Personal data management

Radisson Hotel Group Privacy Policy

LAST REVISED 18 JUNE 2019

Framework for this policy

This Privacy Policy describes how the Radisson Hotel Group and its affiliates and

subsidiaries ("we") collect, use, access and process individual personal data.

This Privacy Policy applies internationally, but depending on where you live

If you are a resident of Canada, some of the provisions of this Privacy Policy may not apply in your country.

your case.

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Depending on the type of personal data, and for the purposes of the European Data Protection Regulation

Radisson Hospitality Inc. and/or Radisson Hospitality Belgium SPRL/BVBA will be considered to be the sole provider of the data.

as controllers or joint controllers. If these groups operate as co

responsible, the two entities will determine together the means and purposes of the processing of your

personal data. This means that you will be able to exercise your rights with either of the

by contacting one of the two companies, as explained below.

In some of the situations described in this Privacy Policy, the hotel in which you

make a reservation and/or a stay will also process your data as the person responsible for or

joint controller. If acting as sole controller, the hotel undertakes to

process the data concerned on its own.

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Radisson Hospitality, Inc. is a company incorporated under the laws of the United States, with its principal place of business and registered offices in the United States.

offices are located at 701 Carlson Parkway, Minnetonka, MN 55305, USA, telephone number

Telephone: +1 (763) 212 5000.

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Radisson Hospitality Belgium SPRL/BVBA is a company under Belgian law, registered with the

Crossroads Bank of Belgian Enterprises, with company number 0442.832.318, and whose registered office is at

The official seat and offices are located at Avenue du Bourget 44, B-1130 Brussels, telephone number

telephone: +32 2 702 9200.

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

The purpose of this Privacy Policy is to inform you about the methods of collection, the definition

and the use of the personal data you provide to us when you use our sites

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Internet and mobile applications, or when using our hotel services. Please note

take the time to read this Privacy Policy carefully. Please note that if you have

the intention to send us the personal data of others, for example when you

a reservation on behalf of another person, you may not share their information

only with his or her prior consent, and once that person has been made aware of the

information about the use of its data, including the principles set out in this Privacy Policy.

confidentiality.

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THIS POLICY INCLUDES A DESCRIPTION OF YOUR RIGHTS REGARDING

DATA PROTECTION, SUCH AS THE RIGHT TO CHALLENGE CERTAIN ACTIVITIES

OF THE PROCESSING THAT WE CARRY OUT. PLEASE NOTE THAT YOUR RIGHTS AS A

THE NUMBER OF PEOPLE INVOLVED MAY VARY DEPENDING ON WHERE YOU LIVE.

THE EUROPEAN DATA PROTECTION REGULATION REQUIRES US TO

LET'S BE PRECISE ABOUT OUR REASONS AND LEGAL BASIS FOR USING

YOUR PERSONAL DATA. THEREFORE, FOR THE SOLE PURPOSE OF THE REGULATION

ON DATA PROTECTION, THE INFORMATION BELOW

DESCRIBE THE TYPES OF DATA WE PROCESS, HOW WE PROCESS IT AND HOW WE

YOUR DATA, THE GROUNDS ON WHICH WE RELY ON IT, AND THE REASONS WHY WE

AND WITH WHOM WE MAY SHARE IT. WITH THE EXCEPTION

OF THE CATEGORIES OF PROCESSED DATA PRESENTED BELOW, NO OTHER

THIS PROVISION IS NOT INTENDED TO BIND US CONTRACTUALLY TO OUR USERS

NON-EU NATIONALS.

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Country-specific provisions

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Please note that there may be local variations to this Privacy Policy, in order to be in line with the

compliance with local legislation.

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In particular, there may be differences within the European Union. In this case, please

contact your hotel receptionist for more information, or contact us

contact privacyquestion@radissonhotels.com. If you have any questions about the practices of a

hotel or the information it provides to you, please contact

the hotel.

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Definitions

Affiliates and subsidiaries: Any company, firm, partnership or other entity that directly or indirectly

indirectly, controls, is controlled by, or is under common control with Radisson Hospitality Inc.

and/or Radisson Hospitality SPRL/BVBA.

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Datacontroller: The natural or legal person, public authority, agency or any

other body which, alone or jointly with others (co-leaders), determines the purposes and

the means of processing personal data.

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European Data Protection Regulation: Regulation 2016/679 of the European Parliament

and of the Council of 27 April 2016 on the protection of individuals with regard to the processing

of personal data and the free flow of such data (the "GDPR"), and

any legislation and/or regulations implemented or created in accordance with the GDPR and the legislation

relating to online privacy, or which modifies, replaces, re-adopts or consolidates any of them, and

all other applicable national laws relating to the processing of personal data and the protection of privacy.

protection of privacy.

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Data manager: A natural or legal person, public authority, agency or

any other body that processes personal data on behalf of the controller

treatment.

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Addressee: A natural or legal person, public authority, agency or other

organization, to whom the personal data is disclosed, whether it is a third party or not.

Third party: A natural or legal person, public authority, agency or any other body

that the data subject, the controller, the data manager, and the

persons who, under the direct authority of the data controller or data manager, are authorised

to process personal data.

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Supervisory authority: An independent public authority that is established by a Member State

in accordance with Article 51 of the GDPR.

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Personal data: Any information relating to an identified or identifiable natural person.

identifiable person (data subject). An identifiable natural person is a person who can be

identified, directly or indirectly, in particular by reference to an identifier such as a name, a

identification number, location data, an online identifier or to one or more

factors specific to physical, physiological, genetic, mental, economic, cultural identity

or company of that natural person.

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Processing: Operation or set of operations performed on personal data or on

personal data sets, whether or not by automated means, such as the

collection, recording, organisation, structuring, storage, adaptation or modification, and

retrieval, access, use, disclosure by transmission, dissemination or otherwise

form of making available, aligning or combining, restricting, deleting or

destruction.

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Data Protection Shield: The legal framework for data protection shields

EU/US and Switzerland/US designed by the Department of Commerce, the European Commission and the

Swiss government to provide a mechanism for companies on both sides of the Atlantic to

to meet data protection requirements, where personal data

from the European Union and Switzerland are transferred to the United States in favour of the

transatlantic trade.

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Radisson Hotel Group: The administrative entities of Radisson, including but not limited to

Radisson Hospitality, Inc. and Radisson Hospitality Belgium SPRL/BVBA, but also the hotels that

operate under the Radisson Hospitality brands (including but not limited to Radisson Blu,

Radisson RED, Radisson Collection, Park Plaza and Park Inn) and their affiliated entities.

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Standard contractual clauses: A set of standard contractual clauses for transfers,

adopted by the European Commission for the international transfer of personal data.

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Personal data breach: A security breach resulting in the destruction of

accidental or unlawful loss, alteration, unauthorised disclosure or access to the

personal data transmitted, stored or otherwise processed.

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Hotel booking procedure

1. Hotel reservation procedure

In the context of the hotel booking procedure, whether it is made online on one of the

of our brands, via an online booking channel, a travel agent, our

or directly with the hotel, we process your personal data for the purpose of (i)

enable you to book the hotel room of your choice; (ii) check the availability of the hotel

and administer the booking; (iii) to send you a booking confirmation; and (iv) to

send emails prior to your arrival. You can unsubscribe from pre-arrival emails at

You can unsubscribe at any time by clicking on the unsubscribe links in the emails you receive.

receive.

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Categories of data processed

Address, booking details (including booking number), date of arrival and departure,

e-mail address, first name/last name, first name/last name of other adult guests, type of payment card,

expiry date and number, Radisson Rewards membership number, telephone number, title

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Source of data

Depending on the reservation mechanism used :

- Directly from the online booking form

- Through the online booking channel used to make the booking

- Via your travel agent

- Via our call centre

- Via the Radisson hotel with which you booked directly

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Reasons for data processing

The processing of data is necessary to conclude and fulfil a contract.

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Recipients of the data

- The Radisson hotel of your choice

- Other Radisson Hotel Group entities involved

- IT service providers involved in the (online) booking process

- IT service providers

- E-mail communication service providers

2. Interrupted or incomplete online booking process (abandoned basket)

When you book online but for some reason you are unable to

To complete the booking process, we process your personal data for the purpose of

allow you to continue the procedure easily online, by sending you an e-mail with a link

to the online booking form, which is pre-filled with the data you have entered

already provided in the form.

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Categories of data processed

Address, date of arrival and departure, e-mail address, first name/last name, first name/last name of other guests

adults, type of payment card, number and expiry date, Radisson membership number

Rewards, phone number, civility

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Source of data

Directly from the online booking form

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Reasons for data processing

It is in the interest of the Radisson Hotel Group as a company to again offer the

sale of a reservation whose procedure has been interrupted or is incomplete. In this context, the

Radisson Hotel Group's business interests take precedence over yours.

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Recipients of the data

- E-mail communication service providers

- Targeted advertising providers

3. Customer satisfaction surveys

We may send you customer satisfaction surveys by e-mail, during

or after your stay to enable us to evaluate the performance of our hotels. You can

unsubscribe from our customer satisfaction survey emails at any time by clicking on the

unsubscribe available in the emails sent to you.

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Categories of data processed

Country of residence, date of arrival and departure, e-mail address, first name/surname, nationality, telephone number

Radisson Rewards member, stay information

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Source of data

Depending on the reservation mechanism used :

- Directly from the booking form

- Through the online booking channel used to make the booking

- Via your travel agent

- Via our call centre

- Via the Radisson hotel with which you booked directly

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Reasons for data processing

The processing of data is necessary to carry out the contract between us.

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Recipients of the data

- Other Radisson Hotel Group entities involved

- Customer satisfaction survey provider

4. Analysis of service emails

In the context of service e-mails, which include e-mails for customer satisfaction surveys

and all pre-arrival emails relating to your booking, we can process and

collect your personal data, especially if you have opened and activated such an e-mail, in order to

measure the click-through rate and improve the content of service emails. You can unsubscribe

of our service emails at any time by clicking on the unsubscribe link contained in the

service emails you receive.

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The information below describes the types of data we process for this purpose, how

we obtain your data, the grounds on which we rely to carry out the collection, and the

processing, and with whom we may share your data.

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Categories of data processed

E-mail address, clicking behaviour in e-mails, e-mail opening behaviour

e-mail, first name/name, Radisson Rewards membership number

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Source of data

From our email analytics service providers

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Reasons for data processing

It is in the legitimate interest of the Radisson Hotel Group as a business to understand the

behaviour of its customers in terms of clicks from e-mails, in order to identify improvements

necessary. In this context, the commercial interests of the Radisson Hotel Group prevail over the

your own.

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Recipients of the data

- Other Radisson Hotel Group entities involved

- IT service providers

- Email analysis service provider

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Hotel guests

1. Arrival and departure from the hotel

During your stay at the hotel of your choice, we will collect and process your personal data

for the purpose of (i) registering your arrival and departure at the hotel; (ii) issuing you with a key card to

your room or allow you to use your mobile device as a room key; (iii)

obtain a credit card guarantee or deposit to ensure payment for your stay; (iv)

manage (and archive) your hotel card; (v) create or update your profile in our

(vi) to assess your eligibility for a room upgrade and the

(vii) manage the payment of your stay; (viii) prepare, print or send

an invoice for your stay; and (ix) pay a commission to your travel agent (if applicable).

where applicable).

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If you have booked a room in one of our hotels, but you do not wish to stay in the hotel, you can

If you do not arrive on the date communicated, without cancelling, we will process your data

(i) to cancel your holiday and any other booking you may have made; and

(ii) manage, process and settle any outstanding payments that may be due.

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Categories of data processed

Address, reservations (hotel, restaurant, event, theatre, etc.), arrival and departure dates,

e-mail address, first name/last name, first name/last name of other adult customers, type of payment card,

expiry date and number, Radisson Rewards membership number, telephone number, title

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Source of data

Depending on the reservation mechanism used :

- Directly from the booking form

- Through the online booking channel used to make the booking

- Via your travel agent

- Via our call centre

- Via the Radisson hotel with which you booked directly

- Directly to you via the hotel registration card

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Reasons for data processing

The processing of data is necessary for the performance of the contract between us.

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Recipients of the data

- Other Radisson Hotel Group entities involved

- IT service providers

- Your travel agent (if applicable)

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2. Credit reports

To guarantee payment for all guests staying at the hotel, each guest must present a

credit card or a deposit on arrival. In order to ensure that you do not exceed your credit limit, we will

during your stay, we run a credit limit report several times a day to ensure that your credit limit is not exceeded.

check whether your credit limit has been exceeded. These credit reports may contain your

personal data. Please note that, in limited circumstances, these

may be subject to one of our internal financial audits, and therefore may be subject to a

consulted by members of our internal audit department, to ensure that our hotels

comply with the internal guidelines and policies of the Radisson Hotel Group.

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Categories of data processed

Date of arrival and departure, first name/name, type of payment card, number and expiry date

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Source of data

Depending on the reservation mechanism used :

- Directly from the booking form

- Through the online booking channel used to make the booking

- Via your travel agent

- Via our call centre

- Via the Radisson hotel with which you booked directly

- Directly to you via the hotel registration card

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Reasons for data processing

The processing of data is necessary to ensure the performance of the contract performance of the contract

that binds us.

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Recipients of the data

- Other Radisson Hotel Group entities involved

- IT service providers

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3. Hotel stay

When you stay at one of our hotels, we strive to make your stay as comfortable as possible.

pleasant as possible. This involves processing your personal data for the purpose of

provide specific services during your stay at the hotel. These services include (i) maintenance

and maintenance; (ii) the return of lost or forgotten items; and/or (iii) the management of your

preferences and those of your co-guests, such as dietary requirements and food preferences.

We have a wide range of pillows to offer you a better service during your stay with us.

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Categories of data processed

Address, eating habits, arrival and departure dates, dietary requirements, address and phone number of the family.

mail, first name/last name, first name/last name of other adult guests, other preferences, contact details

payment (for the purpose of returning lost or forgotten items), telephone number

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Source of data

Depending on the reservation mechanism used :

- Directly from the booking form

- Through the online booking channel used to make the booking

- Via your travel agent

- Via our call centre

- Via the Radisson hotel with which you booked directly

- Directly to you during your stay in the hotel

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Reasons for data processing

It is in the legitimate interest of the Radisson Hotel Group as a business to organise its activities

the hotel's daily maintenance, to personalise the services it provides and/or to be able to

identify the owner of a lost or forgotten object. Given the limited amount of data

personal data processed and shared for this purpose, the business interests of the Radisson Hotel Group

outweigh your own.

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Recipients of the data

- Hotel staff, including housekeeping, maintenance, reception staff

and/or other relevant hotel staff

- Other Radisson Hotel Group entities involved

- IT service providers

- Mail or delivery service providers (for the purpose of returning lost or damaged items)

forgotten)

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4. Additional services and facilities for hotel guests

In many of our hotels you can enjoy the following services and facilities

such as breakfast, room service, minibar, swimming pool

restaurants and bars, spa treatments, laundry service, parking, taxi requests, the

Free Wi-Fi, etc. In case you use additional services or facilities in one of the hotels, please contact us.

of our hotels, your personal data may be processed to (i) manage the booking and

use of such additional hotel services and/or facilities; (ii) manage reservations

services and/or facilities in your file; (iii) personalise your file by

the arrival of returning guests and the choice of facilities and features of the hotel.

rooms; and (iv) manage the expenses incurred for these additional services and/or facilities.

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Categories of data processed

Eating habits, arrival and departure dates, dietary requirements, e-mail address,

first name/last name, first name/last name of other adult guests, type of payment card, number and date

expiry date, Radisson Rewards membership number, title

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Source of data

- Directly from the online booking form

- Through the online booking channel used to make the booking

- Via your travel agent

- Via our call centre

- Directly to you via the hotel registration card

- Directly to you when you request a service or equipment

additional information at the hotel reception or with the concierge

- Via the online booking platform for additional services and facilities

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Reasons for data processing

The processing is necessary for the conclusion and/or performance of the contract.

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Recipients of the data

- Hotel staff, including reception, room service and/or other staff

staff of the hotel concerned

- Other Radisson Hotel Group entities involved

- IT service providers

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Loyalty programmes

1. Radisson Rewards

Radisson Rewards is a worldwide hotel loyalty programme, applicable in all hotels in the

Radisson Hotel Group, and available to guests staying in our hotels, as well as to

business partners, whether they are staying there as clients or booking on behalf of others

people. The Radisson Rewards program is managed by Radisson Hospitality, Inc. The programme

Radisson Rewards offers you many advantages and allows you to collect points

Radisson Rewards during your stay in our hotels, and by purchasing from selected

partners. In this context, we may process your personal data in order to

(i) create your Radisson Rewards profile online, and send you an activation link by e-mail

(ii) provide you with information about your Radisson Rewards points

bookings and award points on your membership card; iv) inform you of your rewards

when you reach a certain level of points; and v) inform you of any changes to the

to the Radisson Rewards programme.

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Categories of data processed

First name/last name, hotel stay information, loyalty program membership number of a

relevant partner company

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Source of data

Directly to you when you request or redeem miles or points

Reasons for data processing

The processing of data is necessary to take action at your request in order to

to execute the contract between us and the recognised partner(s).

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Recipients of the data

- Other Radisson Hotel Group entities involved

- IT service providers

- Relevant partner company

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2. Other loyalty programme

In addition to the Radisson Rewards programme, we also offer our guests the opportunity to

earn miles or points in our partners' loyalty programs, such as

frequent flyer, car rental and transport loyalty programmes

rail. In this context, we may process your personal data in order to (i)

credit your membership account with miles or points at one of our recognised partners after

your stay at our hotel; and (ii) evaluate and fulfill your request to redeem your miles or points

loyalty programmes of our recognised partners at our hotel.

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Categories of data processed

First name/last name, hotel stay information, loyalty program membership number of a

relevant partner company

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Source of data

Directly to you when you request or redeem miles or points

Reasons for data processing

The processing of data is necessary to take action at your request in order to

to execute the contract between us and the recognised partner(s).

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Recipients of the data

- Other Radisson Hotel Group entities involved

- IT service providers

- Relevant partner company

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3. Points

We offer you the possibility to redeem your loyalty points for items such as

gifts, offers from our partners or to help associations. When you make a

In exchange, we process your personal data but also, if applicable, those of the

recipient of the gift card, in order to take care of and correctly complete your exchange. If

you purchase a gift card for another person, we process personal data

to be able to deliver the gift card to the recipient by e-mail or post.

Categories of data processed

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First name/last name, type of payment card, number and expiry date, your address, telephone number, and the number of your

telephone, login details, e-mail address and IP address. If you purchase a gift card

for another person and depending on the delivery method, we will also process the address of the

recipient, the recipient's e-mail address, the recipient's first and last name and his or her telephone number.

phone

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Source of data

Directly to you when you redeem points at the hotel or online

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Reasons for data processing

The processing of data for the performance of the contract you have concluded with us.

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Recipients of the data

- Other Radisson Hotel Group entities involved

- IT service providers

- Gift card platform provider

- Payment service provider

- IT service providers involved in the (online) booking process

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Gift cards

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We offer the possibility to purchase physical or electronic gift cards that can be

exchanged in our hotels to pay for hotel, restaurant and spa treatments.

1. Purchase of a gift card

When you purchase a gift card at one of our hotels or online, we process your

personal data and, if applicable, the personal data of the beneficiary of the gift card

to manage and complete your purchase of the gift card. If you are purchasing the gift card for

another person, we process additional personal data in order to be able to issue the

gift card to the recipient by e-mail or post.

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Categories of data processed

- First name/last name, type of payment card, number and expiry date

- When the gift card is purchased online, in addition to the conditions mentioned above

below, we will process your address, login details, email address and

IP address

- If you purchase the gift card for another person and depending on the delivery method, we will

also process the recipient's address, the recipient's e-mail address, the recipient's first and last name, and

recipient and his telephone number

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Source of data

Directly from you when you purchase the gift card at the hotel or online

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Reasons for data processing

The processing of data is necessary to carry out the contract between us.

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Recipients of the data

- Other Radisson Hotel Group entities involved

- IT service providers

- Gift card platform provider

- Gift card manufacturer

- Payment service provider

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2. Register your gift card

As a recipient of one of our gift cards, you can choose to register your gift card.

online gift to protect the remaining amount on the card in case of loss or theft. If you

decide to register your gift card, we will process your personal data for the purpose of

to make this recording.

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Categories of data processed

Address, date of birth, e-mail address, first name/last name, telephone number, title

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Source of data

Directly to you when you register the gift card online

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Reasons for data processing

Ad hoc consent obtained when registering the gift card

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Recipients of the data

- Other Radisson Hotel Group entities involved

- IT service providers

- Gift card platform provider

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Subscribe to our newsletters

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1. Newsletters and advertising communications

If you have explicitly given your consent to receive our newsletters or

communications, including with respect to Radisson Rewards, we may, from time to time, use our

contact you from time to time to provide you with information about our services and

and therefore process your personal data for this purpose.

If you no longer wish to receive our newsletters or advertising communications, please

Please let us know by sending an e-mail to privacyquestion@radissonhotels.com. You

can unsubscribe from our advertising emails by clicking on the unsubscribe link

contained in the e-mails you receive. For the Radisson Rewards programme, you can

also unsubscribe by updating your profile.

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Categories of data processed

- Address, date of birth, e-mail address, first name/last name, gender, hobbies and interests, telephone number

telephone number, hotel stay history, country of residence

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Source of data

- Directly to you when you subscribe to our newsletter or later by

completing your account

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Reasons for data processing

- Ad hoc consent obtained when subscribing to our newsletter

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Recipients of the data

- Other Radisson Hotel Group entities involved

- IT service providers

- E-mail communication service providers

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2. Analysis of newsletters and advertising communications

We may also collect and use your personal data in connection with our letters

information and advertising communications, especially if you have initiated a conversation through the

through one of our communication channels, in order to analyse and measure the click rate, and

to improve the content of our advertising communications.

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Categories of data processed

- E-mail address, clicking behaviour in e-mails, e-mail opening behaviour

e-mail, first name/name, Radisson Rewards membership number

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Source of data

- Via our email analytics service providers

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Reasons for data processing

- It is in the legitimate interest of the Radisson Hotel Group as a business to understand the rate of

In this context, it is important to have a clear understanding of the interests and needs of the target group. In this context, the interests

The Radisson Hotel Group's commercial activities outweigh yours.

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Recipients of the data

- Other Radisson Hotel Group entities involved

- IT service providers

- Email analysis service provider

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Mobile applications

To help our customers book, plan and enjoy their stay, we offer applications

mobile of our various hotel brands including, but not limited to Radisson Blu, Radisson RED, Radisson Rewards and Park Inn.

These mobile applications can be downloaded

via online application shops such as the Apple App Store or Google Play.

Depending on how you use our mobile applications, your personal data may be

processed to (i) enable you to book a room in the hotel of your choice (see

(ii) process your online check-in; (iii) manage your online registration; (iv) provide you with the

(iii) ordering room service; (iv) reserving a table in a local restaurant; (v) carrying out

special services at your request, such as wake-up service, late departures or

(vi) the possibility of booking meetings and events in our premises.

(vii) the processing of your online check-out and comments on your stay; (viii) the

processing requests you have made through the mobile application, including chat;

and (ix) the display of the number of loyalty points you have accumulated.

If you do not want us to use your real-time geolocation information,

please do not subscribe to the location services. If you have subscribed and wish to

change this option, you can opt out by adjusting the settings on your device or

by deleting the application. Similarly, if you no longer wish to receive push notifications via

one of our mobile applications, you can remove push notification permission for

the mobile application in your device's operating system settings.

The information below describes the types of data we process in the course of our

mobile applications, where we get your data from, the grounds on which we rely

to carry out their processing and with whom we may share your data. For the application

For more information on the Radisson Rewards mobile, please see the dedicated section in the Radisson Rewards section.

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Categories of data processed

- E-mail address, first name/last name, location data, stay information, phone number

phone

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Source of data

- Directly from you when you download one or more of our applications, or

when using the application(s)

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Reasons for data processing

- Ad hoc consent obtained when installing the application or in the course of your use

of the application

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Recipients of the data

- The Radisson hotel of your choice

- Other Radisson Hotel Group entities involved

- Mobile application provider

- Hosting and cloud service providers

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iBeacon

iBeacons are electronic devices that emit signals that can be received by

mobile devices, on which one of our applications is installed. If you have installed one of our

our applications on your device, and that you have authorised the use of geolocation by

the iBeacons installed in our hotel will be able to send a signal to your device via

the application, showing the exact location of your device in real time. The application will be able to

use this information to provide you with special offers and promotions, and to

for your location and time of day. For example, if

If you are in one of our hotels in the late afternoon, your mobile device may receive a

signal from an iBeacon, informing you of our special aperitifs or dinners, via a notification

on the application. Depending on your preferences, the reception of iBeacons messages and proposals

special offers or promotions can be made even if you are not using the application. In order for

our mobile application and services work optimally, we may also

collect other information from the iBeacons' signals, for example, signal strength

between the iBeacon and your device, the time spent near an iBeacon, or the level of

battery of the iBeacon itself. If you do not want us to use your

If you have a real-time geolocation service, please do not subscribe to the location-based services. If you have

and you wish to change this option, you can opt out by adjusting the

settings on your device or by deleting the application.

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Website forms

If you have a specific question or comment, or if you wish to exercise one of your

rights under the RGPD, you can contact us through the contact forms

available on our websites. In this context, we may process your personal data

for the purpose of processing and providing a response to your question or request, or to follow up on

your comments. We also provide other forms on our websites that

can help you request a particular service from us, such as the

guaranteed best price online.

The information below describes the types of data we process for these purposes, from which we

obtain your data, the grounds on which we rely for processing and

with whom we may share your data.

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Categories of data processed

- Address, e-mail address, first name/first name, Radisson Rewards membership number, contact information

stay, telephone number and any other data you choose to give us in

the free comment form.

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Source of data

- Directly from the form

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Reasons for data processing

- Ad hoc consent obtained via the contact form

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Recipients of the data

- Other Radisson Hotel Group entities involved

- IT service providers

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Meetings and events

1. Organisation of meetings and events and comments

If you want to organise a meeting or an event in one of our hotels or if you want to

For more information on this subject, please contact us via the quote request form or the

contact form available on our Website(s), by writing to us on the chatbot (or agent)

dedicated to meetings and events, by contacting the hotel directly.

your choice or by contacting us in other ways. The personal data collected will be

used for the purpose of responding to your request to organise a meeting or event.

We may also send you satisfaction surveys after your meeting or event.

event to measure the performance of our hotels as meeting venues.

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Categories of data processed

- Address, date of meeting or event, e-mail address, first name/surname, occupation

and position, Radisson Rewards membership number, telephone number

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Source of data

Directly to you via :

- the online quote request form

- the online contact form

- the online chatbot for meetings and events

- a request that would have reached us by other means

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Reasons for data processing

Depending on whether you sign the contract directly with us or on behalf of your company,

- The processing of data is necessary to take action, at your request, to

to execute the contract between us

- It is in the legitimate interest of the Radisson Hotel Group as a company to have the

contact details of a main contact person from the company organising the meeting or event and informing them of

of its comments. In this context, the business interests of Radisson Hotel Group

outweigh your own.

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Recipients of the data

- The hotel of your choice

- Other Radisson Hotel Group entities involved

- IT service providers

- Online chatbot service provider

- Provider of meeting satisfaction surveys

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2. Publicity for meetings and events

If you have chosen to receive advertising communications in connection with the organisation of a

meeting or event, we will also use your data to contact you and to provide you with information about the

provide information about our current services and offers.

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Categories of data processed

- Address, e-mail address, first name/surname, occupation and position, telephone number

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Source of data

Directly to you via :

- the online quote request form

- the online contact form

- the online chatbot for meetings and events

- a request that would have reached us by other means

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Reasons for data processing

Ad hoc consent obtained via :

- the online quote request form

- the contact form

- the online chatbot for meetings and events

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Recipients of the data

- Other Radisson Hotel Group entities involved

- IT service providers

- Online chatbot service provider

- E-mail communication service providers

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3. Analysis of publicity communications about meetings and events

We may also collect and use your personal data in the context of our

communications about a meeting or event, especially if you have

initiated a conversation through one of our communication channels, for analysis and

to measure click-through rates and to improve the content of our advertising communications.

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Categories of data processed

- E-mail address, clicking behaviour from e-mails, opening behaviour of e-mails

e-mail, first name/surname, occupation and position, Radisson Rewards membership number

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Source of data

- Via our email analytics service providers

Reasons for data processing

- It is in the legitimate interest of the Radisson Hotel Group as a business to understand the rate of

In this context, it is important to have a clear understanding of the interests and needs of the target group. In this context, the interests

The Radisson Hotel Group's commercial activities outweigh yours.

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Recipients of the data

- Other Radisson Hotel Group entities involved

- IT service providers

- Email analysis service provider

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Analysis

We may use any data collected from you for analytical purposes in order to

to optimise your experience, improve our marketing, business and marketing effectiveness, and

to create customer segments from your personal data and to tailor the information to your needs.

our offers and promotions to your preferences and consumption habits. In the context of this

In this way, we analyse and can aggregate different data we have about

our guests, including (i) responses to our customer satisfaction surveys; (ii) conversations

with our hosts; (iii) click-through rates from our advertising communications; (iv) the

(v) bookings; and (vi) any data received by our website.

through our Radisson Rewards programme. Please also see our

on theAnalysis of publicity communications about meetings and events and

Analysis of newsletters and advertising communications.

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Categories of data processed

- Details of hotel stay, address, reservations (hotel, restaurant, event, theatre, etc.), date

of arrival and departure, title, first name/surname, first name/surname of other guests

adults, e-mail address, telephone number, type of payment card, number and date

expiration date, Radisson Rewards membership number, redemption history

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Source of data

- Directly to you when you register for the Radisson Rewards programme or

when you book or redeem Radisson Rewards points

- Directly from the online booking form

- Through the online booking channel used to make the booking

- Via your travel agent

- Via our call centre

- Via our e-mail analysis provider

- Directly to you when you request a service or equipment

additional information at the hotel reception or with the concierge

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Reasons for data processing

- It is in the legitimate interest of the Radisson Hotel Group as a business to understand the

preferences and consumption patterns of its customers. In this context, the interests

The Radisson Hotel Group's commercial activities outweigh yours.

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Recipients of the data

- Other Radisson Hotel Group entities involved

- IT service providers

- Analysis service provider

- Targeted advertising providers

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Social media and online reviews

We may use your personal data submitted through media platforms

(including Facebook, Instagram, LinkedIn, Weibo and Twitter) or online reviews (including

TripAdvisor) regarding our Radisson Hospitality brands, for the purpose of (i) responding to your

(ii) to monitor our online reputation; and (iii) to improve our services

and identify opportunities that we could focus on.

Some of our social media pages allow users to post their own

content. Please note that any content posted on any of our social media pages is public

and you should be careful about sharing certain personal data on these platforms

(for example, your financial data or your address). We are not responsible for

actions taken by third parties if you post personal data on one of our

social media platforms (e.g. Facebook or Instagram). Please also see

the privacy and cookie policies on the social media platforms that

you use.

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Categories of data processed

- All personal data that you have decided to communicate to us or published on the

social media or other online reviews of us

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Source of data

- Directly to you via social media pages, online booking channels or

other websites (online reviews)

- Via our e-reputation monitoring service provider

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Reasons for data processing

- It is in the interest of the Radisson Hotel Group as a company to process Data

that you have chosen to send to us or to make publicly available on the

social media platforms, online booking channels or other websites (reviews

online) in order to improve our services and identify new business opportunities. In this

In this context, the business interests of Radisson Hotel Group take precedence over your own.

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Recipients of the data

- Other Radisson Hotel Group entities involved

- E-reputation monitoring service provider

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Competition on social media

We may run competitions on our social media pages from time to time. If you

choose to enter these competitions, we will use your personal data to

to organise and manage the competition on social media and to select the winner(s).

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Categories of data processed

- The categories depend on the fields of the competition in question, but include almost

always the following:

Address, e-mail address, first name/surname, telephone number

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Source of data

- Directly to you via our social media pages

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Reasons for data processing

- The processing of data is necessary to carry out the contract between us after you

have accepted the general conditions of the competition.

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Recipients of the data

- Other Radisson Hotel Group entities involved

- IT service provider

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Your rights - under the European Data Protection Regulation

If you live in the European Union, the European Data Protection Regulation

grants specific rights, summarised below, which you can in principle exercise free of charge,

subject to exceptions provided for by law. These rights may be limited, for example, in the

if fulfilling your request would involve disclosing the personal data of others, or if

you ask us to delete information that we are required by law to retain or which

we have legitimate and compelling reasons to retain. You can exercise your rights by

sending your request by e-mail to privacyquestion@radissonhotels.com.

If your problem is not solved, you can file a complaint with the

control of the country in which you reside or the country in which you believe an offence may have been committed

be committed. We encourage you to contact us in the first instance, but to the extent that

where this right applies to you, you are entitled to complain directly to the

control.

1. Right to withdraw consent

Wherever we ask for your consent, you can withdraw it at any time and from any place.

On your own initiative by logging into your online account (if you have one) or by contacting us

contacting privacyquestion@radissonhotels.com. Withdrawing your consent will not affect the

lawful collection and use of your data in accordance with your consent until

at the time you decided to withdraw it. Please note that we may have grounds

legal for the use of your data for other purposes, such as those set out in this policy

of confidentiality.

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2. Right of access and rectification of your data

You have the right to access, verify and rectify your data.

You can ask us for a copy of your data in order to check or correct them.

correct. You can easily change information such as your name, e-mail address, password, etc.

password and/or any other preferences by logging into your online account (if you have one)

or by contacting us at privacyquestion@radissonhotels.com. You can also request

a copy of the personal data we have used in accordance with this privacy policy

confidentiality.

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3. Right to erase your data

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In accordance with the European Data Protection Regulation, you have the right to erase

personal data we have used in accordance with this privacy policy, if

they are no longer necessary for the purposes for which your personal data were originally collected

collected and used, or if you have withdrawn your consent or objected to

the use of your personal data and no other legal basis applies. You

can have your personal data deleted by sending your request by e-mail

at privacyquest ion@radissonhotels.com.

4. Right to restrict the use of your data

In certain circumstances described in the European Data Protection Regulation,

you can ask us to restrict the use of your personal data. This is done by

This is the case, for example, when you dispute the accuracy of your personal data. In this case, we will

restrict the use of your personal data until you verify its accuracy.

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5. Right to object to the use of your data

In certain circumstances described in the European Data Protection Regulation,

you may object to the use of your personal data, including in cases where they

are used for direct marketing purposes.

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6. Right to portability of your data

If you have provided us with your personal data directly and their use is

carried out by automated means and in accordance with your consent or the establishment

contract with us, you have the right to receive personal data that we have

used in a structured, commonly used and machine-readable format, and

pass this data on to another service provider.

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Your rights - Users outside the European Union

Depending on your country of residence, you have different rights regarding personal data

you, and we will comply with the relevant requirements of applicable law and of

this privacy policy.

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Privacy rights in California

If you live in California, you can (once a year) ask us if we have shared

your personal data with third parties for direct marketing purposes. To make the request,

send us an e-mail to privacyquestion@radissonhotels.com or write to us at the following address

below. Indicate in your letter that you reside in California and apply for the

Shine the Light" law. In addition, you have the rights set out in our Privacy Policy.

Californian confidentiality.

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Nevada residents

For Nevada residents: we do not sell your information as defined by law

of Nevada.

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Russian citizens

In accordance with the Russian Federal Law "On Personal Data" No. 152-FZ we collect

record, systematize, accumulate, store, update (renew and modify), and

Extract personal data on Russian citizens using databases located in

on the territory of the Russian Federation. If you indicate that you are a Russian citizen of the

Russian Federation, we will process your personal data in accordance with this obligation and

your profile will be managed in databases located in the Russian Federation. If you

do not indicate that you are a citizen of the Russian Federation, we are not able to

manage your personal data in accordance with these requirements and are not responsible for it.

You are solely responsible for indicating your country of nationality. Information containing

personal information of Russian citizens can be transmitted from the Russian Federation to

countries that guarantee an acceptable level of personal data protection, including

EU Member States and other countries that Russian law considers can be

protection, as well as to other countries that may not guarantee an acceptable level of protection

protection of personal data. By submitting information to us on our sites and

applications, by submitting forms to us, or by registering on our sites, programs and

applications, or by making reservations, you consent to us processing your data

personal.

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Security measures

Appropriate technical and organisational measures shall be implemented to ensure that

adequate level of security for your personal data, including, but not limited to

encryption techniques, access controls to physical and computer systems, and

obligations regarding confidentiality, etc.

In the event that personal data has been compromised due to a data breach

personal data, we will make all necessary notifications in accordance with the laws

in force.

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What rules apply to children?

We do not knowingly collect or request personal data from anyone who is older than

under 18 years of age, nor do we knowingly allow such persons to book a room in one of our

our hotels. If we become aware that we have collected personal data about a

without verification of parental consent, steps will be taken to remove these

information. If you believe that we have or may have information about a

If you are a minor, please contact us at privacyquestion@radissonhotels.com.

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How is your personal data passed on to third parties?

We will only transmit or disclose information as set out in the

present, including to third parties.

Your personal data will also be passed on to government bodies and/or the

law enforcement officials if required for the above purposes, if required by law or if the

protection of the legitimate legal interests of the supervisory authority requires it, in accordance with the laws in

in force. In addition, we may pass your personal data and other information to a

of our business, where it is in our legitimate interests to do so in relation to a particular business.

cessation of trade. In this context, our commercial interests outweigh yours. If

part of our company or assets is sold, we may, for example, disclose information about the

user information in connection with this transaction, subject to applicable law.

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International data transfers

If you are a resident of the European Economic Area (EEA), the data we collect from you will

in accordance with this privacy policy may be transferred or stored

to a destination outside the EEA, including for the purpose of use of the data by

processing companies in order to facilitate the activities of the Radisson Hotel Group. The countries located

outside the EEA may not have laws that provide the same level of protection for your personal data.

personal data than the laws in force within the EEA. In this case, we will implement

appropriate safeguards to ensure that such transfers comply with the EU Regulation on

data protection, by introducing standard contractual clauses approved by the

European Commission as offering adequate protection, or by ensuring that the transfer

is carried out by a data protection shield compliant organisation in case the

transfer is made to the United States of America.

In this regard, please note that Radisson Hospitality, Inc. adheres to the Data Protection Shield

EU - USA and Switzerland - USA. In the event of a conflict between the rules of this

and the Data Protection Shield principles, the Data Protection Shield principles and the

data protection will apply. The monitoring of compliance with the principles of the

Radisson Hospitality, Inc. is subject to the jurisdiction of the Federal Trade

Commission. Radisson Hospitality, Inc. may have a potential liability for

subsequent transfer to a third party. For more information on the EU-State Data Protection Shield

For more information on the United States, as well as the Radisson Hospitality certification page, please visit

Internet https://www.privacyshield.gov/. By virtue of the application of the principles of the

EU - USA and Switzerland - USA data protection, Radisson Hospitality, Inc. is committed to

deal with complaints about the protection, collection and use of your personal data.

In addition, Radisson Hospitality, Inc. is committed to referring complaints that cannot be

resolved under the application of the EU-US and Swiss Data Protection Shield

United States to the American Arbitration Association, http://go.adr.org/privacyshield.html. Finally, in

In certain specific circumstances and as a last resort, individuals will be able to resort to arbitration

a specialist shield committee to be set up by the Department

and the European Commission, and whose decision will be binding.

Note that the data protection shield requirements for processing

complaints may not apply to you if you are not a resident of the European Union

or Switzerland. Similarly, you may not be able to use the

implementation of the data protection shield requirements.

If you would like to know more about our safety precautions

data transfer and the mechanisms in place, you can contact us

at privacyquest ion@radissonhotels.com.

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How long will we keep your personal data?

We keep your personal data for as long as necessary to

carry out the activities set out in this privacy policy, for as long as you are required to do so.

elsewhere communicated or as long as the law permits. For example, we may

retain your personal data if reasonably necessary to

comply with any legal obligation, meet any regulatory requirement, resolve any dispute or

any disputes, or to enforce this privacy policy and prevent fraud and abuse.

To determine the appropriate retention period for your personal data, we

take into account the amount, nature and sensitivity of the personal data, the

potential risks of harm from unauthorised use or disclosure of the data, the

purposes for which we use the personal data and whether we are able to

to achieve these purposes by other means, as well as the legal requirements in force.

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Does this privacy policy apply to third party websites?

If you click on the link to a third party website, you will be redirected to a website on

which we have no control and our privacy policy will no longer produce any

effect. Your browsing and interaction with any other website is subject to the following terms and conditions

Use and Privacy Policy and other applicable policies of that third party website. Read

carefully the privacy policies of other sites. We cannot be held responsible for

responsible for the information or content of these third party websites.

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What happens if this policy is changed?

We reserve the right to change and update this privacy policy from time to time.

confidentiality. We will let you know about these changes if they concern a significant change

whether they are relevant to the nature of the use of the data or whether they are

significant to you in terms of their effect on personal data protection rights

about you.

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How to contact us?

Questions, comments, remarks, requests or complaints regarding this policy may be addressed to the

Confidentiality is welcome and should be sent to privacyquestion@radissonhotels.com. If

you have questions about the practices of a particular hotel or the information it holds,

please contact the hotel directly.

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You can also write to us at the following address

Radisson Hospitality, Inc.

Mail Stop 8256 Attn: Privacy

701 Carlson Parkway

Minnetonka, MN 55305