Last Updated: 29 August 2023
Introduction
The Waterfront Hotel Ltd. (C22209) is committed to protecting the privacy and security of personal data in accordance with the General Data Protection Regulation EU 2016/679 (“GDPR” or “Regulation”), the Data Protection Act (Chapter 586 of the Laws of Malta – “the DPA”) and any other relevant European Union and national law, collectively called “Applicable Data Protection Law”.
Purpose of this Privacy Policy
This privacy policy (referred to as the “Policy”) aims to give you information on how your personal data is collected and processed when you visit our website https://waterfronthotelmalta.com/ (referred to as the “Website” or the “Site”) and any of our official social media pages (e.g., Facebook, Instagram and LinkedIn). Additionally, it applies to individuals including guests who utilize any of our services, including room and suite bookings, food and beverage outlet bookings and the reservation of events and venues within our hotel.
It is important that you carefully review this Privacy Policy in conjunction with any additional privacy policies or privacy notices that we may provide during specific occasions when we are collecting or processing your personal data. This will ensure that you are fully aware of how and why we are using your data. It is important to note that this Privacy Policy serves as a complement to the other privacy policies or privacy notices and is not intended to supersede or replace them.
Please note that this Policy applies only to the use of information collected through our website or during communications with us. It does not apply to the privacy policies or privacy notices of third-party websites linked to our Site or to communications with other third parties.
Controller Details
The Controller is The Waterfront Hotel Ltd., a company registered in Malta bearing company registration number C22209 and having its registered address at Mizzi Organisation, Corporate Office, Testaferrata Street, Ta’ Xbiex, 1407, Malta (the “Controller”).
The Controller is part of the Mizzi Organisation Group (which means those companies having Mizzi Organisation Limited as their ultimate parent company). The Mizzi Group has established an Intra Group Data Transfer Agreement which governs any transfer of personal data within the companies.
The Company has appointed a Data Protection Officer (DPO) who is responsible for overseeing matters in relation to data protection. If you have any queries relating to this Policy, including any requests to exercise your rights, please contact the DPO using the details given below.
Contact Details
Full name of legal entity: The Waterfront Hotel Ltd.
Company Registration Number: C22209
Email Address: info@water.mizzi.com.mt
Postal Address: The Waterfront Hotel Ltd., The Strand, Sliema, GZR 1028, Malta
Data Protection Officer: dpo@water.mizzi.com.mt
How Your Data is Collected
Your personal data is collected when you visit our Website, by filling one of our online forms or placing a booking through our Website. We may also collect your personal data when you contact us via email, phone or through our social media pages.
Additionally, we collect your personal data during the registration and check-in process at our hotel. We may also receive your information from third parties that are booking for the use of any of our services on your behalf.
The Data We May Collect About You
Personal data means any information about an individual from which that person can be identified, directly or indirectly. It does not include data where the identity has been removed (anonymous data).
When collecting and utilizing your personal data, we guarantee that the processing is conducted on a lawful basis as per Article 6 and were applicable Article 9 of the GDPR. The table below presents transparent information regarding the processing of your personal data:
|
Activity |
Personal Data |
Purposes and lawful basis for processing |
|
When you visit this Website |
Usage Data such as cookies, IP address, pages of visited on our Site, the time and date of your visit, time spent on those pages, unique device identifiers etc. Device and Browser Specifications such as browser type, browser versions, the type of mobile device you use, mobile device unique ID, mobile operating system, unique device identifiers etc. |
We collect and use your data to better understand our users’ needs, to continuously improve our website and to enable users to access the website, for purposes of (network) security, to measure and improve the effectiveness of this website, to help diagnose problems with our server, to administer this website, to see where website traffic is coming from, to identify our users and to detect if the visitor has provided his consent through the cookie banner Lawful Basis: Art. 6 (1) (f) of GDPR, the process is necessary to fulfil our legitimate interests. |
|
When you place a Room Reservation |
Identity data such as name, surname, ID number and/or passport number Contact information such as postal address, phone number and email address Credit card data such as card number, security code and expiry date Booking details such as check-in and check-out dates |
We collect your personal data to enable room and suite bookings. We may also send you a confirmation and a pre-arrival message of your reservation. Lawful basis: Art. 6 (1) (b) of GDPR the process is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract. Lawful basis: Art. 6 (1) (f) of GDPR Processing is necessary for our legitimate interests of conducting our business. |
|
When you place a reservation regarding our food & beverage outlet or for a venue and event |
Identity data such as name and surname Contact information such as phone number and email address Health data such as dietary requirements and physical disabilities (on a voluntary basis) |
We collect and use your data for the purpose of booking a restaurant and bar reservation or booking any event of your choice. Lawful Basis: Art. 6 (1) (b) of GDPR the process is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract. Lawful basis: Art. 6 (1) (f) of GDPR Processing is necessary for our legitimate interests of conducting our business. Lawful basis: Art. 6(1)(c) GDPR as processing is necessary for compliance with our legal obligation in case of any checks from health authorities. Lawful basis: Art. 9 (2)(a) of GDPR where the data subject has given explicit consent to the processing of their personal data. |
|
When you request our services through the Contact Us Form or when you contact us via our social media pages |
Identity data such as name and surname Contact information such as phone number and email address Health data such as dietary requirements and physical disabilities (on a voluntary basis) Any information included in your message |
We collect and use this data to reach out when you submit a query through any of the following categories: –
Lawful Basis: Art. 6 (1) (f) of GDPR, the process is necessary to fulfil our legitimate interests. Lawful basis: Art. 9 (2)(a) of GDPR where the data subject has given explicit consent to the processing of their personal data. |
|
To gather your feedback |
Identity data such as name and surname Contact information such as email address |
We collect and use your data to understand whether you were satisfied with our service and making informed decisions to enhance our services, and guest experiences. Lawful Basis: Art. 6 (1) (f) of GDPR, the process is necessary to fulfil our legitimate interests. |
|
To send you marketing communication regarding any promotions, offers or events |
Identity data such as first name and last name Contact information such as phone number and email address Data related to our communications such as date and time accessed, type and content of the communications, your subscription status. |
We collect and use your data to send marketing promotions about goods and services, special offers or events.
Lawful Basis: Art. 6(1)(a) GDPR – the data subject has given consent to the processing of his or her personal data for one or more specific purposes. |
|
CCTVs, room keycards and other entry passes |
|
We collect and use this data solely for the purposes of safety and security of visitors, guests and staff. Lawful Basis: Art. 6 (1) (f) of GDPR, the process is necessary to fulfil our legitimate interests. |
In relation to the legal basis of our legitimate interest under art. 6 (1) (f) GDPR, in addition to the purposes listed above, we might process Your data also for the purposes of the establishment, exercise or defence of a claim or a legal action, to ensure network and information security and to report criminal acts. Where we process your personal data in reliance on article 6(1)(f) GDPR, we ensure that our legitimate interest does not override your interests or fundamental rights and freedoms which require protection of personal data.
You have the right to withdraw the consent to marketing at any time by unsubscribing from our mailing list or by contacting our DPO at dpo@water.mizzi.com.mt.
Cookies
When you visit our Website, we use cookies which allows us to automatically collect information about you as well as your device for different purposes, in order to enhance your navigation on our services, improve our services’ performance and customise your experience on our services. We also use this information to collect statistics about the usage of our services. For further information on what cookies are, which cookies we use, how and why we use cookies, and how you can control cookies, please read our Cookie Policy.
If You fail to provide Your personal data
The provision of personal data is not a statutory or a contractual requirement. However, if you do not provide the requested personal data, we may not be able to provide you with the requested services.
Minors
The Site is not intended for individuals under the age of 13. We do not intentionally collect personal information from children. If you are the parent or guardian and believe your child has provided us with personal information, please contact Us at the address below to request deletion.
Sharing of your personal data
The personal information will be disclosed to third parties only to the extent required for the specific purpose(s), as stipulated in this Policy. We may have to share your personal data with the following categories of recipients:
- Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and auditing services.
- Industry service providers to facilitate the delivery of our services to you. These providers include payment processors, analytical and statistical tool providers, booking processors.
- We may disclose personal data processed to other companies within the Mizzi Group in accordance with Intra Group Data Transfer Agreement.
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Policy.
- Administrative, regulatory or judiciary authorities or agencies and other third parties to comply with any legal, enforcement or regulatory obligation and/or in the cases of an express and justified request or in case of an alleged violation of legal or regulatory provisions.
International Transfer
Unless otherwise required, we keep your information within the European Economic Area (“EEA”). However, in the event that we are required to transfer your personal data to a recipient and/or third party situated in a jurisdiction outside of the EU that has not received an adequacy decision issued by the European Commission (Art. 45 GDPR), the transmission of data shall be subject to appropriate safeguards within the meaning of Article 46(1) GDPR which might include the Standard Contractual Clauses (SCCs). You can obtain a copy of the Standard Contractual Clauses (SCCs) by contacting us at dpo@water.mizzi.com.mt.
Data Security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, 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.
Data Retention
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, 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 unauthorised 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. Where your personal data is no longer required by us, we will either securely delete or anonymise the personal data in question. If you wish to know more about our retention periods, you can contact us at dpo@water.mizzi.com.mt.
Your Rights
Under certain circumstances, you have the following rights under data protection laws in relation to your personal data.
- Right to be informed about the processing of your personal data through this Policy.
- Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide you, or a third party of your choice, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
- Right to be informed of the source where the personal data we hold about you was not provided to us directly by you, you may also have the right to be informed of the source from which your personal data originates.
Please note that your rights in relation to your Personal Data are not absolute and we may not be able to entertain such a request if we are prevented from doing so in terms of an applicable law.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
If you have any questions or wish to exercise your rights, you can directly contact our Data Protection Officer (DPO) via dpo@water.mizzi.com.mt.
Automated Decision-Making
We do not engage in automated decision-making activities. Should we endeavour to make any decision based on fully automated basis we shall notify you and seek your explicit consent.
You have the right to object to processing based solely on automated decision-making (which includes profiling) when that decision-making has a legal effect on you or otherwise significantly affects you.
What We May Need From You
We may need to request specific information from you to help us confirming 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 for further information in relation to your request to speed up our response.
Time Limit to Respond
We try to respond to all legitimate requests within one calendar month. Occasionally it may take us longer 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.
Fees
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 in nature. Alternatively, we could refuse to comply with your request in these circumstances.
Right to Complaint
You have the right to make a complaint at any time to the Information and Data Protection Commissioner Office (IDPC), the Maltese supervisory authority for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the IDPC so kindly contact us in the first instance at dpo@water.mizzi.com.mt. The IDPC’s contact details are as follows:
Address: Level 2, Airways House, High Street, Sliema SLM 1549, Malta
Email: idpc.info@idpc.org.mt
Website: https://idpc.org.mt/file-a-complaint/
Further Processing
Where we need to further process your personal data for a purpose other than that for which your personal data have been collected, we will provide you, with any relevant information prior to the commencement of the further processing.
Changes to the Privacy Policy
We may update this Policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal, or regulatory reasons.
