Privacy Policy

This privacy policy was last updated on 10th September 2018.

This privacy policy describes how the Mannin Hotel Ltd collects, uses, consults or otherwise processes an individual`s Personal Data. We are committed to protecting the privacy of our users and customers.

The Privacy Policy is intended to inform you how we gather, define, and use Personal Data that you provide to us when using our website and mobile applications or when relying on our hospitality services. Please not that if you plan to submit someone else`s Personal Data to us, for instance when making a booking on their behalf, you may only provide us with that person`s details with their consent and after they have been given access to information about how we will use their details including the purposes set out in this Privacy Policy.

This Policy includes a description for your data protection rights, including a right to object to some of the processing activities we carry out. Please not that your rights as a data subject may vary depending upon where you live.

HOTEL BOOKING PROCESS

In the context of hotel booking process – whether this takes place online on our website, through an online booking channel, via a travel agent or directly at the hotel – we process your Personal Data for the purpose of (1) enabling you to reserve a room in the hotel (2) verifying the availability of the hotel room and to administer the booking (3) sending you a booking confirmation and (4) sending you non-commercial pre-arrival emails.

Processed Data Categories

Address, date of arrival and departure, email address, first name / last name, first name / last name of adult co-guest(s), payment card type, number and expiration date, telephone number, title.

Source of Data

Depending on booking mechanism used:

• Directly from you through the online booking form

• Through the online booking channel you used to make the booking

• From your travel agent

• From our receptionist / reservations agent you made a direct booking with

Ground for Processing

Processing is necessary to take steps to enter into and perform a contract

Recipients of Data

• Mannin Hotel

• IT service providers involved in the (online) booking process 

HOTEL GUESTS

1. 1.       HOTEL CHECK-IN AND CHECK-OUT

When staying at the Mannin Hotel, we will collect and process your Personal Data for the purposes of (1) registering your arrival and departure at the hotel; (2)assigning you a key card to your room; (3) obtaining a credit card guarantee or hotel deposit to ensure payment of your stay; (4) managing (and archiving) your hotel registration card; (5)creating or updating your profile in our hotel management system; (6) assessing your eligibility for a room upgrade and managing this if applicable; (7)managing payment of your stay; (8) establishing, printing or sending an invoice for your stay; (9) paying a commission to your travel agent (if applicable)

In the event you have booked a room in the Mannin Hotel but do not show up – without cancelling – on the date of arrival communicated, we will process your Personal Data for the purposes of (1) cancelling your stay and any other reservation you may have made; and (2) managing, processing and settling any outstanding payment that may be due.

Processed data categories

Address, Bookings (hotel, restaurant, event, theatre, etc.), Date of arrival and departure, Email address, First name / Last name, First name / Last name of adult co-guest(s), Payment card type, number and expiration date, Telephone number, Title

Source of data

Depending on the booking mechanism used:

• Directly from you through the booking form

• Through the online booking channel you used to make the booking

• From your travel agent

• From our receptionist / reservations agent

• Directly from you through the hotel registration card 

Ground for processing

Processing is necessary to perform the contract you have with us.

Recipients of data

• Mannin Hotel

• IT service providers

• Your travel agent, if applicable 

1. 2.    CREDIT LIMIT REPORT

To ensure payment for all guests staying in a hotel room, each hotel guest is asked for a credit card or deposit upon arrival. In order to ensure that you do not exceed your credit limit during your stay, we may produce a credit limit report multiple times a day for the purposes of verifying whether your credit limit has been exceeded. These credit limit reports may contain your Personal Data. Please note that in limited circumstances these credit limit reports may be subject to one of our internal financial audits, and may therefore be accessed by members of our internal audit department.

Processed data categories

Date of arrival and departure, First name / Last name, Payment card type, number and expiration date

Source of data

Depending on the booking mechanism used:

• Directly from you through the booking form

• Through the online booking channel you used to make the booking

• From your travel agent

• From our receptionist / reservations agent

• From the Mannin Hotel you made a direct booking with

• Directly from you through the hotel registration card

Ground for processing

Processing is necessary to ensure the performance of the contract you have with us.

Recipients of data

• Mannin Hotel

• IT service providers 

1. 3.       HOTEL STAY

When you stay at the Mannin Hotel, we endeavour to make your stay as pleasant as possible. This requires processing your Personal Data for the purposes of providing specific services during your hotel stay. These services include (1) housekeeping and maintenance; (2) returning lost or forgotten items to you; and/or (3) managing your and your co-guests’ preferences, such as dietary requirements and pillow preferences, in order to provide you with a better service during your stay with us.

Processed data categories

Address, Consumption habits, Date of arrival and departure, Dietary requirements, Email address, First name / Last name, First name / Last name of adult co-guest(s), Other preferences, Telephone number

Source of data

Depending on the booking mechanism used:

• Directly from you through the booking form

• Through the online booking channel you used to make the booking

• From your travel agent

• From the Mannin Hotel you made a direct booking with

• Directly from you during your stay at the hotel

Ground for processing

It is in Mannin Hotel`s legitimate interest as a business to organize its day-to-day hotel maintenance activities, to personalize the services it provides, and/or to be able to identify the owner of a lost or forgotten item. Taking into account the limited Personal Data processed and shared for such purpose(s), Mannin Hotel`s business interests prevail over yours.

Recipients of data

• Hotel personnel, including housekeeping, maintenance, front desk, and/or other hotel personnel concerned

• IT service providers 

1. 4.       HOTEL GUEST AND ADDITIONAL SERVICES AND FACILITIES

At the Mannin Hotel you can benefit from additional services and facilities, such as room service, restaurant and bar, laundry services, taxi requests, free Wi-Fi, etc. In the event you make use of additional services or facilities at the Mannin Hotel, your Personal Data may be processed to (1) manage the booking and use of such additional hotel services and/or facilities; (2) administer any advance bookings of additional services and/or facilities to your file; (3) personalize returning guests’ arrival to the hotel and the choice of room amenities and room features; and (4) manage the expenses incurred for such additional services and/or facilities.

Processed data categories

Consumption habits, Date of arrival and departure, Dietary requirements, Email address, First name / Last name, First name / Last name of adult co-guest(s), Payment card type, number and expiration date, Title

Source of data

• Directly from you through the online booking form

• Through the online booking channel you used to make the booking

• From your travel agent

• Directly from you through the hotel registration card

• Directly from you when making your additional service/facility request with the hotel front desk

Ground for processing

Processing is necessary to take steps with a view to entering into a contract and/or to perform the contract.

Recipients of data

• Hotel personnel, including front desk, room service, and/or other hotel personnel concerned

• IT service providers 

GIFT CARDS / VOUCHERS

We provide the opportunity to purchase physical gift cards / vouchers that can be redeemed at our hotel to pay hotel charges, restaurant and bar services.

1. PURCHASING A GIFT CARD OR VOUCHER

When you purchase a gift card at the Mannin Hotel, we process your and, if applicable, the gift card recipient’s Personal Data for the purposes of managing and successfully completing your purchase of the gift card. If you are purchasing the gift card for another person, we will process additional Personal Data for the purpose of delivering the gift card to the recipient by email or by post.

Processed data categories

First name / Last name, Payment card type, number and expiration date

If you purchase the gift card for someone else and depending on the mode of delivery, we will also process the Address of the recipient, Email address of the recipient, First name / Last name of the recipient, Telephone number of the recipient

Source of data

Directly from you when purchasing the gift card at the hotel.

Ground for processing

Processing is necessary to take steps at your request with a view to enter into and perform a contract.

Recipients of data

• Mannin Hotel

• IT service providers

• Gift card platform provider (if used online service)

• Payment service provider 

SOCIAL MEDIA AND ONLINE REVIEWS

We may process your Personal Data obtained through social media platforms (including Facebook, Instagram, LinkedIn and Twitter) or online reviews (including on TripAdvisor) concerning Mannin Hotel brand for the purposes of (1) addressing your questions or complaints; (2) monitoring our online reputation; and (3) improving our services and identifying opportunities on which we can focus.

Some of our social media pages allow users to submit their own content. Please remember that any content submitted to one of our social media pages can be viewed by the public, and you should be cautious about providing certain personal information (e.g., financial information or address details) via these platforms. We are not responsible for any actions taken by other individuals if you post personal information on one of our social media platforms (e.g., Facebook or Instagram). Please also refer to the respective privacy and cookie policies of the social media platforms you are using.

Processed data categories

Any Personal Data you may decide to share with us or published on social media or in other online reviews about us

Source of data

• Directly from you through publicly accessible social media pages, online booking channels or other (review) websites

• From our online reputation monitoring service provider

Ground for processing

It is in Mannin Hotel’s legitimate interest as a business to understand its guests’ preferences and consumption habits. In this context, Mannin Hotel’s business interests prevail over yours.

Recipients of data

• Other Mannin Hotel entities involved

• Online reputation monitoring service provider 

YOUR RIGHTS – UNDER EU PRIVACY LAW

If you are in the EU, EU Privacy Law grants specific rights, summarized below, which you can in principle exercise free of charge, subject to statutory exceptions. These rights may be limited, for example if fulfilling your request would reveal Personal Data about another person, or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping. To exercise any of your rights, you can file a request via email at info@manninhotel.im

Should you have unresolved concerns, you have the right to lodge a complaint with a Supervisory Authority where you live or where you believe a breach may have occurred. We encourage you to come to us in the first instance but, to the extent that this right applies to you, you are entitled to complain directly to the relevant Supervisory Authority.

1. Right to withdraw consent

Wherever we rely on your consent, you will be able to withdraw that consent at any time you choose and at your own initiative by logging in to your account on our website (if you have one) or by contacting us at info@manninhotel.im . The withdrawal of your consent will not affect the lawfulness of the collection and processing of your data based on your consent up until the moment where you withdraw your consent. Please note that we may have other legal grounds for processing your data for other purposes, such as those set out in this Privacy Policy.

2. Right to access and rectify your data

You have the right to access, review, and rectify your Personal Data. You may be entitled to ask us for a copy of your information, to review or correct it if you wish to rectify any information like your name, email address, passwords and/or any other preferences, you can easily do so by logging in to your account on our website (if you have one) or by contacting us at info@manninhotel.im . You may also request a copy of the Personal Data processed as described in this Privacy Policy.

3. Right to erasure

In accordance with EU Privacy Law, you have the right to erasure of your Personal Data processed by us as described in this Privacy Policy in case it is no longer needed for the purposes for which the Personal Data was initially collected or processed or in the event you have withdrawn your consent or objected to processing as described in this Privacy Policy and no other legal ground for processing applies. Should you wish to have your Personal Data erased, please file a request via email at info@manninhotel.im .

4. Right to restriction of processing

Under certain circumstances described in EU Privacy Law, you may ask us to restrict the processing of your Personal Data. This is for example the case when you contest the accuracy of your Personal Data. In such event, we will restrict the processing until we can verify the accuracy of your data.

5. Right to object to processing

Under certain circumstances described in EU Privacy Law, you may object to the processing of your Personal Data, including where your Personal Data is processed for direct marketing purposes.

6. Right to data portability

Where you have provided your data directly to us and where the processing is carried out by automated means and based on your consent or the performance of a contract between you and us, you have the right to receive the Personal Data processed about you in a structured, commonly used and machine-readable format, and to transmit this data to another service provider. 

SECURITY MEASURES

Appropriate technical and organizational measures are implemented in order to ensure an appropriate level of security of your Personal Data, including but not limited to encryption techniques, physical and IT system access controls, obligations of confidentiality, etc.

In the event Personal Data is compromised as a result of a Personal Data Breach we will make the necessary notifications, as required under applicable laws.

WHAT RULES APPLY TO CHILDREN?

We do not knowingly collect or solicit Personal Data from anyone under the age of 18 or knowingly allow such persons to book a room at the Mannin Hotel.

In the event we learn that we have collected Personal Data from a child under the age of 18 without verification of parental consent, steps will be taken promptly to remove that information. If you believe that we have or may have information from or about a child under 18 years of age, please contact us at info@manninhotel.im

HOW IS YOUR PERSONAL DATA SHARED WITH THIRD PARTIES?

We only share or disclose information as described herein, including with Third Parties.

Your Personal Data will also be shared with government authorities and/or law enforcement officials if required for the purposes above, if mandated by law or if required for the legal protection of the Controller(s) legitimate interests in compliance with applicable laws. In addition, we may share your Personal Data and other information with a successor to all or part of our business, where this is in our legitimate interests in facilitating a business sale and in this context our business interests prevail over yours. For example, if parts of our business or assets are sold, we may disclose user information as part of that transaction, subject to applicable law.

HOW LONG WILL WE KEEP YOUR PERSONAL DATA?

We retain your Personal Data for as long as is required to fulfil the activities set out in this Privacy Policy, for as long as otherwise communicated to you or for as long as is permitted by applicable law. For example, we may retain your Personal Data if it is reasonably necessary to comply with any legal obligations, meet any regulatory requirements, resolve any disputes or litigation, or as otherwise needed to enforce this Privacy Policy and prevent fraud and abuse.

To determine the appropriate retention period for the information we collect from you, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of the data, the purposes for which we process the Personal Data, and whether we can achieve those purposes through other means, and the applicable legal requirements.

DOES THIS PRIVACY POLICY APPLY TO THIRD PARTY WEBSITES?

If you click on a link to a Third Party website, you will be taken to a website we do not control and our Privacy Policy will no longer be in effect. Your browsing and interaction on any other website is subject to the terms of use and privacy and other policies of such Third Party website. Read the privacy policies of other websites carefully. We are not responsible or liable for the information or content on such Third Party websites.