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Hôtel Bristol Geneva Data Privacy Statement

SEGH S.A. manages the Hotel Bristol Geneva and is the operator of the website www.bristol.ch, and thus responsible for the collection, processing and use of your personal data and compliance of data processing with the applicable data privacy legislation.

Your trust is very important to us, which is why we take data privacy very seriously and ensure appropriate security. We comply with the legal provisions of the Federal Data Protection Act (DPA), the Ordinance on the Federal Data Protection Act (FDPA), the Federal Telecommunications Act (TCA) and all other data privacy provisions of Swiss or EU law that may be applicable, in particular the General Data Protection Regulation (GDPR).

In order that you know what personal data we collect about you and the purposes we use it for, please read the information below carefully.

A. Data processing in connection with our website

1. Visiting our website

When you visit our website, our server temporarily records each access in a log file. The following technical data is then recorded, as with any connection to a web server, without any intervention on your part and stored by us until it is automatically deleted after 26 months at the latest:

  • The IP address of the device accessing the website.
  • The name of the owner of the IP address (usually your Internet Service Provider).
  • The date and time of access.
  • The website from which you linked to our website (original URL) and any search terms used.
  • The name and URL of the file accessed.
  • The status code (e.g. error message).
  • The operating system of your device.
  • The browser you are using (name, version and language).
  • The communication protocol used (e.g. HTTP/1.1).
  • Possibly your login or authentication username.

These data are collected and processed for purposes of connecting to and using our website, ensuring the long-term security and stability of the system, and enhancing our online products and services, as well as compiling internal statistics. This data processing is based on our legitimate interests in accordance with Article 6(1)(f) of the GDPR.

Moreover, IP addresses are analysed together with other data in order to recognise and defend against network attacks or other unauthorised or abusive use of the website; they may be used in legal proceedings to identify perpetrators and in lawsuits brought against perpetrators. This data processing is based on our legitimate interest in accordance with Article 6(1)(f) of the GDPR.

2. Filling in our contact form

You may contact us by means of a contact form. For this we require the following information:

  • Your first and last name.
  • Your email address.
  • Your message.

We only use these data, together with your telephone number (optional), so that we can respond to your contact request in the best possible way and in a personal manner. The processing of these data is therefore necessary for the execution of precontractual measures in accordance with Article 6(1)(b) of the GDPR or is based on our legitimate interest in accordance with Article 6(1)(f) of the GDPR.

3. Subscribing to our newsletter

You have the option of subscribing to our newsletter on our website or when you arrive by giving us your consent. To do so, you must register and provide the following data:

  • Your first and last name.
  • Your email address.

These data are essential for data processing. We process these data solely to personalise the information and offers we send you and to tailor them to your needs.

By registering, you consent to the processing of the data you have provided in this context, for the purpose of sending the newsletter to the address you have provided on a regular basis, as well as for the statistical analysis of your user behaviour and optimisation of the newsletter. Under Article 6(1)(a) of the GDPR your consent is the legal basis for processing your email address. We are entitled to use third parties for the technical implementation of advertising campaigns and are entitled to pass on your data for this purpose (see subheading 13).

At the end of each newsletter, you will find a link to unsubscribe at any time. If you wish to unsubscribe, you may optionally give us the reason for doing so. Your personal data will be deleted after you have unsubscribed. Further processing will only take place in an anonymous form for the purpose of optimising our newsletter.

4. Creating a customer account

You can book on our website as a visitor or by creating a customer account. When you register for a customer account, we necessarily collect the following data:

  • Your title.
  • Your first and last name.
  • Your telephone number.
  • Your email address.
  • Your password.

These data and other optional information (e.g. company name) are collected in order to provide you with direct, password-protected access to your account stored in our system. There you can view your previous and current bookings and manage or change your personal data.

Under Article 6(1)(a) of the GDPR your consent is the legal basis for processing your data to this end.

Booking on our website or by email, post or telephone

If you book on our website or by email, post or telephone, we require the following data in order to perform the contract:

  • Your title.
  • Your first and last name.
  • Your date of birth.
  • Your telephone number.
  • Your language.
  • Your credit card details.
  • Your email address.

We use these data, together with other optional information you provide (e.g. expected time of arrival, postal address, preferences, remarks), solely for the purpose of performing the contract, unless otherwise stated in this privacy policy or unless you have given separate consent. We will process these data in order to, among other things, enter your booking in accordance with your request, provide the services you have booked, contact you in the event of uncertainty or problems, and to ensure that payment is taken correctly.

Under Article 6(1)(b) of the GDPR the performance of a contract is the legal basis for processing your data to this end.

Cookies

Cookies make your visit to our website easier, more enjoyable and more useful in many ways. Cookies are files containing information that your web browser automatically stores on your device when you visit our website.

For example, we use cookies to temporarily store the products and services you select and the information you enter when filling out a form on our website so that you do not have to reenter those details when visiting a subpage. In addition, cookies may also be used to identify you as a registered user once you have registered on our website. This prevents you from having to log in again when you visit another subpage.

Most web browsers automatically accept cookies. However, you can change your browser's settings to not store any cookies on your device or to bring up a message every time you receive a new cookie. The following web pages explain how to manage cookies in the most commonly used browsers:

Disabling cookies may prevent you from using our site in its full functionality.

[cookiebot_link title="Click here to see the list of cookies or change your preferences"]

6. Tracking tools

a. General

To best present and continually optimise our website we use Google Analytics, a web anaytics service. In doing so, we create anonymised, pseudonymised user profiles and use small text files stored on your device (cookies). The information generated by cookies about your use of this website is sent to the servers of Google Analytics where it is stored and processed for us. In addition to the data listed under subheading 1, we may receive the following information:

  • The click path taken by a visitor on the website.
  • The duration of the visit on the website or web page.
  • The web page from which a visitor leaves the website.
  • The country, region or city where the website is accessed.
  • Device (type, version, colour depth, resolution, width and height of the browser window).
  • New Visitor, Repeat Visitor or Return Visitor.

This information is used to analyse the use of the website, compile reports on activity on the website, and provide other services in connection with the use of the website and the internet for market research purposes and the correct presentation of the website. This information may also be passed on to third parties insofar as this is required by law or insofar as third parties are commissioned to process these data.

b. Google Analytics

Google Analytics is provided by Google Inc. which is owned by Alphabet Inc. which is registered in the United States. Before data are sent to Google, an IP address is masked by activating IP anonymisation ("anonymizeIP") on this website within the Member States of the European Union or in other countries that are signatories to the Agreement on the European Economic Area. Google does not combine the anonymised IP address sent by your browser via Google Analytics with other data. In exceptional cases a full IP address is sent to a Google server in the United States before being masked. In such cases contractual guarantees ensure that Google Inc. maintains an adequate level of data privacy. According to Google Inc. an IP address is not linked to any other data about a user.

Further information on the web analytics service used can be found on the Google Analytics website. You can find out how to prevent your data being processed by the web analytics service at http://tools.google.com/dlpage/gaoptout?hl=fr.

B. Data processing in connection with your stay

7. Data processing to comply with the legal obligation to report to the authorities

Upon your arrival at our hotel we require the following information about you and those accompanying you:

  • Your first and last name.
  • Your postal address and canton.
  • Your date of birth.
  • Your place of birth.
  • Your nationality.
  • A copy of your ID or passport and your ID or passport number.
  • Your arrival and departure days.
  • Your room number.

We collect this information to comply with the legal obligation to report to the authorities, notably that resulting from criminal law and legislation regulating the hotel trade. Insofar as we are obliged to do so under applicable law, we pass on this information to the police department concerned.

We have a legitimate interest under Article 6(1)(f) of the GDPR to comply with the law.

8. Recording products or services used

If you avail yourself of additional products or services during your stay (e.g. the mini bar), the product or service in question and the date of its use are recorded for billing purposes. We are required to process these data so as to perform your contract with us in accordance with Article 6(1)(b) of the GDPR.

C. Storing and sharing data with third parties

9. Booking via a third-party platform

If you book via a third-party platform, the operator of that platform sends us various personal data. As a rule these data are those listed under subheading 5 of this privacy policy. We may also receive enquiries about your booking. We process these data to capture your booking in accordance with your request and to provide the services so booked. Under Article 6(1)(b) of the GDPR the performance of a contract is the legal basis for processing your data to this end.

Finally, the platform operators may inform us of disputes in connection with a booking. In such cases they also provide us with data about the booking process, for which a copy of the booking confirmation can serve as proof of the actual completion of the booking. We process these data so as to be able to protect and enforce our rights on the basis of our legitimate interest according to Article 6(1)(f) of the GDPR.

We advise you to also read the privacy policies of the respective service providers.

10. Centralised data storage and linking

We store the data specified under subheadings 2-5 and 8-10 of this privacy policy in a centralised electronic data processing system. Your data are then systematically captured and sorted so as to process your bookings and carry out the services contracted. For this we use software from Oracle Software (Schweiz) GmbH, Täfernstrasse 4, 5405 Baden Dättwil.

We have a legitimate interest under Article 6(1)(f) of the GDPR to use this software to process your data as part of managing customer data in a way that benefits customers and is efficient.

11. Storing time

We only store personal data for as long as is necessary for the use of the above-mentioned monitoring services and for further processing based on our legitimate interest. We store contractual data for a longer period if this is required by legal retention obligations. The storage obligations which oblige us to retain data arise from the provisions on the right to notify the authorities, financial accounting and tax law. In accordance with these provisions, business communication, concluded contracts and accounting documents must be kept for up to 10 years. If we no longer need these data for the performance of our services, they will be blocked. This means that these data can only be used for accounting and tax purposes.

12. Transfering data to third parties

We only pass on your personal data with your express consent, if we are under a legal obligation to do so, or if necessary to enforce our rights, in particular those arising from the contractual relationship. In addition, we pass on your data to third parties insofar as this is necessary for using the website and performing the contract (via the website and by other means), in particular to process your bookings.

Our web host Infomaniak is a service provider to whom we transmit personal data collected via the website, or who has access or may have access to such data. The website is hosted on servers in Switzerland. The purpose of transmitting the data is to provide and maintain the functionality of our website. This processing is based on our legitimate interest according to Art. 6 para. 1 letter f GDPR.

Finally, we transmit your credit card information to the issuer and acquirer of your credit card when you pay by credit card on our website. If you choose to pay by credit card, you must enter all the necessary information. Under Article 6(1)(b) of the GDPR the performance of a contract is the legal basis for transferring your data. For the processing of your credit card information by these third parties, please also read the general terms and conditions and the privacy policy of your credit card issuer.

We advise you to read subheadings 7-8 and 10-11 regarding the transfer of your personal information to third parties.

13. Transfering personal data abroad

We may also transfer your personal data to third-party companies (contracted service providers) abroad for data to be processed as specified in this privacy policy. These companies are subject to the same level of data privacy as we are. If the level of data privacy in a particular country does not match the Swiss or European level, we will ensure by contractual means that your personal data are afforded the same privacy level as in Switzerland or the EU.

D. Other information

14. Right to information, rectification, erasure, restriction of processing, and data portability

On request, you have the right to obtain information about your personal data stored by us. Furthermore, you have the right to have incorrect data rectified and to have your personal data erased, provided there is no opposing legal obligation for us to store the data or no opposing legal basis for us to process the data.

You also have the right to demand the return of the data you have provided to us (right to data portability). On request, we will also pass on the data to a third party of your choice. You have the right to obtain the data in a standard format.

You can contact us for the above purposes at bristol@bristol.ch. We will, at our discretion, ask you for proof of identity to process your requests.

15. Data security

We use appropriate technical and organisational security measures to protect your personal data stored by us against manipulation, partial or total loss, and unauthorised access by third parties. Our security measures are constantly being improved in line with technological developments.

You should always keep your login credentials to yourself and close the browser window once you are done using our website, especially if you are not the only person using that device.

We also take data privacy in our company very seriously. Our staff and the service providers we contract are bound by confidentiality and data privacy law.

16. Note on data transfers to the United States

For the sake of full disclosure we wish to inform users whose place of residence or registered office is in Switzerland that the United States is subject to surveillance measures by the American government. These measures generally allow the recording of all personal data transferred from Switzerland to the United States. This is done without any distinction, limitation or exception based on the ends pursued and without any objective criterion for limiting the access of the American government to the data and for limiting their later use to very specific and strictly limited ends that can justify the harm involved in accessing and using the data. Furthermore, we wish to inform you that the United States has no legal remedy for data subjects from Switzerland to gain access to their data and to have them rectified or erased, nor has it any effective legal protection against general rights of access of the American government. We explicitly draw the attention of data subjects to this legal and factual situation so that they can make an informed decision about consenting to the use of their data.

We wish to point out to users from EU Member States that the EU does not consider the United States to have an adequate level of data privacy, particularly in view of the issues discussed in this section. Insofar as we have explained in this privacy policy that some data recipients (e.g. Google) are based in the United States, we will ensure either through contractual arrangements with these companies or through their certification under the EU-US Privacy Shield or the Swiss-US Privacy Shield that your data are afforded a reasonable level of privacy by our partners.

17 Right to complain to a national data protection authority

You have the right to lodge a complaint with a national data protection authority.