Privacy Policy

ILEC Conference Centre

You should read this Privacy Policy carefully before providing us with any of your “Personal Information” (hereinafter referred to as “PI”), i.e. any information collected and recorded in any format that identifies you personally, whether directly (e.g. name) or indirectly (e.g. phone number).

This Hotel Guest Privacy Policy is part of Accor’s terms and conditions governing our hotel services. By accepting said terms and conditions, you expressly consent to this Hotel Guest Privacy Policy.

Accor may use your PI for marketing purposes. If required by applicable law, you will be requested to give your prior express consent to receive such marketing materials.

ACCOR & PRIVACY PRINCIPLES

The following apply throughout the Accor Group worldwide.

1. Transparency: when collecting and processing your PI, we will provide you with relevant information and notice, for what purposes and who are the recipients
2. Legitimacy: we will collect and process your PI only for the purposes which are mentioned to you in this Privacy Policy
3. Relevance & Accuracy: we will only collect PI which is necessary for the purposes of the data processing as set out in this Privacy Policy. We will take all reasonable measures to ensure you that the PI that we have stored is accurate and up to date.
4. Storage: we will keep your PI for the period necessary for the purposes of the data processing as set out in this Privacy Policy and in accordance with local law requirements.
5. Access & Rectification: we offer you ways to access, modify, correct or delete your PI. Please see contact details below.
6. Confidentiality & Security: we will implement reasonable technical and organisational measures to protect your PI against accidental or unlawful alteration or loss, or from unauthorized use, disclosure or access.
7. Sharing & International Transfer: we may share your PI within the Accor Group or with third parties (such as commercial partners and service providers) for the purposes described in this Privacy Policy. We will take appropriate measures to secure such sharing and transfer.

If you have any questions about these Accor 7 Privacy Principles, please Contact Us

SCOPE

This Privacy Policy is applicable to:

1. Any data processing implemented by Accor owned and managed hotels, i.e. hotels which are part of the Accor Group, including managed hotels, e.g. hotels operating under the following brands Sofitel, Pullman, Novotel, Grand Mercure, Mercure, MGallery, Suitehotel, Ibis, all seasons, Etap Hotel, Hotel F1, Formule 1, Studio 6, Motel6. This list is regularly updated.
2. Any Accor booking web sites, i.e. existing Accor websites, e.g. accorhotels.com. and also brand website (www.sofitel.com, www.mercure.com, etc.).
3. Any Accor loyalty program websites www.a-club.com.

Although this Privacy Policy does not apply to franchised hotels, Accor will use reasonable efforts to promote and request that the Accor 7 Privacy Principles be implemented by the said franchisees and that the said franchisees comply with all applicable laws in processing your PI.

WHAT PERSONAL INFORMATION?

You may be asked, at various times, to provide PI about yourself and your family members, such as:

1. Contact information, e.g. name, telephone numbers, e-mail addresses, postal addresses, etc
2. Other personal details: date of birth; nationality
3. Children Information: name, birth date and age
4. Credit card details (only in transactional related system)
5. Membership card numbers of any Accor loyalty program or any membership number of frequent flyer or any of Accor’s partners you are registered with
6. Your dates of arrival and departure/visit from our hotels
7. Your preferences and interests, e.g. smoking or non-smoking room, preferred location of your room (low floor, high floor, etc.), type of bed, preferred newspaper, sports and cultural interests
8. Any questions/comments you may have during or after your stay in one of our hotels.

We do not knowingly collect PI from children under the age of 18, except name, date of birth and nationality as provided directly by an adult on their behalf or with adult’s permission. Please make sure that your children do not provide us with any PI without your permission, e.g. online. If you believe your child has submitted PI to us, please contact us so that we can delete such PI.

Generally, we do not knowingly collect sensitive information such as racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health or sex life details.

In addition, depending on the applicable law, other data than those listed above may also be considered as sensitive data: credit card number, leisure habits, personal activities and hobbies, cultural habits, smoker/ non-smoker status, etc. However, we may need to collect such data which may be considered as sensitive, to satisfy your request or provide you with specific services such as specific diet or any disability access facilities.

In such case, if required by applicable law, we will ask you to expressly consent that we collect and process such sensitive information.

WHEN IS PERSONAL INFORMATION COLLECTED?

PI may be collected in certain circumstances including without limitation as follows:

Hospitality activities such as:

1. Booking of an hotel room
2. Check in and check out
3. Consumption during a stay in an hotel as tracked through room charges
4. Claims, requests and/or disputes

Participation in marketing programs:

1. Registering with Accor’s loyalty programs
2. Contribution to guests surveys and/or comments (e.g. “Guest Satisfaction Survey”, “Contact us”; “Guests comments”; “Satisfait ou invité”)
3. Contests
4. Subscription to newsletters, to receive e-mail offers or promotions
5. Provision of information by third party service providers such as tour operators, travel agencies, GDS reservation systems etc

Internet activities:

1. Connection to any Accor websites (IP address, session cookies)
2. Fill in of an online collection form (e.g. online bookings, questionnaire, etc.)

WHAT DO WE DO WITH PI?

We use your PI for the following purposes:

1. To manage your reservation and booking:
   • – To book and reserve Accor hotel rooms and requested accommodation
   • – To establish and maintain business records and comply with accounting requirements.
   • – For back office processing; including managing a list of undesirable guests, further to a non-payment, or to improper behaviour, etc.
2. To manage your stay at the hotel:
   • – To track consumption (telephone, bar, Internet, pay TV…)
   • – To access rooms
3. To improve our hospitality services, including:
   • – To process your PI in Accor’s Clients Relationship Management (CRM) program
   • – To better understand your needs and requests
   • – To tailor our products and services to better suit your desires
4. To send you newsletters, promotions and marketing material about tourism, hospitality or services, hotel promotions, or about Accor partners. You can choose to unsubscribe from our Email Newsletters service by clicking a link in one of our email newsletters.
5. To improve our Accor services, including:
   • – To conduct surveys and analyze guests’ questionnaires and comments and activity patterns
   • – To manage guests’ complaints
   • – To let you benefit from our loyalty program
6. To secure and improve your use of Accor Internet websites, including:
   • – To improve website navigation
   • – To implement security and fraud prevention means
7. To comply with local regulations (e.g. retention of business or accounting documents)

SHARING YOUR PERSONAL INFORMATION

As a global company, we strive to offer you the same level of service and hospitality all around the world. To this end, subject to your rights set forth in section 13 below, we may have to share your PI with internal or external recipients in the following ways:

1. The Accor Group: we may share your PI with any Accor entity authorized individuals who need to access your PI to provide you with the requested services or in the context of an action as a consequence of you providing such PI:
   • – Hotel Staff
   • – Reservation Staff using Accor reservation tools
   • – Information Technology, commercial partnership and marketing departments
   • – Medical services, if any
   • – Legal Department, if necessary; and
   • – Any relevant individuals of the Accor Group entities for specific categories of data
2. External service providers and partners: we may share your PI with third parties for providing you with the requested services and improving your stay with us :
   • – Third party service providers: IT subcontractors, international call centres, banks, credit card providers; outside counsels, mailing service providers, printing companies
   • – Commercial Partners
3. Local authorities – internal investigations: we may also share information with local authorities if required by local law or as part of internal investigations within the Accor Group in compliance with local regulations.

INTERNATIONAL TRANSFERS

We may transfer for the purposes set forth in Article 7 of this Privacy Policy your PI to recipients, internal or external, which may be located in countries with different levels of PI protection.

Therefore, in addition to the implementation of the present Privacy Policy, Accor implements, appropriate measures, including contractual clauses, to secure transfer of your PI to any Accor entity or external recipient located in a country with a level of protection different from the one existing in the country in which the PI is collected.

DATA SECURITY

Accor takes appropriate technical and organisational measures, in accordance with local law requirements, to protect your PI against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure or access. To this end, we have implemented technical measures such as firewalls and organisational measures such as a login/efficient password system, physical protection, etc.

You may have to enter your credit card details to complete your reservations; in such event, Accor uses Secure Socket Layer (SSL) technology to encrypt such PI.

SESSION COOKIES/EXTERNAL LINKS

Accor uses persistent cookies to manage your session on Accor’s websites and to personalize your online experience (automatic recognition, list of your favourite hotels, etc.).

We also collect technical information on your computer each time you open a page during your visit to our sites. This information includes your IP (Internet Protocol) address, the operating system used, the type of browser, the screen resolution and the origin website address, as needed. We collect this information to improve the quality of your visit to our site and do not sell or transfer this information to third parties. These temporary cookies are a built-in feature of the technology used. Most browsers automatically accept these cookies, but you can delete them or have them automatically refused. As each browser is different, you should refer to the “Help” section on your browser toolbar to find out how to set your preferences regarding cookies. However, you may not be able to use certain features on our site if you choose not to accept cookies.

We may offer you advertising or links to third-parties’ websites which may collect PI about you when you view or click on their advertising or content through the use of cookies. Accor cannot control this collection of information and accepts no responsibility for this collection, use or disclosure of your PI by third-party companies. you should contact these advertisers or content providers if you have any questions about their use of the PI they collect.

Your visit to these third-parties’ websites is in no way subject to this Privacy Policy. Accor takes no responsibility for any privacy policies or practices of any third-parties’ web sites accessible from Accor’s websites.

DATA STORAGE

We will store your PI only for the time necessary for the purposes stated in this Privacy Policy, or as permitted by the applicable law.

ACCESS AND MODIFICATION

you have the right to access, modify or delete your PI. you can also object to the processing of your PI as described in this Hotel Guest Privacy Policy provided that you have legitimate reasons. However, please note that if you object, we may in certain circumstances be unable to provide you with the service requested.

If you wish to exercise your rights on your PI held by a specific hotel, then you must contact the hotel directly.

If you encounter any problem when exercising your rights, you can contact the dedicated Data Privacy Contact of the Accor Group:

• ACCOR
• Data Privacy Dpt
• Immeuble Odyssey
• 110 Avenue de France
• 75210 Paris Cedex 13, France

In the interests of protecting the privacy of all the Accor Group’s guests, we will need to identify you properly prior to responding to your request. To this end, we may request a copy of a valid identification paper such as a current driver’s licence, identity card or passport.

If your PI is not accurate, complete or up to date, please provide the Accor Dpt. Data Privacy with your request for correction. Any requests for correction will be dealt with as soon as practicable or in compliance with applicable law.

UPDATES

We may amend this Privacy Policy from time to time as indicated below. Therefore, we invite you to read this Privacy Policy regularly.