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References to “CHRG” (Constance Hotels, Resorts and Golf) “we” and “our” throughout this Policy, collectively and individually refer to Constance Hospitality Management Ltd, to the distinct legal entities managed and/or operated by Constance Hospitality Management Ltd under any brand names, and to all entities owned/managed/operated by Constance Hotels Services Ltd.
At CHRG, we recognise the importance of privacy. Consequently we make it a high priority to ensure that your personal information remains secure and confidential and is used only for the intended purpose.
"Personal data" means any information relating to you, such as your name or telephone number.
Before you provide us with your personal data, we recommend that you read this policy which explains how we collect data about you and the nature of that data, how we use that data, who that data may be sent to and how you can amend data you have submitted to us.
The seven principles below are applicable within our organisation throughout the world.
At various touch points, we may ask you or collect information about you and/or members of your family, such as:
¨ your name, gender, contact details, address, date of birth, anniversary date, nationality, profession and passport details
¨ guest stay information, including the CHRG hotels where you have stayed, dates of arrival and departure, special interests, specific requests made, observations about your service preferences (including room and vacation preferences, preferred floor, sports, special interests)
¨ special requirements and any information necessary to fulfil these requirements (e.g. allergies, dietary preferences/restrictions or health conditions requiring specific accommodation or service)
¨ your credit card details, payment method details
¨ information, feedback or content you provide in surveys following your stay in any of our establishments
¨ information captured while you access our websites, participate in sweepstakes, contests or promotional offers, or our third party partners
¨ information supplied when you apply for a job and through the use of our recruitment software
¨ contact and other relevant details of our suppliers, contractors and other business partners
The information collected in relation to persons under 16 years of age is limited to their name, nationality, address, date of birth, which can only be supplied to us by a parent or guardian. We would be grateful if you could ensure that your children, aged less than 16 years, do not send us any personal data without your consent (particularly via the Internet). If such data is sent, please notify our Privacy Team via contact details stated at section 14, to arrange for this information to be deleted.
We do not deliberately collect sensitive information, such as information concerning race, ethnicity, political opinions, religious and philosophical beliefs, union membership, or details of health or sexual orientation or character certificate.
However, you can also provide us with sensitive information if you consider that by providing such information we will be able to give you a better service.
Personal data may be collected on a variety of occasions, including:
6.1 Hotel activities:
6.2 Participation in marketing programs or events:
6.3 Transmission of information from third parties:
6.4 Internet activities:
6.5 In other service contracts with CHRG, for example a commitment as model for photo/video shoots
6.6 Registration of children with the Constance Kids Club with the consent of parents or guardian
We collect your personal data for the purposes of:
7.1 Meeting our obligations to our customers
7.2 Managing your booking and other services requested
7.3 Managing your stay at the hotel:
7.4 Improving our products and services:
7.5 Managing our relationship with customers before, during and after your stay:
7.6 Analysing your collected data in order to determine your interests and your customer profile and to allow us to send you personalised offers
7.7 Securing and enhancing your use of CHRG websites, especially:
7.8 Conforming to local legislations (for example, storing of accounting documents)
As we are present in many countries, we endeavour to provide you with the same personalised services at all locations. We disclose personal data in limited circumstances and mainly in connection with services that you request including to manage your access and amendment requests, or for CHRG business purposes. For example, we share the required information:
8.1 Internally, with authorised personnel of CHRG, in order to manage your stay and offer you the best service
8.2 To third parties retained by CHRG for the processing of data on our behalf, for example for the handling of guest satisfaction survey, mailing of newsletters and campaigns, data analysis, statistics, or data storage
8.3 With commercial partners or third party service providers, for e.g. for booking of transfers or activities as requested by yourself
8.4 CHRG does not routinely disclose personal information to other organisations unless:
For the purposes set out in Clause 7 of this Policy, we may transfer your personal data to internal or external recipients who may be in countries offering different levels of personal data protection. Consequently, in addition to implementation of this Policy, CHRG employs appropriate measures to ensure secure transfer of your personal data to CHRG entities or to an external recipient located in a country offering a different level of privacy from that proposed in the country where the personal data is collected.
Such transfer of information does not change any of our commitments to safeguard your privacy and the information remains subject to existing confidentiality obligations.
CHRG takes appropriate technical and organizational measures, in accordance with applicable legal provisions, to protect your personal data against illicit or accidental destruction, accidental alteration or loss, and unauthorized access or disclosure. To this end, we have taken technical measures (such as firewalls) and organizational measures (such as a user ID/password system, means of physical protection etc.).
CHRG will endeavour to take all reasonable steps to keep secure any information which we hold about you, whether electronically or in hard copy, and to keep this information accurate and up to date. We also require our employees and data processors to respect the confidentiality of any personal information held by CHRG.
“Other Information” is any information that does not reveal your specific identity or does not directly relate to an individual, such as:
If we are required to treat Other Information as personal information under applicable law, then we may use it for the required purposes and disclose personal information as detailed in this Statement. We and our third party service providers may collect Other Information in a variety of ways, including:
We retain your personal data only as long as necessary for the purposes set out in this Policy and in accordance with the provisions of applicable laws.
You have the right to access the personal data that CHRG holds on you. You also have the right to request rectification or erasure of the data held, or to restrict the processing of your data, subject to applicable legislations. You may exercise these rights by sending us a written request by email or letter to the following address,
Postal: Constance Hospitality Management Ltd - Constance, 40609 Centre de Flacq, Mauritius, Indian Ocean
Please include your full name, address and telephone number when sending your request, in case we need to contact you to obtain any additional information. For the purpose of confidentiality and protection of your data, we will also require a proof of identity (such as an ID card or passport) before we act on your request.
Where you make more than one request in quick succession, we may respond to your subsequent request by referring to our earlier response and only identifying any items that have changed materially. In some cases we may also request an administrative fee to cover the cost of access.
All requests will receive a response as swiftly as possible and in accordance with applicable law.
Effective date: 28 June, 2018