cookies. We use Functional Cookies to save your settings on the Site—settings such as your language preference or booking information you have previously used when booking a hotel with us. We also use Functional Cookies to store such things as the last hotel you searched for, so that you can easily find it the next time you visit. Some Functional Cookies are essential to viewing maps or videos on our Site. We also use “Flash Cookies” for some of our animated content.
Session Cookies. These types of Cookies are stored only temporarily during a browsing session and are deleted from your device when you close the browser. We use Session Cookies to support the functionality of the Site and to understand your use of the Site—that is, which pages you visit, which links you use and how long you stay on each page.
Persistent Cookies: These types of Cookies are not deleted when you close your browser, but are saved on your device for a fixed period of time or until you delete them. Each time you visit the Site, the server that set the Cookie will recognize the persistent Cookie saved on your device. We and others use persistent Cookies to store your preferences, so that they are available for your next visit, to keep a more accurate account of how often you visit the Site, how often you return, how your use of the Site may vary over time and the effectiveness of advertising efforts.
Advertising Cookies allow us and other advertisers to show you the most relevant products, offers, and advertisements on the Site and third-party sites, or through emails or other message platforms. For example, some Advertising Cookies help our service providers and other advertisers select advertisements that are based on your interests, including those expressed or inferred by visits to our websites or apps or across other websites, online services, and apps over time. Others help prevent the same advertisement from continuously reappearing for you. These types of Cookies also help us provide you with content on the Site that is tailored to your interests and needs. As noted below, some Analytics Cookies and Other Technologies are used in part to facilitate advertising.
Advertising Cookies also include Social Plug-In Cookies. Social Plug-In Cookies are used to share content from the Site with members and non-members of social media networks such as Facebook, Twitter, YouTube and Pinterest. These Cookies are usually set by the social networking provider, enabling such sharing to be smooth and seamless.
Analytics Cookies collect information about your use of the Site, and enable us to improve the way it works. These Cookies give us aggregated information that we use to monitor site performance, count page visits, spot technical errors, see how users reach the Site, and measure the effectiveness of advertising (including emails we send to you).
Other Technologies may be used for the same purposes as our Cookies, to allow us and third parties to know when you visit the Site, and to understand how you interact with emails or advertisements. Through Other Technologies, non-personal information (e.g., your operating system, your browser version, and the URL you came from) or aggregate information may be obtained and used to enhance your experience and understand traffic patterns.
ONLINE AND MOBILE ADVERTISING
We and third parties engage in interest-based advertising provided by vendors in order to deliver advertisements and personalized content that we and other advertisers believe will be of interest to you. To the extent third-parties are using Cookies or Other Technologies to perform these services, Atmosphere Hotels and Resorts does not control the use of this technology or the resulting information for online, mobile, or email advertising, and is not responsible for any actions or policies of such third parties. Advertisements, emails, and other messages may be delivered to you by Atmosphere Hotels and Resorts or its service providers based on your online or mobile usage, your search activity, your geographic location or other information that is collected by us or obtained from third parties. For example, if you go to the Site to book a hotel room, you may later see an advertisement from us when you visit another website. These advertisements may appear on our sites, third-party websites or on mobile platforms. You may also see advertisements for third parties on the Site, other websites or properties, or on your mobile device, based on your visits to, and activities on, the Site, other sites and our apps and third-party apps. Some of our vendors and we may use our own or third-party aggregated or anonymized personal information, demographic data, and other inferred commercial interests to assist in the delivery of our advertisements to you.
We and our business partners use third parties to establish deterministic or probabilistic connections among devices (such as smartphones, tablets, and computers) to deliver more relevant advertising to you and for advertising analytics and reporting purposes. This means that information about your use of websites or applications on your current device may be combined with information from your other devices. We also may share this information and other inferences with third parties to allow them to target advertising, personalize content, or analyze behavior. This allows, for example, advertisements you see on your tablet to be based on activities you engaged in on your smartphone.
These business partners may share and combine information from cookies with identifiers (such as device IDs assigned by Google or Apple) and IP addresses to make connections among related devices. This also allows for a more personalized experience across our services and applications.
MANAGING COOKIES AND OTHER TECHNOLOGIES
If you want to remove or block Cookies from your device at any time, you can update your browser settings (consult your browser’s “help” menu to learn how to remove or block Cookies). Atmosphere Hotels and Resorts’ will not be responsible for your browser settings. You can find good and simple instructions on how to manage Cookies on the different types of web browsers at www.allaboutcookies.org