Main terms used in the Policy:
Hotel - the organization providing hotel services to the client;
Client - an individual, a consumer of hotel services, the subject of personal data;
Hotel services - actions of the hotel to accommodate customers in hotel, as well as other activities related to accommodation, which includes basic and additional services provided to the client;
Personal data - any information provided by you when interacting with us, for example through our Website or when calling us, or data which is collected about you through the use of you Website and allowing you to be identified personally, either directly (e.g. your name) or indirectly, because the data such as your name, identification number, location data, online identifier (e.g. telephone number) serves as an identifier of an individual person.
Processing of personal data - actions (operations) with personal data, including collection, systematization, accumulation, storage, clarification (update, change), use, distribution (including transfer), depersonalization, blocking, destruction of personal data;
Distribution of personal data - actions aimed at the transfer of personal data to a certain circle of persons (transfer of personal data) or to familiarize with the personal data of an unlimited number of persons, including the disclosure of personal data in the media, placement in information and telecommunication networks or providing access to personal data in any other way;
Use of personal data - actions (operations) with personal data performed by the operator in order to make decisions or perform other actions that generate legal consequences with respect to the personal data subject or other persons or otherwise affect the rights and freedoms of the personal data subject or other persons;
Confidentiality of personal data - mandatory requirement for the operator or other person who has access to personal data do not to allow their distribution without the consent of the subject of personal data or other legal grounds;
Data operator — a physical or legal person, public authority, agency or other institution that independently or together with other persons determines the purposes and methods of personal data processing;
The General Data Protection Regulation (EU) 2016/679 ("GDPR") is a regulation in EU law on data protection and privacy for all individuals citizens of the European Union (EU) and the European Economic Area (EEA). It also addresses the export of personal data outside the EU and EEA areas.
Data processor — a physical or legal person, public authority, agency or other institution processing personal data on behalf of the data operator;
Data recipient — a physical or legal person, public authority, agency or other institution to which personal data is provided, regardless of whether it is a third party;
Third party — a physical or legal person, public authority, agency or institution that is not a subject, controller, data processor, as well as persons who are authorized to process personal data by direct order of the operator or data processor.
Supervisory authority — an independent public authority established by the relevant EU country under article 51 of the GDPR.
This Policy establishes the procedure of processing personal data of clients to for whom the hotel provides accommodation and additional services at the hotel.
The purpose of the Policy is to ensure the protection of human rights and freedoms in the processing of personal data.
Personal data are processed in order to fulfill the contract for the provision of accommodation services, one of the parties of which is the client. The hotel collects data only to the extent necessary to achieve this goal.
Personal data can not be used for the purpose of property and moral harm to citizens, difficulties in the implementation of the rights and freedoms of citizens of the Russian Federation.
Content and personal data receipt
Personal data collected and processed by the hotel include:
• personal data (surname, name, patronymic, date, month, year of birth, etc.);
• passport data;
• registration address;
• residence address;
• contact phone number;
• email address;
• type, number and validity of the payment card;
• for foreign citizens visa and migration card details;
• the state number of the client's vehicle when using hotel Parking;
• other information required by the hotel in connection with the conduct of statutory activities, as well as the implementation of contractual relations for the provision of hotel services.
All personal data are received by the hotel staff directly from the subject of personal data — customers and only with their personal consent. The client decides to provide his personal data and consent to their processing by his will and in his interest, confirming this fact with his signature in the registration card, which is issued at the reception and accommodation of the client in the hotel. If the client's personal data can only be obtained from a third party, the client must be notified in advance and written consent must be obtained from him to receive data from a third party.
We collect Personal Data in a variety of ways:
Online Services. We collect Personal Data when you make a reservation, purchase goods and services from our Websites or Apps, communicate with us, or otherwise connect with us or post to social media pages, or sign up for a newsletter or participate in a survey, contest or promotional offer.
Property Visits and Offline Interactions. We collect Personal Data when you visit our hotel or use on-property services such as restaurants, concierge services, and fitness center. We also collect Personal Data when you attend promotional events that we host or in which we participate, or when you provide your Personal Data to facilitate an event.
Customer Care Centers. We collect Personal Data when you make a reservation over the phone, communicate with us by email, fax or via online chat services or contact customer service. These communications may be recorded for purposes of quality assurance and training.
Strategic Business Partners. We collect Personal Data from companies with whom we partner to provide you with goods, services or offers based upon your experiences at our hotel, or that we believe will be of interest to you (“Strategic Business Partners”). Examples of Strategic Business Partners include on-property outlets, travel and tour partners, time share partners, car rental providers and travel booking platforms. Strategic Business Partners are independent from Peter I hotel.
Your browser or device. We collect certain data through your browser or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system name and version, device manufacturer and model, language, internet browser type and version and the name and version of the Online Services (such as the Apps) you are using. We use this data to ensure that the Online Services function properly.
Your use of the Apps. We collect certain data when you download and use an App, such as App usage data, the date and time the App on your device accesses our servers and what data and files have been downloaded to the App based on your device number.
Cookies. We collect certain data from cookies, which are pieces of data stored directly on the computer or mobile device that you are using. Cookies allow us to collect data such as browser type, time spent on the Online Services, pages visited, referring URL, language preferences, and other aggregated traffic data. We use the data for security purposes, to facilitate navigation, to display data more effectively, to collect statistical data, to personalize your experience while using the Online Services and to recognize your computer to assist your use of the Online Services. We also gather statistical data about use of the Online Services to continually improve design and functionality, understand how they are used and assist us with resolving questions.
Pixel Tags and other similar technologies. We collect data from pixel tags (also known as web beacons and clear GIFs), which are used with some Online Services to, among other things, track the actions of users of the Online Services (including email recipients), measure the success of our marketing campaigns and compile statistics about usage of the Online Services.
Your IP Address. We collect your IP address, a number that is automatically assigned to the computer that you are using by your Internet Service Provider (ISP). An IP address is identified and logged automatically in our server log files when a user accesses the Online Services, along with the time of the visit and the pages that are visited. We use IP addresses to calculate usage levels, diagnose server problems and administer the Online Services. We also may derive your approximate location from your IP address.
Aggregated Data. We may aggregate data that we collected and this aggregated data will not personally identify you or any other user.
Processing and storage of personal data
The hotel processes personal data in the interests of customers: to obtain, organize, accumulate, store, clarify (update, change), use, distribute, depersonalize, block, destruct and protect from unauthorized access to personal data of customers;
The consent of the clients to process personal data is not required, because the processing of personal data is carried out for the purpose of execution of the agreement, one of the parties of which is the subject of personal data – the client;
Processing of personal data of customers can only be accessed by hotel staff, allowed to work with the personal data of the client and signed a Non-disclosure agreement on personal data of the client.
The list of hotel employees, which have access to personal data of customers, is settled by the order of the General Manager of Peter I hotel;
Personal data hard copies are stored in front office department of the hotel;
Personal data of clients in electronic form are stored in the local computer network of the hotel in electronic folders, files in personal computers of employees admitted to the processing of personal data of Clients in their workplaces, databases of information systems of personal data.
Transfer of clients ' personal data
The hotel has the right to provide or transfer customers ' personal data to third parties in the following cases:
• if disclosure is required to comply with the law;
• to assist in investigations conducted by law enforcement or other government agencies to protect the legitimate rights of the customer and the hotel.