Symphony Style Hotel Kuwait

The Dining & living area of the Grand Suite at Symphony Style

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This Privacy Policy describes how the Symphony Style Hotel and its Affiliates and Subsidiaries (“we” or “us”) collects, uses, consults or otherwise processes an individual’s Personal Data. This Privacy Policy applies globally but depending on where you live some specific provisions of this Privacy Policy may not apply to you.

For the purposes of Privacy Law, depending on the type of Personal Data processing described in this Privacy Policy, Symphony Style Hotel may be operating as a sole or joint Controller. If operating as joint Controllers, both entities jointly determine the means and purposes of the processing of your Personal Data. What this means for you is that you can exercise your rights against either of the joint Controllers by contacting either company as set out below.

In some of the situations described in this Privacy Policy, the hotel where you made a booking and/or stay will also process your data as a (joint or sole) Controller. The hotel will be solely responsible for the processing activities for which it is the sole Controller.
Symphony Style Hotel, is a company incorporated under Kuwait laws, having its registered seat and its offices at Kuwait telephone number: +965 25770000.
We are committed to protecting the privacy of our users and customers.

This Privacy Policy is intended to inform you how we gather, define, and use Personal Data that you provide to us when using our websites and mobile applications or when relying on our hospitality services. Please take a moment to read this Privacy Policy carefully. Please note that if you plan to submit someone else’s Personal Data to us, for instance when making a booking on their behalf, you may only provide us with that person’s details with their consent and after they have been given access to information about how we will use their details, including the purposes set out in this Privacy Policy.

THIS POLICY INCLUDES A DESCRIPTION OF YOUR DATA PROTECTION RIGHTS, INCLUDING A RIGHT TO OBJECT TO SOME OF THE PROCESSING ACTIVITIES WE CARRY OUT. PLEASE NOTE THAT YOUR RIGHTS AS A DATA SUBJECT MAY VARY DEPENDING UPON WHERE YOU LIVE.

EU PRIVACY LAW REQUIRES US TO BE SPECIFIC ABOUT OUR REASONS AND LEGAL GROUNDS FOR USING YOUR PERSONAL DATA. ACCORDINGLY, FOR THE PURPOSES OF EU PRIVACY LAW ONLY, THE INFORMATION BELOW DESCRIBES THE TYPES OF DATA WE PROCESS, WHERE WE GET YOUR DATA FROM, THE GROUNDS WE RELY ON TO CARRY OUT THE PROCESSING, AND WHO WE MAY SHARE YOUR DATA WITH. EXCEPT FOR THE “PROCESSED DATA CATEGORIES” SECTIONS SET OUT IN THE INFORMATION BELOW, NOTHING IS INTENDED TO BIND US IN RESPECT OF OUR NON-EU USERS.

Country-specific provisions
Please note that there may be local variations to this Privacy Policy in order to comply with local legislation. In particular, there may be local deviations within the European Union in which case, please talk to your hotel’s front desk manager for more information or contact us at info@symphonystylehotel.com. If you have questions about hotel’s practices or the information provided by it, please contact the hotel directly.

Definitions
Affiliates and Subsidiaries: Any corporation, firm, partnership or other entity which directly or indirectly controls, is controlled by, or is under common control with Symphony Style Hotel Controller: The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data.

Processor: A natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the controller.
Recipient: A natural or legal person, public authority, agency or another body, to which the Personal Data are disclosed, whether a Third Party or not.
Third Party: A natural or legal person, public authority, agency or body other than the data subject, controller, Processor and persons who, under the direct authority of the controller or processor, are authorized to process Personal Data.
Personal Data: Any information relating to an identified or identifiable natural person (”Data Subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
Processing: Any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Privacy Shield: The EU-U.S. and Swiss-U.S. Privacy Shield legal framework, designed by the U.S. Department of Commerce and the European Commission and Swiss Administration to provide companies on both sides of the Atlantic with a mechanism to comply with data protection requirements when transferring Personal Data from the European Union and Switzerland to the United States in support of transatlantic commerce.
Symphony Style Hotel: Symphony Style Hotel’s administrative entities, including but not limited to Symphony Style Hotel.
Standard Contractual Clauses: Sets of standard contractual clauses for transfers as adopted by the European Commission for the international transfer of Personal Data.
Personal Data Breach: A breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, Personal Data transmitted, stored or otherwise processed.

Hotel Booking Process
1. Hotel booking process
In the context of the hotel booking process – whether this takes place online on one of our brand websites, through an online booking channel, via a travel agent, through our call center or directly at the hotel – we process your Personal Data for the purpose of (i) enabling you to reserve a room in the hotel of your choice; (ii) verifying the availability of the hotel and to administer the booking; (iii) sending you a booking confirmation; and (iv) sending you pre-arrival emails. You may unsubscribe from pre-arrival emails at any time by clicking on the unsubscribe link in the emails sent to you.

Processed data categories
Address, Booking details (including reservation number), Date of arrival and departure, Email address, First name / Last name, First name / Last name of adult co-guest(s), Payment card type, number and expiration date, Loyalty membership number, Telephone number, Title

Source of data
Depending on the booking mechanism used:
- Directly from you through the online booking form - Through the online booking channel you used to make the booking - From your travel agent - From our call center - From the Symphony Style Hotel you made a direct booking with

Ground for processing
Processing is necessary to take steps to enter into and perform a contract.

Recipients of data
- The Symphony Style Hotel - Other Symphony Style Hotel entities involved - IT service providers involved in the (online) booking process - IT service providers - Email communications service provider

2. Interrupted or incomplete online booking process (abandoned cart)
When you are booking online but for some reason are not able to finalize the booking process, we process your Personal Data for the purpose of enabling you to easily continue the online booking process by sending you an email with a link to the online booking form, which is pre-filled on the basis of the data you had already provided in the form.

Processed data categories
Address, Date of arrival and departure, Email address, First name / Last name, First name / Last name of adult co-guest(s), Payment card type, number and expiration date, Loyalty membership number, Telephone number, Title

Source of data
Directly from you through the online booking form

Ground for processing
It is in Symphony Style Hotel’s legitimate interest as a business to re-market an interrupted or incomplete booking process. In this context, Symphony Style Hotel’s business interests prevail over yours.

Recipients of data
- Email communications service provider - Provider of targeted advertisements

3. Guest satisfaction surveys
We may send you guest satisfaction surveys by email during or after your stay to enable us to measure the performance of our hotels. You may unsubscribe from our guest satisfaction survey emails at any time by clicking on the unsubscribe link in the emails sent to you.

Processed data categories
Country of residence, Date of arrival and departure, Email address, First name / Last name, Nationality, Loyalty membership number, Stay details

Source of data
Depending on the booking mechanism used:
- Directly from you through the booking form - Through the online booking channel you used to make the booking - From your travel agent - From our call center - From the Symphony Style Hotel you made a direct booking with

Ground for processing
Processing is necessary to ensure and follow up on the good performance of the contract you have with us.

Recipients of data
- Other Symphony Style Hotel entities involved - Guest satisfaction survey provider

4. Service emails Analytics
In the context of service emails, which includes guest satisfaction survey emails and any pre-arrival emails concerning your booking, we may process and collect your Personal Data, and notably whether you have opened and actioned a service email, for analytical purposes in order to measure the click-through rate and improve the content of our service emails. You may unsubscribe from our service emails at any time by clicking on the unsubscribe link in the service emails sent to you.

The information below describes the types of data we process for this purpose, where we get your data from, the ground we rely on to carry out the processing, and who we may share your data with.

Processed data categories
Email address, Email clicking behavior, Email opening behavior, First name / Last name, Loyalty membership number

Source of data
From our email analytics service provider

Ground for processing
It is in Symphony Style Hotel’s legitimate interest as a business to understand the email clicking behavior of its guests in order to determine whether improvements are needed. In this context, Symphony Style Hotel’s business interests prevail over yours.

Recipients of data
- Other Symphony Style Hotel entities involved - IT service providers - Email analytics service provider

Hotel Guests
1. Hotel check-in and check-out
When staying at the hotel of your choice, we will collect and process your Personal Data for the purposes of (i) registering your arrival and departure at the hotel; (ii) assigning you a key card to your room or allowing you to use your mobile device as a room key; (iii) obtaining a credit card guarantee or hotel deposit to ensure payment of your stay; (iv) managing (and archiving) your hotel registration card; (v) creating or updating your profile in our hotel management system; (vi) assessing your eligibility for a room upgrade and managing this if applicable; (vii) managing payment of your stay; (viii) establishing, printing or sending an invoice for your stay; and (ix) paying a commission to your travel agent (if applicable).
In the event you have booked a room in one of our hotels but do not show up – without cancelling – on the date of arrival communicated, we will process your Personal Data for the purposes of (i) cancelling your stay and any other reservation you may have made; and (ii) managing, processing and settling any outstanding payment that may be due.

Processed data categories
Address, Bookings (hotel, restaurant, event, theater, etc.), Date of arrival and departure, Email address, First name / Last name, First name / Last name of adult co-guest(s), Payment card type, number and expiration date, Loyalty membership number, Telephone number, Title

Ground for processing
Processing is necessary to perform the contract you have with us.

Recipients of data
- Other Symphony Style Hotel entities involved - IT service providers - Your travel agent (if applicable)

2. Credit limit reports
To ensure payment for all guests staying in a hotel room, each hotel guest is asked for a credit card or deposit upon arrival. In order to ensure that you do not exceed your credit limit during your stay, we produce a credit limit report multiple times a day for the purposes of verifying whether your credit limit has been exceeded. These credit limit reports may contain your Personal Data. Please note that in limited circumstances these credit limit reports may be subject to one of our internal financial audits, and may therefore be accessed by members of our internal audit department, in order to ensure that our hotels follow the Symphony Style Hotel internal guidelines and policies.

Processed data categories
Date of arrival and departure, First name / Last name, Payment card type, number and expiration date

Ground for processing
Processing is necessary to ensure the performance of the contract you have with us.

Recipients of data
- Other Symphony Style Hotel entities involved - IT service providers

3. Hotel stay
When you stay in one of our hotels, we endeavor to make your stay as pleasant as possible. This requires processing your Personal Data for the purposes of providing specific services during your hotel stay. These services include (i) housekeeping and maintenance; (ii) returning lost or forgotten items to you; and/or (iii) managing your and your co-guests’ preferences, such as dietary requirements and pillow preferences, in order to provide you with a better service during your stay with us.

Processed data categories
Address, Consumption habits, Date of arrival and departure, Dietary requirements, Email address, First name / Last name, First name / Last name of adult co-guest(s), Other preferences, Payment details (for the purpose of returning lost or forgotten items), Telephone number

Ground for processing
It is in Symphony Style Hotel’s legitimate interest as a business to organize its day-to-day hotel maintenance activities, to personalize the services it provides, and/or to be able to identify the owner of a lost or forgotten item. Taking into account the limited Personal Data processed and shared for such purpose(s), Symphony Style Hotel’s business interests prevail over yours.

Recipients of data
- Hotel personnel, including housekeeping, maintenance, front desk, and/or other hotel personnel concerned - Other Symphony Style Hotel entities involved - IT service providers - Delivery or courier service providers (for the purpose of returning lost or forgotten items)

4. Hotel guest additional services and facilities
In many of our hotels you can benefit from additional services and facilities, such as breakfast, room service, minibar, pool, restaurants and bars, spa treatments, laundry services, parking, taxi requests, free Wi-Fi, etc. In the event you make use of additional services or facilities at one of our hotels, your Personal Data may be processed to (i) manage the booking and use of such additional hotel services and/or facilities; (ii) administer any advance bookings of additional services and/or facilities to your file; (iii) personalize returning guests’ arrival to the hotel and the choice of room amenities and room features; and (iv) manage the expenses incurred for such additional services and/or facilities.

Processed data categories
Consumption habits, Date of arrival and departure, Dietary requirements, Email address, First name / Last name, First name / Last name of adult co-guest(s), Payment card type, number and expiration date, Loyalty membership number, Title

Source of data
- Directly from you through the online booking form - Through the online booking channel you used to make the booking - From your travel agent - From our call center - Directly from you through the hotel registration card - Directly from you when making your additional service/facility request with the hotel front desk or the concierge - Through the online booking platform for additional services and facilities

Ground for processing
Processing is necessary to take steps with a view to entering into a contract and/or to perform the contract.

Recipients of data
- Hotel personnel, including front desk, room service, and/or other hotel personnel concerned - Other Symphony Style Hotel entities involved - IT service providers

Loyalty Programs
1. Loyalty
Loyalty is a global hotel rewards program applicable throughout the hotels of the Symphony Style Hotel that is available to guests staying in our hotels, and to professional partners irrespective of whether the professional partners stay as guests or book on behalf of others. The Loyalty program is managed by Symphony Style Hotel. The Loyalty program provides you with a number of benefits during your stay at our hotel, and enables you to collect Loyalty points during your stay in our hotels and when purchasing from our selected partners. In such context, we may process your Personal Data in order to be able to i) create your online Loyalty profile, including sending you an activation link by email; ii) provide you with information on your Loyalty points; iii) register your bookings and award points to your membership card; iv) inform you about your rewards once you reach a certain points level; and v) inform you about any changes to the Loyalty program.

Processed data categories
First name / Last name, Hotel stay details, Membership number of loyalty program of relevant partner company

Source of data
Directly from you when claiming or redeeming miles or points

Ground for processing
Processing is necessary to take steps at your request with a view to perform the contract you have with us as well as to perform the contract you have with our recognized partner(s).

Recipients of data
- Other Symphony Style Hotel entities involved - IT service providers - Relevant partner company

2. Other Loyalty Program
Apart from Loyalty, we also offer our guests the possibility to earn miles or points in loyalty programs of our partners, such as frequent flyer programs, car rental programs and railway programs. In such context, we may process your Personal Data in order to be able to (i) award miles or points to your membership account with one of our recognized partners following your stay at our hotel; and (ii) assess and fulfil your request to redeem your miles or points of our recognized partners’ loyalty programs at our hotel.

Processed data categories
First name / Last name, Hotel stay details, Membership number of loyalty program of relevant partner company

Source of data
Directly from you when claiming or redeeming miles or points

Recipients of data
- Other Symphony Style Hotel entities involved - IT service providers - Relevant partner company

3. Redemption
We provide you with the opportunity to redeem your loyalty points for items such as gift cards, partner offers or charities. When you make a redemption, we process your and, if applicable, the gift card recipient’s Personal Data for the purpose of managing and successfully completing your redemption. In cases where you purchase a gift card for another person, we will process additional Personal Data for the purpose of delivering the gift card to the recipient by email or by post.

Processed data categories
First name / Last name, Payment card type, number and expiration date, your Address, Telephone number, Connection logs, email address, and IP address. If you purchase a gift card for someone else and depending on the mode of delivery, we will also process the Address of the recipient, email address of the recipient, First name / Last name of the recipient, Telephone number of the recipient

Source of data
Directly from you when redeeming your points at the hotel or online

Ground for processing
Processing is necessary for the performance of the contract you have with us.

Recipients of data
- Other Symphony Style Hotel entities involved - IT service providers - Gift card platform provider - Payment service provider - IT service providers involved in the (online) booking process

Gift Cards
We provide the opportunity to purchase physical or e-gift cards that can be redeemed at our hotels to pay hotel charges, restaurants and spa treatments.

1. Purchasing a gift card
When you purchase a gift card at one of our hotels or online, we process your and, if applicable, the gift card recipient’s Personal Data for the purposes of managing and successfully completing your purchase of the gift card. If you are purchasing the gift card for another person, we will process additional Personal Data for the purpose of delivering the gift card to the recipient by email or by post.

Processed data categories
- First name / Last name, Payment card type, number and expiration date - If a gift card is purchased online, in addition to the above, we will process your Address, Connection logs, Email address, and IP address - If you purchase the gift card for someone else and depending on the mode of delivery, we will also process the Address of the recipient, Email address of the recipient, First name / Last name of the recipient, Telephone number of the recipient

Source of data
Directly from you when purchasing the gift card at the hotel or online

Ground for processing
Processing is necessary to take steps at your request with a view to enter into and perform a contract.

Recipients of data
- Other Symphony Style Hotel entities involved - IT service providers - Gift card platform provider - Gift card manufacturer - Payment service provider

2. Registering your gift card
As a recipient of one of our gift cards, you may choose to register your gift card online in order to protect the remaining value on the card in case it is lost or stolen. Should you decide to register your gift card, we will process your Personal Data for the purpose of processing such registration.

Processed data categories
Address, Date of birth, Email address, First name / Last name, Telephone number, Title

Source of data
Directly from you during the online registration of the gift card

Ground for processing
Ad hoc consent obtained during the registration of the gift card

Recipients of data
- Other Symphony Style Hotel entities involved - IT service providers - Gift card platform provider

Subscription to Our Newsletters
1. Newsletters and marketing communications

If you have explicitly consented to receive our newsletters or marketing communications, including in relation to Loyalty, we may, from time to time, contact you with information about our services and latest offers and process your Personal Data for this purpose.

If you no longer want to receive our newsletters or marketing communications, please let us know by sending us an email at info@symphonystylehotel.com. You can also unsubscribe from our marketing emails by clicking on the unsubscribe link in the emails sent to you. For Loyalty, you may also unsubscribe by updating your profile.

Processed data categories
- Address, Date of birth, Email address, First name / Last name, Gender, Hobbies and interests, Telephone number, Hotel stay history, Country of residence

Source of data
- Directly from you when subscribing to our newsletter or later when completing your account

Ground for processing
- Ad hoc consent obtained during the subscription to our newsletter

Recipients of data
- Other Symphony Style Hotel entities involved - IT service providers - Email communications service provider

2. Newsletters and marketing communications analytics
In the context of our newsletters and marketing communications, we may also process and collect your Personal Data, and notably whether you have opened and interacted with one of our communications, for analytical purposes in order to measure the click-through rate and improve the content of our newsletters and marketing communications.

Processed data categories
- Email address, Email clicking behavior, Email opening behavior, First name / Last name, Loyalty membership number

Source of Data
- From our email analytics service provider

Grounds for Processing
- It is in Symphony Style Hotel’s legitimate interest as a business to understand the click-through rate of its emails in order to determine whether improvements are needed. In this context, Symphony Style Hotel's business interests prevail over yours.

Recipients of Data
- Other Symphony Style Hotel entities involved - IT service providers - Email analytics service provider

Mobile Applications
In order to assist our guests in booking, planning and enjoying their stay, we offer mobile applications for our different hotel brands including but not limited to.

These mobile apps can be downloaded through online app stores, including the Apple App Store or the Google Play store.

Depending on how you use our mobile applications, your Personal Data may be processed for the purposes of (i) enabling you to reserve a room in the hotel of your choice (see also Hotel Booking Process); (ii) processing your online check-in; (iii) managing your room service order; (iv) booking reservations at your request at a local restaurant; (v) performing special services at your request such as wake up calls, late check-out, or turn down service; (vi) enabling you to book meetings and events in our hotels; (vii) processing your online check-out and your feedback on your stay; (viii) addressing the requests you have made through the mobile app, including through the chat; and (ix) view how many loyalty points you have collected.

To avoid having us receive or use your real-time location, do not opt in to location services. If you did opt in and have changed your mind, you may opt out of location services through your device settings or by deleting the application. Equally, if you would like to no longer receive push notifications via one of our mobile applications, you can revoke push notification permission for the mobile application(s) in your device’s operating system settings.

The information below describes the types of data we process in the context of our mobile applications, where we get your data from, the ground we rely on to carry out the processing, and who we may share your data with. For the Loyalty mobile application, please consult the dedicated section on Loyalty .

Processed data categories
- Email address, First name / Last name, Location data, Stay details, Telephone number

Source of data
- Directly from you when downloading our application(s) or when interacting with the application(s)

Ground for processing
- Ad hoc consent obtained during the installation of the application or in the context of your use of the application

Recipients of data
- The Symphony Style Hotel of your choice - Other Symphony Style Hotel entities involved - Mobile applications provider - Cloud and hosting service providers

iBeacon
iBeacons are electronic devices that broadcast signals that can be received by mobile devices on which one of our mobile apps is installed. If you have voluntarily installed one of our apps on your device, and if you have granted permission for the app to track your location, then iBeacons installed in our hotels may send a signal to the app on your device about the precise, real-time location of the device. The app may use this information to deliver special offers and promotions to you, at a time and place when the information is most relevant. For example, if you are in one of our hotels late in the afternoon, your mobile device may receive a signal from an iBeacon that causes the app to notify you about drink or dinner specials. As a convenience to you, receipt of the iBeacons signal and delivery of the special offer or promotion may occur even if you are not currently using the app. To make our mobile apps and services operate better, we may also collect other information based on iBeacon signals, for example, the strength of the signal between the iBeacon and your device, the duration your device is near the iBeacon, or the battery level of the iBeacon itself. To avoid having us receive or use your precise, real-time location, do not opt in to location services. If you did opt in and have changed your mind, you may opt out of location services through your device settings or by deleting the app.

Website Forms
Should you have a particular query or feedback, including the exercise of one of your rights under the GDPR, you may con