naked Group Global Privacy Statement

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.

Personal Information We Collect

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:

  • Surveys: We may request demographic data or other personal information in customer surveys.
  • On-property Collection:  We collect additional personal information during registration/check-in at our properties, including such information as may be required by local laws. We may also use closed circuit television and other security measures at our properties that may capture or record images of guests and visitors in public areas, as well as information related to your location while on our properties (via keycards and other technologies). We may also use closed-circuit television and other technologies that record sound or video for the protection of our staff, guests and visitors to our properties. In addition, we may collect personal information in connection with on-property services, such as concierge services, health clubs, spas, activities, child care services, equipment rental.
  • Event Profiles:  If you plan an event with us, we collect meeting and event specifications, the date of the event, number of guests, details of the guest rooms, and, for corporate events, information on your organization (name, annual budget, and number of sponsored events per year). We also collect information about the guests that are a part of your group or event. If you visit us as part of a group, we may have personal information about you provided to us by the group and may market to you as a result of your stay with a group or attendance at an event. If you visit us as part of an event, we may share personal information about you with the event planners. If you are an event planner we may also share information about your event with third-party service providers who may market event services to you.
  • Social Media: If you choose to participate in naked-sponsored social media activities or offerings, we may collect certain information from your social media account consistent with your settings within the social media service, such as location, check-ins, activities, interests, photos, status updates and friend list. We may also allow you to enter into contests to provide photos, such as of your stay with us, which you may share with your connections on social media for votes, shared offers or other promotions.
  • Forward-to-a-Friend:  From time to time, we may offer a feature that allows you to send an electronic postcard or otherwise share a message with a friend, whether via the Internet, a stand-alone kiosk or mobile device. If you choose to use this feature, we will ask you for the recipient's name and email address, along with the text of any message you choose to include. By using this feature, you represent that you are entitled to use and provide us with the recipient's name and email address for this purpose.

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.

Personal Information We Collect from Third Parties

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.

Use of Personal Information Collected About You

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:

  • Service Administration: We use your personal information to administer programs in which you participate, including providing you with access to your account information, such as rewards status and offers for which you are eligible; to fulfill services that are part of such program; to enable direct communication between properties within the naked Group; and between the naked Group and you; and to facilitate collections.
  • Meeting and Event Planning: We may use your personal information to provide you with information about meeting and event planning.
  • Marketing and Communications: We may use your personal information to provide or offer you newsletters, promotions and featured specials, as well as other marketing messages. We use your information to provide in-stay messaging, account alerts, and reservation confirmations; to send you marketing messages; and to conduct surveys, sweepstakes, prize draws, and other contests. We may provide these communications via email, postal mail, online advertising, social media, telephone, text message (including SMS and MMS), push notifications, in-app messaging, and other means (including on-property messaging, such as your in-room television). We also use user-generated content (such as photos) from social media services to deliver display advertising or on our website and apps. We may also collect information from your payment card, which can be appended to personal information and used by naked or its business partners to recognize what type of card you have, and present and/or send you targeted marketing messages based on your payment method. We may also partner with third parties to learn whether a visitor to our site has a cash-back offer associated with their payment card and to deliver the visitor advertising and information that explains how to take advantage of that offer through a stay at a hotel within the naked Group.
  • Service Improvements: We may use your personal information to improve naked’s services and to ensure that our site, products, and services are of interest to you. We also use your personal information to provide you with the expected level of hospitality in-room and throughout our properties. This may include providing you with the ability to control your in-room technology through our website or apps on your personal devices.
  • Data Correctness, Analytics and Personalization: We may aggregate your personal information with data from third-party sources for purposes of keeping information up to date and analytics. We also rely on information from third parties in order to provide better, more personalized service. For example, if you connect your social media services or other accounts to our services, we may use this information to make your experiences with us more personal and social, or share and use it as described elsewhere in this Statement.

Personal Information We Share

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:

  • naked Group, Including naked Hub, naked Discovery, Hotels of naked, Managed Hotels and so on: We may share personal information within the naked Group and may individually or jointly use the personal information to provide you with services, personalization, and for the purposes described above. Naked Group is the party responsible for the management of the jointly used personal information. In addition, when we cease managing a hotel that we do not own or end a franchise relationship, we may provide the hotel's owner with certain information about past or future guests of that hotel.
  • Group Events or Meetings:  If you visit naked as part of a group event or meeting, information collected for meeting and event planning may be shared with the organizers of those meetings and events, and, where appropriate, guests who organize or participate in the meeting or event.
  • Business Partners:  We may partner with other companies to provide you with products, services, or offers based upon your experiences at our properties and may share your information with our business partners accordingly. For example, we may help to arrange rental cars or other services from our business partners, and share personal information with our business partners in order to provide those services. If you are an naked Hub member, we may share your personal information with our business partners in order to provide high quality membership service. We may also work with third parties, such as our airline and payment card partners, to allow us and our partners to deliver advertisements to our shared customers. Our partners may be able to provide more relevant offers to you based upon anonymous information that we share about your experiences at our properties, as well as information in your naked Hub profile. Additionally, we may allow third-party partners to recognize you when you visit that 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 share your email address with third parties using available security measures that may match it with their own email addresses so that they can send online and email advertisements to you on our behalf.
  • Co-Sponsors of Promotions:  We co-sponsor promotions, sweepstakes, prize draws, competitions or contests with other companies, and we provide prizes for sweepstakes and contests sponsored by other companies. If you enter one of these sweepstakes or contests, we may share your information with the co-sponsor or third-party sponsor.
  • On-property Services: We may share personal information with third-party providers of on-property services that services such as concierge services, spa treatments, golf, or dining experiences.
  • Service Providers:  We rely on third parties to provide services and products on our behalf and may share your personal information with them as appropriate. Our service providers are contractually obligated to protect your personal information and may not otherwise use or share your personal information, except as may be required by law.
  • Business Transactions:  As we develop our business, we might sell, buy, restructure or reorganize businesses or assets, or cease being the manager or franchisor of a hotel that is currently part of naked Group. In such circumstances, naked may transfer, sell or assign information collected, including, without limitation, Other Information and personal information, to one or more affiliated or unaffiliated third parties to the extent that local laws allow it.
  • Telemarketing:  If you stay at one of our hotels or are an naked Hub member, we may share your telephone number among the naked Group, including hotels and hubs of naked, for purposes of telemarketing. We may also receive your telephone number from our partners or from other sources, which we may use for telemarketing purposes.

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.

Other Information

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 use cookies and other technologies to collect this information. Cookies are pieces of information stored directly on the computer or mobile device that you are using. Cookies allow us to collect information such as browser type, time spent on the Online Services, pages visited, referring URL, language preferences, and other aggregated traffic data. We and our service providers use the information for security purposes, to facilitate navigation, to display information more effectively, to collect statistical information, to personalize your experience while using the Online Services and to recognize your computer in order to assist your use of the Online Services, such as for the online reservation process. We also gather statistical information about use of the Online Services in order to continually improve their design and functionality, understand how they are used and assist us with resolving questions regarding them.

Cookies further allow us to select which of our advertisements or offers are most likely to appeal to you and display them while you are on the Online Services or to send you advertisements and marketing emails. We may also use cookies or other technologies to track responses to our online advertisements and marketing emails. If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows you to automatically decline cookies or be given the choice of declining or accepting the transfer to your computer of a particular cookie (or cookies) from a particular site. If, however, you do not accept cookies, you may experience some inconvenience in your use of the Online Services. For example, we may not be able to recognize your computer, and you may need to log in every time you visit. You also may not receive advertising or other offers from us that are relevant to your interests and needs.

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.

Sensitive Information

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.

Personal Information From Children

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.

Mobile and Location-Based Services

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.

Links to Third-Party Websites and Services

Our site and our mobile applications may contain links to third parties' websites. Please note that we are not responsible for the collection, use, maintenance, sharing, or disclosure of data and information by such third parties. If you provide information on and use third-party sites, the privacy policy and terms of service on those sites are applicable. We encourage you to read the privacy policies of websites that you visit before submitting personal information.

naked may also partner with a limited number of Internet providers to offer Internet access to our guests. Your use of on-property Internet service is subject to the third-party Internet provider’s terms of use and privacy policy. You can access those terms and policies using the links on the service sign-in page, or by visiting the Internet provider’s website.

Protecting Personal Information

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: feedback@livenaked.com.

International Transfers of Personal Information

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.

Changing and Accessing Your Personal Information

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:feedback@livenaked.com. 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.

  • Acceptance and Refusal of Marketing
  • If you have given us your contact information (mail address, fax number, email address or phone number), we may want to inform you about our products and services or invite you to events via email, online advertising, social media, telephone, text message (including SMS and MMS), push notifications, in-app alerts, postal mail, our customer service call center, and other means (including on-property messaging, such as your in-room television).
  • To opt out of text messages, please tell relevant staff that you do not want to receive text messages from naked Group or set up an option of refusal as instructed in the message you received.
  • To be added to naked’s internal do not call list, send a message to following Email Address.
  • If you prefer not to receive email marketing materials from us, you may opt-out at any time by using the unsubscribe function in the email you receive from us.
  • You may control whether our mobile apps send you push notifications by changing your notification settings on your mobile device. If we engage in sending you in-app messages, we will allow control for those in our apps’ settings.

Retaining Personal Information

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.

Statement Modifications

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.

Contact Us

If you have any questions about this Statement or how naked processes your personal information, please contact us by email at feedback@livenaked.com or by postal mail to Legal Department, naked Group, 2/F, 328 Hunan Lu, Shanghai, PRC 200031.