We promise to collect, use and store your personal data in a safe and secure way.
We promise to only use your personal data for the specific purposes stated.
We promise to keep you informed about how we use your information and who we give it to.
This privacy notice tells you what to expect when Attitude Hospitality Management Limited (“Attitude”) collects personal information about you and how we use that data, who that data may be sent to and how you can amend data you have submitted to us.
Attitude is committed to protecting your personal information when you use our services. Whenever you provide such information, we will only use your information in line with all applicable data protection laws, including the EU General Data Protection Regulation (GDPR) and Data Protection Act 2017 (DPA). Your information will be kept in a secure environment and access to it will be restricted according to the 'need to know' principle.
"Personal data" means any information collected and logged in a format that allows you to be identified personally, either directly (e.g. name) or indirectly (e.g. telephone number) as a natural person.
This includes collecting unique online identifiers such as IP addresses, which are numbers that uniquely identify a specific computer or other network device on the internet. For more information, see our section on ‘cookies’ below.
3. WHO ARE WE
Attitude Hospitality Management Ltd (AHML) is a private company incorporated on June 2, 2008 and domiciled in Mauritius. Its registered office is situated at The Junction Business Hub, Block C, Calebasses Branch Road, Calebasses.
AHML is a subsidiary of Attitude Hospitality Ltd (AHL) and provide Management services to all the hotels within the AHL group.
AHML as the Management entity, shall be responsible for handling your personal information, inputted on this website and for reservation and marketing purpose. Given that the contractual relationship will primarily be with the hotels, the responsibility for handling and keeping your personal information will rest on both the hotel and AHML.
This policy applies:
1. To all data processing at Attitude i.e. those operating under Attitude brand name and/or any other brand owned by Attitude.
2. To all reservation websites, including brand sites namely www.hotels-attitude.com
4. PRINCIPLES FOR PROTECTING YOUR PERSONAL DATA
The seven principles below are applicable within our organisation throughout the world.
1. Transparency: When collecting and processing your personal data, we will communicate all information to you and inform you of the purpose and recipients of the data.
2. Legitimacy: We will collect and process your personal data only for the purposes described in this Policy.
3. Relevance and accuracy: We will only collect personal data that is necessary for data processing. We will take all reasonable steps to ensure that the personal data we hold is accurate and up to date.
4. Storage:We will hold your personal data for the period necessary for processing the same in compliance with the provisions of the law.
5. Access, rectification, opposition:You may access, modify, correct or delete your personal data. You may also oppose the use of your personal data, particularly to avoid receiving sales and marketing information.
6. Confidentiality and security: We will ensure reasonable technical and organisational measures are in place to protect your personal data against alteration or accidental or unlawful loss, or unauthorized use, disclosure or access.
7. Sharing and international transfer:We may share your personal data within our organisation or with third parties (such as commercial partners and/or service providers) for the purposes set out in this Policy. We will take appropriate measures to guarantee security when sharing or transferring such data.
5. WHAT PERSONAL DATA IS COLLECTED?
At various times, we will be obliged to ask you, as our guest, for information about you and/or members of your family to provide you the best of our personalised service.
Contact details (for example, last name, first name, telephone number, email)
Personal information (for example, date of birth, nationality)
Information relating to your children (for example, first name, date of birth, age)
Your credit card number (for transaction and reservation purposes)
Your arrival and departure dates
Your preferences and interests (for example, smoking or non-smoking room, preferred floor, type of bedding, type of newspapers/magazines, sports, cultural interests)
Your questions/comments, during or following a stay in one of our establishments and any communication you sent to us.
Your itemized spending during your stay being room charged.
We do not deliberately collect sensitive information, such as information concerning race, ethnicity, political opinions, religious and philosophical beliefs, union membership, or details of health or sexual orientation or character certificate.
However, in limited cases, we might need to collect sensitive data to provide you with a better service and meet your needs, such as your food preferences, allergies, health conditions, current medication and/ or any physical conditions that affect your mobility. In these cases, the sensitive information will be those volunteered by you and which you have unequivocally agreed to communicate to us.
Where a reservation is made on behalf of a child who is under the age of 16 years, we shall not process the latter’s Personal Information, unless express consent is given by the parent or guardian of that child. Where the reservation is made by the child’s parent or guardian, we will request for relevant documentation to demonstrate a parent-child relationship. Where the reservation is not made by the child’s parent or guardian, we will request for written documentation to be issued from the child’s parent or guardian to signify their consent to us processing the child’s Personal Information.
6. WHEN IS PERSONAL DATA COLLECTED?
Personal data will be collected on a variety of occasions, including:
1. Hotel activities:
Booking a room
Checking-in and paying
Eating/drinking at the hotel bar or restaurant during a stay
Other activities such as SPA, Kids Club, Water Sports etc.
Requests, complaints and/or disputes.
2. Participation in marketing programs or events:
Signing up for loyalty programs
Participation in guest surveys (for example, the Guest Satisfaction Survey)
Online games or competitions
Subscription to newsletters, in order to receive offers and promotions via email.
3. Transmission of information from third parties:
Tour operators, travel agencies, reservation systems, and others
4. Internet activities:
Connection to our organisation websites (IP address, cookies)
Online forms (online reservation, questionnaires, our organisation pages on social networks, network login devices such as Facebook login etc.).
5. Closed Circuit Television Systems and Other Security Systems:
Closed circuit Tv (CCTV) images. There is a CCTV Policy in place which standardize the use and monitoring of CCTV at Attitude.
7. HOW WILL ATTITUDE USE THE INFORMATION IT COLLECTS ABOUT ME?
We collect your personal data for a number of purposes including the following:
1. Meeting our obligations to our guests
2. Managing the reservation of rooms and accommodation requests
3. Creation and storage of legal documents in compliance with accounting standards.
4. Managing your stay at the hotel:
Monitoring your use of services (telephone, bar, etc.)
Managing access to rooms
5. Improving our hotel service, especially:
Processing your personal data in our guest marketing program in order to carry out marketing operations, promote brands and gain a better understanding of your requirements and wishes
Adapting our products and services to better meet your requirements
Customizing commercial offers and the promotional messages we send to you through various channels
Informing you of special offers and any new services created by our organisation or one of our subsidiaries.
Carrying out surveys and analyses of questionnaires and guest comments
6. Managing our relationship with guests before, during and after your stay:
Providing details for the guest database
Segmentation operations based on reservation history and guest travel preferences with a view to sending targeted communications
Predicting and anticipating future behaviors
Developing statistics and commercial scores, and carrying out reporting
Providing context data for the offer push tool when a guest visits a Group website or makes a reservation
Knowing and managing the preferences of new or repeat guests
Sending you newsletters, promotions and tourist, hotel or service offers, or offers from partners, or contacting you by telephone
Managing requests to unsubscribe from newsletters, promotions, tourist offers and satisfaction surveys
Taking into account the right to object
7. Use a trusted third party to cross-check, analyze and apply certain devices to your collected data at the time of booking or at the time of your stay, in order to determine your interests and your guest profile, and to allow us to send you personalised offers.
8. Securing and enhancing your use of Attitude websites, especially:
Implementing security and fraud prevention.
9. Conforming to local legislation and applicable international legislation (for example, storing of accounting documents).
8. DISCLOSURE OF PERSONAL INFORMATION
To provide you with the best-individualised service, we have to share your personal data with internal and external recipient subject to the following conditions:
a. Within Attitude, in order to offer you the best service, we can share your personal data and give access to authorised personnel from the Group, including:
Reservation staff using Attitude’s reservation tools
Commercial partners and marketing services
Medical services if applicable
Insurance services if applicable
Legal services if applicable
Generally, any appropriate person within Attitude entities for certain specific categories of personal data.
b. With service providers and partners: your personal data will be sent to a third party for the purposes of supplying you with services and improving your stay, for example:
1. External service providers:
Diving Centres and Boathouse service providers
c. Local authorities: We will also be obliged to send your information to local authorities if this is required by law or as part of an inquiry and in accordance with local regulations.
Attitude does not routinely disclose personal information to other organisations unless:
Required by law.
Use or disclosure is permitted by this policy.
We believe it necessary to provide you with a service or product which you have requested or are contracted to.
To protect the rights, property or personal safety of any member of the public or a guest of Attitude or the interests of Attitude.
You give your consent.
9. INTERNATIONAL TRANSFERS
For the purposes set out in Clause 7 of this policy, we may transfer your personal data to internal or external recipients who may be in countries offering different levels of personal data protection in accordance with section 36 of the DPA 2017.
Consequently, in addition to the implementation of this Policy, Attitude employs appropriate measures to ensure secure transfer of your personal data to an Attitude entity or to an external recipient located in a country offering a different level of privacy from that proposed in the country where the personal data is collected.
As part of the hotel operation, your data will be sent to other service providers outside Mauritius and European Union.
In addition, personal information that you submit for publication on the website will be published on the Internet and may be available, via the Internet, around the world. Attitude cannot prevent the use of such information by others. By submitting your personal data, you expressly agree to these transfers, storing, processing and publishing.
However, any such transfer of information does not change any of our commitments to safeguard your privacy and the information remains subject to existing confidentiality obligations.
10. DATA SECURITY
Attitude takes appropriate technical and organisational measures, in accordance with applicable legal provisions, to protect your personal data against illicit or accidental destruction, accidental alteration or loss, and unauthorized access or disclosure. To this end, we have taken technical measures (such as firewalls) and organisational measures (such as a user ID/password system, means of physical protection etc.).
In the course of processing or transmitting your credit card CVV number Attitude will observe and fully comply with best security practices as mentioned above but not limited to encryption and secure protocol for a secure communication.
Attitude will endeavour to take all reasonable steps to keep secure any information which we hold about you, whether electronically or in hard copy, and to keep this information accurate and up to date. We also require our employees and data processors to respect the confidentiality of any personal information held by Attitude.
11. COLLECTION OF OTHER INFORMATION
“Other Information” is any information that does not reveal your specific identity or does not directly relate to an individual, such as:
Browser and device information
App usage data
Information collected through cookies, pixel tags and other technologies
Demographic information and other information provided by you
If we are required to treat Other Information as Personal Information under applicable law, then we may use it for the required purposes and disclose Personal Information as detailed in this Policy. We and our third party service providers may collect Other Information in a variety of ways, including:
Through your browser or device: Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version and the name and version of the Online Services (such as the Apps) you are using. We use this information to ensure that the Online Services function properly.
Through your use of the Apps: When you download and use an App, we and our service providers may track and collect App usage data, such as the date and time the App on your device accesses our servers and what information and files have been downloaded to the App based on your device number.
IP Address: Your IP address is a number that is automatically assigned to the computer that you are using by your Internet Service Provider (ISP). An IP address may be identified and logged automatically in our server log files whenever a user accesses the Online Services, along with the time of the visit and the page(s) that were visited. Collecting IP addresses is standard practice and is done automatically by many websites, applications and other services. We use IP addresses for purposes such as calculating usage levels, diagnosing server problems and administering the Online Services. We may also derive your approximate location from your IP address.
By aggregating information: Aggregated Personal Information does not personally identify you or any other user of the Services (for example, we may aggregate Personal Information to calculate the percentage of our users who have a particular telephone area code).
12. HOW LONG WILL ATTITUDE KEEP MY INFORMATION
We retain your personal data only for the period necessary for the purposes and in accordance with our Data Retention Policy and with the provisions of applicable laws. (For example financial information is kept for 7 years and client information is retained for 10 years)
13. WHAT RIGHT DO I HAVE OVER MY PERSONAL INFORMATION
Under the General Data Protection Regulation and DPA 2017, you have the right to:
To be informed:this Data Protection Policy provides the information you are entitled to receive.
Access:Please send a written request if you would like confirmation that your data is being processed by us and to receive a copy of your data. We will do utmost to provide the data in a portable format.
Rectification, Erasure or Restriction of Processing:You have the right to request us to correct inaccuracies, complete your personal data. You can also request to erase your data where the data are no longer necessary in relation to the purpose for which the personal data was collected, you have withdrawn your consent, you have object to processing or the data have been unlawfully processed.
To Object:You have the right to object to the processing of your personal data unless we demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defense of a legal claim.
We shall stop the processing of any data, which has been obtained through your express consent upon you withdrawing such consent in writing to the Data Protection Officer
Not to be subject to automated decision-making including profiling:You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or which significantly affects you.The above shall not apply where the decision is:(a) Necessary for entering into, or performing, a contract between you and Attitude;(b) Authorised by a law to which Attitude is subject and which lays down suitable measures to safeguard your rights, freedoms and legitimate interests; or
(c) Based on your explicit consent.
14. HOW TO CONTACT US
To exercise your rights, please contact the Attitude Data Protection Officer using the following contact details:
Data Protection Officer Attitude Hospitality Management Ltd.
The Junction Business Hub, Block C, Calebasses Branch Road Calebasses Republic of Mauritius Email: email@example.com
For the purposes of confidentiality and personal data protection, we will need to identify you in order to respond to your request. You will be asked to include a copy of an official piece of identification, such as a driver's license or passport, along with your request. In some cases we may also request an administrative fee to cover the cost of access.
We will try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
You have the right to complain to the Data Protection Office under the DPA 2017 and the European Data Protection Supervisor or any supervisory authority under the GDPR.
We may modify this policy from time to time. Consequently, we recommend that you consult it regularly, particularly when making a reservation at one of our hotels.
The amended policy will apply between us whether or not we have given you specific notice of any change.