Privacy Policy

1. Applicability Privacy Statement

The Privacy Statement applies to all activities and actions of all Valk Exclusive hotels and restaurants ("Valk Exclusive") related to the services it offers or facilitates in the broadest sense of the word. Appendix 1 with this Privacy Statement contains a list of the hotels and restaurants that fall under this Privacy Statement. On this list you will also find the contact details for all privacy related questions.

The Privacy Statement does not apply to activities related to applicants and staff. For this Valk Exclusief has established and published a separate Privacy Statement. The Privacy Statement also does not apply to the processing of personal data by parties from which Valk Exclusief has received your personal data (such as booking organizations, travel agencies, employers, social media companies), or to the processing by any other third party. With regard to such processing, we refer to the Privacy Statement of these organizations.

2. Consent to processing personal data

By registering for or by using our products or services, you confirm that you have taken note of the content of the Privacy Statement and that you agree with the method of processing of personal data by Valk Exclusief as described in the Privacy Statement. In those situations in which Valk Exclusief is required by applicable privacy laws and regulations to explicitly request permission for the processing of your personal data and you provide this permission, you also consent to agree to what is described in this Privacy Statement.

4. Nature, purpose and basis of the processing of personal data

Valk Exclusief processes various types of personal data for various purposes. Below are more details with regard to which personal data are being used for which purposes.

a. Room and function room bookings

If you book or request a room, function room and/or other hotel facility, your personal data are required (such as your title, name, address, place of residence, date of birth, telephone number, email, signature, departure and arrival date, besides your payment details. If you make a business booking, we will also collectthe name and (address) details of your employer and/or client. We may also collect additional personal information from you that is of importance to our services and that you have provided to us voluntarily.

We only process health-related data in order to provide you with a better services, such as which allergies we should take into account or the fact that you wish to use amenities for the disabled. You are free to deny us health-related information.

As a hotel we are legally obliged to register a number of details (name, place of residence, type of ID, day of arrival and departure) of our guests. Additionally, we process certain data in order to be able to implement our services, and we have a legitimate interest in processing certain data to protect our business operations and to guarantee the quality of our services.

b. Restaurant bookings

If you book in one of our restaurant, we will collect personal information (such as your title, name, address and preferences) in order to confirm the booking and to implement your wishes. Additoinally, we will ask you if there are any allergies, we should consider.

We process these details in order to be able to implement our restaurant services, including your permission.

c. Valk Exclusief Account and Valk Exclusief App

If you make a booking through one of our websites, we will create an account for you that can also be used through our Valk Exclusive app. In this way, booking and information requests during a follow-up visit to the website are easy to access, change and cancel. Furthermore, with your account you will be able to profit form discounts, we offer. In order to create an account your title, gender, name, address, place of residence, date of birth, telephone number and email address are required. If you prefer payment through the Valk Exclusief app, we will also request your payment details. Through your Valk Exclusief account (and app) we collect information about your payments, stays, preferences. Loyaly points for discount and your restaurant ID number (please, see section 3.d. of the Privacy Statement).

As a Valk Exclusive member you also have the option to use the Valk Exclusief online check in service. If you wish to make use of the service, we will additionally process your signature and the type of ID, with which you have identified yourself. You can also opt for linking your payment detaills and license plate number to your Valk Account.

We process this data in order to implement the Valk Account services, including your permission.

d. Restaurant ID

We offer special discount to people who wish to participate in our Restaurant ID programmme. In order to create a Restaurant ID account, your title, gender, name, address, place of residence, date of birth, telephome nummer and email address are required. We also collect information about your Restaurant ID Points and invoices.

We process this data in order to implement the Restaurant ID services, including your permission.

e. Contact requests, reviews, complaints and comments

If you wish to contact us because you have a question, complaint or comment with regard to our hotels, restaurants, services, website(s) or app(s), your contact details will be required, which allows us to contact you or improve our services.

If you place an online review or complaint regarding one of our hotels or restaurants, our services, website(s) or app(s) on one of our website(s), on social media or on a website of a booking partner, we will receive this through the used website and we will use this information to contact you about your complaint or comments or to improve our services.

We have a legitimate interest (improvement of services and complaints procedure) in the processing of these details. By requesting contact or by leaving your details on the contact form(s), website9s), etc,, you grant u spermission to contact you.

f. Security

Our hotels, restaurants, car parks and garages have camera surveillance to promote the safety of our guests, employees and belongings and to prevent theft and other irregularities.

We have a legitimate interest (security) in the processing of these details.

g. License plate registration

Various Valk Exclusief hotels use license plate number registration for registration and payment of parking fees. If you use these parking amenities, your license plate number will be registered in order to implement the parking services.

h. Newsletters and mailings

If you use our services, you can also sign up for our newsletters. By means of personalized e-mail messages our newsletters will inform you about exclusive deals and you will be sent service messages. If you wish to sign up for our newsletter, we will collect your title, name, date of birth and email address, in order to send you the newsletter. We will also record the time, at which you registered for the newsletter.

We use your consent to process this data.

i. Contests

On a regular basis Valk Exclusief organizes competitions, contests and promotions through its website(s) or social media. If you react or participate, youe name and contact details will be required. These are used to inform the prize winners, to carry out the promotion and to measure the response to the promotion.

We use your consent to process this data.

j. (Direct) marketing

In order to send you deals that interest you and that are part of our services, we collect information about people that visit our website, such as demographic details. We do this by placing cookies. We may collect information about you from third parties,m including information from our partners and social media sites, in accordance with your settings on such websites. We refer to the information regarding data collection through cookies in Chapter 7 of the Privacy Statement,

k. Social media

Valk Exclusief can be found on various social media, such as Facebook and Instagram. Valk Exclusief uses social media plugins on its website. When you click on one these buttons and register with our social media account, you grant us permission to place cookies and information (name, gender, place of residence, date of birth, profile) will be shared with us.

l. Blacklist and cash list

Valk Exclusief applies a blacklist policy to combiat nuisance and crime in its hotels and restaurants. Valk Exclusief also keeps a cash list against fraud and non-payment. Valk Exclusief therefore has a legitinate interest in this type of data processing.

On the basis of this policy and in very exceptional cases, Valk Exclusief can decide to refuse a guest access to its hotels or other services or to impose conditions on payment methods. This might be done in case of fraud, when someone causes nuisance, breaks the house rules, causes damage to belongings of other Valk Exclusief guests or employees, causes injury to other Valk Exclusief guests and/or employees or displays other improper behaviour.

Valk Exclusief applies a strict and careful policy in terms of data processing and data security regarding the blacklist and cash list. The regular privacy rights of someone involved apply fully (reference is made to chapter in the Privacy Statement).

m. Processing of data regarding minors and children

Valk Exclusief registers the name of minors and children if they stay at one of our hotels in the company of a parent/guardian. The processing of additional children’s data is not Valk Exclusief’s aim, unless you consider it important that information about your children is brought to our attention.

Valk Exclusief is legally obliged to process this data.

5. Providing and sharing your data with third parties

5.1 Transfer of your personal details

In order to be able to provide certain services and to meet the expected level of hospitality and service, we can share your personal details within Valk Exclusief, with our service providers and other third parties. We ensure that data sharing only takes place if the third party processes the data on the basis of our instructions, takes adequate appropriate (security) measures and guarantees us to obey the applicable privacy laws and regulations. Below you will find an overview of (the categories of) recipients.

1. Valk Exclusief: Companies that are part of or affiliated with Valk Exclusief, are all active in the hotel sector and need your details to be able to provide the selected services correctly. The sole purpose of this transfer is the ability to correctly provide services to you.
2. Event organizations / companies: if you visit Valk Excusief as part of a group event or meeting, information, collected for the planning of the event or meeting can be shared with the organizers and, if applicable, with the guests who organize or attend the meeting or the event.
3. Service providers: we depend on third parties, including IT-service providers, software maintenance parties to deliver services and products on our behalf and we may share your personal information with them, if appropriate. We may also use service providers that communicate news and provide promotional and transactional materials to you on on our behalf, including personalized online advertising, in compliance with your preference and applicable laws.
4. Other: Valk Exclusief may also share personal information in order to:

- comply with applicable laws and regulations;

- respond to government requests or court orders;

- comply with valid legal procedures;

- safeguard the rights, privacy, safety or belongings of Valk Exclusief, guests or employees;

- enforce the conditions of our services;

- respond to an emergency.

5.2 Transfer of personal data outside the EEA

Valk Exclusief may transfer personal data from the Netherlands to abroad. When personal details are processed by us outside the EEA, we will ensure an appropriate level of protection with regard to the transferred data. Service providers and other providers are required to take appropriate measures to guarantee the confidentiality and security of personal data.

5.3 Transfer of personal data (sources)

To be able to provide certain services and to meet the expected level of hospitality and service, we sometimes receive data from other organizations. Below you will find on overview of (the categories of) sources:

a. Valk Exclusief: Companies that are part of Valk Exclusief (see appendix 1) and related parties may share your data with the Hotel in order to be able to perform the selected services correctly. The sole purpose of this transfer is the ability to correctly provide services to you.

b. Booking organisations/online travel agents: the Valk Exclusief hotels can be booked through various websites and apps. These are Valk Exclusief websites and apps (valkexclusief.nl), Van der Valk websites and apps (www.valk.com) or websites and apps from third parties. If you book through a website or app, your details and other information will be passed on to the hotel in question.

c. Employer/client: if you are staying at our hotel for business, it may be that your employer or client has provided us with information about yout.

d. Event organizations: if you visit Valk Exclusief as part of a group event or meeting, information collected for the planning of the event or meeting may be provided by the organizers and, if applicable, by the guests who participate in or organize the meeting or event.

e. Social media: if you prefer to register for the Valk Exclusief app through Facebook, Valk Exclusief will get your name, profile photo and email address from Facebook (in addition to your account details).

6. Retention period

We will not keep your personal data any longer than necessary, unless we have a legal obligation to keep your personal data for a longer period of time or if you have given u spermission to do so. In tha latter case you can always reverse your permission.

Our basic principle is that we only keep personal data for as long as necessary in order to provide you with our products and/or services. After this we will delete your personal data, unless prohibited by law.

The Valk Exclusief account you created will be deleted after an inactive time period of five years. This period is used because of the duration of the Valk Loyal promotions that you as account holder can use.

7. Cookies

Valk Exclusief uses cookies. A cookie is a small text file that is stored on the visitor’s device (eletronic device) on the first visit to a website. The purpose of cookies is to collect information about someone, about the website or statistics. Some cookies also have the purpose to improve the user experience with regard to the website.

Types of cookies

We distinguish between functional and non-functional ccokies. We always place functional cookies. These are necessary for the website to work properly. Non-functional cookies process personal data beyond the range of vision. First and foremost these cookies enable us to improve our services. This allows us, for example, to measure how often our website is used and what information visitors are looking for. We always ask your permission to request non-functional cookies. We use the following non-functional cookies:

a. Analytical cookies - with analytical cookies we collect statistics about the use of the website by users. By measuring website usage, the website can be improved for the benefit of the users. Among other things, the following data is stored:

• the IP address, which is masked in accordance with the guidelines of the privacy laws and regulations;
• technical characteristics, such as the browser you use;
• from which page you came to the web store;
• which internet pages you visit.

b. Advertising cookies – we use advertising cookies to display personalized advertisements and to measure the effectiveness of an advertising campaign. The advertising cookies are necessaryto actually display the advertisements.

c. Social – cookies with which the content of the Valk Exclusief websites can be shared on social media, such as Twitter, Facebook, Google + Linkedin and Youtube. We have no influence on the cookies that social media place nor on the data that they collect.

d. Marketing - cookies with which we can offer relevant customized content. This may include relevant deals and information about our services. We do this on the basis of anonymized data about surfing, searching and purchasing behavour, through our own chaneels and those of third parties. If you disable these cookies you will still see advertisements, but they will be less relevant. These cookies also provide insight into the effectiveness of advertisements.

e. Other - cookies that do not apply to the above categories, such as cookies that help with the improvement of the website’s user-friendliness. These cookies remember preferences and interests, to name a few. These may include language and currency preference, favourite hotel and preferred payment method.

Block and delete cookies
If you do not want our website to store cookies on your computer, you can indicate this in the cookie message that will be shown when you visit our website the first time. Have you already accepted our cookies? In that case you will no longer see this messsage and you (if required) must delete the cookies yourself. You can disable the placement of cookies by changing your browser settings. Please, note that certain functionalities on the website may not or only partially work if you disable cookies.

Cookies used by third parties
Valk Exclusief uses the services of the third parties listed below. While using their services, these parties may also store cookies on your device. At the time of this version of the Privacy Statement, Valk Exclusief used:

- Feedbackify
- Cookiebar
- Sessie
- Login
- RequestVerification
- Facebook
- Google Analytics
- Google Tag Manager
- Hotjar
- Trengo
- Doubleclick
- Shoppingminds

Google Analytics

Valk Exclusief makes use of Google Analytics. The last part of the website visitor’s IP address is masked. We do not share any other details with Google through Google Analytics.

8. Security and measures

We maintain a high level of security with regard to guest data. Guest data is stored incrypted. Access to data by Valk Exclusief employees is based on necessity, given the position of the respective employees (need to know princuple). Periodically Valk Exclusief tests the securoty of its data processing and underlying IT systems. If we outsource data handling processes to third parties, we make agreements with these parties pn adequate security of personal data. The measures taken are in line with applicable privacy laws and regulations. However, absolute (100%) protection of personal data cannot be guaranteed. If – desplite the security measure taken - a security incident takes place, we will take measures to minimize the consequences regarding your privacy.

9. Liability

In view of the aforementioned under point 8, Valk Exclusief cannot be held responsible or liable for illegal, unauthorized or unintended processing and/or access to personal data that cannot be attributed to Valk Exclusief. We are also not responsible for the acts or omissions by third parties with whom we collaborate or to whom we refer on our website(s) or otherwise. He respective third parties are not covered by this Privacy Statements and we therefore advise you to carefully read the pricacy statements of these third parties on the websites. In all the aforementioned cases, Valk Exclusief rejects liability annd there is no right to compensation, performance or any other claim against Valk Exclusief.

Despite the care and attention paid to the management of this website, this site may contain incorrect information. Valk Exclusief cannot be held liable for technical or editorial errors that occur on this website, nor for any consequential damage that is the result of the use or temporary unavailability of this website or the links to third-party websites.

10. Your rights

As a Valk Exclusief guests or as a visitor to one of our website, you can request access, correction, deletion, objection, limitation or transfer of personal data. You also have the right to reverse your granted permission. Any reversed permission is without prejudice to previous processing.

a. Right of access

You have the right to ask Valk Exclusief if we process your personal data. If we do, you have the right to access the respective personal data, the purposes of the processing, any sources or recipients of this personal data besides the retention period.

b. Right to rectification

If it becomes clear that the information is incorrect, you can submit a request to have this corrected.

c. Right to erasure (‘right to be forgotten‘)

You may request us to delete any personal information we collect from you in the following cases:

• the personal data is no longer required for the purposes for which we collected or processed it otherwise;
• if the consent, on which the processing is based, is reversed by you;
• if we process the personal data unlawfully;
• we must delete your personal data, based on a legal obligation;
• we have collected you data through mobile telephony or internet services.

d. Right to restriction of processing

If you have reported an inaccuracy in your personal data to us or if you have objected to the processing, you can request us to restrict the processing, during the time we handle your request. You can also request us to restrict the processing if you believe that we are processing your data unlawfully or that we do not need it any longer for processing purposes and you need it for legal action.

e. Right to data portability

If the processing takes place based on your consent or the processing is carried out throygh automated processes, you can request us to transmit your personal data to you. You can also request us to transmit this data to another controller.

f. Right to object

At all times you have the right to object to the processing of personal data that concern you. This applies in particular to profiles, we have have created based on your personal data or if we use your personal data for direct marketing purposes.

Exercise rights

If you wish to exercise one or more of your rights listed above, this can only be done by sending an email message to the email address of the respective hotel (ssee appendix 1 to the Privacy Statement). Your request must meet the legal requirements. We may require you to identify yourself before we process a request. Valk Exclusief will infor you about its decision within four weeks, unless we inform you within that time period that we will need more time.

Please note that under circumstances or based on applicable (privacy) laws and regulations, Valk Exclusief may refuse to fully or partially comply with your request.

Complaints

If you have a complaint about the use of personal data, you can send it to the aforementioned address or email address. If desired, you can also start a complaints procedure with the Dutch Data Protection Authority. This bodu is authorized to take cognizance of your complaint and may decide to further process the complaint.

11. Contact and identification

For questions, comments or complaints regarding the processing of personal data, you can contact the respective hotel. The contact details can be found in appendix 1 to the Privacy Statement. Please, indicate clearly in the subject title that it is about privacy and what the request is, which allows us to respond within the applicable time frame.

For questions about this Privacy Statement, please contact:

Valk Exclusief
Attn. Privacy coordinator
Winthontlaan 4-6
NL-3526 KV Utrecht
The Netherlands
privacy@valkenhorst.nl

12. Modification of the Privacy Statement

Valk Exclusief may modify the Privacy Statement. Modifications will be published on the websites as mentioned in appendix 1 and they will apply immediately, in full and unabridged to the Valk Exclusief Privacy Policy. Valk Exclusief therefore advises that you check regualrly to see if there are any adjustments.

13. Applicable law and competent court

Dutch law applies to the Privacy Statement. Any disputes between parties will only be submitted to the competent judge of the Midden-Nederland Court.

Latest version May 2019