The Application of this Policy
This Policy applies to personal information regarding guests and the other individuals with whom we do business or who visit us, and to the use of that personal information in any form, whether oral, electronic and/or written.
If we disclose the personal information we hold about you to other of our affiliated hospitality businesses, those entities must first have agreed to be bound by this Policy with respect to their processing of your personal information.
This Policy gives effect to our commitment to protect your personal information and has been adopted by all of the separate and distinct legal entities that manage, operate, franchise, license, own and/or provide services to the various locations operating under or in connection with the New Palace fashion and New Palace hotel. References to “New Palace”, “we” and “our” throughout this Policy, depending upon the context, collectively refer to those separate and distinct legal entities.
While this Policy is intended to describe the broadest range of our personal information processing activities globally, those processing activities may be more limited in some jurisdictions based on the restrictions of their laws. For example, the laws of a particular country/region may limit the types of personal information we can collect or the manner in which we process that personal information. In those instances, we adjust our internal policies and/or practices to reflect the requirements of local law.
Types of Personal Information We Collect
The term “personal information” in this Policy refers to information that identifies or is capable of identifying you as an individual. The types of personal information that we process (which may vary by jurisdiction based on applicable law) include:
your name, gender, personal and work contact details, business title, date and place of birth, image, nationality, and passport and visa information;
guest stay information, including the hotels where you have stayed, dates of arrival and departure, goods and services utilized, special requests made, observations about your service preferences (including room and vacation preferences), telephone numbers dialed and faxes, texts and telephone messages received;
your credit card details, payment method details and your account details and credentials for the New Palace frequent guest program;
any information necessary to fulfill special requests (e.g., health conditions that require specific accommodation or services);
information, feedback or content you provide regarding your marketing preferences, in surveys, sweepstakes, contests or promotional offers, or to our websites and those of third parties;
information collected through the use of closed circuit television systems, internet systems (including wired or wireless networks that collect data about your computer, smart or mobile device, or your location), card key and other security and technology systems;
information collected while you access New Palace website (we describe this in more detail in Sections 6 below);
contact and other relevant details concerning the employees of corporate accounts and vendors and other individuals with whom we do business (e.g., travel agents or meeting and event planners); and
in limited cases, information relating to the credit of customers.
There may be instances in which the personal information that you provide to us or that we collect is considered “Sensitive Personal Information” under the privacy laws of some countries or regions. Those laws define “Sensitive Personal Information” to mean personal information from which we can determine or infer an individual’s racial or ethnic origin, political opinions, religious beliefs or other beliefs of a similar nature, membership in a trade union or professional association, physical or mental health or condition, medical treatment, genetic data, biometric information, and information about an individual’s sexual life or sexual orientation. In some very rare instances, financial records may constitute Sensitive Personal Information where you are located. We only process Sensitive Personal Information in your jurisdiction if and to the extent permitted or required by applicable law.
When you agree to this Policy you are, to the extent required under your local law, granting your express and written consent to the processing of any personal information that you provide to New Palace that is considered to be Sensitive Personal Information or financial information. Save to the extent required by law, you are not obliged to provide New Palace with any of your Sensitive Personal Information, and should you choose not to, this will not prevent you from purchasing any products or services from New Palace.
How We Use Personal Information
Subject to applicable laws, we may collect, use, and disclose relevant portions of your personal information in order to:
provide and charge for hotel accommodation and other goods and services;
provide you with a better or more personalized level of service;
facilitate services on your behalf, including restaurant and transportation transactions;
administer the New Palace frequent guest program;
fulfill contractual obligations to you, anyone involved in the process of making your travel arrangements (e.g., travel agents, group travel organizers or your employer) and vendors (e.g., credit card companies, airline operators and third-party loyalty programs);
conduct market research, customer satisfaction and quality assurance surveys, and direct marketing and sales promotions;
provide for the safety and security of staff, guests and other visitors;
administer general record keeping;
meet legal and regulatory requirements;
test and evaluate new products and services; and
process credit applications.
New Palace uses and retains your personal information for as long as is necessary to fulfill the purpose for which it is being processed, and in line with our legal and regulatory obligations and risk management guidelines.
Disclosures of your Personal Information
From time to time, we may disclose your personal information. We would always make that disclosure in accordance with applicable law. In some jurisdictions, data privacy laws may require us to obtain your consent before we transfer your information from your originating country to other countries. When you agree to this Policy, you are, to the extent required and permitted under your local law, granting your consent to the transfer of your personal information to such other countries for the Purpose and to the extent stated in this section and as described in Section 4 above.
Circumstances where we might make such disclosure (in addition to those described in Section 4 above) include:
5.1 Our Agents, Service Providers and Suppliers
Like most hotel brands, we may outsource the processing of certain functions and/or information to third parties. When we do outsource the processing of your personal information to third parties or provide your personal information to third-party service providers, we oblige those third parties to protect your personal information in accordance with the terms and conditions of this Policy, with appropriate security measures and prohibit them from using your personal information for their own purposes or from disclosing your personal information to others.
5.2 Consumer Insights
Where we hold personal information about you, we may disclose this personal information to other companies that also hold information about you. These companies may combine the information in order to better understand your preferences and interests, thereby enabling them and us to serve you better. If your personal information is used for direct marketing purposes, you have the right to object to that by contacting us using the contact information provided under Section 10 below. Further information about how we conduct direct marketing may be found at Section 7 below.
5.3 Credit Authorization
When you request credit, your personal information will be used and disclosed to appropriate third parties in accordance with applicable laws for the purpose of determining whether to grant and maintain a line of credit to you.
5.4 Business Transfers
As we continue to develop our business, we may sell the hotel, fashion brand and other assets, or cease being the manager or franchisor of New Palace. In those circumstances, we may include the personal information collected about you, or control of that personal information, as a business asset in any such transfer. Also, in the unlikely event that we, or substantially all of our assets, are acquired, personal information collected about you, or control of such information, may be one of the transferred assets.
5.5 Legal Requirements
We reserve the right to disclose any personal information we have concerning you if we are compelled to do so by a court of law or lawfully requested to do so by a governmental entity or if we determine it is necessary or desirable to comply with the law or to protect or defend our rights or property in accordance with applicable laws. We also reserve the right to retain personal information collected and to process such personal information to comply with accounting and tax rules and regulations and any specific record retention laws.
Information We Collect When You Visit Us Online
If you choose to obtain information or do business with us online by visiting http://www.New Palacehotel.com, you may wish to know the following:
6.1 You Can Browse Without Revealing Who You Are
You can always visit our websites without revealing who you are or providing any personal information.
6.2 Usage Information
When you visit our websites, we collect information about how you use those websites. Examples of such information include the Internet Protocol address automatically assigned to your computer each time you browse the Internet, the date and time of your visit, the pages you access and the amount of time you spend on each page, the type of Internet browser you use, your device’s operating system and the URL of any websites that you visited before and after visiting our website. That information is not linked to you as an individual unless you create a user profile, but we may keep records of the type of device being used. We use this information to evaluate and improve the features, guest experience and functionality of our website.
6.3 Cookies and Other Similar Technology
We use cookie technology on our websites to allow us to evaluate and improve the functionality of our websites. Our cookies by themselves cannot be used to reveal your identity. They identify your browser or device, but not you, to our servers when you visit our websites.
If you do not want to accept cookies, you can block them by adjusting the settings on your Internet browser. However, if you block them, you will not be able to use all of the features of our websites, including the customization features associated with creating a user profile.
Further information about cookies and other similar technology and how they work is available at allaboutcookies.org.
6.4 Minor Children
The services offered by New Palace Hotel Bac Lieu are not directed at children under 18 years old. The use of any of our services is only allowed with the valid consent of a parent or a guardian. If we receive information from a child under 18 years old, we reserve the right to delete it. In limited cases as part of a reservation, purchase of other travel-related services, or in exceptional other circumstances (such as features addressed to families) New Palace Hotel Bac Lieu may collect and use information of children only with the consent of the parent.
You may always choose what personal information (if any) you wish to provide to us. However, if you choose not to provide certain details, some of your experiences with us may be affected (for example, we cannot take a reservation without a name).
If you provide us with your contact details (e.g., postal address, email address, telephone number or fax number), we may contact you to let you know about the products, services, promotions and events offered that we think you may be interested in. We may also share your personal information with carefully-selected third parties, who may communicate directly with you. In some jurisdictions, data privacy laws may require us to obtain a separate consent before we do so. You can always choose whether or not to receive any or all of these communications by contacting us as described in Section 10 below or following the “unsubscribe” instructions contained in the communications.
If you have an account with our frequent guest program, we ask you to indicate your communication preferences at the time you apply for membership or when you create your user profile. We may also ask you to indicate how you would like to receive any offers, marketing and promotional information (e.g., via email or regular mail) and whether you would be willing to participate in surveys. Once you have indicated your preferences, you can always change them.
In some jurisdictions, in addition to you agreeing to this Policy, data privacy laws may require us to obtain a separate consent before we send you information that you have not specifically requested. In certain circumstances, your consent may be implied (e.g., where communications are required in order to fulfil your requests and/or where you have volunteered information for use by us). In other cases, we may seek your consent expressly in accordance with applicable laws (e.g., where the information collected is regarded to be Sensitive Personal Information under local regulations).
We will abide by any request from you not to send you direct marketing materials. When such a request is received, your contact details will be “suppressed” rather than deleted. This will ensure that your request is recorded and retained unless you provide a later consent that overrides it.
Updating or Accessing Your Personal Information
With some limited exceptions, you have rights to access and update personal information held about you. If you want to inquire about any personal information we may have about you, you can do so by sending us a written request by letter or email to the addresses set out. Please be sure to include your full name, address and telephone number and a copy of a document evidencing your identity (such as an ID card or passport) so we can ascertain your identity and whether we have any personal information regarding you, or in case we need to contact you to obtain any additional information we may require to make that determination.
You may request that we correct, delete, and/or stop or restrict processing or using personal information that we hold about you by sending a letter or email to the addresses set out in Section 10 below. If we agree that the personal information is incorrect, or that the processing should be stopped, we will delete or correct the personal information. If we do not agree that the personal information is incorrect we will tell you that we do not agree, explain our refusal to you and record the fact that you consider that personal information to be incorrect in the relevant file(s).
Changes to this Policy
Just as our business changes constantly, this Policy may also change. To assist you, this Policy has an effective date set out at the end of this document.
Request for Access to Personal Information/Questions or Complaints
If you have any questions about this Policy, about the processing of your data described, or any concerns or complaints with regard to the administration of the Policy, or if you would like to submit a request (in the manner described in Section 8 above) to exercise your rights in relation to the personal information that we maintain about you, please contact us by any of the following means:
by calling one of the following reservation numbers located at http://www.newpalace.com.vn/;
by sending us an email; or
by contacting the front desk at any of our hotel.
If you are not satisfied with the response that you receive, you can escalate your concern to the Chief Privacy Officer by sending an email to New Palacehotel@gmail.com.
All requests for access to your personal information must be submitted in writing by letter or email. We may respond to your request by letter, email, telephone or any other suitable method.
Effective Date: December 2017