Because we consider you an important customer, our first priority is to offer you exceptional times and stays throughout our properties.
Your complete satisfaction and confidence in Marlin are absolutely essential to us.
As part of our commitment to meeting your expectations, we have set up a customer privacy protection policy. This Policy formalizes our commitments to you and describes how Marlin uses your personal data.
The main rules applicable within the Marlin are founded on six principles.
"Personal data" means any information collected and logged in a format that allows you to be identified personally, either directly (e.g. name) or indirectly (e.g. telephone number) as a natural person.
Before providing us with this information, we recommend that you read this document describing our customer privacy protection policy.
This Personal Data Protection Policy forms part of the terms and conditions that govern our accommodation services. By accepting these terms and conditions, you expressly accept the provisions of this Policy.
The six principles below are applicable within Marlin
- Legitimacy: We will collect and process your personal data only for the purposes described in this Policy.
- Relevance and accuracy: We will only collect personal data that is necessary for data processing. We will take all reasonable steps to ensure that the personal data we hold is accurate and up to date.
- Storage: We will hold your personal data for the period necessary for processing the same in compliance with the provisions of the law.
- Access, rectification, opposition: You may access, modify, correct or delete your personal data. You may also oppose the use of your personal data, particularly to avoid receiving sales and marketing information.
- Confidentiality and security: We will ensure reasonable technical and organizational measures are in place to protect your personal data against alteration or accidental or unlawful loss, or unauthorized use, disclosure or access.
- Sharing and international transfer: We may share your personal data within the Marlin Ltd or with third parties (such as commercial partners and/or service providers) for the purposes set out in this Policy. We will take appropriate measures to guarantee security when sharing or transferring such data.
3. SCOPE OF APPLICATION
This Policy applies:
- To all data processing implemented in our managed properties, i.e. those operating under an Marlin Ltd brand name
- To all Marlin Ltd reservation websites www.marlin.com
At various times, we will be obliged to ask you, as a Marlin Ltd customer, for information about you and/or members of your family, such as:
- Contact details (for example, last name, first name, telephone number, email)
- Personal information (for example, date of birth, nationality)
- Information relating to your children (for example, first name, date of birth, age)
- Your credit card number (for transaction and reservation purposes)
- Your arrival and departure dates
- Your preferences and interests (for example, smoking or non-smoking room, preferred floor, type of bedding, type of newspapers/magazines, sports, cultural interests)
- Your questions/comments, during or following a stay in one of our properties.
The information collected in relation to persons under 18 years of age is limited to their name, nationality and date of birth, which can only be supplied to us by an adult. We would be grateful if you could ensure that your children do not send us any personal data without your consent (particularly via the Internet). If such data is sent, you can contact the Data Privacy department to arrange for this information to be deleted.
We do not deliberately collect sensitive information, such as information concerning race, ethnicity, political opinions, religious and philosophical beliefs, union membership, or details of health or sexual orientation.
Moreover, depending on applicable local laws, other information could be considered sensitive, such as your credit card number, your leisure activities, personal activities and hobbies, and whether or not you are a smoker. We may be obliged to collect such information in order to meet your requirements or provide you with an appropriate service, such as a specific diet.
In this case, depending on the laws in force in certain countries, your prior consent may be required with regard to the collection of sensitive information.
Personal data may be collected on a variety of occasions, including:
- Accommodation activities:
- Booking a room
- Checking-in and paying
- Eating/drinking at the hotel bar or restaurant during a stay
- Requests, complaints and/or disputes.
- Participation in marketing programs or events:
- Participation in customer surveys (for example, the Guest Satisfaction Survey)
- Online games or competitions
- Subscription to newsletters, in order to receive offers and promotions via email.
- Transmission of information from third parties:
- Tour operators, travel agencies, GDS reservation systems, and others
- Internet activities:
- Connection to Marlin websites (IP address, cookies)
- Online forms (online reservation, questionnaires, Marlin pages on social networks, network login devices such as Facebook login etc.).
We collect your personal data for the purposes of:
- Meeting our obligations to our customers.
- Managing the reservation of rooms and accommodation requests:
- Creation and storage of legal documents in compliance with accounting standards.
- Managing your stay at our properties:
- Monitoring your use of services (telephone, bar etc.)
- Managing access to rooms
- Internal management of lists of customers having behaved inappropriately during their stay at the hotel (aggressive and anti-social behaviour, non-compliance with the accommodation contract, non-compliance with safety regulations, theft, damage and vandalism, or payment incidents).
- Improving our service, especially:
- Processing your personal data in our customer marketing program in order to carry out marketing operations, promote brands and gain a better understanding of your requirements and wishes
- Adapting our products and services to better meet your requirements
- Customizing commercial offers and the promotional messages we send to you
- Informing you of special offers and any new services created by Marlin Ltd
- Managing our relationship with customers before, during and after your stay:
- Providing details for the customer database
- Segmentation operations based on reservation history and customer travel preferences with a view to sending targeted communications
- Predicting and anticipating future behaviours
- Developing statistics and commercial scores, and carrying out reporting
- Knowing and managing the preferences of new or repeat customers
- Sending you newsletters, promotions and tourist, hotel or service offers, or contacting you by telephone
- Managing requests to unsubscribe from newsletters, promotions, tourist offers and satisfaction surveys
- Taking into account the right to object
- Use a trusted third party to cross-check, analyse and apply certain devices to your collected data at the time of booking or at the time of your stay, in order to determine your interests and your customer profile, and to allow us to send you personalized offers.
- Improving Marlin Ltd services, especially:
- Carrying out surveys and analyses of questionnaires and customer comments
- Managing claims/complaints
- Securing and enhancing your use of Marlin Ltd websites, especially:
- Improving navigation
- Implementing security and fraud prevention.
- Conforming to local legislation (for example, storing of accounting documents).
To guarantee you the right of access and amendment we have to share your personal data with internal and external recipients subject to the following conditions:
a. Within Marlin, in order to offer you the best service, we can share your personal data and give access to authorized personnel from the Group, including:
- Hotel and building staff
- Reservation staff using Marlin reservation tools
- IT departments
- Commercial partners and marketing services
- Medical services if applicable
- Legal services if applicable
- Generally, any appropriate person within Marlin entities for certain specific categories of personal data.
b. With service providers and partners: your personal data may be sent to a third party for the purposes of supplying you with services and improving your stay, for example:
- External service providers: IT sub-contractors, international call centres, banks, credit card issuers, external lawyers, dispatchers, printers, travel, entertainment companies.
- Commercial partners: Marlin may, unless you specify otherwise to the Data Privacy department, enhance your profile by sharing certain personal information with its preferred commercial partners. In this case, a trusted third party may cross-check, analyse and apply certain devices to your data. This data processing will allow Marlin and its privileged contractual partners to determine your interests and your customer profile, and will allow us to send you personalized offers.
- Social networking sites: If interact on Marlin social media accounts, you explicitly authorize Marlin Ltd to access and store the public data on your activity, as well as the other data mentioned during use.
c. Local authorities: We may also be obliged to send your information to local authorities if this is required by law or as part of an inquiry and in accordance with local regulations.
8. PROTECTION OF YOUR PERSONAL DATA DURING INTERNATIONAL TRANSFERS
For the purposes set out in Clause 7 of this Policy, we may transfer your personal data to internal or external recipients who may be in countries offering different levels of personal data protection.
Consequently, in addition to implementation of this Policy, Marlin employs appropriate measures to ensure secure transfer of your personal data to a Marlin entity or to an external recipient located in a country offering a different level of privacy from that proposed in the country where the personal data is collected.
Other than those that are required to carry out your reservation, dataflows to countries having different levels of personal data protection are regulated by standard contractual manager-to-subcontractor clauses defined by the European Commission. Dataflows to the United States are made to entities that belong to Safe Harbor.
Marlin takes appropriate technical and organizational measures, in accordance with applicable legal provisions, to protect your personal data against illicit or accidental destruction, accidental alteration or loss, and unauthorized access or disclosure.
To this end, we have taken technical measures (such as firewalls) and organizational measures (such as a user ID/password system, means of physical protection etc.).
When you submit credit card data when making a reservation, SSL (Secure Socket Layer) encryption technology is used to guarantee a secure transaction.
10. STORAGE OF DATA
We retain your personal data only for the period necessary for the purposes set out in this Policy or in accordance with the provisions of applicable law.
11. ACCESS/ MODIFICATION/ DELETION
You have the right to access your personal data collected by Marlin and to modify it subject to applicable legal provisions.
You may also exercise your right to object by writing to the address below.
In the event of difficulty exercising your rights, please contact the Data Privacy department for Marlin directly by sending an email to GDPR@marlin.com or by writing to the address below:
Data Privacy Department
111 Westminster Bridge Road
SE1 7HR, London
For the purposes of confidentiality and personal data protection, we will need to identify you in order to respond to your request. You will be asked to include a copy of an official piece of identification, such as a driver's license or passport, along with the completed form you can download here.
If your personal data is inaccurate, incomplete or not up to date, please send the appropriate amendments to the Data Privacy department as indicated above.
All requests will receive a response as swiftly as possible and in accordance with applicable law.
You may also exercise your rights in respect of your personal data that is stored and processed by a hotel following a stay.
We may modify this Policy from time to time. Consequently, we recommend that you consult it regularly, particularly when making a reservation at one of our hotels.
Last updated: May 2018
13. QUESTIONS AND CONTACTS
For any questions concerning Marlin’s personal data protection policy, please contact us by telephone on +44 (0) 20 7378 4840