Last updated 10/05/2021

Personal Data Management

"Personal data" refers to information that can personally identify you or allow the identification of a specific individual. Below is an example of personal data collected from the beginning of the reservation and in accordance with the law:

• First and Last Name
• Gender
• Date and Place of Birth
• Phone Number
• Email Address
• Nationality, Residence, Passport, Visas, or other government-issued identification
• Data related to various types of payments we accept
• Credit/Debit Card Number
• Language preferences
• Important information such as birthdays, anniversaries, and "special occasions"
• Data related to discount or loyalty programs
• Employer information
• Suite theme preferences
• Data about previous stays, guest-related events that influenced the stay, goods and services purchased, and requests for special and non-standard services
• Geolocation information
• ID, profile photos, and public information available on your social media accounts or in our databases
• Biometric data, digital images
• Images and videos captured by surveillance cameras in public areas of our facility, such as entrances, exits, driveways, and hallways
• Personal preferences, dietary restrictions, food and beverage preferences, services, and comforts you have requested or we have learned during your visit
• Indirect data: We also collect data present in your browser, data from app usage, data provided by cookies, demographic data, or other data you provide that cannot reveal your identity or the identity of a person. If such data should reveal your identity or refer to a person, we will treat it as personal data. Other data includes:

In case you provide us, or our service providers, with personal data about other individuals (for example, to make a K-gift or a reservation on behalf of another person), you declare that you are authorized to do so and authorize us to use such data in accordance with this Privacy Policy.

Methods of Personal Data Collection

Online Services: We collect your personal data when you purchase goods and/or services from our website and/or our apps using a device or in-room TV, when you contact us and/or send us messages, when you join our waiting list, when you post on social media, when you subscribe to a newsletter, when you participate in surveys, contests, or promotional offers.

Reception and Front Office: When you make a reservation (by phone or in person at the reception), when you use online chat services or contact our customer service, when you contact us via email or fax.

Service Partners: We collect personal data from independent companies collaborating with us. We have entered into contracts to provide you with services, discounts, and goods based on the experiences you have had at our facility and that may be to your liking. Our service partners include car rental providers and booking engine platforms, pay-TV on-demand service providers.

Internet-Connected Devices and Digital Concierge: We collect personal data from devices connected to our internet networks available in our facility areas. For example, by using our Digital Concierge to personalize your stay experience. We also collect indirect data such as data present in your browser, data from app usage, data provided by cookies, demographic data, or other data you provide that cannot reveal your identity or the identity of a person. If such data should reveal your identity or refer to a person, we will treat it as personal data. Other data includes:

Location-Based Services: We collect personal data when you download our application, during login, and/or later when you join one of our services or programs that require enabling geolocation features on your mobile device. Our app or another program will collect location data until you log out or close the app (the app or another program may collect information if running in the background) or until you disable the location feature on your device.

Methods of Collecting Other Data

We collect Other Data in various ways:

Browser or Device: Through your browser or device, we collect certain information to ensure the proper functioning of online services. The data includes your Media Access Control (MAC) address, the type of computer you are using (Windows, Mac, etc.), screen resolution and operating system characteristics, device manufacturer and model, language, type and version of internet browser, and the identity of the online services you are using (e.g., apps).

App Usage: When you download an app or use our web app, we collect data related to the app's usage, the date and time the app accesses our servers from your device. We also collect data and files downloaded on the app based on your device's MAC address.

Cookies: Cookies are small text strings that websites visited by the user send to their terminal (usually the browser), where they are stored and then sent back to the same websites on the user's next visit. This information is used to improve security, provide simpler navigation by displaying information more effectively, and recognize your computer to provide assistance while using online services. Cookies allow us to collect information such as the type of browser used, time spent on online services, pages visited, referral URL, language preferences, and other aggregated traffic data. We also collect statistical data on the use of online services to continuously improve their design and functionality and to understand how they are used and resolve issues.

If you do not want your data to be collected via cookies, find out how to configure them at http://www.allaboutcookies.org/manage-cookies/index.html. You can choose to accept cookies by changing your browser settings. If you decide not to accept cookies, you may experience some inconvenience in using online services, such as having to log in with each visit or not receiving promotions from us that may interest you.

Pixel Tags and Similar Technologies: Data is collected through pixel tags (also called "web beacons" and "clear GIFs") used in connection with various online services for various purposes, including tracking user actions on online services (including email recipients), assessing the success of our marketing campaigns, and compiling usage statistics for online services.

Statistics: We collect information through Google Analytics, which uses cookies and other technologies to collect and analyze data about the use of our website, our app, and our services. These services collect data about the use of other websites, apps, and online resources. To learn more about Google's procedures, visit www.google.com/policies/privacy/partners/. You can disable Google Analytics by downloading the appropriate browser add-on available at https://tools.google.com/dlpage/gaoptout.

IP Address: Represents a numerical label that uniquely identifies a device you are using, automatically assigned by your Internet Service Provider and connected to the network using the Internet Protocol as a network protocol. The IP address is automatically identified and linked in the log files of our firewall and server each time a user accesses online services. The logs also contain information about the time of the visit and the pages visited. We use IP addresses to calculate usage levels, analyze server issues, and manage online services.

Data Association: We may collect, combine, or associate data that is not useful to identify you or specific individuals.

How We Use Data

We may request your data directly for the following purposes, and if not provided or you prohibit access to it, issues may arise in providing the requested services. All personal data and/or other data will be used to develop new offerings, offer new services, protect our company and our guests, including necessary use to increase our company's legitimate economic interests, such as:

• Using data for requested services: Personal data and other data will be used to guide you through reservations, send administrative messages