Hala Hotel & Aqua Park Privacy Policy

LAST REVISED ON APRIL  3, 2023

Scope of This Policy
definitions
Hotel booking process
HotelGuests
Subscription to Our Newsletters
Analytics and Cookies
Social Media and Online Reviews
Security Measures What Rules Apply to Children?
How Is Your Personal Data Shared with Third Parties?
International Data Transfers
How Long Will We Keep Your Personal Data?
Does This Privacy Policy Apply to Third Party Websites?
What Happens If We Make Modifications to This Policy?
How to Contact Us

Scope of This Policy

This Privacy Policy describes how Hala Hotel & Aqua Park ("us" or "us") collects, uses, consults or otherwise processes an individual's personal data. This Privacy Policy applies globally, but depending on where you live, some specific provisions of this Privacy Policy may not apply to you.

In some of the cases described in this Privacy Policy, the Hotel will process your data as a joint controller. The hotel will be solely responsible for the processing activities.

For any questions, comments or concerns related to privacy and/or data protection, you can also send an email to me

info@halahotelaquapark.com

We are committed to protecting the privacy of our users and customers..

This Privacy Policy is intended to inform you how we collect, identify and use the personal data you provide to us when using our website or when relying on our hospitality services. Please take a moment to read this Privacy Policy carefully. Please note that if you plan to provide another person's personal data to us, for example when making a booking on their behalf, you may only provide us with that person's details with their consent and after you have given them access to information about how we use their details, including for the purposes set out in this policy This privacy.

This policy describes your data protection rights, including the right to object to some of our processing activities. Please note that your rights as a data subject may differ depending on where you live.

Guinea-Bissau privacy law requires us to be specific about our reasons and legal bases for using your personal data. Accordingly, for the purposes of Guinea-Bissau privacy law only, the information below describes the types of data we process, where we obtain your data from, the reasons we rely on it to carry out the processing, and with whom we may share your data. Except for the “Categories of Processed Data” sections set forth in the information below, nothing is intended to link us in relation to our users outside of these terms below

The purpose of this Privacy Policy (hereinafter referred to as the “Privacy Policy”) is to inform any person who browses the Website and/or fills out forms displayed on the Website and/or books a room on the Website (hereinafter referred to as “User(s)” or “you”) to the obligations undertaken by Hala Hotel & Aqua Park in order to ensure the protection of its personal data..

In particular, we provide you with information about the personal data we collect from you, how we use, disclose and protect it and, finally, how you can exercise your rights over this data.

Definitions

Controller: The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data.

Processor: A natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the controller.

Recipient: A natural or legal person, public authority, agency or another body, to which the Personal Data are disclosed, whether a Third Party or not.

Third Party: A natural or legal person, public authority, agency or body other than the data subject, controller, Processor and persons who, under the direct authority of the controller or processor, are authorized to process Personal Data.

Supervisory Authority: An independent public authority which is established by a Member State pursuant to Article 51 of the GDPR. 

Personal Data: Any information relating to an identified or identifiable natural person (”Data Subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Processing: Any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction. 

Personal Data Breach: A breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, Personal Data transmitted, stored or otherwise processed.

Hotel Booking Process

1. Hotel booking process 

In the context of the hotel booking process – whether this takes place online of our website, through an online booking channel, via a travel agent, through our call center or directly at the hotel – we process your Personal Data for the purpose of (i) enabling you to reserve a room in the hotel; (ii) verifying the availability of the room and to administer the booking; (iii) sending you a booking confirmation; and (iv) sending you pre-arrival emails. You may unsubscribe from pre-arrival emails at any time by clicking on the unsubscribe link in the emails sent to you. 

Processed data categories 

Address, Booking details (including reservation number), Date of arrival and departure, Email address, First name / Last name, First name / Last name of adult co-guest(s), number and expiration date, , Telephone number, Note

Source of data

Depending on the booking mechanism used:

- Directly from you through the online booking form
- Through the online booking channel you used to make the booking 
- From your travel agent 
- From our call center 
- From the Hala hotel you made a direct booking with

Ground for processing

Processing is necessary to take steps to enter into and perform a contract.

Recipients of data 
- The Hala hotel of your choice
- IT service providers involved in the (online) booking process
- IT service providers
- Email communications service provider

2. Guest satisfaction surveys

We may send you guest satisfaction surveys by email during or after your stay to enable us to measure the performance of our hotels. You may unsubscribe from our guest satisfaction survey emails at any time by clicking on the unsubscribe link in the emails sent to you.

Processed data categories

Country of residence, Date of arrival and departure, Email address, First name / Last name, Nationality, Stay details

Source of data

Depending on the booking mechanism used:

- Directly from you through the booking form
- Through the online booking channel you used to make the booking
- From your travel agent
- From our call center
- From the Hala hotel you made a direct booking with

Ground for processing

Processing is necessary to ensure and follow up on the good performance of the contract you have with us.

Recipients of data
- Guest satisfaction survey provider

3. Service emails Analytics

In the context of service emails, which includes guest satisfaction survey emails and any pre-arrival emails concerning your booking, we may process and collect your Personal Data, and notably whether you have opened and actioned a service email, for analytical purposes in order to measure the click-through rate and improve the content of our service emails. You may unsubscribe from our service emails at any time by clicking on the unsubscribe link in the service emails sent to you.

The information below describes the types of data we process for this purpose, where we get your data from, the ground we rely on to carry out the processing, and who we may share your data with.

Processed data categories

Email address, Email clicking behavior, Email opening behavior, First name / Last name.

Source of data

From our email analytics service provider

Ground for processing

It is in Hala Hotel & Aqua Park’s legitimate interest as a business to understand the email clicking behavior of its guests in order to determine whether improvements are needed. In this context, Hala Hotel & Aqua Park’s business interests prevail over yours.

Recipients of data
- IT service providers
- Email analytics service provider

Hotel Guests

1. Hotel check-in and check-out

When staying at Hala Hotel & Aqua Park, we will collect and process your Personal Data for the purposes of (i) registering your arrival and departure at the hotel; (ii) assigning you a key card to your room; (iii) obtaining a credit card guarantee or hotel deposit to ensure payment of your stay; (iv) managing (and archiving) your hotel registration card; (v) creating or updating your profile in our hotel management system; (vi) assessing your eligibility for a room upgrade and managing this if applicable; (vii) managing payment of your stay; (viii) establishing, printing or sending an invoice for your stay; and (ix) paying a commission to your travel agent (if applicable).

In the event you have booked a room but do not show up – without cancelling – on the date of arrival communicated, we will process your Personal Data for the purposes of (i) cancelling your stay and any other reservation you may have made; and (ii) managing, processing and settling any outstanding payment that may be due.

Processed data categories

Address, Bookings (hotel, restaurant, event, theater, etc.), Date of arrival and departure, Email address, First name / Last name, First name / Last name of adult co-guest(s), Payment card type, number and expiration date, Telephone number, Title

Source of data

Depending on the booking mechanism used:

- Directly from you through the booking form
- Through the online booking channel you used to make the booking
- From your travel agent
- From our call center
- From the Hala hotel you made a direct booking with
- Directly from you through the hotel registration card

Ground for processing

Processing is necessary to perform the contract you have with us.

Recipients of data
- IT service providers
- Your travel agent (if applicable)

2. Credit limit reports

To ensure payment for all guests staying in a hotel room, each hotel guest is asked for a credit card or deposit upon arrival. In order to ensure that you do not exceed your credit limit during your stay, we produce a credit limit report multiple times a day for the purposes of verifying whether your credit limit has been exceeded. These credit limit reports may contain your Personal Data. Please note that in limited circumstances these credit limit reports may be subject to one of our internal financial audits, and may therefore be accessed by members of our internal audit department, in order to ensure that our hotels follow the Hala Hotel & Aqua Park’s internal guidelines and policies.

Processed data categories

Date of arrival and departure, First name / Last name, Payment card type, number and expiration date

Source of data

Depending on the booking mechanism used:

- Directly from you through the booking form
- Through the online booking channel you used to make the booking
- From your travel agent
- From our call center
- From the Hala hotel you made a direct booking with
- Directly from you through the hotel registration card

Ground for processing

Processing is necessary to ensure the performance of the contract you have with us.

Recipients of data
- IT service providers

3. Hotel stay

When you stay in Hala Hotel & Aqua Park’s, we endeavor to make your stay as pleasant as possible. This requires processing your Personal Data for the purposes of providing specific services during your hotel stay. These services include (i) housekeeping and maintenance; (ii) returning lost or forgotten items to you; and/or (iii) managing your and your co-guests’ preferences, such as dietary requirements and pillow preferences, in order to provide you with a better service during your stay with us.

Processed data categories

Address, Consumption habits, Date of arrival and departure, Dietary requirements, Email address, First name / Last name, First name / Last name of adult co-guest(s), Other preferences, Payment details (for the purpose of returning lost or forgotten items), Telephone number

Source of data

Depending on the booking mechanism used:

- Directly from you through the booking form
- Through the online booking channel you used to make the booking
- From your travel agent
- From our call center
- From the Hala hotel you made a direct booking with
- Directly from you during your stay at the hotel

Ground for processing

It is in Hala Hotel & Aqua Park’s legitimate interest as a business to organize its day-to-day hotel maintenance activities, to personalize the services it provides, and/or to be able to identify the owner of a lost or forgotten item. Taking into account the limited Personal Data processed and shared for such purpose(s), Hala Hotel & Aqua Park’s business interests prevail over yours.

Recipients of data

- Hotel personnel, including housekeeping, maintenance, front desk, and/or other hotel personnel concerned
- IT service providers
- Delivery or courier service providers (for the purpose of returning lost or forgotten items)

4. Hotel guest additional services and facilities

In our hotel you can benefit from additional services and facilities, such as breakfast, room service, minibar, waterpark, pool, restaurants and bars, spa treatments, laundry services, parking, taxi requests, free Wi-Fi, etc. In the event you make use of additional services or facilities at one of our hotels, your Personal Data may be processed to (i) manage the booking and use of such additional hotel services and/or facilities; (ii) administer any advance bookings of additional services and/or facilities to your file; (iii) personalize returning guests’ arrival to the hotel and the choice of room amenities and room features; and (iv) manage the expenses incurred for such additional services and/or facilities.

Processed data categories

Consumption habits, Date of arrival and departure, Dietary requirements, Email address, First name / Last name, First name / Last name of adult co-guest(s), Payment card type, number and expiration date, Note

Source of data

- Directly from you through the online booking form
- Through the online booking channel you used to make the booking
- From your travel agent
- From our call center
- Directly from you through the hotel registration card
- Directly from you when making your additional service/facility request with the hotel front desk or the concierge
- Through the online booking platform for additional services and facilities

Ground for processing

Processing is necessary to take steps with a view to entering into a contract and/or to perform the contract.

Recipients of data

- Hotel personnel, including front desk, room service, and/or other hotel personnel concerned
- IT service providers

Subscription to Our Newsletters

1. Newsletters and marketing communications

If you have explicitly consented to receive our newsletters or marketing communications, we may, from time to time, contact you with information about our services and latest offers and process your Personal Data for this purpose.

If you no longer want to receive our newsletters or marketing communications, please let us know by sending us an email at info@halahotelaquapaek.com. You can also unsubscribe from our marketing emails by clicking on the unsubscribe link in the emails sent to you.

Processed data categories

- Address, Date of birth, Email address, First name / Last name, Gender, Hobbies and interests, Telephone number, Hotel stay history, Country of residence

Source of data

- Directly from you when subscribing to our newsletter or later when completing your account

Ground for processing

- Ad hoc consent obtained during the subscription to our newsletter

Recipients of data
- IT service providers
- Email communications service provider

2. Newsletters and marketing communications analytics

In the context of our newsletters and marketing communications, we may also process and collect your Personal Data, and notably whether you have opened and interacted with one of our communications, for analytical purposes in order to measure the click-through rate and improve the content of our newsletters and marketing communications.

Processed data categories

- Email address, Email clicking behavior, Email opening behavior, First name / Last name,

Source of Data

- From our email analytics service provider

Grounds for Processing

- It is Hala Hotel & Aqua Park’s legitimate interest as a business to understand the click-through rate of its emails in order to determine whether improvements are needed. In this context, Hala Hotel & Aqua Park’s business interests prevail over yours.

Recipients of Data
- IT service providers
- Email analytics service provider

 

Analytics and Cookies

We may use any data you provide to us for analytical purposes to optimize your experience, enhance our marketing, business and operational efficiency, create segments of our customers based on their Personal Data and tailor our offers and promotions to your preferences and consumption habits. In the context of such analytics, we analyze and may combine different data we hold about our guests, including (i) responses to guest satisfaction surveys; (ii) communications guests have with us; (iii) click-through rates for our marketing communications; (iv) our guests’ behavior on our websites; (v) bookings.

Processed data categories

- Hotel stay details, Address, Bookings (hotel, restaurant, event, theatre, etc.), Date of arrival and departure, Title, First name / Last name, First name / Last name of adult co-guest(s), Email address, Telephone number, Payment card type, number and expiration date, redemption history

Source of Data
- Directly from you through the online booking form
- Through the online booking channel you used to make the booking
- From your travel agent
- From our call center
- From our email analytics provider
- Directly from you when making your additional service/facility request with the hotel front desk or the concierge

Ground for processing

- It is in Hala Hotel & Aqua Park’s legitimate interest as a business to understand its guests’ preferences and consumption habits. In this context, Hala Hotel & Aqua Park’s business interests prevail over yours.

Recipients of data
- IT service providers
- Analytics service provider
- Providers of targeted advertisements

Processed data categories

- Any Personal Data you may decide to share with us or published on social media or in other online reviews about us

Source of Data

- Directly from you through publicly accessible social media pages, online booking channels or other (review) websites
- From our online reputation monitoring service provider

Ground for processing

- It is in Hala Hotel & Aqua Park’s legitimate interest as a business to process the Personal Data you have chosen to address to us or make publicly available on social media platforms, online booking channels or other (review) websites in order to improve our services and identify business opportunities. In this context, Hala Hotel & Aqua Park’s business interests prevail over yours..

Recipients of data
- Online reputation monitoring service provider

log files

As with most different websites, we collect and use data in log files.The information in the log files includes your Internet Protocol (IP) address, your Internet service provider (ISP), the browser you used to visit our Site, the time of your visit, and the pages you visited on our site.

Cookies            

We use cookies to give you the best possible user experience on a simple site, for more information about cookies.

Essential cookies

Essential cookies are necessary for you to navigate and move around the site, and do not store any information that could be used for advertising purposes. Without essential cookies, our site will not function properly.

custom cookie

These cookies store information, such as your personal preferences, and use it to personalize a unique experience for you.This may include displaying a popup only once in your visit, saving your language preferences, or allowing you to automatically sign in to some of our features.

Analytics cookies

Analytics cookies capture anonymous data so we can see trends and improve your website experience.These allow us to test different designs, and help us identify a break if a part of our site is not working.

Advertising cookies

Some third party advertisers may use cookies or web beacons when advertising on our site.

They will send information to these advertisers (such as Google through the Google AdSense program) including your IP address, Internet service provider, the browser you used to visit our site, and in some cases information about whether you have Flash installed.

Third party vendors, including Google, use cookies to serve ads based on a user's previous visits to our website or other websites.

Using advertising cookies, Google and its partners will be able to display ads to your users based on their visits to our site and/or other sites across the Internet.

Users may opt out of the use of personalized ads by going to the Ads Settings.

If you have not opted out of serving third party ads, the cookies of other third party ad networks or vendors may also be used to serve ads on our site.

This is generally used for geotargeting purposes for example (showing SEO ads in Bissau to someone in Bissau) or showing specific ads based on specific sites visited (eg showing real estate ads to someone who visits real estate websites).

By continuing to use our site, you agree to the placement of cookies on your device. You can choose to selectively disable or turn off cookies or third party cookies in your browser settings. However, this can affect how you interact with our site as well as with other websites.

Social Media and Online Reviews

We may process your Personal Data obtained through social media platforms (including Facebook, Instagram, and LinkedIn) or online reviews (including on TripAdvisor) concerning our Hala Hospitality for the purposes of (i) addressing your questions or complaints; (ii) monitoring our online reputation; and (iii) improving our services and identifying opportunities on which we can focus.

Some of our social media pages allow users to submit their own content. Please remember that any content submitted to one of our social media pages can be viewed by the public, and you should be cautious about providing certain personal information (e.g., financial information or address details) via these platforms. We are not responsible for any actions taken by other individuals if you post personal information on one of our social media platforms (e.g., Facebook or Instagram). Please also refer to the respective privacy and cookie policies of the social media platforms you are using.

Processed data categories

- Any Personal Data you may decide to share with us or published on social media or in other online reviews about us

Source of Data

- Directly from you through publicly accessible social media pages, online booking channels or other (review) websites
- From our online reputation monitoring service provider

Ground for processing

- It is in Hala Hotel & Aqua Park’s legitimate interest as a business to process the Personal Data you have chosen to address to us or make publicly available on social media platforms, online booking channels or other (review) websites in order to improve our services and identify business opportunities. In this context, Hala Hotel & Aqua Park’s business interests prevail over yours..

Recipients of data
- Online reputation monitoring service provider

Social media contests

From time to time, we may organize a contest on one of our social media pages. If you choose to participate in such contest, we will process your Personal Data for the purpose of organizing and managing the social media contest and picking the winner(s).

Processed data categories

- This depends on the data fields in the contest concerned, but almost always includes the following categories of data:

Address, Email address, First name / Last name, Telephone number

Source of Data

- Directly from you through our social media pages

Ground for processing

- Processing is necessary to take steps to enter into and perform a contract as you accept the terms and conditions of the contest.

Recipients of data
- IT service provider

Security Measures

Appropriate technical and organizational measures are implemented in order to ensure an appropriate level of security of your Personal Data, including but not limited to encryption techniques, physical and IT system access controls, obligations of confidentiality, etc.

In the event Personal Data is compromised as a result of a Personal Data Breach we will make the necessary notifications, as required under applicable laws.

What Rules Apply to Children?

We do not knowingly collect or solicit Personal Data from anyone under the age of 18 or knowingly allow such persons to book a room in one of our hotels. In the event we learn that we have collected Personal Data from a child under the age of 18 without verification of parental consent, steps will be taken promptly to remove that information. If you believe that we have or may have information from or about a child under 18 years of age, please contact us at info@halahotelaquapark.com.

How Is Your Personal Data Shared with Third Parties?

We only share or disclose information as described herein, including with Third Parties.

Your Personal Data will also be shared with government authorities and/or law enforcement officials if required for the purposes above, if mandated by law or if required for the legal protection of the Controller(s) legitimate interests in compliance with applicable laws. In addition, we may share your Personal Data and other information with a successor to all or part of our business, where this is in our legitimate interests in facilitating a business sale and in this context our business interests prevail over yours. For example, if parts of our business or assets are sold, we may disclose user information as part of that transaction, subject to applicable law.

How Long Will We Keep Your Personal Data?

We retain your Personal Data for as long as is required to fulfil the activities set out in this Privacy Policy, for as long as otherwise communicated to you or for as long as is permitted by applicable law. For example, we may retain your Personal Data if it is reasonably necessary to comply with any legal obligations, meet any regulatory requirements, resolve any disputes or litigation, or as otherwise needed to enforce this Privacy Policy and prevent fraud and abuse.

To determine the appropriate retention period for the information we collect from you, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of the data, the purposes for which we process the Personal Data, and whether we can achieve those purposes through other means, and the applicable legal requirements.

Does This Privacy Policy Apply to Third Party Websites?

If you click on a link to a Third Party website, you will be taken to a website we do not control and our Privacy Policy will no longer be in effect. Your browsing and interaction on any other website is subject to the terms of use and privacy and other policies of such Third Party website. Read the privacy policies of other websites carefully. We are not responsible or liable for the information or content on such Third Party websites.

What Happens If We make modifications to This Policy?

We reserve the right to modify and update this Privacy Policy from time to time. We will bring these changes to your attention should they be indicative of a fundamental change to the processing or be relevant to the nature of the processing or be relevant to you and impact your data protection rights.

How to Contact Us

Questions, comments, remarks, requests or complaints regarding this Privacy Policy are welcome and should be addressed to info@halahotelaquapark.com. If you have questions about an individual hotel’s practices or the information it has, please contact the hotel directly.