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CUSTOMER PERSONAL DATA PROTECTION CHARTER
Last Updated: September 05, 2022
1. THE ACCOR GROUP'S COMMITMENT TO PROTECTING PRIVACY
We consider you an important customer. Our first priority is to offer you
exceptional stays and experiences throughout the world.
Your complete satisfaction and confidence in Accoris absolutely essential to us.
That's why, as part of our commitment to meeting your expectations, we have set
up (and we had a privacy policy before the much anticipated GDPR - General Data
Protection Regulation ;-)) a customer personal data protection charter. This
charter formalizes our commitments to you and describes how the AccorGroup uses
your personal data.
2. SCOPE OF APPLICATION
In this charter, “AccorGroup” means:
* Accor SA, the AccorGroup parent company, with registered offices at 82 rue
Henri Farman, 92130 Issy-les-Moulineaux, France;
* Subsidiary or “family” companies of Accor SA involved in the hotel businesses
of the AccorGroup; and
* hotels operated under one of the AccorGroup brands throughout the world
(Raffles, Sofitel Legend, Fairmont, SO/, Sofitel, onefinestay, Rixos,
MGallery, Pullman, Swissôtel, 25hours Hotels, Novotel, Mercure, Mama Shelter,
Adagio, JO&JOE, ibis, ibis Styles, ibis budget, Grand Mercure, The Sebel and
hotelF1). This list of brands is regularly updated and can be viewed
on accor.com.
Good to know!
You probably don't know this, but the hotel you are booked to stay in is
probably not owned by Accor SA or one of its family of companies. Most
Accorbranded hotels are operated under a franchise or management agreement
between the hotel’s owner and Accor SA (or one of its subsidiaries across the
world).
This is why, when staying in one of these hotels, your personal data will be
dealt with by Accor SA and the hotel, both acting as Data Controllers for their
own, separate, purposes. In summary:
* Accor SA will process your data because it manages a central booking engine,
which allows Accor SA to collect the data necessary to organise your stay in
hotels under an Accorbrand and to communicate this data to the concerned
hotels. Accor SA also manages a global database of clients who stay in hotels
under an Accorbrand. With the help of its subsidiary PRO-FID SAS, Accor SA
also manages the Le Club Accor loyalty programme;
* Each hotel will process your data to manage its contractual relationship with
you (invoicing, payment, booking management etc.), to perform marketing
activities and to comply with its legal obligations.
Accor SA has communicated the principles set out in this charter to all of the
Accorbranded hotels and their respective owners. We will do our upmost to ensure
that all hotels comply with the applicable data protection laws and this charter
in relation to the processing of your personal data.
3. ACCOR' TEN PRINCIPLES FOR PROTECTING YOUR PERSONAL DATA
In accordance with applicable regulations, in particular the European General
Data Protection Regulation, we have instituted the following ten principles
throughout the AccorGroup:
1. Lawfulness: We use personal data only if:
* we obtain the consent of the person, OR
* it is necessary to do so for the performance of a contract to which the
person is a party, OR
* it is necessary for compliance with a legal obligation, OR
* it is necessary in order to protect the vital interests of the person, OR
* we have a legitimate interest in using personal data and our usage does
not adversely affect the persons’ rights
2. Fairness: We can explain why we need the personal data we collect.
3. Purpose limitation and data minimisation: We only use personal data that we
really need. If the result can be achieved with less personal data, then we
make sure we use the minimum data required.
4. Transparency: We inform people about the way we use their personal data
5. We facilitate the exercise of the people’s rights: access to their personal
data, rectification and erasure of their personal data and the right to
object to the use of their personal data
6. Storage limitation: We retain personal data for a limited period
7. We ensure the security of personal data, i.e. its integrity and
confidentiality.
8. If a third party uses personal data, we make sure it has the capacity to
protect that personal data.
9. If personal data is transferred outside Europe, we ensure this transfer is
covered by specific legal tools.
10. If personal data is compromised (lost, stolen, damaged, unavailable…), we
notify such breaches to the respective country’s responsible authority and
to the person concerned, if the breach is likely to cause a high-risk in
respect of the rights and freedoms of this person.
For any questions concerning the ten principles of Accordata protection
policies, please contact the Data Privacy department whose details appear in the
clause "Your rights".
4. WHAT PERSONAL DATA IS COLLECTED?
At various times, we may collect information about you and/or the persons
accompanying you, including the following:
* Contact details (for example, last name, first name, telephone number, email)
* Personal information (for example, date of birth, nationality)
* Information relating to your children (for example, first name, date of
birth, age)
* Your credit card number (for transaction and reservation purposes)
* Information contained on a form of identification (such as ID card, passport
or driver licence)
* Your membership number for the Accor loyalty program or another partner
program (for example, an airline loyalty programme) and information related
to your activities within the context of the loyalty program
* Your arrival and departure dates
* Your preferences and interests (for example, smoking or non-smoking room,
preferred floor, type of bedding, type of newspapers/magazines, sports,
cultural interests, food and beverages preferences, etc.)
* Your questions/comments, during or following a stay in one of our
Accorbranded establishments
* Technical and location data you generate as a result of using our websites
and applications.
The information collected in relation to persons under 16 years of age is
limited to their name, nationality and date of birth, which can only be supplied
to us by an adult. We would be grateful if you could ensure that your children
do not send us any personal data without your consent (particularly via the
Internet). If such data is sent, you can contact the Data Privacy department
(see clause "Your rights" below) to arrange for this information to be deleted.
In order to meet your requirements or provide you with a specific service (such
as dietary requirements), we may have to collect sensitive information, such as
information concerning race, ethnicity, political opinions, religious and
philosophical beliefs, union membership, or details of health or sexual
orientation. In this case, we will only process this data if you provide your
express prior consent.
5.WHEN IS YOUR PERSONAL DATA COLLECTED?
Personal data may be collected on a variety of occasions, including:
1. Hotel activities:
* Booking a room
* Checking-in and paying
* Hotel stays and services provided during a stay
* Eating/drinking at the hotel bar or restaurant during a stay
* Requests, complaints and/or disputes.
2. Participation in marketing programs or events:
* Signing up for loyalty programs
* Participation in customer surveys (for example, the Guest Satisfaction
Survey)
* Online games or competitions
* Subscription to newsletters, in order to receive offers and promotions via
email.
3. Transmission of information from third parties:
* Tour operators, travel agencies (online or not), GDS reservation systems
and others
4. Internet activities:
* Connection to Accorwebsites (IP address, cookies in accordance with
our Policy about the use of tracers)
* Online forms (online reservation, questionnaires, Accorpages on social
networks, social networks login devices such as Facebook login,
conversations with chatbot, etc.).
6. WHAT PURPOSES IS YOUR DATA COLLECTED FOR AND HOW LONG DO WE RETAIN IT?
The table below sets out why we process your data, the lawful basis for the
processing and the associated retention period:
Purpose/Activity Lawful basis for processing including basis of legitimate
interest Retention period Meeting our obligations to our customers. Performance
of a contract with you.
Necessary to comply with a legal obligation.
Necessary for our legitimate interest in running our business and providing you
with requested products and services. 10 years from the booking in accordance
with legal obligations. Managing the reservation of rooms and accommodation
requests, in particular the creation and storage of legal documents in
compliance with accounting standards. Managing your stay at the hotel:
* Managing access to rooms
* Monitoring your use of services (telephone, bar, pay TV etc.)
Performance of a contract with you.
Necessary for our legitimate interest in running our business and providing you
with requested products and services. For the duration of your stay. Managing
our relationship with customers before, during and after your stay:
* Managing the loyalty program
* Inputting details into the customer database
* Segmentation analysis based on reservation history and customer travel
preferences with a view to sending targeted communications, subject to the
requirements of the EU ePrivacy directive (2002/58/EC as amended in 2009)
* Predicting and anticipating future customer behaviors
* Developing statistics, commercial scores and carrying out reporting of the
same
* Providing context data for our marketing tools. This happens when a customer
visits a Group website or makes a reservation
* Understanding and managing the preferences of new or repeat customers
* Sending customers newsletters, promotions, tourist, hotel or service offers,
offers from Accor SA or its commercial partners, or contacting you by
telephone subject to the requirements of the EU ePrivacy directive
(2002/58/EG as amended in 2009)
Performance of our contract with you and for the management of your membership
in the loyalty program.
Necessary for our legitimate interests in promoting and improving our services.
Processing based on your consent for direct marketing purposes. 3 years from the
last date on which you have interacted with us in any way, if you are not a
member of the loyalty programme.
6 years from the last date on which you have interacted with us in any way, if
you are a member of the loyalty programme. Improving our hotel service by:
* Personalising your check-in, improving the quality of service and customer
experience
* Processing your personal data through our customer marketing program in order
to carry out marketing operations, promote brands and gain a better
understanding of your requirements and wishes
* Adapting our products and services to better meet your requirements
* Customising the commercial offers and promotional messages we send you
* Informing you of special offers and any new services created by Accor SA or
one of its subsidiaries or commercial partners.
Performance of contract with you in relation to the management of your
membership in the loyalty program.
Necessary for our legitimate interests in promoting our services, performing
direct marketing activities (taking into account your commercial relationship
with AccorGroup) and improving our services. 3 years from the last date on which
you have interacted with us in any way, if you are not a member of the loyalty
program.
6 years from the last date on which you have interacted with us in any way, if
you are a member of the loyalty program. Use a trusted third party to
cross-check, analyse and combine your collected data at the time of booking or
at the time of your stay, in order to determine your interests and develop your
customer profile and to allow us to send you personalized offers. Necessary for
our legitimate interests in promoting our services, performing direct marketing
activities (taking into account your commercial relationship with one of the
AccorGroup’s entities)) and improving our services. 3 years from the last date
on which you have interacted with us in any way, if you are not a member of the
loyalty program.
6 years from the last date on which you have interacted with us in any way, if
you are a member of the loyalty program. Improving Accor SA services, in
particular:
* Carrying out surveys and analyses of questionnaires and customer comments
* Managing claims/complaints
* Offering you the benefits of our loyalty program.
Performance of contract with you (for the management of your membership in the
loyalty program)
Necessary for our legitimate interests in promoting our services, performing
direct marketing activities (taking into account your commercial relationship
with one of the AccorGroup’s entities)) and improving our services. 3 years from
the last date on which you have interacted with us in any way, if you are not a
member of the loyalty program.
6 years from the last date on which you have interacted with us in any way, if
you are a member of the loyalty program.
6 years from the date of closure of your file in case of a claim or a complaint.
Securing and enhancing your use of Accor SA websites, applications and services
by:
* Improving navigation;
* Maintenance and support; and
* Implementing security and fraud prevention.
Necessary for our legitimate interests in running our business, provision of
administration and IT services and network security to prevent fraud 13 months
from the collection of the information. Internal management of lists of
customers having behaved inappropriately during their stay at the hotel
(aggressive and anti-social behaviour, non-compliance with safety regulations,
theft, damage and vandalism or payment incidents). Necessary for our legitimate
interests in running our business and to prevent fraud and the abuse of our
property and staff. Up to 122 days from the recording of an event. Securing
payments by determining the associated level of fraud risk. As part of this
analysis, Accor SA and hotels may use the AccorGroup risk prevention service
provider to refine their analysis.
Depending on the results of the investigations carried out, AccorGroup may take
security measures, in particular AccorGroup may request the use of a different
booking channel or for the use of an alternative payment method. These measures
will have the effect of suspending the execution of the booking or, if the
result of the analysis does not guarantee the safety of the order, of cancelling
it. Fraudulent use of a means of payment leading to payment default may result
in the entry of data in the AccorGroup incident file, which may lead AccorGroup
to block future payments or carry out additional checks. Necessary for our
legitimate interests in running our business and to prevent fraud. 90 days to
our database to allow for analysis and controls and then 2 years in a separated
database used for improving the system.
In case of recording in the incident file, 2 years from recording or until
regularization of the situation if earlier. Securing properties and persons and
preventing non-payments.
For these reasons, some hotels have a feature that allow them to include in the
category of "ineffective" customers, any customer whose behaviour has been
inappropriate in the following ways: aggression and rudeness, non-compliance
with the hotel contract, failure to observe safety rules, theft, damage and
vandalism, or payment issues. The status of “ineffective” may cause the hotel
where this listing originated to refuse a customer's reservation when he/she
returns to the same hotel. Necessary for our legitimate interests in running our
business, securing properties and persons and preventing non-payments. 122 days
from registration. Using services to search for persons staying in AccorGroup
hotels in the event of serious events affecting the hotel in question (natural
disasters, terrorist attacks, etc.). Protection of the vital interests of the
guests. For the duration of the event. Conforming to any applicable legislation
(for example, storing of accounting documents), including:
* Managing requests to unsubscribe from newsletters, promotions, tourist offers
and satisfaction surveys
* Managing data subject’s requests regarding their personal data.
Necessary to comply with a legal obligation. As stipulated in the respective
country’s legislation.
7. CONDITIONS OF THIRD-PARTY ACCESS TO YOUR PERSONAL DATA
The AccorGroup operates in many countries and we endeavour to provide you with
the same services throughout the world. Thus, we have to share your personal
data with internal and external recipients subject to the following conditions:
In particular, the data related to your stays, preferences, satisfaction and, if
the case may be, your loyalty program membership are shared between the hotels
operating under the AccorGroup brands. This data is used to improve the quality
of service and your experience in each of these hotels. In this context, your
data is processed jointly by Accor SA and these hotels. In order to pursue this
legitimate interest, whilst safeguarding your rights and liberties, a specific
joint controllership agreement describes the obligations and responsibilities of
Accor SA and these hotels. You may, at any time, object to the sharing of this
data between the hotels and Accor SA by contacting the Data Privacy department
whose details appear in the clause "Your rights". You can also request a summary
of the key points of the joint controllership agreement.
1. We share your data with a number of authorised people and departments in the
AccorGroup in order to offer you the best experience in our hotels. The
following teams may have access to your data:
* Hotel staff
* Reservation staff using Accorreservation tools
* IT departments
* Commercial partners and marketing services
* Medical services if applicable
* Legal services if applicable
* Generally, any appropriate person within AccorGroup entities for certain
specific categories of personal data.
2. With service providers and partners: your personal data may be sent to a
third party for the purposes of supplying you with services and improving
your stay, for example:
* External service providers: IT sub-contractors, international call
centres, banks, credit card issuers, external lawyers, dispatchers,
printers.
* Commercial partners: Accor SA may, unless you specify otherwise to the
Data Privacy department, enhance your profile by sharing certain personal
information with its preferred commercial partners. In this case, a
trusted third party may cross-check, analyse and combine your data. This
data processing will allow Accor SA and its privileged contractual
partners to determine your interests and customer profile to allow us to
send you personalized offers.
* Social networking sites: In order to allow you to be identified on the
Accorwebsite without the need to fill out a registration form, Accor SA
has put in place a social network login system. If you log in using the
social network login system, you explicitly authorize Accor SA to access
and store the public data on your social network account (e.g. Facebook,
LinkedIn, Google, Instagram…), as well as other data stated during use of
such social network login system. Accor SA may also communicate your email
address to social networks in order to identify whether you are already a
user of the concerned social network and in order to post personalized,
relevant adverts on your social network account if appropriate.
3. With local authorities: We may be obliged to send your information to local
authorities if this is required by law or as part of an inquiry. We will
ensure that any such transfer is carried out in accordance with local
regulations.
8. PROTECTION OF YOUR PERSONAL DATA DURING INTERNATIONAL TRANSFERS
For the purposes set out in clause 6 of this charter, we may transfer your
personal data to internal or external recipients who may be in countries or
regions offering different levels of personal data protection.
Consequently, in addition to implementation of this charter, Accor employs
appropriate measures to ensure secure transfer of your personal data to an Accor
entity or to an external recipient located in a country or region offering a
different level of privacy from that in the country or region where the personal
data was collected.
Your data may be sent, in particular as part of the reservation process, to
Accorhotels located outside of the European Union, in particular in the
following countries/regions: South Africa, Algeria, Andorra, Angola, Saudi
Arabia, Argentina, Australia, Bahrain, Benin, Brazil, Cambodia, Cameroon,
Canada, Chile, China (including Taiwan Region, Hong Kong Special Administrative
Region and Macau Special Administrative Region), Colombia, South Korea, Ivory
Coast, Cuba, Egypt, United Arab Emirates, Ecuador, United States of America,
Fiji, Ghana, Guatemala, Equatorial Guinea, India, Indonesia, Israel, Japan,
Jordan, Kuwait, Laos, Lebanon, Madagascar, Malaysia, Morocco, Mauritius, Mexico,
Monaco, Myanmar, Nigeria, New Zealand, Oman, Uzbekistan, Panama, Paraguay, Peru,
Philippines, Qatar, Democratic Republic of Congo, Dominican Republic, Russia,
Senegal, Singapore, Switzerland, Chad, Thailand, Togo, Tunisia, Turkmenistan,
Turkey, Ukraine, Uruguay, Vietnam, Yemen.
Other than those that are required to carry out your reservation, data transfers
to countries having different levels of personal data protection, are regulated
by standard contractual clauses defined by the European Commission.
9. DATA SECURITY
Accor SA takes appropriate technical and organizational measures, in accordance
with applicable legal provisions (in particular: Art. 32 GDPR), to protect your
personal data against illicit or accidental destruction, alteration or loss
misuse and unauthorized access, modification 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.) to ensure the
ongoing confidentiality, integrity, availability and resilience of processing
systems and services. In relation to the submission of credit card data when
making a reservation, SSL (Secure Socket Layer) encryption technology is used to
guarantee a secure transaction. Organizational measures ensure the security of
the processing.
10. COOKIES
Accor SA uses cookies and other tracking technologies on its websites. To find
out more about how Accor uses these trackers and how to configure them, please
consult our policy on trackers using the “Cookies” link at the bottom of our web
pages.
11. YOUR RIGHTS
You have the right to obtain information about and access your personal data
collected by Accor SA, subject to applicable legal provisions. Also you have the
right to have your personal data rectified, erased or have the processing of it
restricted. Furthermore you have the right to data portability and to issue
instructions on how your data is to be treated after your death (hopefully as
late as possible!). You can also object to the processing of your personal data,
in particular to the sharing of the data related to your stays, preferences and
satisfaction between the hotels operating under the AccorGroup brands.
In the event that you wish to exercise any of your above rights, please contact
the Data Privacy department for the AccorGroup directly by sending an email
to data.privacy@accor.com or by writing to the address below:
Accor
Département Protection des Données Personnelles (Data Privacy Department)
82, rue Henri Farman -ACC 1208
CS 20077
92445 Issy-les-Moulineaux - FRANCE
For the purposes of confidentiality and personal data protection, we will need
to check your identity in order to respond to your request. In case of
reasonable doubts concerning your identity you may be asked to include a copy of
an official piece of identification, such as an ID card or passport, along with
your request. A black and white copy of the relevant page of your identity
document is sufficient.
All requests will receive a response as swiftly as possible.
You may also exercise your rights in respect of your personal data that is
stored and processed by a hotel as a data controller. To do this, you must
contact the hotel directly. You will find all necessary information to contact a
hotel on all.accor.com. If you need any assistance, please contact AccorData
Privacy Department by writing to data.privacy@accor.com or to the above postal
address.
You also have the right to lodge a complaint with a data protection authority.
For your information,
You can contact Accordata protection officer by writing to
accorhotels.dpo(at)accor.com or to the above postal address.
If you are in Australia or New Zealand and have a complaint about how we
collect, hold, use or disclose your personal data, you can also
contact privacy.au@accor.com.
12. UPDATES
We may modify this charter from time to time. Consequently, we recommend that
you consult it regularly, particularly when making a reservation at one of our
hotels.
13. QUESTIONS AND CONTACTS
For any questions concerning The Accor Group's personal data protection policy,
please contact the Data Privacy department (See clause "Your rights").
14. NOTICES RELATED TO LOCAL LAWS AND REGULATIONS
Accor SA is established in France and as such its data processing activities
first have to be compliant with the European General Data Protection Regulation
(“GDPR”). But in addition to the GDPR, there are other laws and regulations
which, depending on your specific situation, may also govern the use of your
personal data. You will find below additional information that may apply to
you.
14.1. Privacy Notice for California residents
This “Privacy Policy for California residents” is part of the Accor SA “Customer
Personal Data Protection Charter” and should therefore be read in conjunction
with it.
The California Consumer Privacy Act 2018 (“CCPA”) requires that we provide
California residents with a privacy policy that contains a comprehensive
description of our online and offline practices regarding the collection, use,
disclosure, and sale of personal information and of the rights of California
residents regarding their personal information.
The CCPA defines “Personal Information” as information that identifies, relates
to, describes, is reasonably capable of being associated with, or could
reasonably be linked, directly or indirectly, with a particular California
resident or household. In the context of this “Privacy Policy for California
residents” section, the term “Personal Information” will refer to this
information.
Accor SA may collect the categories of Personal Information as described in
section 4. What personal data is collected? of our Customer Personal Data
Protection Charter.
If you would like more details about when your Personal Information is
collected, what purposes it is collected for and how long we retain it, please
see sections below of our Customer Personal Data Protection Charter:
5. When is your personal data collected?
6. What purposes is your data collected for and how long do we retain it?
In addition to the purposes set forth in our Customer Personal Data Protection
Charter, we currently collect and have collected and “sold” (see section “Do Not
Sell” below) Personal Information for the following business or commercial
purposes:
* Auditing related to a current interaction with you and concurrent
transactions, including, but not limited to, counting ad impressions to
unique visitors, verifying positioning and quality of ad impressions, and
auditing compliance with this specification and other standards
* Detecting security incidents, protecting against malicious, deceptive,
fraudulent, or illegal activity, and prosecuting those responsible for that
activity
* Debugging to identify and repair errors that impair existing intended
functionality
* Performing services, including maintaining or servicing accounts, providing
customer service, processing reservations, verifying customer information,
processing payments, providing advertising or marketing services, or
providing analytic services
* Undertaking activities to verify or maintain the quality or safety of our
services, and to improve, upgrade, or enhance same
* Commercial purposes, such as by inducing another person to buy, join,
subscribe to, provide, or exchange property or information, or enabling or
effecting, directly or indirectly, a commercial transaction
We may share your Personal Information with internal and external recipients
subject to the conditions set forth in section 7. Conditions of third-party
access to your personal data of our Customer Personal Data Protection Charter.
The categories of third parties to whom your Personal Information may be
disclosed or “sold” (see section “Do Not Sell” below) on a need-to-know basis
are:
* Service Providers: external Service Providers;
* Other Third Parties: appropriate persons within hotels and Accor Group
entities; commercial partners; social networking sites; local authorities (if
and as legally required).
We do not knowingly “sell” (see section “Do Not Sell” below) the Personal
Information of minors under 16 years of age. For more information on data
collected in relation to persons under 16 years of age and to arrange for this
information to be deleted, see section 4. What personal data is collected? of
our Customer Personal Data Protection Charter.
RIGHT TO KNOW ABOUT PERSONAL INFORMATION
As a California resident, you have the right to request that we disclose what
Personal Information we have collected about you in the 12-month period
preceding your request, and more specifically the following:
* The categories of Personal Information we have collected about you;
* The categories of sources from which the Personal Information was collected;
* The business or commercial purpose for collecting Personal Information, and
if applicable, for “selling” Personal Information;
* The categories of Personal Information that we “sold” (if applicable) or
disclosed for a business purpose;
* The categories of third parties to whom we have “sold” (if applicable) or
disclosed Personal Information; and
* The specific pieces of Personal Information we have collected about you.
RIGHT TO REQUEST DELETION OF PERSONAL INFORMATION
As a California resident and subject to certain exemptions, you have the right
to request the deletion of your Personal Information that we collect.
HOW TO SUBMIT A REQUEST TO KNOW OR TO DELETE
You may submit a request to know or to delete:
* by sending an email to data.privacy@Accor.com
* by contacting us at 877 856 1464 (toll free), or
* by writing to the address below:
Accor SA
Département Protection des Données Personnelles (Data Privacy Department)
82, rue Henri Farman - ACC 1208
CS 20077
92445 Issy-les-Moulineaux – France
When you submit your request, we will need to verify your identity pursuant to
regulations adopted by the Attorney General and ask you to provide sufficient
information in order to allow us to reasonably verify you are the person about
whom we have collected information.
As part of our verification method, we will seek to verify the information in
your request with the Personal Information we maintain about you. We will verify
your identity either to a “reasonable degree of certainty” or a “reasonably high
degree of certainty” depending on the sensitivity of the Personal Information
and the risk of harm to you by unauthorized disclosure or deletion as
applicable. In addition, you may be required to submit a signed declaration
under penalty of perjury stating that you are the individual whose Personal
Information is being requested.
We will respond to your request to know or to delete within 45 days, unless
additional time is needed, in which case we will let you know.
AUTHORIZED AGENTS
The CCPA allows California residents to designate an authorized agent to
exercise their rights. If you submit a request via an authorized agent acting on
your behalf, we will require this authorized agent to provide proof that you
gave the agent signed permission to submit the request.
“DO NOT SELL MY PERSONAL INFORMATION”: RIGHT TO OPT-OUT OF THE SALE OF PERSONAL
INFORMATION
Under the CCPA, the disclosure of Personal Information to a third party for
monetary or other consideration of value can be considered as a "sale", the term
“sale” being broadly defined.
The CCPA defines a “sale” as selling, renting, releasing, disclosing,
disseminating, making available, transferring, or otherwise communicating
orally, in writing, or by electronic or other means, a California resident’s
Personal Information to another business or a third party for monetary or other
valuable consideration.
The CCPA gives residents of California the right to opt out of the "sale" of
their Personal Information.
We do not “sell” customers’ personal data in the strictest sense of the term.
However, we offer Californian residents the opportunity to exercise this right,
should one of our business practices be considered a “sale” within the meaning
of the CCPA.
To opt-out of our use of third-party advertising cookies, see the “COOKIES”
section below.
You may submit a request to opt-out of the sale of your Personal Information:
* by using this form Do Not Sell My Personal Information
* by sending an email to data.privacy@accor.com,
* by contacting us at 877 856 1464 (toll free),
* by writing to the address below:
Accor SA
Département Protection des Données Personnelles (Data Privacy Department)
82, rue Henri Farman - ACC 1208
CS 20077
92445 Issy-les-Moulineaux – France
COOKIES
On the Accor websites, Accor and its partners store or retrieve information on
your device in order to: operate the websites and provide you with the services
you request (these cannot be rejected), enhance and customize website
functionalities, measure website audience and performance, profile your
interests to provide you with relevant advertising and allow you to interact
with social networks.
You can modify your choices at any time by clicking on the "Cookies" link at the
bottom of the respective website.
Some internet browsers incorporate a “Do Not Track” feature that signals to
websites you visit that you do not want to have your online activity tracked.
Given that there is not a uniform way that browsers communicate the “Do Not
Track” signal, the websites do not currently interpret, respond to or alter
their practices when they receive “Do Not Track” signals.
FINANCIAL INCENTIVES AND NON-DISCRIMINATION
We will not discriminate against you for exercising any of your CCPA rights.
Unless permitted by the CCPA, we will not:
* Deny you goods or services;
* Charge you different prices or rates for goods or services, including through
granting discounts or other benefits, or imposing penalties;
* Provide you a different level or quality of goods or services;
* Suggest that you may receive a different price or rate for goods or services
or a different level or quality of goods or services.
However, as permitted by and in compliance with the CCPA, we may offer you
certain financial incentives that can result in a different price, rate, level,
or quality of services. Any financial incentive we offer will be reasonably
related to the value of your Personal Information and your participation will be
subject to any applicable terms. Participation in a financial incentive program
requires your prior opt-in consent, which you may revoke at any time.
SHINE THE LIGHT LAW
If you are a California resident, California Civil Code § 1798.83 permits you to
request information regarding the disclosure of your personal information by us
to third parties for the third parties’ direct marketing purposes (as those
terms are defined in that statute).
This information is as follows: in accordance with European regulations, we will
only disclose your personal information to third parties for the third parties’
direct marketing purposes with your express prior consent and a prior
information on the third parties your information will be disclosed to.
14.2 Privacy Notice for Nevada residents
Nevada law allows Nevada residents to opt-out of the sale of certain types of
personal information. Subject to several exceptions, Nevada law defines “sale”
to mean the exchange of certain types of personal information for monetary
consideration to another person. We do not currently sell personal information
as defined in the Nevada law. However, if you are a Nevada resident, you still
may submit a verified request to opt-out of sales. Opt-out requests may be sent
to data.privacy@accor.com.
14.3 Privacy Notice for Chinese residents
14.3.1 Introduction
This Privacy Notice for China is part of the Accor SA "Customer Personal Data
Protection Charter" and should be read in conjunction with it. This notice is
made pursuant to the Personal Information Protection Law of the People's
Republic of China ("PIPL") and applies to our personal information processing
activities:
* in the People's Republic of China (which, for the purposes of this notice
only, excludes the Hong Kong SAR, Macau SAR and Taiwan China) ("China"); and
* outside China for the purposes of providing products and services to people
in China.
For the above personal information processing activities, if there is any
inconsistency between this Privacy Notice for China and the above Customer
Personal Data Protection Charter, this Privacy Notice for China prevails.
14.3.2 Collection, Use and Retention of Personal Information
The PIPL defines "Personal Information" as any kind of information related to an
identified or identifiable natural person as electronically or otherwise
recorded, excluding information that has been anonymized. Processing activities
include the collection, storage, use, processing, transmission, provision,
disclosure, and deletion of personal information.
To know more about how we collect, use and retain your personal information,
please read the following sections in the Customer Personal Data Protection
Charter:
4. WHAT PERSONAL DATA IS COLLECTED?
5. WHEN IS YOUR PERSONAL DATA COLLECTED?
6. WHAT PURPOSES IS YOUR DATA COLLECTED FOR AND HOW LONG DO WE RETAIN IT?
The PIPL gives "Sensitive Personal Information" extra protection and defines it
as information that, once leaked or illegally used, will easily lead to the
infringement of human dignity or harm to the personal or property safety of a
natural person. Accor will only process Sensitive Personal Information if there
is a specified purpose, necessity and strict measures for its protection.
Sensitive Personal Information we collect may include information such as
transaction information, ID card or passport related information, location
information and stay records.
The Personal Information of minors under 14 is also Sensitive Personal
Information in China, which we normally only collect from parents or guardians
and is limited to their name, nationality and date of birth. We would be
grateful if you could ensure that your children do not send us any personal
information without your consent (particularly via the Internet). If such
information is sent, you can contact the Data Privacy department to arrange for
this information to be deleted.
14.3.3 Justification of Processing for China
We only process Personal Information if there is a "lawful basis", including:
* Your consent;
* The processing is necessary for the conclusion or performance of a contract
to which you are a contracting party;
* The processing is necessary for performing a statutory responsibility or
statutory obligation;
* The processing is necessary for responding to a public health emergency, or
protecting the life, health or property of a natural person in an emergency;
* The personal information is processed within a reasonable manner to carry out
any news reporting, supervision by public opinions or any other activity for
public interest purposes;
* The personal information has already been disclosed by the individual or
otherwise legally disclosed and is processed within a reasonable scope and in
accordance with the PIPL; or
* Any other circumstance as provided by law or administrative regulations of
China.
All our processing in China is conducted under one of the above lawful bases as
described in section 6. What purposes is your data collected for and how long do
we retain it? in the "Customer Personal Data Protection Charter" except for the
following activities which are conducted under the lawful bases described in the
table below:
Purpose/Activity Lawful basis for processing Use a trusted third party to
cross-check, analyze and combine your collected data at the time of booking or
at the time of your stay, in order to determine your interests and develop your
customer profile and to allow us to send you personalized offers. Consent
Securing and enhancing your use of Accor SA websites, applications and services
by:
* Improving navigation;
* Maintenance and support; and
* Implementing security and fraud prevention.
The conclusion or performance of a contract to which you are a contracting party
Internal management of lists of customers having behaved inappropriately during
their stay at the hotel (aggressive and anti-social behavior, non-compliance
with safety regulations, theft, damage and vandalism or payment incidents). The
conclusion or performance of a contract to which you are a contracting party
Securing payments by determining the associated level of fraud risk. As part of
this analysis, Accor SA and hotels may use the AccorGroup risk prevention
service provider to refine their analysis.
Depending on the results of the investigations carried out, AccorGroup may take
security measures, in particular AccorGroup may request the use of a different
booking channel or for the use of an alternative payment method. These measures
will have the effect of suspending the execution of the booking or, if the
result of the analysis does not guarantee the safety of the order, of cancelling
it. Fraudulent use of a means of payment leading to payment default may result
in the entry of data in the AccorGroup incident file, which may lead AccorGroup
to block future payments or carry out additional checks. The conclusion or
performance of a contract to which you are a contracting party Securing
properties and persons and preventing non-payments.
For these reasons, some hotels have a feature that allow them to include in the
category of "ineffective" customers, any customer whose behavior has been
inappropriate in the following ways: aggression and rudeness, non-compliance
with the hotel contract, failure to observe safety rules, theft, damage and
vandalism, or payment issues. The status of "ineffective" may cause the hotel
where this listing originated to refuse a customer's reservation when he/she
returns to the same hotel. The conclusion or performance of a contract to which
you are a contracting party Using services to search for persons staying in
AccorGroup hotels in the event of serious events affecting the hotel in question
(natural disasters, terrorist attacks, etc.). Responding to a public health
emergency, or for protecting the life, health or property safety of a natural
person in the case of an emergency;
14.3.4 System Permissions
When you use our App and Weixin Mini-program, we will seek system permissions on
your device to ensure the functionality of our products/services and their safe
and stable operation as follows:
Name of system permissions Description Purposes Applicable platforms
android.permission.ACCESS_NETWORK_STATE View network status Allows an
application to view the status of all networks. Android
android.permission.INTERNET Full internet access Allows an application to create
network sockets. Android android.permission.WAKE_LOCK Prevent phone from
sleeping Allows an application to prevent the phone from going to sleep. Android
android.permission.ACCESS_WIFI_STATE View Wi-Fi status Allows an application to
view the information about the status of Wi-Fi. Android
com.google.android.c2dm.permission.RECEIVE C2DM permissions Permission for cloud
to device messaging. Android android.permission.RECEIVE_BOOT_COMPLETED
Automatically start at boot Allows an application to start itself as soon as the
System has finished booting. Android android.permission.FOREGROUND_SERVICE
Allows a regular application to use service.startforeground Allows a regular
application to use service.startforeground. Android
com.google.android.finsky.permission.BIND_GET_INSTALL_REFERRER_SERVICE Get APP
installation information for notification pushing To get information about the
origin of the installation of the APP by the user in order for the push
notification system to reach Google servers and push the notification on the
right device. Android android.permission.VIBRATE Control device vibration Allows
the application to control device vibration. Android
com.accor.appli.hybrid.inhouse.batch.permission.INTERNAL_BROADCAST Push
notifications To request user authorization to send him/her push notifications
Android android.permission.READ_EXTERNAL_STORAGE Read external storage contents
Allows an application to read external storage. Necessary to install the
application on a device without internal memory. Android
android.permission.WRITE_EXTERNAL_STORAGE Read/modify/delete external storage
contents Allows an application to write to external storage. Necessary to
install the application on a device without internal memory. Android
android.permission.READ_PHONE_STATE Read phone state and identity Allows the
application to access the phone features of the device. Feature to call Accor
customer Help Center in the app. Android android.permission.BLUETOOTH Create
Bluetooth Connections Allows applications to connect to paired Bluetooth
devices. Necessary to have the Accor Hotel Keyless functionality (keyless door
lock). Android android.permission.BLUETOOTH_ADMIN Bluetooth Administration
Allows applications to discover and pair Bluetooth devices.
Necessary to have the Accor Hotel Keyless functionality (keyless door lock).
Android android.permission.ACCESS_FINE_LOCATION Fine (GPS) location Access fine
location sources, such as the GPS on the phone, where available. Necessary for
the geolocation hotel search feature (find a hotel around me). Android
android.permission.ACCESS_COARSE_LOCATION Coarse (networkbased) location Access
coarse location sources, such as the mobile network database, to determine an
approximate phone location, where available. Necessary to define the language to
be displayed in the application. Android NSCalendarsUsageDescription Calendar
Add booking to calendar iOS NSMicrophoneUsageDescription Microphone Voice Search
feature iOS NSLocationAlwaysUsageDescription Location Find hotels + taxi or
chauffeur-driven car iOS NSLocationWhenInUseUsageDescription Location Find
hotels + taxi or chauffeur-driven car iOS NSSpeechRecognitionUsageDescription
Speech recognition Voice search feature iOS NSUserTrackingUsageDescription
Tracking (IDFA/ATT) Tracking. Necessary because of mandatory IDFA / ATT Apple’s
rule. Consent is needed prior sending identifier to partners. iOS Push
notification Push iOS Background app refresh Allow the application to be
refreshed in background. Can be turned off in iOS settings iOS
NSBluetoothAlwaysUsageDescription Bluetooth Necessary to have the Accor Hotel
Keyless functionality (keyless door lock) iOS Share Profile (Nickname, Gender,
region, Country, Image/Avatar) Avoid to fill the same information in a form in
Mini-Program Weixin Mini-Program Share Mobile number Automatically fill in the
mobile phone number, which is used to send SMS notifications such as room
information. Weixin Mini-Program Share WeChat Chat feature Activation of chat
notification. Weixin Mini-Program Share WeChat Pay Payment through WeChat.
Weixin Mini-Program Share Geo fencing Geo localization, necessary for the
geolocation hotel search feature (find a hotel around me). Weixin Mini-Program
Please note that by turning on any of the permissions, you authorize us to
collect and use the relevant personal information to provide you with the
corresponding services, and by turning off any of the permissions, you cancel
your authorization, and we will no longer collect and use the relevant personal
information based on the corresponding permissions, nor can we continue to
provide you with the services corresponding to the permissions. Your decision to
cancel your authorization will not affect any previous collection and use of
information based on your authorization. You can manage your authorizations
through your device settings.
14.3.5 Conditions of Third-Party Access to Your Personal Information
Entrusted Personal Information Processing
In order to provide certain services to you, we may need to entrust a service
provider to process some of your personal information. We will enter into strict
confidentiality agreements and personal information protection clauses with such
entrusted parties, requiring them to process and protect your personal
information in accordance with our requirements, this Privacy Notice and any
other relevant confidentiality and security requirements.
Providing Personal Information to Third-Party Service Providers
In order to give you a better service experience, we provide you with access to
a variety of products or services provided by third party service providers.
When you use these services, we may, with your explicit authorization or
consent, provide or share your personal information for the purposes described
in the Customer Personal Data Protection Charter among members of the Accor
Group or third party service providers, including:
* Accor SA subsidiaries;
* Franchised and managed hotels;
* Master franchisees;
* Spa, restaurant, health club, concierge and other outlets at properties to
provide you with services;
* Loyalty programs partners;
* AccorPlus loyalty program;
* Travel agencies and distributions systems operators;
* Payment services providers;
* Travel insurance partners;
* Advertising network and analytics providers for Accor's website and mobile
applications.
Third-Party SDKs We Use
Our website, App and Mini-program may have integrated third-party software
development kits (SDKs) to ensure their stable operation and to provide relevant
services to you. If you want to know more information about the third-party SDKs
we use, please see the following SDK list:
Number Name of the SDK SDK service provider Purposes of processing personal
information Personal information collected via SDK SDK service provider's
privacy policy 1 Firebase Google, Inc. User tracking and engagement. No personal
information, only anonymous navigation data.
https://firebase.google.com/support/privacy 2 Firebase Crashlytics Google, Inc.
User crash monitoring. No personal information, only anonymous data about crash:
device, OS version https://firebase.google.com/support/privacy 3 Firebase Remote
Config Google, Inc. Enable feature without submitting a new app on the store. No
personal information, only anonymous data: app version
https://firebase.google.com/support/privacy 4 Firebase Analytics Google, Inc.
User tracking and engagement. No personal information, only anonymous navigation
data: screen view, click, time on each page
https://firebase.google.com/support/privacy 5 GoogleAnalytics Google, Inc. User
tracking and engagement. No personal information, only anonymous data
https://developers.google.com/analytics/
devguides/collection/protocol/policy 6 GoogleTagManager Google, Inc. Managing
tracking plan in the app No personal information, only anonymous data
https://marketingplatform.google.com/
about/analytics/tag-manager/use-
policy/#:~:text=If%20You%20have%
203rd%20Party,responsible%20for%203
rd%20Party%20Tags.&text=to%20upload
%20any%20data%20to,such%20information
%20by%20Google%2C%20or 7 Branch Branch Metrics, Inc. Deeplink handling. No
personal data https://branch.io/policies/privacy-policy/ 8 Batch IMEDIAPP SA
User push notification management. Device installation ID
https://batch.com/privacy-policy 9 BatchExtension IMEDIAPP SA Custom push
notification Device installation ID https://batch.com/privacy-policy 10
Dynatrace Dynatrace LLC Application API call tracking, used for stats and API
debugging. Anonymous data, except PMID (user id). With this PMID we can show:
-App version
-User actions
-User crashs
-Device
-OS version
-IP Adress https://www.dynatrace.com/company/
trust-center/privacy/ 11 One Trust One Trust, LLC. User consent management
platform. Cookie consent for one device / no user data
https://www.onetrust.com/privacy-notice/ 12 Alamofire Open Source
(https://github.com/Alamofire/Alamofire) HTTP networking library for iOS No
personal information NA
13 Apollo MG Code EPE Android Graph QL API client No personal information
https://www.apollographql.com/
privacy-policy/ 14 Content Square Content Square, Inc. Web analytics feature No
personal information, only anonymous data
https://contentsquare.com/privacy-center/privacy-policy/ 15 Materiel Design
Google User Interface Design Tool No personal information NA 16 Kingfisher Open
Source (https://github.com/onevcat/Kingfisher/) Library for downloading and
caching images from the web No personal information NA 17 FSCalendar Open source
(https://github.com/onevcat/Kingfisher/FSCalendar) Library for downloading and
caching images from the web No personal information NA 18 Threat Matrix
LexisNexis Risk Solutions Inc. Security analytics. No personal information
https://risk.lexisnexis.com/group/privacy-policy 19 Cardinal Commerce Visa, Inc.
PSD2 Banking authorisation management. No personal information
https://usa.visa.com/legal/
privacy-policy.html 20 Imperva Imperva, Inc. Bot detection / security No
personal information https://www.imperva.com/trust-center/privacy-statement/ 21
Karhoo Flit Technologies Ltd Chauffeur driven car booking SDK. No personal
information https://www.karhoo.com/
privacy-policy/ 22 Stay My Way Stay My Way Contactless door opening. PMID /
Reservation ID NA 23 Debug Tool Kit Open Source
(https://github.com/dbukowski/DBDebugToolkit) Access to debugging logs No
personal information, only anonymous data NA 24 Nimble Open Source
(https://github.com/Quick/Nimble ) express the expected outcomes of Swift or
Objective-C expression No personal information NA 25 Facebook Meta, Inc. User
tracking, such as Firebase, for Facebook purposes PMID (user identifier)
https://www.facebook.com/policy.php 26 Baidu Maps Baidu, Inc. Mapping
application for China. No personal information http://privacy.baidu.com/policy
27 Retrofit2 Open source (https://square.github.io/retrofit/ ) Android REST API
client. No personal information NA
14.3.6 Protection of Your Personal Data During International Transfers
We use central systems hosted in France to process your booking, stays and
membership information. Your data may be sent, in particular as part of the
reservation process, to Accor hotels located in the following countries or
regions: Austria, Belgium, Bulgaria, Croatia, Republic of Cyprus, Czech
Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Ireland,
Italy, Latvia, Lithuania, Luxembourg, Malta, Netherlands, Poland, Portugal,
Romania, Slovakia, Slovenia, Spain, Sweden, Iceland, Liechtenstein, Norway,
South Africa, Algeria, Andorra, Angola, Saudi Arabia, Argentina, Australia,
Bahrain, Benin, Brazil, Cambodia, Cameroon, Canada, Chile, Colombia, South
Korea, Ivory Coast, Cuba, Egypt, United Arab Emirates, Ecuador, United States of
America, Fiji, Ghana, Guatemala, Equatorial Guinea, Hong Kong SAR, India,
Indonesia, Israel, Japan, Jordan, Kuwait, Laos, Lebanon, Macao SAR, Madagascar,
Malaysia, Morocco, Mauritius, Mexico, Monaco, Myanmar, Nigeria, New Zealand,
Oman, Uzbekistan, Panama, Paraguay, Peru, Philippines, Qatar, Democratic
Republic of Congo, Dominican Republic, Russia, Senegal, Singapore, Switzerland,
Chad, Thailand, Togo, Tunisia, Turkmenistan, Turkey, Ukraine, United Kingdom
Uruguay, Vietnam, Yemen, Taiwan China.
We will work with these personal information recipients located outside China
through agreements and other means that require them to take necessary personal
information security measures and clarify their personal information protection
responsibilities to ensure that your personal information receives adequate and
uniform protection in China and countries or regions outside China.
14.3.7 Data Security
We take appropriate technical and organizational measures, in accordance with
applicable legal provisions, to protect your personal information against
unlawful or accidental destruction, alteration, loss, misuse, access,
modification or disclosure. For more information, please read 9. DATA SECURITY
in the Customer Personal Data Protection Charter.
14.3.8 Your Rights
In addition to your rights under 11. YOUR RIGHTS in "Customer Personal Data
Protection Charter", unless otherwise provided by law or administrative
regulations of China, you also have the following rights:
* the right to be informed about and the right to decide on the processing of
your personal information, as well as the right to restrict or deny us from
processing of your personal information;
* the right to access or make copies of your personal information from us;
* the right to have your personal information transferred to another entity
that you designate, provided that the conditions prescribed by the national
cybersecurity authority are met;
* the right to ask us to correct or complete your personal information;
* the right to withdraw your consent if our processing activities are based on
your consent;
* the right to ask us to explain the rules of processing your personal
information;
* the right to ask us to explain decisions we make through automated
decision-making, if the decision has a material impact on your rights and
interests, as well as the right to refuse the making of decisions by us
solely by means of automated decision-making.
As introduced in 11. YOUR RIGHTS in "Customer Personal Data Protection Charter"
you may contact the Data Privacy department for the AccorGroup or the hotel
directly in the event that you wish to exercise any of your rights. In addition,
if you use our App you can also correct, complete or delete some of your
personal information by clicking on the “Account” button, then clicking on
“Advanced settings” and then on “Request the deletion of your account”.
We will deal with your requests to exercise your rights under applicable Chinese
laws or administrative regulations promptly and within 15 working days.
14.3.9 Questions and Contacts
In the event that you have any questions about your personal information or wish
to exercise any of your rights, please contact the AccorGroup Data Privacy
department directly by sending an email to data.privacy@accor.com or by writing
to the address below:
Accor
Département Protection des Données Personnelles (Data Privacy Department)
82, rue Henri Farman -ACC 1208
CS 20077
92445 Issy-les-Moulineaux - FRANCE
Alternatively, if you wish to contact our people in China, please contact:
Email: China.DataPrivacy.Team@accor.com
Address：AAPC (Shanghai) Co., Ltd,
12F, Tower C, The PLACE, No.150 Zun Yi Road, Shanghai 200051, P R. China
--------------------------------------------------------------------------------
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