The Borealis Hotel Group Privacy Statement

Thank you for visiting our website and your interest in our company. The protection of your personal data is important to us. Pursuant to Articles 12, 13, 14 and 21 of the General Data Protection Regulation (GDPR), this policy explains how your personal data is handled when you use our website https://www.borealishotelgroup.com (hereinafter referred to as the “website”).

Personal data are individual details about personal or factual circumstances of a specific or identifiable natural person. This includes information such as name, address, telephone number and date of birth.

1 Controller

Controller within the meaning of the General Data Protection Regulation:

Borealis Hotel Group B.V.

Strawinskylaan 3051

1077ZX, Amsterdam, The Netherlands

Email: info@borealishotelgroup.com

Homepage: www.borealishotelgroup.com

Phone: +31 (0) 20 301 22 55

2 Data protection officer

Contact details of our data protection officer:

Our in-house data protection officer can be contacted at the above address, Data Protection Department, or by email at: privacy@borealishotelgroup.com

3 Purposes and legal bases for data processing

3.1 Use of the website for information purposes

You can visit our website without providing any additional personal information. If you only use our website for informational purposes, i.e. you do not otherwise provide us with any information about yourself, we do not process any personal data, with the exception of the data that your browser transmits to enable you to visit the website and information that is transmit-ted to us as part of cookies used for statistical analysis of the use of our website.

3.1.1 Technical provision of the website

For the purpose of the technical provision of the website, it is necessary that we process certain automatically transmitted information from you so that your browser can display our website and you can use the website. This information is automatically collected each time you visit our website and stored in our server log files. This information relates to the computer system of the accessing computer.

Furthermore, we use Cookies to enable you to use our website. Cookies are text files that are stored in the internet browser or by the internet browser on your computer system in the case of visiting a website. A Cookie contains a character string that facilitates a clear identification of the browser when the website is revisited. We use Cookies exclusively to make our website available with its technical functions. Some functions of our website cannot be made available without the use of Cookies.

We do not use your information that we have collected via the above Cookies to create user profiles or evaluate your surf behavior.

We process your personal data for the technical provision of our website on the following legal bases:

  • for the performance of a contract or the implementation of pre-contractual measures in accordance with Art. 6 para. 1 lit. b GDPR, insofar as you visit our website to obtain information about us; and
  • to protect our legitimate interests in accordance with Art. 6 para. 1 lit. f GDPR in order to be able to make the website technically available to you. Our legitimate interest is to be able to provide you with an attractive, technically functioning and user-friendly website, as well as to take measures to protect our website against cyber risks and to prevent cyber risks for third parties arising from our website.

3.1.2 Consent Management

On our website we use the consent manager “Cookiebot” of Usercentrics A/S, Havnegade 39, 1058 Copenhagen, Denmark. Cookiebot is a solution that we use to obtain your consent for certain data processing that requires your consent (e.g. analysis, tracking or similar). By using Cookiebot, we can inform you about the individual cookies and tools we use. You can use Cookiebot to choose which cookies and tools you want to categorically allow or reject. At the end of this privacy policy, Cookiebot also provides an overview of the cookies used and the option to change or revoke your consents. This allows you to make an informed decision about the sharing of your data and enables us to use cookies and tools in a transparent and documented manner that complies with data protection requirements.

Cookiebot processes your personal data to record your decision to allow cookies and tools and to store it for a revisit to our website. This includes the corresponding cookie with your consent decision as well as further usage data, e.g. IP address, domain name, time of request, server data (including data transmission types, server status, etc.), country, browser and operating system.

For further information and the privacy policy of Cookiebot, please visit: https://www.cookiebot.com/en/privacy-policy/.

We process your personal data for the technical provision of our website on the following legal bases:

  • for the performance of a contract or the implementation of pre-contractual measures in accordance with Art. 6 para. 1 lit. b GDPR, insofar as you visit our website to obtain information about us;
  • for the use of cookie management in order to comply with a legal obligation to which we as Controller are subject in accordance with Art. 6 para. 1 lit. c GDPR. The legal obligation lies in informing you about the cookies we use and obtaining and documenting your consent to data processing; and
  • to protect our legitimate interests in accordance with Art. 6 para. 1 lit. f GDPR in order to be able to make cookie management technically available to you. Our legitimate interest is to be able to provide you with an attractive, technically functioning and user-friendly cookie management, as well as to take measures to protect the cookie management from cyber risks and to prevent cyber risks for third parties arising from the cookie management.

3.2 Statistical analysis of the use of the website and range increase

For the purpose of statistical analysis of the use of our website, we use Google Analytics, and thus cookies, which enable an analysis of your surfing behavior. This allows us to improve the quality of our website and its content. We learn how the website is used and can thus constantly optimize our services.

The information obtained through the statistical analysis of our website will not be merged with your other data collected through the website.

We process your personal data for the statistical analysis of the use of our website on the basis of the following legal basis:

  • Your consent in accordance with Art. 6 para. 1 lit. a GDPR.

3.2.1 Google Analytics 4 with server-side tracking

On our website we use Google Analytics 4 (“Google Analytics”), a web analytics service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Google Analytics uses “cookies”, which are text files placed on your computer, to help the website analyze how users use the site. As part of the integration of Google Analytics, we use so-called “server-side tagging”. Here, a server is placed between the collection by us and the transmission to Google. The server acts as a protective buffer. By activating this server, Google has no direct access to our website and our users’ data. In this way, we ensure that no personal data is transmitted directly from our website to Google. In Google Analytics 4, the anonymization of IP addresses is activated by default. The IP address transmitted by your browser as part of Google Analytics will not be merged with other Google data.

We process your personal and non-personal data for analysis on our website on the following legal basis:

  • Your consent in accordance with Art. 6 para. 1 lit. a GDPR for the initial storage and reading of data as well as further data processing (e.g. analysis).

Once you have given your consent, you can revoke it at any time for the future by preventing the storage of cookies by setting your browser software accordingly. However, we would like to point out that in this case you may not be able to use all the functions of our website to their full extent.

You can configure your browser settings by downloading and installing the browser plugin available at the following link: http://tools.google.com/dlpage/gaoptout?hl=de or you can call up the Consent Manager again via the menu item “Cookie settings” and remove the tick you have set for consent under the respective category and then confirm the setting.

You can find more information on the terms of use and data protection of Google Analytics at http://www.google.com/analytics/terms/de.html or at https://www.google.de/intl/de/policies

3.2.2 Google Maps

Google Maps, a service of Google Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland, is integrated on our website.

In order to increase the protection of your data when you visit our website, Google Maps is restricted and will only be displayed with your consent. This ensures that no connection is established with Google’s servers when you visit our website and that your data is not transmitted to Google. Only when you consent to the transfer to Google and click on the corresponding button will your browser establish a direct connection to Google’s servers so that you can plan a route, for example. This means that neither we nor Google collect any data from you on our website without your consent.

We process your personal and non-personal data to make it easier for you to navigate to us on our website on the following legal basis:

  • Your consent in accordance with Art. 6 para. 1 lit. a GDPR with regard to the initial storage and reading of data as well as for further data processing (e.g. provision of the function).

Once you have given your consent, you can revoke it at any time for the future, call up the Consent Manager again via the menu item “Cookie settings” and remove the check mark you have set for consent under the respective category and then confirm the setting.

The purpose and scope of the data collection and the further processing and use of the data by Google as well as your rights in this regard and setting options to protect your privacy can be found in Google’s data protection information at https://www.google.com/policies/privacy/partners/?hl=de

3.2.3 Online presence in social media

We maintain online presences within social networks and platforms in order to communicate with our customers, interested parties and users active there and to inform them about our services. Furthermore, user data is generally processed for market research and advertising purposes. For example, usage profiles can be created from the usage behavior and the resulting interests of the users.

The usage profiles can in turn be used, for example, to place advertisements inside and outside the platforms that presumably correspond to the interests of the users. For these purposes, cookies are generally stored on the user’s computer, in which the user’s usage behavior and interests are stored. Furthermore, data can also be stored in the user profiles independently of the devices used by the users (especially if the users are members of the respective platforms and are logged in to them).

We process your personal data on the following legal basis:

  • to protect our legitimate interests in accordance with Art. 6 para. 1 lit. f GDPR in order to be able to effectively inform users and communicate with users.
  • If users are asked by the respective providers to consent to data processing (i.e. to give their consent, e.g. by ticking a checkbox or confirming a button), the legal basis for processing is Art. 6 para. 1 lit. a., Art. 7 GDPR. For a detailed description of the respective processing and the opt-out options, please refer to the information provided by the providers linked below.

In the case of requests for information and the assertion of user rights, we would also like to point out that these can be asserted most effectively with the providers. Only the providers have access to the users’ data and can take appropriate measures and provide information directly. If you still need help, you can contact us.

3.3 Active use of the website

In addition to the purely informative use of our website, you can also actively use our website to send an application or to contact us. In addition to the processing of your personal data described above for purely informational use, we will then also process further personal data from you.

3.3.1 User enquiries

In order to be able to process and respond to your requests to us, e.g. via the contact form, or to our e-mail address, we process the personal data from you that you provide in this context. In any case, this includes your name and your e-mail address in order to send you an answer, as well as the other information you send us as part of your communication.

We process your personal data to respond to user requests on the basis of the following legal bases:

  • to protect our legitimate interests in accordance with Art. 6 para. 1 lit. f GDPR; our legitimate interest is the appropriate response to customer requests;
  • If the request is aimed at concluding a contract, the additional legal basis is Art. 6 para. 1 lit. b GDPR.

3.3.2 Sending an application

We will process your personal data in the context of your application insofar as you provide this data to us. Please note that for job applications, separate privacy policies are provided on our dedicated recruitment portals / websites for both Belgium and the Netherlands and Germany which can be found under “Careers” on our website. Therefore, for detailed information on how your personal data is handled during the application process, please refer to the specific privacy notices available there.

3.3.3 Compliance with legal obligations

We also process your personal data in order to fulfil other legal obligations. These may affect us in connection with the processing of the order or business communication, among other things. These include, in particular, retention periods under commercial, trade or tax law.

We process your personal data on the following legal basis:

  • for the fulfilment of a legal obligation to which we are subject in accordance with Art. 6 para. 1 lit. c GDPR in connection with commercial, trade or tax law, insofar as we are obliged to record and store your data.

3.3.4 Law enforcement

We also process your personal data in order to be able to assert our rights and enforce our legal claims. We also process your personal data in order to be able to defend ourselves against legal claims. Finally, we process your personal data to the extent necessary to prevent or prosecute criminal offences.

We process your personal data for this purpose on the following legal basis:

  • to protect our legitimate interests in accordance with Art. 6 para. 1 lit. f GDPR, insofar as we assert legal claims or defend ourselves in legal disputes or prevent or investigate criminal offences.

3.3.5 Company sale/merger, etc.

We may process your personal data in order to complete a (partial) business sale or merger (or similar process such as acquisition in liquidation, insolvency, dissolution, etc.) with another company. In the event that another company acquires or intends to acquire the assets, which may include your personal data, from us or we carry out or seek to carry out a merger with another company, we may need to grant that company access to or transfer your personal data stored with us for the purpose of reviewing and carrying out the sale of the company/merger (e.g. to determine the value of the company or business risks, to transfer the data/assets, etc.).

In doing so, we process your personal data on the following legal basis:

  • to safeguard our legitimate interests pursuant to Art. 6 para. 1 lit. f GDPR, in order to be able to organize and implement a planned company sale or merger.

4 Links

Some sections of our websites contain links to third-party websites. These websites are subject to their own data protection policies. We are not responsible for their operation, including their data handling practices. If you send information to or through such third-party sites, you should review their privacy policies before sending them any information that can be attributed to you.

5 Categories of recipients

Initially, only our employees receive knowledge of your personal data. In addition, we share your personal data with other recipients who provide services for us in connection with our website, insofar as this is permitted or required by law. We limit the disclosure of your personal data to what is necessary. In some cases, our service providers receive your personal data as data processors and are then strictly bound by our instructions when handling your personal data. In some cases, the recipients act independently with the data that we transfer to them.

Below we list the categories of recipients of your personal data:

  • Service Provider for administration and operation of the website;
  • IT service provider for the hosting of our website;
  • Public bodies and institutions insofar as we are legally obliged to do so;
  • Other categories of recipients, if applicable.

We can also exchange your personal data within our company group operating across Europe, e.g. with subsidiaries which require this data to fulfil our contractual and legal obligations or on the basis of our legitimate interests. These may involve economic, administrative or other internal commercial purposes; this shall only apply if not overridden by your interests or fundamental rights and freedoms.

6 Transfer to Third Countries

If personal data is transferred to service providers or group companies outside the European Economic Area (EEA), the transfer will only take place if the third country has been confirmed by the EU Commission to have an adequate level of data protection or if other appropriate data protection guarantees (e.g. the agreement of EU standard contractual clauses) are in place.

7 Duration of storage

7.1 Informational use of the website

In terms of the use of our website for purely informational purposes, we initially store your personal data on our servers only for the duration of your visit to our website. This personal data is deleted without undue delay as soon as you leave our website.

Cookies installed by us are usually also deleted after you leave our website. However, this does not apply to cookies from Google, for example. These cookies may remain stored for a longer period of time. If you have a Google account, the data may also be stored for a longer period. In certain cases, the storage period can also be reset and restarted when you visit the website again. The cookies we use and the respective storage periods can be found at the end of this privacy policy. In addition, you have the option to delete installed cookies yourself at any time or to revoke your consent via the consent management at the end of this privacy policy.

7.2 Active use of the website

When you actively use our website, we initially store your personal data for the duration of the response to your request or for the duration of our business relationship. This also includes the initiation of a contract (pre-contractual legal relationship) and the processing/performance of a contract.

In addition, we store your personal data until any legal claims arising from the relationship with you expire so that we can use them as evidence if necessary. We delete your personal data when the statute of limitations expires, unless there is a legal obligation to retain it.

8 Your rights as data subject

You are entitled to the following rights as a data subject, which you can assert against us, subject to the legal requirements:

Right to access: You are entitled to request confirmation from us at any time within the scope of Art. 15 of the GDPR as to whether we are processing personal data relating to you; if this is the case, you are also entitled within the scope of Art. 15 of the GDPR to receive information about this personal data as well as certain other information (including processing purposes, categories of personal data, categories of recipients, planned storage period, the origin of the data, the use of automated decision-making and, in the case of third country transfers, the appropriate safeguards and a copy of your data).

Right to rectification: In accordance with Art. 16 GDPR, you are entitled to demand that we correct the personal data stored about you if it is inaccurate or incorrect.

Right to erasure: You have the right, under the conditions of Article 17 GDPR, to demand that we delete personal data relating to you without delay. The right to deletion does not apply, inter alia, if the processing of the personal data is necessary for (i) the exercise of the right to freedom of expression and information, (ii) compliance with a legal obligation to which we are subject (e.g. legal obligations to retain records) or (iii) the assertion, exercise or defense of legal claims.

Right to restriction of processing: You are entitled to demand that we limit the processing of your personal data under the conditions of Art. 18 GDPR.

Right to data portability: You are entitled, under the conditions of Art. 20 GDPR, to demand that we hand over to you the personal data concerning you that you have provided to us in a structured, common and machine-readable format.

Right to withdraw consent: You have the right to revoke your consent to the processing of personal data at any time with effect for the future. The lawfulness of the processing carried out on the basis of the consent until the revocation is not affected.

Right to object: You have the right to object to the processing of your personal data under the conditions of Art. 21 GDPR, so that we have to stop processing your personal data. The right to object only exists within the limits provided for in Art. 21 GDPR. In addition, our interests may conflict with the termination of processing, so that we are entitled to process your personal data despite your objection.

Right to lodge a complaint with a supervisory authority: You have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your place of residence, place of work or place of the alleged infringement, under the conditions of Article 77 GDPR, if you consider that the processing of personal data concerning you infringes the GDPR. The right of complaint is without prejudice to any other administrative or judicial remedy.

The supervisory authority responsible for us is:

Autoriteit Persoonsgegevens
(Dutch Data Protection Authority)

Postbus 93374

2509 AJ Den Haag, The Netherlands

Email: info@autoriteitpersoonsgegevens.nl

Phone: +31 70 888 8500

However, we recommend that you always send your complaint to our data protection officer in the first instance.

Where possible, you should send requests to exercise your rights to the above address under Item 1 or directly to our data protection officer. 

Right to object (Article 21 GDPR)

You have the right to object, on grounds relating to your particular situation, at any time to processing of your personal data which is based on Art. 6 para. 1 lit. f GDPR (data processing based on a balance of interests, or Art. 6 para. 1 lit. e GDPR (data processing in the public interest). This also applies to profiling (Art. 4 para. 4 GDPR) based on these provisions.

If you make an objection, we will no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims.

In individual cases, we also process your data for the purpose of direct advertising. If you do not wish to receive any advertising, you are entitled to object to this at any time; this also applies to profiling if this is in conjunction with such direct advertising. We shall comply with this objection for the future.

We will no longer process your data for the purposes of direct advertising if you object to processing for these purposes.

Objections can be informal and should be sent where possible to the address stated under Item 1.

9 Scope of your obligations to provide data

In principle, you are not obliged to provide us with your personal data. However, if you do not do so, we will not, for instance, be able to make our website available to you, respond to your enquiries, provide you with information, etc. or enter into a contract with you. Personal data that we do not absolutely need for the above-mentioned processing purposes are marked as voluntary by “if applicable” or another sign.

10 Automated Decision Making / Profiling

We do not use automated decision making or profiling (an automated analysis of your personal circumstances).

11 Amendments

We reserve the right to amend this privacy statement at any time. Any changes will be announced through the publication of an amended privacy statement on our website. Unless provision is made otherwise, such changes will be effective immediately. Please check this privacy statement regularly to see the most up to date version.

Last updated: October 2024

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