Privacy

Because you as a guest are important to us, our main priority is to ensure that you enjoy your stay in all our hotels. Your satisfaction and trust in Carlton Collection is therefore of great importance to us. For this reason, we have drawn up a privacy and security policy for customer data that describes how we use your personal data. The main rules that apply are based on seven principles.

'Personal data': this means all information that is collected and recorded in a way in which you personally can be identified as a natural person. This may be directly, for example by your name, or indirectly by your telephone number. Before you give us this information, we recommend that you first read this policy. This privacy and security policy for customer data is part of the terms and conditions that apply to our (hotel) services. At the end of this document you will find a list of all hotels that belong to the Carlton Collection. 

The seven principles below apply within all hotels of the Carlton Collection.

1. Openness: in the collection and processing of your personal data we communicate all information to you and inform you of the purpose and the recipients of the data.

2. Relevance: we collect and process your personal data only for the purposes described in this policy.

3. Necessity: we only collect personal data that are necessary for the processing of these data. We take all reasonable measures to ensure that the personal data in our possession are correct.

4. Storage: we may not keep your personal data for longer than is necessary for the processing of these data in accordance with the provisions of the law.

5. Access, correction and objection: you may view your personal data and have them changed, corrected or deleted. You may also object to the use of your personal data, in particular to prevent you receiving advertising and marketing information. The details of the department you should contact are given below (see “13. How do you access or view...?”).

6. Confidentiality and security: we make sure that reasonable technical and organisational measures are taken in order to protect your personal data against misuse, unlawful loss or unauthorised use, disclosure or access.

7. Sharing and international transfer: we may only share your personal data within the Carlton Collection group or with third parties (such as commercial partners and/or service providers) with a view to the objectives of this policy. We take appropriate measures to guarantee security during the sharing and transfer of these data.

For all questions relating to the seven principles of the privacy and security policy for customer data of the Carlton Collection, please contact the department that deals with the protection of personal data. Read more here: “13. How do you access or view...?”.

When you make a booking to stay in one of our hotels, we need certain data from you. We also process data in other cases, such as for information requests and visits to our websites. In doing so we also use third parties who receive certain personal data and process it on behalf of the Carlton Collection. This is done, for example, when sending your confirmation, sending brochures and mailings, sending personal offers prior to your stay or when processing our guest survey that you receive from us after your departure. When you make a reservation, your data is, of course, shared with the hotel where you will be staying.

At various times we are obliged to ask you, as a guest of the Carlton Collection, for information about yourself and/or your family members. Below you can read more about which data we process and what we do with it.

a. Contact data (first name, surname, address and city, telephone number and e-mail address)

We use your personal data to be able to speak to you personally in the hotel, but also in our further communication with you. These data are also necessary to record your booking and to include the data in the night register. We normally send you your booking details by e-mail. But in exceptional cases we may also send information to your home address.

It may be the case that we need to contact you about your booking. We may ring you if there are any questions and may send you a message, for example, if your hotel room is available earlier. Sometimes we call you before your arrival or at the end of your stay to ask you whether everything is clear or whether you were satisfied with everything.

You receive an e-mail about your reservation or with your invoice and prior to your stay we also send you useful information about our additional services and, for example, activities in the vicinity, everything to make your stay with us a more enjoyable experience. You also receive newsletters by e-mail if you have registered for this. If you prefer not to receive newsletters and offers, it is easy to unsubscribe by clicking on the link in the newsletter.

b. Personal data (date of birth, nationality, gender, children/family composition)

Anyone who books a hotel room at the Carlton Collection must be at least 18 years old. Tourist tax may depend on the age of the persons staying in the accommodation and therefore we require dates of birth. If you or someone travelling with you has a birthday during the stay, we like to remember this and do something that little bit extra to mark the occasion. It also means we can prepare the room optimally for the age of the guests and the composition of your family; for example provide a cot or child’s bed.

c. Payment data

To pay for your booking we use a secure payment environment. If you pay with iDeal or by transfer, your data is stored in our administration to link the payment to your booking. We only make further use of your bank account number if you receive money back from us. If you pay by credit card, we send your credit card details from our secure environment directly to our credit card partner. Our partner carries out our credit card payments and tells us whether your payment has been successful. The data concerned are stored securely so that we can charge any extra payments to your credit card. Of course, you always receive a statement of these payments from us.

d. Data relating to your stay (arrival and departure dates, preferences and interests)

The arrival and departure date of your stay in order to execute the agreement with you and also preferences and interests so that we can fulfil your wishes as optimally as possible, for example: dietary requirements, desired floor, type of bed linen and certain newspapers/magazines.

e. IP addresses

We, or third parties on our behalf, may search for your IP address on the internet. We remember your preferences and can therefore give appropriate advice. This can also be used for fraud protection.

f. Persons under the age of 18

The information collected on persons under the age of 18 remains limited to their name, nationality and date of birth. These data may only be provided to us by an adult. We would appreciate it if you ensure that your children do not send us any personal data without your permission (specifically via the internet). If these data are sent, you can contact our department that deals with the protection of personal data (see “13. How do you access or view...?”) to delete this information.

Personal data may be collected at different times and include:

a. Hotel activities

• Booking a room

• Checking in/out, parking and paying

• During your stay at the hotel (for example, camera surveillance)

• Eating/drinking in the hotel bar or restaurant during a stay (incl. table reservation)

• Requests, complaints and/or disputes

b. Participation in marketing programmes or events

• Registration for loyalty programmes

• Participation in surveys among guests (for example, the guest satisfaction survey)

• Online games or competitions

• Subscription to newsletters to receive offers and promotions by e-mail

c. Transfer of information to third parties

• Tour operators, travel agencies, GDS reservation systems, etc.

• Organisers of events in our rooms (presentation lists, with overnight stay if required)

d. Internet activities

• Connection to the Carlton Collection websites (IP address, cookies) or guests Wi-Fi networks

• Online forms (online reservations, questionnaires, Carlton Collection pages on social media, network registrations such as registration on Facebook, etc.).

We collect your personal data for the following purposes:

a. To fulfil our obligations towards our customers

b. To manage room reservations and accommodation requests:

Creation and storage of legal documents in accordance with accounting norms.

c. To manage your stay at the hotel:

• Check of your use of the services (telephone, bar, pay-tv, etc.)

• Management of room access (key system and/or mobile access)

• Internal management of lists of guests who have not behaved appropriately during their stay at the hotel (aggressive and antisocial behaviour, violation of the contract with the hotel, violation of the safety regulations, theft, damage and vandalism, or payment problems).

d. To improve our hotel service, i.e.:

• Processing of your personal data in our customer marketing programme for marketing activities, for promotion and to obtain a better understanding of your requirements and wishes

• Modification of our products and services so we can respond to your requirements more effectively

• Analysis of contact moments to provide you with better information

• Customisation of commercial offers and the advertising messages we send

• To inform you about special offers and new services of the Carlton Collection

e. To manage our relationship with guests before, during and after their stay:

• Management of (external) loyalty programmes

• Provision of data for the guest database

• Segmentation based on the guest’s reservation history and travel preferences with a view to sending targeted communication

• Prediction and anticipation of future behaviour

• Analysis of statistics and commercial scores, and making reports

• To consult the preferences of new or returning guests and management of these preferences

• To send you newsletters, promotions and tourist offers or offers of hotels and services or to contact you directly by telephone. If you prefer not to continue to receive newsletters and offers, you can simply unsubscribe by clicking on the link in the newsletter.

• Management of requests to unsubscribe from newsletters, promotions, tourist offers and satisfaction surveys

f. To provide services to the members of our sports centre (HUP Sports):

• Management and administration of (fitness) subscriptions

• Drawing up of personal training and diet plans

g. To engage a reliable third party to enable us to use your collected data to send you personalised offers.

h. To improve the Carlton Collection services by carrying out surveys, analyses of questionnaires and complaint management and guest feedback.

i. To protect and improve the use of the Carlton Collection websites, specifically:

• Improvement of navigation

• Implementation of security measures and fraud prevention

j. To comply with local legislation (for example the storage of accounting documents)

k. To guarantee your safety and that of our other guests, personnel and our buildings and property

l. We sometimes use guest data to investigate, prevent and combat fraud. In some circumstances we are legally obliged to pass personal data to relevant organisations.

Our aim is to provide the same service in each of our hotels. For this reason and to guarantee that you have access and correction rights (see “13. How do you access or view...?”) we share your personal data with internal and external recipients under the following conditions:

a. Within the Carlton Collection we may share your personal data and give access to them to authorised personnel of the group, including:

• Hotel personnel

• Reservation employees who use our reservation systems

• IT departments

• Commercial partners and marketing agencies

• Legal services, if applicable

b. With service providers and partners: your personal data may be sent to a third party with a view to providing services and improving your stay, such as for example external service providers, IT subcontractors, banks and credit card companies, this always exclusively for the purposes described here.

c. Local authorities: We may be obliged to send your data to local authorities if this is required by law or as part of an investigation and in accordance with the local regulations.

For the application of article 7 of this policy we may transfer your personal data to recipients who are possibly located in countries with a different level of protection of personal data.

For this reason the Carlton Collection has also taken appropriate measures to ensure the safe internal transfer of your personal data to an external recipient who is located in a country with a different level of privacy to that in the country in which the personal data are collected.

In accordance with the applicable statutory provisions, Carlton Collection takes all appropriate technical and organisational measures to protect your personal data against misuse, unlawful loss or unauthorised use, disclosure or access. For this purpose, we have taken technical measures (such as firewalls, monitoring of file access) and organisational measures (such as training of personnel in privacy awareness, a robust username/password system, physical security, etc.). If, despite these measures, a data leak occurs, we have in place a procedure to report this in the correct manner. 

We also expect that external parties who process personal data for us have taken the required contractual and organisational measures to do this as safely as possible and that they also guarantee that they will only process your data for the purposes described here. We record this formally as far as possible and supervise this where possible. In addition, we keep an up-to-date overview of these external parties and which specific data they process on our behalf and for what purpose.

If you use credit card data to make the reservation or give us other personal data online when making the reservation, SSL coding technology (Secure Socket Layer) is used to guarantee safe communication.

Legislation stipulates a number of principles for the processing of personal data. This concerns here mainly the processing of data based on:

• an agreement;

• a justified interest of the Carlton Collection;

• a given consent;

• a legal obligation.

We mainly use your data in connection with your booking and therefore on the basis of an agreement with you. Your booking is recorded and we do everything further to make your stay as enjoyable as possible. Additional contact moments, such as reviews, marketing activities and the recording and analysis of your activities take place in connection with a justified interest of the Carlton Collection. You can also register for a newsletter yourself. In this case you give us permission to use your data for this purpose. There are also legal obligations, such as the inclusion of your data in the night register, for example.

Carlton Collection and other parties use cookies to analyse websites to make them more user-friendly, to offer social media and to display suitable offers to you on and outside the website.

1. Why a cookie policy?

Carlton Collection has drawn up this policy so that you know what we do with cookies and to give you more information on:

• The origin and purpose of the data that are processed when you visit our websites

• Your rights relating to cookies and other trackers we use

2. What is a cookie?

A cookie is a small text file that is placed on your computer or other device when you visit a website. By placing these cookies, Carlton Collection can provide you with a better service immediately and in the future. Both Carlton Collection and the other parties that we work together with (such as Google) may place cookies on your computer and other devices. Read more about how Google uses information from our website or apps.

There are different kinds of cookies:

• Session cookies are deleted as soon as you close the browser or leave the website

• Permanent cookies remain present on your machine until their expiry date unless you delete them using your browser

3. Why are cookies used?

We use cookies and other trackers mainly for the following purposes:

Technical cookies are strictly necessary to browse on Carlton Collection websites and to use all functions of these websites, in particular for:

• Management of authentication of website visitors and the corresponding security measures, and ensuring the correct operation of the authentication module

• Optimisation of the user experience and making browsing on websites more user-friendly, in particular to set the technical routes for browsing

• Storage of data relating to the cookie information banner that is displayed to website visitors who, after accepting cookies on their device, continue on the website

• Implementation of security measures (for example, if after a certain time you are asked to register again for content or a service, or to enable basic functions of Carlton Collection websites and the use of important technical functions of these sites, such as keeping track of performance and errors on the website, management of user sessions, etc.)

Functional cookies are used to improve user friendliness, such as, for example:

• Changing Carlton Collection websites on the display settings of your device (language, currency, screen resolution, control system, configuration and settings of the display of webpages based on the machine you are using and machine location, etc.)

• Storage and changing of specific data that you enter on Carlton Collection websites to facilitate subsequent visits

• To enable you to open your personal pages more quickly by storing registration data or data previously entered

Cookies for tracking visitors are used to improve user friendliness by helping us to understand better your interactions with Carlton Collection websites (most visited pages, applications used, etc.); these cookies can collect statistical data or test different ways of displaying information to improve the relevance and usability of our services.

Advertising cookies are used (i) to provide you with relevant, targeted content in advertisements that may be of interest to you (best offers, other destinations, etc.) based on your interests, browsing behaviour, preferences and other factors, and (ii) to reduce the number of times the advertisements appear. Please note that advertisements of Carlton Collection may be displayed even without cookies. They are displayed purely as part of a commercial advertisement program and doesn’t have any relation with cookies.

Transaction/Partner cookies are used if you have made a booking and if applicable, to pay our partners commission (identify which external website has directed a visitor to our website).

Social network cookies that are set by third parties enable you to share your opinion of Carlton Collection websites and their content on social networks (for example the 'Share' and 'Like' buttons for social networks).

In some cases the (future) social network applications on the Carlton Collection websites may identify you, even if you have not clicked on the sharing button. This button can allow a social network to remember your browsing behaviour on the Carlton Collection websites, simply because your social network account was active on your device (open session) while you were browsing.

We recommend that you read the policy of these social networks and familiarise yourself with how they use the browsing data they may collect, in particular with regard to advertising. The specific aim of this policy is to enable you to make choices with regard to these social networks, in particular by configuring your user account for these networks.

For more information on the way in which these parties use cookies, you should read their privacy terms and conditions, such as those of Google Analytics, for example. If you want to switch off the analysis of your browsing behaviour by Google completely, and therefore for all websites you visit, you can install an add-on to your web browser(s) for this. 

4. Which cookies are being used on our website?

For an up-to-date overview of the cookies used on our websites, please see www.carlton.nl/en/cookie-settings.

For our websites and the hotel websites, we make use of Microsoft Clarity, an analytics tool provided by Microsoft, to gain insight into how our website is used and to improve it. Clarity records, among other things, how visitors navigate through the website, where they click, how far they scroll and how pages are used. This may take place through session recordings and heatmaps.

Microsoft Clarity processes technical data such as (anonymised) IP addresses, device data, browser information and interaction data. This data is used solely for the analysis and improvement of the website.

The data is processed by Microsoft in accordance with applicable privacy legislation. More information can be found in Microsoft’s privacy statement:

https://www.microsoft.com/en-us/privacy/privacystatement

Microsoft Clarity is only loaded after you have given your consent via our cookie settings (where applicable).

5. Permission

The installation of certain cookies is subject to your permission. If you are visiting the Carlton Collection websites for the first time, you are asked whether you agree to the installation of this type of cookie. This type of cookie is only activated once you have given your permission.

This process is supported by means of an information banner on the start page of the Carlton Collection websites; this banner informs you that you agree to the installation of cookies on your device for which your permission is required if you continue to browse on the website.

You can change your settings for our website at any time via www.carlton.nl/en/cookie-settings.

6. Deleting and/or blocking cookies

You can delete cookies and other trackers in different ways.

Browser settings

Although most browsers are set as standard to accept cookies, if you want you can select to allow all cookies, to block all cookies or even decide yourself which cookies to accept based on their senders.

You can also set your browser to allow or block cookies based on specific cases. Your browser can delete cookies from your device at regular intervals. Don’t forget to configure the browsers on all your different devices (tablets, smartphones, computers, etc.).

How you manage cookies and your preferences is different with each browser and is described in the help menu of your browser. You can also read here how to change your cookie preferences. For example:

For Safari™: http://www.apple.com/legal/privacy/en-ww/cookies

For Chrome™: http://support.google.com/chrome/bin/answer.py?hl=en&hlrm=en&answer=95647

For Firefox™: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences

For Opera™: http://help.opera.com/Windows/10.20/en/cookies.html

The storage of a cookie on your machine depends on the preferences you set and you can change these preferences free of charge at any time with your browser software settings.

If you set your browser to accept cookies on your machine, the cookies that are embedded in pages and content that you view are temporarily stored in a location for this purpose on your machine. They can only be read by their owner.

However, you can set your browser to block cookies. Bear in mind that if you set your browser to block cookies, this means that some functions and pages on the Carlton Collection websites are not accessible, and we cannot be held liable for this.

7. Help to completely block cookies

Various professional advertising platforms also give you the option to accept or block cookies that are used by companies that are a member. These centralised mechanisms do not block the display of advertisements, but simply prevent the installation of cookies for personal advertisements.

For example, you can visit the website http://www.youronlinechoices.com to stop the installation of cookies on your machine. This website is supported by digital advertising professionals and is managed by the European Digital Advertising Alliance (EDAA).

We only keep your personal data for the period necessary for the purposes of this policy or in accordance with the provisions of the applicable legislation.

You have the right to access your personal data as collected by Carlton Collection. If requested, we will tell you which of your personal data we process. In addition, you can access these data and if necessary update, modify, delete or protect them, for example if they are incorrect. This may mean that you can no longer use (part of) our services or we may not be able to provide you with the best possible service.

You can send a message to the department that deals with the protection of personal data, as given below.

Carlton Collection

Attn. Data Privacy department

Floraweg 25

3542 DX Utrecht

The Netherlands

Or by e-mail: privacy@carlton.nl

For the purposes of confidentiality and protection of personal data, we may ask you to identify yourself. You are then requested to send a copy of an official proof of identity, such as a driving licence or passport. We kindly request that you always block out your civil service (BSN) number and photograph or render it illegible. There are also apps and templates available to visually block this.

We will reply to all requests as quickly as possible, at the latest within 14 days, and in accordance with the applicable legislation. If you have a complaint relating to the processing of your personal data, you may also contact the relevant public authority (for the Netherlands: Data Protection Authority ('Autoriteit Persoonsgegevens'), https://www.autoriteitpersoonsgegevens.nl/).

We may change this policy from time to time. We therefore recommend that you consult the policy regularly, particularly when making a reservation at one of our hotels. You can do this at any time at this page. This policy will then have a different date (stated below, including a summary of the most important changes).

For all questions relating to the privacy and security policy for customer data of Carlton Collection, please contact the department that deals with the protection of personal data (see “13. How do you access or view...?”).

The following hotels are part of Carlton Collection:

Banks Mansion, Amsterdam, The Netherlands

Carlton Ambassador, The Hague, The Netherlands

Carlton Beach, The Hague/Scheveningen, The Netherlands

HUP, Mierlo, The Netherlands

Carlton Oasis, Spijkenisse, The Netherlands

Carlton President, Utrecht, The Netherlands

Carlton Square, Haarlem, The Netherlands

Banks Antwerp, Antwerp, Belgium

The Dominican, Brussels, Belgium

Carlton George, Glasgow, United Kingdom

Market Street hotel, Edinburgh, United Kingdom

In addition, HUP Sports (Mierlo) is part of Carlton Collection.

For a complete overview of the contact details per hotel see www.carlton.nl/en/contact.