1. OUR COMMITMENT
As one of our valued guest (hereinafter “You”), it is always a pleasure to welcome You to one of our hotels. Our first priority is to offer You exceptional stays and experiences around the world. Your full satisfaction and faith in Accor S.A. is essential to us.

We recognize that privacy is part of Your expectations as a guest. Therefore, we have designed and implemented this Hotel Guest Privacy Policy which describes how Accor S.A. uses Your Personal Information on the basis of Accor S.A.’s “7 Privacy Principles” (hereinafter “Accor S.A. 7 Privacy Principles”)which constitute core principles for Accor S.A. and which therefore apply throughout the Accor Group (Accor S.A. and its subsidiaries) worldwide.

2. CONSENT TO THIS HOTEL GUEST PRIVACY POLICY
You should read this Hotel Guest Privacy Policy carefully before providing us with any of Your “Personal Information” (hereinafter referred to as “PI”), i.e. any information collected and recorded in any format that identifies You personally, whether directly (e.g. name) or indirectly (e.g. phone number).

This Hotel Guest Privacy Policy is part of Accor S.A.’s terms and conditions governing our hotel services. By accepting said terms and conditions, You expressly consent to this Hotel Guest Privacy Policy.

Accor S.A. may use Your PI for marketing purposes. If required by applicable law, You will be requested to give Your prior express consent to receive such marketing materials

3. ACCOR S.A. 7 PRIVACY PRINCIPLES
The following constitute Accor S.A. 7 Privacy Principles, which apply throughout the Accor Group worldwide.

• a. Transparency: when collecting and processing Your PI, we will provide You with relevant information and notice, for what purposes and who are the recipients.
• b. Legitimacy: we will collect and process Your PI only for the purposes which are mentioned to You in this Hotel Guest Privacy Policy.
• c. Relevance & Accuracy: we will only collect PI which is necessary for the purposes of the data processing as set out in this Hotel Guest Privacy Policy. We will take all reasonable measures to ensure You that the PI that we have stored is accurate and up to date.
• d. Storage: we will keep Your PI for the period necessary for the purposes of the data processing as set out in this Hotel Guest Privacy Policy and in accordance with local law requirements.
• e. Access, Rectification and Objection: we offer You ways to access, modify, correct or delete Your PI. You also have the opportunity to object to the processing of Your PI for marketing purposes. Please see contact details below.
• f. Confidentiality & Security: we will implement reasonable technical and organisational measures to protect Your PI against accidental or unlawful alteration or loss, or from unauthorized use, disclosure or access
• g. Sharing & International Transfer: we may share Your PI within the Accor Group or with third parties (such as commercial partners and service providers) for the purposes described in this Hotel Guest Privacy Policy. We will take appropriate measures to secure such sharing and transfer.

If You have any questions about these Accor S.A. 7 Privacy Principles, please contact Accor S.A. Data Privacy Contact as described in section 13 of this Hotel Guest Privacy Policy.

4. SCOPE
This Hotel Guest Privacy Policy is applicable to:

• a. Any data processing implemented by Accor S.A. owned and managed hotels, i.e. hotels which are part of the Accor Group, including managed hotels, e.g. hotels operating under the following brands Sofitel, Pullman, Novotel, Suite Novotel, Grand Mercure, Mercure, MGallery, ibis, ibis Styles, ibis budget, Hotel F1. This list is regularly updated.
• b. Any Accor S.A. booking web sites, i.e. existing Accor S.A. websites, e.g. www.accorhotels.com and also brands websites (www.sofitel.com, www.mercure.com, etc…).

Although this Hotel Guest Privacy Policy does not apply to franchised hotels, Accor S.A. will use reasonable efforts to promote and request that the Accor S.A. 7 Privacy Principles be implemented by the said franchisees and that the said franchisees comply with all applicable laws in processing Your PI.

5. WHAT PERSONAL INFORMATION?
As an Accor S.A.’s guest, You may be asked, at various times, to provide PI about Yourself and Your family members, such as:

• Contact information, e.g. name, telephone numbers, e-mail addresses, postal addresses, etc;
• Other personal details: date of birth; nationality,
• Children Information: name, birth date and age;
• Credit card details (only in transactional related system)
• Membership card numbers of any Accor S.A. loyalty program or any membership number of frequent flyer or any of Accor S.A.’s partners You are registered with;
• Your dates of arrival and departure/visit from our hotels;
• Your preferences and interests, e.g. smoking or non-smoking room, preferred location of Your room (low floor, high floor, etc.), type of bed, preferred newspaper, sports and cultural interests;
• Any questions/comments You may have during or after Your stay in one of our hotels.

We do not knowingly collect PI from children under the age of 18, except name, date of birth and nationality as provided directly by an adult on their behalf or with adult’s permission. Please make sure that Your children do not provide us with any PI without Your permission, e.g. online. If You believe Your child has submitted PI to us, please contact us so that we can delete such PI.

Generally, we do not knowingly collect sensitive information such as racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health or sex life details.

In addition, depending on the applicable law, other data than those listed above may also be considered as sensitive data: credit card number, leisure habits, personal activities and hobbies, cultural habits, smoker/ non-smoker status, etc. However, we may need to collect such data which may be considered as sensitive, to satisfy Your request or provide You with specific services such as specific diet or any disability access facilities.

In such case, if required by applicable law, we will ask You to expressly consent that we collect and process such sensitive information.

6. WHEN IS MY PERSONAL INFORMATION COLLECTED?
PI may be collected in certain circumstances including without limitation as follows:

a.     Hospitality activities such as :

• Booking of an hotel room;
• Check in and check out;
• Consumption during a stay in an hotel as tracked through room charges;
• Claims, requests and/or disputes.

b.     Participation in marketing programs:

• Registering with Accor S.A.’s loyalty programs;
• Contribution to guests surveys and/or comments (e.g. “Guest Satisfaction Survey”, “Contact us”; “Guests comments”; “Satisfait ou invité”);
• Contests;
• Subscription to newsletters, to receive e-mail offers or promotions.

c. Provision of information by third party service providers:

• Tour operators, travel agencies, GDS reservation systems, others, …

d. Internet activities:

• Connection to any Accor S.A. websites (IP address, session cookies);
• Fill in of an online collection form (e.g. online bookings, questionnaire, etc.).

7. WHAT ARE THE PURPOSES?
We use Your PI for the following purposes:

a.     To manage Your reservation and booking:

• To book and reserve Accor S.A. hotel rooms and requested accommodation;
• To establish and maintain business records and comply with accounting requirements;
• For back office processing; including managing a list of undesirable guests, further to a non-payment, or to improper behaviour, etc.

b.     To manage Your stay at the hotel:

• To track consumption (telephone, bar, Internet, pay TV…);
• To access rooms.

c.     To improve our hospitality services, including:

• To process Your PI in Accor S.A.’s Clients Relationship Management (CRM) program;
• To better understand Your needs and requests;
• To tailor our products and services to better suit Your desires.

d.     To send You newsletters, promotions and marketing material about tourism, hospitality or services, hotel promotions, or Accor S.A. partners or contact you by telephone. You can choose to unsubscribe from our Email Newsletters service by clicking the dedicated link in our email newsletters.

e.     To improve our Accor S.A. services, including:

• To conduct surveys and analyze guests’ questionnaires and comments and activity patterns
• To manage guests’ complaints.
• To let you benefit from our loyalty program

f.      To secure and improve Your use of Accor S.A. Internet websites, including:

• To improve website navigation and;
• To implement security and fraud prevention means.

g.     To comply with local regulations (e.g. retention of business or accounting documents).

8. SHARING OF YOUR PERSONAL INFORMATION
As a global company, we strive to offer You the same level of service and hospitality all around the world. To this end, subject to Your rights set forth in section 13 below, we may have to share Your PI with internal or external recipients in the following ways:

a.     The Accor Group: we may share Your PI with any Accor S.A. entity authorized individuals who need to access Your PI to provide You with the requested services or in the context of an action as a consequence of You providing such PI:

• Hotel Staff;
• Reservation Staff using Accor S.A. reservation tools;
• Information Technology, commercial partnership and marketing departments;
• Medical services, if any;
• Legal Department, if necessary; and
• Any relevant individuals of the Accor Group entities for specific categories of data.
  
  

b.     External service providers and partners: we may share Your PI with third parties for providing You with the requested services and improving Your stay with us:

• Third party service providers: IT subcontractors, international call centers, banks, credit card providers; outside counsels, mailing service providers, printing companies;
• Commercial Partners.
  
  

c.     Local authorities – internal investigations: we may also share information with local authorities if required by local law or as part of internal investigations within the Accor Group in compliance with local regulations.

9. INTERNATIONAL TRANSFERS
We may transfer for the purposes set forth in Article 7 of this Hotel Guest Privacy Policy Your PI to recipients, internal or external, which may be located in countries with different levels of PI protection.

Therefore, in addition to the implementation of the present Hotel Guest Privacy Policy, Accor S.A. implements, , appropriate measures, including contractual clauses, to secure transfer of Your PI to any Accor S.A. entity or external recipient located in a country with a level of protection different from the one existing in the country in which the PI is collected.

10. DATA SECURITY
Accor S.A. takes appropriate technical and organisational measures, in accordance with local law requirements, to protect Your PI against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure or access. To this end, we have implemented technical measures such as firewalls and organisational measures such as a login/efficient password system, physical protection, etc.

You may have to enter Your credit card details to complete Your reservations; in such event, Accor S.A. uses Secure Socket Layer (SSL) technology to encrypt such PI.

11. COOKIES
When you visit the Accor Group’s websites, some browsing-related information on your device (computer, Smartphone, tablet etc.) is likely to be recorded in files called “cookies” and stored on your device.

a.     What are the different types of cookies?



There are several categories of cookies:

• Strictly necessary cookies: these cookies are essential in order to browse some websites and use all of their features (the user’s operating system support, display etc.). Without these cookies, features such as the display will not have optimum functionality. Note: these cookies collect purely technical data and do not identify you personally.
• Performance cookies: these cookies help us improve a user’s experience by helping us understand how they use our websites (most frequently visited pages, applications used etc.). These cookies do not identify you individually.
• Functionality cookies: in order to make browsing easier, these cookies store certain user preferences (language, username, country etc.).
• Targeting/advertising cookies: these cookies enable a user to receive targeted advertisements based on their interests, but they also limit the number of times that the advertisements appear.
• Affiliate cookies: these cookies enable third parties (“affiliates”) that publish marketing campaigns on their websites to be paid on behalf of the “web merchant”.
• Cookies from social networks: these third-party Cookies let you communicate the content of our site to others, as well as your opinion in relation to our site. This is the case with the “Share” and “Like” buttons on “Facebook,” “Twitter,” “LinkedIn,” “Viadeo,” etc.
Social networks which offer these application buttons can identify you by these buttons, even if you did not click on one of them when you visited our site. Indeed, some Cookies allow the social network concerned to follow your navigation on our site whenever your social network account is activated on your device when at the same time, you are on our site.
We have no control over the procedures social networks use to collect information about your navigation on our site. Please read these social networks privacy policies regarding personal data. These should allow you to exercise certain privacy options with these social networks, in particular by adjusting your user accounts for each of these networks.
  
  

b.     Why does Accor S.A. use cookies?



Cookies help us to improve the quality of your browsing experience when visiting the Accor Group’s websites. This technical process primarily allows us to:

• adapt the layout of our websites to suit your device’s display preferences (language, display resolution, operating system used etc.)
• store some of the information that you fill in on our online forms to help us personalize your subsequent visits to our websites
• enable you to access your personal pages more quickly by storing the log-in details or information that you have previously entered
• collect statistics. These relate mainly to the number of times you visit our websites and your use of the different services that we provide (sections and content viewed, links), with the aim of improving their relevance and usability
• put security measures in place (for example asking you to reconnect to a page or service after a certain amount of time has elapsed)
• offer you, through advertisements, personalized content that is likely to be of interest to you (better offers, other destinations etc.).

Important: Advertisements or links to third-party websites may be included on our websites. Your personal details may be collected by third parties when you click on these links. This Charter does not cover visits to third-party websites. The Accor Group cannot be held responsible for the policy of third-parties regarding personal details and the use thereof.

c.     How can you manage your cookies (enable, limit, block)?



Configuring your Internet browser (Internet Explorer™, Firefox™, Safari™, Google Chrome™, Opera™ etc.) is a free and effective way of managing cookies. You can then decide:

• to enable the use of all cookies integrated in the pages and content that you consult. Note: on the one hand, these cookies will only be readable by their issuers. On the other hand, this process is not definitive, and it will always be possible for you to disable these cookies afterwards, (cookie management will vary depending on your Internet browser; please refer to the relevant instructions)
• to block the use of cookies on your device. In this case, we would advise you that ease of navigation will be affected. Some functions require the use of cookies (for example, it is possible that your operating system will not be recognized or that the language displayed will not be the expected language). Consequently, we will accept no responsibility for any inconvenience caused by the possible malfunction of our services due to the necessary cookies being unavailable
• to be asked by your browser to either agree or disagree before the installation of a new cookie on your device
• to accept or reject the cookies depending on the issuer


The way cookies are managed will depend on your browser.

Here, you will find all information relating to usage instructions:


For Internet Explorer™
For Chrome™
For Safari™
For Firefox™ 

For Opera™

“Flash”© cookies in “Adobe Flash Player”™



“Adobe Flash Player”™ is an application which enables the rapid development of dynamic content using “Flash” programming language. Flash (and applications of the same type) stores the settings, preferences and usage of this content using technology similar to cookies. However, “Adobe Flash Player”™ manages this information and your preferences through an interface that is different to the one provided by your browser software.



As your device is likely to display content developed using Flash language, we would ask you to access Flash cookie management by consulting the site directly http://www.adobe.com/.

12. DATA STORAGE
We will store Your PI only for the time necessary for the purposes stated in this Hotel Guest Privacy Policy, or as permitted by the applicable law.

13. UPDATES
We may amend this Hotel Guest Privacy Policy from time to time as indicated below. Therefore, we invite You to read this Hotel Guest Privacy Policy regularly and in any event when making a reservation in one of our Hotels. This Hotel Guest Privacy Policy was last updated on.

14. QUESTIONS / CONTACT
If You have any questions about this Hotel Guest Privacy Policy or how Accor S.A. processes Your PI in general, please contact us at Data Privacy Dpt. as mentioned in section 13 above.