BookingSuite Umbrella Privacy Statement

Effective Date: April 2018


This Privacy Statement applies to BookingSuite B.V., Herengracht 597, 1017 CE Amsterdam, the Netherlands, ('BookingSuite') and describes how BookingSuite collects and uses the information, which may include personal data, you provide on our website http://suite.booking.com ('Site') or via our products such as WebFamily, RateFamily, Connected Marketplace and other products that are offered by BookingSuite ('Products'). The Site and the BookingSuite Products are jointly referred to as the 'Services'. This Privacy Statement applies to owners, employees, representatives or other individuals acting on behalf of party to which BookingSuite provides the Services. We act in our partners’ interest and are transparent about the processing of any personal data.


Data Collection

To register your property, to grant you access and to use our Services, BookingSuite requests you to provide the following information, some of which may be personal data:

Contact details: We collect your contact information such as first name and last name, date of birth (as may be required), business email address and address, telephone and fax number.

Financial information: We collect data necessary for payment, including for invoicing purposes, such as your bank details, bank account number and VAT number.

Products and services: We register which services and/or products are provided by you through BookingSuite.

Other: When communicating with BookingSuite, BookingSuite collects and processes communications. During calls with our customer service centre, live listening may be done or calls may be recorded for quality control and training purposes, which includes the usage of the recordings for the handling of claims and fraud detection purposes. Recordings are kept for a limited amount of time and automatically deleted, unless BookingSuite has a legitimate interest to keep such recording for a longer period, including for fraud investigation and legal purposes.


Data we collect automatically

When using the Services, BookingSuite also collects information automatically, some of which may be personal data. This includes data such as language settings, IP address, location, device settings, device OS, log information, time of usage, URL requested, status report, user agent (information about the browser version), operating system, result (viewer or booker), browsing history, user Booking ID, and type of data viewed. BookingSuite may also collect data automatically through cookies. For information on how we use cookies, click here.


Information we receive from other sources

Information on insolvencies: In insolvency matters, BookingSuite can receive information from insolvency administrators, courts or other public authorities relating to you.
Data related to law enforcement and tax authority requests: Law enforcement or tax authorities can contact BookingSuite with additional information about you in case you are the subject of an investigation.
Fraud detection: In certain instances, and as permitted by applicable law, BookingSuite may collect data through third party sources for fraud detection and prevention purposes.

In addition, your personal data may be processed if you have been registered by someone in your organisation as an authorised user of the Products or as a contact person. Your personal data may have been provided to us through our referral mechanism because someone believes that you may be interested in the Products. If we have received your personal data via our referral mechanism and where permitted by law, we will process your personal data only to contact you once and to track the success of our referral program. It is our legitimate interest to process this data for our commercial business purposes.


Processing Purposes

We use the information you provide, some of which may be personal data, for the following purposes:

A. Registration and account administration: We use the information to register your property and to allow you and BookingSuite to administer and manage the Products offered to you.

B. Completing registration: If you haven’t finalised the online registration, we send a reminder to continue with the registration. We believe that this additional service is useful to you and allows you to continue with the registration without having to fill in all the registration details from scratch. Reminder emails that we may send you will contain an unsubscribe option that you can use if you don’t want us to send messages to you in the future.

C. Customer Service: We use the information to provide you customer support services, such as to respond to your requests, questions and concerns.

D. Marketing/Communications: We use the information to provide you with information that you request, to send our newsletter, marketing communications and updates about new Products and services or other news or offers which we believe will be of interest to you. Where we use your personal data for direct marketing purposes, such as newsletters and marketing communications on new Products and services or other offers which we believe will be of interest to you, we include an unsubscribe link that you can use if you don’t want us to send messages in the future. We may invite you to attend events we believe may be of interest to you. We may also use your personal data to invite you to participate in referral programs or in competitions.

E. Certain Products may offer you means to communicate with your guests or vendors, which always includes BookingSuite as a recipient. BookingSuite has access to these communications and uses automated systems to review, scan, and analyse communications for security purposes; fraud prevention; compliance with legal and regulatory requirements; investigations of potential misconduct; product development and improvement; research and customer or technical support. BookingSuite stores all communications sent or received.

F. Analytics, improvements and research: We use the information which may include personal data to conduct research and analysis. We may involve a third party to do this on our behalf. We may share or disclose the results of such research, including to third-parties and our affiliates, in anonymous, aggregated form. We also use the information, which may include personal data, to assess the needs of your business, to determine suitable products and to improve our Services and marketing efforts. We may invite you to take part in surveys, such as market research, and to analyse how to improve your experience, and the functionality and quality of our Products. Please consult the information provided when invited to participate in a survey or market research to understand how personal data may be treated differently from this Privacy Statement.

G. Security, fraud detection and prevention: We use the information, which may include personal data, in order to prevent fraud and other illegal or infringing activities when using our Site as well as our Products. We also use this information to investigate and detect fraud. BookingSuite can use personal data for risk assessment and security purposes, including the authentication of users. For these purposes, personal data may be shared with third parties, such as law enforcement authorities as permitted by applicable law and external advisors.

H. Legal and compliance: In certain cases, BookingSuite needs to use the information provided, which may include personal data, to handle and resolve legal disputes or complaints, for regulatory investigations and compliance, to enforce agreement(s) or to comply with lawful requests from law enforcement insofar as it is required by law.

If we use automated means to process personal data which produces legal effects or significantly affects you, we will implement suitable measures to safeguard you rights and freedoms, including the right to obtain human intervention.


Legal Bases

In view of purpose A and C, BookingSuite relies on the legal basis that the processing of your personal data is necessary for the performance of your agreement with BookingSuite. If you do not provide the requested information, BookingSuite cannot register your property or allow you to administer and manage the Products, nor can we provide customer service to you. In view of purposes B and D to H, BookingSuite relies on its legitimate commercial business interest to provide its Services to you, to prevent fraud and to improve its Services. When using personal data to serve our commercial business interest, BookingSuite will always balance your rights and interests in the protection of your information against BookingSuite’s rights and interests. For purpose H, BookingSuite relies also where applicable on compliance with legal obligations (such as lawful law enforcement requests). Where needed under applicable law, BookingSuite will obtain your consent prior to processing your personal data for direct marketing purposes.

If you wish to object to the processing set out under B and D to F and no opt-out mechanism is available to you directly (for instance in your account settings), to the extent applicable, please contact dataprotectionoffice@booking.com.


Data Sharing

Sharing With Affiliates: In order to support the use of the Services, your information which may include personal data may be shared with subsidiaries of the Booking.com corporate family which may act as service providers for BookingSuite, including in relation to customer support services. As permitted by law, your information may also be shared for analytical purposes and fraud detection and prevention purposes. Where required by law, we shall first ask your consent before our affiliates may use your personal data for other purposes such as marketing communications. To find out everything you need to know about the Booking.com corporate family, visit About Booking.com.

Booking Holdings Inc.: BookingSuite, a member of the Booking Holdings Inc. group of companies, may need to share some parts of your information which may include personal data with other members of Booking Holdings Inc., for compliance or fraud detection and prevention purposes as permitted by applicable law and strictly necessary to protect Booking Holdings Inc. and its members, including BookingSuite, its customers and business partners from fraudulent activities and investigating and handling data security breaches.

Sharing With Third-Parties: We share your information, which may include personal data, with third parties as permitted by law and as described below. We do not sell or rent your personal data.

  • Service Providers (including suppliers): We share your information with third party service providers to provide our Services, store data and/or maintain the Site or conduct business on our behalf. These service providers shall process personal data only as instructed by and to provide the services to BookingSuite.

  • Business Partners: We share your information, upon your instruction, with business partners to enable them to provide services to you.

  • Payment Providers and other Financial Institutions: To process payments between you and BookingSuite and/or third parties through BookingSuite your information, as relevant, is shared with payment providers and other financial institutions.

  • Compelled Disclosure: When legally required, strictly necessary for the performance of the Services, or to protect our rights, or the rights of Booking Holdings Inc. group of companies or users, we disclose your information to governmental authorities including law enforcement (subject to a lawful request), any of the affiliates part of Booking Holdings Inc. including Booking.com B.V., or in legal proceedings.

  • Sale or Merger: We may share your information in the event of a merger, acquisition, or sale of all or a portion of our assets. Of course, we shall notify you via email and/or a prominent notice on our Site and inform you of your rights.

Sharing and Disclosure of Aggregate Data: We may share information in aggregate form and/or in a form which does not enable the recipient of such information to identify you, with third parties, for example for industry analysis and demographic profiling.


International Data Transfers

The transmission of personal data as described in this Privacy Statement may include overseas transfers of personal data to countries whose data protection laws are not as comprehensive as those of the countries within the European Union. Where required by European law, BookingSuite shall only transfer personal data to recipients offering an adequate level of data protection. In these situations, as may be required, we make contractual arrangements to ensure that your personal data is still protected in line with European standards. You can ask us to see a copy of these contractual agreements using the contact details below.


Security

BookingSuite observes reasonable procedures to prevent unauthorised access to, and the misuse of, information including personal data. We use appropriate business systems and procedures to protect and safeguard information including personal data. We also use security procedures and technical and physical restrictions for accessing and using the personal data on our servers. Only authorised personnel are permitted to access personal data in the course of their work.


Data Retention

We will retain your information, which may include personal data, for as long as we deem it necessary to enable you to use our Services, to provide our Services to you, to comply with applicable laws, resolve disputes with any parties and otherwise as necessary to allow us to conduct our business, including to detect and prevent fraud or other illegal activities. All personal data we retain will be subject to this Privacy Statement. If you have a question about a specific retention period for certain types of personal data we process about you, please contact us via the contact details included below.


Your Choices and Rights

We want you to be in control of how your personal data is used by us. You can do this in the following ways:

  • You can ask us for a copy of the personal data we hold about you;

  • you can inform us of any changes to your personal data, or you can ask us to correct any of the personal data we hold about you, though you may be able to make changes directly on our Site;

  • in certain situations, you can ask us to erase or block, or restrict the processing of, the personal data we hold about you, or object to particular ways in which we are using your personal data; and

  • in certain situations, you can also ask us to send the personal data you have given us to a third party.

Where we are using your personal data on the basis of your consent, you are entitled to withdraw that consent at any time subject to applicable law. Moreover, where we process your personal data based on legitimate interest or the public interest, you have the right to object at any time to that use of your personal data subject to applicable law.

We rely on you to ensure that your personal data is complete, accurate and current. Please do inform us promptly of any changes to or inaccuracies of to your personal data by contacting suitehelp@booking.com.


Questions or Complaints

If you have questions or concerns about our processing of your personal data you are welcome to contact us via suitehelp@booking.com or you may contact our data protection officer via dataprotectionoffice@booking.com. If you want to exercise any of the rights you have under this Privacy Statement, please contact our data protection officer via dataprotectionoffice@booking.com. All questions and complaints reported to BookingSuite will be investigated. BookingSuite will attempt to resolve complaints and questions in line with internal policies. You may also contact your local data protection authority with questions and complaints.


Changes to the Privacy Statement

Just as our business changes constantly, this Privacy Statement may also change from time to time. If you want to see changes made to this Privacy Statement from time to time, we invite you to access this Privacy Statement to see the changes. If we make material changes or changes that will have an impact on you (e.g. when we start processing your personal data for other purposes than set out above), we will contact you prior to commencing that processing.