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CITIZENM PRIVACY STATEMENT

 

1.  Introduction

This Privacy Statement applies to the processing by citizenM of your (our guests') personal data. citizenM takes your privacy very seriously and treats all your personal data with great care. citizenM acts in accordance with the applicable data protection legislation.

When you visit our websites (or subdomains) (the “Website”), make a reservation, contact us, purchase products from us or visit one of our hotels, we collect personal data from and about you. This Privacy Statement describes which personal data is collected and for which purposes this personal data is processed by citizenM. It also states which rights you have under applicable data protection law.

 

2. Who processes your personal data?

Your personal data may be processed by or on behalf of:
A. the entities operating a citizenM branded hotel, whether owned or licensed by citizenM Operations B.V. and its wholly and partially owned affiliates (each hereinafter referred to as a: citizenM Hotel; see the full list of our citizenM hotels, and the legal entities that operate these hotels here; and/or
B. citizenM Operations Holding B.V. (hereinafter referred to as: citizenM Operations), a limited liability company registered under the laws of the Netherlands, having its statutory seat in Amsterdam, the Netherlands and its offices at Leidseweg 219 (2253 AE) Voorschoten, the Netherlands. citizenM Operations Holding B.V. is registered with the Dutch Chamber of Commerce under registration number 34218994.

 

3. Joint controllers – point of contact

In the context of providing our hotel services and related services/products, the relevant citizenM Hotel(s) of your choice and citizenM Operations shall together operate as joint data controllers for the processing of your personal data.

Each citizenM Hotel and citizenM Operations have entered into an agreement to determine their respective obligations for compliance with data protection law. They have agreed that citizenM Operations is the point of contact for all queries and requests regarding the processing of your personal data, and that citizenM Operations is authorized to enter into data processing agreements with third parties on behalf of each citizenM Hotel In the event citizenM Operations or a citizenM Hotel processes personal data for its own purposes only, it will act as sole controller for the processing of this personal data.

 

4. Which personal data do we process, and for what purposes do we process personal data?

Regardless of which citizenM hotel you stay in, your personal data will be stored in (i) centralized systems which are under the control of citizenM Operations and accessible for authorized staff of citizenM Operations and the citizenM Hotels, and (ii) local systems controlled solely by the relevant citizenM Hotel(s). We want to get to know you, because that enables us to make your stay more pleasant, so you may one day decide to return to our hotels. We collect, store and process personal data at two different stages: (i) before you decide to stay in one of our hotels and (ii) when you stay or have stayed in one of our hotels.

i. Before you decide to stay in one of our hotels
When you visit our Website, we collect information about your use of the Website. This includes both information we collect directly from you, and information we collect about your behavior. This information may constitute 'personal data' under applicable law. We use this information to provide you with (personal) offers, both on our Website and via advertisements on other websites you visit. The information about your use of the Website comprises http header information which your browser transmits to our webserver, information collected through the use of cookies and log information which displays the pages that you visited on our Website.

ii. When you stay or have stayed in one of our hotels
When you make a reservation, you will have to provide us with your name, your (email) address, phone number, the dates you are staying with us and a credit card token or other payment information as applicable. We use this personal data to process the reservation, for billing purposes, and to allow us to communicate with you about your reservation. When you stay in one of our hotels, we will collect personal data about your preferences, use of our services, and location.

Overview of activities under stage (i) and (ii)
We may at each of the stages outlined above use your personal data. For your convenience, we have made an overview of activities that involve the processing of your personal data, and the corresponding legal basis/legal bases that allow/s us to process this data:

 Purpose/activityLegal basis
1. First of all, we store the personal data you provide to us in our systems for administrative purposes.
  • consent (if required)
  • enter into or perform a contract to which you are a party
2. Under several jurisdictions and/or local city regulations we are legally obliged to ask you to provide us with certain information when you arrive at a citizenM Hotel. This may include information such as: birth date, nationality, place of residence, date of arrival and profession.
  • compliance with a legal obligation
3. We will have to verify your identity when you arrive at a citizenM Hotel. We will use your passport or other identification document. We will not store a copy of your passport, unless to the extent permitted by law.
  • enter into or perform a contract to which you are a party
  • for the purposes of our, or a third party's, legitimate interests
4. We store information of your use of the systems in the guest room to ensure that they work correctly. This information is used by our 24/7 support team for preventative and reactive support purposes.
  • for the purposes of our, or a third party's, legitimate interests
5. We store your personal data in our database(s), also after your transaction has been completed and after you have stayed in one of our hotels, in order to comply with data retention obligations and to be able to contact you and welcome you again in the future.
  • compliance with a legal obligation
  • enter into or perform a contract to which you are a party
  • for the purposes of our, or a third party's, legitimate interests
6. Since we operate internationally, it may be necessary to transfer personal data to a citizenM hotel or other recipient (such as franchisees, partners and third party service providers) in a country outside of the country where it was originally collected or outside of your country of residence or nationality. For many of our business purposes we use cloud based services. Therefore, for technical and organizational reasons, it may be necessary that your personal data is transferred to servers located in the US, or to servers located in countries outside of the European Economic Area ('EEA').
  • enter into or perform a contract to which you are a party
  • for the purposes of our, or a third party's, legitimate interests

When we transfer the data to a country outside of the EEA that does not offer an adequate level of data protection, we will ensure compliance with applicable law by way of:
  • EU Model Clauses
  • EU-US Privacy Shield-certification
  • other legally accepted safeguards, as applicable
7. We process your booking, howsoever made (directly via our website or via a third party (online) travel agent.
  • enter into or perform a contract to which you are a party
8. We create a general and simple profile of you on the basis of information disclosed by you via public sources on the internet. We will not use any sensitive personal data that we may collect or derive from your stay or from public sources on the internet.
  • enter into or perform a contract to which you are a party
  • for the purposes of our, or a third party's, legitimate interests
9. We offer and provide services and products you request from us or which we may think you are interested in, via email, telephone or other media. You can subscribe to our newsletter, which contains commercial offers and news of citizenM and related third parties. We use the email address you provide to send the newsletter to. If you no longer wish to receive the newsletter, you can use the link provided in every newsletter to unsubscribe.
  • consent (if required)
  • enter into or perform a contract to which you are a party
  • for the purposes of our, or a third party's, legitimate interests
10. We use credit card data or other payment data for invoicing purposes.
  • enter into or perform a contract to which you are a party
11. If you would like to park in our parking garage we may collect your license plate number in order to provide you access to the parking garage.
  • enter into or perform a contract to which you are a party
12. We collect (meta)data on your use of our Wi-Fi services for security and anti-piracy purposes (such as: IP address, your device's MAC address, connections made, location, etc.). We do not process the content of traffic.
  • consent (if required)
  • for the purposes of our, or a third party's, legitimate interests
13. We collect automatically generated information for statistical (research) purposes. This information tells us how well our services are functioning. This information may be provided to third parties, but only if permitted by law or if this information cannot be traced back to you.
  • for the purposes of our, or a third party's, legitimate interests
14. We track information on your purchases for future use in case you return to a citizenM Hotel.
  • for the purposes of our, or a third party's, legitimate interests
15. We track and record your use of our, or our affiliates', (online) services, either through cookies or via other means. Cookies enable us and others to monitor your browsing behavior. Please read our Cookie Statement for further information on cookies.
  • consent (if required)
  • enter into or perform a contract to which you are a party
  • for the purposes of our, or a third party's, legitimate interests
16. We engage in the advertising and marketing of our brand, company, affiliates, services and/or products both online and offline, possibly via third party service providers. For this, we use your contact details, information on your stay at a citizenM Hotel and information collected through cookies.
  • for the purposes of our, or a third party's, legitimate interests
17. We endeavor to provide a high level of security of both the information we store as well as our facilities, (IT) systems and premises, by means of encryption, physical security measures, passwords, company procedures and policies and professional IT support. Personal data may be processed in this context by citizenM and its vendors.
  • for the purposes of our, or a third party's, legitimate interests
18. We endeavor to prevent our services and facilities (hotels) from being used for illegal purposes, of any kind. Personal data may be processed in this context by citizenM and its vendors, such as through CCTV surveillance.
  • for the purposes of our, or a third party's, legitimate interests
19. We engage in activities required for compliance with legal obligations, third party claims or requests from public authorities, such as (i) the mandatory storage/containment of certain information because of a criminal investigation, (ii) requests from third parties for access to information (iii) any further instructions from third parties, such as supervisory authorities, that involve data processing.
  • consent (if required)
  • enter into or perform a contract to which you are a party
  • for the purposes of our, or a third party's, legitimate interests

 

5. Your rights

Right to revoke consent
If we process personal data on the basis of your consent, you have the legal right to revoke such consent at any time. We will then cease the relevant processing activity going forward.

Right of access to your information 
If you want to know what personal data we have collected or process about you, you may request us to provide a copy of your personal data by sending an email to privacy@citizenm.com. We will ask you to identify yourself. We will not provide you with a copy of your personal data to the extent that the rights and freedoms of others are or may be adversely affected.

Right to rectification and erasure of data, and restriction of processing
If you believe that our processing of your personal is incorrect, inaccurate, unlawful, excessive, incomplete, no longer relevant, or if you think that your data is stored longer than necessary, you may ask us to change or remove such personal data or restrict such processing activity, by sending an email to privacy@citizenm.com.

Right to data portability
You have the right to receive your personal data, which you have provided to us, in a structured, commonly used and machine-readable format, in accordance with section 20 of the General Data Protection Regulation.

Right to object 
You have the legal right to object, on grounds relating to your particular personal situation, at any time to processing of your personal data which is based on the legal basis of either point (e) or (f) of section 6(1) of the General Data Protection Regulation (i.e. the performance of a task carried out in the public interest; the purposes of our, or a third party's, legitimate interests) including profiling based on those provisions [see the Schedule under clause 4 of this Privacy Statement]. We will only cease the processing if so required under section 21(1) of the General Data Protection Regulation. Furthermore, you have the right to object at any time to our processing of your personal data for direct marketing purposes by either (i) opting out by using the option we provide in the relevant direct marketing message (e.g. an email newsletter), or (ii) by sending an email to privacy@citizenm.com. For the sake of clarity: without prejudice to the foregoing we are at all times entitled to send you messages that do not constitute direct marketing.

General information relevant for all requests and queries
You must exercise your rights, as explained in this clause, in accordance with applicable law, in particular section 15, 16, 17, 18, 20 and 21 of the General Data Protection Regulation, if and when it applies. We will solely review your request or query in light of our obligations under applicable mandatory data protection law. Nothing in this Privacy Statement is intended to provide you with rights beyond or in addition to your rights as a data subject under applicable mandatory data protection law. 
We will use reasonable endeavors to respond to your request or query within one month. We are entitled to extend this term by another two months if the complexity of the situation so requires. If your request is manifestly unfounded or excessive we may either (i) charge you a fee, or (ii) refuse to process your request. With respect to access requests we may also charge you for extra copies. If we decide not to honor your request or answer your query, we will explain our reasons for doing so in our reply.

 

6. Protection and storage of your data

We have used and will continue to use reasonable endeavors to protect your personal data against loss, alteration or any form of unlawful use. Where possible, your personal data will be encrypted and stored on a virtual private server that is secured by means of state of the art protection measures. A strictly limited amount of people have access to your personal data. We will retain your personal data for the period necessary to fulfill the purposes outlined in this Privacy Statement, generally 2 years, unless a longer retention period is required or permitted by law (which is typically the case in the context of our obligations under tax law).

 

7. Cookies

The Website uses various cookies. Information generated by the use of cookies may constitute personal data. We can use the personal data collected in this manner for the purposes as stipulated in this Privacy Statement. If you want to know more about our use of cookies, read our Cookie Statement.

 

8. Supervisory authority and applicable law

With respect to the processing of your personal data, citizenM Operations is the 'main establishment' of the citizenM Group. This means that the data protection authority of the Netherlands (Autoriteit Persoonsgegevens) shall have jurisdiction with respect to the cross-border processing of your personal data in which citizenM Operations is involved. Notwithstanding the foregoing you shall be entitled to lodge a complaint with the competent supervisory authority in the territory of a citizenM Hotel.

The processing of your personal data by citizenM Operations and the relevant citizenM Hotel(s) shall be subject to the laws of the Netherlands, including the General Data Protection Regulation, when it applies from 25 May 2018 onwards. The applicability of the laws of the Netherlands and General Data Protection Regulation shall be without prejudice to any provisions that may apply to a particular processing activity under local mandatory data protection law.

 

9. General

In case you have any questions in relation to this Privacy Statement, you may send an email to privacy@citizenm.com.

We have done our best to make sure that this Privacy Statement explains the way in which we process your personal data, and rights you have in relation thereto. We may change this Privacy Statement from time to time to make sure it is still up to date. To make sure you consult the most recent version of our Privacy Statement, please check the Privacy Statement published on our Website.

Last update: 26 September 2017.