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Datenschutzerklärung b_smart selection Anstalt

Data protection b_smart selection Institute

Extent of this policy
This privacy policy describes the way in which both bsmart selection AG, based in Industriestrasse 2, FL-9487 Gamprin-Bendern and all their hotels (hereafter “b_smart” or “we”) collect, use or retrieve personal data, or process it in any other way.

The following companies are part of the b_smart selection:
​b_smart hotel Bendern (bsmart hotel Ben AG)
b_smart motel Sevelen (bsmart motel Sev GmbH)
b_smart motel Basel (bsmart motel Bas GmbH)
b_smart motel Landquart (bsmart motel Lan GmbH)
Hotel Vaduzerhof Vaduz (Hotel Vaduzerhof Anstalt)
Hotel Meierhof (Meierhof Hospitality Anstalt)
Hotel Rebstock (Rebstock Hospitality AG)
Motel Rheinfels Park (Rheinfelspark Hospitality GmbH)
Aparthotel Wiggertal (Wiggertal Hospitality GmbH)
​flexy.motel Ebnat-Kappel (flexy.motel Ebn GmbH)
​flexy.motel Buchs (flexy.motel Buc GmbH)
Hotel Freihof Wil (flexy.motel Wi GmbH)

This privacy policy has universal validity. However, it is possible that certain regulations in this guideline are not applicable to you, depending on your place of residence.

For the purpose of EU data protection rights, b_smart can function as the sole data controller, depending on the way in which personal data are processed as described in this privacy policy. As a sole data controller, b_smart determines the means and purposes for processing your personal data. On your part, this signifies that you may assert your rights against b_smart as a sole data controller by contacting the enterprise.

In some of the situations described in this privacy policy, the particular b_smart hotel where you have booked a stay or have stayed will also be responsible for processing your data. b_smart is solely responsible for its data processing activities, in which it functions as the sole controller of these data.

The b_smart selection is a registered enterprise with headquarters in the Principality of Liechtenstein, where Lichtenstein law applies. We are committed to protecting the privacy of our users and customers.

This privacy policy is intended to inform you of the way in which we collect, target and utilise data. Please take some time to carefully read through this privacy policy. Should you intend to forward us personal data belonging to third parties, e.g. reserving in their name, please ensure that we receive these data only with their due consent and after they have been informed about how we will use their data, including use for the purposes given in this privacy policy.

This policy comprises a description of your privacy rights, including cancellation rights exerted against our processing activities. The EU data protection law requires us to precisely state the reasons and legal rationales concerning our usage of your personal data.
Correspondingly, for the purpose of EU data protection law, the following information describes the types of data, the source of your data, justifiable reasons for processing them and the partner to whom we forward them. With the exception of sections on the “Categories of processed data”, listed in the information to follow, we are in no way bound to users outside the EU.

1    Booking process

1.1    Booking process
Within the booking process-, regardless of whether this take place online on our web site via an online booking channel, via a travel advisor, or directly on the business premises, your personal data are processed for the purpose of (1) enabling you to reserve a room in one of our hotels, (2) checking the availability of your chosen hotel and managing the booking, (3) sending you a booking confirmation, and (4) sending you non-commercial emails in advance. You can unsubscribe to these emails at any time before arrival by clicking on the opt-out link in the emails sent to you.

1.2    Categories of processed data
Address, arrival and departure date, email address, forename/surname, forename/surname of the adult companion, type of payment card, number and expiry date, telephone number, title

1.3    Data source
Dependent on the booking method used:
_directly by you with the online booking form
_via the online booking channel which you used
_by your travel advisor

1.4    Rationale for processing your data
Processing your data is necessary as an action required for entering and fulfilling a contract.

Data recipients:
_ b_smart hotels
_IT service providers involved in the (online) booking process
_IT service providers
_email communication service providers

2.    Satisfaction surveys
During or after your stay, we can send you guest surveys via email to enable us to measure our business performance. You can unsubscribe from our emails regarding customer satisfaction surveys at any time by clicking on the opt-out link in the emails sent to you.

2.1     Categories of processed data
Country of residence, arrival and departure, email address, forename/surname, nationality, details of your stay

2.2     Data source
Dependent on the booking method used:
_directly by you with the booking form
_via the online booking channel which you used 
_via your travel advisor

2.3    Rationale for data processing
This is necessary to ensure the efficacy of the contract entered with us.

2.4    Data recipients
_b_smart companies
_providers of customer satisfaction surveys

3.     Service email analytics
In relation to service emails, including both emails regarding customer satisfaction surveys and non-commercial emails on your booking, we may collect and process your personal data for analytical purposes and particularly when you have opened and edited a service email to measure click rate and improve the content of our service emails. You can unsubscribe from our service emails at any time by clicking on the opt-out link in the service emails sent to you.

The following information describes the types of data which we process for this purpose, the source of your data, the rationale for processing them and the partners to whom we can forward your data.

3.1    Categories of processed data
Email address, email click tendencies, email opening tendencies, forename/surname

3.2    Data source
This comes from our email analysis service provider.

3.3    Rationale for processing data
It is within b_smart’s rightful interest to understand its guests’ clicking behaviour to establish whether any system improvements are required. In this respect, smart’s business interests take precedence over your interests.

3.4    Data recipients
_IT service providers
_Email analysis service providers

4.    Hotel/motel guests

4.1    Checking in and out
While staying in one of our hotels, we will collect and process your personal data in order to (i) record your arrival and departure at b_smart; allocate you a key card for your room; (iii) receive a credit card guarantee or deposit to ensure payment for your stay; (iv) manage (and archive) your registration card; (v) create and update your profile in our management system; (vi) examine whether you may be entitled to a room upgrade and arrange for this where applicable; (vii) manage your payment; (viii)issue, print or send an invoice for your stay; and (ix) pay a commission to your travel advisor. 
Should you have booked a room in one of our businesses without having arrived on the day specified and not having made a cancellation, we will process your personal data for the purpose of (i) the cancellation of your stay and every other reservation which you made; and (ii) management, processing and settlement of any outstanding payments.

4.2    Categories of processed data
Address, bookings (hotel, restaurant, events, theatre etc.), date of arrival and departure, email address, forename/surname, forename/surname of the adult accompanier, payment card type, number and expiry date, telephone number, title

4.3    Data source
Dependent on the booking method used:
_Directly by you using the booking form
_Via the online booking channel which you used
_From your travel advisor
_From b_smart
_Directly by you using the hotel registration card

4.4    Rationale for data processing
The data processing procedure is necessary to adhere to the contract which you have with us. 

4.5    Data recipients
_b_smart
_IT service providers
_Your travel advisor, if applicable

5.    During your stay
When you stay overnight in one of our hotels, we are committed to make your stay as enjoyable as possible. This requires your personal data to be processed to provide specific services during your stay. These services include (i) management and maintenance; return to you of lost or forgotten possessions; and/or (iii) management of your preferences and those of your accompanier, such as dietary requirements, to provide you with a better service during your stay with us.

5.1    Categories of processed data
Address, consumer habits, arrival and departure date, dietary requirements, email address, forename/surname, forename/surname of accompanying adult guests, other preferences, telephone number

5.2    Data source
Dependent on the booking method used:
_directly by you using the booking form
_via the online booking channel which you used
_By your travel advisor
_by the b_smart business where you booked
_directly by you during your stay in the business

5.3    Rationale for data processing
It is within b_smart’s legitimate interests to organise their daily hotel maintenance works, personalise the services provided and/or being able to identify the owner of lost or forgotten possessions. Regarding the restricted personal data which are processed and forwarded for this purpose, b_smart’s business interests take precedence over your own.

5.4    Data recipients
_Hotel personnel, including cleaning-,maintenance, reception- and/or other personnel
_Other participating b_smart businesses
_IT providers

6.    Subscription to our newsletter

6. 1    Newsletters and marketing information
Should you have given due consent to receive our newsletters or marketing information, we can occasionally contact you with information regarding our services and the latest deals, as well as processing your personal data for this purpose.
If you would no longer like to receive our newsletters or marketing information, you can unsubscribe from our marketing emails by clicking on the opt-out link in the emails sent to you. 

6.2    Categories of processed data
Address, date of birth, email address, forename/surname, gender, hobbies and interests, telephone number, past experiences of staying in hotels, country of residence

6.3    Data sources
Data come directly from you when you subscribe to our newsletters or later when filling out your account.

6.4    Condition required for data processing
Ad hoc consent, obtained during subscription to our newsletter.

6.5    Data recipients
_B_smart
_IT Service providers
_Email communication service providers

6.6    Website forms
Should you have specific enquiries or feedback, including the exertion of one of your rights as per the data protection act, you can contact us on our website via the contact forms. In this regard, we can process your personal data for the purposes of editing and preparing a response to your enquiries or for keeping track of your feedback. We will also provide other forms on our website to help you request a particular service from us. 

6.7    Categories of processed data
Address, email address, forename/surname, details of stay. Telephone number and all other data which you would like to share with us in comment boxes.

6.8    Data sources
_Directly from you using the form
_Basis for processing
_Ad-hoc consent, obtained from the contact form data recipients
_Other b_smart enterprises involved
_IT service providers

7.0    Meetings and events

7.1    Organisation and feedback from meetings and events
Should you wish to organise a meeting or event on b_smart premises or would like further information in this respect, you can contact us by sending us an email. The personal data collected will be processed for handling your enquiry on organising a meeting or event.
After your meeting or event, we can also send you surveys regarding your satisfaction in order for us to rate the performance of our hotels as meeting venues.

7.1.2.    Categories of processed data
Address, date of meeting or event, email address, forename/surname, occupation and employment, telephone number

7.1.3    Data source
This comes directly from you through
_an online contact form
_an enquiry sent in another manner

7.1.4    Rationale for data processing
Depending on whether you enter contracts directly with us or on your company’s behalf:
_Data processing is necessary to take action on your request to enter and fulfil a contract.
_It is within b_smart’s legitimate interests as an enterprise to have a directing contact person in the company to organise meetings and events and give feedback on this event. In this regard, b_smart’s business interests take precedence over your own interests.

7.1.5    Data recipients
_The company of your choice
_Other b_smart businesses involved
_IT service providers
_Satisfaction questionnaire providers

7.2     Marketing information for meetings and events
Should you decide to receive commercial communications concerning the organisation of meetings or events, we will also process your data to contact you with information concerning our services and latest deals.

7.2.1    Categories of processed data
Address, email address, forename/name, occupation and employment, telephone number

7.2.2    Data source
This comes directly from you through:
_an online contact form
_an enquiry sent in a different manner

7.2.3    Condition required for data processing
Ad hoc consent through
_an online contact form

7.2.4    Data recipients
_Other b-smart businesses involved
_IT service providers
_email communication service providers

7.3     Marketing information for meetings and events
In relation to our marketing information regarding meetings and events, we can collect and process your personal data, particularly should you have opened one of our messages and interacted with it in order to measure the click-through rate and improve the content of our marketing information.

7.3.1    Categories of processed data
Email address, email click tendencies, email opening tendencies, forename/surname, occupation and employment

7.3.2    Data source
This comes from our email analysis service provider

7.3.3    Rationale for data processing
It is within b_smart‘s legitimate interests to understand the click-through rate of its emails to establish whether improvements are required. In this relation, b_smart’s business interests take precedence over your interests.

7.3.4    Data recipients
_Other b_smart enterprises involved
_IT providers
_Email analysis service providers

8.0    Analytics
We may use all data with which you provide us for analytical purposes to optimise your experience, improve our marketing-, business and operational efficiency, as well as to compile divisional lists of our customers based on their personal data and tailor our offers and special deals to your preferences and consumer habits. Within the realms of such analytics, we analyse and combine various data stored by us concerning our guests, including (i) responses to customer satisfaction surveys; (ii) communication with guests; (iii) clicking rates for our marketing communication; (iv) guest conduct on our websites; (v) reservations. Please also consider our special sections on analytics of marketing information for meetings and events and analytics of newsletters and marketing information.

8.1    Categories of processed data
Information on stays, addresses, reservations (hotel, restaurants, events, theatre etc.), arrival and departure dates, titles, surnames/forenames, forenames/surnames of adult accompaniers, email addresses, payment card type, number and expiry date, redemption history

8.2    Source of data
_Directly from you through the online booking form
_Via the online booking channel which you used
_From your travel advisor
_From our email analytics provider
_Directly from you, should you send your enquiry to b_smart concerning 
    additional services/facilities

8.3    Rationale for data processing
It is within b_smart’s rightful interests to understand its guests’ preferences and consumer habits. In this relation, b_smart’s business interests take precedence over your own interests.

8.4    Data recipients
_Other b_smart enterprises involved
_IT service providers
_Analytics service providers

9.0    Social media and online ratings
We may process your personal data obtained by us via social media platforms (including Facebook, Instagram, LinkedIn and Twitter) or online ratings (including TripAdvisor) for the purpose of (i) handling your enquiries or complaints (ii) monitoring our online reputation; and (iii) improving our service provision and identifying possible areas for us to work on.
On some of our social media sites, users can submit their own contributions. However, please remember that all content submitted on any of our social media sites can be viewed by the public, and that you should be cautious about providing certain personal information (e.g. bank details or address dates) via these platforms. We accept no responsibility for other persons’ actions which may arise should you post personal information on one of our social media platforms (e.g. Facebook or Instagram). Please also consider the relevant data protection- and Cookies policies on the social media platforms which you use.

9.1    Categories of processed data
This concerns all personal data that you forward to us or wish to publish on social media or other online reviews regarding us.

9.2    Data source
_This comes directly from you through social media sites, online 
    booking channels or other review sites, all accessible to the general 
    public
_It also comes from our online reputation monitoring service provider.

9.3    Basis for data processing
It is within b_smart’s rightful interests to understand the preferences and consumer habits of its guests. In this respect, b_smart’s business interests take precedence over your own interests.

9.4    Data recipients
_Other b_smart enterprises involved
_Providers of online reputation monitoring services

10.    Your rights – as per EU data protection law
If you are present within the EU, EU data protection law confers specific rights which are summarised hereafter and which you may essentially exert without incurring a fee, subject to legal exceptions. However, these rights can be restricted, e.g. when fulfilment of your request exposes personal data concerning another individual or if you ask us to delete information which must be retained by law or which we have obligatory, rightful interests to retain. In order to exert your rights, please contact our data protection officer.

Should you have unsolved interests, you have the right to file a complaint to a regulatory authority, either near your place of residence or where you believe that an offence was committed. We recommend that you come to us in the first instance. However, to the extent that this right applies to you, you have the right to directly contact the responsible regulatory authority.

10.1     Cancellation rights
Whilst we trust in your consent, you can withdraw this consent at any time and at your own initiative by contacting our data protection officer. Revoking your consent does not retroactively affect the legality of the collection and processing of your data for the period of your previous consent. Please consider that we may have a different legal basis for processing your data for other purposes, as explained in this privacy policy.

10.2     Right to access and correct your data
You are entitled to access, examine and correct your personal data. You may also be entitled to request a copy of your data from us or examine or correct them by contacting our data protection officer, e.g. should you wish to correct information such as your name, email address, passwords and other settings. You can also request a copy of the processed personal data as described in this privacy policy.

10.3    Deletion rights
As per EU data protection law, you have the right to delete your personal data processed in accordance with this policy; insofar as they are no longer required for the purposes for which the personal data were originally collected or processed or for the event that you withdrew your consent or cancelled the processing of your data, as described in this privacy policy, and there is no other valid legal basis for data processing. If you wish to delete your personal data, please send us an enquiry to our data protection officer.

10.4    Right to request restrictions on data processing
Under particular circumstances described in EU data protection law, you can ask us to restrict the processing of your personal data. For example, this applies should you dispute the accuracy of your personal data. In this event, we will restrict the processing procedure until we can examine the accuracy of your data.

10.5    Right to cancellation of data processing
Under particular circumstances described in EU data protection law, you can revoke the processing of your personal data, even if your personal data are processed for direct marketing purposes.

11.    Security measures
Appropriate technical and organisational measures are taken to ensure an adequate level of safety of your personal data, including, but not restricted to encryption technology, access control to IT systems, confidentiality agreements etc. In the event that personal data are compromised resulting from an infringement of data protection regulations, we will notify all affected persons in accordance with legal requirements in force.

11.1    How long do we retain your personal data?
We will retain your personal data for the period required to complete activities listed in this privacy policy, unless you are told otherwise or while the law in force permits it. For example, we can store your personal data should this be meaningfully required for fulfilling legal obligations and regulatory requirements, resolving (legal) disputes or for the event that the data are required for a different purpose to enforce this privacy policy and prevent fraud and misuse.

To determine the period during which the data collected by us are stored, we consider the quantity, type and sensitivity of the personal data, the potential risk of damage through unauthorised use or display of data, the purposes for which we process the personal data, and whether we can fulfil these purposes through different means and still comply with the legal requirements in force.

11.2    Is this privacy policy applicable to third party websites?
Should you click on a link to a third party website, you will be directed to a website which is beyond our control and where our privacy policy is not applicable. The ways in which you explore and interact with another website are subject to user terms and privacy policies of the third party website. Please carefully read through the privacy policies on these other websites. We are neither responsible nor liable for information or content present on third party websites.

11.3    What happens if we carry out amends to this guideline?
We reserve the right to occasionally alter and update this privacy statement. We will keep you informed of these alterations should they concern a fundamental change in the processing procedure or are relevant either to you or the way in which data are processed, and in the event that they compromise your data protection rights.

11.4    How to contact us
Questions, formal enquiries, comments or complaints pertaining to this privacy policy will be welcomed and should be addressed directly to our data protection officer. You can contact the data protection officer under the following address:

Advocatur Seeger, Frick & Partner
Landstrasse 81
9494 Schaan
Principality of Liechtenstein
Tel. +423 265 22 22
mail@sfplex.li