Alexander Hotel – Privacy Policy

Introduction

This Privacy Policy (hereinafter: the “Privacy Policy” or “Policy”) has been adopted by Grand Bay Hotels Ltd. (hereinafter: the “Alexander Hotel”, the “Hotel”, “we” and “our”) and applies to all collection and use of “Personal Information” (as defined below) made by the Hotel when providing the Hotel’s websites at: https://www.alexander.co.il/ (hereinafter the “Website”), and while providing Hotel accommodation services including customer service and other additional services (the Website and the hosting services will be collectively referred to hereinafter as the “Services”).

The purpose of the Privacy Policy is to provide transparency about how Personal Information of users of the Site (hereinafter “Users”) as well as by individuals who are visiting the Hotel and/or using the hospitality services of the Hotel (hereinafter “Guests”) is being handled.

You have no legal obligation to provide us with any information. If you choose to provide us with your Personal Information we need to provide you the Services, you will do so at your own free will. Should you choose not to disclose to us your Personal Information, we may not be able to provide you with the Services, in part or in full. Please read this Privacy Policy carefully to ensure that you agree to its terms. If you do not agree to the terms of the Policy, please refrain from using the Website and/or the Services. For any questions regarding privacy, please contact us at: [email protected]. 

 

1. Definitions 

In this Policy, the following terms will be defined as follows:

1.1 “Personal Information” or “Personal Data” means any information that can be used to identify a person, directly or indirectly, including similar terms  as defined in the Privacy laws applicable to the Hotel.

1.2 “Anonymous Information” means data that does not specifically identify the person and does not relate to a particular person. The Hotel collects Anonymous Information, such as browser and mobile device data,  and aggregated statistical data regarding the use of our Website and/or Services, .

1.3 “Information” means Personal Information and Anonymous Information.

1.4 “Privacy Laws” means the Privacy Protection Law 5741-1981 and the regulations amended thereunder, the guidelines of the Privacy Protection Authority and with respect to individuals from the EU, the General Data Protection Regulation 679/2016 (“GDPR”); each insofar as they apply to the Hotel.

 

2. How we collect Personal Information: 

2.1 The Alexander Hotel collects Personal Information by the following means:

2.1.1 We collect information that is proactively provided to us by the Users of the 

Site as well as information that is automatically collected by us through cookies and tracking tools. For more information on the use of cookies, please see section 11 below.

2.1.2 When Users use the Alexander Hotel’s pages on social media platforms (hereinafter: “Social Media Platforms”). Please note that the use of Social Media Platform is subject to the terms of the privacy policy of each such Social Media Platform, which we are not responsible for. We undertake to use the information collected through Social Media Platform, and which is transmitted from Social Media Platform to our information systems, in accordance with the terms of this Privacy Policy.

2.1.3 When Guests visit or stay at the Alexander Hotel, or through other communication channels with the Alexander Hotel, such as the Alexander Hotel customer service center.

 

3. The Personal Information we collect:

3.1 The Alexander Hotel collects various types of information, including:

3.1.1 Contact and identification details including name, e-mail address, mailing address, telephone number, fax number, passport number, ID number of a Guest and of those accompanying a Guest such as spouse and children.

3.1.2  Billing information including means of payment such as payment card details, billing address and bank account number as well as any additional information as required by PCI DSS and any applicable law.

3.1.3 Demographic information (such as age, gender, residential address, citizenship, and preferred language, as well as birthdays and anniversaries, if provided).

3.1.4 Information included in and/or pertaining to our Guests reservations: dates of stay and/or visit to the Alexander Hotel, goods and services purchased at the Hotel or through the Hotel including various shuttle and tourist services at the Guest’s request, Personal Preferences (as defined below), phone calls made, and information collected using electronic cards. 

3.1.5 Medical information such as a disability or medical condition to the extent that provided or to the extent required by law to be collected such as in reference to COVID-19; and information required to fulfill special requests or accommodation conditions.

3.1.6 Information about our Guests’ and Users’ as interests, activities, hobbies, food and beverage selection, services used by our  Guests and any special requests made to us, or preferences learned about the Guests during their visit to the Alexander Hotel (“Personal Preferences”).

3.1.7 Information related to Alexander Hotel club membership.

3.1.8 Information based on geographical location, as well as Anonymous Information as set forth below.

3.1.9 Photos, video and audio collected by security cameras located in public areas of the Alexander Hotel, such as the corridors and lobby of the Alexander Hotel (CCTV systems).

3.2 Combination of Personal Information with Anonymous Information: To the extent that we combine Personal Information with Anonymous Information, we will treat the combined information as Personal Information, as long as the information is combined.

3.3 Providing information about third parties: should you provide the Hotel and/or the Hotel’s service providers Personal Information about third parties (for example – in case you use the Website or call the Hotel to make a reservation for another person), you declare that that person’s consent has been obtained to contact on their behalf and to provide the said information, and that person allows the Alexander Hotel to make use of the Personal Information in accordance with the provisions of this Privacy Policy.

 

4. The purposes for which the information is collected, and the uses made of Personal Information

The Alexander Hotel collects and processes the Personal Information for the following purposes, and makes the following uses of it, before, during and after the Guests’ visit to the Hotel:

4.1 Communication with those showing interest in Hotel Services – to give you information about the Hotel’s Services as you contact us for this purpose, through the Website or customer service center.

4.2 Making orders and purchasing Services and products – We will collect Personal Information including contact and identification information, demographic information, financial information and Personal Preferences for the purpose of completing a booking on the Website, for completing the Hotel reception process (check-in), and for providing other products and Services including orders from third party services such as transportation and tourism, at the request of the Guest.

4.3 Keeping contact with Guests – sending marketing messaging and promotional material regarding the Alexander Hotel, products and Services, including spa services, gym, bars, restaurants and more; to enable us to hold “returning customer” events which the Alexander Hotel may conduct from time to time, including with our business partners.

4.4 Responses to inquiries – Alexander Hotel processes Information in connection with inquiries from service users, such as contact and identification information, booking details, and all information included in the inquiry, including information about Personal Preferences; For the purpose of communicating with Hotel Guests and answering questions and requests by Users and Guests.

4.5 Improving Services and products, marketing and promotion – developing new products, improving the Website and the Hotel’s Services, analyzing Personal Information as well as Anonymous Information to identify use trends of the Website and Services.. In addition, assessing effectiveness of promotional marketing strategies, performance evaluations of third parties (such as travel agents and other business partners), occupation prediction and meeting commitments.

4.6 Administrative and other communications – sending information to Hotel clients regarding changes in the Website’s terms of use, Privacy Policy or other administrative information, for example: information about reservations made, order confirmation and more. 

4.7 Safety and Security – Maintaining the health and safety of Hotel staff, Guests, and other visitors, during their stay at the Alexander Hotel.

4.8 Obligations by virtue of law – to comply with the provisions of the law, including rules, regulations, guidelines and legal proceedings as well as to comply with the instructions or requests of competent authorities or courts.

4.9 Use of information to perform statistical calculations – The Alexander Hotel uses Anonymous Information to perform certain statistical calculations, provided that these do not include identifying information.

 

5. Disclosure and transfer of Personal Information

The Alexander Hotel may disclose and transfer Personal Information as follows:

5.1 The representative who provided the Alexander Hotel with Personal Information about Guests, such as a travel agency representative or agent, employer or spouse.

5.2 To service providers to the Alexander Hotel, such as IT, legal advisors, accountants, payment service providers and more.

5.3 To business partners of the Alexander Hotel in the field of marketing and advertising subject to the provisions of any law and customer consent as required, in order to publish relevant advertisements to website Users, and to encourage Users to visit the Website and Hotel again in the future. 

5.4 The Alexander Hotel may transfer Personal Information to third parties to the maximum extent permitted by any law including privacy protection laws, in the event of a merger, sale of property or shares, joint venture, assignment of rights and/or obligations, transfers or other changes in the Alexander Hotel business, or in contemplation of any of the above as well as in the event of liquidation, receivership and other similar proceedings.

5.5 The Alexander Hotel may disclose Personal Information if it is deemed necessary to:

5.5.1 Comply with the provisions of the law.

5.5.2 To comply with court decisions in legal proceedings.

5.5.3 For the purpose of responding to requests and inquiries from public or governmental authorities.

5.5.4 For the enforcement of the terms of use.

5.5.5 For the protection of the business interests of the Alexander Hotel.

5.5.6 For the protection of the rights, privacy, safety or property of the Alexander Hotel, its Guests, the users of the Services and of other parties.

5.5.7 In order to enable the Alexander Hotel to establish or defend itself from any claims and seek any remedy to which the Hotel is entitled by law and/or agreement, as well as to reduce damages.

 

6. Transfer of information outside of the State of Israel

6.1 In general, the information will be processed within the borders of the State of Israel. Information processing which is performed by third parties or cloud services may and will be performed on servers around the world, such as the servers of Google and companies that provide us with dedicated tourism software required to provide the Services.

6.2 However, some of the information may be stored in a cloud outside the borders of the State of Israel or the European Union. In such cases, the Alexander Hotel will act to ensure that appropriate measures have been taken to secure the Personal Information at an adequate level of protection in accordance with the provisions of the Privacy Protection Law applicable to the Hotel. If you are an Israeli data subject, by continuing to browse the Website and using Services, you agree to the transfer of information to the servers of third-party providers of the Hotel outside the borders of the State of Israel.

 

7. Your rights with respect to your Personal Information

Website Users, Hotel Guests and visitors are entitled to exercise their legal rights pertaining to Personal Information collected and processed by us, as detailed below.

7.1 Israeli Data Subject’s Rights

7.1.1 The right to request to review the information

7.1.2 The right to request that the information be corrected in order to ensure that it is complete, correct and up to date.

7.1.3 The right to request to be deleted from the Hotel Database (as defined in the PPL).

7.2 EU Data Subject’s Rights

If you are protected by the GDPR, and we are a/the “Controller” of your Personal Information, (as defined in the General Data Protection Regulation 679/2016, the “GDPR”), you have the following Rights (which may be subject to certain exemptions or derogations):

7.2.1 Accessing and rectifying your Personal Information. You are entitled to access your Personal Information and to rectify it, if you find it is incomplete, incorrect or outdated.

7.2.2 Right of erasure, restriction and objection to processing. You are entitled to request the erasure or the restriction of processing of your Personal Information or to object to such processing.

7.2.3 Personal Information Portability. To the extent applicable to you and to the Services, you may request us to transmit your Personal Information to another party.

7.2.4 The rights to withdraw consent, if this was the basis for collection of your Personal Information.

7.2.5 Right to lodge a complaint. You may submit a complaint to the relevant Supervisory Authority in your jurisdiction.

7.3 We respect the rights above and strive to enable those who approach us to exercise them. At any time, you may contact us to request a copy of the information, correction or deletion of the information from the Database at the following email address: [email protected]. We will examine your request and respond in accordance with the provisions of the applicable laws, including Privacy Laws. 

7.4 Should you contact us, we will need to ask you for certain means of identification in order to verify your identity and to protect your information from unauthorized and illegal inquiries. Should you not provide us with suitable means of identification, we may not be able to provide you with your request. In the event that we would have to reject your request, we will provide you with the reason for the rejection as required by applicable laws.

7.5 Handling of inquiries regarding Personal Information will usually be free of charge. In some cases, we may be required to charge a fee. We will also be entitled to determine that the information will be reviewed at the Hotel, in accordance with the Hotel’s information security guidelines and the provisions of the law.

 

8. Legal Basis

8.1 If you are protected by the GDPR, and we are a/the “Controller” of your Personal Information, (as defined in the General Data Protection Regulation 679/2016, the “GDPR”) please note that we will process your information under the following legal bases:

8.1.1 Entry into a contract with the data subject. For example: booking information relating to reservations made to the Services;

8.1.2 Legitimate interest: for example – recording sales calls and the use of security cameras on our premises;

8.1.3 Legal obligation: for example: the collection of health information related to COVID-19 and the collection of passports at the check-in process which is subject to regulations applicable to the hospitality industry;

8.1.4 Vital interest: if during your stay, you are unwell and incapable of making decisions regarding your condition we may process your Personal Information to protect your vital interests.

 

9. Information security

9.1 The Alexander Hotel takes reasonable and industry accepted organizational and technical measures to protect Personal Information from unauthorized or illegal access, use, loss or damage. The Alexander Hotel reviews and monitors activity with the appropriate frequency of such means of protection and security. 

9.2 When the Alexander Hotel is required to disclose or transfer Personal Information to third parties requesting access, the Alexander Hotel ensures that those third parties commit to an adequate and appropriate level of information protection.

9.3 If you have reason to believe that communication with the Alexander Hotel is not secure (for example – if you believe that your personal account has been compromised), please contact [email protected] immediately.

 

10. Information retention period

10.1 Subject to the provisions of applicable laws, the Alexander Hotel will retain Personal Information for the period required to provide the Services.

10.2 For as long as the Hotel has a legal obligation to retain the information, the Hotel will retain the information in accordance with the provisions of any applicable law including the Privacy Laws.

10.3 Upon completion of the Services, the Hotel will retain the Information for a reasonable period of time, as long as the Hotel is legally entitled to do so for legitimate purposes including but not limited to legitimate business and administrative purposes, managing records and documenting business and accounting operations, and defending against legal proceedings.

 

11. Use of Services by minors

The Alexander Hotel collects Personal Information from Guests under the age of 18 as part of the guest registration process and within the provision of the Services, where they relate to children, however this is subject to the consent of the parent or custodian of the minor. The Alexander Hotel does not knowingly collect Personal Information from a person under the age of 18 for any other purpose.

 

12. Cookies and analytics tools 

12.1 The Website uses Cookies for the daily operation of the Website and to gather statistics about the use of the Website, verification of details, tailoring the Website to your Personal Preferences and information security requirements. cookies are text files that your browser creates by command from the company’s computers. Some cookies will expire when you close the browser and others are stored on your device’s hard drive.

12.2 If you do not wish to receive cookies, you can avoid this by changing the settings in your browser. To do so, please use the browser help file, or this link: https://www.allaboutcookies.org/ . However, please be advised that disabling cookies may impair your ability to use some of the features of this website as well as your user experience. In addition, you can delete cookies on your computer at any time. We suggest that you do so only if you are convinced that you do not want the Website to be tailored to your preferences. We will make it clear that the Website can also be used as long as you choose to disable the cookies, with the necessary adaptations.

12.3 “Google Analytics” Cookies are used to collect information about how Users use the Website. The Alexander Hotel uses the information to create reports and to further improve the site. These Cookies gather information anonymously, for example determining the number of visitors, where Users came to the site from, and which buttons they clicked. “Google Analytics Cookies” include the Google AdWords & DoubleClick cookies for marketing, advertising and remarketing. These enable the Alexander Hotel’s advertising partners to identify visitors and contact them with ads and information based on interest. For more information click here. 

12.4 Facebook cookies – The use of these cookies is for advertising based on the user’s interest, meaning, ads that the user may be interested in, based on their activity on sites that are not Facebook. These cookies collect information from Website visits and enable the promotion of ads through the “Facebook” platform. For more information click here. 

12.5 Trivago cookies are used for interest-based advertising tailored to the user. These cookies collect information from site visits. For information click here.

 

13. Use of Anonymous Information. The Company may use Anonymous Information or disclose it to third parties at its sole discretion, inter alia, in order to improve the Website and the Services as well as to perform statistical analyzes of the Website and Services.

 

14. Updates

The Alexander Hotel may change and update its Privacy Policy from time to time. In the event of a substantial change in the Hotel’s practice of information management, the Hotel will give notice of this on the Website and/or in the regular communication channels with Website Users and Hotel Guests. The said change will take effect 7 days from the date of publication of the updated Policy on the Website. Insignificant changes will take effect immediately without notice. We encourage you to refer to the Privacy Policy from time to time for updates. Responsibility for knowing the changes to the Privacy Policy, if any, lies solely with the Users.

 

15. Applicable law and Jurisdiction

This policy is subject to the laws of The State of Israel. The competent courts of Tel Aviv-Yafo will have exclusive jurisdiction to hear any matter arising from this Privacy Policy.

 

16. Contact

For any questions regarding this Privacy Policy, or privacy protection management by the Alexander Hotel, please contact us at: hotel@ alexander.co.il

 

 

Last update: 1.3.2021

Effective as of: 1.3.2021

© All rights reserved – Alexander Hotel