PRIVACY POLICY OF CHICLAND HOTEL

1.PURPOSE OF COLLECTION OF PERSONAL INFORMATION

WHY WE COLLECT PERSONAL INFORMATION

Please note that the collection of Personal Information is based on the guest’s consent. Guests are required to consent to the collection and processing of their Personal Information for Chicland Hotel to provide its services.

PURPOSE	DESCRIPTION OF ACTIVITIES ASSOCIATED WITH THE PURPOSES	LEGAL BASIS (WHERE APPLICABLE)
Reservations & Guest Registration Information	There are several activities associated with these purposes, including facilitating hotel reservations and bookings and related services; providing pre-arrival communications (logistics, modifications, preferences, etc.); and processing payments and security deposits.	Performance of a contract with the individual making the reservation. Legitimate interests of the individual making the reservation, such as honoring the guest's preferences, as well as those of any individuals accompanying the primary guest (for example, a spouse, children, or friends). Legal obligations related to financial transactions, such as maintaining accounting books and records.
On-Property Guest Services & Stay Experience	There are a number of activities associated with these purposes, including facilitating check-in and check-out; processing payments; providing consistent and personalized services and recommendations regarding on-property offerings (based on prior stay history or stated preferences); providing bell services, luggage storage, and parking; arranging appointments with third-party service providers on behalf of guests (such as coordinating tours and other excursions; arranging taxi services, shuttle services, and private drivers; and facilitating reservations and bookings at restaurants and events); managing and enabling access to Wi-Fi, television, and other connectivity services (including access to business center amenities); facilitating in-room dining services (including any dietary restrictions or other personal needs communicated by the guest); providing housekeeping services (including housekeeping frequency, special pillow or bedding preferences, and other amenities requested by the guest) and laundry services; handling guest requests, inquiries, and complaints; and determining eligibility for age-restricted goods and services (such as alcoholic beverages or in-room adult entertainment).	Performance of a contract, such as processing payments Legitimate interests, such as honoring guest preferences (for example, a room near the elevator or on the highest floor) Consent, such as collecting information regarding dietary preferences that the guest chooses to provide Legal obligations, such as collecting a national identification number where required by law
Meetings & Events	There are a number of activities associated with these purposes, including communicating with planners and attendees regarding meetings or events (“Events”); facilitating Event bookings and related attendee reservations through all booking channels; engaging in pre- and post-Event communications (logistics, accommodations, modifications, payments, etc.); preparing and coordinating Events in accordance with the instructions, expectations, and preferences of the group, planner, or attendees; arranging guest rooms; facilitating catering services; enabling the use of third-party service providers (including audiovisual and transportation providers); receiving and transporting Event-related materials and equipment; communicating regarding invoicing and the collection of outstanding amounts; collecting or processing payments, deposits, and commissions; conducting credit checks; handling requests, inquiries, and complaints from groups, planners, or attendees; and communicating with attendees before, during, and after the Event..	Performance of a contract, such as collecting information related to an Event. Legitimate interests, such as responding to guest complaints or concerns related to an Event Legal obligations related to financial transactions, such as obligations to maintain accounting books and records
Chicland Hotel Operations & General Business Administration	There are some activities associated with these purposes, including managing customer care services to support and address inquiries, feedback, and complaints regarding any of our services (for example, in person, via telephone, email, or social media); managing security and fraud prevention; administering online services (including troubleshooting, data analysis, testing, system maintenance, support, reporting, and data hosting); monitoring and analyzing service usage and leveraging data analytics to improve services, marketing, programs, and the overall guest experience, collect feedback, conduct pilot programs for potential new services, and develop new services as well as enhance existing offerings.	Performance of a contract, such as ensuring that online services function properly, so that guests can make reservations Legitimate interests, such as responding to guest complaints and concerns, which may include, where permitted by applicable law, recording customer care service calls Legal obligations related to financial transactions, such as maintaining accounting books and records
Incident Response & Emergency Situations	Certain activities are associated with this purpose, including, without limitation: ensuring the security of services at the hotel; responding to, managing, and documenting incidents occurring at the hotel, medical emergencies, and other emergencies; proactively monitoring the property to support incident prevention, response, and comprehensive documentation (including through security cameras and body-worn cameras); requesting assistance from emergency services; and issuing notifications and alerts in the event of an incident or emergency (such as via SMS, email, telephone calls, audio-visual device prompts, or other communication channels).	Performance of a Contract, such as providing security services for guests and associates through interactions with on-property security personnel Legitimate Interests, such as monitoring the property through security cameras and body-worn cameras to help ensure the safety and security of guests and associates Legal Obligations, such as documenting and providing records relating to incidents occurring at the hotel Vital Interests of an Individual, such as contacting medical services on behalf of a guest experiencing illness or injury
Legal & Compliance	Certain activities are associated with this purpose, including, without limitation: complying with applicable laws and regulations; responding to and complying with legal processes; addressing requests from public authorities and governmental agencies; meeting national security or law enforcement requirements; enforcing our terms and conditions; protecting our operations; safeguarding the rights, privacy, safety, or property of Chicland Hotel, our guests, visitors, and other relevant individuals; and enabling us to pursue available legal remedies and limit potential damages that Chicland Hotel may incur.	Legal Obligations, such as complying with applicable legal processes Legitimate Interests, such as enforcing our terms and conditions to protect our brand Vital Interests of an Individual, such as contacting emergency services in the event of disturbances or guest-related incidents
Spa, Wellness and Beauty Services	There are certain activities associated with this purpose, including: facilitating reservations and bookings; determining eligibility to receive services; accommodating disabilities or other health-related conditions and providing appropriate and safe activities, services, and treatments; delivering consistent and personalized services based on prior experiences and guest-stated preferences; processing payments; arranging qualified professionals for specific therapies and services; and managing guest requests, inquiries, and complaints.	Performance of a contract, such as processing payments Consent, such as collecting information regarding relevant conditions in connection with the provision of massage services Legitimate interests, such as delivering personalized services (for example, offering a therapy based on prior activities or preferences) Compliance with legal obligations relating to financial transactions, such as requirements to maintain books and records.
Fitness and Recreation Services	There are certain activities associated with this purpose, including: facilitating reservations and bookings; determining eligibility to receive services; implementing applicable restrictions and providing appropriate and safe activities and services; delivering consistent and personalized services based on prior usage and the individual’s stated preferences; processing payments; and managing guest requests, inquiries, and complaints.	Performance of a contract, such as processing payments Consent, such as the collection of information regarding prior injuries during a physical consultation Legitimate interests, such as providing personalized services (for example, offering fitness and/or recreational activities or opportunities based on past participation) Compliance with legal obligations related to financial transactions, such as record-keeping requirements Vital interests of the guest, such as contacting medical services in the event of an illness or injury occurring while using fitness equipment.
Food & Beverage Services	There are certain activities associated with this purpose, including facilitating reservations, accommodating dietary preferences, delivering consistent and personalized services based on prior experiences and guest-stated preferences, processing payments, arranging bookings, and managing guest requests, inquiries, and complaints.	Performance of a contract, such as processing payments Consent, such as collecting information regarding a guest’s dietary preferences, restrictions, or other personal requirements, when placing an order Legitimate interests, such as providing personalized services (for example, offering red wine based on a guest’s prior requests) Compliance with legal obligations relating to financial transactions, such as requirements to maintain books and records Vital interests of the guest, such as contacting medical services in the event of an illness or medical emergency occurring at a restaurant.
Children’s Services (For Parents and Legal Guardians)	Facilitating reservations and bookings; preparing and coordinating hotel accommodations and services in accordance with guests’ preferences, instructions, and expectations; processing payments and issuing invoices; and providing child-friendly food and beverage services (for example, offering special children’s menus or discounted breakfast options for children below a specified age).	Performance of a contract, such as where a child of a certain age staying in the room with their parents, may result in an additional charge or a discount Consent of a parent or legal guardian, such as fulfilling a child’s needs in accordance with parental instructions Legitimate interests, such as providing cribs and other child-related amenities Compliance with legal obligations relating to financial transactions, such as requirements to maintain books and records

ADDITIONAL INFORMATION REGARDING YOUR PERSONAL PREFERENCES

Our objective is to better serve you, meet your expectations, and deliver the level of hospitality you anticipate at each stage of your travel journey, as well as to provide you with personalized advertising and marketing communications. Please see below for additional information regarding the Personal Data we collect in connection with your Preferences and how we use such data.

PREFERENCES	PURPOSE	LEGAL BASIS (WHERE APPLICABLE)
Special Occasions	When you stay with us, we seek to assist you in celebrating any special occasions, such as anniversaries or birthdays. For example, we may note these dates to provide you with a birthday or anniversary amenity.	Legitimate interests, for the purpose of delivering exceptional services to you. Consent, where you have provided your agreement
Interests and Passions	We aim to provide services that enhance your experience at Chicland Hotel. To achieve this, we may retain information regarding your preferences for certain types of activities you wish to participate in (such as beach excursions, fitness activities, travel and transportation details and related services, or spa services) to offer you similar experiences should you plan to stay with us again in the future.
Family Relationships (e.g., spouse, son, daughter, etc.)	We understand that your Preferences may vary depending on your traveling companions (for example, your preferred room type). We may maintain records of your relationships in order to assist us in providing the most comfortable stay possible at Chicland Hotel. For example, if we are aware that you are traveling with a young child, we may proactively arrange appropriate accommodations, such as a crib or an extra bed.
Dietary Preferences	When you stay with us, we seek to ensure your safety and well-being, to attend to your health-related needs where applicable, and to provide services designed to enhance your overall experience. For example, we may record your dining or beverage preferences in order to better accommodate your requests, including when you order in-room dining services or choose to dine at one of our cafés or restaurants.	Legitimate Interests, for the purpose of delivering exceptional service to you Consent

2. SCOPE OF REGULATION AND APPLICABILITY

Scope of Regulation:
- This Policy sets forth the procedures and responsibilities for ensuring the protection of customer information.
Applicability:
- Applicable to the safeguarding of customer information security and confidentiality of Chicland Hotel Joint Stock Company.
- Applicable to all employees of the Company responsible for implementing this Policy.
- Applicable to advertising partners and related service providers.

3. DEFINITIONS AND ABBREVIATIONS

1. Information Security: Information security refers to the preservation of confidentiality, integrity, accuracy, and availability of all information. These four elements are integral and inseparable components of comprehensive information protection:
- Confidentiality: Ensuring that information is accessible only to authorized individuals and that access is granted strictly on a need-to-know basis.
- Integrity: Safeguarding the completeness and reliability of information systems and preventing unauthorized alteration or destruction of information.
- Accuracy: Ensuring that information is accurate, complete, and free from errors or content that infringes intellectual property rights.
- Availability: Ensuring that information and related systems remain accessible and usable when required, at any time and from any authorized location.
Customer Information: Customer Information refers to all information provided by customers in the course of interacting with the enterprise through communication channels, platforms, or marketing campaigns.

4. SCOPE OF INFORMATION COLLECTION

Below is the translation rendered in a formal, comprehensive corporate privacy tone consistent with hospitality group policy language:

The collection, use, and/or disclosure of Customers’ Personal Data is conducted on the basis of the Customer’s consent. At various touchpoints throughout your journey as our customer, we collect Personal Data in accordance with applicable laws in order to provide standardized and high-quality services. “Personal Data” refers to information that identifies you as an individual or relates to you as an identifiable individual. We collect and process the following categories of Personal Data about you:

General Identification Information, including full name, mailing address, email address, telephone number, social media account ID, profile photograph, and other publicly available data or data provided through the linking of your social media account with your loyalty account, as well as similar identifiers. Demographic Information and Important Dates, including gender, language preference, nationality, date of birth, anniversaries, or other special occasions.

Government-Issued Identification, including passport, visa, or other government-issued identification documents (and the Personal Data contained therein).

Financial Information, including credit, debit, or other payment-related data.

Travel Information, including prior stays or guest interactions (including interactions via our chat functionality), goods and services purchased, special service requests and amenities, travel itineraries, travel group information, activity data, or employer details (for work-related bookings). Health Information, including information collected in connection with the provision of our spa, wellness, and beauty services.

Other Information. In more limited circumstances, we may also collect:

Information regarding family members and traveling companions (including names and ages of children);

Biometric data;
Images, video, and audio data collected through: voice recordings (for example, when we record customer service calls for quality assurance purposes); security cameras located in public areas such as hallways and lobbies within our properties; and body-worn cameras used by loss prevention personnel and other security staff.

We may also collect information regarding your Preferences, whether provided directly by you or recorded during your stay, in order to deliver enhanced experiences during your current and future stays. These may include: Interests and Passions, such as preferences for golf, spa services, or other activities during your stay; Food and Beverage Preferences, which may include health-related restrictions or personal requirements so that we may support your well-being; Room and Stay Preferences, including room selections, amenities, and likes and dislikes to help us improve our Services.

Other Preferences may include information about individuals with whom you typically travel, your relationship to them, special dates such as anniversaries and birthdays, and marital status.

If you submit any Personal Data relating to another individual to us or to our Service Providers (for example, if you make a reservation for another person), you represent that you have the authority to do so and that you authorize us to use such data in accordance with this Privacy Policy. We may also collect “Other Data” that does not directly reveal your specific identity. However, to the extent that Other Data reveals your specific identity or relates to an identifiable individual, we will treat such Other Data as Personal Data.

Other Data includes.

System Data: When customers use desktop computers or mobile devices to access our Online Services, we collect certain data through the browser or automatically through the device, such as computer type, screen resolution, operating system name and version, device model and manufacturer, language, internet browser type and version, and the name and version of the Online Services being used.

Precise Location-Based Services: With your consent, we may collect the precise geolocation of your device using satellite, cellular tower, Wi-Fi signals, or other technologies. We collect this data if you opt in through an Application or other program (either upon initial login or thereafter) to enhance special offers and enable location-based features on your device, such as locating nearby hotels, identifying airport shuttle locations, displaying maps, and providing directions. If you choose to share your location, the Application or other program will continue to collect location data in accordance with your selected sharing preferences.

Choice Regarding Precise Location Sharing: Users may specify through their device operating system settings (for example, via the “Settings” icon) whether to always share location data, share location data only while using the Application, or never share location data. If you select sharing only while using the Application, we will have access to such data until you log out of or close the Application, or until you disable location services for the Application or other program through your device settings.

5. SCOPE OF USE OF INFORMATION

Chicland Hotel uses the data provided by customers for the following purposes:

To create or maintain membership accounts;
To provide, in whole or in part, our services, including reservations, restaurant, and spa services;
To contact, notify, or send confirmations relating to reservation status, appointments, events, policy changes, or other important information;
To process payments, refunds, or address other matters related to the provision of services;
To issue value-added tax (VAT) invoices to customers;
To provide technical support or customer care services;
To manage complaints or incidents arising in connection with the use of our services;
For other purposes as may be required by operational needs and/or applicable laws from time to time.

6. COMMITMENT TO THE PROTECTION OF CUSTOMERS’ PERSONAL INFORMATION

Below is the translation rendered in a formal, corporate privacy tone consistent with hospitality policy documentation:
Personal Data collected from Customers shall be kept confidential and stored on our servers in compliance with the conditions and standards prescribed under the laws of Vietnam.
Customers’ personal information on the website https://chiclandhotel.com is strictly protected by Chicland Hotel in accordance with its Personal Information Protection Policy. The collection and processing of each Customer’s information shall be carried out only with the Customer’s consent in connection with transactions, payments, issuance of value-added tax (VAT) invoices, and promotional activities.
We shall not use, transfer, provide, or disclose Customers’ Personal Data to any third party without the Customer’s consent.
However, the internet environment is not entirely secure, and we cannot guarantee that Personal Data transmitted over the internet will always remain confidential. Accordingly, Personal Data collected and stored may be subject to unauthorized access by third parties (such as hackers), which could result in potential impacts or losses to Customers. When transmitting Personal Data via the internet, Customers should use secure systems to access websites, applications, or devices, and are responsible for maintaining the confidentiality and security of their authentication credentials for each website, application, or device. Customers must promptly notify Chicland Hotel upon detecting any misuse of login information and immediately change their access passwords. Chicland Hotel will use reasonable efforts to remedy and strengthen security safeguards and to mitigate potential damages to Customers.
If the server storing information is subject to a cyberattack resulting in the loss of Customers’ Personal Data, Chicland Hotel shall notify the competent authorities for timely investigation and resolution, and inform affected Customers in accordance with applicable laws.
The Management of Chicland Hotel requires individuals purchasing goods, products, or services to provide complete and accurate Personal Data, including full name, contact address, email address, and telephone number, and to be responsible for the legality and accuracy of such information. Chicland Hotel shall not be liable for, nor resolve, any claims relating to a Customer’s rights or interests where it is determined that the Personal Data provided at the time of initial registration was inaccurate or incomplete.

7. RETENTION PERIOD AND PERSONS AUTHORIZED TO ACCESS INFORMATION

Retention Period: Chicland Hotel retains Customers’ Personal Data in a manner consistent with its operational activities and for a period appropriate to the purposes of processing and the Customers’ requirements.

The retention period depends on the purposes of processing, the Customers’ requests, or requirements from competent authorities in accordance with applicable laws. Personal Data will be deleted, destroyed, or anonymized once it is no longer necessary for the purposes for which it was collected, or upon receipt of a valid request from the Customer, unless otherwise required by law.

Unless otherwise provided by applicable laws, the commencement and termination of the processing of Customers’ Personal Data shall be as follows:

Commencement: From the time the Customer provides consent for Chicland Hotel to process Personal Data in accordance with this Policy;
Termination: Upon completion of the processing activities, or upon receipt of a request to terminate processing and/or withdrawal of consent by the Customer, and/or at another time as required by law.

Personal Data shall be securely stored on our website (https://chiclandhotel.com) until a deletion request is received from the data subject.

The selection and operation of storage systems are strictly controlled to:

Monitor and manage internal access rights based on authorization levels;
Detect unauthorized access and enable data recovery in the event of an incident.

Chicland Hotel is committed to processing Customers’ Personal Data securely and confidentially, ensuring the lawful rights and interests of Customers within its capabilities and in accordance with applicable laws. We implement appropriate data processing methods, as well as suitable technical and organizational security measures, to prevent unauthorized access, reading, use, modification, disclosure, destruction, or other unlawful processing of Personal Data.

However, the internet environment is not entirely secure, and we cannot guarantee that Personal Data transmitted over the internet will always remain confidential. Accordingly, Personal Data collected and stored may be subject to unauthorized access by third parties (such as hackers), which could result in impacts or losses to Customers. Customers should use secure systems when transmitting Personal Data and are responsible for maintaining the confidentiality of their login credentials. Customers must promptly notify Chicland Hotel if they detect any misuse of their login information and immediately change their passwords. Chicland Hotel will use reasonable efforts to strengthen security safeguards and mitigate potential damages.

Persons or Organizations Authorized to Access Information

The following persons or organizations may have access to Personal Data:

Relevant internal employees (including front office, food and beverage, sales and marketing, and accounting personnel);
Transportation providers and advertising partners;
Competent state authorities upon lawful request.

Our objective is to serve you with hospitality and Services that meet your expectations. To do so, we may share Personal Data and Other Data with the following parties:

Chicland Hotel Affiliates: We collect and share Personal Data and Other Data among affiliated entities for the purposes described in this Privacy Policy, such as providing and personalizing Services, communicating with you, and facilitating our business operations. Personal Data used to make reservations may be shared with the relevant property to fulfill and complete your booking.
On-Property and Travel Service Providers: We may share your information with spa facilities, restaurants, health clubs, and guest support departments.
Advertising Partners: We share Personal Data and Other Data with advertising partners, including companies such as Meta, Google, and others, to provide marketing, advertising, and promotional services.
Service Providers: We disclose Personal Data and Other Data to third-party service providers, including website hosting providers, chat functionality providers, data analytics providers, payment processors, booking fulfillment providers, IT and infrastructure providers, customer service providers, email distribution providers, marketing service providers, auditors, and other service partners.

Other Uses and Disclosures

We may use and disclose Personal Data as we believe to be necessary or appropriate:

To comply with applicable laws, including laws outside your country of residence;
To comply with legal processes;
To respond to requests from public and governmental authorities, including authorities outside your country of residence, and to meet national security or law enforcement requirements;
To enforce our terms and conditions;
To protect our business operations, including in connection with any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business.

We may use and disclose Other Data for any purpose, except where otherwise restricted under applicable law.

8. METHODS AND TOOLS FOR CONSUMERS TO ACCESS AND CORRECT THEIR PERSONAL DATA

Below is the translation rendered in a formal, corporate privacy tone consistent with hospitality policy documentation:

Customers have the right to access or correct their Personal Data by logging into their account on the website https://chiclandhotel.com to review or update their Personal Data directly, or by requesting assistance from the Chicland Hotel Administration.

Customers have the right to request that Chicland Hotel update, amend, or delete their Personal Data.

Customers are responsible for timely updating and correcting their Personal Data and for ensuring the accuracy and completeness of the information they provide to Chicland Hotel.

• Additional Information

To protect your privacy, we will only respond to requests concerning Personal Data associated with the email address and/or loyalty account number that you confirm in your request. We may also need to verify your identity before fulfilling certain requests.

We will endeavor to respond to your request as soon as reasonably practicable and in accordance with applicable laws. Please note that certain Privacy Rights may not be available under applicable laws to all customers or to all users of our Services.

• Contact Us

If you have any questions regarding your Privacy Choices or Personal Rights, please contact us at: https://chiclandhotel.com

9. CONTACT INFORMATION

Chicland Hotel recommends that Customers regularly visit the website https://chiclandhotel.com to stay informed of any updates or amendments (if any) to this Notice.

With the objective of continuously enhancing service quality, Chicland Hotel welcomes and values all feedback, inquiries, and complaints from our Customers. Please contact us at:

Company Name: Chic-Land Joint Stock Company

Tax Code: 0401699071

Address: No. 210 Vo Nguyen Giap street, An Hai ward, Da Nang city, Vietnam

Phone Number: 0236.223.2222

Email: hotel@chicland.vn

Website: https://chiclandhotel.com