Privacy Policy - Sea Executive Suites
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PRIVACY POLICY AND CONSENT TO USE OF DATA

Sea Executive Suites Hotel – Privacy Policy

Version: April 25, 2019 | You may contact us for previous versions of the Privacy Policy.
In a nutshell:

● Guests from all over the world choose Sea Executive Suites in Tel Aviv as their destination of choice and trust us with their personal information. It’s our privilege and duty to protect our customers’ data and yours.
● We collect and process personal information of our guests and their companions in order to provide our services, keep in touch, promote our hotel online and offline, and fulfill our legal obligations.
● Like most businesses, we also collect and process personal information of our website visitors, business contacts, and customers.
● We respect your rights regarding your personal information. If you have any questions regarding your personal data, please contact contact us, we’re here to help:

[email protected]

Now in more detail:

1) Introduction and Definitions

We are Sea Dream Hotels Ltd. – the management company of Sea Executive Suites Hotel in Tel Aviv – simply referenced here as “Sea Hotel”. You can find our contact details below.
Sea Hotel is located on the beachside of Tel Aviv, Israel. Sea Hotel’s management company is incorporated as an Israeli company. Sea Hotel attracts and welcomes guests from all over the world, and respects their privacy, implementing Israeli law and other applicable regulations, such as the EU’s General Data Protection Regulation.
In addition, we also operate several Websites – such as sea-hotel.co.il – and collect personal data of Website Visitors. Some Visitors and other people who communicate with us become our business Contacts or Customers. Some Customers come to Sea Hotel along with their companions, who are also our Guests. We collect and process various personal information regarding our Visitors, Contacts, Customers, and Guests, and we are the Data Controller for such personal data.

2) How Do We Collect Personal Data?

If you’re a Contact, Customer, or Guest of ours, there might be several ways in which we receive your personal data:
1) When you share it with us directly, through your communication with us on the Websites’ contact forms, by email, phone, facsimile, at the reception or in conversations with hotel staff, through your use of the Sea Hotel’s services and facilities, at events or trade fairs, or via any other communication channel
2) When you make a reservation or ask for a quote online on a third-party website, travel application, or travel agent, or communicate with a business partner of ours or another third-party, and they share your information with us, based on their interaction with you, their purposes, their legal bases, and their privacy policy. In such cases, we take responsibility for controlling only the personal data that we have received.
3) When you’re visiting or staying at Sea Hotel as a companion to a Customer or a visitor to a business meeting, and we attain certain personal information about you from our Customer, or through our staff or electronic measures (such as Wi-Fi routers and security cameras). In such cases, we take responsibility for controlling only the personal data that we have received.
4) We might augment the personal data we have about you with the information that you provided us directly, information others have provided us about you, and data we’ve collected about you from your use of our Websites (see below).
If you’re a Visitor to our Websites or use the Wi-Fi or wired computer network at Sea Hotel, we might receive some personal data through your device, operating system, and browser, and various hosting, tracking, analytics and advertising technologies used on our Websites, such as cookies (see below), Analytics and Advertising technologies, and other technologies. Our Websites do not currently respond to “Do Not Track” signals sent by your browser or device.

3) What Personal Data Do We Process?

If you’re a Contact, Customer, or Guest of ours, we may collect and process these types of personal data about you:
● Identification information, such as full name, identification numbers, ID and Passport details, birth date, gender, car plate number, driver’s license, workplace and title
● Contact details, such as country/time zone, work and home addresses, phone numbers, email address, and communication preferences
● Travel and hospitality information, such as number of guests, arrival and departure times, flight numbers, services consumed at the hotel, dietary preferences, and other preferences shared with us
● Social networking information you’ve shared with us
● Payment information, such as bank account number, credit card details, or other billing information
● Photos and videos shared with us on social networks, or taken by Sea Hotel’s security cameras
● Feedback, rating, and commentaries you’ve shared with us about your experience at Sea Hotel, or any feedback, rating, and commentaries you’ve communicated about us at a third-party website or application that shares such feedback with us
● Any personal data contained in any photos, media, and other files sent to us or shared with us
● Any other personal data you provide us at Sea Hotel or on any communication channel, such as email correspondence, customer support, and phone conversations.

We also collect and process these types of non-identifiable personal data about anyone using our Websites, Wi-Fi and computer networks at Sea Hotel:
● Usage, logs, analytics, and other device- and technical data collected when you use our Websites or networks, including device information and identification numbers, operating system information, IP address, browser and session information, browsing history and referrals, cookie information, web beacons, advertising identification numbers, language information, connectivity information, configuration information, metadata of files, and usage information (such as page views, clicks, and usage time).

4) What About Personal Data of Children?

Sea Hotel is providing hospitality services to adult Customers and does not intentionally markets its services to children under 16 years old. We do not knowingly collect or process information about children, other than of minor Guests accompanying our Customers, as required by law or collected automatically by electronic means (such as security cameras). To the extent we’d learn that any information was mistakenly collected on children younger than 16 years old, we will delete it immediately. Please contact us (contact details below) if you have any concerns with respect to children’s personal data.

5) What About Cookies?

A cookie is a small data file that your browser saves on your computer or mobile device. We use cookies to collect information and provide our services. We may use cookies to enable certain features, understand how you interact with us, monitor your usage of our Websites, products and services, and personalize your experience and advertising displayed to you. You can set your browser to prevent the use of cookies. If you don’t accept cookies, our Websites might not function properly.

6) What Are The Purposes for Processing Personal Data?

How Is Your Personal Data Used?
We may process your personal data for our own business purposes, including:
1) Delivering our services and offerings, improving them, and developing new services and offerings
2) Providing information about our business, services and offerings
3) Providing customer support, billing, and invoicing
4) Contacting you and communicating with you face to face at Sea Hotel and via any communication channel, including email, phone, SMS, social networks, third-party websites and applications, and other messaging platforms
5) Analyzing and optimizing Websites traffic and usage
6) Protecting our company, staff, Customers, Guests, and systems
7) Online advertising in all forms and channels, including targeting you and others who share similar characteristics as you (lookalikes) online on search engines, websites, apps, messaging platforms, social networking platforms, and offline
8) Direct Marketing in all forms and channels, including email, SMS, messaging, postal service, and more; you can always opt-out from Direct Marketing by unsubscribing yourself through links on any communication or by contacting us and notifying us accordingly.

7) What Is The Legal Basis For The Processing of Data?

We process personal data based on any or some of the following legal bases:
1. Processing is necessary for the performance of a contract with you (the data subject), or in order to take steps at your request prior to entering into a contract – for example, making a reservation for accommodation at Sea Hotel, providing you various services during your stay, or making reservations on your behalf with local restaurants or service providers;
2. Processing is necessary for compliance with a legal obligation to which we are subject, for example the need to maintain Guest records and billing records;
3. Processing is necessary in order to protect your vital interests or the vital interests of another person, for example protecting our Guests through the use of security cameras around the hotel, protecting our staff, or for the establishment, exercise, or defense of legal claims;
4. Processing is necessary for the purposes of the legitimate interests pursued by us, for example the conduct of our business, the delivery of our services, and the promotion of Sea Hotel;
5. We received your consent to the processing of your personal data for specific purposes communicated in this policy. If our processing is based on your consent, you can always withdraw your consent by contacting us.

8) Who Is Your Information Shared With?

We may share your personal information with our staff, subsidiaries, affiliates, contractors, consultants, Customers (if you’re a Guest accompanying them), resellers (such as booking websites and travel applications), and other third-party business partners, for the provision of our services and our operations.
We process your personal data on our servers and computers, hotel management systems (such as Silverbyte), cloud hosting services (such as Microsoft and Google), support systems and services, billing systems, SMS gateways, Email and SMS notification and communication services, and backup systems.
We use additional processors around the world for various processing activities needed for the performance of our Websites, our services, our operations, and our business, and share information with such processors on a need basis. Such processors include hosting and backup providers (such as Microsoft and Google), analytics providers (such as Google, Hotjar, and CallTrackingMetrics), website technology (such as Microsoft Azure and IIS), advertising technology (such as Google, Facebook, and Sojern), mail and newsletter services (such as Microsoft Office, Mailchimp and SitePackage), feedback services (such as Howazit), telecommunication services, security technology and services, and more. We limit the information we share with each processor based on the business need in using such processor, to protect your information while still effectively benefiting from the services of such processor.
We may also share non-personally identifiable information and aggregate information for any purpose. Such data is not personal data, and its sharing cannot be used to identify you.
We may need to share your information with law enforcement agencies, courts of law, and other governmental organizations, if ordered to do so by competent bodies and according to applicable law.
Mergers and Acquisitions
If we are involved with a merger, asset sale, financing, liquidation, bankruptcy, or the acquisition of all or part of our business to another company, we may share your information with that company and its advisors before and after the transaction date.

9) How Do We Safeguard Your Personal Data?

We take information security seriously. We implement state of the art security standards to prevent unauthorized access, maintain data accuracy, and ensure the correct use of information. We encrypt major data communication transmissions to avoid interception and securely backup the information on our platforms to avoid data loss. We also implement appropriate organizational measures to protect your information.
We apply our security standards also when working with business and technology partners. We only select and contract with processors and third parties who use appropriate security measures and provide sufficient guarantees, including technical and organizational measures, to ensure the appropriate protection of the data we entrust with them.
Unfortunately, although we make significant efforts to keep your data safe, we cannot fully ensure or warrant the security of your personal information.

10) Do We Transfer Personal Data Internationally?

Most of our information is stored in Israel, at Sea Hotel and at carefully-selected Israeli hosting services. We also store data over the cloud, mainly on Microsoft Azure servers around the world. Microsoft takes extreme measures with respect to privacy and data security. Read more about Microsoft’s measures here.
At the same time, our business is international – we serve Customers worldwide and we utilize additional processors and service providers in various countries. Therefore, we transfer, store or otherwise process your personal information in other countries. We take appropriate safeguards in the selection of our processing vendors around the world to require that your personal information is well protected. Despite our efforts, it may be the case that a country where your personal information is processed has different, or less protective, data protection and privacy regulation than the country you live in.

11) For How Long Do We Keep Personal Data?

We keep personal information we collect for different periods, depending on the type of information, for example: the required period for keeping guest records and billing records according to Israeli law, the frequency of your use of our services, and other factors.
Generally speaking, we will retain your personal information for a period reasonably needed to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. We will also retain your personal information for as long as necessary to resolve disputes, enforce our rights and agreements, and protect our staff and Customers.
If we no longer need your information for the purposes mentioned in this Privacy Policy, we will delete or anonymize it. In certain occasions we might not be able to fully delete or anonymize your personal information due to technical or operational reasons, for example deleting from backup storage and archives. In such cases, we shall take reasonable measures to secure any information still maintained by us according to our standard data security practices.
Please be aware, that third parties with whom we’ve shared your information (other than our data processors), based on the legal bases detailed in this policy, may retain your information even after we deleted or anonymized any data related to you on our platforms. Such data retention by third parties is subject to their privacy policies, purposes, legal bases, agreements with you, and any applicable law. We take no responsibility over third parties’ use of personal data outside of Sea Hotel’s control.

12) What Are Your Rights With Respect to Your Personal Data?

According to the data protection and privacy regulations in Israel, or where you live, you may have certain rights with respect to your personal information.
Your rights may include, under certain terms and conditions set in the EU General Data Protection Regulation (GDPR) or other applicable law:
● Right of Access to your personal data processed by us;
● Right to Rectification of inaccurate or incomplete personal data;
● Right to Erasure of your personal data (“Right to be Forgotten”);
● Right to Restriction of Processing for a certain period or under certain conditions;
● Right to Data Portability of your personal data to another data controller in a structured format;
● Right to Object the processing of your personal data. Specifically, you have the right to object further processing of your personal data for direct marketing purposes;
● Right Not To Be Subject to a Decision Based Solely on Automated Decision-Making. We do not make any decisions with legal effect based solely on automated decision-making;
● Right to File a Complaint with the applicable data protection authority in your country.
After deletion or anonymization of your personal data following its retention period, the rights to access, erasure, rectification, and data portability cannot be enforced.
Your personal information is processed based on several legal bases, sometimes including your consent. You can withdraw your consent at any time by contacting us. Other legal bases, including statutory or contractual requirements that apply to you might remain intact even following the withdrawal of your consent.

13) Do We Ever Change Our Privacy Policy?

Occasionally, we change this Privacy Policy to accommodate changes to our business practices, industry standards, or new regulation. If we have your contact details, we will let you know personally if such changes are material, and seek consent for the updated Privacy Policy where required and as needed.
Please read the latest Privacy Policy available here from time to time. Note that we may require your consent to our up-to-date Terms of Service and Privacy Policy whenever you use our Websites or consume services at Sea Hotel. If you do not agree to these terms and policy, please do not use our Websites and services.
14) Who Can You Contact Regarding Your Personal Data?
You can contact us with any question or concern you have at:

Sea Dream Hotels Ltd.
1 Trumpeldor St.
Tel Aviv 6343315, Israel
Tel: +972-3-795-3434
Email: [email protected]