We consider you an important customer. Our first priority is to offer you exceptional stays and experiences throughout the world.
Your complete satisfaction and confidence in The Healing Waters Spa(“THW”) is absolutely essential to us.
In THW dance with applicable regulations, in particular the European General Data Protection Regulation, we have instituted the following ten principles throughout the THW:
1. Lawfulness: We use personal data only if:
- we obtain the consent of the person, OR
- it is necessary to do so for the performance of a contract to which the person is a party, OR
- it is necessary for compliance with a legal obligation, OR
- it is necessary in order to protect the vital interests of the person, OR
- we have a legitimate interest in using personal data and our usage does not adversely affect the persons’ rights.
2. Fairness: We can explain why we need the personal data we collect.
3. Purpose limitation and data minimisation: We only use personal data that we really need. If the result can be achieved with less personal data, then we make sure we use the minimum data required.
4. Transparency: We inform people about the way we use their personal data.
5. We facilitate the exercise of the people’s rights: access to their personal data, rectification and erasure of their personal data and the right to object to the use of their personal data.
6. Storage limitation: We retain personal data for a limited period.
7. We ensure the security of personal data, i.e. its integrity and confidentiality.
8. If a third party uses personal data, we make sure it has the capacity to protect that personal data.
9. If personal data is transferred outside Europe, we ensure this transfer is covered by specific legal tools.
10. If personal data is compromised (lost, stolen, damaged, unavailable…), we notify such breaches to the respective country’s responsible authority and to the person concerned, if the breach is likely to cause a high-risk in respect of the rights and freedoms of this person.
For any questions concerning the ten principles of THW data protection policies, please contact us at firstname.lastname@example.org.
WHAT PERSONAL DATA IS COLLECTED?
At various times, we may collect information about you and/or the persons accompanying you, including the following:
- Contact details (for example, last name, first name, telephone number, email)
- Personal information (for example, date of birth, nationality)
- Information relating to your children (for example, first name, date of birth, age)
- Your credit card number (for transaction and reservation purposes)
- Technical and location data you generate as a result of using our websites and applications.
The information collected in relation to persons under 16 years of age is limited to their name, nationality and date of birth, which can only be supplied to us by an adult. We would be grateful if you could ensure that your children do not send us any personal data without your consent (particularly via the Internet). If such data is sent, you can contact us at email@example.com to arrange for this information to be deleted.
WHEN IS YOUR PERSONAL DATA COLLECTED?
Personal data may be collected on a variety of occasions, including:
1. Spa bookings:
- Booking a treatment
2. Participation in marketing programs or events:
- Signing up for loyalty programs
- Participation in customer surveys (for example, the Guest Satisfaction Survey)
- Subscription to newsletters, in order to receive offers and promotions via email.
- Purchasing products from the Shop
- Creating an online account
CONDITIONS OF THIRD-PARTY ACCESS TO YOUR PERSONAL DATA
The THW operates in many countries and we endeavour to provide you with the same services throughout the world. Thus, we have to share your personal data with internal and external recipients subject to the following conditions:
1. We share your data with a number of authorised people and departments in the THW in order to offer you the best experience our Spa. The following teams may have access to your data:
- Commercial partners and marketing services
- Medical services if applicable
- Legal services if applicable
- Generally, any appropriate person within THW entities for certain specific categories of personal data.
This data is used to improve the quality of service and your experience at THW. You may, at any time, object to the sharing of this data by contacting us at firstname.lastname@example.org.
Your personal data may be sent to a third party for the purposes of supplying you with services and improving your stay, for example:
- External service providers: IT sub-contractors, international call centres, banks, credit card issuers, external lawyers, dispatchers, printers.
- Social networking sites: In order to allow you to be identified on the THW website without the need to fill out a registration form, THW SA has put in place a social network login system. If you log in using the social network login system, you explicitly authorize THW SA to access and store the public data on your social network account (e.g. Facebook, LinkedIn, Google, Instagram…), as well as other data stated during use of such social network login system. THW SA may also communicate your email address to social networks in order to identify whether you are already a user of the concerned social network and in order to post personalized, relevant adverts on your social network account if appropriate.
- With local authorities: We may be obliged to send your information to local authorities if this is required by law or as part of an inquiry.
PROTECTION OF YOUR PERSONAL DATA DURING INTERNATIONAL TRANSFERS
For the purposes set out in clause 6 of this charter, we may transfer your personal data to internal or external recipients who may be in countries offering different levels of personal data protection.
Other than those that are required to carry out your reservation, data transfers to countries having different levels of personal data protection, are regulated by standard contractual clauses defined by the European Commission. Data transfers to the United States may also be made to entities that belong to the US-Privacy Shield.
You have the right to obtain information about and access your personal data collected by THW, subject to applicable legal provisions.
Also you have the right to have your personal data rectified, erased or have the processing of it restricted. Furthermore you have the right to data portability and to issue instructions on how your data is to be treated after your death (hopefully as late as possible!). You can also object to the processing of your personal data, in particular to the sharing of the data related to your treatment, preferences and satisfaction.
In the event that you wish to exercise any of your above rights, please contact us at email@example.com.