Privacy Policy

I. Data Controller
II. Definitions
III. Data management
III.1. Newsletter
III.2. Facebook page
III.3. Website traffic data
III.4. Contact
IV. Data security
IV.1. SSL system
IV.2. Other security-related activities
V. Data transfer
VI. Data processors
VII. Rights and legal remedies
VII.1. Providing information
VII.2. Corrections
VII.3. Deletion and blocking, objection
VII.4. Judicial redress
VII.5. Compensation and injury claims
VIII. Miscellaneous provisions

I. Data Controller

Danubius Hotel Operation and Services Private Company Limited by Shares
Seat: 1051 Budapest, Szent István tér 11.
Co. Reg. No.: 01-10-041120
registered by the Registry Court of the Budapest Tribunal
Tax No.: 10219522-2-44
Phone number: 06/1-8894172
legal associate responsible for data protection: Dr. Helga Sztanó
e-mail: adat(at)danubiushotels.com
Data Controlling Registration Number: 52139/2012.

(hereinafter: „Company” or „Danubius Co.”)

The Company respects the personal rights of its Guests, hence it prepared this Data Protection Guide (hereinafter: Guide), which is available in electronic format at the Company’s website as well as in print format in each hotel.

The Company, as data controller, hereby states that it observes the provisions of Act 112 of 2011 (hereinafter: “Data Protection Act”) on the rights for information management and freedom of information.

This Guide provides a general overview on how the Company manages data in the course of its services. Due to the wide range of Guests’ demands, the manner of data management may occasionally vary from what is described in this Guide. Such variance may occur upon the request by the Guest, and the Company shall inform the Guest about the particular manner in advance. The Company shall provide information about any data management not described in this guide prior to the particular data management process.

The Company shall only manage personal data for pre-determined purposes, for the necessary period of time and in order to exercise its rights and fulfil obligations. The Company shall only manage such personal data that are indispensable and suitable for fulfilling the objective of the particular data management activity.

Legal statements containing the agreement of minors under sixteen years of age shall not be valid unless agreed or subsequently approved by the statutory guardian of such minors.

If the Company uses the received data for any other purpose than the original purpose of data collection, the Company shall inform the data subjects in each case and ask for their specific, prior consent and/or shall provide an opportunity for them to disallow such usage.

Personal data communicated to the Company during the data management process shall only be disclosed to such persons contracted or employed by the Company entrusted with duties in relation to the given data management process.

II. Definitions

Data subject: any specific natural person identified or identifiable (directly or indirectly) based on the personal data;

Personal data: any data that can relate to the data subject – especially the data subject’s name, identification number, as well as one or more pieces of information characteristic of their physical, physiological, mental, economical, cultural or social attributes – and any such conclusions regarding the data subject that can be drawn from such data;

Special data: personal data regarding racial origin, nationality, political opinion or party affiliation, religious or other philosophical convictions, advocacy organisation membership and sexual activities, as well as personal data concerning health conditions and addictions, and personal data on prior criminal activity;

Consent: voluntary and specific expression of the data subject’s intention, which is based on proper information and by which the data subjects provide a clear and unambiguous consent to managing their personal data comprehensively or for particular operations;

Objection: a statement by the data subjects in which they object to the management of their personal data and request the termination of data management and/or the deletion of the data managed;

Data Controller: the natural or legal persons or organizations not having a legal personality, who or which determine the purpose of data management on its own or together with others, and make and carry out the decision regarding data management (including the equipment used), or have the data processor entrusted by them to carry out such decisions;

Data management: regardless of the procedure applied; any operation or the whole of operations performed on data, specifically including the collection, recording, systematization, storage, modification, application, query, transfer, publication, harmonisation or linking, blockage, deletion and destruction of data, as well as the prevention of the further usage of such data, photographing, audio or visual recording, as well as the recording of physical attributes suitable for the identification of a person (e.g.: finger- or palm prints, DNA samples, iris scans);

Data transfer: rendering data accessible for certain third parties;

Publication: rendering data accessible for the general public;

Data deletion: rendering data unrecognisable in such a manner that their restoration is no longer possible;

Tagging data: applying an identifying mark to the data in order to distinguish them;

Data blocking: applying an identifying mark to the data in order to block their management for a defined period of time or for good;

Data processing: performing any technical tasks related to data management operations, regardless of the method and equipment applied for the performance of such operations as well as of the place of application, provided that the tasks are performed in terms of data;

Data processor: natural or legal persons and/or organizations not having a legal personality, who or which perform data processing activities based on their contract with the data controller – including contracts concluded pursuant to legal provisions;

Third party: natural or legal persons and/or organizations without a legal personality, who or which are not identical with the data subject, the data controller or the data processor.

III. Data management

III.1. Newsletter

The Company shall not send newsletters to natural persons unless consented to by the data subject. The data subjects consent to the Company sending electronic newsletters to their e-mail address by providing an address in the course of signing up for the newsletter (at the website, via e-mail or in print). By providing their address, the data subjects consent to having promotional material sent to them.

The Company shall store the provided personal data on a special list, separated from data handed over to the Company for other purposes. This list shall only be accessible to the Company’s authorized personnel and data processors. The Company shall not disclose the list or data to any third party and/or unauthorized parties, and shall take all security measures to prevent any unauthorized person from viewing them.

The purpose of data management in relation to sending newsletters is to provide comprehensive, general or customized information to the addressee regarding the Company’s latest special offers.

The Company shall only manage the personal data collected for this purpose for as long as the Company wishes to inform the data subjects via the newsletter and/or until the data subjects unsubscribe from the newsletter.

The data subjects may unsubscribe from the newsletter any time at the bottom of the newsletter or at newsletter@danubiushotels.com, or by sending a request to hirlevel@danubiushotels.com

They may also unsubscribe from the newsletter by written request at the following postal address: Danubius Hotel Operation and Services Private Company Limited by Shares, 1051 Budapest, Szent István tér 11.

The Company reviews the newsletter list every five years and requests a confirmation of consent to the newsletter after five years. Within 30 (Thirty) days after the delivery of such e-mails, the Company shall delete the data of all data subjects that have not confirmed their consent to the newsletter.

The Company shall request another consent to send the newsletter to all persons who have not opened any newsletters within one year. If the data subjects do not re-consent to sending the newsletter, their personal data shall be transferred to the Prohibited List within 30 (thirty) days after the delivery of the e-mail requesting re-consent.

Guests may subscribe to the newsfeed posted on the Facebook wall by clicking “like” and can also unsubscribe there by clicking “dislike” and/or can delete the undesired newsfeed from their walls with the help of wall settings.

The Company may send promotional materials by mail without the prior consent of the data subjects as long as the Company provides an opportunity to prohibit further promotional materials.

III.2. Facebook page

The Company and the hotels/restaurants/fitness clubs/etc. can also be contacted individually via Facebook.

The purpose of data management is to share the contents of the website of Danubius Hotels Group. Guests may reserve rooms, participate in prize drawings and learn about the latest special offers via the Facebook page.

By clicking “like” on the Company’s Facebook page, the data subjects consent to the Company posting its news and offers on the data subjects’ wall.

The provisions of Article III.1. apply to the newsletter.

Data management shall be conducted in compliance with Article III.2. in the course of using Facebook applications and prize drawings.

The Company also publishes photos/videos about various events/hotels/fitness clubs/restaurants etc. on its Facebook page. Unless it is a photo of a group of people, the Company shall always request the prior written consent of the data subjects before publication.

You can find further information about the data management of the Facebook page in the data protection guidelines and rules at www.facebook.com

III.3. Website traffic data

III.3.1. References and links
The Company’s website may contain links that are not operated by the Company, and are only there to inform visitors. The Company has no influence whatsoever on the content and security of the websites operated by partner companies, and therefore it is not responsible for them either. Before providing your data in any form at the given site, please review the data protection statements and data management guidelines of the websites you visit.

III.3.2. Analytics, cookies
In order to monitor its websites, the Company uses an analytical tool which prepares a data string and tracks how the visitors use the Internet pages. When a page is viewed, the system generates a cookie in order to record the information related to the visit (pages visited, time spent on our pages, browsing data, exits, etc) but these data cannot be linked to the visitor’s person. This tool is instrumental in improving the ergonomic design of the website, creating a user-friendly website and enhancing the online experience for visitors. The Company does not use the analytical systems to collect personal information. Most Internet browsers accept cookies, but visitors have the option of deleting or automatically rejecting them. Since all browsers are different, visitors can set their cookie preferences individually with the help of the browser toolbar. You might not be able to use certain features on our website if you decide not to accept cookies.

III.3.3. Remarketing codes
We use remarketing codes to log when users view specific pages, allowing us to provide targeted advertising in the future. Visitors to the website may disable cookies that provide remarketing codes through the appropriate settings on the specific browser used.

III.4. Contact

The Company can be contacted via e-mail. The Company shall manage the messages until the given request/question is fulfiled/answered, then, after the request/question is closed, it archives such e-mails and stores them for 5 (five) years.

IV. Data security

IV. 1. SSL system

The Company uses SSL cryptography on its websites for online reservations. Any information shared by the data subject with the Company shall be encrypted automatically and be protected when transferred through the network. When the information is received by our server, it is decoded by using an individual private key. SSL enables the browser to connect to the website and establish a secure communication channel in a transparent manner. SSL is the most widely used and most successful cryptographic system. In order to use the system, the data subjects simply need to verify their browsers’ compatibility.

IV. 2. Other security-related activities

The Company shall ensure transparency to control and establish how and what personal data are transferred by applying data transferring devices, who and when entered which data into the system, and shall also make sure that the system can be restored in the case of a failure. Reports are generated with regard to errors occurring in the course of automated processing.

The Company shall manage personal data confidentially, and shall not disclose them to unauthorized persons. The Company shall particularly protect personal data from unauthorized access, modification, transfer, publication, deletion or destruction as well as from accidental destruction, harm and inaccessibility due to modification of the applied technology. The Company shall take all security measures in order to ensure the technical protection of personal data.

V. Data transfer

The Company has the right to transfer personal data handed over to the Company to hotel operating corporations belonging to the Danubius Hotels Group hotel chain but not operated by Danubius Co., as well as to business partners participating in the organization of the given prize drawing. These entities shall manage the provided data in the manner defined in this Guide. Such data transfer may only take place if the data subjects have been informed in advance accordingly, upon using the given service or participating in the prize drawing or guest loyalty programme.

In order to verify the legality of data transfer and inform the data subjects, the Company shall keep a data transfer log containing the time of transfer of the managed personal data, the legal basis and addressee of data transfer as well as the definition of the scope of the transferred personal data, and any data defined in the rule of law prescribing data management.

The Company reserves the right to hand over the managed personal data without the specific consent of the data subject to the competent authorities and courts in cases defined in the law, upon request from the authorities and courts.

In compliance with the principle of binding data to function and in order to operate the Group’s joint Guest Loyalty Programme, online room reservation system and newsletter system, the data detailed in the following Articles of this Guide: Room reservation (III.1.1.), Danubius Account (III.1.2.), Bank card data (III.1.6), Guest Loyalty Programme (III.2.) and Newsletter (III.7.), shall be transferred to the following companies in the European Union:

CP Regents Park Two Ltd.
Seat: CP House, Otterspool Way,
Watford WD25 7JP, England
Co. Reg. No.: 5307946
EU VAT No.: GB 848957555

Slovenske liecebne kupele Piešťany, a.s./Slovak Health Spa Piešťany, Inc.
Abbreviated name: SLKP, a.s.
Seat: Winterova 29, 921 29 Piešťany, Slovakia
Co. Reg. No.:: Obch. reg. KS Trnava, odd. Sa, vlozka č. 181/T
EU VAT No: SK2020389668

SC Balneoclimaterica SA Sovata
Seat: Str, Trandafirilor nr. 99, Cod.545500, Romania
EU VAT No: RO1245068
Co. Reg. No.:: J26/266/1991

Léčebné lázně Mariánské Lázně a.s.
Seat: Masarykova 22, 353 29 Mariánské Lázně, Czech Republic
Co. Reg. No.:: B 196
EU VAT No: CZ45359113

In the cases above, the sources of data are the information technology sub-systems owned by the Company (Danubius Co.)

In other issues, the companies’ data management policies shall be governed by the data controlling regulations of each country.

VI. Data processors

You can request the specific list of the Company’s data processors by sending an e-mail to adat@danubiushotels.com or by contacting the company’s employee responsible for data protection via their contacts specified in Article I. Such requests shall be fulfiled in writing by the Company within 30 (Thirty) days.

VII. Rights and legal remedies

VII.1. Providing information

Upon requests sent by the data subjects to the e-mail addresses in each chapter or addressed to the Company (Danubius Zrt. 1051 Budapest, Szent István tér 11.), the Company shall provide information regarding the particular subject’s data managed by the Company and/or processed by the data processors entrusted by the Company; the source of such data; the purpose, legal basis and duration of the data management; the names and addresses of data processors as well as their activities related to data management; and (in the case of a transfer of the data subject’s personal data) the legal basis and recipient of data transfer. Such information shall be provided within 25 (twentyfive) days, free of charge once a year for identical data, and for a fee for all additional requests.

If the provision of information is denied, the Company shall inform the data subject in writing as to which provision of which law was the legal basis to deny the information, and also inform the data subject regarding options for legal remedy.

VII.2. Corrections

If the personal data are incorrect, and the correct data are available to the Company, it shall correct such personal data.

The Company shall inform the data subject regarding the correction as well as all parties that may potentially have received the data from the Company for data management purposes. Such notice is omissible if the rightful interest of the data subject is not violated in terms of the purpose of data management.

Corrections upon request, deadline for administration and legal remedy are governed by Article VII.1.

VII.3. Deletion and blocking, objection

Cases of deletion and blocking of personal data and objections against data management are governed by the relevant provisions of the Data Protection Act in Sections 17 – 21.

The company shall provide information on the legal regulations laid out in this paragraph upon requests sent to adat@danubiushotels.com

VII.4. Judicial redress

If their privacy rights are breached, data subjects may file a lawsuit against the Company. The court procedure shall be governed by provisions in Section 22 of the Data Protection Act, and the First Book, Chapter Three, Title XII (Sections 2:51 – 2:54) of Act V of 2013 concerning the Civil Code, and other relevant legal provisions.

The company shall provide information on the legal regulations laid out in this paragraph upon requests sent to adat@danubiushotels.com

VII.5. Compensation and injury claims

If the Company causes injury or violates the subject’s privacy rights through handling the subject’s data in an unlawful manner or through violating its data security requirements, then the affected party may demand an injury claim from the Company.

The data controller shall be exempt from liability for the damage caused and from its obligation to compensate an injury claim, if it can prove that the damage or violation of the privacy rights of the affected party was caused by an unavoidable force falling outside the scope of data management.

The Company shall be exempted from liability and its obligation to compensate an injury claim, if it can prove that the damage or violation of the privacy rights of the affected party was caused by an unavoidable force outside the scope of data management. The damage may not be compensated and an injury claim may not be demanded, if it was due to the wilful or grossly negligent misconduct of the damaged party.

VIII. Miscellaneous provisions

The Company reserves the right to modify this Guide, of which it will notify the affected data subjects.

The Company shall not assume liability for the accuracy of data provided by website visitors or Guests.

With regard to data protection issues, you can request the assistance of the local Office for personal data protection

Czeck Republik – The Office for personal data protection
Adress: Pplk. Sochora 27, 170 00 Praha 7
Information: +420 234 665 555
Phone: +420 234 665 111
Fax: +420 234 665 444
e-mail: posta@uoou.cz
Tax number: 70837627
ID data box: qkbaa2n

Hungary – Hungarian National Authority for Data Protection and Freedom of Information
President: Dr. Attila Péterfalvi
Mailing address: 1534 Budapest, Pf.: 834
Address: 1125 Budapest, Szilágyi Erzsébet fasor 22/c
Phone: +36 (1) 391-1400
Fax: +36 (1) 391-1410
www: www.naih.hu
e-mail: ugyfelszolgalat@naih.hu

Latest update: 12 Febrary 2016