Welcome to Hotelier’s Network Middle East DMCC and our website at www.thehospitalitynetwork.com. We take the protection of your personal data very seriously and process your data in accordance with the UAE`s Personal Data Protection Law (“PDPL”) and the General Data Protection Regulation (“GDPR”).
Personal data is information that makes it possible to identify a natural person. This includes in particular, your name, date of birth, address, telephone number, e-mail address, but also your IP address. Anonymous data as such only exists if no personal reference to the user can be made.
The Data Controller
In accordance with the PDPL and the GDPR, the person responsible for processing of personal data when using the website is:
Hotelier’s Network Middle East DMCC
Jumeirah Bay X2 Tower, Cluster X
Jumeirah Lakes Towers
Dubai, United Arab Emirates
Phone: +9714 437 5796
Categories of data subjects and types of data processed
During the course of using our website and services, we process the following types of data from visitors and users:
i) inventory data (e.g., names, addresses),
ii) contact data (e.g., e-mail, telephone numbers),
iii) content data (e.g., text entries, messages, testimonials),
iv) usage data (e.g., web pages visited, interest in content, access times), and
v) meta/communication data (e.g., device information, IP addresses).
Purpose of the processing
The Purpose of processing personal information are:
i) provision of the online offer, its functions and contents,
ii) responding to contact requests and communicating with users,
iii) security measures, andreach measurement/marketing.
Relevant legal basis
In accordance with the PDPL and the GDPR, the following legal basis, unless specifically described below apply to the processing of your personal data:
i) the legal basis for obtaining consent is of course consent,
ii) the legal basis for processing in order to fulfil our services and carry out contractual measures and respond to enquiries is contract fulfilment,
iii) the legal basis for processing in order to fulfil our legal obligations is our legal obligation, and
iv) the legal basis for processing in order to protect our legitimate interests is our legitimate interests.
Security of your personal data
We take appropriate technical and organizational measures in accordance with the PDPL and the GDPR, taking into account the state of the art, the implementation costs and the nature, scope, circumstances and purposes of the processing, as well as the varying likelihood and severity of the risk to the rights and freedoms of natural persons, in order to ensure a level of protection appropriate to the risk.
The measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical access to the data, as well as access to, input, disclosure, ensuring availability and segregation of the data. We also have procedures in place to ensure the exercise of data subjects' rights, deletion of data and response to data compromise. Furthermore, we already take the protection of personal data into account during the development and selection of hardware, software and procedures, in accordance with the principle of data protection through technology design and through data protection-friendly default settings.
Cooperation with processors and third parties
If, in the course of our processing, we disclose data to other persons and companies, transmit it to them or otherwise grant them access to the data, this will only be done on the basis of a legal permission (e.g. if a transmission of the data to third parties, such as to payment service providers (PayPal and/or Stripe), is necessary for the performance of the contract, within the Hotelier’s Network Middle East DMCC, you have consented, a legal obligation provides for this or on the basis of our legitimate interests (e.g. when using agents, web hosts, etc.), for scheduling appointments or conferences (Calendly) for marketing and promotional emails (MailChimp), or for online data storage (pCloud and Dropbox).
Transfers to third countries
If we process data in a third country (i.e. outside the UAE) or if this is done in the context of using third-party services or disclosing or transferring data to third parties, this is only done if it is done in order to fulfil our (pre-)contractual obligations, on the basis of your consent, due to a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we only process or allow the processing of data in a third country if the special requirements of the PDPL and the GDPR are met. This means, for example, that the processing is carried out on the basis of special guarantees, such as the officially recognised determination of a level of data protection corresponding to that of the UAE or compliance with officially recognised special contractual obligations (so-called "standard contractual clauses").
These rights are standardized in both the PDPL and GDPR. This includes:
i) the right to information,
ii) the right to rectification,
iii) the right to erasure,
iv) the right to restriction of data processing,
v) the right to data portability,
vi) the right to object to data processing,
vii) the right to revoke any consent you have given.
Please contact us at any time with questions and suggestions regarding data protection and to enforce your rights.
Deletion of data
The data processed by us will be deleted or its processing restricted in accordance with the PDPL and the GDPR. Unless expressly stated in this data protection declaration, the data stored by us will be deleted as soon as it is no longer required for its intended purpose and the deletion does not conflict with any statutory retention obligations. If the data is not deleted because it is required for other and legally permissible purposes, its processing will be restricted. I.e., the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for reasons of commercial or tax law. As described herein, we may retain your personal data for future marketing purposes based on your consent, to withdraw your consent please contact us at any time.
In addition, we process:
i) Contract data (e.g., subject matter of the contract, term, category of customer), and
ii) Payment data (e.g., bank details, payment history).
of our customers, prospective customers for the purpose of providing contractual services, service and customer care, marketing, advertising, and market research.
We process the data of our customers within the scope of our contractual services. In doing so, we process:
i) inventory data (e.g., customer master data, such as names or addresses),
ii) membership data, data of attendees or speakers or participants in our events (e.g., photograph, your curricula vitae/biography and audio/visual recordings)
iii) contact data (e.g., e-mail, telephone numbers),
iv) content data (e.g., text entries, testimonials and messages),
v) contract data (e.g., subject matter of contract, term),
vi) payment data (e.g., bank details, payment history),
vii) usage data and metadata (e.g., in the context of evaluating and measuring the success of marketing measures).
As a matter of principle, we do not process special categories of personal data, unless these are components of commissioned processing. The purpose of the processing is the provision of contractual services, billing, and our customer service. We process data that is necessary for the justification and fulfilment of contractual services and point out the necessity of their disclosure. Disclosure to external parties only takes place if it is necessary in the context of the service.
When processing the data provided to us within the scope of providing our services, we act in accordance with the instructions of the client as well as the legal requirements and do not process the data for any other purposes than those specified in the service.
We delete the data after the expiry of statutory warranty and comparable obligations. The necessity of storing the data is reviewed every three years; in the case of statutory archiving obligations, the deletion takes place after their expiry.
In the case of data disclosed to us by the user within the scope of a service, we delete the data in accordance with the specifications of the service, in principle after the end of the service.
Administration, financial accounting, office organization, contact management
We process data within the scope of administrative tasks as well as organization of our business, financial accounting, and compliance with legal obligations, such as archiving.
In doing so, we process the same data that we process in the context of providing our contractual services. The purpose and our interest in the processing lies in the administration, financial accounting, office organization, archiving of data, i.e., tasks that serve the maintenance of our business activities, performance of our tasks and provision of our services.
The deletion of data with regard to contractual services and contractual communication corresponds to the information mentioned in these processing activities.
In this context, we disclose or transmit data to the tax authorities, consultants such as tax advisors or auditors as well as other fee offices and payment service providers.
Furthermore, we store information on suppliers, organizers, and other business partners on the basis of our business interests, e.g., for the purpose of contacting them at a later date. This data, most of which is company-related, is stored permanently.
When contacting us (e.g., via e-mail, WhatsApp, phone or social media), the user's details are processed for the purpose of handling the request and its processing. The user's details may be stored in a customer relationship management system (Zoho) or comparable enquiry organization. We delete the enquiries if they are no longer necessary. We review the necessity every two years; furthermore, the legal archiving obligations apply.
Controls For Do-Not-Track Features
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ('DNT') feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.
Databases or data sets that include Personal Data may be breached inadvertently or through wrongful intrusion. Upon becoming aware of a data breach, we will notify all affected individuals whose Personal Data may have been compromised, and the notice will be accompanied by a description of action being taken to reconcile any damage as a result of the data breach. Notices will be provided as expeditiously as possible after which the breach was discovered.
Our services are restricted to users who are 18 years of age or older. We do not knowingly collect personal information from anyone under the age of 18. If you suspect that a user is under the age of 18, please contact us.
Because we’re always looking for new and innovative ways to improve our website and services, this policy may change over time. We will notify you before any material changes take effect so that you have time to review the changes.