Kruger Gate Hotel Privacy Statement for the Collection of Personal Data

Introduction

The Kruger Gate Hotel and its affiliates (“Hotel,” “we,” “our”), is committed to protecting the Personal Data it collects, stores and uses. This Privacy Statement covers Personal Data of individuals other than Hotel Associates, such as contractors, consultants, Hotel employees, and non-guests (“you,” “your”).

Purpose

The collection and use of your Personal Data enables The Hotel to engage in business planning and operational processes, such as project implementation, providing training, and administering discount programs.

What Data the Hotel Collects, Uses, Transfers and Shares, and Why

The Kruger Gate Hotel may have collected or will collect information about you and your relationship with us and, in certain cases, about those to whom room rates and food and beverage discounts are offered. We refer to such data as “Personal Data.” For more specific information regarding the Personal Data about you that we may collect, use, transfer, and share, and the purposes for which it may be collected, used, transferred, and shared, please see the end of this Statement. We will not use Personal Data for any purpose incompatible with the purposes described in this Statement, unless it is required or authorized by law, authorized by you, or is in your own vital interest (e.g., in the case of a medical emergency).

With the exception of certain data that is required by law, or is necessary or important to the performance of our business, your decision to provide Personal Data to us is voluntary. However, if you do not provide certain required data, we may not be able to accomplish some of the purposes outlined in this Statement.

Who Has Access to Your Personal Data

Access to Personal Data within our organization will be limited to personnel with a business need to access Personal Data for the purposes described at the end of this Statement, and may include personnel in Human Resources, Information Technology, Compliance, Legal, Financeand Accounting, and Internal Audit. Occasionally, we may also need to make Personal Data available to owners of the property that we manage or other unaffiliated, third party service providers.

Third party service providers and owners are expected to protect the confidentiality and security of Personal Data, and only use Personal Data for the provision of services, or in accordance with agreements, and in compliance with applicable law.

Security

The Kruger Gate Hotel will take appropriate measures to protect Personal Data, consistent with applicable privacy and data security laws and regulations, including requiring service providers to use appropriate measures to protect the confidentiality and security of Personal Data.

Data Integrity and Retention

The Kruger Gate Hotel will take appropriate measures to protect Personal Data, consistent with applicable privacy and data security laws and regulations, including requiring service providers to use appropriate measures to protect the confidentiality and security of Personal Data.

The criteria used to determine our retention periods include:

• The length of time we have an ongoing relationship with you
• Whether there is a legal obligation to which we are subject
• Whether retention is advisable considering our legal position (such as, for statutes of limitations, litigation or regulatory investigations)

Individual Rights Requests

Please contact info@Krugergatehotel.com if you have any questions or concerns about how Marriott processes Personal Data; if you wish to request access, correction, suppression, or deletion of your Personal Data; if you wish to request that we cease using your Personal Data; or if you would like to request an electronic copy of your Personal Data for purposes of transmitting it to another company. Kruger Gate Hotel will respond consistent with applicable law. Please note, however, that certain Personal Data may be exempt from these requests pursuant to applicable data protection laws or other laws and regulations.

Your Obligations

Please keep Personal Data current and inform us of any significant changes to Personal Data. You agree to inform others whose Personal Data you provide to Marriott about the content of this Statement, and to obtain their consent (provided they are legally competent to give consent) for the use (including transfer and disclosure) of that Personal Data by us as set out in this Statement, or as required by applicable law.

Reasons and Basis for Collection, Use, Transfer and Disclosure

The Hotel collects and processes data about you: (i) because such data is of particular importance to us and we have a specific legitimate interest under law to process it; (ii) because such data is necessary to fulfill a contract; or (iii) where necessary to protect the vital interests of any person. Our legitimate interest in collecting and processing Personal Data is detailed at the end of this notice and includes, for example, to administer and generally conduct business within our organization. Where this reason does not apply, your decision to provide Personal Data to us is voluntary, and we will process such data with your consent, which you may withdraw at any time.

Data Protection Contact Information

If you have any questions or concerns, please initiate your request with your corporate representative. We will investigate and attempt to resolve complaints and disputes regarding use and disclosure of Personal Data.

If you are not satisfied, you may contact us via email on Info@Krugergatehotel.com

Changes to the Statement

Kruger Gate Hotel reserves the right to amend this Statement at any time in order to address future business developments or changes in the industry or legal trends. Kruger Gate Hotel will post the revised Statement on the home page of this website. You can determine when the Statement was revised by referring to the “Last Updated” legend at the top of this Statement.

The Data We Collect

At touchpoints throughout your GUEST journey, we collect Personal Data in accordance with the law, and to serve you better. Personal Data is information that may identify you as an individual or relate to you as an identifiable individual. We collect and process the following types of Personal Data about you:

• Name
• Gender
• Postal address
• Telephone number
• Email address
• Financial information (such as credit and debit card number or other payment data)
• Language preference
• Date and place of birth
• Nationality, passport, visa, or other government-issued identification data
• Important dates: birthdays, anniversaries, and special occasions
• Membership or loyalty program data (including co-branded payment cards, travel partner program affiliations)
• Employer details (for business-related bookings)
• Travel itinerary, tour group, or activity data
• Prior GUEST stays or interactions, goods and services purchased, special service and amenity requests
• Social media account ID, profile photo and other data publicly available, or data made available by linking your social media and loyalty accounts
• In more limited circumstances, we may also collect:
• Data about family members and companions, names, and ages of children
• Biometric data
• Images, video and audio data via: (a) security cameras located in public areas, such as hallways and lobbies, in our properties; and (b) body-worn cameras carried by our loss prevention officers and other security personnel

We may also collect information about your Preferences that we use to make your current and future stays and experience with us more enjoyable, including information about your interests and other relevant information that we learn about you during your stay. This may also include any likes and dislikes about our services that you tell us about so that we can improve our services, and specific dietary, health restrictions or personal needs to ensure your wellbeing. We may also collect your “Personal Preferences,” that may include details of your special anniversaries (such as your birthday or wedding anniversary), what type of activities you prefer to take part in when staying with us, and your hobbies. Personal Preferences may also include details about who you usually travel with, their relationship to you, and your marital status.

If you submit any Personal Data about other people to us or our Service Providers (e.g., if you make a reservation for another individual), you represent that you have the authority to do so and you permit us to use the data in accordance with this Privacy Statement.

Cookies And Other Data

We may also collect “Other Data” that generally do not reveal your specific identity or do not directly relate to an identified individual. To the extent Other Data reveal your specific identity or relate to an individual, we will treat Other Data as Personal Data. Other Data include:

• Your browser or device. We collect certain data through your browser or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Apple), 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 data to ensure that the Online Services function properly.
• Your use of the Apps. We collect certain data when you download and use an App, such as App usage data, the date and time the App on your device accesses our servers, and what data and files have been downloaded to the App based on your device number. We use this data to ensure that the Online Services function properly. Our Apps may contain software development kits (SDKs) from third parties which may collect and transmit Other Data to enable various features in the App. We may also collect mobile device advertising identifiers to enhance and personalize your experience and deliver relevant products, content, or ads to show you on our Website, Apps, or external advertising.
• Cookies. We collect certain data from cookies, which are pieces of data stored directly on the computer or mobile device that you are using. Cookies allow us to collect browser type, time spent on the Online Services, pages visited, referring URL, language preferences, and other aggregated traffic data. We use functional cookies to obtain the data for security purposes, to facilitate navigation, to display content more effectively, to collect statistical data, to personalize your experience while using the Online Services, and to recognize your computer to assist your use of the Online Services. We also gather statistical cookie data about use of the Online Services to continually improve design and functionality, understand how they are used and assist us with resolving questions. Advertising cookies further allow us to select which advertisements or offers are most likely to appeal to you and display them while you are using the Online Services. We also use them to send marketing emails and to track responses to online advertisements and marketing emails. You can learn more about cookies at: http://www.allaboutcookies.org/manage-cookies/index.html

• Manage Cookie Preferences:
  • You can choose whether to accept cookies by managing your tracking preferences by clicking on “Tracking Preferences”located at the bottom of our home page or by changing the settings on your browser. If, however, you do not accept cookies, you may experience some inconvenience in your use of the Online Services. For example, we will not be able to recognize your computer, and you will need to log in every time you visit. You also will not receive advertising or other offers from us that are relevant to your interests and needs. At this time, we do not respond to browser “Do-Not-Track” signals.

• • Third Party Advertising:
    • We may use third-party advertising companies to serve advertisements regarding goods and services that may interest you when you access and use the Online Services, other websites, or online services. To serve such advertisements, these companies place or recognize a unique cookie on your browser (including through use of pixel tags). If you would like more information about this practice, and to learn about your choices in connection with it, please visit http://www.networkadvertising.org/managing/opt_out.aspand http://www.aboutads.info/.
  • • Pixel Tags and other similar technologies. We collect data from pixel tags (also known as web beacons and clear GIFs), which are used with some Online Services to, among other things, track the actions of users of the Online Services (including email recipients), measure the success of our marketing campaigns, and compile statistics about usage of the Online Services.
    • Analytics. We collect data through Google Analytics and Adobe Analytics, which use cookies and technologies to collect and analyze data about use of the Services. These services collect data regarding the use of other websites, apps, and online resources. You can learn about Google’s practices by going to www.google.com/policies/privacy/‌partners/ and opt out by downloading the Google Analytics opt out browser add-on, available at https://tools.google.com/dlpage/gaoptout. You can learn more about Adobe and opt out by visiting http://www.adobe.com/privacy/opt-out.html.
    • Your IP Address. We collect your IP address, a number that is automatically assigned to the device that you are using by your Internet Service Provider (ISP). An IP address is identified and logged automatically in our server log files when a user accesses the Online Services, along with the time of the visit and the pages that were visited. We use IP addresses to calculate usage levels, diagnose server problems and administer the Online Services. We also may derive your approximate location from your IP address.
    • Aggregated and Segmented Data. We may aggregate data that we collect, and this aggregated data will not personally identify you or any other user. We may also use both Personal Data and Other Data to divide customers into segments, or groups, in order to provide more relevant advertising.
    • Precise Location-Based Services. With your consent, we may collect the precise physical location of your device by using satellite, cell phone tower, Wi-Fi signals, or other technologies. We will collect this data if you opt-in through the App or other program (either during your initial login or later) to improve special offers and to enable location-driven capabilities on your device. If you have opted-in to share your location, the App or other program will continue to collect location data based on how you chose to share the data.
  • Precise Location Opt-Out:The user can specify via the device’s operating system to always share location, only when the App is in use, or never. If you choose only when the App is in use, we will have access to the data until you log off or close the application or if you use your phone’s or other device’s settings to disable location capabilities for the App or other program.

The Purposes for which we May Collect, Use, Transfer and Share Personal Data

• Communications and Security: Facilitating communications and safeguarding and maintaining IT infrastructure by using various security tools, office equipment, facilities and other property.
• Business Operations: Operating and managing the IT, communications systems, and facilities, managing product and service development, improving products and services, managing our assets, project management, business continuity, offering services and benefits, and maintaining records relating to business activities.
• Compliance: Complying with legal and other requirements applicable to our business in all countries or regions in which we operate, record-keeping and reporting obligations, conducting audits, compliance with government inspections and other requests from government or other public authorities, responding to legal process such as subpoenas, pursuing legal rights and remedies, defending litigation and managing any internal complaints or claims (including those received through hotlines), conducting investigations including reported allegations of wrongdoing, policy violations, fraud, financial reporting concerns, and complying with internal policies and procedures.
• Monitoring: Monitoring of email and other Hotel-owned resources, and other monitoring activities as permitted by local law. Please note that electronic communications, such as emails from Kruger Gate Hotel-provided electronic communication services and the Hotel network, do not grant personal, privileged, or confidential status or rights in such communications to the sender, recipient, or user of such messages. There is no right to privacy or to assert any privileges with respect to such electronic communications. The Hotel reserves the right to access, monitor, review, copy, and/or delete any such electronic communications. We also reserve the right to assert privileged or confidential status or rights in such communications as permitted by law.

The Categories of Unaffiliated Third Parties with whom The Kruger Gate Hotel May Share Personal Data

• Service Providers: Companies that provide products and services to our organization such as, human resources services, expense management, IT systems suppliers and support, trade bodies and associations, accountants, auditors, lawyers, insurers, bankers, and other outside professional advisors and service providers.
• Public and Governmental Authorities: Entities that regulate or have jurisdiction over our organization such as regulatory authorities, law enforcement, public bodies, and judicial bodies.