This Privacy Policy describes how the Victoria Hotel Group and its Affiliates and Subsidiaries (“we” or “us”) collects, uses, consults or otherwise processes an individual’s Personal Data. This Privacy Policy applies globally, but depending on where you live some specific provisions of this Privacy Policy may not apply to you.

Victoria Hospitality Belgium SPRL/BVBA may be operating as a sole or joint Controller. If operating as joint Controllers, both entities jointly determine the means and purposes of the processing of your Personal Data. What this means for you is that you can exercise your rights against either of the joint Controllers by contacting either company as set out below.

In some of the situations described in this Privacy Policy, the hotel where you made a booking and/or stay will also process your data as a (joint or sole) Controller. The hotel will be solely responsible for the processing activities for which it is the sole Controller.

Victoria Hospitality, Inc. is a company incorporated under US laws, having its registered seat and its offices at 701 Carlson Parkway, Minnetonka, MN 55305, United States, telephone number: +1 (763) 212-5000.

Victoria Hospitality Belgium SPRL/BVBA is a company incorporated under Belgian laws, registered at the Belgian Crossroads Bank for Enterprises with company number 0442.832.318, having its registered seat and its offices at Avenue du Bourget 44, B-1130 Brussels, telephone number: +32 2 702 9200.

We are committed to protecting the privacy of our users and customers.

Affiliates and Subsidiaries: Any corporation, firm, partnership or other entity which directly or indirectly controls, is controlled by, or is under common control with Victoria Hospitality Inc. and/or Victoria Hospitality SPRL/BVBA.

Controller: The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data.

EU Privacy Law: Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of Personal Data and on the free movement of such data (the ”GDPR”), as well as any legislation and/or regulation implementing or created pursuant to the GDPR and the e-Privacy legislation, or which amends, replaces, re-enacts or consolidates any of them, and all other national applicable laws relating to the processing of Personal Data and privacy.

Processor: A natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the controller.

Recipient: A natural or legal person, public authority, agency or another body, to which the Personal Data are disclosed, whether a Third Party or not.

Third Party: A natural or legal person, public authority, agency or body other than the data subject, controller, Processor and persons who, under the direct authority of the controller or processor, are authorized to process Personal Data.

Supervisory Authority: An independent public authority which is established by a Member State pursuant to Article 51 of the GDPR.

Personal Data: Any information relating to an identified or identifiable natural person (”Data Subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

1. Hotel booking process

In the context of the hotel booking process – whether this takes place online on one of our brand websites, through an online booking channel, via a travel agent, through our call center or directly at the hotel – we process your Personal Data for the purpose of (i) enabling you to reserve a room in the hotel of your choice; (ii) verifying the availability of the hotel and to administer the booking; (iii) sending you a booking confirmation; and (iv) sending you pre-arrival emails. You may unsubscribe from pre-arrival emails at any time by clicking on the unsubscribe link in the emails sent to you.

Processed data categories

Address, Booking details (including reservation number), 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, Victoria Rewards membership number, Telephone number, Title

Source of data

Depending on the 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 call center - From the Victoria hotel you made a direct booking with

Recipients of data

- Other Victoria Hotel Group entities involved - IT service providers involved in the (online) booking process - IT service providers - From our call center - Email communications service provider

2. Interrupted or incomplete online booking process (abandoned cart)
When you are booking online but for some reason are not able to finalize the booking process, we process your Personal Data for the purpose of enabling you to easily continue the online booking process by sending you an email with a link to the online booking form, which is pre-filled on the basis of the data you had already provided in the form.

1. Victoria Rewards
Victoria Rewards is a global hotel rewards program applicable throughout the hotels of the Victoria Hotel Group that is available to guests staying in our hotels, and to professional partners irrespective of whether the professional partners stay as guests or book on behalf of others. The Victoria Rewards program is managed by Victoria Hospitality, Inc. The Victoria Rewards program provides you with a number of benefits during your stay at our hotel, and enables you to collect Victoria Rewards points during your stay in our hotels and when purchasing from our selected partners. In such context, we may process your Personal Data in order to be able to i) create your online Victoria Rewards profile, including sending you an activation link by email; ii) provide you with information on your Victoria Rewards points; iii) register your bookings and award points to your membership card; iv) inform you about your rewards once you reach a certain points level; and v) inform you about any changes to the Victoria Rewards program.

2. Other Loyalty Program
Apart from Victoria Rewards, we also offer our guests the possibility to earn miles or points in loyalty programs of our partners, such as frequent flyer programs, car rental programs and railway programs. In such context, we may process your Personal Data in order to be able to (i) award miles or points to your membership account with one of our recognized partners following your stay at our hotel; and (ii) assess and fulfil your request to redeem your miles or points of our recognized partners’ loyalty programs at our hotel.

3. Redemption
We provide you with the opportunity to redeem your loyalty points for items such as gift cards, partner offers or charities. When you make a redemption, we process your and, if applicable, the gift card recipient’s Personal Data for the purpose of managing and successfully completing your redemption. In cases where you purchase a 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.

We provide the opportunity to purchase physical or e-gift cards that can be redeemed at our hotels to pay hotel charges, restaurants and spa treatments.

1. Purchasing a gift card
When you purchase a gift card at one of our hotels or online, 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 a gift card is purchased online, in addition to the above, we will process your Address, Connection logs, Email address, and IP address - 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

2. Registering your gift card
As a recipient of one of our gift cards, you may choose to register your gift card online in order to protect the remaining value on the card in case it is lost or stolen. Should you decide to register your gift card, we will process your Personal Data for the purpose of processing such registration.

1. Newsletters and marketing communications
If you have explicitly consented to receive our newsletters or marketing communications, including in relation to Victoria Rewards, we may, from time to time, contact you with information about our services and latest offers and process your Personal Data for this purpose.

If you no longer want to receive our newsletters or marketing communications, please let us know by sending us an email at privacyquestion@Victoriahotels.com. You can also unsubscribe from our marketing emails by clicking on the unsubscribe link in the emails sent to you. For Victoria Rewards, you may also unsubscribe by updating your profile.

2. Newsletters and marketing communications analytics
In the context of our newsletters and marketing communications, we may also process and collect your Personal Data, and notably whether you have opened and interacted with one of our communications, for analytical purposes in order to measure the click-through rate and improve the content of our newsletters and marketing communications

In order to assist our guests in booking, planning and enjoying their stay, we offer mobile applications for our different hotel brands including but not limited to Victoria Blu, Victoria RED, Victoria Rewards, and Park Inn. These mobile apps can be downloaded through online app stores, including the Apple App Store or the Google Play store.

Depending on how you use our mobile applications, your Personal Data may be processed for the purposes of (i) enabling you to reserve a room in the hotel of your choice (see also Hotel Booking Process); (ii) processing your online check-in; (iii) managing your room service order; (iv) booking reservations at your request at a local restaurant; (v) performing special services at your request such as wake up calls, late check-out, or turn down service; (vi) enabling you to book meetings and events in our hotels; (vii) processing your online check-out and your feedback on your stay; (viii) addressing the requests you have made through the mobile app, including through the chat; and (ix) view how many loyalty points you have collected.

To avoid having us receive or use your real-time location, do not opt in to location services. If you did opt in and have changed your mind, you may opt out of location services through your device settings or by deleting the application. Equally, if you would like to no longer receive push notifications via one of our mobile applications, you can revoke push notification permission for the mobile application(s) in your device’s operating system settings.

The information below describes the types of data we process in the context of our mobile applications, where we get your data from, the ground we rely on to carry out the processing, and who we may share your data with. For the Victoria Rewards mobile application, please consult the dedicated section on Victoria Rewards .

iBeacon

iBeacons are electronic devices that broadcast signals that can be received by mobile devices on which one of our mobile apps is installed. If you have voluntarily installed one of our apps on your device, and if you have granted permission for the app to track your location, then iBeacons installed in our hotels may send a signal to the app on your device about the precise, real-time location of the device. The app may use this information to deliver special offers and promotions to you, at a time and place when the information is most relevant. For example, if you are in one of our hotels late in the afternoon, your mobile device may receive a signal from an iBeacon that causes the app to notify you about drink or dinner specials. As a convenience to you, receipt of the iBeacons signal and delivery of the special offer or promotion may occur even if you are not currently using the app. To make our mobile apps and services operate better, we may also collect other information based on iBeacon signals, for example, the strength of the signal between the iBeacon and your device, the duration your device is near the iBeacon, or the battery level of the iBeacon itself. To avoid having us receive or use your precise, real-time location, do not opt in to location services. If you did opt in and have changed your mind, you may opt out of location services through your device settings or by deleting the app.

Should you have a particular query or feedback, including the exercise of one of your rights under the GDPR, you may contact us through the contact forms available on our website(s). In such context, we may process your Personal Data for the purposes of handling and providing an answer to your query or request or to follow up on your feedback. We also provide other forms on our websites which may assist you in requesting a particular service from us, such as the best online rate guarantee form.

The information below describes the types of data we process for these purposes, where we get your data from, the ground we rely on to carry out the processing, and who we may share your data with.

Processed data categories

- Address, Email address, First name / Last name, Victoria Rewards membership number, Stay details, Telephone number, and any other data you may decide to share with us in open comment boxes.

Source of data

- Directly from you through the form

Ground for processing

- Ad hoc consent obtained through the contact form

Recipients of data

- Other Victoria Hotel Group entities involved - IT service providers

1. Meetings and events organization and feedback
If you wish to organize a meeting or event in one of our hotels or if you would like more information on this possibility, you can reach out to us by filling in the Request a Proposal form or dedicated contact form on our website(s), by interacting with the online meetings and events chatbot, by directly contacting the hotel of your choice or by contacting us by other means. The Personal Data collected will be processed for the purposes of fulfilling your request to organize a meeting or event.

We may also send you meeting satisfaction surveys after your meeting or event to enable us to measure the performance of our hotels as meeting venues.

Processed data categories

- Address, Date of meeting or event, Email address, First name / Last name, Profession and employment, Victoria Rewards membership number, Telephone number

Source of data

Directly from you through:

- the online Request a Proposal form - the online contact form - the meetings and events chatbot - a request communicated by other means

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 privacyquestion@victoriahotels.com.

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 privacyquestion@victoriahotels.com . 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 privacyquestion@Victoriahotels.com . 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 privacyquestion@victoriahotels.com.

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.