INTRODUCTION

Welcome to the Leonardo Hotels’ Privacy Notice.

Leonardo Hotels (as further explained below) respects your privacy and is committed to protecting your personal data. This privacy notice will inform how we collect and process your personal data. This includes when you, or someone on your behalf, makes a booking, requests information from us, contacts us (or we contact you), uses our website(s)/apps, links from our website(s)/apps, connects with us via social media, through our contact centre or hotels, or any other engagement we have with you (regardless of where you are based). It also tells you about your privacy rights and how the law protects you.

This privacy notice is provided in a layered format so you can click through to the specific areas set out below.

1. IMPORTANT INFORMATION AND WHO WE ARE
2. THE DATA WE COLLECT ABOUT YOU
3. HOW IS YOUR PERSONAL DATA COLLECTED
4. HOW WE USE YOUR PERSONAL DATA
5. DISCLOSURES OF YOUR PERSONAL DATA
6. INTERNATIONAL TRANSFERS
7. DATA SECURITY
8. DATA RETENTION
9. YOUR LEGAL RIGHTS

• ANNEXES

1. IMPORTANT INFORMATION AND WHO WE ARE

PURPOSE OF THIS PRIVACY NOTICE

This privacy notice aims to give you information on how Leonardo Hotels collects and processes your personal data in our dealings with you, including in providing accommodation and other services to you, including any data you may provide through our website. On the use of cookies, we provide an additional notice which you can find here. 

This general privacy notice may be supplemented by other special notices, we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data, e.g. such as for the AdvantageCLUB members, where you find a special notice under https://www.leonardo-hotels.com/leonardo-advantage-club-terms-and-conditions and for our Career Website you can find a special notice under https://careers.leonardohotels.com/terms.aspx#privacy. This privacy notice supplements our other special notices and is not intended to override them.

DATA CONTROLLER

Leonardo Hotels is made up of different hotels and legal entities which are led by Sunflower Management GmbH & Co. KG Landsberger Allee 117a, 10407 Berlin, Germany; Email address: info@leonardo-hotels.com; Tel.: +49 (0) 306883220 (“Leonardo Management”) and with hotels operated by its affiliates and other companies within Europe (together “Leonardo Hotels” or “Leonardo Hotels Group”). Leonardo Hotels is part of the Fattal Hotels group of companies (“Fattal Hotels Group”).

Leonardo Management operates this website and is the data controller for relevant processing of personal data.

When you book a hotel (over this website or otherwise) of Leonardo Hotels Group or receive other services, the Leonardo Hotels Group company operating such hotel and providing the services processes your data jointly with Leonardo Management. Annex 1 to this Privacy Notice lists all Leonardo Hotels and all companies of Leonardo Hotels Group to make it transparent which company is the respective company processing the data of your booking and of other services you receive from such company. When we mention “Leonardo Hotels", "we", "us" or "our" in this privacy notice, we are referring to the relevant company in the Leonardo Hotels Group together with Leonardo Management. Section 9 below (Your Legal Rights) explains our joint data controllership in more detail and how you can execute your rights against Leonardo Hotels Group.

On this website, you can further book other hotels of the Fattal Hotels Group or other hotel operators which are not operated by a Leonardo Hotels Group company. The companies operating these hotels are listed in Annex 2. to this Privacy Notice. When you book a hotel listed at Annex 2, Leonardo Management is a booking platform only and forwards your booking data to the relevant hotel. For further details please see Fattal Hotels Group privacy notice.                           

Leonardo Management has appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice and the processing of your data by Leonardo Hotels. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

CONTACT DETAILS

You can reach our data protection officer (DPO) at:

• Email address: dataprotection@leonardo-hotels.com
• Postal address: Leonardo Hotels c/o Sunflower Management GmbH & Co. KG, Landsberger Allee 117a, 10407 Berlin, Germany
• Phone number: +49 (0) 30 6883220

You have the right to make a complaint at any time to the data protection authority supervising us. We would, however, appreciate the chance to deal with your concerns before you approach the Authority – so please contact us or our DPO in the first instance.

2. THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, last name, username or similar identifier, marital status, title, date of birth, place of birth, nationality, passport or ID card number (where legally required), gender and car number plate and, if your booking is made by your employer or you notify us, also name and contact data of your employer; job position if you are a business contact.

• Contact Data includes billing address, home address, email address and fax and telephone numbers.
• Special Requirements Data includes health, disability and religious or dietary requirements if you notify us of any special needs and provide this information.
• Booking and Transaction Data includes bank account or payment card details and details about payments, purpose of stay and other details of your bookings, stays and other services you have purchased from us, and comments and responses to surveys you provided relating to our service.
• Technical Data of your Visit to this Website includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
• AdvantageCLUB and other Profile Data includes your e-mail address registered for the AdvantageCLUB and password, membership number for Advantage Club and any partner programs (e.g. Miles & More, BahnBonus) services provided to you, your interests and preferences, feedback and survey responses. If you are an Advantage Club member, please also see the Leonardo AdvantageCLUB membership: Data privacy notice (https://www.leonardo-hotels.com/leonardo-advantage-club-terms-and-conditions), which covers in more detail all aspects of our processing of data relating to the Advantage Club and prevails this privacy notice in this respect.
• Usage Data includes information about how you use our services, or link with us via social media and our website.
• Special Traveller’s Data includes information about your recent stays/travelling, Covid test, Covid symptoms as may be required by Federal or local law in connection with the Corona pandemic.

We will not collect all the data referred to above in each case, but only such data as required for the specific purpose.

In the normal course, we will only process Special Categories of Personal Data about you (this includes data revealing your religious beliefs, or information about your health needs and disabilities to the extent you have given your explicit consent and it is needed to cater to your requirements during your stay with us or other use of our facilities or services or if required by law. We may also, however, need to process such information in the event of an accident or a medical or other emergency during your stay or your other use of our facilities.

We obtain limited information about children who are booked in to stay at our hotels (number, age, and where legally required other data such as name, date of birth, place of birth).

IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with accommodation or our other services). In this case, we may have to cancel a booking or other service you have with us but we will notify you if this is the case at the time.

3. HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity, Contact, Special Traveller’s Data and Booking and Transaction Data by filling in forms (on paper, check-in kiosk or web/mobile application) or by corresponding with us by post, phone, email, via our website, chatbot, on social media or otherwise. This includes personal data you provide when you:
  • make a booking for one of our hotels, whether for overnight stays, day rooms, functions or conferences;
  • check in to one of our hotels;
  • attend a function, conference or otherwise use the facilities at one of our hotels;
  • sign up to our Advantage Club;
  • subscribe to our newsletter and/or other publications;
  • request a brochure or other promotional or marketing materials to be sent to you;
  • enter a competition, or respond to a promotion
  • respond to a survey; or
  • give us some feedback; or

book a service provided by a hotel (e.g., vehicle rental).

• Automated technologies or interactions. As you visit our website, interact with our chatbot, our online check-in applications or via social media, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, e-mails, server logs and other similar technologies. Please see our Cookie Policy for further details.
• Travel agencies or other third parties acting on your or your employer's behalf. We may receive personal data about you if a booking is made for you by a travel agency, online portal or another third person, who may be a family member or travelling companion, or agent or other intermediary, working for you or, where you are travelling on business, your employer or other third party on your behalf (tour operators, Online Travel Agencies, Global Distribution Systems) reservation systems, and similar, Contact, Booking and Transaction Data from providers of technical, payment and delivery).
• HTML email web beacons. Our emails may contain a single, campaign-unique “web beacon pixel” to tell us whether our emails are opened and verify any clicks through to links within the email. We may use this information for purposes including determining which of our emails are more interesting to you, to query whether users who do not open our emails wish to continue receiving them. The pixel will be deleted when you delete the email. If you do not wish the pixel to be downloaded to your device, you should select to receive emails from us in plain text rather than HTML.
• Other third parties or publicly available sources. We may receive personal data about you from third parties and public sources as set out below:
  • Web and social media analytics providers
  • Advertising networks
  • Web interaction technology providers
  • Identity and Contact Data from publicly availably sources such as trade registers of EU member states
  • feedback on different online portals & review sites
• Monitoring. We may monitor and/or record: (a) transactions and activities at all points of contact; and (b) web, social media and app traffic and activities.

These are to ensure that we carry out your instructions accurately, for training purposes and to improve our services, and to ensure security and prevent fraud. For the greater security of our guests and patrons, and to prevent and detect crime, we use CCTV in and around our premises. To obtain information about our use of CCTV contact us.

• Business Contacts. If you are a business contact of Leonardo Hotels, we may receive your data as you interact with our website, from trade fair visit/ workshops, personal meetings, corresponding with you through emails and phone, through contractual negotiation and agreements.

4. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to do so. Most commonly, we will use your personal data in the following circumstances (each a “Legal Ground”):

• Performance of contract: Where we need to provide the booked accommodation and services, or otherwise perform the contract we have entered into with you (or are about to enter into).
• Consent: Where you provide us your explicit consent.

• Legitimate interests: Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

• Comply with obligation: Where we need to comply with a legal or regulatory obligation.
• Vital interests: In the case of any accident or a medical or other emergency, to protect your or another individual's vital interests, where you or they are not able to give consent.

For any processing that is based on your consent (mainly applying to online advertising to you), you have the right to withdraw such consent at any time by Contacting us.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We collect and process your personal data for purposes such as and:

• To make a booking, including reserving disability adapted accommodation, to provide accommodation and other services to you including meeting your specific health, disability, dietary and religious requirements, to manage your stay at the hotel and to monitor the use of our services, and to collect and recover money owed to us, to offer you further services relating to your hotel booking (e.g. upgrade, online check-in), asking you to give feedback about your stay at the hotel

Legal grounds: Performance of Contract, Consent (for meeting your specific health, disability, dietary and religious requirements), Legitimate interest (to improve our services)

• To deal with issues, complaints or disputes arising out of our relationship with you, and to prevent or detect crime, including fraud, To manage our relationship with you which will include:
  • Notifying you about changes to our terms or privacy policy
  • Asking you to leave a review or take a survey, or participate in a prize draw or competition
  • To improve our service to you

Legal grounds: Legitimate interest (to monitor and improve our services, to prevent crime and fraud, to keep our documents up to date)

• To administer and protect our business including our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data), to deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you, and to make suggestions and recommendations to you about our services that may be of interest to you

Legal grounds: Legitimate interest (to develop our business and do marketing), Performance of Contract (where website is used to book or deliver service or manage AdvantageCLUB membership)

• To use data analytics to improve our website, services, marketing, customer relationships and experiences

Legal grounds: Consent (for use of cookies and analytics); Legitimate interest (to develop our business and do marketing)

• To deal with an accident or medical or other emergency

Legal grounds: Vital Interest

• To comply with local legislation (for example, storing of accounting documents or registration cards, asking for Special Traveller’s Data)

Legal grounds: Comply with obligation

• To offer you further services from hotel or third parties relating to your stay in the hotel (e.g. vehicle rental, tickets for sights etc.)

Legal grounds: Legitimate interest (to develop our business and do marketing), Consent

We do not undertake automated decision making using your personal data.

MARKETING/PROMOTIONAL OFFERS

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Where you have agreed to receive it and provided your consent, we may use your Identity, Contact, Technical, Usage and AdvantageClub or other Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you.

You can revoke your consent and unsubscribe from our marketing communication at any time by following the opt-out links on any marketing message sent to you or by Contacting us at any time.

SURVEY E-MAIL, RELATED SERVICES OFFER, INFORMATION E-MAILS

You can object to receiving e-mails asking you to take part in a survey, informing you about related services such as room upgrade or information e-mails about the possibility to check in online at any time by following the opt-out links on any such message sent to you or by Contacting us at any time without incurring any costs other than the transmission costs according to the basic tariffs.

COOKIES

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. You can choose to deactivate certain cookies in the Cookie Settings accessible here. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.

CHANGE OF PURPOSE

We will only use your personal data for the purposes for which we collected it, unless we consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please Contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the categories of parties set out below for the purposes set out above.

• Other companies in the Leonardo Hotels Group and Fattal Hotels Group based within the European Economic Area, Switzerland, United Kingdom of Great Britain or Israel involved in providing services to you, whether directly or for providing underlying infrastructure services on our behalf and instruction.

• External third parties, including:
• business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you; these include contractors who provide services to you in their own name such as the third party provider offering Wi-Fi services, as well as our other providers acting as processor on our behalf and as instructed by us (such as the providers of our IT and CCTV infrastructure);
• entities who manage your booking with one of our hotels, e.g. the travel agent or event organizer which arranged a booking for you;
• analytics and search engine providers that assist us in the improvement and optimisation of our services and website (as processor acting on our behalf and as instructed by us);
• professional advisers, including lawyers, banks, auditors and insurers;
• tax and customs authorities, police, public registry authorities, regulators and other authorities;
• entities involved in credit checking and anti-fraud activities, crime prevention/detection, risk assessment and management and dispute resolution.

Where these third parties are our processors, we require them to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party processors to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions. Some of the third parties mentioned above, for example many professional advisers, travel agents, event organizers and authorities, are controllers who, like us, are subject to specific obligations under data protection law, and who will have their own privacy notices setting out how they deal with personal data.

6. INTERNATIONAL TRANSFERS

We may share your personal data within the Leonardo Hotels Group and, if your booking relates to a hotel listed in Annex 2, with the relevant hotel operator. All companies are currently based in the European Economic Area (EEA), UK, Switzerland or Israel (where the EU Commission decided that these two countries provide an adequate level of data protection).

Though we do not seek actively to transfer personal data outside the EEA, some of the external third parties we deal with are based outside the EEA or process personal data outside the EEA, so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data outside of the EEA, we ensure an appropriate level of protection is given to the personal data and we use the EU Standard Contractual Clauses where appropriate to ensure this.

7. DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. Processors we appoint will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. DATA RETENTION

HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

In some circumstances you can ask us to delete your data: see Request erasure below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

9. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

• Request access to your personal data.

• Request correction of your personal data.

• Request erasure of your personal data.

• Object to processing of your personal data.

• Request restriction of processing your personal data.

• Request transfer of your personal data.

• Right to withdraw consent.

If you wish to exercise any of the rights set out above, please Contact us.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to enable us to deal with your request or to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or we have received a number of requests. In this case, we will notify you and keep you updated.

YOUR LEGAL RIGHTS

You have the right to:

• Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on our legitimate interest (or that of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following situations: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Dealing with Joint Controllers

As set out in the beginning of this notice, Leonardo Management and the Leonardo Hotels Group company operating the hotel you booked and from which you receive services are jointly determining the purposes and means of processing your data. As so-called joint data controllers, Leonardo Management and Leonardo Hotels Group companies entered into an agreement to govern how to allow you to effectively exercise your rights as a data subject. Leonardo Management agreed to be your central point of contact for this purpose. Thus, if you do want to exercise any of your rights listed above, please contact Leonardo Management who will then liaise with the other Leonardo Hotels group companies to comply with your request.

Annexe 1

Annexe 2