Customer Care: +32 258 80 062 (Global Access) Log in MENU PRIVACY POLICY 1. IDENTIFICATION Identity: NH HOTEL GROUP, S.A. (hereinafter “NH HOTEL GROUP”) Tax ID: A-28027944 Address: Calle Santa Engracia 120, 7ª, 28003, Madrid Data Protection Officer (DPO): you may contact our DPO by the following: E-mail: dpo@nh-hotels.com Telephone: Headquarters at Calle Santa Engracia 120, 7ª, 28003, Madrid Please state the reference "Data Protection Officer" 2. INFORMATION AND CONSENT By accepting this Privacy Policy, the user is informed and provides their free, informed, specific and unambiguous consent for the personal data they provide on the website at www.nh-hotels.com (hereinafter the “Website”) to be processed by NH HOTEL GROUP, with their browsing data and any other data they provide to NH HOTEL GROUP in the future. The user must read this Privacy Policy carefully, which has been written clearly and simply, to improve understanding, to freely and voluntarily decide whether they wish to provide their personal data to NH HOTEL GROUP. 3. REQUIREMENT TO PROVIDE DATA Data requested in Website forms are generally mandatory (unless otherwise specified in the requested field) to comply with the stated purposes. Therefore, if these are not provided or not provided correctly, they may not be addressed, without affecting the free display of the Website content. 4. FOR WHAT PURPOSE WILL NH HOTEL GROUP PROCESS USERS’ PERSONAL DATA? The personal data provided through the Website will be processed by NH HOTEL GROUP for the following purposes: 1. Data provided for making reservations, both through the website and the contact center (call center, email or chat) for individual, group and room bookings: Managing booking requests made by users. Sending the confirmation or documentation for the booking made. If consent has been given, sending commercial communications on behalf of NH HOTEL GROUP Analyzing the use of the Website and checking user preferences and behavior. 2. Data provided to register as a user with NH HOTEL GROUP: Managing your request to register or deregister within the category chosen by the user. Checking that the user meets the requirements for registering within the selected category, whenever NH HOTEL GROUP deems it appropriate. Handling and responding to potential requests for information made by the user. Searching for promotions that fit the needs selected by the user. Sending customized commercial communications on behalf of NH HOTEL GROUP. Analyzing the use of the Website and checking user preferences and behavior. 3. Data provided through the Best Price form: Managing contact and information requests by the user through the channels provided for this on the NH HOTEL GROUP websites. Managing the request made. Analyzing the use of the Website and checking user preferences and behavior. 4. Data provided for publications on BLOGs belonging to NH HOTEL GROUP: Managing the publication of comments on the Website. Managing the subscription and/or unsubscription to the Blog Newsletter at the user’s request. Analyzing the use of the Website and checking user preferences and behavior. If required, monitoring the content of users’ comments and, where appropriate, deleting those whose content does not meet the conditions of the current Website at the discretion of NH HOTEL GROUP. 5. Data provided for changing or cancelling reservations: Managing the requests to change or cancel your reservation made to NH HOTEL GROUP by the user. Responding to requests made to NH HOTEL GROUP. Analyzing the use of the Website and checking user preferences and behavior. 6. Data provided for sending out Newsletter: Managing subscription and/or unsubscription to the Newsletter, made through the channel provided on the NH HOTEL GROUP Website 7. Data provided for the NH Rewards Program: Managing the loyalty program and processing your membership application, assigning your member number, access keys to your private online area and allowing you to collect and redeem points. Customizing loyalty program services to Members’ preferences and tastes, and getting feedback on the service provided at our hotels. This may include sending surveys on quality and the tailoring and customization of services provided by NH. Sending out correspondence related to your account, including for example, points balance, card category, notifications and anything else to keep you informed about your account status. Sending customized commercial communications by email or similar means, on offers and services related to the Program, unless You object to this processing. 8. Data provided on Corporate contact forms and website: Managing contact and information requests by the user through the channels provided for this on the NH HOTEL GROUP websites. Managing the request made. Analyzing the use of the Website and checking user preferences and behavior. 9. Data provided on the basket recovery form: Sending a reminder of users’ incomplete reservations or, if applicable, searches made by users. Analyzing the use of the Website and checking user preferences and behavior. 10. Information provided as part of the NH Hotel Group Benefit Program for Companies, NH&YourSpace and NH&YourAgencySpace programmes: Delivery of personalized messages via email or similar channels with offers and services related to the programme, as well as offers and services from NH Hotel Group Partners sent via email and other similar channels. Manage user booking requests. Send booking confirmations or documentation. Analyse website use and check user preferences and behaviour. 5. WHAT USER DATA WILL NH HOTEL GROUP PROCESS? NH HOTEL GROUP will process the following categories of user data: 1. Data provided for making reservations, both through the website and the contact center (call center, email or chat) for individual, group and room bookings: Identifying data: name, surname, nationality. Contact details: email address, telephone number. Transactional data for goods and services with NH HOTEL GROUP: Products and services purchased or in which you show interest. Stay preferences. Economic, financial and insurance data. Other data: data provided by the data subjects in open fields or during calls. Browsing data. 2. Data provided to register as a user with NH HOTEL GROUP: Identifying data: name, surname, address, nationality Contact details: email address, telephone number. Identification codes and keys for the user and/or member. Details employment data: profession, sector. 3. Data provided through the Best Price form: Identifying data: name, surname. Contact details: email address, telephone number. Transactional data for goods and services. Other data: data provided by the data subjects in open fields on forms available on the Website or in the attached documents. Browsing data. 4. Data provided for publications on BLOGs belonging to NH HOTEL GROUP Identifying data: name, surname. Contact details: country of residence, email address. Browsing data. 5. Data provided for changing or cancelling reservations: Identifying data: name, surname. Contact details: email address, telephone number. Transactional data for goods and services. Economic, financial and insurance data. Other data: data provided by the data subjects in open fields on forms available on the Website or in the attached documents. Browsing data. 6. Data provided for sending out Newsletter: Identifying data: name, surname. Contact details: country of residence, email address. Data on personal characteristics: language. 7. Data provided for the NH Rewards Program: Identifying data: name, surname, ID card, signature, address, nationality. Data on personal characteristics: date of birth, gender. Contact details: email, telephone number Identification codes and keys for the user and/or member. Transactions for goods and services with NH HOTEL GROUP: Products and services purchased or in which you show interest. Stay preferences Browsing data 8. Data provided on Corporate contact forms and websites: Identifying data: name, surname. Contact details: email address, telephone number. Transactional data for goods and services. Other data: data provided by the data subjects in open fields on forms available on the Website or in the attached documents. Browsing data. 9. Data provided on the basket recovery form: Contact details: address and email. If the user provides data on third parties, they declare that they have their consent and commit to providing them with the information in the Privacy Policy, thereby exempting NH HOTEL GROUP of any liability in this regard. However, NH HOTEL GROUP may make periodic checks to confirm this, using appropriate due diligence, in accordance with data protection regulations. 6. WHAT IS THE JUSTIFICATION FOR PROCESSING USERS’ DATA? The justification for processing your personal data will be as follows: For making reservations, both through the website and the contact centre (call centre, email or chat) for individual, group and room bookings: performance of the contract between the parties. For analyzing the use of the Website, the legitimate interest of NH HOTEL GROUP For managing user registration: the consent requested and, in verification, users’ compliance with terms and conditions, and for analyzing the use of the Website, the legitimate interest of NH HOTEL GROUP. However, if you withdraw your consent, this will not affect the legality of prior processing. For the Best Price form: the consent requested from you which you may withdraw at any time. However, if you withdraw your consent, this will not affect the legality of prior processing. For analyzing the use of the Website, the legitimate interest of NH HOTEL GROUP For managing and publishing comments or publications sent by users on BLOGs belonging to NH HOTEL GROUP: the consent given by the user and, in Website analysis, confirming user preferences and behavior, and in monitoring the content of the comments, the legitimate interest of NH HOTEL GROUP. If you withdraw your consent for processing in the publication of comments, these will be deleted from the Website by NH HOTEL GROUP. For changes and/or cancellation of your reservation: the performance of the contract between the parties. For analyzing the use of the Website, the legitimate interest of NH HOTEL GROUP. For sending the Newsletter: the consent provided by the user. For registration and management as a member of the NH Rewards Program: the performance of the contract between the parties, while the member’s consent will be the basis for sending commercial communications. For analyzing the use of the Website, the legitimate interest of NH HOTEL GROUP. For sending Corporate contact forms and website: the consent provided by the user. For analyzing the use of the Website, the legitimate interest of NH HOTEL GROUP. For sending the basket recovery reminder: the consent provided by the user. For analyzing the use of the Website, the legitimate interest of NH HOTEL GROUP. Consents obtained for the aforementioned purposes are separate and the user may revoke only one without affecting the others. To revoke this consent, the User may contact NH HOTEL GROUP by the following methods: protecciondedatos@nh-hotels.com 7. WITH WHICH RECIPIENTS WILL USER DATA BE SHARED? User data may be disclosed to: Data provided for making reservations, both through the website and the contact center (call center, email or chat) for individual, group and room bookings: Companies belonging to or affiliated with NH Hotel Group, all within the hotel sector, which require access to your data for correct provision of the chosen services. Likewise, your data will be communicated to any entities that own the hotels, so these entities will know the conditions of your stay (price, dates, services included, etc.). Some of these entities may be located outside the European Economic Area, including in countries that do not offer a level of protection comparable to the level in Spain. The sole purpose of this communication will be to be able to provide the services to your correctly. Data provided to register as a user with NH HOTEL GROUP: Companies within the group to which NH HOTEL GROUP belongs, solely for internal administrative purposes and/or for the purposes indicated above. Data provided through the Best Price form: Companies within the group to which NH HOTEL GROUP belongs, solely for internal administrative purposes and/or for the purposes indicated above. Data provided for publications on BLOGs belonging to NH HOTEL GROUP: Data provided by users will be published on the Website, and will be accessible to any user accessing the same. Data provided for changing or cancelling reservations: Companies belonging to or affiliated with NH Hotel Group, all within the hotel sector, which require access to your data for correct provision of the chosen services. In addition, your data will be disclosed to hotel owners, so that they are aware of the conditions of your stay (price, dates, services included, ...), and any of these may be located outside the European Economic Area, including in countries which do not offer an equivalent level of protection to Spain for the sole purpose of correct service provision. Data provided for sending out the Newsletter will not be disclosed to third party companies. Data provided for the NH Rewards Program: Entities belonging to the NH Rewards Program, all within the hotel sector, as required for the correct provision of services under the NH Rewards Program, so that they are aware of the terms of your stay (price, dates, services included, ...) and information on your account, balance, points and category, any of which may be located outside the European Economic Area including countries which do not offer an equivalent level of protection, this access being required for normal operation of the NH Rewards Program. These entities may be consulted at https://www.nh-hotels.com/nh-hotel-group-companies Data provided on Corporate contact forms and website: Companies within the group to which NH HOTEL GROUP belongs, solely for internal administrative purposes and/or for the purposes indicated above. Data provided on the basket recovery form: Companies within the group to which NH HOTEL GROUP belongs, solely for internal administrative purposes and/or for the purposes indicated above In addition, data may be accessed by NH HOTEL GROUP suppliers, when this is required for proper compliance with legal obligations and/or for the purposes indicated above. These providers will not process your data for purposes not previously advised by NH HOTEL GROUP. 8. INTERNATIONAL TRANSFERS OF DATA Please be advised that your data will be transferred to third parties located outside the European Economic Area, specifically, the USA, India and the Philippines. It will be transferred as a result of the services provided by Accenture to NH HOTEL GROUP in terms of the back office management connected to the company’s invoicing. In this regard, please be advised that the company is regulated by means of contractual clauses approved in advance by the AEPD. 9. DATA STORAGE Your data will be stored for the following periods: Data provided for making reservations, both through the website and the contact centre (call centre, email or chat) for individual, group and room bookings: will be stored throughout the contractual relationship, and after termination of the same, for the limitation period for legal actions that could result from it. Data provided to register as a user with NH HOTEL GROUP: for as long as the user does not withdraw the consent provided. However, if you withdraw your consent, this will not affect the legality of prior processing. Data provided through the Best Price form: for as long as required to manage your request. Data provided for publications on BLOGs belonging to NH HOTEL GROUP: Data will be stored for as long as the user does not withdraw the consent given. Data provided for changing or cancelling reservations: will be stored throughout the contractual relationship, and after termination of the same, for the limitation period for legal actions that could result from it. Data provided for sending out Newsletter: will be stored for as long as the user does not withdraw the consent provided for this. Data provided for the NH Rewards Program: will be stored throughout the contractual relationship, and after termination of the same, for the limitation period for legal actions that could result from it. Data provided on Corporate contact forms and website: will be stored for the period required to process and answer your request and, when this is complete, for the limitation period for legal actions resulting from this request. Data provided on the basket recovery form: will be stored for 15 days after abandoning the reservation. 10. USER LIABILITY The user: Guarantees that they are above eighteen (18) years of age and that the data they provide to NH HOTEL GROUP and true, precise, complete and up to date. For these purposes, the user is liable for the veracity of all the data disclosed and must keep the information provided properly up to date, to reflect their actual situation. They guarantee that they have informed the third parties whose data they have provided, if they have done so, of the points covered in this document. In addition, they guarantee that their authorization has been obtained to provide their data to NH HOTEL GROUP for the indicated purposes. They will be liable for any false or inaccurate information they provide on the Website and for direct or indirect damage caused to NH HOTEL GROUP or to third parties. 11. EXERCISE OF RIGHTS Users may write to NH HOTEL GROUP, at the address noted at the top of this Policy, or by email to protecciondedatos@nh-hotels.com, including a copy of their identity document, at any time and free of charge, to: Revoke consent already granted. Receive confirmation on whether or not NH HOTEL GROUP is processing personal data belonging to the user. Access your personal data. Correct inaccurate or incomplete data. Request the deletion of your personal data when, for any reason, the data is no longer necessary for the purposed for which it was obtained. Request that NH HOTEL GROUP restrict data processing when any of the conditions in the data protection regulations are met. Request the portability of the data provided by the User in cases envisaged in the regulations. Contact the DPO of NH HOTEL GROUP at the following address: dpo@nh-hotels.com Lodge a complaint relating to protection of your personal data with the Spanish Data Protection Agency at Calle de Jorge Juan, 6, 28001 Madrid, when the data subject believes that NH HOTEL GROUP has infringed the rights recognized by applicable data protection regulations. 12. SECURITY MEASURES NH HOTEL GROUP will process user data absolutely confidentially at all times, under the duty of secrecy of the same, in accordance with applicable regulations, taking necessary technical and organizational measures to guarantee the security of your data and prevent unauthorized changes, loss, processing or access, in view of the state of technology, the nature of the data stored and risks to which they are exposed. Last updated: May 2018. 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