Privacy policy
1. SmartHOTEL B.V.
SmartHOTEL B.V. (hereinafter “SmartHOTEL” or “we”) is a Netherlands based company. Our business operations are in the Netherlands, and we store our data on servers in the European Economic Area (EER).
The websites operated by SmartHOTEL and any micro-sites, mobile-site, or subdomains of such sites (collectively, the “Website”) and all features, functions, software and services offered through the Website are referred to as the “Service.”
If you would like to make use of the Service, you will have to agree to the terms of use for the Service. After you have agreed to the terms of service you are a customer of SmartHOTEL (“Customer”).
It is important to us that your Personal Data is treated with care and that you are well informed about the way we process your personal data.
When you visit the Website, correspond with us, are (or are in the process of becoming) one of our Customers we process personal data about you as a data controller.
2. What is Personal Information?
“Personal Information” means any information relating to an identified or identifiable natural person (“data subject”) according to the definition of personal data as set out in Directive 95/46/EC of the European Parliament and of the Council of 24 October 1995 on the protection of individuals with regard to the processing of personal data and on the free movement of such data (the “Directive”).
An identifiable person is someone who can be identified, directly or indirectly, in particular by reference to an identification number or to one or more factors specific to his physical, physiological, mental, economic, cultural or social identity.
“Personal Information” is information that identifies an individual (such as a name, address, telephone number, mobile number, e-mail address, or other account number), and all information about that individual’s location or activities, such as information about his or her use of the Service, IP-addresses or mobile device identifiers, when this can be linked to any Personal Information.
“Personal Information” also includes demographic information such as date of birth, gender, geographic area and preferences when this information can be linked to any other Personal Information.
“Personal Information” does not include “aggregate” information, which is data about a group or category of products, services or users, when this “aggregate” information cannot be linked to any Personal Information. Aggregate data helps us understand trends and our Customers’ needs so that we can better consider new features and functions, or otherwise tailor our Services. These Privacy Terms do not restrict or limit our collection and use of “aggregate” information.
3. When, why and how do we process your data?
A. When you visit and use our Website
When you browse our Website, we process your IP-address, Google Analytics ID, internet browser and device type, location data and your use of our Website, including which pages you visited, how you got to our Website, the time and length of your visit and your language preferences.
We use this data for our legitimate interests being: making sure our Website works properly, can be improved, debugged and optimized (using statistical analyses), delivering you content and for DDOS mitigation on our Website.
We collect this data using cookies and similar techniques, including tags/beacons and java scripts. More information about these techniques can be found in our Cookies Policy.
When we collect information about how you use our Website, such as which landing pages you visit and which items you look at, we do so to decide about how we could best provide our services to you. For example, if you read about our Services on our Website, we might classify you as a user or a Website visitor who is interested in our Services and therefore as a potential customer. Based on the audience we expect you belong to, we may act, for example by contacting you with offers about our products and services, if we have your consent for this.
In order to make the most accurate assessment about which audience you likely belong to, and as you can also read in our Cookies Policy, we also use tracking cookies. These cookies track information about how you use our Website and which other websites you visit, for example to show you advertisements if we suspect that you might be interested in our products and services. We only place these tracking/targeting cookies with your prior consent. For more information about these tracking cookies, please view our Cookies Policy.
How long do we keep this data?
We will keep your data for as long as we reasonably need it for the purposes listed above.
For example, data about your visits to our Website will be retained until your use or browsing session ends, except where it concerns data collected for the analytical and marketing purposes specified above. In those cases, we will keep your information for 1 year after collection.
B. When you are a Customer using our Service(s)
If you register to become a Customers by entering into an agreement with SmartHOTEL, we collect information we need to establish and perform a contract with you, including your contact information, address, ID documentation, tax information and payment details.
We use this information to set up our Services for you, to provide support, onboarding, integration to our Services, helping you with settings in your Customer Area (being: Connect Studio, Payment Studio and Channel Management Extranet), POS terminal field services, installation of POS terminals on location and to pick up old/damaged POS terminals, and other actions which need to be taken to establish or perform our contract with you.
In addition, we use your information for our legitimate interest of managing our internal administration and for complying with our legal obligations, such as KYC (Know Your Customer) and taxation obligations.
We also collect data about your use of our Services and your Customer Area account, including your login details, and the questions, queries, comments and complaints you send us in relation to our business relationship. We process this data to be able to perform our contract with you by following up with you and providing you with support and for our legitimate interest of being able to optimize and improve our products and services.
We can also use your (company) e-mail address for: keeping you up to date with our products and services; making you offers tailored to your needs (meaning similar products and services you have already purchased from us); or inviting you to events.
How long do we keep this data?
If you are or becoming a Customers, we will keep information relating to our business relationship until 7 years after the end of your contract with us or until our rejection of your application to become a Customer.
C. How we process data for our newsletter and marketing purposes
You can sign up for our newsletter or receive invitations to events using your name and e-mail address via the sign-up form on our Website. When you sign up, you indicate your consent to receive our newsletter and invitations. You can at any time unsubscribe from receiving these e-mails by following the instructions provided in the newsletters.
If you are a Customer, we may contact you in relation to relevant Services, for our legitimate interest of developing our business. We can do this via e-mail or, we connect to you on LinkedIN and/or to send you messages on LinkedIN.
If you are not yet a Customer, we will only contact you, for example via e-mail or LinkedIn, with offers or about our Services. When we contact you in this context via e-mail, you always have an opportunity to opt out at any moment by following the instructions in the e-mail or by contacting us using the contact details below under (“Contacting us”).
You can also download content, for example blogs, white papers and research reports, from our Website using the form designed for this purpose. We collect the data you fill out on the form: name, e-mail address and function (e.g. manager). We process the data you fill out for our legitimate interest of keeping track of who downloads our content.
How long do we keep this data?
We store the information that we process because of you describing to our newsletters or because you have consented to receive information about our Services or about offers until you decide you would no longer like to receive these mailings.
D. When you contact us or request us to contact you
Via the Website, you can contact us or ask us to contact you regarding questions, queries, (support) requests, comments or complaints, fill out an application to become a merchant or a partner or sign up for a test account. When you do this, we collect the information that you fill out, including your name, company, contact details, the reason you are contacting us, verification that you are not a robot and other information you decide to provide us. You can also contact us by calling us or e-mailing us using for example the contact details listed on our Website. If you do so, we will collect your name, company and any other information we need to be of further assistance to you and/or communicate with you.
We use this data above to answer your question, comment or complaint and respond to your queries and (support) requests and to assess your application to become a merchant or partner. As such, this data is used by us to establish or perform our (future) contract with you and for our legitimate interests in following up with you. We also use the data above for our legitimate interest of conducting business with you and managing our internal administration, for training purposes, for establishing and performing our contract with you, for our legitimate interest of conducting marketing research so we can improve our products and services and to be able to offer our (future) merchants tailored products and services.
How long do we keep this data?
We will keep your data about any questions, comments or (supports) requests you have made to us, for as long as we reasonably need it for the purposes listed above which will be at least two years.
E. Other purposes
If necessary, we may also process any of your information above for our legitimate interest of protecting our legal rights, for example in connection with legal claims, and when we have a legal obligation to process your information. In the case of a reorganization, change in ownership, or merger, we may transfer your data as well.
4. How long do we keep your information?
We will keep your data for as long as reasonably needed for the purposes defined above.
The retention terms defined above may be longer if we are required to keep data longer based on applicable law or to administer our business. If we need to keep any information longer for our legitimate interest of protecting our legal rights, we will keep the necessary information for this purpose until the relevant claim(s) has/have been settled.
5. Social media buttons
We use plugins on our Website from social media networks such as LinkedIN and Twitter. You can recognize these plugins by their logos.
We do not have any influence over which data these providers collect from you, and we are also not aware of the extent of their data processing. If you would like more information about their data processing, we recommend that you review the respective privacy policies on the websites of these providers.
6. Cookies
We use cookies and similar techniques, such as tags/beacons and java scripts, which are small text files stored on your device. Cookies enable us to recognize people and Customers who have previously visited the Website. Furthermore, Cookies allow us, in conjunction with our web server’s log files, to calculate the aggregate number of people visiting our Website and which parts are most popular. This helps us gather feedback to improve our Website and better serve you.
Cookies do not allow us to gather any Personal Information about you and we do not intentionally store any Personal Information that your browser provided us in your Cookies.
If you wish to block, erase, or be warned of cookies, please refer to your browser or mobile device’s instructions or help screen to learn about these functions. However, if a browser or mobile device is set not to accept cookies or if you reject a cookie, some portions of the Website and Service may not function properly. For example, you may not be able to sign in and may not be able to access certain Website features or Service.
You may find out more specific information about our use of cookies and web beacons at our Cookie Policy. You can find out more information about how to change your browser cookie settings at www.allaboutcookies.org.
We may also use third parties to serve ads on our Website. These third parties may place cookies, clear gifs or other devices on your computer to collect information, and information provided by these devices may be used, among other things, to deliver advertising targeted to your interests and to better understand the usage and visitation of our Website and the other site Websites tracked by these third parties. If you wish to not have this information used for the purpose of serving you targeted ads, you may opt-out by clicking here www.youronlinechoices.eu. Please note this does not opt you out of being served advertising. You will continue to receive generic ads. Please note that we have no access or control of any third-party tracking technologies. If you wish to block third party cookies, please refer to your browser instructions or help screen to learn about these functions.
7. With whom do we share this information?
To provide the Website and Services we need to engage the help of third parties. Where necessary we will share your information with our service providers and professional advisers (e.g. IT providers, KYC partners, CRM providers, social media providers such as LinkedIN, analysts, customer service providers, business development providers and legal service providers). We have concluded agreements with our service providers to protect your personal data.
If our company or business is sold or integrated with another business, your details will be disclosed to our advisers and any prospective purchaser’s adviser and will be passed to the new owners of the business.
Otherwise we will not share your information with any third party, unless we have your prior permission, where this is necessary in connection with the purposes above or with legal claims or when we have a legal obligation to do so.
8. How do we protect your data?
SmartHOTEL shall ensure it implements and maintains compliance with appropriate technical and organizational security measures for the processing of Personal Information. We follow generally accepted standards to protect the Personal Information submitted to us, both during transmission and once we receive it.
We have put in place physical, electronic, and managerial procedures that are designed to prevent unauthorized access, loss, or misuse.
We use TLS (Transport Layer Security) technology to encrypt your transmission of sensitive information to us, such as account passwords, credit card numbers and other payment-related identifiable information).
We restrict internal access to Personal Information to employees who need the information to perform their duties. The unauthorized access or use of such information by an employee is prohibited and constitutes grounds for disciplinary action.
Our information management systems are configured in such a way as to block or inhibit employees from accessing information that they have no authority to access.
You should note that our processors may be responsible for processing, handling or storing some of the Personal Information that we receive. They are not authorized to market to you independently. These processors are contractually by means of a data processing agreement with SmartHOTEL required to safeguard and secure the Personal Information they received from us.
No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security.
9. Your Rights
You are entitled to object to us processing your personal data, including profiling. You may ask us for an overview of your information and ask for a copy. You may request us to correct or delete certain data, restrict processing of your data, or ask us to transfer some of this information to other organizations. In some cases, you may object to the processing of your data and, where we have asked for your consent to process personal data, you can withdraw this consent at any time. Where we process your data for our legitimate interests, you can contact us if you want more information about these.
However, there are some exceptions to these rights. For example, we will not be able to delete your data if we are required by law to keep it or if we hold it in connection with a contract with you. Similarly, access to your data may be refused if making the information available would reveal personal information about another person or if we are legally prevented from disclosing such information.
If you wish to exercise any of these rights, please contact us using the details below.
10. Contacting us, questions and complaints
Questions, comments, requests, concerns or complaints concerning this privacy statement and/or the way SmartHOTEL processes your personal data can be addressed to: privacy@smarthotel.nl.
SmartHOTEL B.V. (hereinafter “SmartHOTEL” or “we”) is a Netherlands based company. Our business operations are in the Netherlands, and we store our data on servers in the European Economic Area (EER).
The websites operated by SmartHOTEL and any micro-sites, mobile-site, or subdomains of such sites (collectively, the “Website”) and all features, functions, software and services offered through the Website are referred to as the “Service.”
If you would like to make use of the Service, you will have to agree to the terms of use for the Service. After you have agreed to the terms of service you are a customer of SmartHOTEL (“Customer”).
It is important to us that your Personal Data is treated with care and that you are well informed about the way we process your personal data.
When you visit the Website, correspond with us, are (or are in the process of becoming) one of our Customers we process personal data about you as a data controller.
2. What is Personal Information?
“Personal Information” means any information relating to an identified or identifiable natural person (“data subject”) according to the definition of personal data as set out in Directive 95/46/EC of the European Parliament and of the Council of 24 October 1995 on the protection of individuals with regard to the processing of personal data and on the free movement of such data (the “Directive”).
An identifiable person is someone who can be identified, directly or indirectly, in particular by reference to an identification number or to one or more factors specific to his physical, physiological, mental, economic, cultural or social identity.
“Personal Information” is information that identifies an individual (such as a name, address, telephone number, mobile number, e-mail address, or other account number), and all information about that individual’s location or activities, such as information about his or her use of the Service, IP-addresses or mobile device identifiers, when this can be linked to any Personal Information.
“Personal Information” also includes demographic information such as date of birth, gender, geographic area and preferences when this information can be linked to any other Personal Information.
“Personal Information” does not include “aggregate” information, which is data about a group or category of products, services or users, when this “aggregate” information cannot be linked to any Personal Information. Aggregate data helps us understand trends and our Customers’ needs so that we can better consider new features and functions, or otherwise tailor our Services. These Privacy Terms do not restrict or limit our collection and use of “aggregate” information.
3. When, why and how do we process your data?
A. When you visit and use our Website
When you browse our Website, we process your IP-address, Google Analytics ID, internet browser and device type, location data and your use of our Website, including which pages you visited, how you got to our Website, the time and length of your visit and your language preferences.
We use this data for our legitimate interests being: making sure our Website works properly, can be improved, debugged and optimized (using statistical analyses), delivering you content and for DDOS mitigation on our Website.
We collect this data using cookies and similar techniques, including tags/beacons and java scripts. More information about these techniques can be found in our Cookies Policy.
When we collect information about how you use our Website, such as which landing pages you visit and which items you look at, we do so to decide about how we could best provide our services to you. For example, if you read about our Services on our Website, we might classify you as a user or a Website visitor who is interested in our Services and therefore as a potential customer. Based on the audience we expect you belong to, we may act, for example by contacting you with offers about our products and services, if we have your consent for this.
In order to make the most accurate assessment about which audience you likely belong to, and as you can also read in our Cookies Policy, we also use tracking cookies. These cookies track information about how you use our Website and which other websites you visit, for example to show you advertisements if we suspect that you might be interested in our products and services. We only place these tracking/targeting cookies with your prior consent. For more information about these tracking cookies, please view our Cookies Policy.
How long do we keep this data?
We will keep your data for as long as we reasonably need it for the purposes listed above.
For example, data about your visits to our Website will be retained until your use or browsing session ends, except where it concerns data collected for the analytical and marketing purposes specified above. In those cases, we will keep your information for 1 year after collection.
B. When you are a Customer using our Service(s)
If you register to become a Customers by entering into an agreement with SmartHOTEL, we collect information we need to establish and perform a contract with you, including your contact information, address, ID documentation, tax information and payment details.
We use this information to set up our Services for you, to provide support, onboarding, integration to our Services, helping you with settings in your Customer Area (being: Connect Studio, Payment Studio and Channel Management Extranet), POS terminal field services, installation of POS terminals on location and to pick up old/damaged POS terminals, and other actions which need to be taken to establish or perform our contract with you.
In addition, we use your information for our legitimate interest of managing our internal administration and for complying with our legal obligations, such as KYC (Know Your Customer) and taxation obligations.
We also collect data about your use of our Services and your Customer Area account, including your login details, and the questions, queries, comments and complaints you send us in relation to our business relationship. We process this data to be able to perform our contract with you by following up with you and providing you with support and for our legitimate interest of being able to optimize and improve our products and services.
We can also use your (company) e-mail address for: keeping you up to date with our products and services; making you offers tailored to your needs (meaning similar products and services you have already purchased from us); or inviting you to events.
How long do we keep this data?
If you are or becoming a Customers, we will keep information relating to our business relationship until 7 years after the end of your contract with us or until our rejection of your application to become a Customer.
C. How we process data for our newsletter and marketing purposes
You can sign up for our newsletter or receive invitations to events using your name and e-mail address via the sign-up form on our Website. When you sign up, you indicate your consent to receive our newsletter and invitations. You can at any time unsubscribe from receiving these e-mails by following the instructions provided in the newsletters.
If you are a Customer, we may contact you in relation to relevant Services, for our legitimate interest of developing our business. We can do this via e-mail or, we connect to you on LinkedIN and/or to send you messages on LinkedIN.
If you are not yet a Customer, we will only contact you, for example via e-mail or LinkedIn, with offers or about our Services. When we contact you in this context via e-mail, you always have an opportunity to opt out at any moment by following the instructions in the e-mail or by contacting us using the contact details below under (“Contacting us”).
You can also download content, for example blogs, white papers and research reports, from our Website using the form designed for this purpose. We collect the data you fill out on the form: name, e-mail address and function (e.g. manager). We process the data you fill out for our legitimate interest of keeping track of who downloads our content.
How long do we keep this data?
We store the information that we process because of you describing to our newsletters or because you have consented to receive information about our Services or about offers until you decide you would no longer like to receive these mailings.
D. When you contact us or request us to contact you
Via the Website, you can contact us or ask us to contact you regarding questions, queries, (support) requests, comments or complaints, fill out an application to become a merchant or a partner or sign up for a test account. When you do this, we collect the information that you fill out, including your name, company, contact details, the reason you are contacting us, verification that you are not a robot and other information you decide to provide us. You can also contact us by calling us or e-mailing us using for example the contact details listed on our Website. If you do so, we will collect your name, company and any other information we need to be of further assistance to you and/or communicate with you.
We use this data above to answer your question, comment or complaint and respond to your queries and (support) requests and to assess your application to become a merchant or partner. As such, this data is used by us to establish or perform our (future) contract with you and for our legitimate interests in following up with you. We also use the data above for our legitimate interest of conducting business with you and managing our internal administration, for training purposes, for establishing and performing our contract with you, for our legitimate interest of conducting marketing research so we can improve our products and services and to be able to offer our (future) merchants tailored products and services.
How long do we keep this data?
We will keep your data about any questions, comments or (supports) requests you have made to us, for as long as we reasonably need it for the purposes listed above which will be at least two years.
E. Other purposes
If necessary, we may also process any of your information above for our legitimate interest of protecting our legal rights, for example in connection with legal claims, and when we have a legal obligation to process your information. In the case of a reorganization, change in ownership, or merger, we may transfer your data as well.
4. How long do we keep your information?
We will keep your data for as long as reasonably needed for the purposes defined above.
The retention terms defined above may be longer if we are required to keep data longer based on applicable law or to administer our business. If we need to keep any information longer for our legitimate interest of protecting our legal rights, we will keep the necessary information for this purpose until the relevant claim(s) has/have been settled.
5. Social media buttons
We use plugins on our Website from social media networks such as LinkedIN and Twitter. You can recognize these plugins by their logos.
We do not have any influence over which data these providers collect from you, and we are also not aware of the extent of their data processing. If you would like more information about their data processing, we recommend that you review the respective privacy policies on the websites of these providers.
6. Cookies
We use cookies and similar techniques, such as tags/beacons and java scripts, which are small text files stored on your device. Cookies enable us to recognize people and Customers who have previously visited the Website. Furthermore, Cookies allow us, in conjunction with our web server’s log files, to calculate the aggregate number of people visiting our Website and which parts are most popular. This helps us gather feedback to improve our Website and better serve you.
Cookies do not allow us to gather any Personal Information about you and we do not intentionally store any Personal Information that your browser provided us in your Cookies.
If you wish to block, erase, or be warned of cookies, please refer to your browser or mobile device’s instructions or help screen to learn about these functions. However, if a browser or mobile device is set not to accept cookies or if you reject a cookie, some portions of the Website and Service may not function properly. For example, you may not be able to sign in and may not be able to access certain Website features or Service.
You may find out more specific information about our use of cookies and web beacons at our Cookie Policy. You can find out more information about how to change your browser cookie settings at www.allaboutcookies.org.
We may also use third parties to serve ads on our Website. These third parties may place cookies, clear gifs or other devices on your computer to collect information, and information provided by these devices may be used, among other things, to deliver advertising targeted to your interests and to better understand the usage and visitation of our Website and the other site Websites tracked by these third parties. If you wish to not have this information used for the purpose of serving you targeted ads, you may opt-out by clicking here www.youronlinechoices.eu. Please note this does not opt you out of being served advertising. You will continue to receive generic ads. Please note that we have no access or control of any third-party tracking technologies. If you wish to block third party cookies, please refer to your browser instructions or help screen to learn about these functions.
7. With whom do we share this information?
To provide the Website and Services we need to engage the help of third parties. Where necessary we will share your information with our service providers and professional advisers (e.g. IT providers, KYC partners, CRM providers, social media providers such as LinkedIN, analysts, customer service providers, business development providers and legal service providers). We have concluded agreements with our service providers to protect your personal data.
If our company or business is sold or integrated with another business, your details will be disclosed to our advisers and any prospective purchaser’s adviser and will be passed to the new owners of the business.
Otherwise we will not share your information with any third party, unless we have your prior permission, where this is necessary in connection with the purposes above or with legal claims or when we have a legal obligation to do so.
8. How do we protect your data?
SmartHOTEL shall ensure it implements and maintains compliance with appropriate technical and organizational security measures for the processing of Personal Information. We follow generally accepted standards to protect the Personal Information submitted to us, both during transmission and once we receive it.
We have put in place physical, electronic, and managerial procedures that are designed to prevent unauthorized access, loss, or misuse.
We use TLS (Transport Layer Security) technology to encrypt your transmission of sensitive information to us, such as account passwords, credit card numbers and other payment-related identifiable information).
We restrict internal access to Personal Information to employees who need the information to perform their duties. The unauthorized access or use of such information by an employee is prohibited and constitutes grounds for disciplinary action.
Our information management systems are configured in such a way as to block or inhibit employees from accessing information that they have no authority to access.
You should note that our processors may be responsible for processing, handling or storing some of the Personal Information that we receive. They are not authorized to market to you independently. These processors are contractually by means of a data processing agreement with SmartHOTEL required to safeguard and secure the Personal Information they received from us.
No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security.
9. Your Rights
You are entitled to object to us processing your personal data, including profiling. You may ask us for an overview of your information and ask for a copy. You may request us to correct or delete certain data, restrict processing of your data, or ask us to transfer some of this information to other organizations. In some cases, you may object to the processing of your data and, where we have asked for your consent to process personal data, you can withdraw this consent at any time. Where we process your data for our legitimate interests, you can contact us if you want more information about these.
However, there are some exceptions to these rights. For example, we will not be able to delete your data if we are required by law to keep it or if we hold it in connection with a contract with you. Similarly, access to your data may be refused if making the information available would reveal personal information about another person or if we are legally prevented from disclosing such information.
If you wish to exercise any of these rights, please contact us using the details below.
10. Contacting us, questions and complaints
Questions, comments, requests, concerns or complaints concerning this privacy statement and/or the way SmartHOTEL processes your personal data can be addressed to: privacy@smarthotel.nl.
