Consumer customer's personal data file description and processing personal data in Holiday Club Spa Hotels chain's hotels.

PERSONAL DATA FILE DESCRIPTION
Personal Data Act (523/99) Section 10
Adopted 9 December 2002

1. Controller

Name: Hotels and restaurants in Sokotel Oy and Holiday Club Spa Hotels chain.

Contact details: Sokotel Oy, PO Box 68, 00088 S-RYHMÄ, FINLAND, tel. +358 10 76 82800

2. Contact person
Tiina Luukkonen
Contact details: PO Box 67, 00088 S-RYHMÄ, FINLAND

3. Name of the personal data file
Customer register for Sokotel Oy and the hotels and restaurants in Holiday Club Spa Hotels chain.

4. Purpose of the processing of personal data
The controller processes customers' personal data for the following purposes:

- Managing and developing customer relations
- Managing bookings
- Invoicing, supervision of payments and collection of receivables
- Marketing the controller's goods and services
- Developing the controller's business and customer services connected to it
- Making restaurant reservations and booking conference premises
- Following and analysing customers' interests and accommodation and eating choices and developing related customer services
- Registering the functions and perks of the loyal customer programme.
- Catering for loyal customers' wishes and developing customer services and directing resources correctly
- Registering the perks of the loyal customer programme's cooperation businesses

Personal data processing in accordance with Personal Data Act Section 8, subsection 1, paragraphs 1, 2, 5 and 6.

5. Data included in the personal data file
The following customer information is collected and recorded:

- Customer data: Name, date of birth, customer number, contact details (e.g. landline and mobile phone numbers, email address and other electronic address details), title or profession, language code, sex, nationality, number of adults and children who stayed the night with the customer and invoicing details
- Customer feedback data: Customer satisfaction details, comments regarding the controller's service and other information gained on the customer's consent.
- Booking information (e.g. information on earlier and forthcoming bookings)
- Information regarding using the service: e.g. the service's usage, purchase and cancellation information and information regarding from which hotel or restaurant the customer has bought the service
- Information on the customer's wishes and choices: e.g. a non-smoking room or table, class of room and required services.
- Customer's choice of payment and payment history (including payments in arrears) and invoicing details
- Customer's permission for email, text message and other direct marketing through automatic systems.
- Prohibition details on direct advertising, distance selling and other direct marketing in accordance with legislation
- Information on belonging to the controller's and its cooperation partners' loyal customer or similar schemes and all necessary information for receiving the perks for belonging to the scheme.
- Loyal customer card details (e.g. card number and validity)
- Card-specific information on the  use of the controller's services (e.g. hotel stays and purchases)
- Points collected by the loyal customer and paid plus points
- Information on hobbies and interests
- Other information collected on customer consent (e.g. any mobility restrictions, disabilities and illnesses which are necessary to carry out the required the service)

6. Regular sources of data
Information regarding the customer is collected from the customer with his/her consent (Personal Data Act, Section 8, subsection 1, paragraph 1) and the bookings requested and purchases made by the customer (Personal Data Act, Section 8, subsection 1, paragraphs 2 and 5). Data may also be collected, recorded and updated based on registers held by  the Population Register Centre and other address, updating or equivalent registers offering similar service.

7. Regular disclosure of data and transfer of data outside the EU or the EEA
Customers' personal data is regularly disclosed to SOK's customer owner services' bonus system and to associations which have made a cooperation agreement with the controller.

Customers' personal data is disclosed and transferred outside the European Economic Area when the accommodation or other service requested by the customer requires it. Disclosing and transferring data is based on the customer's consent and assignment (Personal Data Act, Section 23, subsections 1 and 2).

Regular disclosure of customers' personal data to the marketing register of Sokotel Oy and Holiday Club Spa Hotels chain's hotels and restaurants is carried out after the contact between the controller and customer has ended.

8. Principles for the protection of the personal data file

A. Tangible material
Material in a tangible format is kept in the locked and supervised premises of Sokotel Oy and each hotel in the Holiday Spa Hotels chain.

B. Data in electronic format
Only those employees employed by Sokotel Oy and Holiday Club Spa Hotels chain's hotels who need the data as part of their employment have an access right to the register. They have user IDs and passwords.

The information is stored in S Group's closed network which is protected by a firewall.

INFORMATION TO CUSTOMERS IN ACCORDANCE WITH PERSONAL DATA ACT SECTION 24

Personal data file description
The personal data file description discussing the customer register of Sokotel Oy and Holiday Club Spa Hotels chain's hotels is available at Sokotel Oy's premises at PO Box 68, 00088 S-RYHMÄ, FINLAND and on the website www.holidayclubhotels.fi. The personal data file description is also available in every Holiday Club Spa Hotels chain's hotel.

Right of access and the right to revise incorrect information
The customer has the right to access information in the register that applies to him/her. When the customer wishes to use his/her right of access, s/he must send a request signed in person to Sokotel Oy in the above mentioned address. The customer can also visit Sokotel Oy or any Holiday Club Spa Hotels chain's hotel with a document proving his/her identity. When requesting right of access, the customer must give his/her name, address and telephone number. Sokotel Oy sends the customer a written response in 30 days after the customer has been to Sokotel Oy or Holiday Club Spa Hotels chain's hotel in person or the customer's right of access request in writing has arrived at Sokotel Oy or a Holiday Club Spa Hotels chain's hotel.

If there are errors in the customer's details, the customer can present Sokotel Oy and any Holiday Club Spa Hotels chain's hotel with a request to amend the error.

Right to prohibit
The customer has the right to prohibit the controller from processing his/her data for the use of direct advertising, distance selling or other direct marketing.  The customer can prohibit it by informing Sokotel Oy at Po Box 67, 00088 S-RYHMÄ, FINLAND in writing or phoning +358 20 1234 900.

Holiday Club Spa Hotels chain
Information on the hotels and restaurants in the Holiday Club Spa Hotels chain at any one time is available by phoning +358 30 1234 900 and on Holiday Club Spa Hotels chain's website at www.holidayclub.fi.

PROCESSING PERSONAL DATA IN HOLIDAY CLUB SPA HOTELS

Collecting information
Personal data is collected in accordance with the Personal Data Act as the customer makes a phone, fax, email or Internet reservation for a room, treatment, activity or meeting service.

Right of access and the right to revise incorrect information
As our customer, you have the right to access information concerning you in our customer register. When you wish to use your right of access, please send a signed right of access request to Sokotel Oy, Tiina Luukkonen, PO Box 67, 00088 S-RYHMÄ, FINLAND.

If your data is erroneous, you can request an amendment to the error.

Right to prohibit
You have the right to prohibit Holiday Club Spa Hotels from using your details for direct advertising, distance selling and other direct marketing. You can prohibit it by writing to Sokotel Oy, Tiina Luukkonen, Po Box 67, 00088 S-RYHMÄ, FINLAND. You can also inform about the prohibition by phoning Holiday Club Spa Hotels Sales, tel. +358 20 1234 900 (Mon-Fri 8am - 8pm). 

Data storage
The data is stored in S Group's protected network which is separated from the public network with firewalls.

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