Global Privacy Statement
MDD Europe Ltd. | Global Privacy Statement
Last Updated: January 1st, 2022
This privacy statement (“Statement”) applies to MDD Europe Ltd. and its subsidiaries (collectively, "MDD", "we," or "us"). At MDD, we strive to deliver outstanding products, and services to all our corporate and individual customers around the world.
We value your business and, more importantly, your loyalty. We recognize that privacy is an important issue. We have developed this statement to explain our practices regarding the personal information we collect from you or about you on this site or via our apps, through written or verbal communications with us, when you visit one of our properties, or from other sources. While this statement broadly describes the practices, we have adopted across MDD globally, local laws vary and some jurisdictions may place restrictions on our processing activities (e.g., certain jurisdictions may require affirmative consent to send marketing messages). Therefore, our actual practices in such jurisdictions may be more limited than those described herein in order to enable us to comply with local requirements. If you are a resident of the European Economic Area (EEA), please see Appendix A for additional information regarding MDD’s use of your personal information.
By using any of our products or services and/or by agreeing to this Statement, e.g. in the context of registering for any of our products or services, you understand and acknowledge that we will collect and use personal information as described in this Statement.
Please note that this Statement does not apply to our processing of personal information on behalf of and subject to the instructions of third parties such as airlines, car rental companies and other service providers, companies that organize or offer packaged travel arrangements, marketing partners, or corporate customers.
Personal information we collect
We collect personal information at every customer interaction, and in conducting every aspect of our business, we may collect personal or corporate information. This personal information may include: your name, mailing address, billing address, email address, phone number, information related to your interaction with MDD, information related to the purchase and receipt of products or services; marketing and communication preferences and other types of information that you choose to provide to us or that we may obtain about you. Surveys: We may request demographic data or other personal information in customer surveys.
If you choose to participate in MDD sponsored social media activities or offerings, we may collect certain information from your social media account consistent with your settings within the social media service, such as location, check-ins, activities, interests, photos, status updates and friend list. We may also allow you to enter into contests to provide photos, such as of your stay with us, which you may share with your connections on social media for votes, shared offers or other promotions. Forward-to-a-Friend: From time to time, we may offer a feature that allows you to send an electronic postcard or otherwise share a message with a friend, whether via the Internet, a stand-alone kiosk or mobile device. If you choose to use this feature, we will ask you for the recipient's name and email address, along with the text of any message you choose to include. By using this feature, you represent that you are entitled to use and provide us with the recipient's name and email address for this purpose.
We may combine the information you provide to us with information we obtain from third parties, such as credit reporting agencies and public records databases. We use this information to conduct potential due diligence processes.
Use of personal information collected about you
We use your personal information in several ways, including to provide and personalize the services you request and expect from MDD, to conduct direct marketing and sales promotions and as set forth below in more detail. We will collect your consent prior to processing your data where required by applicable law.
We use your corporate and personal information to administer programs in which you participate, including providing you with access to your account information, such as offers for which you are eligible; to fulfil services that are part of such program; to enable direct communication between us and you; and to facilitate collections.
Marketing and communications
Where permitted we may use your personal information to provide or offer you newsletters, promotions and featured specials, as well as other marketing messages in accordance with any communications preferences you have expressed. We use your information to provide in-stay messaging, account alerts, and reservation confirmations; to send you marketing messages; and to conduct surveys, sweepstakes, prize draws, and other contests. We may provide these communications via email, postal mail, online advertising, social media, telephone, text message (including SMS and MMS), push notifications, in-app messaging, and other means with your consent, we also use user-generated content (such as photos) from social media services to deliver display advertising or on our website and apps.
We may use your personal information to improve MDD’s services and to ensure that our site, products, and services are of interest to you. We also use your personal information to provide you with the expected level of hospitality in-room and throughout our properties.
Data correctness, analytics and personalization
We may aggregate your corporate and personal information with data from third-party sources for purposes of keeping information up to date and analytics.
Personal information we share
In order to offer you the best level of service, we may share your personal information among MDD subsidiaries, our service providers, and other third parties.
We may partner with suppliers and service partners to provide you with products, services, or offers may share your information with our business partners accordingly. For example, we may share a hashed version of your email address with third parties using available security measures that may match it with their own hashed versions of email addresses so that they can send online and email advertisements to you on our behalf.
Co-Sponsors of Promotions
We co-sponsor promotions, sweepstakes, prize draws, competitions or contests with other companies, and we provide prizes for sweepstakes and contests sponsored by other companies. If you enter one of these sweepstakes or contests, we may share your information with the co-sponsor or third-party sponsor.
Generally, our service providers are obligated to protect your personal information and may not otherwise use or share your personal information, except as may be required by law. We may use service providers to communicate news and deliver promotional and transactional materials to you on our behalf, including personalized online and mobile advertising in accordance with your preferences and applicable law. Please see our Cookies Statement for more information. MDD will only work with parties that offer a method to opt-out of such advertising. We may also share information with service providers to allow you to create itineraries by selecting sites, activities, and restaurants from lists that we have personalized for you based on your preferences and third-party data.
As we develop our business, we might sell, buy, restructure or reorganize businesses or assets. In such circumstances, MDD may transfer information collected, including, without limitation, Other Information (described below) and personal information, to one or more affiliated or unaffiliated third parties in connection with these business transactions. To the extent that local laws require it, we will provide notice of our intent to transfer personal data to a third party for this purpose and explain how you can object to such transfer.
We may share your telephone number among the MDD group for purposes of telemarketing in accordance with your preferences and applicable law. We may also receive your telephone number from our partners or from other sources, which we may use for telemarketing purposes.
In addition, MDD may disclose personal information in order to: (i) comply with applicable laws, (ii) respond to governmental inquiries or requests from public authorities, (iii) comply with valid legal process, (iv) protect the rights, privacy, safety or property of MDD, site visitors, customers, employees or the public, (v) permit us to pursue available remedies or limit the damages that we may sustain, (vi) enforce our websites' terms and conditions, and (vii) respond to an emergency.
When you visit and interact with MDD websites and apps, we collect other information that does not directly identify you about your use of the site, such as a catalog of the site pages you visit, and the number of visits to our sites (“Other Information”). We use Other Information, as well as data received from third parties, to deliver you email, online (on our sites and other sites) and mobile advertisements.
We may use information we have collected and aggregated, or anonymized personal information received from third parties, to understand more about our users (for example, we may use aggregated information to calculate the percentage of our users who have a particular telephone area code). This includes demographic data, such as date of birth, gender and marital status, inferred commercial interests, such as favorite products or hobbies, and other information we may collect from you or from third parties.
Because Other Information does not personally identify you, such information may be disclosed for any purpose where permitted by law. In some instances, we may combine Other Information with personal information. If we do combine any Other Information with personal information, the combined information will be treated by us as personal information in accordance with this Statement.
The term "sensitive information" refers to information related to your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, sex life, or sexual orientation, genetic information, criminal background, and any biometric data used for the purpose of unique identification. In some jurisdictions, mobile phone numbers, location data,
and information contained on identity documents also are considered sensitive information. We do not generally collect sensitive information unless we are required to do so pursuant to applicable laws or regulations.
Personal information from children
We do not knowingly collect personal information from individuals under 18 years of age. As a parent or legal guardian, please do not to allow your children to submit personal information without your permission.
Links to third-party websites and services
Protecting personal information
MDD will take reasonable measures to: (i) protect personal information from unauthorized access, disclosure, alteration or destruction, and (ii) keep personal information accurate and up to date as appropriate. In the event of a security incident, MDD will notify regulators and/or consumers as required by applicable laws or regulations. We also seek to require our affiliates and service providers with whom we share personal information to exercise reasonable efforts to maintain the confidentiality of personal information about you. For online transactions, we
use reasonable technological measures to protect the personal information that you transmit to us via our site. Unfortunately, however, no security system or system of transmitting data over the Internet can be guaranteed to be entirely secure. For your own privacy protection, please do not send payment card numbers or any other confidential personal information to us via email. We will not contact you by mobile/text messaging or email to ask for your confidential personal information or payment card details.
International transfers of personal information
As a global company, we endeavor to provide you with the same level of service that you have come to expect at MDD no matter where you are in the world. To provide this service, you acknowledge that we may share your personal information among staff members, our service providers, and other third parties, which may be located in countries outside of your own.
Changing and accessing your personal information
To the extent required by applicable law, you may be able to request that we inform you about the personal information we maintain about you and, where appropriate, withdraw your consent for certain data processing activity and/or request that we update, correct, delete, and/or stop processing your personal information. We will make all required updates and changes within the time specified by applicable law and as required by law. When permitted by law, we may charge an appropriate fee to cover the costs of responding to the request. Such requests may be submitted in writing to email@example.com or MDD Europe Ltd., Unit 6 Mead Business Ctr, Mead Lane, Hertford, SG13 7BJ, UK. To protect your confidentiality, we can only respond to such requests to the email address that you have registered or otherwise provided to us. Please remember that if you make such a request, we may not be able to provide you with the same quality and variety of services to which you are accustomed. In addition, in some circumstances based on applicable law, you may request that we cease sharing personal information about you with our business partners or that MDD cease using personal information about you by contacting us using the email or mailing address above. We will seek to honor those requests consistently with applicable law.
Retaining personal information
We retain personal information about you for the period necessary to fulfill the purposes outlined in this statement, unless a longer retention period is required or permitted by applicable law. We retain personal information collected in order to fulfill customer requests for seven years after the last business process. We retain other personal information for shorter periods of time if possible and if permitted by law. We will destroy your personal information as early as practicable and in a way that the information may not be restored or reconstructed. If printed on paper, the personal information will be destroyed in a secure manner, such as by cross-shredding or incinerating the paper documents or otherwise and, if saved in electronic form, the personal information will be destroyed by technical means to ensure the information may not be restored or reconstructed at a later time.
Choices – Marketing communications
If you have given us your contact information (mail address, fax number, email address or phone number), we may want to inform you in accordance with any preferences you have expressed, and with your consent where required, about our products and services or invite you to events via email, online advertising, social media, WeChat, WhatsApp, telephone, text message (including SMS and MMS), push notifications, in-app alerts, postal
mail, our customer service call center, and other means. If you prefer not to receive email marketing materials from us, you may opt-out at any time by using the unsubscribe function in the email you receive from us.
To opt out of text messages, reply “STOP” to the message you received. To be added to MDD’s internal do not call list, send a message to firstname.lastname@example.org. You may control whether our mobile apps send you push notifications by changing your notification settings on your mobile device. If we engage in sending you in-app messages, we will allow control for those in our apps’ settings. For more information about cookies and interest-based advertising and to learn about how to manage these technologies, please see our Cookies Statement.
We may modify this statement from time to time. When we make material changes to this statement, we will post a link to the revised statement on the homepage of our site, and if you have registered for any of your products or services, will may also inform you though a communications channel that you have provided. You can tell when this statement was last updated by looking at the link and at the date at the top of the statement. Any changes to our statement will become effective upon posting of the revised statement on the site. Use of the site, any of our products and services, and/or providing consent to the updated statement following such changes constitutes your acceptance of the revised Statement then in effect.
If you have any questions about this statement or how MDD processes your personal information, or if you wish to either provide a compliment or a complaint, please contact us by email email@example.com or by postal mail to MDD Europe Ltd., Unit 6 Mead Business Ctr, Mead Lane, Hertford, SG13 7BJ, UK. We will respond within 30 days or sooner if practicable.
ADDITIONAL PROVISIONS APPLICABLE TO PROCESSING OF PERSONAL INFORMATION OF EEA RESIDENTS
For individuals residing in the EEA, this Appendix outlines certain additional information that MDD is obligated to provide to you, as well as certain rights you have with respect to the processing of your personal information, pursuant to applicable local laws. This Appendix will control to the extent it conflicts with any provision in the main body of this Statement.
Data Protection Officer: MDD’s may be contacted by email at firstname.lastname@example.org, or at the following address: MDD Europe Ltd., Unit 6 Mead Business Ctr, Mead Lane, Hertford, SG13 7BJ, UK
Purposes and Legal Basis for Processing: MDD processes your personal information for the purposes set forth in Sections 4 (Use of Personal Information Collected About You) and 5 (Personal Information We Share) of the main body of this Statement.
The legal bases for MDD’s processing activities include processing such information as necessary to comply with our contractual obligations, compliance with our legal obligations, protecting the safety of our employees, guests and others, for our legitimate business interests, and pursuant to your consent. The legal basis for the processing of your personal information is based on the purpose for which such information was provided or collected:
We process the personal information based on our business relationship with you and in furtherance of our business interests, including to personalize your use of our services and applications, to communicate news and promotional items, and to deliver personalized advertising and content.
Surveys: Completion of surveys is voluntary – we process the information obtained from surveys based on your consent and in furtherance of our business interests, including marketing, service improvements, and analytics.
We process the personal information obtained in connection with your event based on our contractual relationship with you and for our business interests, including for marketing, service improvements, and analytics and service personalization, as described in Section 4 of our Global Privacy Statement (above).
Social media: Participation in MDD-sponsored social media activities and offerings is voluntary - we process information obtained from social media participation based on your consent and in furtherance of our related business interests, including for marketing, service improvements, and analytics and service personalization, as described in Section 4 of our Global Privacy Statement (above).
Promotions and sweepstakes: Participation in sweepstakes, contests and other promotional offerings is voluntary – we process the information obtained from such participation based on your consent and as necessary to administer the offering. We also use certain data for our business purposes, including for marketing, service improvements, and analytics and service personalization, as described in Section 4 of our Global Privacy Statement (above).
Direct marketing: We use your personal information to send you marketing messages based on your consent. You may withdraw your consent for direct marketing communications at any time by contacting us at email@example.com or by following the unsubscribe instructions in the marketing message.
Retention: We retain personal information about you for the time necessary to accomplish the purpose for which such information was collected, usually for the duration of any contractual relationship and for any period thereafter as legally required or permitted by applicable law. Our retention policies reflect applicable statute of limitation periods and legal requirements.
Data subject rights: Residents of the EEA have the following rights: Access, Correction and Erasure Requests: You have the right to: a) ask us to confirm whether we are processing your personal information, b) receive information on how your data is processed obtain a copy of your personal information, c) request that we update or correct your personal information and d) request that we delete personal information in certain circumstances
Right to object to processing: You have the right to request that MDD cease processing of your personal information: for marketing activities, including profiling for statistical purposes where such processing is based on our legitimate business interests, unless we are able to demonstrate a compelling legitimate basis for such processing or we need to process your personal information for the establishment, exercise or defense of a legal claim Right to Restrict Processing: You have the right to request that MDD limit the processing of your personal information: a) while MDD is evaluating or in the process of responding to a request by you to update or correct your personal information, b) where such processing is unlawful and you do not want MDD to delete your data, c) where MDD no longer requires such data, but you want us to retain the data for the establishment, exercise or defense of a legal claim and d) where you have submitted an objection to processing based on our legitimate business interests, pending our response to such request. Where we limit the processing of your personal information pursuant to your request, we will inform you prior to re-engaging in such processing.
Data portability requests: You have the right to request that we provide you or a third party that you designate with certain of your personal information in a commonly used, machine readable format. Please note, however, that data portability rights apply only to personal information that we have obtained directly from you and only where our processing is based on consent or the performance of a contract. Submitting Requests: your requests may be submitted in writing to firstname.lastname@example.org, or by mail to MDD Europe Ltd., Unit 6 Mead Business Ctr, Mead Lane, Hertford, SG13 7BJ, UK.
We will respond to all such requests within 30 days of our receipt of the request, unless there are extenuating circumstances, in which event we may take up to 60 days to respond. We will inform you if we expect our response to take longer than 30 days. Please note, however, that certain personal information may be exempt from such rights pursuant to applicable data protection laws. In addition, we will not respond to any request unless we are able to appropriately verify the requester’s identity. We may charge you a reasonable fee for subsequent copies of data that you request.
If you have concerns about our data practices or the exercise of your rights, you may either contact MDD at email@example.com or the supervisory authority in the Member State of your residence.
Right to withdraw consent: You have the right to withdraw your consent to any processing that we conduct solely based on your consent (such as sending direct marketing materials to your personal email account). You may withdraw your consent to marketing activities by following the instructions on any marketing emails or contacting firstname.lastname@example.org. For any other activities for which you have previously consented, you may contact email@example.com to withdraw such consent.
Segmentation (also referred to as profiling) and automated decision making: We use personal information to divide large groups of consumers into sub-groups of consumers (known as segments) based on some type of shared characteristics such as geography, behavior, or demographics. With your consent, we make automated decisions, meaning without human interference, using segmentation and/or your specific personal information to offer you certain benefits based on your characteristics (such as discounted room rates or other special offers based on your geography, behavior, or demographics).
International data transfers: We may transfer the personal information we collect about you pursuant to the purposes described in this Statement to countries that have not been found by the European Commission to provide adequate protection. We use appropriate safeguards for the transfer of personal information among our affiliates in various jurisdictions, and where required, we have implemented European Union controller-to-controller standard contractual clauses or other such safeguards for such purposes. To obtain a copy of theses clauses or additional information on transfers, you may send your request to firstname.lastname@example.org.