1.3) Simplotel terms require all account owners to be at least eighteen (18) years of age (or have the permission and supervision of a responsible parent or legal guardian), therefore this policy does not discuss the use of our Website, or Services by minors.
2. COLLECTION OF THE END USERS’ DATA
2.1) In the course of using the Website, Simplotel collects the following information that you provide to us through the use of the websites designed and created by us (“End User Data”):
2.1.1) Contact details (for instance, last name, first name, telephone number, email, address).
2.2) We may automatically collect some information about your hardware devices when you access the websites. For example, when you utilize the website and our Services designed by us, hosted on third party services as such Amazon Web Services (AWS), Cloudinary, etc., we may collect your internet protocol (“IP”) address and the type of device you use, as well as your geographic location. We may combine this automatically gathered information with other information, including other End User Data we have collected about you;
2.4) We may receive information from third parties (including, for example business partners, providers of technical, payment and delivery services, social media service providers, advertising networks, analytics providers, and search information providers) about your usage trends;
2.5) We may receive information when you fill up forms on websites designed by Simplotel, this data provided on those websites shall be stored on our systems. All such data shall be provided to the Merchant via email. The Merchant’s use of such data shall be governed by their individual privacy policies.
3. USE OF THE USERS’ DATA
3.1) We use your End User Data and other information we obtain from your current and past activities on the website designed by us to: resolve disputes; troubleshoot problems; collect fees owed; measure consumer interest in the services and features provided by us, inform you about the Merchant’s offers, products, services, and updates; customize your experience; detect and protect us against error, fraud and other criminal activity. We use your IP address information for
debugging and analytical purposes. Such End User Data shall also be used to provide analytics data to the Merchant
3.2) We or our group companies, may collect, hold and use information you share on the websites designed by us in order to provide our services and products to you.
3.4) The End User Data of a general nature may however be revealed to third parties and Simplotel. The Merchant Website(s) designed by us might use the data provided by you differently. Please refer to the Merchant Website policies to understand how the data will be used.
3.5) We use or may use the data collected through cookies, log file, device identifiers, location data and clear gifs information to: (a) remember information so that you will not have to re-enter it during your visit or the next time you visit the site; (b) provide custom, personalized content and information and offers on behalf of the Website; (c) provide and monitor the effectiveness of our services; (d) monitor aggregate metrics and demographic patterns; and (e) diagnose or fix technology problems.
3.6) We may use third parties that we refer to as internal service providers to facilitate or outsource one or more aspects of the business, product and service operations that we provide to you on the Merchant Website and therefore we may provide some of the End User Data directly to these internal service providers. These internal service providers are subject to confidentiality agreements with us and other legal restrictions that prohibit their use of the information we provide them for any other purpose except to facilitate the specific outsourced Merchant Website related operation,
4. SHARING YOUR USER DATA
4.1) We may share your information as well as information from tools like cookies, log files, and device identifiers and location data, with third-party organizations that help us provide the services to you through the websites designed by Simplotel. Our service providers will be given access to your information as is reasonably necessary to provide the Services under reasonable confidentiality terms.
4.2) We may remove parts of data that can identify you and share anonymized data with other parties. We may also combine your information with other information in a way that it is no longer associated with you and share that aggregated information.
4.3) When you use the Merchant Websites, we will process some personal data for or on behalf of the hotel. This means we operate as a ‘processer’ for the Merchant Website you are using, while the hotel is a ‘controller’, for the Merchant Website and the services you are using in accordance with EU privacy laws and regulations.
4.4) Your End User Data may be shared with our various technology providers that the Merchant Website may use to process payments and/or make reservations. These technology providers include our payment gateways, channel managers, hotel management systems. Your End User Data may also be shared with various email and network providers in order for the Merchant Website to communicate with you regarding your stay and reservations that you have made.
4.5) All of our End User Data is stored on our servers in Singapore, and might be processed in India. Some of our third parties may track your IP address to provide you content from a server close to you in order to give you a fast experience or for other technical analytical or debugging purposes. In such cases, your IP address may be in servers across the world. The hotel is responsible to ensure that you process (personal) data in accordance with applicable (privacy) laws and regulations, and that a valid legal basis applies for your processing of personal data using their systems.
4.6) Simplotel does not collect, retain, or share data regarding a particular user’s activity across multiple websites or applications that are not owned by Simplotel. Simplotel does assign each user a unique user ID within the scope of an individual website. While we retain your IP data, none of the information retained will allow the End User to be identified on other websites.
4.7) Simplotel through the Merchant Website used by you may share your sensitive information with any third party without obtaining your prior consent in the following limited circumstances:
5. COMMUNICATION AND MARKETING
5.1) When you create provide your email id, you will be able to receive promotional emails regarding latest offers and discounts from the hotel facilitated by Simplotel.
5.2) Please note that in case you don’t wish to receive such e-mail, you have the full liberty to opt-out of such communication at any time.
5.2.1) To unsubscribe from our email list, you can send us the email at email@example.com.
5.2.2) Please note, that should you opt-out of our emailing list, as described here, we will not be able to remove your information from the databases of affiliates, franchisees or business partners with which we have already shared your End User Data, prior to the date of your opt-out request.
6. RIGHTS UNDER THE EU PRIVACY LAW
6.1) If you are in the EU, in addition to the above-mentioned rights the General Data Protection Regulations (GDPR) grants you specific rights, summarized below, which you can in principle exercise free of charge, subject to statutory exceptions, regarding your data. To exercise any of your rights, you can file a request via email at firstname.lastname@example.org.
6.1.1) 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 contacting us at email@example.com.
6.1.2) Right to access and rectify your data: You have the right to access, review, and rectify your information. 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.
6.1.3) Right to erasure: You may request that we erase your information in certain circumstances, such as where we collected your information on the basis of your consent, and you withdraw your consent. Additionally, the Merchant shall be responsible for erasing any such information from their systems. For complete erasure, it is also necessary for you to contact the Merchant;
6.1.4) Right to restriction of processing: Under certain circumstances described in EU Privacy Law, you may ask us to restrict the processing of your information.
6.1.5) Right to data portability: You may request that we provide a copy of your information to you in a structured, commonly used and machine-readable format in certain circumstances.
7. RIGHTS UNDER THE CALIFORNIA ONLINE PRIVACY PROTECTION ACT
7.1) As a resident of California, in addition to the above-mentioned rights the California Online Privacy Protection Act (“CalOPPA”) grants specific rights summarized below, which you can in principle exercise free of charge, subject to statutory exceptions, regarding your data. To exercise any of your rights, you can file a request via email at firstname.lastname@example.org.
7.1.1) California Civil Code Section 1798.83, known as the “Shine The Light” law, permits our customers who are California residents to request and obtain from us a list of what personal information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year and the names and addresses of those third parties. Such requests may be made only once a year and are free of charge.
7.1.2) Most web browsers include a do not track (“DNT”) feature or setting that you can activate to signal your privacy preference. This will allow for your Visitor Data not to be monitored and collected. As this stage, no uniform technology standard for recognizing and implementing the DNT signals have been confirmed. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we are required to follow in the future, we will inform you about such practice in a revised version of this privacy notice.
8.1) To support delivery of our Services, Simplotel may engage and use data processors with access to certain Customer Data (each, a “Subprocessor”). This section provides important information about the identity, location and role of each Subprocessor.
8.2) All our processors and sub-processors are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our processors and sub- processors to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions. The list of Subprocessors we use is below.
- Amazon Web Services
- Google Analytics
- Google Maps
- Send In Blue
- Value First
- Google Adwords
- Payment Gateways such as InstaMojo, PayPal, AirPay, etc.
- Channel Managers and PMSes that the hotel asks us to integrate with so that the
reservation you make with us is available to them during checkin.
8.4) As our business grows and evolves, the Subprocessors we engage may also change. We will endeavour to provide the owner of Customer’s account with notice of any new Subprocessors to the extent required under the Agreement, along with posting such updates here. Please check back frequently for updates.
9.1) We have implemented procedures to help protect the information that you provide to us. However, no method of transmitting or storing electronic data is ever completely secure, and we cannot guarantee that such information will never be accessed, used, or released in a manner that is inconsistent with this policy. You agree and acknowledge that we may engage third-party services providers for the provision of cloud service storage solutions, and Simplotel is not responsible for any lapse in security on the part of such service providers. We expressly disclaim any representation or warranty, whether express or implied, with respect to ensuring, guaranteeing, or otherwise offering any definitive promise of security in connection with your Information.
9.2) You shall be solely responsible for all activities performed by you through the relevant Merchant Website. Simplotel assumes no responsibility or liability for the improper use of information relating to usage of credit cards and/or debit cards by you, whether online or off-line.
9.3) To protect your privacy and security, we will verify your identity before granting access or making changes to your personally identifying information.
10. CONTACT US