This is the Privacy Notice to Guests (hereinafter the “Notice”) by “AVANT APARTMENTS AT THE FORT”, 26 Street 3 Avenue, Bonifacio Global City, Taguig. We are dedicated to protecting your privacy and safeguarding your personally identifiable information (hereinafter “Personal Data”) whether you are making a reservation or you come as a client from a booking engine. We strive to create an experience that is responsive to our Guests' needs by using the Personal Data you entrust us with responsibly. Our property is committed to respecting your privacy and adhering to the principles of applicable data protection and privacy laws. This Notice contains information in accordance with Article 13 of the General Data Protection Regulation (Regulation EU 2016/679 – GDPR), regarding the processing of your Personal Data as a Guest by Avant Apartments At The Fort as Data Controller.
2. WHAT PERSONAL DATA WE COLLECT IN RELATION TO YOU
We collect and use your Personal Data when you make a reservation or if you stay at a property we manage (hereinafter a “Property”). We generally collect your Personal Data directly from you, but in some cases we may collect your Personal Data from other sources. We do not generally collect Special Categories of personal data, unless it is volunteered by you or unless we are required to do so pursuant to applicable laws or regulations. We may use health data provided by you to serve you better and meet your particular needs and special requests or those of your companions.
Types of Personal Data which we collect include among others the following:
If you make a reservation:
Your full name, home, professional and e-mail addresses, telephone number, lifestyle information such as room preferences and other information necessary to fulfill special occasions and special requests.
During your stay at a Property:
Your full name, email address, ID and Passport numbers, nationality, date of birth, gender. Details of your stay, such as arrival and departure dates, type of room, room preference, full names, dates of birth and passport numbers of companions, specific requests to the Hotel (e.g. health conditions that require special room accommodations). Information on your bookings, booking reference. Details of complaints and other remarks you may have.
Reviews/feedback in relation to our services provided during your stay, post photos, quotes.
Other sources of Personal Data
In some cases we will receive your Personal Data from other sources such as:
A travel agent, a booking engine or tour operator when you make a reservation through them.
3. PURPOSES FOR COLLECTION AND PROCESSING
We collect and process your Personal Data for the following purposes:
Performing a contract or transaction such as making a reservation and handling your stay at a Property, by providing the products and services you requested, fulfilling your special requests; Better understanding your interests and preferences and offering you a unique experience during your stay; To comply with obligations imposed by law or regulations such as the tax authorities or the police; Handling your remarks, complaints, incidents, illnesses, accidents and claims during your stay or after your departure; For marketing reasons/communications with you in relation to the products and services offered To make contact or interact with you, to conduct financial data evaluation/statistical analysis based on demographics, reservation, your stay or other data/market research and for your registration to our loyal membership program.
4. LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA
We are committed to collecting and processing your Personal Data in accordance with applicable data protection laws. We will only process your Personal Data if at least one of the following conditions applies:
You have given your consent to the processing of your Personal Data for one or more specific purposes e.g. for marketing purposes and subscribing to receive newsletters; Processing is necessary for the performance of a contract with you or in order to take steps at your request prior to entering into a contract e.g. to make a reservation and provide the products and services you request; Processing is necessary for compliance with a legal obligation to which Avant Apartments At the Fort is subject e.g. sharing your Personal Data with regulatory authorities; Processing is necessary in order to protect your vital interests or those of another natural person e.g. in an emergency, an incident, illness or accident; Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority; Processing is necessary for the purposes of the legitimate interests pursued by Avant Apartments At The Fort by a third party, except where such interests are overridden by your interests or fundamental rights and freedoms which require protection of Personal Data, e.g. when it is necessary to protect our property or establish, exercise or defend legal claims.
As part of our commitment to keep you informed, we may mail, e-mail, contact you by other means to inform you about news and services or other relevant information that may be of interest to you. You will not ever receive mailings or other communications from third parties. We always offer you the option to decline any or all of these communications by following the directions included in our e- mails or by contacting us directly to [email protected] Avant Apartments At The Fort includes, in any case, provisions for: Determining what disclosures are made in order to obtain valid consent. Ensuring the request for consent is presented in a manner which is clearly distinguishable from any other matters, is made in an intelligible and easily accessible form, and uses clear and plain language. Ensuring the consent is freely given (i.e. is not based on a contract that is conditional on the processing of Personal Data that is unnecessary for the performance of that contract). Documenting the date, method and content of the disclosures made, as well as the validity, scope, and volition of the consents given. Providing a simple method for a data subject to withdraw their consent at any time.
5. WHO MIGHT WE SHARE YOUR PERSONAL DATA WITH?
We apply strict security rules regarding the processing of Personal Data and third parties’ access to our records and files. We do not share your Personal Data except when It is necessary to fulfill an obligation imposed by law.
6. SECURITY SAFEGUARDS
Avant Apartments At The Fort recognizes the importance of information security and is constantly reviewing and enhancing our technical, physical, and logical security rules and procedures. Our website and servers have security measures in place to help protect your personally identifiable information against loss, misuse, and alteration while under our control. Although "guaranteed security" does not exist either on or off the Internet, we safeguard your information using both procedural and technical safeguards, including password controls, "firewalls" and encryption methods.
7. DATA RETENTION PERIOD
Avant Apartments At The Fort is committed not to retain Personal Data for a period longer than necessary for the reasons that the Personal Data was obtained and/or to meet legal and regulatory requirements. After this period, we will erase Personal Data. However, if Personal Data is needed after this period for statistical/analytical/historical/legitimate business purposes, we will take appropriate measures to anonymise this data.
8. YOUR RIGHTS UNDER EU DATA PROTECTION LAWS
In this section we address the rights deriving from Regulation (EU) 2016/679 and how these rights can be exercised by you.
8.1 Your Right of Access or Rectification Avant Apartments At The Fort assumes that Personal Data collected directly from you will be accurate and complete. You have the right to ask for a copy of your Personal Data we hold about you. If you want to exercise your right of access or rectification, you may use the Data Subject Request Form – Registration Form.
8.2 Your Right to Erasure
You may request that any Personal Data held about you be deleted or removed, and, in such case, any third parties who process or use that data must also comply with such request. An erasure request can only be refused if an exemption applies. If you want to exercise your right of access or rectification, you may use the Data Subject Request Form – Registration form.
We are obligated to erase Personal Data where one of the following applies:
Personal Data is no longer necessary in relation to the purposes for which they were collected or otherwise processed; You withdraw consent and no other legal basis for processing exists; You object to the processing carried out on the grounds our legitimate interests and there are no other overriding legitimate grounds for the processing; the Personal Data has been unlawfully processed. If we cannot actually delete Personal Data, we ensure that it: is not able, or will not attempt, to use the Personal Data to inform any decision in respect of any individual or in a manner that affects the individual in any way; does not give any other organization access to the Personal Data; protects the Personal Data with appropriate technical and organizational security; and commits to permanent deletion of the information if, or when, this becomes possible.
8.3 Your Right to Restrict Processing
You have the right to restrict us from processing Personal Data.
8.4 Your Right to Object
You have the right to object at any time to processing of your Personal Data by using the Data Subject Request Form.
8.5 Your Right to Data Portability
Upon request and provided that the relevant requirements stipulated in Article 20 of GDPR are met, you have the right to receive a copy of your Personal Data in a structured format using the Data Subject Request Form.
How to make a complaint
If you are not satisfied with the way in which your Personal Data has been processed, please submit your complaint or request/objection in one of the manners set out below in the Contact us section or to email address [email protected]
Please note that we may ask you to verify your identify before we can act on your request or complaint. We may ask you for more information to ensure that you are authorized to make such a request or complaint when you contact us on behalf of another data subject. If you are dissatisfied with our response to your complaint or request, you may lodge a complaint with the competent data protection authority.
9. CONTACT US
If you would like to update your information, modify your communication preferences and submit any request or objection or if you do not want to receive marketing communications from Avant Apartments At The Fort in the future, you can contact us: By e-mail: [email protected] or by telephone: 0063 97762 96264 by writing to us at: Avant Apartments At The Fort 26 Street 3 Avenue Bonifacio Global City Taguig 1634 Metro Manila Philippines
Updates to the Privacy Notice
Avant Apartments At The Fort may amend this Privacy Notice from time to time in order to meet changes in the regulatory environment. Updated versions will be posted to our web site and date stamped so that you are always aware of when the Privacy Notice was last updated.
Last update: April 2022
10. KEY TERMS
“Personal Data" means any information relating to an identified or identifiable natural person
(“Data Subject"); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
“Special categories of personal data” means the Personal Data referring to racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data, data concerning health or data concerning sex life or sexual orientation.
“Processing" means any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, use, disclosure, alignment, restriction, erasure.
“Consent" of the data subject means any freely given, specific, informed and unambiguous indication of the data subject's wishes by which he/she, by a statement or by a clear affirmative action, signifies agreement to the processing of Personal Data relating to him or her.
“Data Controller" means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data.
“Data Processor" means a natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Data Controller.
“European Economic Area (“EEA”)”: EU Member States plus Norway, Iceland and Lichtenstein.