ROOMNET LLC Guest Entertainment and Internet Access Privacy Notice Introduction and main purposes
This Privacy Policy relates to users of ROOMNET LLC systems installed in hotels and similar accommodation units. Guests of these establishments and will use ROOMNET’s systems to access the internet, use entertainment and guest services applications to enhance their stay. We will collect, use and process certain personal information required to enable or enhance purposes connected with your visit at this property. This data will be purged after the use of services has concluded. Some data may be retained by the establishment in other systems to enhance your guest experience for future stays in this or other associated locations. Except where required by law, we use the personal data you provide for the following purposes:to register you on our platform during your stay to deliver the specific information or services you have requested; to enable you to access your own subscription content; to allow you to connect to the internet to respond to your requests and feedback; and analyse and/or improve our services.Under data protection law we are required to advise you on the legal basis for processing your personal data. For the most part, the processing of your personal information is based either on a) our legitimate interests related to us providing you services you have requested or otherwise your customer relationship with the property.In the table below we set out further information about the purposes for which we use your personal data and the legal basis we rely on for its use. Note that we may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data.
Purpose/Activity
Types of personal data that may be processed
Lawful basis for processing including basis of legitimate interest
Internet Access
Collection of personal information provided by you
(a) Name
(b) Email address
(c) Telephone number
(d) Room number
Necessary for our legitimate interests of providing you access to the internet services of the property in which you are staying.
Guest Entertainment System
Collection of personal information provided by you
(a) Name
(b) Room number
(c) Sign in credentials to access your streaming services
We rely on your consent to process personal information relating to your subscription services to enable us to download the service providers application onto our platform. Enabling you to log into the service and enjoy your subscription content at the property.
Guest Services Applications
(a) Name
(b) Room number
In some cases, we may ask for your consent to share your personal data and responses with a third party in digital (data file). You are under no obligation to agree to this and you will always be informed who these third parties are. We would share this personal information based on your consent.
To manage incentives
(a) Name
(b) E-mail address
(c) Telephone number
Some projects may include an incentive for your loyalty. These incentives will be processed by B2B international staff. Incentives will usually be in the form of loyalty points or vouchers. We process this personal information on the basis of your consent.
To share information with our service providers.
(a) Usage
(b) Marketing and communications
(c) Technical
It is our legitimate business interest to share your data with trusted third parties who provide us with services relevant to the provision of our website. This data is shared anonymously to assist us in understanding system usage an improving the services for future stays and other customers and their guests.
How long we keep your personal information
We store your personal information in accordance with legal, regulatory, financial and best-practice business requirements. Once your personal information is no longer necessary, we will securely delete/destroy your data in line with our data retention policies.Our standard retention period for personal data relating to providing services are:Guest Internet
Our standard retention period for personal data relating to guest internet usage is 3 years.
Guest Entertainment and Guest Services Applications
Our standard retention period for personal data relating to guest entertainment system usage is for the duration of the stay. All data is wiped upon check-out.
How we secure your personal information
We maintain appropriate organisational and technological safeguards to help protect against unauthorised use, access to or accidental loss, alteration or destruction of personal data. We also seek to ensure our service providers and partners do the same.
Information Sharing and Disclosure
We DO NOT send personal data collected to third party organizations.We do have offices and operations in a number of international locations, and we share information between our group companies for business and administrative purposes.Your usage information may also be stored in one or more databases hosted by third parties. These third parties do not have use or access to your personal information for any purpose other than cloud storage or retrieval.Where required or permitted by law, personal information may be provided to others, such as regulators and law enforcement agencies, for example in response to a court order or a subpoena, or in response to a law enforcement agency’s request, or where we believe it is necessary to investigate, prevent or take action regarding illegal activities, and as otherwise required by law.From time to time, we may consider corporate transactions such as a merger, acquisition, reorganisation, asset sale, or similar. In these instances, we may transfer or allow access to information to enable the assessment and undertaking of that transaction. If we buy or sell any business or assets, usage information may be transferred to third parties involved in the transaction.
International and group company transfers of personal information
We are part of an international group of companies and, as such, from time to time we may transfer usage information concerning you to countries outside the European Union (“EU”).Where we transfer usage information outside of EU, we either transfer information to countries that provide an adequate level of protection (as determined by the European Commission) or we have appropriate safeguards in place. Appropriate safeguards to cover these transfers are in the form of standard contractual/data protection clauses adopted by the European Commission and where transfers are to the US, we may rely on Privacy Shield certification. Where we transfer information between our group companies, we have covered these transfers by entering into standard contractual clauses adopted by the European Commission.If you would like more information on the any of the data transfer mechanisms on which we rely please contact us at using the details provided below.
Your rights regarding the personal information you provide to us
General rightsIf you would like us to delete your information from our records, please contact us using the contact details below and we will respond within a reasonable time. Please note that we may be required to retain certain information by law and/or for our own legitimate business purpose.Users from the EUIf you are from the EU, you have rights (with some exceptions and restrictions) to:object to our processing of your personal information. You can object at any time and we shall stop processing the information you have objected to, unless we can show compelling legitimate grounds to continue that processing;
access your personal information. If you make this kind of request and we hold personal information about you, we are required to provide you with information on it, including a description and copy of the personal information and why we are processing it;
request erasure of your personal information in certain circumstances.request correction or updating of the personal information that we hold about you and that is inaccurate;
request the restriction of our processing of your personal information in some situations. If you request this, we can continue to store your personal information but are restricted from processing it while the restriction is in place;
withdraw your consent to our use of your personal information at any time. When you use our website you may have been asked to consent to the use of cookies. You may withdraw your consent to our processing of your personal information that has been derived from cookies. If you do withdraw consent, that will not affect the lawfulness of what we have done with your personal information before you withdrew consent;
object to our use of your personal information for direct marketing;
request portability of your personal information that we hold, in certain circumstances;
complain to your local data protection authority about our collection or use of your personal information. For example, in the UK, the local data protection authority is the UK Information Commissioner’s Office.If you exercise the rights above and there is any question about who you are, we may require you to provide information from which we can satisfy ourselves as to your identity.If you are from the EU and would like to exercise any of these rights in relation to any information, we hold about you please contact us using the contact details provided below. We will consider and respond to your request in accordance with the relevant law.
Updates
This Privacy Notice may be updated from time to time to reflect changes in law, best practice or a change in our practices regarding the treatment of personal data. The date of the most recent revision will appear at the top of this page. If you do not agree to the changes, please do not continue to use our services and please refrain from sharing your personal data with us. You should check this notice frequently for updates.
Time limit to respond
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. YOUR LEGAL RIGHTS
You have the right to:
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 to you, or a third party you have chosen, 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. How to contact us
If you have any questions about this Privacy Notice, our approach to privacy or you would like to exercise any of the rights mentioned in this Privacy Notice you can contact our Chief Executive Officer in any of the following ways:Address: Chief Executive Officer, ROOMNET LLC, 232 Avenida Fabricante, Second Floor – Suite 105, San Clemente, CA 92673, United States
In this Supplementary Information section, we explain some of terminology used in this Privacy Notice.“data controller” – the person or company that controls the purposes and means of processing personal data.“personal data” – any information that relates to you (or from which you can be identified).“processing”– means doing anything with data. For example, it includes collecting it, holding it, disclosing it and deleting it.“transfer” – sending personal information outside the European Economic Area (e.g. by storing it on equipment located outside the European Economic Area), or allowing someone from outside the European Economic Area to access the personal information.
