What Personal Information We Collect
- your name and surname, gender, personal and work contact details (such as address, telephone number, e-mail address, ) business title, date and place of birth, image, nationality, and passport and visa information;
- guest stay information, including the hotels where you have stayed, dates of arrival and departure, goods and services utilized, special requests made, observations about your service preferences (including room and vacation preferences), telephone numbers dialed and faxes, texts and telephone messages received;
- your credit card or debit card details or other means of payment accepted by Starfish;
- any information necessary to fulfil special requests (i.e. health conditions that require specific accommodation or services);
- information, feedback or content you provide regarding your marketing preferences, in surveys, contests, or promotional offers, or to our websites and those of third parties that have a commercial relationship with Starfish;
- information collected while at a Starfish hotel through the use of closed circuit television systems, internet systems (including wireless networks that collect data about your computer, smart or mobile device, or your location), card key and other security and technology systems;
- images and audio of you captured by surveillance cameras throughout the Starfish hotels for security purposes; and
- information collected while you access a Starfish website (we describe this in more detail in Section 9 below).
We may collect data that is sensitive such as ethnic background or origin, religion, past and current health, and will seek your consent under applicable law. This sensitive data will be treated accordingly.
The Personal Information we process is information that you or someone acting on your behalf knowingly provides to us or information that we receive from a third party. In case of Personal Information belonging to minors or mentally incapables under applicable law, we will seek consent of parents, legal guardians or legal representatives, as appropriate. Parents, legal guardians or legal representatives shall exercise data protection rights on behalf of such minors or mentally incapable people.
How We Use Your Personal Information
Subject to applicable laws, we may collect, use and disclose your personal information in order to:
- register, confirm, provide and charge for hotel accommodation, services and products charged to your room and other goods and services requested by you, including those services requested to third parties with a commercial relationship with Starfish;
- provide you with a better or more personalized level of service, including information and services from a third party (such as additional guest services at Starfish hotels, local attractions, excursions and transportation options);
- respond to requests for information and services, including services from a third party (such as transportation providers and providers of excursions);
- fulfil contractual obligations to you, anyone involved in the process of making your travel arrangements (i.e. tour operators, travel agents, group travel organizers or your employer) and vendors (i.e. credit card companies, airline operators, excursion providers);
- provide for the safety and security of staff, guests and other visitors;
- administer general record keeping;
- meet legal and regulatory requirements;
- advise you about new products and services that may be of interest to you, subject to your consent in accordance with applicable laws (may be considered as secondary or non-necessary purpose);
- communicate about, and administer your participation in, special events, programs, surveys, contests and other offers or promotions, subject to your consent in accordance with applicable laws (may be considered as secondary non-necessary purpose);
- develop and maintain our relationship with you and communicate with you;
- bill you for our products and services and collect outstanding debts; and
- perform data analyses and conduct other research (such as market and consumer research and trend analysis) to develop, manage, protect and improve our products and services, website, and business (including analyzing the effectiveness of our marketing, sales and advertising) (may be considered as secondary non-necessary purpose).
When We Disclose Your Personal Information
4.1 Our affiliates and subsidiaries
Starfish may disclose and you authorize Starfish to disclose your Personal Information with its affiliates and subsidiaries.
4.2 Our Agents, Service Providers and Suppliers
4.3 Legal Requirements
Starfish reserves the right to disclose Personal Information to a third party if a law, regulation, search warrant, subpoena or court order legally requires or authorizes us to do so, or in the context of discovery procedures or if we determine it is necessary or desirable to comply with the law or to protect or defend our rights or property in accordance with applicable laws. We also reserve the right to retain Personal Information collected and to process such Personal Information to comply with accounting and tax rules and regulations and any specific record retention laws.
4.4 Business Transfers
Starfish reserves the right to disclose and/or transfer Personal Information to a third party in the event of a proposed or actual purchase, sale (including a liquidation, realization, foreclosure or repossession), lease, merger, amalgamation or any other type of acquisition, disposal, transfer, conveyance or financing of all or any portion of Starfish or of any of the business or assets or shares of Starfish or a division thereof in order for you to continue to receive the same products and services from the third party in accordance with applicable law and you consent to such disclosure and/or transfer.
Consent and Your Rights to Access Data
Starfish collects Personal Information about you only when you voluntarily provide it. You may always choose what Personal Information (if any) you wish to provide to us. However, if you choose not to provide certain details, some of your experiences with us may be affected (for example, we cannot take a reservation without a name).
We will seek consent for the use or disclosure of your Personal Information at the time of collection. Subject to applicable laws, you have the right to access, correct or request the deletion of your Personal Information at any time. In certain circumstances, you may have the right to object to the processing of your Personal Information. In such case, please contact our Privacy Officer as described below under “Contacting Us”.
You also have the right to withdraw your consent at any time, subject to legal restrictions and where applicable reasonable notice is required. If you wish to withdraw your consent, please contact our Privacy Officer as described below under “Contacting Us”.
We will not, as a condition of the supply of a product or service, require you to consent to the collection, use or disclosure of information beyond that required to fulfill the explicitly specified and legitimate purposes for which the information is being provided.
Use or Disclosure for Marketing Purposes
If you have subscribed to receive Starfish promotional and marketing emails, we may also use (but will not disclose) your Personal Information to send you relevant information by email based on your subscription preferences. We may also disclose your Personal Information to our affiliates so that they can send you promotional materials directly by email.
You may unsubscribe at any time by clicking the unsubscribe link imbedded at the bottom of Starfish’s email communications. Note, however, that clients of Starfish will continue to receive periodic emails that relate to their business relationship with us.
If you believe that any of the purposes of use described above do not originate from or are not necessary for your relationship with Starfish or if you choose not to allow us to use your Personal Information for marketing purposes, you may request that we not process your Personal Information for those purposes by contacting us as outlined below (see “Contacting Us”).
How We Protect Your Personal Information
Starfish makes commercially reasonable efforts to ensure that Personal Information collected from you is protected against loss, theft and unauthorized access, disclosure, copying, use, or modification. This protection applies in relation to information stored in both electronic and hard copy form. Access to your Personal Information is restricted to selected employees or representatives. In addition, Starfish employs generally accepted information security techniques, such as firewalls, access control procedures and cryptography, to protect Personal Information against loss and unauthorized access.
Retention and Storage of Your Personal Information
When you visit our website, we or one of our third party service providers places a text file called a “cookie” in the browser directory of your computer’s hard drive. A cookie is a small piece of information that a website can store on your web browser and later retrieve information. The cookie cannot be read by any website other than the one that placed the cookie.
You can choose to disable cookies in your browser at any time by following the procedure described in the Tools or Preferences menu in your browser. If you choose to modify your browser in this manner, some pages of this website may not function properly. Further information about cookies and other similar technology and how they work is available at allaboutcookies.org.
Links to Third Party Sites
Accessing, Correcting, Updating, or Deleting Your Information
You can help us maintain the accuracy of your Personal Information by notifying us of any changes to this information. You may also contact Starfish’s Privacy Officer as indicated below to withdraw your consent for processing your Personal Information, to access, correct, update, delete or object to the processing of your Personal Information.
We will inform you of a decision regarding your request in relation with your Personal Information in accordance with applicable law. With respect to a request for access to your Personal Information, we will send you a response by email, fax or postal mail as provided.
We may require you to confirm your identity (such as by providing government-issued identification) before processing any request in relation with your Personal Information.