Personal Data Policy
Who manages the personal data of the guests who stay at the Hotel?
Willa Lubicz Ltd manages the data of the Hotel’s guests. Full name of legal entity: Willa Lubicz Spółka z ograniczoną odpowiedzialnością (Willa Lubicz Ltd.) Company number: 0000129621 (registered in VIII Wydział Gospodarczy KRS in Gdańsk). Postal address: 43 Orłowska Street, 81-522 Gdynia, Poland
Who is the Hotel’s Data Privacy Manager and how can they be contacted?
Willa Lubicz Ltd. chose not to appoint a Data Privacy Manager, but the Hotel Manager, Mrs Małgorzata Jarosz-Misiejko, is the appointed representative who can be contacted about all data privacy matters on: email@example.com, or +48 58 668-47-40 or by post on: ul. Orłowska 43, 81-522 Gdynia, Poland.
For what purpose does the Hotel collect personal data?
The main reason for collecting personal data by the Hotel is the creation and realisation of the contract for the provision of hotel services. Additionally, the Hotel collects personal data for the following reasons:
- in case the Hotel is forced to seek damage claims against a guest, or in case a guests makes legal claims against the Hotel,
- to document the realisation of services for taxation reasons,
- to provide the highest quality of services to the Hotel guests.
When a Hotel guest has agreed to have their data processed for marketing purposes, the Hotel will only use the guest’s data for that purpose, i.e. to deliver marketing information and offers generated by the Hotel about their own products and services.
Additionally, the Hotel processes personal data gathered via the Hotel CCTV monitoring system to ensure the safety of the Hotel guests, staff and other persons who find themselves on the Hotel premises.
What is the legal basis for the processing of personal data?
The contract for the provision of hotel services is the legal basis for the processing of personal data by the Hotel.
The legal basis for the processing of personal data for marketing purposes is a guest’s agreement for their data to be processed this way. This can be withdrawn at any time. The cancellation of this agreement does not affect personal data that has already been processed.
The legal basis for the processing of personal data via the Hotel’s CCTV monitoring system is the protection of the vital interests of the guests and other persons on the premises, as well as justified purposes of the administrator.
The legal basis for the processing of personal data of the Hotel’s guests for the purpose of providing the highest quality hotel service is the administrator’s justified purpose.
Who can access the personal records held by the Hotel?
The Hotel shares its data with the following categories of entities:
- IT companies that deliver IT services and software to the Hotel,
- accounting firm that manage the Hotel’s books,
- transportation and taxi services if a guest requests a courier delivery or a ride,
- legal firm that provide advisory and representation services to the Hotel.
How long will the personal data be held/processed?
Personal data that has been:
- acquired via the contract for the provision of hotel services will be processed for the length of time equivalent to the limitation of tax claims or legal claims brought in by the Hotel or by the guest, depending on which of those happens at a later date,
- acquired via the agreement to the processing of personal data for marketing purposes, will be held for the length of time specified therein,
- acquired via the Hotel CCTV monitoring system will be processed for the period of 7 days from the date of the recording, at the end of which it will be permanently deleted.
What rights does the guest have to the processed personal data?
Every guest has the right to correct, remove or limit the personal data submitted to the Hotel. Additionally, every guest has the right to protest against the processing of their personal data. Access to personal data will be made possible on Hotel premises if needed. Guests can also email firstname.lastname@example.org for additional information about personal data.
Is it possible to complain about how personal data has been handled by the Hotel?
Yes, every guest has the right to complain to the supervising body, in this case to the Urząd Ochrony Danych Osobowych (the Office for Personal Data Protection), who can be contacted on this postal address: ul. Stawki 2, 00-193 Warszawa, Poland.
Will the Hotel pass personal data on to entities that aren’t based within the EEA?
No. The Hotel has no intention of passing personal data on to entities based beyond the EEA.
Is the submission of personal data a legal or contractual requirement?
Submitting the first and last name as well as the guests’ address of residence is a contractual requirement — without this data the Hotel cannot enter into a contract for the provision of hotel services with a guest.
Is the personal data submitted to the Hotel subject to any automatic decisions, such as marketing profiling?
No. the Hotel does not automate any of its decisions about how to process personal data, and it does not do client profiling.