INTRODUCTION
Welcome to master’s Privacy Notice.
Gala Home LTD, together with its subsidiaries GALA MASTERS (UK) LIMITED (in the UK) and Gala Master GmbH (in Austria), doing business as “master”, respects your privacy and is committed to protecting your personal data. This privacy notice will inform you about how we collect and process your personal data. This includes when you make a booking, request information from us, contact us (or we contact you), use our website(s)/apps, connect with us via social media, through our contact center or hotels, or any other engagement we have with you (regardless of where you are based). It also informs you about your privacy rights and how the law protects you.
This privacy notice is provided in a layered format so you can click through to the specific areas set out below.
- IMPORTANT INFORMATION AND WHO WE ARE
- THE DATA WE COLLECT ABOUT YOU
- HOW IS YOUR PERSONAL DATA COLLECTED
- HOW WE USE YOUR PERSONAL DATA
- DISCLOSURES OF YOUR PERSONAL DATA
- INTERNATIONAL TRANSFERS
- DATA SECURITY
- DATA RETENTION
- YOUR LEGAL RIGHTS
1. IMPORTANT INFORMATION AND WHO WE ARE PURPOSE OF THIS PRIVACY NOTICE
This privacy notice aims to provide you with information on how Gala Home LTD collects and processes your personal data in our dealings with you, including in providing accommodation and other services to you, including any data you may provide through our website. On the use of cookies, we provide an additional notice which you can find here.
This general privacy notice may be supplemented by other special notices we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements our other special notices and is not intended to override them.
DATA CONTROLLER
Gala Home LTD is the data controller for the relevant processing of personal data. Gala Home LTD operates properties in Israel (master Shenkin, master Haifa, master Beer Sheva, master Mazeh, master Bat Yam), Austria (master Mirabell, master Linzergasse), and the UK (master St. Paul). Gala Master GmbH and GALA MASTERS (UK) LIMITED are subsidiaries of Gala Home LTD and operate properties in Austria and the UK, respectively.
CONTACT DETAILS
You can reach our data protection officer (DPO) at:
Email address: dataprotection@stay-master.com
Postal address: Gala Home LTD, Yigal Alon 94, Tel Aviv, Israel
You have the right to make a complaint at any time to the data protection authority supervising us. We would, however, appreciate the chance to deal with your concerns before you approach the authority, so please contact us or our DPO in the first instance.
2. THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified.
We may collect, use, store, and transfer different kinds of personal data about you, which we have grouped together as follows:
- Identity Data includes first name, last name, username or similar identifier, marital status, title, date of birth, nationality, passport or ID card number (where legally required), gender, and car number plate. If your booking is made by your employer or you notify us, we may also collect the name and contact data of your employer and your job position if you are a business contact.
- Contact Data includes billing address, home address, email address, fax and telephone numbers.
- Special Requirements Data includes health, disability, and religious or dietary requirements if you notify us of any special needs and provide this information.
- Booking and Transaction Data includes bank account or payment card details and details about payments, purpose of stay, and other details of your bookings, stays, and other services you have purchased from us, as well as comments and responses to surveys you provide relating to our service.
- Technical Data of your Visit to this Website includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
- Usage Data includes information about how you use our services, or link with us via social media and our website.
- Special Traveler’s Data includes information about your recent stays/traveling, Covid test, and Covid symptoms as may be required by Federal or local law in connection with the Corona pandemic.
We will not collect all the data referred to above in each case but only such data as required for the specific purpose.
IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect personal data by law or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with accommodation or our other services). In this case, we may have to cancel a booking or other service you have with us, but we will notify you if this is the case at the time.
3. HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you, including through:
- Direct interactions. You may give us your Identity, Contact, Special Traveler’s Data, and Booking and Transaction Data by filling in forms (on paper, check-in kiosk, or web/mobile application) or by corresponding with us by post, phone, email, via our website, chatbot, on social media, or otherwise. This includes personal data you provide when you:
- Make a booking for one of our hotels, whether for overnight stays, day rooms, functions, or conferences.
- Check in to one of our hotels.
- Attend a function, conference, or otherwise use the facilities at one of our hotels.
- Subscribe to our newsletter and/or other publications.
- Request a brochure or other promotional or marketing materials to be sent to you.
- Enter a competition or respond to a promotion.
- Respond to a survey or give us feedback.
- Book a service provided by a hotel (e.g., Transportation services).
- Automated technologies or interactions. As you visit our website, interact with our chatbot, our online check-in applications, or via social media, we may automatically collect Technical Data about your equipment, browsing actions, and patterns. We collect this personal data by using cookies, e-mails, server logs, and other similar technologies. Please see our Cookie Policy for further details.
- Travel agencies or other third parties acting on your or your employer’s behalf. We may receive personal data about you if a booking is made for you by a travel agency, online portal, or another third person acting on your behalf or on behalf of your employer or other third party (e.g., tour operators, Online Travel Agencies, Global Distribution Systems).
- HTML email web beacons. Our emails may contain a single, campaign-unique “web beacon pixel” to tell us whether our emails are opened and verify any clicks through to links within the email.
- Other third parties or publicly available sources. We may receive personal data about you from third parties and public sources such as web and social media analytics providers, advertising networks, web interaction technology providers, publicly available trade registers, and feedback on different online portals and review sites.
- Monitoring. We may monitor and/or record transactions and activities at all points of contact, as well as web, social media, and app traffic and activities. These are done to ensure the accuracy of your instructions, for training purposes, to improve our services, and to ensure security and prevent fraud. We also use CCTV in and around our premises for the security of our guests and patrons, as well as to prevent and detect crime.
- Business Contacts. If you are a business contact of Gala Home LTD, we may receive your data as you interact with our website, from trade fair visits/workshops, personal meetings, correspondence through emails and phone, contractual negotiations, and agreements.
4. HOW WE USE YOUR PERSONAL DATA
- We will only use your personal data when the law allows us to do so. Most commonly, we will use your personal data in the following circumstances:
- Performance of contract: Where we need to provide the booked accommodation and services, or otherwise perform the contract we have entered into with you (or are about to enter into).
- Consent: Where you provide us with your explicit consent.
- Legitimate interests: Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Comply with obligation: Where we need to comply with a legal or regulatory obligation.
- Vital interests: In the case of any accident or medical or other emergency, to protect your or another individual’s vital interests, where you or they are not able to give consent.
For any processing that is based on your consent, you have the right to withdraw such consent at any time by contacting us.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We collect and process your personal data for purposes such as:
- Making a booking, including reserving disability adapted accommodation, providing accommodation and other services to you, managing your stay at the hotel, and monitoring the use of our services.
- Dealing with issues, complaints, or disputes arising out of our relationship with you and preventing or detecting crime, including fraud.
- Managing our relationship with you, which includes notifying you about changes to our terms or privacy policy, asking you to leave a review or take a survey, or participate in a prize draw or competition.
- Administering and protecting our business, including our website, delivering relevant website content and advertisements to you, measuring or understanding the effectiveness of the advertising we serve to you, and making suggestions and recommendations to you about our services that may be of interest to you.
- Using data analytics to improve our website, services, marketing, customer relationships, and experiences.
- Dealing with accidents, medical emergencies, or other emergencies.
- Complying with local legislation, such as storing accounting documents or registration cards and asking for Special Traveler’s Data.
- Offering you further services from the hotel or third parties relating to your stay at the hotel (e.g., transportation services, tickets for sights, etc.).
We do not undertake automated decision-making using your personal data.
MARKETING/PROMOTIONAL OFFERS
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
Where you have agreed to receive it and provided your consent, we may use your Identity, Contact, Technical, Usage, and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you.
You can revoke your consent and unsubscribe from our marketing communication at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.
SURVEY EMAIL, RELATED SERVICES OFFER, INFORMATION EMAILS
You can object to receiving emails asking you to take part in a survey, informing you about related services, or providing information about the possibility to check-in online at any time by following the opt-out links on any such message sent to you or by contacting us at any time.
COOKIES
We use cookies on our website. For more information about the cookies we use, the purposes for which we use them, and how you can manage your cookie preferences, please see our Cookie Policy.
CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason, and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis that allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. DISCLOSURES OF YOUR PERSONAL DATA
We may share your personal data with the parties set out below for the purposes set out in this privacy notice:
- Other entities within the Gala Home LTD group, including subsidiaries and affiliates, to provide our services to you and for internal administrative purposes.
- Third-party service providers who provide services such as IT and system administration, payment processing, customer service, marketing, survey, data analysis, and other similar services to enable them to provide their services to us and to you.
- Business partners, suppliers, and sub-contractors for the performance of any contract we enter into with you.
- Professional advisers including lawyers, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance, and accounting services.
- Law enforcement or regulatory agencies, government bodies, courts, or other third parties if we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish, or defend our legal rights, or (iii) to protect your vital interests or those of any other person.
- Potential buyers or investors in the event of a proposed merger, acquisition, or any form of sale or transfer of some or all of our assets. In the event of such a transaction, we will ensure that the recipient agrees to treat your personal data in a manner consistent with this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes, and we only permit them to process your personal data for specified purposes and in accordance with our instructions.
6.INTERNATIONAL TRANSFERS
We may share your personal data within the group and. All companies are currently based in the European Economic Area (EEA), UK, or Israel (where the EU Commission decided that the country provides an adequate level of data protection).
Though we do not seek actively to transfer personal data outside the EEA, UK or Israel, some of the external third parties we deal with are based outside these territories or process personal data outside these territories, so their processing of your personal data will involve a transfer of data outside these territories.
Whenever we transfer your personal data out of the country where it was collected, we ensure a similar degree of protection is afforded to it by implementing appropriate safeguards. For transfers to countries outside the European Economic Area (EEA), this may include entering into standard contractual clauses approved by the European Commission or relying on other legal mechanisms, such as the EU-US Privacy Shield framework (which has been invalidated as of July 16, 2020, by the judgment of the Court of Justice of the European Union).
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the country where it was collected.
7. DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. DATA RETENTION
We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data, and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances, we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
9. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These rights may include:
- Request access to your personal data.
- Request correction of your personal data.
- Request erasure of your personal data.
- Object to the processing of your personal data.
- Request restriction of processing your personal data.
- Request the transfer of your personal data.
- Right to withdraw consent.
If you wish to exercise any of the rights set out above, please contact us.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We 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.
ANNEXES For further information,
please refer to the following annexes:
