We offer our products and services globally, as such, we are committed to comply with local and international data privacy legislation, including the Protection of Personal Information Act and the General Data Privacy Regulations (“GDPR”).
Who is collecting your information
Any personal information provided to or collected by us is controlled by us, Babylonstoren Proprietary Limited (South Africa).
For those in the European Economic Area and the UK, Babylonstoren UK Limited may also be the data controller for personal data.
Information we collect
We collect and receive information about you in the following ways:
Information you give us
This includes any information that you provide to us directly, whether in person or through our Platforms, via phone, text messages, social media, fax or any other medium, this may include information you give to us:
- by filling in forms on our Platforms (like when you register on our Platforms or subscribe to use services on our Platforms) or when you visit our premises (like when you eat or stay with us, or come to our spa);
- when you enter a competition, promotion or complete a survey;
- by posting comments or content on our Platforms;
- when you purchase one of our Services;
- when you contact us and when you otherwise provide information directly to us.
Information we collect or receive when you use our Platforms:
We collect information when you use our Platforms or Services, or buy products from us by using cookies, web beacons and other technologies. Depending on how you access and use our Platforms, we may receive:
- Log information (for example information about your interactions with our Platforms and other services you use, the content you view and the search queries you submit);
- Information we infer about you based on your interaction with our products and services;
- Device information (for example the type of device you're using, how you access our Platforms, your browser or operating system and your Internet Protocol ("IP") address);
- Information collected using Google Analytics (as detailed below).
Information from third-party sources
We may receive additional information about you that is publicly available or that you have consented to being shared with us and combine that with the information we have collected or received about you in other ways. We may also receive information about you when you choose to connect with social networking services while using our Platforms.
How we use the information we collect and receive
We collect, store and use the personal information in order to:
- provide Services to you;
- enable you to create a personal profile on our Platforms;
- enable you to make use of our Platforms or Services in the manner described on our Platforms, from time to time;
- enable us to create a personal profile of you and make relevant recommendations on a personalised basis, which may include tailoring our Services and Platforms to your interests and needs, and ensure they work on your device;
- communicate with you;
- send you information, advertising or newsletter about our Services or the Services of other companies in our group;
- to provide effective advertising, which may include linking your information with that of a third party (for example, to provide you with news, special offers and general information about other goods, services and events which we offer, that are similar to those that you have already used or enquired about). Also refer to “How we share the information we collect section below;
- compile and maintain our Platforms and client database;
- register and/or authenticate users of and/or visitors to our Platforms or premises;
- identify and take reasonable measures to prevent fraudulent use of or access to our Platforms;
- compile non-personal statistical information about browsing habits, click patterns and access to our Platforms;
- attract suppliers by showing de-identified information about the database, for example demographics;
- track client database size and growth;
- to process your payments;
- to assess and handle any complaints;
- to develop and improve our Services, communication methods and the functionality of our Platforms;
- comply with any contractual obligations we have in respect of the provision of information or Services to you; and
- to manage communication, customer profile and customer feedback. We may publish feedback (comments or reviews) provided by you via our Platforms or otherwise on our social media accounts or in other promotional material or brochures.
How we share the information we collect and receive
We may share information with:
- Companies in our group, in other words, our holding company, subsidiaries, or sister companies;
- affiliated companies (for instance other hotel groups around the world that we affiliate with);
- Our local agents, listed below;
- Business partners. We may share non-personally identifiable information with select business partners. This means that we do not disclose information about identifiable individuals to our business partners, but we may provide them with aggregate information about our users;
- Other parties in response to legal process or when necessary to conduct or protect our Platforms. We may disclose your information if we are under a duty to disclose or share your information in order to comply with any legal obligation or to protect our Platforms. We may also disclose your information during the process of debt collection, or to our attorneys in connection with any potential, threatened or actual litigation, or to our auditors for the purpose of auditing our accounts;
- Other parties in connection with certain business transactions. In the event that we restructure or sell any of our businesses or assets, we may disclose your personal information to the prospective buyer of such business or assets or other transacting party;
- Companies that provide services to us. Companies that provide services to us or act on our behalf may have access to information about you. These companies are limited in their ability to use information they receive in the course of providing services to us or you;
- Third-parties where you provided consent. We may share information with third-parties where you provide consent in the form of explicit opt-in. Such circumstances may include (but are not limited to) an entry into a competition sponsored by a third-party where the provision of your information is a condition for entry to the competition, or where you 1. express your interest in a product or service for which you would like more information;
- Other parties that provide content, advertising services, or functionality on our Platforms. Some of the content, advertising, and functionality on our Platforms may be provided by third parties that are not affiliated with us. Such third parties include:
- advertising providers, which help us provide ads that are tailored to users' interests and understand how users respond to those ads;
- Audience-measurement companies, which help us measure the overall usage of our Platforms and compare that usage to other online services; and
- Social networking services (like Facebook, Twitter, LinkedIn, Instagram) that enable you to register and log into certain of our services and to share things you find on our Platforms with your social network. This is only applicable if you choose to connect with a social networking service; we may provide other registration and login methods.
These parties may be situated in a different country to you. You agree that your information may be shared with any of the abovementioned parties in another country and you consent to the cross border transfer of your information to another country, whose privacy laws may not be equivalent to the laws in your country of residence.
You have the right to ask us not to contact you for marketing purposes. You can exercise this right at any time by using any of the various "opt-out" options that we will always provide to you when we communicate with you.
You have various rights over how your personal information is processed and can exercise these rights at any time by sending an email to [email protected].
Your rights are:
- you have the right to be provided with clear, transparent and easily understandable information about how we use your personal information;
- you have the right to access, correct or update your personal information at any time;
- under certain circumstances, you have right to request that we delete your data. If you wish to delete the personal information we hold about you, please let us know and we will take reasonable steps to respond to your request in accordance with legal requirements.
- under certain circumstances, you have the right to restrict the processing of your personal information;
- under certain circumstances, you have the right to object to certain types of processing, including processing for direct marketing;
- you have the right to lodge a complaint about how we process your personal information directly with any local data privacy authority. In South Africa, you can lodge a complaint with the Information Regulator at [email protected];
- if you have given your consent for us to use your personal information, you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your personal information with your consent up to that point is unlawful);
- you have the right not to be subject to a decision which is based solely on automated processing and which produces legal or other significant effects on you;
Further information and advice about your rights can be obtained from the data protection regulator in your country.
If the personal information we collect is no longer needed for any purposes and we are not required by law to retain it, we will do what we can to delete, destroy or permanently de-identify it.
When you provide consent to be tracked while visiting our Platforms, we may collect information using Google Analytics Advertising Features. These features enable us to enhance our understanding of user behavior and provide personalized advertising and recommendations. The Google Analytics Advertising Features used include:
- Remarketing with Google Analytics
- Google Display Network Impression Reporting
- Google Analytics Demographics and Interest Reporting
- Integrated services that require Google Analytics to collect data for advertising purposes, including the collection of data via advertising cookies and identifiers
By enabling Google Analytics Advertising Features, we allow Google Analytics to collect data about your visit using Google advertising cookies and identifiers, in addition to the data collected through our standard analytics implementation.
To comply with our obligations, we ensure the following:
- We do not identify individual users or facilitate the merging of personally identifiable information with additional information collected through any Google advertising product or feature unless we have robust notice and the user's prior affirmative consent (opt-in) for such identification or merging, and we are using a Google Analytics feature that explicitly supports it.
- We do not attempt to disaggregate data that Google reports in aggregate, regardless of user consent.
To learn more about personally identifiable information (PII) and how it is handled, we recommend reviewing Google's contracts and policies.
We also encourage you to view Google Analytics' currently available opt-outs for the web.
Both the company and third-party vendors use first-party cookies (like Google Analytics cookies) and other identifiers set by the company's platforms, as well as third-party cookies (like Google advertising cookies) and other identifiers set by external parties, for purposes such as improving the services, personalizing content, displaying targeted advertising, and analyzing user behavior.
To exercise opt-out of Google Advertising Features:
- Ads Settings: Visitors can opt-out of Google Analytics Advertising Features by accessing their Ads Settings. The Ads Settings allow users to manage their ad preferences and control the types of ads they see across Google's advertising network. By adjusting the settings, visitors can choose to opt-out of personalized advertising.
- Ad Settings for mobile apps: For mobile app users, there are specific Ad Settings available within mobile apps. These settings provide options to control personalized advertising within the app and opt-out if desired. Visitors can access these settings within the app itself.
- Other available means: In addition to Ads Settings, there are other means available for opting out of Google Analytics Advertising Features, like the NAI's (Network Advertising Initiative) consumer opt-out. The NAI provides a platform where users can opt-out of targeted advertising by participating companies.
Our commitment to security
Although no one can guarantee the security of the information collected and received, we do employ a number of safeguards intended to mitigate the risk of unauthorized access or disclosure of your information. We will do our best to protect your personal information and we will use up to date technology that will help us to do this.
Links to other websites
Our Platforms contain links to and from websites, mobile applications or services of third parties, advertisers or affiliates. Please note that we are not responsible for the privacy practices of such other parties and advise you to read the privacy statements of each website you visit which collects personal information.
Babylonstoren is based in and operates from South Africa, and, regardless of where you use or access our Platforms, products, or services, your information may be transferred to and maintained on servers located in South Africa (or elsewhere in the world). Please note that any information we obtain about you will be stored in accordance with South African privacy laws, regulations and standards, which may not be equivalent to the laws in your country of residence. By using our Platforms, you consent to this collection, transfer, storage and processing of information to and in South Africa.
If you have a privacy concern, complaint or question, please contact us at [email protected].