Privacy Notice

We at Fitch Hotel take your privacy seriously and are committed to protecting your personal data

This privacy notice (the “Notice”) provides information on our practices regarding collection, use, disclosure and transfer of personal data that (i) you may provide, or (ii) [name of company and company number] and its affiliates may, from time to time (“We” or “Us”) collect, on our premises or via this website (www.fitchhotel.com – the “Website”) and through the use of our online facilities (including our mobile application and our social media pages). Where we refer to the “Website”, we also refer to data collected via these third-party platforms.  

For the purpose of protecting your rights in terms of EU law, specifically in terms of the General Data Protection Regulation (Regulation  (EU)  2016/679 – the “GDPR”) as implemented into Maltese law by means of the Data Protection Act (chapter 586 of the laws of Malta – the “Act”), you must be informed when your personal data is processed by any organization. You also have the right to know the details and purpose of that processing. 

If you have any questions about how we protect your privacy, you can contact us on dataprivacy@hotelfitch.com.

We are the controllers of personal data in terms of the GDPR and the Act and we assure you that we will only use and disclose any personal data collected from you in accordance with the manner set out in this policy.

Information we collect and how we collect it In order to provide you with our services, we will need to collect and process your personal data.  In most instances, this personal data will be requested from you when you are making, for example, an enquiry, a reservation or when you are choosing to sign up to our free e-newsletter or other resources.  

The information which we may collect and process on you may include, but is not limited to, contact information (such as your name, email address and phone number), reservation details (including date of stay and room preferences), payment information (such as card details, in as far as we need it for your reservation), special requests or preference, communication history with us (such as emails and phone calls), CCTV footage in public areas (for security purposes) and information collected via cookies and similar technologies when you use our website or mobile applications (reference is to be made to our Cookie Policy for further information on this). 

Third Parties

In some circumstances we may process information on the basis of personal data that we have received or obtained from a third party (for example, travel agencies). In these circumstances, your personal data may be said to have been passively collected (that is, gathered without you actively providing the information). We use analytical and statistical tools that monitor details of your visits to our website and the resources that you access, including, but not limited to, traffic data, location data, weblogs and other communication data (but this data will not identify you personally). Please refer to our Cookie Policy for more information. 

We may rely on third party service providers to help deliver our goods and services to you, including when you visit our Website or any of our properties. Sometimes we partner with other businesses to provide you with services, products and other offers (for example, we use a third party to handle bookings via our Website or on our premises). We may need to share your personal data with our business partners in order to provide you with those services which you have requested. Your payment information (e.g. credit card details) provided when you make a purchase from our website are not received or stored by us. That information is processed securely and privately by the third-party payment processors that we use. Fitch Hotel will not have access to that information at any time. We may share your personal data with our payment processors, but only for the purpose of completing the relevant payment transaction. Such payment processors are required to maintain the confidentiality and protection of your personal data and payment information.

Use of your information

The information that we collect and store relating to you is primarily used to enable us to provide our services to you, and to meet our contractual commitments to you and to:

• process reservations and manage your stay;
• communicate with you regarding your reservation and requests;
• improve our services, including customer service and website functionality;
• personalize your experience at our hotel;
• ensure the security and safety of our guests and premises; and
• comply with legal and regulatory obligations.

• In addition, we may use the information for the following purposes:
• To notify you about any changes to our website, such as improvements or service/product changes, that may affect our service;

• If you are an existing customer, we may contact you with information about goods and services similar to those that were the subject of a previous sale to you;

• Where you have consented to receive such information, to provide information on other parties’ products or services that we feel may be of interest to you;

• Where you have consented to receive our e-newsletters, from time to time to provide that to you.

Legal Basis

For all of the uses of your personal data (as described above), we ensure that there is a legal basis under applicable data protection laws for us to use such personal data.

We process your personal data based on one or more of the following legal grounds:

1. Performance of a contract with you.
2. Compliance with a legal obligation.
3. Consent where applicable.
4. Our legitimate interests to ensure the safety of our premises.

Disclosure of your information

We may disclose your information to the relevant authorities and industry service providers where necessary in relation to: (i) the provision of our services; (ii) investigations of fraudulent activities and/or to prevent fraud and minimise credit risk; and (iii) to enable us to comply with the law. We may also be required to provide personal data to authorities in order to meet our obligations. We may also disclose your personal data to answer enquiries made in relation to our services which we have provided to you in order to safeguard our legitimate interests.

Where you have consented for us to do so, we may provide your data to selected third parties who may contact you about their goods or services that you may be interested in.

Please be advised that we do not reveal information about identifiable individuals to our advertisers, but we may, on occasion; provide them with aggregate statistical information about our visitors.

Where we store and transfer your data

As part of the services offered to you, for example through our website, the information you provide to us may be transferred to and stored as we use remote website server hosts to provide the website and some aspects of our service – this is generally the nature of data stored in “the Cloud”. It may also be processed by staff operating our servers who work for one of our suppliers, e.g. our website server host.  We use appropriate procedures in order to protect and safeguard the personal data that you send to us.

A transfer of your personal data may happen, for example in cases such as hotel overbooking. If we transfer or store your personal data, we will take steps with the aim of ensuring that your privacy rights continue to be protected, as outlined in this Notice and in accordance with the Act and the GDPR.

We do not use or disclose sensitive personal data, such as race, religion, or political affiliations, without your explicit consent.

We may disclose your personal data outside of our group:

a) in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets; and

(b) if Fitch Hotel’s business is bought by a third party, in which case personal data held by it about its customers will be one of the assets to transfer to the buyer. However, any such transfer will only be on terms that the confidentiality of your personal data is protected and that the terms of this privacy notice will continue to be complied with by the recipient. If this happens, you will be notified of such transfer.

Otherwise, we will process, disclose or share your personal data only if required to do so by law or in good faith and the belief that such action is necessary to comply with legal requirements or legal process served on us or the website.

You have the right to opt out of our processing of your personal data for marketing purposes by contacting us at dataprivacy@hotelfitch.com

Retention Periods

We will retain your information for no longer than is necessary, keeping in mind the purpose for which we first collected the data. As a general rule, we will retain personal data until such time as you ask us to stop communication with you. We may retain some of your information if it is necessary for us in order to meet legal or regulatory requirements, resolve disputes, prevent fraud and abuse or to enforce our terms and conditions. Should you wish to obtain specific information regarding the retention periods of various types of data, please contact our data protection officer on the address detailed  below.

Security

Whilst we have the technical and organisational measures in place to protect your personal data, the transmission of information via the Internet or email is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of data while you are transmitting it to us via our Website; any such transmission is at your own risk. Once we have received your personal data, we will use adequate procedures and security features to try to prevent unauthorised access, disclosure, alteration, or destruction. 

Third party links

You might find links to third party websites on our website. These websites should have their own privacy policies, which you should check. We do not accept any responsibility or liability for their policies whatsoever as we have no control over them.

Use of cookies

Our website uses cookies. We use cookies to gather information about your computer for our services and to provide statistical information regarding the use of our website. Such information will not identify you personally – it is statistical data about our visitors and their use of our website. This statistical data does not identify any personal details whatsoever. We may also gather information about your general Internet use by using a cookie file. Where used, these cookies are downloaded to your computer automatically. This cookie file is stored on the hard drive of your computer, as cookies contain information that is transferred to your computer’s hard drive. They help us to improve our website and the service that we provide to you. All computers have the ability to decline cookies. This can be done by activating the setting on your browser which enables you to decline the cookies. Please note that should you choose to decline cookies, you may be unable to access particular parts of our Website. Where we work with advertisers on our website, our advertisers may also use cookies, over which we have no control. Such cookies (if used) would be downloaded once you click on advertisements on our website.] Please refer to our Cookie Policy for further information. 

Your rights

The Act and GDPR give you certain rights regarding your personal data.  . 

Under applicable law, you have the right to:

• request a copy of the personal data about you that we hold;
• request correction or deletion of personal data about you that is inaccurate;
• withdraw any applicable consent for processing and transfer;
• object to our using your personal information for marketing purposes; and
• object to profiling and automated decision making. 

In some circumstances, you may also have a “data portability” right to require us to transfer your personal data to you or to a new service provider.

We will ask your consent if we intend to use your data for marketing purposes or if we intend to disclose your information to any third party for marketing purposes.

Please write to us or contact us by email (dataprivacy@hotelfitch.com) if you wish to exercise your rights, have a complaint to file, or just have questions. 

Changes to this Notice

We may update these policies to reflect changes to the Website and customer feedback. Please regularly review these policies to be informed of how we are protecting your personal data. We welcome any queries, comments or requests you may have regarding this Notice.

Please do not hesitate to contact us.

Fitch Hotel, 58, Wilga Str, Paceville St Julians Malta or dataprivacy@hotelfitch.com

Version 1.2 revised on 17.10.2023

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