MOXY Chelsea

Privacy Policy

1. WHO WE ARE

This website (“Site”) is operated by the Moxy Hotels (“Moxy,” “we,” “us” and/or “our”). You can contact us as indicated under the “Contact” section below.

2. WHAT IS THIS PRIVACY POLICY IS FOR

This privacy policy (“Privacy Policy”) applies to personal data that we collect from you as a user of this Site or as a client or customer (“you” or “your” being interpreted accordingly). It provides information on what personal data we collect, why we collect the personal data, how it is used and the lawful basis on which your personal data is processed, and what your rights are under the applicable data protection and privacy laws, including the General Data Protection Regulation (“GDPR”) which became applicable to us and you as of May 2018.

Personal data as used in this Privacy Policy means any information that can be used to directly or indirectly identify an individual, and may include your name, address, email address, phone number, contact preferences and IP address.

By using our Site or submitting your personal data you are agreeing to accept the terms of this Privacy Policy, so please read it carefully.

3. PERSONAL DATA WE COLLECT

We collect the following personal data about you:

• Reservation Information: Guest information, such as your first and last name, email address, billing and payment information (for further details please also refer to the section below headed “Payment Information”).
• Other Information: Personal details you choose to give when corresponding with us by phone or e-mail, participating in user/customer surveys or otherwise visiting and interacting with this Site or any other websites we operate, and personal data that you provide to us when you visit one of our hotels. We can also combine personal data that you provide to us with other information we collect about you when you make a reservation through third-party services such as online restaurant-reservation or travel fare aggregator websites, as necessary to process your requests.

4. AUTOMATICALLY COLLECTED PERSONAL DATA

Log Data: When you visit our Site, our servers record information (“log data”), including information that your browser automatically sends whenever you visit the Site. This log data includes your Internet Protocol (“IP”) address (from which we understand the country you are connecting from at the time you visit the Site), browser type and settings, the date and time of your request.

Our Site uses cookies (small text files placed on your device) and similar technologies to distinguish you from other users. This is to provide you with a good user experience when you browse our Site and allows us to improve its features.

5. HOW WE USE YOUR PERSONAL DATA

We use your personal data on the following grounds:

• Our legitimate business interests: For example, in connection with completion and fulfillment of reservations, to conduct user/customer surveys, to address inquiries and complaints, for direct marketing or service improvements, for administrative, operational, IT, troubleshooting, data analysis or analytics purposes, to provide you, with information about goods or services, events and other promotions we feel may interest you as a customer. Where we rely on this basis, we carry out a legitimate business assessment to ensure that our business interests do not override your rights. In some cases, you may have the right to object to this use of your personal information. For more information, please read the ‘Your Rights’ section of this Privacy Policy.
• Contract: Where it is necessary in connection with a product or service we are providing to you
• Consent: If we are not relying on another basis for processing your personal information, we will seek your consent prior to any use of your personal information. A clear request for your consent will be presented to you and you will have the ability to withdraw your consent at any time.

We may anonymize, aggregate and de-identify the data that we collect and use such anonymized, aggregated and de-identified data for our own internal business purposes, including sharing it with our current and prospective customers, business partners, our affiliated businesses, agents and other third parties for commercial, statistical and market research purposes, for example to allow those parties to analyze patterns among groups of people, and conducting research on demographics, interests and behavior.

6. DISCLOSURE OF YOUR INFORMATION

We may share your personal data with third parties in the following situations:

• With other companies in the Moxy group, our partners, suppliers or agents who perform services on our behalf, such as (i) card processing or payment services (see the section below headed “Payment Information”), (ii) credit reference agencies to protect against possible fraud, (iii) IT suppliers and contractors (e.g. data hosting providers or delivery partners) as necessary to provide IT support and enable us to provide goods/services available on this Site or to members, (iv) web analytics providers, (v) providers of digital advertising services and (vi) providers of CRM, marketing and sales software solutions
• In response to a request for information from a competent authority if we believe disclosure is in accordance with, or is otherwise required by, any applicable law, regulation or legal process with law enforcement bodies or other third parties as necessary to comply with the law;
• If we decide to re-organize or sell our businesses we may need to disclose your personal information in the course of this activity to prospective purchasers; or
• If we otherwise notify you of the disclosure and you consent to it.

7. PAYMENT INFORMATION

Any credit/debit card payments and other payments you make through our Site will be processed by our third-party payment providers and the payment data you submit will be securely stored and encrypted by our payment service providers using up to date industry standards. Please note that we do not ourselves directly process or store the debit/credit card data that you submit.

We may arrange that card or payment data you submit in support of a reservation is stored for the purpose of collecting the applicable fees. We store and use this card or payment information for the purpose of processing any future payments that you make as a customer for additional goods and services. We will store this data in accordance with our legal obligations under applicable law and only for so long as legally permitted. You may choose to opt out of us holding your card or payment data although this means that you will need to re-supply us with card/payment details for the purpose of making any future purchases.

8. PERSONAL DATA TRANSFERS

If you are based in the European Union (EU) we may need to transfer your personal data to recipients outside of the EU.

This may happen if our servers or our suppliers or service providers are based outside the EU or if you visit our website while traveling to countries outside this area.

We only make these transfers, where the EU has made an ‘adequacy decision’ for the country to which the data will be transferred or where we have put in place the ‘appropriate safeguards’ that the law requires.

9. SECURITY

Where we have given you (or where you have chosen) a password or log-in which enables you to access certain restricted parts of our Site, you are responsible for doing everything you reasonably can to keep these details secret. You must not share your password or log-in details with anyone else.

Unfortunately, the transmission of information over the internet or public communications networks can never be completely secure. We will take appropriate technical and organizational security measures to protect the personal data that you submit to us against unauthorized/unlawful access or loss, destruction or damage, although we cannot 100% guarantee the security of personal data that you provide to us online.

10. YOUR DATA PROTECTION RIGHTS

We will keep your personal data only for as long as is reasonably necessary for the purposes outlined in this Privacy Policy, or for the duration required by any legal, regulatory, accounting or reporting requirements, whichever is longer. Upon expiration of the applicable retention period we will securely destroy your personal data in accordance with applicable laws and regulations. In some circumstances we may anonymize your personal data so that it can no longer be associated with you, in which case it is no longer personal data.

11. YOUR PERSONAL DATA PROTECTION RIGHTS

Your local law may provide rights regarding the use of your personal information. Where the GDPR applies to personal information, it gives individuals resident in the EU certain rights that they can exercise free of charge. These include the:

• Right to correct your personal information
• Right to access your personal data
• Right to data portability
• Right to object to use of personal data (for example, where we are using it for direct marketing or our lawful basis is our legitimate interest)
• Right to restrict the use of your data in some circumstances
• Right to erasure in some circumstances

If you would like to assert one or more of these rights, please email or write to us at the address set out in the Contact section of the Privacy Policy. We will respond to your requests within all applicable timeframes.

You may also unsubscribe from receiving our email marketing communications at any time by following the “unsubscribe” instructions included in our communication.

12. CHANGES TO OUR PRIVACY POLICY

Any changes we may make to our Privacy Policy in the future will be posted on this page. Please check back frequently to see any updates or modifications. If required by the applicable law, we will notify you of any material or substantive changes to this Privacy Policy.

13. CONTACT

Questions, comments or requests regarding this Privacy Policy should be addressed to compliance@lightstonegroup.com.