International Hotel Supply Company respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and explains your privacy rights and how the law protects you.
This privacy notice is provided in a layered format so you can click through to the specific areas set out below
1. IMPORTANT INFORMATION
This privacy notice aims to give you information on how International Hotel Supply Company collects and processes your personal data through your use of this website, including any data you may provide through this website when you register for our services.
This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.
CONTROLER
International Hotel Supply Company is made up of different legal entities. This privacy notice is issued on behalf of the International Hotel Supply Company Group so when we mention American Hotel Register Company, we are referring to the relevant company in the Group responsible for processing your data. International Hotel Supply Company is the controller of your data for when you purchase a product with us.
We have appointed a data protection manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including requests to exercise your legal rights, including the right to be forgotten, please contact the data privacy manager using the details set out below.
Mrs. Diana van der Blom
gdpr@internationalhotel.com
You have the right to make a complaint at any time to Dutch Data Protection Authority (Dutch DPA) for data protection issues (https://autoriteitpersoonsgegevens.nl/en). We would, however, appreciate the chance to deal with your concerns before you approach the Dutch DPA so please contact us in the first instance.
CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES
The data protection law will change on May 25, 2018. Although this privacy notice sets out most of your rights under the new laws, we may not yet be able to respond to some of your requests (for example, a request for the transfer of your personal data) until June 2018 as we are still working towards getting our systems ready for some of these changes.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
THIRD-PARTY LINKS
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
2. THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes [first name, last name, username or similar identifier and title]
- Contact Data includes [billing address, delivery address, email address and telephone numbers]
- Financial Data includes [bank account and payment card details]
- Transaction Data includes [details about payments to and from you and other details of products and services you purchased from us]
- Technical Data includes [internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website]
- Profile Data includes [your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses]
- Usage Data includes [information about how you use our website, products and services]
- Marketing and Communication Data includes [your preferences in receiving marketing from us and our third parties and your communication preferences]
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We DO NOT collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data.
IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
3. HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through
- Direct Interactions. You may give us your identity, contact and financial data by filling in forms or by corresponding with us by phone, email or otherwise. This includes data you provide when you:
- Create an account on our website;
- Subscribe to our services;
- Request marketing to be sent to you;
- Give us feedback
- Automated Technologies or Interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy for further details
- Third Parties or Publicly Available Sources. We may receive personal data about you from various third parties and public sources.
4. HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for legitimate interest (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email. You have the right to withdraw consent to marketing at any time by contacting us at gdpr@internationalhotel.com.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out below, in table format, a description of all the ways we plan to use your personal data, and the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.
| Purpose/Activity | Type of Data | Lawful Basis for Processing |
|---|---|---|
| Customer Information | Identity & Contact | Performance of a contract with you |
To process and deliver your order including:
| Identity, Contact, Financial, Transaction, Marketing and Communications | Performance of a contract with you and necessary for our legitimate interests (to recover debts due to us) |
To manage our relationship with you which will include:
| Identity, Contact, Profile, Marketing and Communications | Performance of a contract with you, necessity to comply with a legal obligation and necessary for our legitimate interest (to keep our records updated and to study how customers use our products/services) |
| To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data | Identity, Contact & Technical | Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security and to prevent fraud) |
| To use data analytics to improve our website, products/services, marketing, customer relationships and experiences | Technical & Usage | Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and inform our marketing strategy) |
| To make suggestions and recommendations to you about goods or services that may be of interest to you | Identity, Contact, Technical, Usage & Profile | Necessary for our legitimate interests (to develop our products/services and grow our business) |
MARKETING
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
PROMOTIONAL OFFERS FROM US
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and, in each case, you have not opted out of receiving that marketing.
COOKIES
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see Cookie Policy
5. DISCLOSURES OF YOUR PERSONAL DATA
We may need to share your personal data with the parties set out below for the purposes set out in the table above in section 4.
- Internal Third Parties
- External Third Parties
- Thirds parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. INTERNATIONAL TRANSFERS
We share your personal data within American Hotel Register Company. This will involve transferring your data outside the European Economic Area (EAA). We ensure your personal data is protected by requiring all our group companies to follow the same rules when processing your personal data as we do.
7. DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on your instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. DATA RETENTION
HOW LONG WILL WE USE YOUR PERSONAL DATA FOR?
We will only retain your personal data for as long as necessary to fulfill the purpose we collected it for, including for the purpose of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances, you can ask us to delete your data: see Request Erasure in section 9 for further information.
9. YOUR LEGAL RIGHTS
Under certain circumstances you have the rights under data protection laws in relation to your personal data. Your rights include the following requests:
- Request access to your personal data
- Request correction of your personal data
- Request erasure of your personal data – “Right to be Forgotten”
- Object to processing of your personal data
- Request restriction of processing your personal data
- Request transfer of your personal data
- Right to withdraw consent
If you wish to exercise any of the rights set out above, please contact us at gdpr@internationalhotel.com.
WHAT WE MAY NEED FROM YOU
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
TIME LIMIT TO RESPOND
We try to respond to all legitimate requests within one month (30 days). Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated