This privacy statement (“Statement”) applies to all of the hotels and hubs within the naked Group and all of its subsidiaries and affiliates as well.naked Group(collectively, "naked," "we," or "us"). At naked, we strive to deliver outstanding products, services, and experiences around the world. We value your business and your loyalty. We recognize that privacy is an important issue. We have developed this Statement to explain our practices regarding the personal information we collect from you or about you on this site or via our apps, through written or verbal communications with us, when you visit one of our properties, or from other sources. While this Statement broadly describes the practices we have adopted across naked globally, local laws vary and some jurisdictions may place restrictions on our processing activities (e.g., certain jurisdictions may require an express consent to send marketing messages). Therefore, our actual practices in such jurisdictions may be more limited than those described herein in order to enable us to comply with local requirements.
By using any of our products or services and/or by agreeing to this Statement, e.g. in the context of registering for any of our products or services, you agree to the collection and use of Personal Information as described in this Statement.
Please note that this Statement does not apply to our processing of personal information on behalf of and subject to the instructions of third parties such as airlines, car rental companies and other service providers, companies that organize or offer packaged travel arrangements, marketing partners, or corporate customers.
At every touch point or guest interaction, and in conducting every aspect of our business, we may collect personal information. This personal information may include: your contact information; information related to your reservation, stay or visit to a property; participation in a naked Hub membership or loyalty program; participation in a contest, sweepstakes, or marketing program (even if you do not stay at one of our hotels or you are not a member of our Hubs); information related to the purchase and receipt of products or services; personal characteristics, nationality, income, idetification information, passport number and date and place of issue; travel history; payment information, such as your payment card number and other card information, as well as authentication information and other billing and account details associated with mobile billing; guest preferences; marketing and communication preferences; information about vehicles you may bring onto our properties; reviews and opinions about our Portfolio of Brands or properties (if they are identified or associated with you); hotel, airline and rental car packages booked; groups with which you are associated for stays at hotels; information provided on naked Hub membership and account applications; and other types of information that you choose to provide to us or that we may obtain from third parties.
We may ask for details on joint travelers, including their names and frequent flyer numbers, and the age of the driver of the rental car. We may also collect information related to conversations, including recording or monitoring customer service calls and other communications such as in-app messages and SMS.
In addition, we collect other personal information in certain cases, such as:
In addition to the information we collect from you directly, we may also infer information about you based on the information you provide to us or from Other Information we collect.
We may also collect information about you from third parties, including information from our airline, payment card, and other partners; from your social media services consistent with your settings on such services; and from other third-party sources. We may append this information to the information we have on file for you and share it with others consistent with this Statement.
We use your personal information in a number of ways, including to provide and personalize the services you request and expect from naked, to offer you the expected level of hospitality in-room and throughout our properties, conduct direct marketing and sales promotions and as set forth below in more detail:
In order to offer you the expected level of hospitality and to provide you with the best level of service, we may share your personal information among members of the naked Group, our service providers, third parties and others as set forth in detail below:
Other: In addition, naked may disclose personal information in order to: (i) comply with applicable laws, (ii) respond to governmental inquiries or requests from public authorities, (iii) comply with valid legal process, (iv) protect the rights, privacy, safety or property of naked, site visitors, guests, employees or the public, (v) permit us to pursue available remedies or limit the damages that we may sustain, (vi) enforce our websites' terms and conditions, and (vii) respond to an emergency.
When you visit and interact with naked websites and apps, we collect other, non-personally identifying information about your use of the site, such as a catalog of the site pages you visit, and the number of visits to our sites (“Other Information”). We use Other Information, as well as data received from third parties, to deliver you email, online (on our sites and other sites) and mobile advertisements. We may also use Other Information to allow third-party partners to recognize you as a naked hotel member or a naked Hub member when you visit the partner’s website or app, or to recognize you as one of their customers when you visit naked websites or apps so that they may provide more relevant offers to you.
We may use information we have collected and aggregated, or anonymized personal information received from third parties, to understand more about our users (for example, we may use aggregated information to calculate the percentage of our users who have a particular telephone area code). This includes demographic data, such as date of birth, gender and marital status, inferred commercial interests, such as favorite products or hobbies, and other information we may collect from you or from third parties.
Because Other Information does not personally identify you, such information may be disclosed for any purpose. In some instances, we may combine Other Information with personal information. If we do combine any Other Information with personal information, the combined information will be treated by us as personal information in accordance with this Statement.
The term "sensitive information" refers to information related to your racial or ethnic origin, political opinions, religion or other beliefs, health or sex life, criminal background or trade union membership. We do not generally collect sensitive information unless it is volunteered by you. We may use health data provided by you to serve you better and meet your particular needs.
We do not knowingly collect personal information from individuals under 18 years of age. As a parent or legal guardian, please do not to allow your children to submit personal information without your permission.
We provide mobile apps that can be downloaded to your smartphone or mobile device. These apps have a variety of functionalities that enhance the customer experience. In addition to providing services, our apps may collect personal and Other Information that will be used in accordance with this Statement.
If you allow our mobile apps to access your location information on your device, our mobile apps may use your mobile device’s Global Positioning System (GPS) technology and other technology (such as wireless transmitters known as beacons) to provide you with information and offers based on the location of your device. Beacons allow us to collect information about your location within participating hotels by communicating with mobile devices that are in range. We may use this location information to enhance your on-property experience by delivering push notifications and other content to your mobile device, providing navigation assistance as you move around our locations, and sending you information and offers about products, services, or activities we believe may be of interest to you. We may share this information with third parties, including business partners and service providers, to provide information, offers, and services that may be of interest to you. To the extent any location data is combined with personal information, that information will be treated as personal information in accordance with this Statement. You may prevent or limit collection of location information by changing the settings in the naked app, or by changing your device’s settings.
naked will take reasonable measures to: (i) protect personal information from unauthorized access, disclosure, alteration or destruction, and (ii) keep personal information accurate and up-to-date as appropriate. We also seek to require our affiliates and service providers with whom we share personal information to exercise reasonable efforts to maintain the confidentiality of personal information about you. For online transactions, we use reasonable technology to protect the personal information that you transmit to us via our site. Unfortunately, however, no security system or system of transmitting data over the Internet can be guaranteed to be entirely secure.
For your own privacy protection, please do not send payment card numbers or any other confidential personal information to us via email. We will not contact you by mobile/text messaging or email to ask for your confidential personal information or payment card details. We will only ask for payment card details by telephone when you are booking a reservation or promotional package. We will not contact you to ask for your naked Hub account log-in information. If you receive this type of request, you should not respond to it. We also ask that you please notify us at following website: email@example.com.
As a global company, we endeavor to provide you with the same level of service that you have come to expect at naked whether you are in Beijing, Shanghai or Singapore. To provide this service, you agree that we may share your personal information among members of the naked Group, our service providers, and other third parties, which may be located in countries outside of your own. We promise to comply with all national/ regional laws and regulations on international transfer of personal information where our entities locate. Although the data protection laws of these various countries may differ from those in your own country, we will take appropriate steps to ensure that your personal information is handled as described in this Statement.
If you are an naked Hub member, the information you provided to us at the time of registration may be accessed, reviewed and updated at any time by signing in to your naked Hub profile.
To the extent required by applicable law, you may be able to request that we inform you about the personal information we maintain about you and, where appropriate, request that we update, correct and/or suppress personal information about you that we maintain in our active database. We will make all required updates and changes within the time specified by applicable law and, where permitted by law, may charge an appropriate fee to cover the costs of responding to the request. Such written or eletronic requests must be submitted in writing to the following address:firstname.lastname@example.org. To protect your confidentiality, we can only respond to such requests to the email address that you have registered or otherwise provided to us. Please remember that if you make such a request, we may not be able to provide you with the same quality and variety of services to which you are accustomed.
In addition, in some circumstances based on applicable law, you may request that we cease sharing personal information about you with our business partners or that naked cease using personal information about you on the grounds that such personal information was acquired by unjust means or used in violation of law by sending your written request to the following address:Legal Department, naked Group, 2/F, 328 Hunan Lu, Shanghai, PRC 200031. We will seek to honor those requests consistently with applicable law.
We retain personal information about you for the period necessary to fulfill the purposes outlined in this Statement, unless a longer retention period is required or permitted by applicable law.
We may modify this Statement from time to time. When we make material changes to this Statement we will post a link to the revised Statement on the homepage of our site, and if you have registered for any of your products or services, will may also inform you though a communications channel that you have provided. You can tell when this Statement was last updated by looking at the link and at the date at the top of the Statement. Any changes to our Statement will become effective upon posting of the revised Statement on the site. Use of the site, any of our products and services, and/or providing consent to the updated Statement following such changes constitutes your acceptance of the revised Statement then in effect.
If you have any questions about this Statement or how naked processes your personal information, please contact us by email at email@example.com or by postal mail to Legal Department, naked Group, 2/F, 328 Hunan Lu, Shanghai, PRC 200031.