Privacy Statement

The Astadala Hospitality, which includes PT. Anugerah Paskah Bali, PT. Anugerah Bene Kuta, PT. Anugerah Haere Seminyak and its direct and indirect subsidiaries (collectively, “Astadala,” “we,” or “us”) and their affiliates, values you as our guest and recognizes that privacy is important to you. We want you to be familiar with how we collect, use and disclose data.

This Privacy Statement describes the privacy practices of the Astadala Hospitality for data that we collect:


Collectively, we refer to the Websites, the Apps and our Social Media Pages, as the “Online Services” and, together with offline channels, the “Services.” By using the Services, you agree to the terms and conditions of this Privacy Statement.


Collection of Personal Data

Personal Data” are data that identify you as an individual or relate to an identifiable individual.

At touch points throughout your journey as our guest, we collect Personal Data in accordance with law, such as:


In more limited circumstances, we also may collect:


If you submit any Personal Data about other people to us or our Service Providers (e.g., if you make a reservation for another individual), you represent that you have the authority to do so and you permit us to use the data in accordance with this Privacy Statement.


How We Collect Personal Data

We collect Personal Data in a variety of ways:


Collection of Other Data

Other Data” are data that generally do not reveal your specific identity or do not directly relate to an individual. To the extent Other Data reveal your specific identity or relate to an individual, we will treat Other Data as Personal Data. Other Data include:


How We Collect Other Data

We collect Other Data in a variety of ways:


Cookies further allow us to select which advertisements or offers are most likely to appeal to you and display them while you are using the Online Services or to send marketing emails. We also use cookies to track responses to online advertisements and marketing emails.

If you do not want data collected with cookies, you can learn more about controlling cookies at: allaboutcookies.org/manage-cookies/.

You can choose whether to accept cookies by changing the settings on your browser or by managing your tracking preferences by clicking on “Tracking Preferences” located at the bottom of our home page. If, however, you do not accept cookies, you may experience some inconvenience in your use of the Online Services. For example, we will not be able to recognize your computer, and you will need to log in every time you visit. You also will not receive advertising or other offers from us that are relevant to your interests and needs. At this time, we do not respond to browser “Do-Not-Track” signals.


Aggregated Data. We may aggregate data that we collected and this aggregated data will not personally identify you or any other user.


Use of Personal Data and Other Data

We use Personal Data and Other Data to provide you with Services, to develop new offerings and to protect the Astadala Hospitality and our guests as detailed below. In some instances, we will request that you provide Personal Data or Other Data to us directly. If you do not provide the data that we request, or prohibit us from collecting such data, we may not be able to provide the requested Services.

We use Personal Data and Other Data for our legitimate business interests, including the following:


We use Personal Data and Other Data in above ways to manage our contractual relationship with you, comply with a legal obligation, and/or because we have a legitimate interest to do so.


Disclosure of Personal Data and Other Data

Our goal is to provide you with the highest level of hospitality and Services, and to do so, we share Personal Data and Other Data with the following:


Corporate Reorganization. We may disclose or transfer your Personal Data and Other Data 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 the Astadala Hospitality business, assets or stock (including any bankruptcy or similar proceedings).


Other Uses and Disclosures

We will use and disclose Personal Data as we believe to be necessary or appropriate: (a) to comply with 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 authorities outside your country of residence and to meet national security or law enforcement requirements; (d) to enforce our terms and conditions; (e) to protect our operations; (f) to protect the rights, privacy, safety or property of the Astadala Hospitality, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

We may use and disclose Other Data for any purpose, except where we are not allowed to under applicable law. In some instances, we may combine Other Data with Personal Data (such as combining your name with your location). If we do, we will treat the combined data as Personal Data as long as it is combined.


Non-Astadala Hospitality Entities

This Privacy Statement does not address, and we are not responsible for the privacy, data or other practices of any entities outside of the Astadala Hospitality, including, Strategic Business Partners, Service Providers, or any third party operating any site or service to which the Services link, payment service, membership/loyalty program, or website that is the landing page of the high-speed Internet providers at our properties. The inclusion of a link on the Online Services does not imply endorsement of the linked site or service by us. We have no control over, and are not responsible for, any third party’s collection, use and disclosure of your Personal Data.

In addition, we are not responsible for the data collection, use, disclosure or security policies or practices of other organizations, such as Facebook, Apple, Google, Microsoft, RIM or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including with respect to any Personal Data you disclose to other organizations through or the Apps or our Social Media Pages.


Third Party Advertisers

We may use third-party advertising companies to serve advertisements regarding goods and services that may interest you when you access and use the Online Services, other websites or online services. To serve such advertisements, these companies place or recognize a unique cookie on your browser (including through use of pixel tags). If you would like more information about this practice, and to learn about your choices in connection with it, please visit networkadvertising.org/managing/opt_out.asp and aboutads.info/. To opt out of the practice, you may download the AppChoices app at aboutads.info/appchoices.


Security

We seek to use reasonable organizational, technical and administrative measures to protect Personal Data. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account has been compromised), please immediately notify us in accordance with the “Contacting Us” section, below.


Choices, Access, and Retention

You have choices when it comes to how we use your data and we want to ensure you have the information to make the choices that are right for you.

If you no longer want to receive marketing-related emails, you may opt out by following the instructions in any such email you receive from us.

In addition, members of our membership programs can opt out from marketing-related emails through their program account, or by sending a letter to:

Member Support – (Unsubscribe)
The Seminyak Suite – Private Villa
Jl. Raya Seminyak 17, Seminyak, Kuta, Bali 80361, Indonesia

We will try to comply with your request as soon as reasonably practicable. If you opt out of receiving marketing emails from us, we may still send you important administrative messages, from which you cannot opt out.

We reserve our right not to respond to requests submitted to addresses other than the addresses specified in this paragraph.


How You Can Access, Change, or Suppress Your Personal Data

If you would like to review, correct, update, suppress, restrict or delete Personal Data that you have previously provided to us, or if you would like to receive an electronic copy of your Personal Data for purposes of transmitting it to another company (to the extent this right to data portability is provided to you by law), you can contact us at [email protected], or by mail:

Astadala Hospitality - (Privacy Compliance)
The Seminyak Suite – Private Villa
Jl. Raya Seminyak 17, Seminyak, Kuta, Bali 80361, Indonesia.

In your request, please make clear what Personal Data you would like to have changed, whether you would like to have your Personal Data suppressed from our database, or other limitations you would like to put on our use of your Personal Data. For your protection, we only fulfill requests for the Personal Data associated with the particular email address that you use to send us your request, and we may need to verify your identity before fulfilling your request. We will try to comply with your request as soon as reasonably practicable.

Please note that we often need to retain certain data for record-keeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion (e.g., when you make a purchase or reservation, or enter a promotion, you may not be able to change or delete the Personal Data provided until after the completion of such purchase, reservation, or promotion). There may also be residual data that will remain within our databases and other records, which will not be removed. In addition, there may be certain data that we may not allow you to review for legal, security or other reasons.


Retention

We will retain your Personal Data for the period necessary to fulfill the purposes outlined in this Privacy Statement unless a longer retention period is required or permitted by law.

The criteria used to determine our retention periods include:


Sensitive Data

Unless specifically requested, we ask that you not send us, and you not disclose, on or through the Services or otherwise to us, any Sensitive Personal Data (e.g., social security numbers, national identification number, data related to racial or ethnic origin, political opinions, religion, ideological or other beliefs, health, biometrics or genetic characteristics, criminal background, trade union membership, or administrative or criminal proceedings and sanctions).


Use of Services by Minors

The Services are not directed to individuals under the age of eighteen (18), and we request that they not provide Personal Data through the Services.


Cross-Border Transfer

The Astadala Hospitality is a global organization and provides a global service. Sharing data cross-border is essential to the Services so that you receive the same high-quality service wherever you are in the world. As a result, we will, subject to law, transfer Personal Data and Other Data collected in connection with the Services, to entities in countries where data protection standards may differ from those in the country where you reside. By making a reservation, visiting or staying at a Astadala branded property or using any Astadala Hospitality branded service, you understand that we transfer your Personal Data globally.

In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries will be entitled to access your Personal Data.

Some of the non-EEA countries are recognized by the European Commission as providing an adequate level of data protection according to EEA standards (the full list of these countries is available here).


Updates to This Privacy Statement

The “Last Updated” legend at the bottom of this page indicates when this Privacy Statement was last revised. Any changes will become effective when we post the revised Privacy Statement on the Online Services. Your use of the Services following these changes means that you accept the revised Privacy Statement. If you would like to review the version of the Privacy Statement that was effective immediately prior to this revision, please contact us at [email protected]


Contacting Us

If you have any questions about this Privacy Statement, please contact us at [email protected], or by mail:

Astadala Hospitality - (Privacy Compliance)
The Seminyak Suite – Private Villa
Jl. Raya Seminyak 17, Seminyak, Kuta, Bali 80361, Indonesia.

Because your email communications to us may not always be secure, please do not include credit card or Sensitive Data in your emails to us.



Last updated: 18 May, 2018