A. OUR ROLE IN YOUR PRIVACY

If you are a Spinola Hotel customer then you most likely have provided us, and will provide us in the future, with your personal data.

It is our job to inform you on our data processing activities, and handle your personal data lawfully an securely.

B. YOUR ROLE IN YOUR PRIVACY

It’s in your interest to read this policy to be informed about our data processing activities. You should know that by handing over your data to us, you are authorising us to process it on your behalf and in accordance to this Privacy policy

C. WHEN AND HOW WE COLLECT YOUR DATA

Data is collected from the first moment you interact with and affiliated websites. Some data is collected automatically and some manually submitted.

The only data collected automatically are through the cookies on our website, so please read the cookie policy.

You give us the rest of the data when you make certain payments, when you opt to fill in the data collection cards (located at our stores) for marketing material, when you create a profile (account) on one of our sites or when you sign up to a newsletter. Occasionally you may give us your data when you contact us via email, phone calls or even on one of our social media pages.

D. WHAT DATA DO WE COLLECT

Contact details:

Name and surname, email address, phone number, shipping and billing addresses, etc.

Sensitive data:

We do not process any sensitive (special categories) of personal data.

Financial information:

Bank account number, credit/debit card details, etc.

Data that identifies you:

IP address, login information, preferred settings, time settings, authentication details, etc.

Data on how you use Spinola Hotel:

Cookie data, website statistics and analytics. Please read the cookie data for the full list.

How and why we use your data

The new General Data Protection Regulation changes the way we may process personal data. It must be processed for a legitimate purpose and can only be processed lawfully. We obtain your personal data for the following purposes:

Online accounts

To be able to place orders and purchase online, we must obtain a certain amount of data to verify your legitimacy and payment transactions.

Legal basis for processing: Legitimate interest, contractual obligation, legal obligation.

General queries and customer support

The only information we require of you when managing your queries are basic contact details and your message. We need this to be able to reply and solve any issues you might have.

Legal basis for processing: Legitimate interest.

Marketing purposes

You may opt to us sending you promotions, marketing material and newsletters. We use this data to understand customer behaviour, communicate product information, reward customers for their business and extend VIP invitations. To do this we require some basic contact information. We will only process your data for marketing if we have obtained your consent to do so.

Legal basis for processing: Consent.

Improving Spinola Hotel Group

We strive to constantly and consistently improve our service and enhance your experience, so we gather data to help us do this, through customer comments,

Legal basis for processing: Legitimate interest.

What do these legal basis’ mean?

Legitimate interest:

Processing data is necessary for our legitimate interest to fulfil our services and satisfy our customers.

Contractual obligation:

Processing data is necessary to fulfil the performance of a contract.

Legal obligation:

Processing data is necessary under applicable law.

Consent:

Processing data is only allowed after obtaining our customers’ consent.

E. YOUR PRIVACY CHOICES AND RIGHTS

You can choose not to provide us with personal data.

If you choose to do this, you are still allowed to use our website, but we might not be able to resolve any requests or satisfy a an order/purchase.

You can turn off cookies in your browser by changing its settings.

You can block cookies by changing some settings in your browser, and you can also delete certain cookies. This will still allow you to use our website, but you might not be able to access its full functionality and features.

Your rights.

You can exercise your rights by sending us an email at @malta.com

You have the:

• Right to be informed;
• Right of access (request a copy of the data held about you);
• Right to rectification (change/update incorrect data);
• Right to erasure (only applicable under certain circumstances);
• Right to restrict processing (this may impede certain aspects of our business relationship);
• Right to data portability (have your data transferred to a service provider of your choosing);
• Right to object (this may also impede certain aspects of our business relationship);
• Rights in relation to automated decision making and profiling.

F. HOW SECURE IS THE DATA WE COLLECT?

All your personal data is kept secure in several locations (Servers, Clouds, etc.) all of which are encrypted and equipped with antivirus and malware systems along with firewalls and password protection.

Keep in mind

Unfortunately, data transmitted over the internet is not always 100% safe and secure and it’s very difficult to guarantee such security, and although we take all necessary precautions to ensure your data is safe, be aware that you provide us with your data at your own risk. If you ever think or believe that your data might have been breached, then please contact us immediately on spinolahotel@spinolahotelmalta.com