LAST UPDATED: September 14, 2021
The Company is the controller and is responsible for your Personal Information.
Full name of legal entity:
Email address: firstname.lastname@example.org
Zola – Palais de bohème
Vorgartenstraße 217, 1020
Tel: +43 (1) 8900870
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk) Opens in New Window. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please do contact us in the first instance at email@example.com.
“Personal Information” is information that identifies you as an individual or relates to an identifiable person, including:
Identity Data which includes: first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
Contact Data which includes billing address, delivery address, email address and telephone numbers.
Financial Data which includes bank account and payment card details.
Transaction Data which includes details about payments to and from you and other details of products and services you have purchased from us.
Technical Data which includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our Services.
Profile Data which includes your username and password, profile picture, reservations, purchases or orders made by you, your interests, preferences, feedback and survey responses.
Usage Data which includes information about how you use our Websites, products and Services (as defined below).
Marketing and Communications Data which includes your preferences in receiving marketing from us and our third parties and your communication preferences.
Information collected through the use of key card and other security systems.
We may also disclose your Personal Information to a third party when you ask us to do so or when we believe it is required by law.
How We Collect Personal Information
We and our third party service providers may collect Personal Information in a variety of ways, including:
Through the Services: we may collect Personal Information through the Services, such as when you sign up for our Wi-Fi, sign-up or opt-in as a subscriber to Zola Culture or make a purchase or booking.
From Other Sources: we may receive your Personal Information from other sources, such as public databases; joint marketing partners; online travel/restaurant companies; booking engines; social media platforms; people with whom you are friends or otherwise connected on social media platforms; and other third parties. For example, if you choose to connect your social media account to your Website account, certain Personal Information from your social media account will be shared with us, and it may include Personal Information that is part of your profile or your friends’ profiles.
How We Use Personal Information
We will only use or disclose your Personal Information when the law allows us to. Most commonly, we use or disclose your Personal Information in the following circumstances:
where we need to perform the contract we are about to enter into or have entered into with you;
where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; or where we need to comply with a legal or regulatory obligation. Generally we do not rely on consent as a legal basis for processing your Personal Information, other than in relation to sending direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us at firstname.lastname@example.org. Please note that if, in the event we rely on your consent to process your Personal Information, you withdraw your consent we may no longer be able to provide you with: (a) updates and promotions; (b) the best user experience possible to our Services; (c) the best customer experience.
We have set out below a description of all the ways in which we plan to use your Personal Information:
to respond to your inquiries and fulfill your requests, such as to send you the Zola newsletter and other marketing materials;
to send administrative information to you, such as information regarding the Services and changes to our terms, conditions and policies; to complete and fulfill your booking or other purchase, including, for example, to process your payment, communicate with you regarding your purchase and provide you with related customer service; to send you marketing communications that we believe may be of interest to you; to contact you with respect to any membership and/or billing inquires; to personalize your experience on the Services by presenting products and offers tailored to you; to allow you to participate in sweepstakes, contests and similar promotions and to administer these activities. Some of these activities have additional rules, which could contain additional information about how we use and disclose your Personal Information, so we suggest that you read such rules carefully.
to facilitate social sharing functionality; to allow you to send messages to a friend through the Services. By using this functionality, you are telling us that you are authorized to use and provide us with your friend’s name and email address; for our business purposes, such as data analysis; market research; surveys; customer satisfaction; audits; fraud monitoring and prevention; developing new products and services; enhancing, improving or modifying our Services; identifying usage trends; determining the effectiveness of our promotional campaigns and operating and expanding our business activities; and as we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.
How We Disclose Your Personal Information
to our third party service providers who provide services such as website hosting, data analysis, data analytics, payment processing, information technology and related infrastructure provision, customer service, email delivery, auditing and other services. For example, we may use Google Analytics and others to provide analytics; to non-affiliated third parties, to permit them to send you marketing communications, if you have opted-in to such sharing; to third-party sponsors of sweepstakes, contests and similar promotions; to identify you to anyone to whom you send messages through the Services; by you, on message boards, chat, profile pages, blogs and other services to which you are able to post information and materials. Please note that any information you post or disclose through these services will become public and may be available to other users of the Services and to the general public. We urge you to be very careful when deciding to disclose your Personal Information, or any other information, on the Services;
to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings); and as we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.
Other Information We May Collect
“Other Information” is any information that does not reveal your specific identity or does not directly relate to an individual, such as:
Browser and device information; App usage data; Information collected through cookies, pixel tags and other technologies; Demographic information and other information provided by you; and aggregated information.
How We May Collect Other Information / Online Tracking
We may collect Other Information in a variety of ways, including: Through your browser or device: Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version and the name and version of the Services (such as the App) you are using. We use this information to ensure that the Services function properly. Through your use of the App: When you download and use the App, we may track and collect App usage data, such as the date and time the App on your device accesses our servers and what information and files have been downloaded to the App based on your device number.
Using pixel tags and other similar technologies: We may use pixel tags (also known as web beacons and clear GIFs) in connection with the Services to, among other things, track the actions of users of the Services (including email recipients), measure the success of our marketing campaigns and compile statistics about usage of the Services and response rates.
Using Adobe Flash technology (including Flash Local Shared Objects (“Flash LSOs”)) and other similar technologies: We may use Flash LSOs and other technologies to, among other things, collect and store information about your use of the Services. If you do not want Flash LSOs stored on your computer, you can adjust the settings of your Flash player to block Flash LSO storage using the tools contained in the Website Storage Settings Panel. You can also control Flash LSOs by going to the Global Storage Settings Panel and following the instructions (which may include instructions that explain, for example, how to delete existing Flash LSOs (referred to as “information” on the Macromedia site), how to prevent Flash LSOs from being placed on your computer without your being asked, and (for Flash Player 8 and later) how to block Flash LSOs that are not being delivered by the operator of the page you are on at the time). Please note that setting the Flash Player to restrict or limit acceptance of Flash LSOs may reduce or impede the functionality of some Flash applications, including, potentially, Flash applications used in connection with the Services or our online content.
IP Address: Your “IP Address” is a number that is automatically assigned to your computer by your Internet Service Provider. An IP Address may be identified and logged automatically in our server log files whenever a user accesses the Services, along with the time of the visit and the page(s) visited. Collecting IP Addresses is standard practice and is done automatically by many websites, applications and other services. We use IP Addresses for purposes such as calculating usage levels, helping diagnose server problems and administering the Services.
Physical Location: We may collect the physical location of your device by, for example, using satellite, cell phone tower or WiFi signals. We may use your device’s physical location to provide you with personalized location-based services and content.
From you: Information, such as your gender or preferred means of communication, is collected when you voluntarily provide it. Unless combined with Personal Information, this information does not personally identify you.
By aggregating information: We may aggregate users’ Personal Information (for example, we may calculate the percentage of our users who have a particular telephone area code). Aggregated Personal Information does not personally identify you or any other user of the Services.
How We May Use and Disclose other information
We may use and disclose other information for any purpose, except where we are required to do otherwise under applicable law. If we are required to treat other information as Personal Information under applicable law, then we may use it for all the purposes for which we use and disclose Personal Information.
We may combine other information with Personal Information. If we do, we will treat the combined information as Personal Information as long as it is combined.
THIRD PARTY SERVICES
We seek to use appropriate organizational, technical and administrative measures to protect Personal Information within our organization, including: (a) the pseudonymization and encryption of your personal information where appropriate; (b) ensuring ongoing confidentiality, integrity, availability and resilience of processing systems and services; (c) ensuring we can restore access to personal information in a timely manner if a physical or technical incident occurs; and (d) regular testing, assessment and evaluation of the effectiveness of our technical and organizational measures to ensure your personal information is secure. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure and we cannot ensure the security of the information that you transmit. If you have reason to believe that your interaction with us is no longer secure, please immediately contact us in accordance with the “Contacting Us” section.
CHOICES AND ACCESS
Your choices regarding our use of your Personal Information
You may opt out from receiving electronic communications from us. If you no longer want to receive marketing-related emails from us on a going-forward basis, you may opt out of receiving them by following the instructions contained in each such message.
We will try to comply with your request as soon as reasonably practicable. If you opt-out, we may still send you important administrative messages, from which you cannot opt-out.
How you can access, change or suppress your Personal Information
If you would like to review, correct, update, suppress or delete Personal Information that you have provided to us, contact us at the address below. In your request, please make clear what Personal Information you would like to have changed, whether you would like to have the Personal Information you have provided to us suppressed from our database, or otherwise let us know what limitations you would like to put on our use of the Personal Information you have provided us. For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable.
Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting such change or deletion. There may also be residual information that will remain within our databases and other records and which will not be removed.
We will retain your Personal Information for the period necessary to provide the Services. Processing is therefore necessary for the purposes of our legitimate interest, unless a longer retention period is required or permitted by law.
USE OF SERVICES BY MINORS
The Services are not directed to individuals under the age of thirteen (13), and we request that these individuals do not provide Personal Information through the Services.
We are committed to complying with applicable laws, regulations and mandatory government standards regarding the protection of Personal Information.
If we transfer your Personal Information out of your jurisdiction, we will implement suitable safeguards or rely on legally-provided mechanisms to lawfully transfer data across borders to ensure that your Personal Information is protected.
YOUR LEGAL RIGHTS
You have rights under data protection laws in relation to your Personal Information: You have the right to:
Request access to your Personal Information (commonly known as a “data subject access request”). This enables you to receive a copy of the Personal Information we hold about you and to check that we are lawfully processing it.
Request correction of the Personal Information 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 Information. This enables you to ask us to delete or remove Personal Information 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 Information 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 Information 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 Information 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 Information 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 Information. This enables you to ask us to suspend the processing of your Personal Information 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 Information to you or to a third party. We will provide to you, or a third party you have chosen, your Personal Information 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 Information. 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.
In respect of exercising your rights, please note:
No fee usually required.
You will not have to pay a fee to access your Personal Information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Information (or to exercise any of your other rights). This is a security measure to ensure that Personal Information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
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.
We ask that you not send us, and you not disclose, any sensitive Personal Information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Services or otherwise to us.