The privacy and security of your information is very important to us. Whether you are visiting our website, using our app, booking a room, or are a member of one of our loyalty programs, we want you to trust the way that we manage your information and to keep you informed about how we use that information.
We have prepared this Privacy Statement to explain more about who we are, how we collect and manage your information (whether through our website, mobile apps, our social media pages, or offline) and the choices you have about how we use your information.
Who we are
This Privacy Statement is issued by the The Wind Group of Companies (collectively referred to as “TWG”, “we”, “us” or “our” in this Privacy Statement), which includes the direct and indirect subsidiaries of The Wind Group and covers information that we collect and use in the course of our business. When we mention “TWG”, “we”, “us”, or “our”, we are referring to the relevant company in the The Wind Group that processes your personal information.
Your information may also be collected and used by TWG-branded hotels.
Information we collect and how we use and share it
We collect personal information directly from you, about you from other persons/entities/online channels, and automatically as you use our website, mobile application, and through certain offerings or services available at TWG-branded properties (such as TWG wI-fI). In particular, we collect and use information about you if you (or someone on your behalf) makes a reservation to stay at an TWG-branded hotel or property offered through TWG reservations, participate in one of our loyalty programs, or interact with us through our corporate site or mobile app. You do not have to provide us with your personal information in order to use our website or mobile app; in some cases, however, we may not be able to provide services to you without your personal information (for example, we would not be able to complete a requested booking or enroll you in our rewards program).
The legal basis for processing your personal data
We are committed to collecting and using your information in accordance with applicable data protection laws.
We collect, use and share your information where we have an appropriate legal basis to do this.
This may be because:
- you have provided your consent to us using the personal information;
- our use of your information is necessary to perform our contract with you, for example, making and managing your booking and operating and providing services in connection with our Loyalty Program in accordance with the terms of our agreement with you;
- our use of your information is necessary to meet responsibilities we have to our regulators, tax officials, law enforcement, or otherwise meet our legal responsibilities;
- our use of your information is in our legitimate interest as a commercial organization, for example to operate and improve our services and to keep people informed about our products and services (including for profiling and targeted advertising) – in these cases we will look after your information at all times in a way that is proportionate and respects your privacy rights.
If you have provided your consent to our processing of your information you can withdraw this consent at any time by contacting the TWG.
As we operate via a global network, it may be necessary to transfer your information to a country outside of the country where it was originally collected or outside of your country of residence or nationality. The information that you provide us during the course of a reservation or through the provision of any other services may be transferred to any of our TWG-owned or affiliated entities and hotels for the purposes of carrying out or facilitating these services. It will also be necessary to transfer this information to other entities, including, without limitation, our TWG-branded hotels, partners and our service providers.
Where we transfer information which originates in the European Union (“EU”) to a country outside of the EU, we will take steps to make sure such transfer is carefully managed to protect your privacy rights:
- we will only transfer personal information to countries which are recognized as providing an adequate level of legal protection or where we can be satisfied that alternative arrangements are in place to protect your privacy rights; and
- any requests for information we receive from law enforcement or regulators will be carefully validated before personal information is disclosed.
When we otherwise transfer personal information between jurisdictions, we will take such steps as required by local law in an effort to ensure that such transfer is managed to protect your privacy rights.
Using our websites, mobile applications and other technology
Cookies and other tracking technologies
What is a cookie: A “cookie” is a small text file that is placed onto an Internet user’s web browser or device and is used to remember as well as obtain information about that party. You might be assigned a cookie when visiting our websites or when using our mobile applications. In some instances, where permitted under the applicable law, cookies may also be used for the purposes of certain email campaigns.
What types of cookies we use and how we use them: We use three primary types of cookies, which include:
- Functional Cookies – these cookies support the use of the website and applications and enable certain features to enhance your experience. For example, we use functional cookies to facilitate your reservation and to remember your selections as you move from page to page. We also use functional cookies for remembering things like your sign-in information and hotel preferences to avoid you having to re-enter it.
- Performance Cookies – these cookies collect information needed to support the website and our applications and allow us to improve our website and identify any problems that you faced while visiting us. For example, performance cookies may provide us with information about how you came to our website and how you navigated around our website during your visit. We also use these cookies to provide us with certain statistical and analytics information, such as how many visitors came to our website or how effective our advertising is.
- Targeting Cookies – these cookies are used to collect information from you to help us to improve our products and services as well as serve you with targeted advertisements that we believe will be relevant for you. We use targeting cookies across our websites and applications for various marketing initiatives and campaigns. For more information, please see the targeted advertising section below.
To learn more about cookies and how they are used, please visit: www.allaboutcookies.org.
Cookies: As described above, we use a number of service providers to help us manage, carry out and improve our advertising. These parties set cookies at our direction to help us collect information and provide you with advertisements that we believe would be relevant for you. In some instances, these parties may also assist us by providing certain statistical and analytics information in relation to our marketing practices. We also may share information collected through cookies (and other tracking technologies) with third parties to use for their own analytics and marketing purposes. These third parties may serve targeted advertising to you about TWG and non-TWG branded hotels. The scope of information shared may include information collected through cookies, such as your IP address/device ID, and information about the search that you performed on our website (e.g., you were looking for a hotel in New York City), but would not include your name or TWG Rewards information.
Managing cookies and opting out: You can choose to visit our web sites without cookies, but in some cases certain services, features and functionality may not be available. To visit without cookies, you can configure your browser to reject all cookies or notify you when a cookie is set. Each browser is different, so check the “Help” menu of your browser to learn how to change your cookie preferences.
Other technologies: Other technologies such as pixels and web beacons may also be used on our websites, mobile applications, in email messages and in other areas of our business. These technologies are used to improve our products and services as well as our marketing efforts.
Targeted advertising: We and our service providers may serve targeted advertisements through the use of first-party or third-party cookies, pixels and web beacons when you visit our website, use our mobile applications, or visit websites owned by other entities. In some instances, these cookies may be persistent cookies. We and our service providers may also use cookie and other information to try to identify other devices and web browsers that you may use so we and our service providers may serve targeted advertisements to those devices. We do this to provide you with advertising that we believe may be relevant for you as well as improve our own products and services, including the functionality and performance of our websites and mobile applications.
Do-Not-Track: Currently, our systems do not recognize browser “do-not-track” signals. You may, however, disable certain tracking as discussed in this section (e.g., by disabling cookies).
Use of WI-FI services (TWG Wifi)
When you use the TWG WI-FI service (TWG wifi), we may collect and process certain additional information.
What information we collect
- Registration and User-Provided Information: When you register to use TWG wifi, we may collect personal information about you including your Rewards number. You may also provide us with personal information about you in various ways when you use TWG wifi, for example, when you send us customer service-related requests.
- Device Identifiers. In the course of providing the TWG wifi, we may automatically collect a device identifier (such as your IP address, MAC address, device name or other unique identifier) for the computer, mobile device, technology or other device you use to access TWG wifi. A device identifier is a number that is automatically assigned to your device when you access TWG wifi, and we may identify your device by its device identifier. When you use TWG wifi, we may view your device identifier and use this information to enhance our service. We may associate your device identifier with other information about you, such as your TWG Rewards number.
- Other device information: We may also automatically record certain information from your device including, device type, the web pages, apps or sites that you visit, and the dates and times that you visit, access, or use TWG wifi (Internet activity information). While generally this information is pseudonymous and/or aggregated, this information may be associated with your TWG Rewards number and/or other TWG service account information or persistent identifiers. This data helps us to manage our networks and provides us with information about the use of TWG wifi. We do not, however, collect and process the contents of email communications or other electronic communications you send or receive when using TWG wifi.
- Location information: We may collect information about your location through your use of the WI-FI services we provide at our hotels to enable us to improve our service and provide certain services to you such as customized offers and promotions.
How We Use the Information We Collect
We use personal information only for the purposes described in this Privacy Statement, except if otherwise disclosed to you at the time the data is collected or otherwise authorized by law or by you. We use the personal information that we collect through TWG wifi:
- to operate, maintain, enhance and provide all features of the service, to provide services and information that you request, to respond to comments and questions and to provide support to users.
- to understand and analyze the usage trends and preferences of our users, to improve the TWG wifi service, and to develop new products, services, features, and functionality. If you provide your contact information or your TWG Rewards number, we may (with your consent or where permitted by applicable law) send you personalized offers based on your web usage and location.
Using Personal Information to create profiles
Our goal is to create a personalized and customized experience for you when you stay at an TWG-branded property. In order to determine appropriate advertising and to customize your experience, as described in the section above in relation to cookies, we have relationships with companies such as Google and Facebook which enable us to serve targeted advertising. In addition, we also match Facebook and Google users across sites and devices which enables us to better understand your interests. We use this information to enable us to tailor our marketing communications to you so we can make sure we tell you about things which are most likely to be of interest to you.
How we secure your information
We are committed to protecting the confidentiality and security of the information that you provide to us. To do this, technical, physical and organizational security measures are put in place to protect against any unauthorized access, disclosure, damage or loss of your information. The collection, transmission and storage of information can never be guaranteed to be completely secure, however, we take steps to ensure that appropriate security safeguards are in place to protect your information.
Links to Other Sites
Our websites and applications contain links to websites that are maintained and/or controlled by non-affiliated parties. In some instances these websites may be co-branded and display our logos or other trademarks. You can always tell whether you are on one of our websites by checking the uniform record locator (“URL”) on the page that you are visiting. We encourage you to review the privacy policies of these websites as their privacy practices may differ from ours.
Our websites are not intended for children and we do not intentionally solicit or collect personal information from individuals under the age of 18. If we are notified or otherwise discover that a minor’s personal information has been improperly collected, we will take all commercially reasonable steps to delete that information. In limited instances, we may have a campaign or program targeted toward children. In these instances, details on the information practices will be presented within the terms and conditions of the program or campaign.
Retaining your information in our systems
How to contact us
For any questions or concerns regarding this Privacy Statement or our data privacy practices, please contact us:
- By email: firstname.lastname@example.org
To the extent permitted under the local law, you may also use the above contact details to request access to, correct, or (in certain circumstances) delete, any of your personal information that is held by TWG, or, where we have relied upon your consent to process your personal information, to withdraw your consent to such processing of your personal information. These requests will be reviewed and processed in line with the local law.
You also may have a right under the local law to lodge a complaint with us or with your local data protection supervisory authority at any time. However, we ask that you please try to resolve any issues with us first before referring your complaint to the supervisory authority.
Changes to this Privacy Statement
In some instances, we may have to change, modify or amend this Privacy Statement in order to comply with the evolving regulatory environment or the needs of our business. Subject to any applicable legal requirements to provide additional notice, any changes to this Privacy Statement will be communicated through our websites and mobile applications. However, if there will be changes made to the use of your personal information in a manner different from that stated at the time of collection we will take appropriate steps to notify you, such as by posting a notice on our website for 30 days prior to the changes taking effect or by emailing you.
Effective Date: April 1, 2019