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Data privacy

CUSTOMER PERSONAL DATA PROTECTION CHARTER

1. THE ACCOR GROUP'S COMMITMENT TO PROTECTING PRIVACY

Because we consider you an important customer, our first priority is to offer you exceptional times and stays throughout the world.

Your complete satisfaction and confidence in Accor S.A. are absolutely essential to us.

That's why, as part of our commitment to meeting your expectations, we have set up a customer privacy protection policy. This Charter formalizes our commitments to you and describes how Accor S.A. uses your personal data.

The main rules applicable within the Accor Group worldwide (Accor S.A. and its subsidiaries) are founded on seven principles.

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2. CONSENT

"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 Charter forms part of the terms and conditions that govern our hotel services. By accepting these terms and conditions, you expressly accept the provisions of this Charter.

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3. ACCOR'S SEVEN PRINCIPLES FOR PROTECTING YOUR PERSONAL DATA

The seven principles below are applicable within the Accor Group throughout the world.

  1. Transparency : When collecting and processing your personal data, we will communicate all information to you and inform you of the purpose and recipients of the data.
  2. Legitimacy : We will collect and process your personal data only for the purposes described in this Charter.
  3. 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.
  4. Storage : We will hold your personal data for the period necessary for processing the same in compliance with the provisions of the law.
  5. 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. The details of the department to contact in this respect are shown below (§13) in the clause « Access and modification »
  6. 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.
  7. Sharing and international transfer : We may share your personal data within the Accor Group or with third parties (such as commercial partners and/or service providers) for the purposes set out in this Charter. We will take appropriate measures to guarantee security when sharing or transferring such data.

For any questions concerning the seven principles of Accor Data Protection, please contact the Data Privacy department whose details appear in the clause « Access and modification ».

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4. SCOPE OF APPLICATION

This Charter applies:

  1. To all data processing implemented in our subsidiary and managed hotels, i.e. those operating under an Accor Group brand name (Sofitel, Pullman, Novotel, Suite Novotel, Mercure, MGallery, ibis, ibis Styles, ibis budget, Hotel F1 etc.) This list is regularly updated.
  2. 2. To all Accor S.A. reservation websites, including www.accorhotels.com but also brand sites (www.sofitel.com, www.mercure.com, etc...).

Although our customer privacy protection policies cannot be imposed on our franchised hotels, Accor S.A. will do its utmost to promote the seven principles set out in this Charter so that our franchises comply with the applicable laws in relation to the processing of your personal data.

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5. WHAT PERSONAL DATA IS COLLECTED?

At various times, we will be obliged to ask you, as an Accor S.A. 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 membership number for the Accor loyalty program or another partner program (for example, the airline loyalty program)
  • 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 establishments.

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 (« Access and modification » clause) 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.

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6. WHEN IS YOUR PERSONAL DATA COLLECTED?

Personal data may be collected on a variety of occasions, including:

  1. Hotel activities:
    • Booking a room
    • Checking-in and paying
    • Eating/drinking at the hotel bar or restaurant during a stay
    • Requests, complaints and/or disputes.
  2. Participation in marketing programs or events:
    • Signing up for loyalty programs
    • 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.
  3. Transmission of information from third parties:
    • Tour operators, travel agencies, GDS reservation systems, and others
  4. Internet activities:
    • Connection to Accor websites (IP address, cookies)
    • Online forms (online reservation, questionnaires, Accor pages on social networks, network login devices such as Facebook login etc.).

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7. FOR WHAT PURPOSES?

We collect your personal data for the purposes of:

  1. Meeting our obligations to our customers.
  2. Managing the reservation of rooms and accommodation requests:
    • Creation and storage of legal documents in compliance with accounting standards.
  3. Managing your stay at the hotel:
    • Monitoring your use of services (telephone, bar, pay TV etc.)
    • Managing access to rooms
    • Internal management of lists of customers having behaved inappropriately during their stay at the hotel (aggressive and anti-social behavior, non-compliance with the hotel contract, non-compliance with safety regulations, theft, damage and vandalism, or payment incidents).
  4. Improving our hotel 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 Accor S.A. or one of its subsidiaries.
  5. Managing our relationship with customers before, during and after your stay:
    • Managing the loyalty program
    • 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 behaviors
    • Developing statistics and commercial scores, and carrying out reporting
    • Providing context data for the offer push tool when a customer visits a Group website or makes a reservation
    • Knowing and managing the preferences of new or repeat customers
    • Sending you newsletters, promotions and tourist, hotel or service offers, or offers from Accor S.A. partners, or contacting you by telephone
    • Managing requests to unsubscribe from newsletters, promotions, tourist offers and satisfaction surveys
    • Taking into account the right to object
    • Using a dedicated telephone service to search for persons staying in Accor Group hotels in the event of serious events affecting the hotel in question (natural disasters, terrorist attacks etc.).
  6. Use a trusted third party to cross-check, analyze 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.
  7. Improving Accor S.A. services, especially:
    • Carrying out surveys and analyses of questionnaires and customer comments
    • Managing claims/complaints
    • Offering you the benefits of our loyalty program.
  8. Securing and enhancing your use of Accor S.A. websites, especially:
    • Improving navigation
    • Implementing security and fraud prevention.
  9. 9. Conforming to local legislation (for example, storing of accounting documents).

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8. CONDITIONS OF THIRD-PARTY ACCESS TO YOUR PERSONAL DATA

As we are present in many countries, we endeavor to provide you with the same services throughout the world. Thus, to guarantee you the right of access and amendment (« Access and modification » clause), we have to share your personal data with internal and external recipients subject to the following conditions:

a. Within the Accor Group, 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 staff
  • Reservation staff using Accor reservation tools
  • IT departments
  • Commercial partners and marketing services
  • Medical services if applicable
  • Legal services if applicable
  • Generally, any appropriate person within Accor Group 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:

  1. External service providers: IT sub-contractors, international call centers, banks, credit card issuers, external lawyers, dispatchers, printers.
  2. Commercial partners: Accor S.A. 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, analyze and apply certain devices to your data. This data processing will allow Accor S.A. and its privileged contractual partners to determine your interests and your customer profile, and will allow us to send you personalized offers.
  3. Social networking sites: In order to allow you to be identified on the website without the need to fill out a registration form, Accor S.A. has put the Facebook login system in place. If you log in using the Facebook login system, you explicitly authorize Accor S.A. to access and store the public data on your Facebook account, as well as the other data mentioned during use of the Facebook login system. Accor S.A. may also communicate your email address to Facebook in order to identify whether you are already a Facebook user, in order to post personalized and relevant ads on your Facebook account if appropriate.

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.

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9. PROTECTION OF YOUR PERSONAL DATA DURING INTERNATIONAL TRANSFERS

For the purposes set out in Clause 7 of this Charter, 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 Charter, Accor S.A. employs appropriate measures to ensure secure transfer of your personal data to an Accor 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.

As part of these activities, your data may be sent, in particular as part of the reservation process, to Accor hotels located outside of the European Union, in particular in the following countries: South Africa, Algeria, Andorra, Saudi Arabia, Argentina, Australia, Bahrain, Benin, Brazil, Cambodia, Cameroon, Canada, Chile, China, Colombia, South Korea, Ivory Coast, Cuba, Egypt, United Arab Emirates, Ecuador, United States of America, Fiji, Ghana, Guatemala, Equatorial Guinea, India, Indonesia, Israel, Japan, Jordan, Kuwait, Laos, Lebanon, Madagascar, Malaysia, Morocco, Mauritius, Mexico, Monaco, Nigeria, New Zealand, Oman, Uzbekistan, Panama, Paraguay, Peru, Philippines, Qatar, Dominican Republic, Russia, Senegal, Singapore, Switzerland, Chad, Thailand, Togo, Tunisia, Turkmenistan, Turkey, Ukraine, Uruguay, Vietnam, Yemen, Taiwan, Hong Kong, Macao, Dubai.

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.

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10. DATA SECURITY

Accor S.A. 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.

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11. COOKIES

When you visit Accor S.A.'s websites or mobile applications, some browsing-related information on your device (computer, Smartphone, tablet etc.) is likely to be recorded in files called "cookies" stored on your device.

a. Why does Accor S.A. use cookies?

Cookies help us to improve the quality of your browsing experience when visiting Accor S.A. websites. This technical process primarily allows us to:

  • Adapt our websites to suit your device's display preferences (language, display resolution, operating system used etc.)
  • Store some of the information that you fill out on our websites to facilitate and personalize your subsequent visits to our websites
  • Enable you to access your personal pages more quickly by storing the login details or information that you have previously entered
  • Collect statistics. These relate mainly to the number of times you visit our websites and your use of the different services that we provide (sections and content visited, links), with the aim of improving their relevance and usability
  • Put security measures in place (for example, asking you to reconnect to a page or service after a certain amount of time has elapsed)
  • Offer you, through advertisements, personalized content that is likely to be of interest to you (better offers, other destinations etc.).

Note: On our sites, we can show adverts for, or suggest links to, third-party sites which may collect your personal data when you click on the links in question. This Charter does not cover visits to third-party sites and Accor S.A. cannot be held responsible for their data protection policy or use of personal details.

b. What are the different types of cookies?

There are several categories of cookies:

  • Strictly necessary cookies: These cookies are essential in order to make it easier to browse our websites and use all of their features (the user's operating system support, display etc.). Without these cookies, features such as the display will not have optimum functionality. Note: These cookies collect purely technical data and do not identify you personally.
  • User-monitoring cookies: These cookies help us improve users' experience by helping us understand how they use our websites (most frequently visited pages, applications used etc.). These cookies do not identify you personally./li>
  • Functionality cookies: In order to make browsing easier, these cookies store certain user preferences (language, username, country etc.).
  • Targeted advertising cookies: These cookies enable users to receive targeted advertisements based on their interests, but they also limit the number of times that the advertisements appear.
  • Affiliate cookies: These cookies enable third parties ("affiliates") that publish marketing campaigns on their websites to be paid on behalf of the « web merchant ».
  • Cookies from social networks: These third-party cookies let you communicate the content of our site to others, as well as your opinion on it. This is the case with the « Share » and « Like » application buttons on social networks such as Facebook, Twitter, LinkedIn, Viadeo etc. Social networks that offer these application buttons can identify you by these buttons, even if you did not click on one of them when you visited our site. Indeed, certain cookies allow the social network concerned to follow your navigation on our site whenever your social network account is activated on your device at the same time that you are on our site. We have no control over the procedures social networks use to collect information about your navigation on our site. Please read these social networks' privacy policies regarding personal data. These should allow you to exercise certain privacy options with these social networks, in particular by adjusting your user accounts for each of these networks.

c. How can you manage your cookies (enable, limit, block)?

The setup of your Internet browser (Internet Explorer™, Firefox™, Safari™, Google Chrome™, Opera™ etc.) is a free and effective means of determining how cookies are managed in advance. You can then decide:

  • To enable the use of all cookies integrated in the pages and content that you consult. Note: On the one hand, these cookies will only be readable by their issuers. On the other hand, this process is not definitive, and it will always be possible for you to disable these cookies afterwards (cookie management will vary depending on your Internet browser; please refer to the relevant instructions)
  • To block the use of cookies on your device. In this case, we would advise you that ease of navigation will be affected. Some functions require the use of cookies (for example, it is possible that your operating system will not be recognized or that the language displayed will not be the one that you would expect). Consequently, we will accept no responsibility for any inconvenience caused by the possible malfunction of our services due to the necessary cookies being unavailable
  • To be asked by your browser to either agree or disagree before the installation of a new cookie on your device
  • To accept or reject the cookies depending on the issuer

The way cookies are managed will depend on your browser. You will find this information in the relevant user guide:
For Internet Explorer™: http://windows.microsoft.com/en-US/windows7/Block-enable-or-allow-cookies
For Chrome™: http://support.google.com/chrome/bin/answer.py?hl=en&hlrm=en&answer=95647
For Safari™: http://support.apple.com/kb/HT1677?viewlocale=en_US
For Firefox™: http://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences
For Opera™ : http://help.opera.com/Windows/10.20/en/cookies.html

Flash© cookies in Adobe Flash Player™

Adobe Flash Player™ is an application that enables the rapid development of dynamic content using Flash programming language. Flash (and applications of the same type) stores the settings, preferences and usage of this content using technology similar to cookies. However, Adobe Flash Player™ manages this information and your preferences through an interface that is different to the one provided by your browser software.

As your device is likely to display content developed using Flash language, we would ask you to access Flash cookie management tools directly from the site http://www.adobe.com/.

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12. STORAGE OF DATA

We retain your personal data only for the period necessary for the purposes set out in this Charter or in accordance with the provisions of applicable law.

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13. ACCESS AND MODIFICATION

You have the right to access your personal data collected by Accor S.A. and to modify it subject to applicable legal provisions.

To this end, you may exercise your rights pertaining to the personal data held at a hotel and should contact the hotel directly.

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 the Accor Group directly by sending an email to data.privacy@accor.com or by writing to the address below:

ACCOR
Département Protection des Données Personnelles
(Data Privacy)

Immeuble Odyssey
110 Avenue de France
75210 Paris Cedex 13, France

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 your request.

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.

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14. UPDATES

We may modify this Charter from time to time. Consequently, we recommend that you consult it regularly, particularly when making a reservation at one of our hotels.

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15. QUESTIONS AND CONTACTS

For any questions concerning the Accor Group's personal data protection policy, please contact the Data Privacy department (« Access and modification » clause).

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