ARENA HOSPITALITY GROUP PRIVACY POLICY
Adopted on 24.05.2018., Version: 1.0
Available: at https://www.arenahospitalitygroup.com/ and at reception desks of all our facilities.
Any change of this Privacy Policy will be available and published on the website https://www.arenahospitalitygroup.com/ and at reception desks of all our facilities.
We at Arena Hospitality Group d.d. and our subsidiary companies (hereinafter: “Company”, “AHG”, “we”, “our”, “us”) are dedicated to protecting the privacy of our customers, employees, suppliers, visitors of our web sites as well as of all users of the services provided by us (hereinafter: “you”, “your”). Please read carefully the following privacy policy (hereinafter: “Privacy Policy”) we provide you with in order to explain how we, as a data processor, process your personal data.
„Personal data“ means any information relating to an identified or identifiable natural person, an identifiable natural person is one who can be identified, directly or indirectly.
We only process your Personal Data in accordance with applicable law: Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (hereinafter: “General Data Protection Regulation”, “GDPR”) and Croatian Act on implementation of General Data Protection Regulation.
1. ABOUT US
Arena Hospitality Group d.d. for tourism and hospitality is joint-stock company with headquarter in Pula, Smareglina ulica 3, Republic of Croatia and operates under the legislation of the Republic of Croatia and the EU acquis communautaire.
Company (directly or through its’ associated companies) operates and develops full-service hotels and self-catering holiday apartment resorts in the upscale, upper-upscale and lifestyle market classes. The Company’s hotels and resorts are located in exclusive destinations in Croatia and in major business and regional centres in Germany and Hungary. The Company co-owns and operates campsites on the southern coast of the Istrian peninsula in Croatia Company’s facilities operate under the Park Plaza® and art’otel® brands, Arena Hotels and Apartments® and Arena Campsites®. The Company has an ownership or operational interest in fifteen hotels and four resorts, including hotel rooms, suites and apartments, and eight campsites, including pitches, mobile homes, rentals, and apartments.
Park Plaza Hotels Europe B.V., a company registered at Viñoly Tower, 5th Floor, Claude Debussylaan 14, 1082 MD Amsterdam, The Netherlands (hereinafter referred to as: “PPHE”), a member of the PPHE Hotel Group ((hereinafter referred to as: “PPHE Group”), is the master sub-franchisee of the Park Plaza brand with Radisson Hotel Group, in among others, Croatia, and is a long-term business partner of Arena Hospitality Group. Arena Hospitality Group d.d. has entrusted certain personal data processing activities with PPHE and guarantees appropriate personal data protection measures in accordance with the GDPR.
2. PURPOSE OF THIS POLICY – PROTECTING OF YOUR RIGHTS
This Privacy Policy explains our approach to processing any personal information that we might collect from you or which we have obtained about you from a third-party and the purposes for which we process your personal information. This Privacy Policy does not relate to the processing of personal data under Park Plaza® and art’otel® brands. To see all information about processing personal data under Park Plaza® and art’otel® brands please visit https://www.pphe.com/~/media/Files/P/PPHE-Corp/documents/privacy%20policy/Privacy_Policy.pdf (“General Policy”). This Privacy Policy sets out your rights in respect of our processing of your personal information and your access to your personal information we process, as follows:
- Your right of access;
If case of your inquiry, we’ll confirm whether we’re processing your personal information and, if so, provide you with a copy of that personal information (along with certain other details). If you require additional copies, we may need to charge a reasonable fee.
- Your right to rectification;
You should update the personal data held by us by contacting us directly by mail, email or by making a change during your stay or on your registration card at check-in. We encourage you to update your details as and when there is a change to them.
If the personal information we hold about you is inaccurate or incomplete, you’re entitled to have it rectified. If we’ve shared your personal information with others, we’ll let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.
- Your right to erasure; You can ask us to delete or remove your personal information in some circumstances such as where we no longer need it or if you withdraw your consent (where applicable). If we’ve shared your personal information with others, we’ll let them know about the erasure where possible. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.
- Your right to restrict processing;
You can ask us to ‘block’ or suppress the processing of your personal information in certain circumstances such as where you contest the accuracy of that personal information or you object to us processing it. It won’t stop us from storing your personal information though. We’ll tell you before we lift any restriction. If we’ve shared your personal information with others, we’ll let them know about the restriction where it is possible for us to do so. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.
- Your right to data portability;
You have the right, in certain circumstances, to obtain personal information you’ve provided us with (in a structured, commonly used and machine readable format) and to reuse it elsewhere or to ask us to transfer this to a third party of your choice.
- Your right to object;
You can ask us to stop processing your personal information, and we will do so, if we are:
- relying on our own or someone else’s legitimate interests to process your personal information, except if we can demonstrate compelling legal grounds for the processing; or
- processing your personal information for direct marketing.
- Your rights in relation to automated decision-making and profiling.
You have the right not to be subject to a decision when it’s based on automatic processing, including profiling, if it produces a legal effect or similarly significantly affects you, unless such profiling is necessary for entering into, or the performance of, a contract between you and us, is authorised by Union or Law of Republic of Croatia or based on your explicit consent.
- Your right to withdraw consent;
If we rely on your consent (or explicit consent) as our legal basis for processing your personal information, you have the right to withdraw that consent at any time.
- Your right to lodge a complaint with the supervisory authority;
If you have a concern about any aspect of our privacy practices, including the way we’ve handled your personal information, you can report it to the Croatian Personal data Protection Agency (AZOP). You can find details about how to do this on the AZOP website http://azop.hr/data-protection-agency at or by calling their helpline on 00385 (0)1 4609-000
If you have any questions about this Privacy Policy or want to exercise your rights set out above, please contact us in written by sending:
1) an e-mail to [email protected]; or/and
2) a letter at Arena Hospitality Group d.d. (to Data Protection Officer), Smareglina 3, 52100 Pula, Croatia.
3. WHAT PERSONAL INFORMATION DO WE COLLECT AND HOW DO WE USE IT?
We process information about our past, current and prospective guests, employees, customers, suppliers, franchisees, third-party hotel owners, partners, shareholders and other individuals with whom we communicate. We use your personal data for a range of purposes set out below in more detail however our primary uses are as follows: (i) to perform the Services; (ii) to help us improve our Sites and/or Services and develop and market new Services; and (iii) to comply with any applicable law, court order, other judicial process, or the requirements of a regulator.
In particular, we use your personal information for the following purposes:
- To deliver our Services;
1) We collect and maintain personal information that you voluntarily submit to us during your use of the Sites and/or our Services:
mobile app: Hotels;
mobile app: Campsites;
(further on: “Sites”).
As our sites contain cookies and other technologies you should be aware of, please visit our Cookie Policy. (dodati link) to get an information about our use of these technologies.
We may use the contact, identification and payment details you have provided to us so that we can fulfil the supply of Services you have booked via our Sites, through third party, by phone through call centres operated for us or on our behalf or via in-person bookings, this may include use of information such as your name, title, address, previous stay information, service preferences, telephone number, gender, nationality, passport number, date and place of issue of your passport, payment information including credit card details and CVV code, flight details, names of other guests on the booking, room preferences, notes provided by you voluntarily, and preferred communications methods. We also receive information from third party entities and sites, travel agents, social media sites, PPHE, third party booking websites/agents/intermediaries, meeting and event planners, restaurant and spa booking services which we will use for those purposes. This includes verifying your identity, contacting you in respect of hotel reservations and processing your reservation and booking payment.
Who do we share your personal information with for this purpose?
We may share your personal information with third parties (including but not limited to PPHE) for the following purposes:
- To send you pre-arrival check-in/check-out communications;
- To verify your identification;
- To verify card payments (including the pre-authorisation process which may be conducted at check-in at our hotels) and process refunds;
- To make reservations, cancellations and booking changes;
- To facilitate your booking and any specific requirements or services requested; and/or
- To undertake loyalty programme membership services
- To send, where available, pre-arrival text or email with stay information, free service offerings including online check-in, text messages on the day of check-in, room preference requests.
What is our legal basis and for how long do we process your information?
It is necessary for us to use your personal information to perform our obligations in accordance with any contract that we may have with you.
we will process such information until the completion of our contractual relation.
2) Please note also that AHG will not be able to provide you a service if you don’t submit minimum information required by the law for your registration as a guest in all relevant registers:
- Name and surname;
- Address of residence;
- Date and place of birth;
- Number, type and place of issue of identification document;
- Citizenship;
- Category of sojourn tax;
- Sex.
Who do we share your personal information with for this purpose?
With authorised institutions and organizations of the Republic of Croatia, as provided by the law, through the “E-visitor” electronic system.
What is our legal basis and for how long do we process your information?
It is required by the local law and we process such information for 10 years of the date of your stay
3) Please note also that we are obliged by law to issue the invoice for the provided service in order we may process the next data:
- Name and surname;
- Address of residence.
Who do we share your personal information with for this purpose?
With authorised institutions and organisations of the Republic of Croatia, as provided by the law.
What is our legal basis and for how long do we process your information?
It is required by the local law and we process such information for 11 years of the date of the invoice issue.
- To communicate with you by way of our newsletter and to provide you with selected business information
We collect and maintain personal information including your name and contact details such as e-mail address so that we can communicate with you via our newsletters and to provide you with information and benefits relating to the operation of our Services and related promotions and offers.
Who do we share your personal information with for this purpose?
We may share that information with other members of PPHE Group.
What is our legal basis and for how long do we process your information?
It is in our legitimate interest to use your personal information to communicate with you in this way. We process such information no more than seven (7) years from the date of our last interaction with you or by the moment of opt-out.
- To address your enquiries and provide customer service support
Where you enquire about our Services, or require customer support in respect of our Services we may collect personal information about you. We use various user interfaces to allow you to request information about our Services or to make enquiries. Contact information may be requested in each case, together with details of other personal information that is relevant to your customer service enquiry. This information is used in order to enable us to respond to your requests.
Who do we share your personal information with for this purpose?
We may use a third party service provider to assist us with customer feedback requests.
What is our legal basis and for how long do we process your information?
Depending on the nature of your enquiry or request the legal basis for us to process such personal information will either be because:
(a) processing is necessary to perform our obligations in accordance with any contract that we may have with you;
(b) because it is in our legitimate interest to use your personal information in such a way to ensure that we provide the very best customer service we can to you; and/or
(c) where you have consented to such processing until the consent withdrawal.
- Security and surveillance
We may use video surveillance to view and record individuals on or around (internally and externally) our accommodation facilities. The images of individuals recorded by video surveillance will constitute personal data.
Video surveillance maybe used to record sound in certain places. Video surveillance images may be monitored by authorised personnel. We will display signs within our facilitieswhich, among other, contain contact information of our data protection officer and alert individuals that they may be recorded where video surveillance is in use.
Who do we share your personal information with for this purpose?
We may share your personal information, recorded via our video surveillance with the third parties as required by law or as necessary for the functioning of the video surveillance security system, including law enforcement, the police, strictly necessary technical service providers and AHG affiliates only as strictly required.
What is our legal basis and for how long do we process your information?
It is in our legitimate business interests to use the information recorded via our video surveillance for the following purposes:
- for the personal safety of our staff and guests;
- to act as a deterrent to prevent crime and protect our facilities and assets from damage;
- to protect guests’ belongings against damage and crime; and
- to support law enforcement bodies in the prevention, detection and prosecution of crime.
We process such information for a period of six (6) months, unless they are to be used as a proof in process before court, administrative body, arbitration or similar process.
- Careers
We may collect personal information in order to consider and process any enquiries or applications regarding our employment opportunities.
We collect and maintain personal information that you voluntarily submit to us or which we collect from third party recruitment agencies for this purpose. The information that we collect may include your name/surname, contact details, education details, and any other information that you include on your CV, application documents and cover letter.
You can apply for vacancies here: https://jobs.pphe.com/arenaturist. Where you apply for a vacancy using social networks including but not limited to Facebook, we may collect any information you make publicly available through the concerned social network. We may use this information in order to communicate with you about your application.
Who do we share your personal information with for this purpose?
We do not share your personal information for this purpose.
What is our legal basis and for how long do we process your information?
It is in our legitimate business interests to use the information you provide to us when you apply for a job vacancy for the purposes described above. We process such information for five (5) years.
- Business, administration and legal compliance
We use your personal information for the following business administration and legal compliance purposes:
- for record keeping purposes;
- to comply with our legal obligations;
- to enforce our legal rights;
- protect the rights of third parties; and
- in connection with a business transition such as a merger, acquisition by another company, or sale of all or a portion of our assets.
Who do we share your personal information with for these purposes?
We will share your personal information with professional advisers such as lawyers and accountants and/or governmental or regulatory authorities.
What is our legal basis?
Where we use your personal information in connection with a business transition, enforce our legal rights, or to protect the rights of third parties it is in our legitimate interest to do so. For all other purposes described in this section, it is our legal obligation to use your personal information to comply with any legal obligations imposed upon us such as a court order.
Where we share your sensitive personal information, we shall obtain your consent to do so.
- Marketing communications
We carry out the following marketing activities using your personal information:
- Email marketing
We use information that we observe about you from your interactions with our Sites, our email communications to you and/or with our Services and/or your email address, to send you marketing communications by email, where you have consented to receive such marketing communications, or where we have another lawful basis to do so.
We will abide by any request from you not to send you direct marketing materials.
Who do we share your personal information with for these purposes?
We share your personal information with several third party email marketing providers who assist us in delivering our email marketing campaigns.
What is our legal basis?
It is in our legitimate interest to use your personal information for marketing purposes.
We will only send you marketing communications via email where you have consented to receive such marketing communications, or where we have a lawful right to do so.
- Social media marketing
We may use the following social media sites to market our Services to you: Facebook, Twitter, Instagram, YouTube and LinkedIn where you are a registered user of such services. Where you participate in our sponsored social media activities or offerings we may collect certain information from your social media account with your permission such as location information, check-in notifications, social media activities, photos, status updates and publicly available comments and friends lists.
We may use information that we observe about you from your interactions with our Sites, our email communications to you and/or with our Services to provide you with personalised advertising on social media channels operated by Facebook or others.
Who do we share your personal information with for these purposes?
We share your email address with third-party service providers who assist us with social media remarketing campaigns.
Your encrypted email address is also shared by us or our third-party service providers with Facebook under the terms of their Facebook Customer Audiences services.
What is our legal basis?
Where your personal information is completely anonymised, we do not require a legal basis to use it as the personal information will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of such anonymised personal information may be subject to other laws where your consent is required. Please see our Cookie Policy for further details.
Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information for marketing purposes.
4. GENERAL
Child or Children in the meaning of this Privacy Policy is an individual under 16 years. AHG may collect personal information such name and surname, years, address from children only:
1) where required by applicable law, for the period required by the law
2) within the activity of Artur Club and Artur Kids Club on the base of written consent of their adult parents or guardians where such information will be deleted upon children’s departure from the facility.
This Policy is written in the Croatian language and may be translated into other languages. In the event of any inconsistency between the English version and the translated version of this Policy, the Croatian version shall prevail.