1. How is your Personal Data Collected?

We use different methods to collect data from and about you including through:
Direct interactions – You may give us your Identity, Contact and Financial Data by filling in forms (e.g. “Contact Us” or “Newsletter Subscription”, etc.) or by corresponding with us by phone, email or otherwise.
Automated technologies or interactions – As you interact with our website or any other system operated by us, we may automatically collect Personal Data (please refer to the description below, under “Cookies Usage”).
Third parties or publicly available sources – We may receive personal data about you from various third parties and public sources, e.g.: advertising and social networks, analytics providers, search information providers.

2. Usage of your Personal Data

We will only use your personal data when the law allows us to, i.e. when we have a Lawful Basis for such usage. Such lawful and legal basis can be any of the following:
Carry out our obligations arising from any contracts entered between you and us. For example, making and managing your booking and operating and providing services in connection with any of our loyalty programs in accordance with the terms of our agreement with you;
Your consent for the process of your personal data;
our use of your information is necessary to meet responsibilities we have to our regulators, tax officials, law enforcement, or otherwise meet our legal responsibilities;
Our use of your information is in our legitimate interest as a commercial organisation. For example, to operate and improve our services and to keep people informed about our products and services (including for profiling and targeted advertising). In these cases, we will look after your information at all times in a way that is proportionate and respects your privacy rights.
In general, we do not rely on consent as a legal basis for processing your personal data, other than in relation to sending third party direct marketing communications to you via email or text message. Yet, in any case in which you have provided your consent to our processing of your information, you can withdraw this consent at any time by contacting us through the contact details provided above.

3. Transfer and disclosure of Personal Data

We may disclose your personal data to third party service providers for the purpose of providing services to you, for example the processing and fulfillment of your booking or reservation. We may also disclose your personal data in other occasions in accordance with applicable law, e.g. when we have a legal obligation to do so, or when we are allowed to do so under our legitimate interests. In any such transfer we will take steps to make sure such transfer is carefully managed to protect your privacy rights:
transfers within our group and affiliates will be subject to an agreement / policies and procedures made to ensure that your data receives an adequate and consistent level of protection;
transfers to any subcontractor or processor will be subject to contractual terms ensuring the security and protection of any personal data, in accordance with applicable law provisions;
any transfer of data which originates in the European Union (“EU”) to a country outside of the European Economic Area (EEA), shall be made in compliance with the provisions of chapter 5 of the GDPR. Such transfer can be made to countries which are recognized as providing an adequate level of legal protection or where we can be satisfied that alternative arrangements are in place to protect your privacy rights, e.g. the EU-US Privacy Shield;
any requests for information we receive from law enforcement or regulators will be carefully validated before the disclosure of any Personal Data.

4. Links to other sites

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

5. How we secure your information

We are committed to protecting the security of your personal data. We use a variety of security technologies and procedures to help protect your personal data from unauthorised access and use. However, the collection, transmission and storage of information can never be guaranteed to be completely secure. Yet, we take steps to ensure that appropriate security safeguards are in place to protect your information, and we will continue to revise policies and implement additional security features as new technologies become available.

6. Retaining your information in our systems

We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. We maintain a data retention policy which we apply to all the records we hold, ensuring minimization of retention periods
In some circumstances we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

7. Data Subjects’ rights under EU data protection laws – GDPR

Under EU law, EU residents and individuals, have certain rights to apply to us to provide information or make amendments to how we process data relating them:
right to access your personal data – you can ask us to confirm whether or not we have and use your personal data, and if so, you can ask for a copy of your data;
right to correct your personal data – you can ask us to correct any of your personal data which is incorrect, after verifying the accuracy of the data first;
right to erase your personal data – you can ask us to erase your personal data if you think we no longer need to use it for the purpose we collected it from you. You can also ask for such erasure in any case in which the process of your data was based on your consent, or where we have used it unlawfully or where we are subject to a legal obligation to erase your personal data. any request for such erasure will be subject to our obligations under the law (e.g. our obligation to keep some records for tax or customs purposes);
right to restrict our use in your personal data – you can ask us to restrict our use of your personal data in certain circumstances;
right to object to how we use your personal data – you can object to any use of your personal data which we have justified by our legitimate interest if you believe your fundamental rights and freedoms to data protection outweigh our legitimate interest in using the information;
you can always require us to refrain from using your data for direct marketing purposes;
you can ask us to transfer your information to another organisation and/or provide you with a copy of your personal data.
These rights apply in certain circumstances in accordance with the provision of the GDPR. In addition, we may not always be able to do what you have asked, for example, if it would impact the duty of confidentiality we owe to others, or if we are otherwise legally entitled to deal with the request in a different way. However, we encourage you to contact us with any such request, and we will be happy to assist you.

8. Special Notification for California Residents

Individual customers who reside in California and have provided their personal information to the Hilton Portfolio of Brands may request information about our disclosures of certain categories of personal information to third parties for their direct marketing purposes. Such requests must be submitted to us through the contact information Specified above.

9. Changes to this Privacy Statement

We reserve the right to change this statement from time to time at our sole discretion. If we make any changes, we will post those changes here so that you can see what information we gather, how we might use that information and in what circumstances we may disclose it. By continuing to use our site or our services or otherwise provide data after we post any such changes, you accept and agree to this statement as modified.