Effective Date: December 2022

This Privacy Statement applies to www.sunidoinn.com owned and operated by Su Nido Inn/B&W Inns LLC. This Privacy Statement describes how we collect and use the information, which may include personal data, you provide on our website: www.sunidoinn.com. It also describes the choices available to you regarding our use of your personal data and how you can access and update this data.

Data Collection

The types of personal data that we collect include:

• Your first name, last name, email address, phone number, and home address;
• Credit card details (type of card, credit card number, name on card, expiration date, and security code);
• Guest stay data, including date of arrival and departure, special requests made, observations about your service preferences (including room preferences, facilities, or any other services used);
• Data you provide regarding your marketing preferences or in the course of participating in surveys, contests, or promotional offers;

You may always choose what personal data (if any) you want to provide to us. However, if you choose not to provide certain details, some of your transactions with us may be impacted.

Data We Collect Automatically

When using our website, we also collect information automatically, some of which may be personal data. This includes data such as language settings, IP address, location, device settings, device OS, log information, time of usage, URL requested, status report, user agent (information about the browser version), operating system, result (viewer or booker), browsing history, and type of data viewed. We may also collect data automatically through cookies. For information on how we use cookies, click here.

Processing Purposes

We use your personal data for the following purposes:

1. Reservations: We use your personal data to complete and administer your online reservation.
2. Customer Service: We use your personal data to provide customer service.
3. Guest Reviews: We may use your contact data to invite you by email to write a guest review after your stay. This can help other travelers to pick the accommodations that suits them best. If you submit a guest review, your review may be published on our website.
4. Marketing Activities: We also use your data for marketing activities, as permitted by law. Where we use your personal data for direct marketing purposes (e.g. commercial newsletters and marketing communications on new products and services or other offers we think may be of interest to you), we include an unsubscribe link that you can use if you do not want us to send messages in the future.
5. Other Communications: There may be other times when we contact you by email, mail, phone, or texting, depending on the contact data you share with us. There could be a number of reasons for this:
   
   1. We may need to respond to and handle requests you’ve made.
   2. If you haven’t finalized a reservation online, we may email you a reminder to continue with your reservation. We believe this additional service is useful to you because it allows you to carry on with a reservation without having to search for the accommodation again or filling in all the reservation details from scratch.
   3. When you use our services, we may send you a questionnaire or invite you to provide a review about your experience with our website. We believe this additional service is useful to you and to us, as we will be able to improve our website based on your feedback.
6. Analytics, Improvements, and Research: We use personal data to conduct research and analysis. We may involve a third party to do this on our behalf. We may share or disclose the results of such research (including to third-parties) in anonymous, aggregated form. We use your personal data for analytical purposes to improve our services, enhance the user experience, and improve the functionality and quality of our online travel services.
7. Security, Fraud Detection, and Prevention: We use the information, which may include personal data, in order to prevent fraud and other illegal or infringing activities. We also use this information to investigate and detect fraud. We can use personal data for risk assessment and security purposes, including the authentication of users. For these purposes, personal data may be shared with third parties, such as law enforcement authorities as permitted by applicable law and external advisers.
8. Legal and Compliance: In certain cases, we need to use the information provided, which may include personal data, to handle and resolve legal disputes or complaints, for regulatory investigations and compliance, or to enforce agreement(s), or to comply with lawful requests from law enforcement insofar as it is required by law.

   If we use automated means to process personal data which produces legal effects or significantly affects you, we will implement suitable measures to safeguard your rights and freedoms, including the right to obtain human intervention.

Legal Bases

• In view of purposes A and B, we rely on the performance of a contract: The use of your data may be necessary to perform the contract that you have with us. For example, if you use our services to make an online reservation, we will use your data to carry out our obligation to complete and administer that reservation under the contract that we have with you.
• In view of purposes C – H, we rely on its legitimate interests: We use your data for our legitimate interests, such as providing you with the best appropriate content for the website, emails, and newsletters to improve and promote our products, services, and the content on our website, as well as for administrative, fraud detection, and legal purposes. When using personal data to serve our legitimate interests, we will always balance your rights and interests in the protection of your information against our rights and interests.
• In respect of purpose H, we also rely, where applicable, on our obligation to comply with applicable law.
• Where needed under applicable law, we will obtain your consent prior to processing your personal data for direct marketing purposes.

If needed in accordance with applicable law, we will ask for your consent. You can withdraw your consent anytime by contacting us at any of the addresses at the end of this Privacy Statement.

If you want to object to the processing set out under C-F and there’s no opt-out mechanism available to you directly (e.g. in your account settings), to the extent applicable, please contact [email protected].

Data Sharing

• Third-party service providers: We use service providers to process your personal data strictly on our behalf. This processing would be for purposes as included in this Privacy Statement, such as facilitating reservation payments, sending out marketing material, or for analytical support services. These service providers are bound by confidentiality clauses and are not allowed to use your personal data for their own purposes or any other purpose.
• Competent authorities: We disclose personal data to law enforcement and other governmental authorities insofar as it is required by law or is strictly necessary for the prevention, detection or prosecution of criminal acts and fraud.

International Data Transfers

The transmission of personal data as described in this Privacy Statement may include overseas transfers of personal data to countries whose data protection laws are not as comprehensive as those of the countries within the European Union. Where required by European law, we shall only transfer personal data to recipients offering an adequate level of data protection. In these situations, we make contractual arrangements to ensure that your personal data is still protected in line with European standards. You can ask us to see a copy of these clauses using the contact details below.

Security

B&W Inns LLC observes reasonable procedures to prevent unauthorized access to, and the misuse of information, including personal data. We use appropriate business systems and procedures to protect and safeguard information including personal data. We also use security procedures, technical, and physical restrictions for accessing and using the personal data on our servers. Only authorized personnel are permitted to access personal data in the course of their work.

Data Retention

We will retain your information, which may include personal data, for as long as we deem it necessary to provide services to you, comply with applicable laws, resolve disputes with any parties, and otherwise as necessary to allow us to conduct our business, including to detect and prevent fraud or other illegal activities. All personal data we retain will be subject to this Privacy Statement. If you have a question about a specific retention period for certain types of personal data we process about you, contact us using the contact details included below.

Your Choices and Rights

We want you to be in control of how your personal data is used by us. You can do this in the following ways:

• You can ask us for a copy of the personal data we hold about you;
• You can inform us of any changes to your personal data, or you can ask us to correct any of the personal data we hold about you;
• In certain situations, you can ask us to erase, block, or restrict the processing of the personal data we hold about you, or object to particular ways in which we are using your personal data; and
• In certain situations, you can also ask us to send the personal data you’ve given us to a third party.

Where we are using your personal data on the basis of your consent, you are entitled to withdraw that consent at any time subject to applicable law. Moreover, where we process your personal data based on legitimate interest or the public interest, you have the right to object at any time to that use of your personal data, subject to applicable law.

We rely on you to ensure that your personal data is complete, accurate, and current. Be sure to inform us as soon as possible regarding any changes to or inaccuracies in your personal data by contacting [email protected]. We will handle your request in accordance with the applicable law.

Questions or Complaints

If you have questions or concerns about our processing of your personal data, or if you want to exercise any of the rights you have under this notice, you are welcome to contact us at [email protected]. You may also contact your local data protection authority with questions and complaints.

Changes to the Notice

Just as our business changes constantly, this Privacy Statement may also change for time to time. If you want to see changes made to this Privacy Statement from time to time, we invite you to access this Privacy Statement to see the changes. If we make material changes or changes that will have an impact on you (e.g. when we start processing your personal data for purpose other than those set out above), we will contact you prior to starting that processing.