Last Updated: March 2018
FORM Hotels (“FORM”, “we”, “our” or “us” as the context may be) are committed to protecting and respecting your privacy.
This site is operated by Smartotels Hospitality International Limited.
How this Privacy Statement applies
This policy (together with our Terms and Conditions and any other documents referred to on it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting www.form-hotel.com, or any FORM branded websites (“the Sites”) or using any of our products or services, you agree and consent to your personal information being used and disclosed in the manner set out in this Privacy Statement. In certain countries, we will not collect personal information from you unless you have specifically agreed or consented to us doing so (for example through your acceptance of this Privacy Statement or via an electronic tick-box or other similar measures as required by local privacy and data protection laws).
You do not have to provide your personal information to us, but if you do not provide certain information we will only be able to provide limited products and services to you. Where you refuse to provide mandatory travel information or allow us to disclose it to required governmental agencies and as otherwise required, we will not be able to book a room for you.
This Privacy Statement applies even if you have booked your travel or other products or services via a third party (such as a travel agent or holiday company), as this Privacy Statement forms part of your Terms and Conditions and your contract with us and/or annexed products or services.
Personal Information we collect from you
Information you give us: We may collect personal data directly from you when you use our Sites, contact us by telephone, by email or in person when you travel (such as your image, gender, first name, business title, surname, address, social media account ID and email address). When you register an account with us we collect - title, first name, surname, and email address. We may also collect your organization name, organization address and organization phone number. Where applicable by law, when you check-in we collect - date of birth, nationality, passport, visa or other government-issued identification information and the information of eventual accompanying persons. We may collect your email address and / or phone number for automated check-in and to provide relevant information for your booking. If you book additional services, we will use the information you provide to provide you with the requested services.
When you are making payments, we will collect just the transaction details, all credit card related information is processed by the payment provider. You may also choose to store your credit card details with us for future use. However, we do not store your CVC/CVV code (the security code on the back of a credit card).
From time to time we may update the methods of collection and data fields above. Where there are significant changes we will find a way to notify you, in accordance with the section "Notification of changes to this Privacy Statement" below.
Information we receive from other sources: We may also collect personal information from third parties who you have authorized to provide your personal information to us (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies, your travel companion, travel agencies or tour operators) as well as any of the other websites we operate or the other services we provide (in this case we will have informed you when we collected that data if we intend to share those data internally and combine it with data collected on this site).
Information about others: You may provide us with information about others, for example:
- If you ask us to provide them with information or allow them to manage your booking on your behalf; and/or,
- If you make or manage a booking for or on behalf of another person who has allowed you to do so.
We need to know the names of all guests. If you are booking a room on behalf of someone else, you must obtain their consent to use their personal information, including their sensitive personal data as described below. We proceed on the basis that you have obtained these consents.
Where required by local laws, we would advise you to keep a record of their agreement and provide them with a copy of, or link to, this policy. This is especially the case if you provide us with sensitive information about them (e.g. a reference to an illness or health condition).
You may also provide information about others for purposes such as referring a friend to use so we can offer them our products or services. You must only contact individuals via our Sites who you know would be happy to hear from you and you must not use our products or services to send unsolicited 'spam' messages.
How we use personal information
We use the information provided in the following ways:
- To fulfill our agreement with you and/or deal with your booking or intended booking, including the processing of your booking and payment, ensuring your room is available, sending you pre-arrival messages, including your itinerary or other details relating to your booking, and contacting you if there is a problem with your booking (for example by sending you a service message to inform you when your booking has not been completed);
- To manage your wider travel and products or services requirements, for example liaising with and transferring your data to other service providers and/or travel facilitators so that they can facilitate your travel arrangements, so any disruption can be minimized;
- To personalize the service you receive, for example being aware of previous travel experiences or preferences, and tailoring the way we provide our products or services to you based on your preferences and profile;
- To permit facial recognition and other biometric technologies for identification purposes that may be used by ourselves, including on behalf of Governments and to comply with local regulatory requirements;
- To share data with FORM loyalty schemes and operators;
- To provide you access to the rooms, and other products or services (e.g. meetings, events or celebrations);
- To improve our content and product offerings, and to customize our Sites’ content, layout, products and services (see "Aggregate data, data analytics and social media functionality" below.)
- To interact with you at different touch points throughout your journey (for example we may inform you that your check in time has been anticipated);
- To register you with our Sites and administer our Sites’ products or services where you have registered to receive these. You can unsubscribe from these Platform products or services at any time;
- To invite you to participate in and to administer any sweepstake, promotion, contest, competition, prize draw or your acceptance of any other promotional offer you may enter, and notify winners, as more fully set out in the applicable terms and conditions;
- To personalize the look and feel of our Sites and our communications with you, so as to align with preferences you may have told us about or which we have inferred from your use of our Sites, market research and, (where you have agreed to this) via social media and networks;
- To answer any queries which you may send to us by email or other forms of communication, and we may keep a record of these contacts including call recordings (to the extent permitted by applicable law);
- To conduct customer satisfaction surveys and improve the products and services we offer or create new products and services;
- To meet our legal compliance obligations or for accounting or audit purposes, including the prevention of fraud for online payments and use of loyalty schemes;
- To protect our property, rights, and interests as well as the property, rights, and interests of other persons;
- For legal purposes, such as to respond to a valid legal subpoena or regulatory order;
- For credit checking and credit scoring purposes;
- For crime prevention and detection;
- For direct marketing purposes, as set out in detail below in the section "How do we use your personal information for marketing purposes"; and
- As you may authorize or consent to additionally from time to time.
We may use location data for our mobile website and mobile app to enable us to provide the most helpful format and content (for example pre-populating the hotel location) providing that you have agreed to the use of your location data;
What sensitive personal information might we require or hold?
Sensitive personal information includes data about an individual's preferences, allergies and meal preferences and other categories of personal information which are closely protected. We do not generally collect this information from you (or those you are booking for), but where we do, we seek to minimize the collection and use of it.
Where you have notified us of a health issue that you or someone in your booking requires special assistance either at check-in or during the stay, you agree that you have voluntarily provided that information to us and that you consent (and those you are booking for consent) for us to use that information to provide you with these products or services.
In each case, you specifically consent (on your behalf and on behalf of those you are booking for) that we can use and transfer outside your local country to anywhere in the world where you are travelling or have travelled from or where we provide products or services from (or the FORM service providers do or your travel agent does) (see "To whom do we disclose your personal information" below).
How we use your personal information for marketing purposes
Where you have indicated, you would like to receive updates from us:
- We may send marketing to you to tell you about developments in the products and services available through our Sites and those of our carefully selected partners (provided that we will communicate these to you in conjunction with our own marketing);
- Where we are able to determine or you have indicated to us that you would like to receive it, other third parties may also send you marketing or updates relating to their products or services; and
- We will use your personal preferences which you have told us about, which we have derived from Cookies (see our “Cookies” below) and/or which we have inferred from your service usage (see Aggregate data, data analytics and social media functionality below) or market research. We will use this information to tailor the advertising and communications that you receive to be those of the most relevance and interest to you.
You can also unsubscribe from receiving certain electronic messages (see "Withdrawing your consent" below).
To whom we disclose your personal information
We may disclose information about you as follows:
- To subsidiaries for fulfilment of the purposes listed above;
- We may also disclose your personal information as permitted or required by law. For example, we will disclose personal information to those governmental bodies who have authority to obtain it, in order to comply with a warrant or subpoena issued by a court of competent jurisdiction, and to comply with record production requirements;
- To third parties whose products or services you are purchasing such as airlines, tourism agencies, hotel and car hire companies, or to travel agents, including if there is a problem with your booking so that your travel agent can resolve it with you, and you acknowledge and consent that this may also be sensitive personal information;
- To our third-party service providers and processors, as set out below;
- To third party advertising and social media Sites to provide advertising and the information requested by social media Sites to deliver the user's requested functionality;
- In operating our loyalty schemes and referrals, to other loyalty schemes, as set out in their terms;
- In the event of a sale of all or substantially all of the assets of FORM or a FORM subsidiary, sale or transfer of the business, such FORM subsidiary may transfer personal information in its control to a third-party purchaser that agrees to use personal information for the same reasons identified in this Privacy Statement;
- To anyone to whom we transfer or may transfer our rights and duties under our agreement with you; your friend, if you make a "refer a friend" request or similar;
- Where you have authorized someone else to manage your booking;
- To other regulatory authorities in order to comply with the law in those countries; if we have a duty to do so or if the law allows us to do so; and
- To our employees and agents to do any of the above on our behalf, now or in the future.
Working with other service providers and companies
For operational reasons, we transfer personal information to service providers and companies who help us manage our systems and processes, and to deliver our products or services to customers.
These may include: banks and payment card verification providers, our data warehouse and customer relationship management, marketing organizations (who may provide support for marketing and promotional communications); internet service providers who administer our Sites and provide internet services and host our facilities; chauffeurs, hotel teams, car services agencies, IT service providers, and consumer research companies that assist us with understanding consumer interests by conducting surveys.
We have implemented safeguards to ensure that our service providers treat personal information in a way that is consistent with the terms of this Privacy Statement and applicable laws, and that it is not used except to fulfil products or services to us or where we believe it is necessary for a legitimate reason connected with the products or services we offer, or as set out in the "What sensitive personal data might you require or hold?" section above.
These service providers and group companies may be located in your country, countries in the European Economic Area, in the United Arab Emirates or elsewhere in the world. Different privacy laws may apply in these countries. See further detail in our "Transfer of your personal information" section below.
Your data may be transferred to the [UAE], and the countries where our servers are located. [NTD: May need to be amended based on where data is stored]
We keep records for as long as required to manage bookings and provide the other relevant products or services anticipated by this Privacy Statement, including keeping you up-to-date with our marketing, and where we are required to by law or for records purposes. We also retain your information to make your future interactions with us convenient and to personalize the products, services and communications with you.
By choosing to provide us with your personal information you are consenting to its use in accordance with the principles outlined in this Privacy Statement and as outlined at the time you are asked to provide any personal information. We and other members of FORM may contact you by phone, email, SMS and mobile device messages or notifications (and gaining your consent where we are required to do so) in order to provide you with updates pertaining to our products or services as well as information about additional offers, products, services or events that we believe may be of interest to you.
Withdrawing your consent
You do not have to provide us with your personal information. However, if you choose not to provide certain personal information we request and/or require or consent to its use and disclosure, you will still be able to visit our Sites but you may be unable to access certain options, products or services, and in some cases, we may not be able to fulfil your booking.
All marketing communications we send to you will provide you with a way to withdraw your consent to future marketing. If you no longer wish to receive promotional materials you may opt-out of receiving these communications by informing us or changing your account settings, this will remove you from FORM’s marketing lists.
Be aware that if you unsubscribe completely from our marketing communications we may be unable to notify you of tailored offers to meet your needs.
Please note that if you unsubscribe from marketing communications you will still receive operational and service messages from us regarding your booking and responses to your enquiries made to us, and that we may hold your details on a suppression list so we don't send you marketing communications in the future.
You also have the ability to change your Cookie settings to block certain types of Cookie through your web browser.
We will take appropriate steps to protect the personal information you share with us. We have implemented technology and security features to safeguard the privacy of your personal information. We invest significant resources to protect your personal information, from loss, misuse, unauthorized access, modification or disclosure. However, no internet-based site can be 100% secure and we cannot be held responsible for unauthorized or unintended access that is beyond our control.
Protecting your details and protecting yourself against internet fraud
Here are some simple steps you can take to ensure your information is kept securely:
Keep your booking reference confidential - upon making a booking a unique booking reference will appear on the email confirmation. It is important that you keep your booking reference confidential at all times. Other persons may be able to access your booking details through our system if you disclose your booking reference to them.
If you are travelling in a group and would prefer that your individual booking details are not available to other members of the group, you may choose to have each person make a separate booking.
Keep your customer log-in details confidential. You should not share your log in details with anyone else. You should also log out when you finish using our Sites. This is especially important if you are using a publicly accessible computer.
Be aware of "Phishing", which is where someone tries to represent themselves as someone else to gain information from you - always check whether emails from any sender are actually from them, and if in doubt, go directly to their website and do not click on links in emails, as these may take you to "clone" websites which use your information illegally.
Aggregate data, data analytics and social media functionality
We may aggregate personal information and remove any identifying elements in order to analyze patterns and improve our marketing and promotional efforts, to analyze Site use, to improve our content and product offerings, and to customize our Sites’ content, layout, products and services, and we may appoint third parties to do this on our behalf, as set out above.
We gather certain usage information like the number and frequency of visitors to our Sites. This information may include which webpage you just came from, which webpage you next go to, what browser you are using, your device and your IP address. We only use such data in the aggregate. This collective data helps us to determine how much our customers use parts of our Sites, and do research on our users’ demographics, interests, and behavior to better understand and serve you.
If you use buttons on our Sites linked to social media or similar sites (for example "Like" and/or "Share" buttons), content from our Sites may be sent back to that other website or service and, depending on your privacy settings, may be privately or publicly visible (for example to friends, followers or generally to anyone who has access to your profile page).
Cookies and other tracking technologies
A “Cookie” is a small computer file which is downloaded to your device. It collects information as to how you navigate our Sites and the internet, and helps us provide better services to you and tailor certain content. You can block Cookies by activating the setting on your browser that allows you to refuse the setting of all or some Cookies. However, if you use your browser settings to block all Cookies (including essential Cookies) you may not be able to access all or parts of our site. You should note that this may have an impact on our ability to provide the Webpage services to you.
Except for essential cookies, all cookies will expire after [insert expiry period].
Do Not Track
Currently, our systems do not honor browser do-not-track requests; you may delete Cookies and other tracking technologies using the processes specified in your computer.
Our Sites may contain links to other websites. Please be aware that we are not responsible for the privacy practices of websites not operated by us. We encourage you to read the privacy statements of each and every web site that collects personally identifiable information. This privacy statement applies solely to information collected by our Sites.
Correction/updating of personal information
If your personally identifiable information changes or is inaccurate, or if you no longer desire our service, we will provide a way to correct, update or suppress your personal information provided to us. If you are concerned that any of the information we hold about you is incorrect, please contact us. These rights are without prejudice to any legal rights you may have in applicable laws, including your right to object to certain processing of data.
Access to your personal information
You may have the right to receive a copy of personal information we keep about you, including the sources of the data, the purposes and methods of processing, any electronic decision-making and the entities with whom we share your data. We will endeavor to provide the information you require within a reasonable time. There may be a small monetary charge for some requests, depending on the information requested, to the extent permitted by applicable law.
Transfer of your personal information
Some parties that process or store personal information in accordance with this Privacy Statement may be located in jurisdictions outside your country of residence or our country of incorporation. Therefore, you understand and unambiguously agree that your information may be processed and stored in these jurisdictions and that different privacy laws may apply in these countries which may not ensure the same level of data protection as granted in your country of residence. We only make these arrangements or transfers where we are satisfied that adequate levels of protection are in place to protect any information held in that country or that the service provider acts at all times in compliance with applicable privacy laws. Where required under applicable laws we will take measures to ensure that personal information handled in other countries will receive at least the same level of protection as it is given in your home country.
In the event your personal information is transferred to a foreign jurisdiction, it may be subject to the laws of that jurisdiction and we may be required to disclose it to the courts, law enforcement or governmental authorities in those jurisdictions but we will only do so where required by applicable laws.
Notification of changes to this Privacy Statement
We may amend this Privacy Statement from time to time in order to meet changes in the regulatory environment, business needs, or to satisfy the needs of our guests, properties, strategic marketing partners, and service providers. If we decide to change our Privacy Statement, we will post those changes on our Sites. If at any point, we decide to use personally identifiable information in a manner materially different from that stated at the time it was collected (and/or where we are required under applicable law), we will notify you. You will have a choice as to whether or not we use your information in this different manner. We will use information in accordance with the Privacy Statement under which the information was collected until you agree otherwise, but if you do not accept the amended Privacy Statement, please stop using our Sites. Each version has a version number and date so you can check this easily.
Our Contact Details
Kindly contact us via e-mail at: firstname.lastname@example.org if you:
- have a query regarding your online booking or encountered any problems whilst making your booking;
- experience any technical problems during your interaction with this web site;
- have any queries, concerns or complaints regarding your privacy or this Privacy Statement; and
- have queries regarding this privacy statement.