1. Privacy Notice
In adigital world were data flows at the speed of light and data storage andprocess made simpler and faster, protect the privacy of individuals isessential for the future of any businesses and to advance to a true digitaleconomy. This Privacy Notice demonstrates our full commitment to the right ofindividuals to privacy and data protection and summarizes how we treatinformation that may be used to directly or indirectly identify an individual("Personal Data").
1.1 The Muthu Hotels MGM commitment to protecting privacy
Because we consider you an important customer, our first priority is to offeryou exceptional times and stays throughout our properties. Your completesatisfaction and confidence in Muthu Hotels MGM are absolutely essential to us.As part of our commitment to meeting your expectations, we have set up acustomer privacy protection policy.
ThisNotice formalizes our commitments to you and describes how Muthu Hotels MGMuses your personal data within the data privacy principles.
"Personal data" means any information collected and logged in aformat that allows you to be identified personally, either directly (e.g. name)or indirectly (e.g. e-mail) as a natural person. Before providing us with thisinformation, we recommend that you read this document describing our customerprivacy protection policy.
Although,when necessary we’ll ask for your consent, this Privacy Notice forms part ofthe terms and conditions that govern our hospitality services. By acceptingthese terms and conditions, you expressly accept the provisions of this Notice.
1.3 Muthu Hotels MGM data privacy principles
The principles below are applicable within the Muthu Hotels MGM.
1.3.a Transparency: When collecting and processing yourpersonal data, we will communicate all information to you and inform you of thepurpose and recipients of the data.
1.3.b Legitimacy: We will collect and process yourpersonal data only for the purposes described in this Notice.
1.3.c Proportionality and accuracy: We will only collectpersonal data that is necessary within the data processing purpose. We willtake all reasonable steps to ensure that the personal data we hold is accurateand up to date.
1.3.d Retention limitation: We will hold your personaldata only for the period necessary for processing the same in compliance withthe provisions of the law.
1.3.e Access, rectification, opposition: You may access,modify, correct or delete your personal data. You may also oppose the use ofyour personal data, particularly to avoid receiving sales and marketinginformation. The details of the department to contact in this respect are shownbelow (§13) in the clause "Access and modification".
1.3.f Confidentiality and security: We willensure reasonable technical and organizational measures are in place to protectyour personal data against alteration or accidental or unlawful loss, orunauthorized use, disclosure or access.
1.3.g Sharing and international transfer: We may shareyour personal data within the Muthu Hotels MGM or with third parties (such ascommercial partners and/or service providers) for the purposes set out in thisNotice. We will take appropriate measures to guarantee security when sharing ortransferring such data.
1.3.h No data sell: Muthu Hotels MGM will not sell yourpersonal data.
For anyquestions concerning Muthu Hotels MGM Data Protection, please contact the ourData Privacy department whose details appear in the clause "Access andmodification".
1.4 Scope of application
This Privacy Notice applies to:
1.4.a All data processing implemented in our subsidiary andmanaged hotels, i.e. those operating under an Muthu Hotels MGM brand namelisted here. Thislist is regularly updated.
1.4.b All Muthu Hotels MGM reservation websites, includingwww.muthuhotels.com but also brand sites (www.mgmhotelresort.com,www.leisuredimensions.com, www.muthuhighlandheritage.co.uk)
Althoughour customer privacy protection policies cannot be imposed on our franchisedhotels, Muthu Hotels MGM will do its utmost to promote the privacy principlesset out in this Notice so that our franchises comply with the applicable lawsin relation to the processing of your personal data.
1.5 What personal data do we collect
At various times, we will be obliged to ask you, as an Muthu Hotels MGMcustomer, for information about you and/or members of your family, such as:
1.5.a Contact details (for example, lastname, first name, telephone number, email).
1.5.b Personal information(for example, date of birth, nationality).
1.5.c Information relating to your children(for example, first name, date of birth, age).
1.5.d Your credit card number (fortransaction and reservation purposes).
1.5.e Your membership number for the MuthuHotels MGM loyalty program (Vacation Club, Infiniti, Atlas, Muthu HighlandHeritage Coach Tours) or another partner program (RCI, the airline loyaltyprogram)
1.5.f Your arrival anddeparture dates.
1.5.g Your preferences and interests (for example,smoking or non-smoking room, preferred floor, type of bedding, type ofnewspapers/magazines, sports, cultural interests).
1.5.h Your questions/comments, during or followinga stay in one of our establishments.
Pleasenote that information collected in relation to persons under 13 years of age islimited to their name, nationality and date of birth, which can only besupplied to us by an adult, so it is important that you could ensure that yourchildren do not send us any personal data without your consent (particularlyvia the Internet). If such data is sent, you can contact the Data Privacy department,details appear in the clause "Access and modification", to arrangefor this information to be deleted.
We do notdeliberately collect sensitive information, such as information concerningrace, ethnicity, political opinions, religious and philosophical beliefs, unionmembership, or details of health or sexual orientation.
Moreover,depending on applicable local laws, other information could be consideredsensitive, such as your credit card number, your leisure activities, personalactivities and hobbies, and whether or not you are a smoker. We may be obligedto collect such information in order to meet your requirements or provide youwith an appropriate service, such as a specific diet.
In thiscase, depending on the laws in force in certain countries, your prior consentmay be required with regard to the collection of sensitive information.
1.6 When is your personal datacollected?
Personal data collection can occur on a variety of occasions, including:
1.6.A 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
1.6.B Participation in marketing programs or events
- Signing up for loyalty programs
- Participation in customer surveys (for example, the Guest Satisfaction Survey)
- Subscription to newsletters, in order to receive offers and promotions via email
1.6.C Transmission of information from third parties
- Tour operators, travel agencies, GDS reservation systems, and others
1.6.D Internet activities
- Connection to Muthu Hotels MGM websites (IP address, cookies)
- Online forms (online reservation, questionnaires, Muthu Hotels MGM pages on social networks, network login devices such as Facebook login, etc.)
1.7 Purpose of personal data collection
We collect your personal data for the purposes of:
1.7.A Legal obligations
- Some countries require by law the collection of personal data and send it to the authorities (i.e. passport our identification details)
- Storing accounting documents
1.7.B Meeting our obligations to our customers
1.7.C Managing the reservation of rooms and accommodationrequests:
- Creation and storage of legal documents in compliance with accounting standards
1.7.D Managing your stay at the hotel:
- 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)
1.7.E Improving our hotel service, especially:
- Processing your personal data in our customer marketing program (eShots, Newsletters) 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 Muthu Hotels MGM or one of its subsidiaries
1.7.F Managing our relationship with customers before, during andafter 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 Muthu Hotels MGM 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 Muthu Hotels MGM partners or contacting you by telephone.
- Managing requests to unsubscribe from newsletters, promotions, tourist offers and satisfaction surveys or taking into account the right to object
- Using a dedicated telephone service to search for persons staying in Muthu Hotels MGM hotels in the event of serious events affecting the hotel in question (natural disasters, terrorist attacks etc.).
1.7.G Use a trusted third party to cross-check, analyze and applycertain devices to your collected data at the time of booking or at the time ofyour stay, in order to determine your interests and your customer profile, andto allow us to send you personalized offers.
1.7.H Improving Muthu Hotels MGM services, especially:
- Carrying out surveys and analyses of questionnaires and customer comments and managing claims or complaints.
- Offering you the benefits of our loyalty program.
1.7.I Securing and enhancing your use of Muthu Hotels MGMwebsites, especially:
- Improving navigation and user interaction experience.
- Implementing security and fraud prevention.
1.8 Conditions of third-party access to your personal data
MuthuHotels MGM makes an effort to provide you with the same services throughout theworld. Thus, to guarantee you the right of access and amendment ("Accessand modification" clause), we have to share your personal data withinternal and external recipients subject to the following conditions:
1.8.A Within the Muthu Hotels MGM, in order to offer you thebest service, we can share your personal data and give access to authorizedpersonnel from the Group, including:
- Hotel staff, reservation staff using Muthu Hotels MGM reservation tools, IT departments.
- Commercial partners ( examples: RCI Europe Limited HUTCHINSONS & Associates Trustees Ltd. HMC Funding – Business Brookers Limited Honeycomb Finance Ltd; MONDI-HOLIDAY GmbH & Co. KG GeoHoliday, PRAXIS, Visacar, Best4U, Official Taxi Tenerife, Taxis Almeria) and marketing services.
- Medical services and or legal services if applicable.
- Generally, any appropriate person within Muthu Hotels MGM entities for certain specific categories of personal data.
1.8.B With service providers and partners: your personaldata may be sent to a third party for the purposes of supplying you withservices and improving your stay, for example:
- External service providers: IT sub-contractors, international call centers, banks, credit card issuers, external lawyers, dispatchers, printers.
- Commercial partners: Muthu Hotels MGM 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 Muthu Hotels MGM and its privileged contractual partners to determine your interests and your customer profile and will allow us to send you personalized offers.
- Social networking sites: In order to allow you to be identified on the website without the need to fill out a registration form, Muthu Hotels MGM has put the Facebook login system in place. If you log in using the Facebook login system, you explicitly authorize Muthu Hotels MGM 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. Muthu Hotels MGM 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.
- 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.
1.9 Protection of your personal data during internationaltransfers
For the purposes set out in this Notice, we may transfer your personal data tointernal or external recipients who may be in countries offering differentlevels of personal data protection.
Consequently,in addition to implementation of this Notice Muthu Hotels MGM employsappropriate measures to ensure secure transfer of your personal data to anMuthu Hotels MGM entity or to an external recipient located in a countryoffering a different level of privacy from that proposed in the country wherethe personal data is collected.
As partof these activities, your data may be sent, in particular as part of thereservation process, to Muthu Hotels MGM hotels located outside of the EuropeanUnion, in particular in the following countries: India, Singapore.
Otherthan those that are required to carry out your reservation, dataflows tocountries having different levels of personal data protection are regulated bystandard contractual manager-to-subcontractor clauses defined by the EuropeanCommission. Dataflows to the United States are made to entities that belong toSafe Harbor.
1.10 Data security
Muthu Hotels MGM takes appropriate technical and organizational measures, inaccordance with applicable legal provisions, to protect your personal dataagainst illicit or accidental destruction, accidental alteration or loss, andunauthorized access or disclosure. To this end, we have taken technicalmeasures (such as firewalls) and organizational measures (such as a userID/password system, means of physical protection etc.), also when you submitcredit card data when making a reservation, SSL (Secure Socket Layer)encryption technology is used to guarantee a secure transaction.
1.11 Storage of data
We retainyour personal data only for the period necessary for the purposes set out inthis Notice or in accordance with the provisions of applicable law.
1.12 Access and modification
You have the right to access your personal data collected by Muthu Hotels MGMand to modify it subject to applicable legal provisions. You may also exerciseyour right to object by writing to the address below.
In theevent of difficulty exercising your rights, please contact the Data Privacydepartment for the Muthu Hotels MGM directly by sending an email firstname.lastname@example.org or by writing to the address below:
Muthu Clumber Park
Verinica Ventures Limited
Blyth Road, Clumber Park, Nottinghamshire, S80 3PA
Vat Number: 258 7563 58
For thepurposes of confidentiality and personal data protection, we will need toidentify you in order to respond to your request. You will be asked to providesome personal data, along with your request.
If yourpersonal data is inaccurate, incomplete or not up to date, please send theappropriate amendments to the Data Privacy department as indicated above.
Allrequests will receive a response as swiftly as possible and in accordance withapplicable law.
You mayalso exercise your rights in respect of your personal data that is stored andprocessed by a hotel following a stay. To do this, you must contact the hoteldirectly.
We may modify this Notice from time to time, we recommend that you consult itregularly, particularly when making a reservation at one of our hotels.
1.14 Questions and contacts
For any questions concerning the Muthu Hotels MGM personal data protectionpolicy, please contact the Data Privacy department stated on the "Accessand modification" clause.
*Definition of Vacation Club includes Club Infiniti, Club Infiniti Fractional,Club Atlas, Club Navigator, Club Genesis, Club Infiniti Investigate, ClubInfiniti Investigate-Exit, Infiniti Experiences, Infiniti Impressions, MGMHoliday Club and Smart Vacations.
The “Vacation Club” is part of the Group of Companies of the MuthuHotels MGM Group.
A. Why do we have a cookies policy?
With aview to provide information and ensure transparency, Muthu Hotels MGMestablished this policy so that you can learn more about:
·The origin and purpose of the information processed when you browse MuthuHotels MGM Websites
·Your rights with regard to cookies and other tracers used by Muthu Hotels MGM
B. What is a cookie?
Cookiesand other similar tracers are packets of data used by servers to send statusinformation to a user's browser and return status information to the originalserver through this same browser.
Thestatus information can be a session identifier, a language, an expiration date,a response field or other types of information.
Duringtheir validity period, cookies are used to store status information when abrowser accesses various pages of a website or when the browser returns to thiswebsite at a later point.
There aredifferent types of cookies:
·Session cookies, which are deleted as soon as you exit the browser or leave thewebsite.
·Persistent cookies, which remain on your device until their expiration or untilyou delete them using the features of your browser.
We usecookies and other tracers primarily for the following purposes:
Cookiesstrictly necessary for browsing the Muthu Hotels MGM Websites and the abilityto use all of their features, and intended in particular to:
·Manage authentication of website visitors and the associated security measures,and ensure proper functioning of the authentication module.
·Optimize the user experience and facilitate browsing, in particular determining"technical routes" for browsing
·Store information regarding the "cookies" information banner seen bywebsite visitors who then continue to browse the website after agreeing toaccept cookies on their device
·Implement security measures (for example, when you are asked to log in againafter a certain period of time, or to ensure basic operation of Muthu HotelsMGM Websites and use of their major technical features, such as monitoring ofperformance and browsing errors, management of user sessions, etc.)
Cookiesfor features intended in particular to:
·Adapt Muthu Hotels MGM Websites to the display preferences of your device(language, currency, display resolution, operating system used, configurationand settings of the display of web pages based on the device you are using andits location, etc.).
·Store specific information that you enter on Muthu Hotels MGM Websites in orderto facilitate and customize your subsequent visits (including displaying thevisitor's first and last names if the visitor has a user account).
·Allow you to access your personal pages more quickly by storing the logindetails or information that you previously entered
Cookiesfor visitor tracking are aimed at improving the comfort of users by helping usunderstand your interactions with Muthu Hotels MGM Websites (most visitedpages, applications used, etc.); these cookies may collect statistics or testdifferent ways of displaying information in order to improve the relevance andusability of our services.
Advertisingcookies are intended to (i) offer you, in advertising spaces, relevant,targeted content that may be of interest to you (best offers, otherdestinations, etc.) based on your interests, browsing behavior, preferences,and other factors, and (ii) reduce the number of times that the advertisementsappear.
Affiliatecookies identify the third-party website that redirected a visitor to MuthuHotels MGM Websites.
Socialnetwork cookies, set by third parties, allow you to share your opinion aboutand content from Muthu Hotels MGM Websites on social networks (for example, the"Share" or "Like" application buttons for social networks).
Thesocial network applications on Muthu Hotels MGM Websites as mentioned above canin some cases allow the social networks concerned to identify you even if youdid not click on the application button. This type of button can allow a socialnetwork to track your browsing on Muthu Hotels MGM Websites, simply becauseyour account in the social network concerned is enabled on your device (opensession) while you are browsing.
Werecommend that you read the policies of these social networks to familiarizeyourself with how they use the browsing information they may collect,especially with regard to advertising. These policies must specifically allowyou to make choices on these social networks, particularly by configuring youruser accounts for each of them.
D. Cookie Consent
Theinstallation of certain cookies is subject to your consent. Also, when youfirst visit the Muthu Hotels MGM Websites, you are asked whether you agree tothe installation of this type of cookie, which is only activated after youracceptance.
Thisprocess is supported by means of an information banner on the home page of theMuthu Hotels MGM Websites, which informs you that by continuing to browse, youare agreeing to the installation of cookies that require consent on yourdevice.
You canchange your mind at any time using the various methods described in section"Deleting and/or blocking cookies".
E. Deleting and/or blocking cookies
You haveseveral options for deleting cookies and other tracers.
E.1 Browser settings
Althoughmost browsers are set by default to accept cookies, you can, if you desire,choose to accept all cookies, always block cookies, or choose which cookies toaccept based on their senders.
You canalso set your browser to accept or block cookies on a case-by-case basis beforethey are installed. Your browser also allows you to regularly delete cookiesfrom your device. Remember to configure all the browsers in your differentdevices (tablets, smartphones, computers, etc.).
Regardingmanagement of cookies and your preferences, configuration varies for eachbrowser. This is described in the Help menu of your browser, as well as how toedit your preferences with regard to cookies. For example:
·For Internet Explorer: http://windows.microsoft.com/en-US/windows-vista/Block-or-allow-cookies
·For Safari: http://www.apple.com/legal/privacy/en-ww/cookies
·For Opera: http://help.opera.com/Windows/10.20/en/cookies.html
·For Google Chrome:http://support.google.com/chrome/bin/answer.py?hl=en&hlrm=en&answer=95647
Saving acookie to your device depends on your wishes, which you can exercise and changeat any time and free of charge using the settings offered by your browsersoftware. If your browser is set to accept cookies on your device, the cookiesembedded in the pages and content that you view may be temporarily stored in adedicated space on your device. They can only be read by their issuer. However,you can set your browser to block cookies. Keep in mind that if you set yourbrowser to block cookies, some features, pages and spaces on MGM Muthu HotelsWebsites will not be accessible, and we cannot be held responsible in thiscase.
E.2 Specialized advertising platforms
Severalprofessional advertising platforms also give you the option to accept or blockcookies used by companies that are members. These centralized mechanisms do notblock the display of ads; they simply prevent the installation of cookies thattailor ads to your interests.
Forexample, you can visit the website http://www.youronlinechoices.com to prohibitthe installation of these cookies on your device. This website is offered bydigital advertising professionals brought together within the European DigitalAdvertising Alliance (EDAA) and managed in France by Interactive AdvertisingBureau France.