Swissôtel Clark - Luxury hotel - Privacy Policy

Swissôtel Clark (hereinafter referred to as Swissotel), owned and operated by Hann Philippines, Inc., recognizes and respects your rights to privacy and is committed to keep secure and confidential all personal information and sensitive personal information that you may provide to us or those that we may collect from you upon entering, engaging, and/or transacting with us.  

This privacy policy explains (1) what personal data that Swissotel collects, (2) how Swissotel processes your personal information, (3) how Swissotel store your personal information, and (4) what are the steps you could take to exercise your rights as Data Subjects.  

This policy is in compliance with the Republic Act No. 10173 or the Data Privacy Act (DPA) of 2012, relevant issuances of the National Privacy Commission (NPC), and relevant international Data Privacy Laws. 

 

Use and Processing of Personal Data 

Swissotel processes personal data in order to fulfill specific purposes and to perform our obligations and rights as a Hotel industry, we may collect, use, store, retain, disclose. And process your personal data which we will inform you, as our Data Subjects, through privacy notices, statements, forms, documents, and other relevant media outlet.  

Furthermore, there may also be specific provisions, which may apply to our collection and use of your personal information such as but not limited to information provided when subscribing to our newsletter and/or participating in our surveys.  

 

Collection of Personal Data 

Swissotel collects a wide range of personal and sensitive personal information due to the nature of our operations. Our platform or authorized personnel will only collect necessary and relevant information from you.  

In general, these are the personal data we may collect from you and/or persons accompanying you:  

a. Contact details (for example, last name, first name, telephone number, email) 

b. Personal information (for example, date of birth, nationality) 

c. Information relating to your children (for example, first name, date of birth, age) 

d. Your credit card number (for transaction and reservation purposes) 

e. Information contained on a form of identification (such as ID card, passport or driver license) 

f. Your membership number for the Accor loyalty program or another partner program (for example, an airline loyalty programme) and information related to your activities within the context of the loyalty program 

g. Your arrival and departure dates 

h. Your preferences and interests (for example, smoking or non-smoking room, preferred floor, type of bedding, type of newspapers/magazines, sports, cultural interests, food and beverages preferences, etc.) 

i. Your questions/comments, during or following a stay in one of our Accor branded establishments 

j. The technical and location data you generate as a result of using our websites and applications. 

As a Data Subject, you are responsible for ensuring that all personal data you provide is accurate, complete, and up to date. 

 

Legal Basis for Processing 

Our lawful basis for collecting and processing your personal data includes your consent, out obligation to comply with legal and regulatory requirements, the necessity to perform our contractual obligations, and our legitimate interests in ensuring the security and integrity of our services. We collect and process data only for declared, specific, and legitimate purposes, and we do not use your data for reasons incompatible with the declared purposes. 

 

Sharing of Personal Data 

The disclosure of your Personal Data will only be performed when it is reasonably necessary, in conditions such as the following:  

a. Disclosure of information to our service providers, agents, or business partners and affiliates that we work with in connection with our business; 

b. In circumstances where we believed that disclosure is required under the law, to cooperate with regulators or law enforcement authorities; or to enforce our agreements, or to protect our rights, property, and safety of Swissotel Clark, our guests, or others. The foregoing includes exchanging information with other organizations for the purposes of fraud protection and credit risk protection. 

c. Swissotel may contract with third parties who do analysis and development on our behalf. We may share your information with such third party who uses the information only to perform services as requested by the company and agrees to maintain the information as strictly confidential. 

d. We may also use your information to send you promotional materials, which you may find of interest, if you agree to receive these types of promotions. 

 

Protecting Your Personal Data  

Swissotel implements appropriate organizational, technical, and physical measures to safeguard your personal data against unauthorized access, disclosure, altercation, or destruction. Once we received your personal data, we take all reasonable steps to ensure that the information we collect, use, or disclose is accurate, up to date, and stored in a secure environment, these steps also include the following: 

a. Access to personal data is limited to authorized personnel who are bound by confidentiality obligations and trained in data protection practices.  

b. We use security technologies such as encryption, secure servers, firewalls, and access controls to protect your data. Sensitive information transmitted through our website is protected using industry-standard Secure-Socket Layer (SSL) 

c. We maintain physical safeguards, including restricted access to facilities and secure storage systems, to prevent unauthorized entry and data breaches. 

We continuously review and enhance our security measures to ensure your personal data remains well protected.  

 

Retention and Disposal of Personal Data 

Any personal data we collect from you is stored in secured facilities and retained in accordance with certain parameters, industry standards, and regulations. The table below sets out the associated retention period for each data processing activity that includes but is not limited to:  

Data Processing Activity	Retention Period
Room reservations and accommodation requests	10 years from the booking date
Hotel stay management	For the duration of your stay
Customer relationship management	3 years after the last interaction (non-members)    6 years after last interaction (loyalty program members)
Service improvement and personalization	3 years after the last interaction (non-members)    6 years after last interaction (loyalty program members)
Third-party data enrichment for customer profiling	3 years after the last interaction (non-members)    6 years after last interaction (loyalty program members)
Customer experience management	3 years after the last interaction (non-members)    6 years after last interaction (loyalty program members)  6 years after file closure
Digital service improvement and maintenance	3 years after the last interaction (non-members)    6 years after last interaction (loyalty program members)  6 years after file closure
Guest incident and risk management	Up to 122 days after recording of an event
Payment fraud risk assessment	90 days in the database to allow for analysis and control  2 years in a separated database for system improvement purposes
Guest security and risk management	122 days from registration
Crisis management and guest tracking	For the duration of the event
Legal and regulatory compliance management	As stipulated in the Philippine legislation

 

Data Privacy for Minors 

Swissotel recognizes that minors merit special protection under the Data Privacy Act of 2012, NPC issuances, and relevant international privacy protection laws, since they may not fully understand the implications of the data processing activities involving their information. Our platform and authorized personnel do not directly collect personal identifiable information from persons under the age of eighteen (18). Personal data pertaining to children are collected or will be provided by the adults accompanying them. This practice is to ensure that we are keeping safe of your children’s data while being able to provide services that are in need of information.  

 

Use of Cookies 

By continuing to browse this site, you are agreeing to the use of cookies, whose purpose it is to provide web analytics and measurements of visitor traffic and browsing behavior, define personalized services and offers tailored to your interests, and share data with, or redirect users from, third-party websites, including social networks. 

To learn more and parameterize the cookies, click here. 

 

Exercise Your Data Privacy Rights  

While we do our best to protect your personal data, you should also keep in mind that you play an important and substantial part in protecting the security and confidentiality of your personal information. You may exercise your data subject rights as you have the right to have reasonable control over the flow of your personal information. Under the Data Privacy Act of 2012, your data subject rights are as follows:  

a. You have the right to be fully informed about how your personal data is collected, used, and processed. Including the specific purposes for which it is intended. We encourage you to review this Privacy Policy thoroughly before giving your consent; 

b. You have the right to object to the processing of your personal data; 

c. You have the right to have reasonable access to your personal data;  

d. You have the right to request rectification or correction of any inaccurate or incomplete personal data that we hold about you;  

e. You have the right to request suspension, withdrawal, blocking, removal, or destruction of your personal data;  

f. You have the right to request a copy of your personal data in structured, commonly used, and machine-readable format including if it has been processed electronically; and  

g. You are entitled to compensation for any harm or damage you may suffer due to inaccuracy, incompleteness, obsolescence, falsity, unlawful acquisition, or unauthorized use of your personal data.  

 

If you would like to know whether we process or hold any Personal Data relating to you, including the purposes for which such data are processed, you may accomplish and submit the Access Request Forms.  

If you wish to request the suspension or cessation of processing, correction, updating, erasure, or deletion of your Personal Data, you may accomplish and submit the Erasure and Correction Request Form.  

For any other inquiries, concerns, complaints, or claims relating to your data privacy rights or the processing of your Personal Data, you may accomplish and submit the Inquiries and Complaints Form.  

Once you have downloaded and completed the form, please submit it to the contact provided below. Please note that the granting of this request is subject to the Swissotel’s internal policies and procedures. The request may be denied if it conflicts with internal processes or falls under any of the allowable grounds for denial as provided under the Data Privacy Act of 2012 and its Implementing Rules and Regulations. If denied, you will be notified in writing with the reason(s).  

 

Amendments to this Privacy Policy 

Swissotel Clark reserves the right to modify this Privacy Policy at any time. Continued use of this website or any Hann Philippines, Inc. services provided herein signifies acceptance of any such modification.  

 

Contact Us  

We take the privacy of your information seriously and it is important that you understand how we manage your personal information. If you have any questions or comments in relation to this Privacy Policy, you may contact us through the details provided below:  

Data Protection Officer  

dpo@hannresorts.com 

M.A. Roxas Highway cor. C.M. Recto, Clark Freeport Zone, Philippines, 2003