This Privacy Notice has been adopted by all of the distinct legal entities that manage and operate Zunya. Those entities include HUMAAN EXPERIENCE ZUNYA SRL and its direct and indirect subsidiaries and affiliates. References to “we”, “us”, “our” and “Zunya” throughout this Privacy Notice, depending on the context, refer collectively to those separate and distinct legal entities.
What is personal information?
Personal information is any information about you as an identifiable individual. The personal information that we process includes:
· Identity information – such as name, age, gender, passport information, CCTV images, and publicly available photograph;
· Contact information – such as your home address, zip/postal code, email address and phone number;
· Financial information – such as your credit card details, itemized spending and transaction history;
· Reservation information – such as the type and location of the rooms you reserve and the dates of your reservations;
· Health information – where disclosed and relevant to the provision of services;
· Preference information – such as special requests, service issues and other preferences for your stay;
· Public information – such as when we review public platforms to understand what you are saying about us or the hospitality industry;
· Technical information – such as information about the device you use to interact with us (including the unique device identifier, hardware model, operating system and version, and mobile network information); and
· Correspondence information – when you contact us, such as to send an enquiry or make a request, any correspondence or application may be kept and added to your personal information.
How do we use your personal information?
For each of the categories of personal information described above, we use your personal information for the following purposes:
· to enable you to use our website;
· to help us identify you;
· to process transactions through our website (including taking payment for purchases you may make through our website) and to assist in any inquiries about your transaction;
· for billing purposes in relation to your stay with us;
· to contact you in relation to matters that arise from your stay with us;
· to send you newsletters regarding our properties and to advise you of promotions or to inform you of offers or other information that may be of interest to you (if, where required, you separately provide your consent for us to do so);
· to conduct surveys or focus groups to receive your views of Zunya and service delivery (if, where required, you separately provide your consent to this);
· for you to participate in one of our on-line promotions;
· to analyze customer trends and insights; and
· to operate our business, including for internal purposes such as auditing, data analysis, statistical and research purposes and troubleshooting to help us improve our services.
On what basis do we use your personal information?
We use your personal information on the following basis:
· to comply with legal and regulatory obligations, including financial reporting requirements imposed by government regulators;
· to enter into agreements with you, and to perform our agreement to provide services to you when you stay with us;
· for legitimate business purposes – using your personal information helps us to operate and improve our business and minimize any disruption to the services that we may offer to you. It also allows us to make our communications with you more relevant and personalized to you, and to make your experience of our services more efficient and effective;
· because you have given your consent – at times we may ask for your consent to allow us to use your personal information for one or more purposes; or
· for the establishment, exercise or defence of legal claims or proceedings.
How and from what sources is personal information collected?
For each of the categories of personal information and purposes described above, we collect your personal information while monitoring our technology tools and services, including comment cards and email communications sent to and from Zunya.
Otherwise, we gather information when you provide it to us, or interact with us directly, for example:
· when you make a purchase through our website;
· during your stay at Zunya, including information provided during check-in.
We also receive information about you from other sources, such as our business partners and publicly available sources. We combine information that we have about you from various sources, including the information that you have provided to us.
How do we protect personal information?
We use a variety of security measures and technologies to help protect your personal information from unauthorised access, use, disclosure, alteration or destruction, consistent with applicable data protection and privacy laws.
We endeavor to protect the privacy of your account and other personal information that we hold in our records, but unfortunately, we cannot guarantee complete security. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information. Also, while we endeavor to put adequate contractual protections in place, we cannot guarantee the security of any personal information in databases hosted by third parties.
It is important to note that any e-mail communication is not secure. This is a risk inherent in the use of e-mail. Please be aware of this when requesting information or sending forms to us by e-mail (for example, from the “Contact” section of our website). We recommend that you do not include any confidential information (i.e. credit card information) when using e-mail. For your protection, our e-mail responses to you will not include any confidential information.
Finally, to be prudent, please be sure to always close your browsers when you are done using a form or the reservation site. Although the session will terminate after a short period of inactivity, it is best to close your browsers immediately upon completion, especially when using a public computer.
Will personal information be provided to third parties?
We do not and will not sell your personal information.
For each of the categories of personal information, source of information and purposes described above, we may share certain of your personal information with:
· agents, contractors or third party service providers of Zunya who provide services to Zunya to better serve your needs as a Guest;
· a prospective buyer or investor in the event that we sell any business or assets;
· our professional advisors; and
· local or foreign regulators, governments, courts, law enforcement and national security authorities.
You may advise the hotel if you do not want personal preferences shared.
If you have chosen to join a subscription list, please note that they are only used for internal purposes and we do not sell or rent our subscription lists to anyone.
Transfers of your personal information outside your home country
Your personal information may be processed by Zunya and its trusted third party suppliers anywhere in the world, including in countries where data privacy laws may not be equivalent to, or as protective as, the laws in your home country.
Accessing, correcting or deleting your personal information
We understand that you may like to know what personal information we hold about you, or to correct or delete certain information we hold about you. We are happy to assist you with your request.
To protect your personal information, we require that you prove your identity to us at the time your request is made. This may involve providing us with information which we hold on file about you (e.g. a home or business address), or we may require you to produce some form of photo or government issued identification.
Zunya reserves the right to decline a request to access, correct or delete your personal information under certain circumstances as permitted by law. In particular, there may be a variety of legitimate business reasons why we may be unable to delete your personal information and where we are permitted to decline your request to delete your information.
If we decline your request, you will be provided with the reasons.
You may also be entitled to:
· request the restriction of the processing of your personal information, or object to that processing;
· opt out from processing of your personal information for direct marketing purposes;
· withdraw your consent to the processing of your personal information (where Zunya is processing your personal information based on your consent); and
You have the right to be free from discrimination (e.g. you will not be penalised) in relation to the exercise of your privacy rights under this privacy notice.
Where you are given the option to share personal information with Zunya, you can always choose not to do so.
If you do not wish to receive marketing information from Zunya, you may indicate your wishes on your registration card when you stay with us or send an e-mail to: [email protected]. You will always have the ability to accept or decline any form of communication from Zunya. You may unsubscribe from electronic marketing communications at any time by selecting the “unsubscribe” link included in such communications.
If you object to the processing of your personal information, or if you have provided your consent to processing and you later choose to withdraw it, we will respect that choice in accordance with our legal obligations.
This could mean that we are unable to perform the actions necessary to achieve the purposes of processing described above (see ‘How do we use your personal information?’) or that you are unable to make use of the services offered by us.
After you have chosen to withdraw your consent Zunya may be able to continue to process your personal information to the extent required or otherwise permitted by law.
If at any time you wish to exercise any of these rights, you can do so via email [email protected].
How long is my personal information retained?
Your personal information will be stored for the period of time required by law in the jurisdiction of any hotel holding the information. This may involve retaining information following your stay. We will delete your personal information once it is no longer required for any of the purposes described above.
We will also keep your personal information where we need to do so in connection with a legal action or an investigation involving Zunya.
If you have any questions or concerns regarding this Privacy Notice, please contact us by writing to the following address:
HUMAAN EXPERIENCE ZUNYA SRL
Edificio EBC Centro Corporativo
Escazu San Rafael
San jose, 10203, Costa Rica