Q.8 What can you do if you have any questions or concerns or want to access your personal information?
1. WHAT INFORMATION ABOUT YOU DO WE COLLECT?
Mandarin Oriental collects your information to operate effectively and provide you with the best experiences with our services. The specific kind of information collected will depend on the context of your interactions with Mandarin Oriental, and the services you use. The following are examples of the information that may be collected:
- Contact information (such as name, email address, mailing address, and phone number);
- Payment information (including payment card numbers, billing address, and bank account information);
- Demographic data (such as age, gender, country, and preferred language);
- Information related to your reservation, stay, or visit to a property (including the Mandarin Oriental hotels where you have stayed, date of arrival and departure, and goods and services purchased);
- Information necessary to fulfill your special requests and/or specific accommodations;
- Loyalty program member information, online account details, profile or password details and any frequent flyer or travel partner program affiliation;
- Copies of your correspondence if you contact us;
- Your interests and preferences;
- Information collected through the use of closed circuit television systems, card key and other security systems; and
- Information related to your use and interaction with our website.
We collect this information in a variety of ways, including:
- Automatic Information: When you use or interact with our website and/or use any apps that we may make available on our website, we receive and store information generated by your activity and information automatically collected from your browser or mobile device. For example, like many websites, we obtain certain information when your web browser accesses our website including your IP address, browser type, operating system, mobile network data, pages viewed and access times. This information helps us to communicate with our customers and better understand them.
- Security Systems: When you visit our managed properties, information may be collected about you through such properties’ closed circuit television systems, electronic key cards and other security systems.
- Information from Other Sources: We may receive information about you from other sources, such as public databases, joint marketing partners, and other third parties. This may include information from your travel agent, airline, credit card, and other partners.
- Age Limitations: Mandarin Oriental does not knowingly collect personally identifiable information from our websites from any person under the age of 18. Mandarin Oriental may collect personally identifiable information from people under the age of 18 as part of the guest registration process, but always with the consent of such person’s parent or guardian.
2. HOW DO WE USE YOUR INFORMATION?
Mandarin Oriental collects your information to operate effectively and provide you with the best experiences with our services. Mandarin Oriental may collect, use, and disclose the information it collects for a variety of reasons, including for the following purposes:
- Fulfillment of Reservation and Other Purchases: We may process information relating to transactions that you enter into with us and/or through our website ("transaction data"). The transaction data may be processed for the purpose of completing your room reservation, supplying the purchased goods and services, customizing our services to your preferences, seeking your feedback on your stay at our properties, and keeping proper records of those transactions.
- Membership Programs: To administer and operate voluntary membership programs, including the Fans of M.O. program, loyalty programs and frequent flyer programs. The data may be processed for the purposes of recording stay and transactional data, earning and redeeming rewards, points, or credits in connection with the programs.
- Response to Inquiries: We may process information contained in or relating to any communication that you send to us ("correspondence data"). The correspondence data may include the communication content and metadata associated with the communication. The correspondence data may be processed for the purposes of communicating with you and record-keeping.
- Internal Business Purposes: For our internal business purposes, such as data analysis, audits, developing new products, enhancing the website, improving our services, identifying usage trends and visiting patterns, determining the effectiveness of our promotions, and meeting contractual obligations.
- Administrative and Other Communications: To send you important information regarding our website, changes to our terms, conditions, and policies, or other administrative information (e.g., information about your travel reservations, such as reservation confirmations).
- Marketing and Promotions: To communicate news and promotions to you relating to Mandarin Oriental Hotel Group-related products and services and other products and services we think may be of interest to you, and to operate sweepstakes, contests, or other marketing or promotional activities.
- Safety and Security: To maintain your safety and security as well as that of other guests and personnel, while you visit our managed hotels and residences.
- Our Legal Duties: To comply with legal and regulatory requirements or demands in accordance with applicable law, a court order, subpoena, or other legal process.
- Additional Uses: We may also use your data other ways as described to you when you provide such information to us.
The legal basis for processing your personal information is made up of one or more of the following reasons: (i) your consent, and/or (ii) providing the services you have requested, and/or (iii) compliance with applicable laws, regulations, court orders or other legal process.
3. WHAT ABOUT COOKIES?
We use tracking tools like browser cookies and web beacons to collect information from you. We collect information about users over time when you use this website or any apps that we may make available on our website. We may have third parties collect personal information this way. Learn more about these tools and how you can control them here.
4. DOES MANDARIN ORIENTAL SHARE THE INFORMATION IT RECEIVES?
As an international hotel and residences management company and with the global geographical diversity of our business, it is essential that we share information across multiple jurisdictions in order to provide you with and to maintain the best possible service. The specific kind of information we share will depend on the context of your interactions with Mandarin Oriental, and the services you use. Accordingly, your personal information may be shared with the following parties insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy:
- to any Mandarin Oriental entity and hotels and residences managed by us;
- to the representative or travel advisor that has supplied us with your personal information (for example, your travel agent, personal assistant, employer or spouse who has provided us with your details);
- to third parties not affiliated with Mandarin Oriental when we have your consent to do so;
- to our marketing and advertisement partners to provide you with more-relevant ads on our site and to encourage you to return to our site;
- to third parties not affiliated with Mandarin Oriental if we have a good-faith belief that it is reasonably necessary to: (1) meet any applicable law, regulation, legal process or enforceable governmental request; (2) enforce applicable terms of service, including investigation of potential violations; (3) detect, prevent, or otherwise address fraud, security or technical issues; and (4) protect against harm to the rights, property or safety of Mandarin Oriental, our users or the public as required or permitted by law; and
- to any third parties to the extent necessary with respect to a sale of all or part of our business operations or assets.
5. DOES MANDARIN ORIENTAL TRANSFER INFORMATION OVERSEAS?
As an international hotel and residences management company and with the global geographical diversity of our business, it is essential that we share information across multiple jurisdictions in order to provide you with and to maintain the best possible services. By using and/or purchasing our goods and services, we may transfer your personal information across multiple jurisdictions. Accordingly, insofar as reasonably necessary for the purposes, and on the legal basis, set out in this policy, we may transfer and store your personal information:
- in or to Hong Kong, the United Kingdom and the United States of America, where our corporate offices are located;
- in those countries in which we manage and operate hotels and residences and/or operate sales offices, including Chile, China, Czech Republic, France, Germany, Hong Kong S.A.R., Indonesia, Italy, Japan, Macau S.A.R., Malaysia, Morocco, Qatar, Singapore, Spain, St Vincent & The Grenadines, Switzerland, Thailand, Turkey, United Kingdom and United States; and
- in such other countries where our third party service providers, advisors and consultants are located, which changes from time to time.
Such transfers may be to a country which may not provide the same level of privacy protection as that provided by the country in which the information was collected but we will take reasonable steps (including entering into data transfer agreements based on the European Commission model clauses, or requiring compliance with the EU-US Privacy Shield) to ensure that while your personal information is within our control, we will handle your personal information using reasonable security and confidentiality procedures to keep your personal information secure and confidential.
6. HOW SECURE IS YOUR INFORMATION?
We implement reasonable administrative, organisational and technical safeguards and security measures to protect personal information within our control from unauthorized access, acquisition, disclosure, destruction or alteration, accidental loss, misuse or damage. We regularly review and monitor such safeguards and security measures.
7. HOW LONG WILL MANDARIN ORIENTAL KEEP YOUR INFORMATION?
To the extent permissible by applicable law, we will retain your personal information for such period as necessary to satisfy or to fulfill the following:
- the purposes for which that personal information was provided,
- an identifiable and ongoing business need, including record keeping,
- a specific legal or regulatory requirement, and/or
- a requirement to retain records that may be relevant to any notified regulatory investigations or active legal proceedings.
Where there is no sufficient justification to retain such personal information, such personal information will be safely and securely deleted, disposed of, anonymised and/or blocked.
8. WHAT CAN YOU DO IF YOU HAVE ANY QUESTIONS OR CONCERNS OR WANT TO ACCESS YOUR PERSONAL DATA?
Our Data Protection Officer will be happy to answer any concerns or queries you may have relating to the use or storage of your personal data. Your principal rights under the European Union General Data Protection Regulation are: (a) the right to access; (b) the right to rectification; (c) the right to erasure; (d) the right to restrict processing; (e) the right to object to processing; (f) the right to data portability; (g) the right to complain to a supervisory authority; and (h) the right to withdraw consent. You may exercise any of these rights in relation to your personal data by contacting our Data Protection Officer. Our Data Protection Officer can be contacted by email at email@example.com or by post at 8th Floor, One Island East, Taikoo Place, 18 Westlands Road, Quarry Bay, Hong Kong.
9. WHAT ABOUT LINKED WEBSITES?
The linking of third party websites to this website does not indicate any association with or endorsement by Mandarin Oriental. Mandarin Oriental does not assume responsibility or liability of any nature whatsoever for the activities conducted or information contained in the third party websites.
* "Mandarin Oriental", "Mandarin Oriental Hotel Group", "we", "us" and "ourselves" refers to Mandarin Oriental Hotel Group Limited and its affiliates directly involved in the group’s management and operation of properties around the world, including the local management entities in the following jurisdictions: in the Czech Republic this is Mandarin Oriental Prague S.R.O.; in France this is MOHG Hotel (Paris) SARL; in Germany this is Mandarin Oriental Munich GmbH; in Italy this is Mandarin Oriental Hotel Management (BVI) Limited, Mandarin Oriental (UK) Limited and Mandarin Oriental Residences Management (UK) Limited; in Spain this is Mandarin Oriental Spain SL and Mandarin Oriental Spain Residences SL; in Morocco this is MO Management SARL; in Switzerland this is Mandarin Oriental (Switzerland) SA and Société pour l’Exploitation de Mandarin Oriental (Genève) SA; and in the United Kingdom this is Mandarin Oriental Hyde Park Limited, Mandarin Oriental (UK) Limited and Mandarin Oriental Residences Management (UK) Limited. Mandarin Oriental Hotel Group Limited and the applicable local management entities as set forth above are “data controllers”. The contact details for the data controller(s) are: by e-mail at: firstname.lastname@example.org, and by post at: c/o Mandarin Oriental Hotel Group Limited, 8th Floor, One Island East, Taikoo Place, 18 Westlands Road, Quarry Bay, Hong Kong.
Effective Date:1 February 2019