1 October, 2013

Xotels Ltd. Online Privacy Statement

Our Mission
At Xotels, we are dedicated to protecting your privacy and safeguarding your PII. We are using the information you entrust us responsibly. Xotels is committed to respecting your privacy and adhering to the principles of applicable data protection and privacy laws throughout the world. In case of conflicting laws, the laws of the land of as applicable in the conditions of sale or service of Xotels shall prevail. However, your privacy is our main concern.

We have provided this Privacy Statement as an explanation of the information we collect, how we use it, and how the use of this information can benefit your experience on our web sites and during your relationship with us. We wish to help you make informed decisions, so please take a moment to read the sections below.

Xotels and affiliates and providers
In order to provide multiple access points to the services and products we offer, Xotels operates directly, or through its affiliates or service providers, many web sites, including without limitation www.xotels.com. Any third party, which is an affiliate or provider of Xotels, will only be allowed to collect personally identifiable information (hereinafter: “PII”) on behalf of Xotels when such is explicitly mentioned on their website. Any one of these web sites may ask for and collect in order to enhance your experience and provide you with relevant information.

TYPES OF INFORMATION WE COLLECT
Information may be collected as part of: (i) fulfilling registration or information requests, (ii) purchasing products, (iii) registering for program membership, (iv) submitting a job application, or (v) responding to communications from us (e.g., surveys, promotional offers, or registration confirmations). We endeavor to collect information only with your knowledge and with your permission if necessary. The types of PII that we collect may include your name, home, work and e-mail addresses, telephone and fax numbers, credit card information, date of birth, gender, and professional behavior information such as event or trade show attendance, professional media preference, and other information necessary to fulfill special requests.

Xotels may also collect non-PII about you, such as your use of our web sites, communication preferences, professional habits, aggregated data relative to your purchases, and responses to promotional offers and surveys.

PURPOSE FOR COLLECTION, PROCESSING, AND DISCLOSURE

Collection & Use
Xotels is fully committed to providing you with information about the collection and use of PII (PII) furnished by, or collected from, visitors while using our web sites, products and services. It is our practice not to ask you for information unless we need it or intend to use it. Some of the primary purposes for collecting your PII are as follows:

  • providing services such as processing a transaction (e.g., making a seminar registration, fulfilling a request for information, or completing a product order)
  • marketing and communications with you in relation to the products and services offered by Xotels , our strategic marketing partners, and other trusted third parties
  • performing market research via surveys to better serve your needs, improve the effectiveness of our web sites, your customer experience, our various types of communications, advertising campaigns, and/or promotional activities

You will always be offered the choice not to submit your PII or to decide what communications you want to receive from us. However, doing so may cause certain transactions to become affected. For example, not providing a name will prevent the processing of registrations.

Processing and Disclosure
In most cases, the information you provide is added to a local or global database. In the course of processing your information, it may be necessary to transfer your PII to Xotels’ affiliates, properties within the Xotels system and/or third party service providers located in the country where the system is located and throughout the world for the purposes outlined within this Privacy Statement. As a general practice, Xotels does not sell, rent, or give physical possession of your PII to unaffiliated third parties outside the Xotels system. Situations in which Xotels may disclose your information to others include:

  • when we have received your consent to do so
  • in situations where sharing or disclosing your information is required in order to offer you products or services you desire (e.g., seminar sponsor offers)
  • when companies or services providers that perform business activities on behalf of Xotels require such information (e.g., credit card processing, customer support services, market research administration or database management services)
  • when a company leaves the Xotels system and access to your PII is necessary to facilitate business operations or meet contractual obligations
  • in the event Xotels is merged or acquired by another company
  • to comply with legal or regulatory requirements or obligations in accordance with applicable law or court order
  • in case of emergency such as to safeguard the life, health, or property of an individual

If information is shared as mentioned above, we seek to limit the scope of information that is furnished to the amount necessary for the performance of the specific function. Unless otherwise precluded by legal process, we require third parties to protect your PII and abide by applicable privacy laws and regulations.

CONSENT
As part of our commitment to keep you informed, we may mail, e-mail, telephone, sms, or contact you by other means to notify you of new Xotels products and services, or upcoming Xotels special offers, events, enhancements, or other relevant information that may be of interest to you. You may also receive mailings or other communications from carefully selected third parties. We always offer you the option to decline any or all of these communications by following the directions included in our e-mails or other communications, or by contacting Xotels directly.

If you are member of a Xotels loyalty program or community, you may also change your communication choices by updating your e-mail preferences in your individual membership profile. We would like to keep all of our clients and visitors informed and equally able to take advantage of the benefits offered by Xotels and its strategic marketing partners. However, depending on the country where you live, certain data privacy regulations may require us to obtain your permission before we send you information that you have not requested from us.

DATA TRANSFERS ACROSS INTERNATIONAL BORDERS
We endeavor to provide you with the same outstanding service in all locations. To achieve this goal, we have established or endeavoring to establish a global network comprised of properties, offices, data centers, trusted marketing partners, service providers, customer contact centers, and trained associates around the globe. The nature of our business and our operations require us to transfer your information, including PII, to other group companies, properties, centers of operations, data centers, or service providers that may be located in countries outside of your own. Although the data protection and other laws of these various countries may not be as comprehensive as those in your own country, Xotels will take appropriate steps to ensure that your PII is protected and handled as described in this Privacy Statement.

ACCESS TO PERSONALLY IDENTIFIABLE INFORMATION
To ensure that your PII is accurate and up to date, we encourage you to regularly review and update your information as appropriate (e.g., in the event your home or e-mail address changes, or you wish to add an additional method for us to communicate with you). If you are member of a Xotels loyalty program or community, you can review and update your individual membership profile on-line or with the assistance of a Xotels customer service representative. Please note that in an effort to prevent the unauthorized disclosure of your PII, you may be asked to provide proof of identity (or other authentication materials) together with the completed access request form.
If, upon review, you wish to deactivate your Xotels loyalty program or community member profile, or update your PII, we will endeavor to do so in a timely manner. Occasionally, information that you request to be removed will be retained in certain files for a period of time in order to properly resolve disputes or to troubleshoot problems. In addition, some types of information may be stored indefinitely on “back up” systems or within log files due to technical constraints, or financial or legal requirements. Therefore, you should not always expect that all of your PII will be completely removed from our databases in response to your request.

SECURITY SAFEGUARDS
Xotels recognizes the importance of information security, and is constantly reviewing and enhancing our technical, physical, and logical security rules and procedures. All Xotels owned web sites and servers have security measures in place to help protect your PII against loss, misuse, and alteration while under our control. Although “guaranteed security” does not exist either on or off the Internet, we safeguard your information using both procedural and technical safeguards, including password controls, “firewalls” and the use of up to 128-bit encryption based on a Class 3 Digital Certificate issued by VeriSign, Inc. This allows for the use of Secure Sockets Layer (SSL), an encryption method used to help protect your data from interception and hacking while in transit.

In some cases your permission will be implied from the nature of the service requested or transaction undertaken. For example, Xotels may collect and use PII that you volunteer, or behavioral data or information collected in the aggregate. In addition, your permission will be deemed given for communications from us that are necessary to fulfill transactions and services that you request.

In certain circumstances, we will seek your express permission when we collect information that is regarded under certain data privacy regulations to be sensitive in nature (e.g., information revealing racial or ethnic origin, political opinions, or health conditions).

ON-LINE TECHNOLOGIES
Xotels may use cookies, invisible pixels, and web beacons to obtain information about you while visiting our web sites. A cookie is a very small text file that is sent to your browser from a web server and stored on your computer’s hard drive. It assigns the computer with a unique identifier, which in turn, becomes your identification card whenever you return to a Xotels web site.

Cookies are designed to save you time because they help us to provide you with a customized experience without you having to remind us of your preferences each time you return to our web pages. Xotels cookies are not designed to damage your files, nor can they read information from other files on your computer hard drive.

Cookies can also help us provide you with a personalized on-line experience in the following ways:

  • they remember your user name and password for future visits so log-in is easier and faster
  • they ensure you are provided with the appropriate frames and content
  • they ensure you obtain all requested information
  • they help us deliver communications that are relevant and responsive to your interests and location

Xotels cookies are limited to our web sites only, and are not designed to follow you when traveling on the Internet after leaving Xotels owned web sites. We track the usage of our web sites in order to better meet your needs and to help make it easier for you to find information in the future. Please note that in addition to Xotels cookies, various third parties may also place cookies on your computer’s hard drive. Xotels is not responsible for the presence or absence of third party cookies, or for the technological capabilities or practices employed by third parties in connection with third party cookies.

If you would prefer not to have the benefits of cookies, your Internet browser can be adjusted to treat cookies in different ways. Depending upon the type of browser you are using, you may be able to configure your browser so that: (i) you are prompted to accept or reject cookies on an individual basis or (ii) you may be able to prevent your browser from accepting any cookies at all. You should refer to the supplier or manufacturer of your web browser for specific details about cookie security. However, you should also understand that rejecting cookies might affect your ability to perform certain transactions on our web sites and our ability to recognize your browser from one visit to the next.

Xotels also uses invisible pixels, sometimes called web beacons, to count how many people visit certain web pages. Information collected from invisible pixels is used and reported in the aggregate and does not contain PII. Xotels may use this information to improve marketing programs and content.

LINKS TO OTHER WEB SITES
In order to anticipate your needs, Xotels provides links to other web sites for your convenience and information. Xotels is not responsible or liable for any content presented by or contained on any independent web site, including, but not limited to, any advertising claims or marketing practices. Please note that while Xotels will protect your information on Xotels owned and operated web sites, we cannot control and will not be responsible for the privacy policies of third party web sites, including web sites owned or controlled by independent franchisees, third party owners of consultancy companies, service providers or technology companies that may use the name of a Xotels brand, or web sites not controlled or authorized by Xotels.

Third party web sites that are accessed through links on our web sites have separate privacy and data collection practices, and security measures. We have no responsibility or liability for the practices, policies and security measures implemented by third parties on their web sites. We encourage you to contact them to ask questions about their privacy practices, policies and security measures before disclosing any PII. We recommend that you review the privacy statements and policies of linked web sites to understand how those web sites collect, use and store information.

MINORS
Xotels does not seek to obtain nor does it wish to receive PII directly from minors; however, we cannot always determine the age of persons who access and use our web sites. If a minor (as defined by applicable law) provides us with his/her data without parental or guardian consent, we encourage the parent or guardian to contact us to have this information removed and to unsubscribe the minor from future Xotels marketing communications.

CONTACT US
If you would like to update your information, modify your communication preferences, or if you do not want to receive marketing communications from Xotels in the future, you can contact us:

  • by e-mail: office@xotels.com
  • by fax: +31 205 248 703
  • by writing to us at:

Xotels Ltd.
Keizersgracht 241
1016 EA Amsterdam
The Netherlands

VAT-number: NL 81 53 48 617 B01
Chambers of Commerce, Haarlem – the Netherlands, Nr: 34 24 13 54
IBAN Number: NL73 RABO 0117 8390 94
BIC Number: RABONL2U

If you would like to contact Xotels Customer Service Department, please choose the most convenient method from the following:

  • by e-mail: office@xotels.com
  • by telephone: 000000000
  • by fax: +31 205 248 703
  • by writing to us at:

attn. Customer Service
Xotels Ltd.
Keizersgracht 241
1016 EA Amsterdam
The Netherlands

If you have comments or questions regarding Xotels’ data privacy practices or this Privacy Statement, you may contact us by choosing the most convenient method from the following:

  • by e-mail: office@xotels.com
  • by fax: +31 205 248 703
  • by writing to us at:

attn. Consumer Affairs – Privacy
Xotels Ltd.
Keizersgracht 241
1016 EA Amsterdam
The Netherlands

UPDATES TO THE PRIVACY STATEMENT
Xotels may amend this Privacy Statement from time to time in order to meet changes in the regulatory environment, business needs, or to satisfy the needs of our clients, franchisees, strategic marketing partners, and service providers. Updated versions will be posted to our web site and date stamped so that you are always aware of when the Privacy Statement was last updated.