Privacy Policy

INTRODUCTION

Sofitel Philippine Plaza Manila respects your privacy and recognize the need for appropriate measures to protect and manage your personal data entrusted to us. Our Privacy Policy follows, and is consistent with, the Data Privacy Act of 2012 (DPA), its Implementing Rules and Regulations (IRR), other issuances of National Privacy Commission (NPC), as well as other relevant laws of the Philippines.
Personal data refers to all types of personal information, sensitive personal information and privileged information. Personal information refers to “any information, whether or not recorded in any form, from which the identity of an individual is apparent or can reasonably and/or directly be ascertained by the entity holding the information, or, when put together with other information, would directly and certainly identify an individual”.

This Privacy Policy pronounces how Sofitel process (how it collects, uses, shares, and keeps) and protect your personal data. It also provides the steps that you can take should you wish for any change in how we use your personal data, or if you want us to stop using your personal data.

Why do we collect your personal data?
To enable us to comply with our corporate policies in relation to data subjects as well as with the requirements under the Data Privacy Act, it is important that we collect, use, store and retain your personal data only as is reasonable and necessary for a declared and specific purpose stated in the pertinent consent forms.
In general, we are using your data for any of the following purposes:
 To properly deliver our services and continuously serve your interests.
 To consider your potential as an accredited supplier of the Company; and
 To consider your potential employment or application for internship or student assistantship program with the Company and be able to perform recruitment processes;

Other uses by nature of our transactions
In addition from the general uses mentioned above, we may use your personal information depending on your transactions with us in any of the following means:

A.) When you are a customer:

 Properly respond to your inquiries;
 Process your reservation in a timely manner;
 Contact you for matters relating to your event booking, restaurant reservation, spa and recreation arrangements and/or room reservation;
 Take into account your preferences and special requests for your event, dining, massage or treatment, and/or room reservation;
 Process your check-in registration;
 Process your membership registration to Le Club;
 Process your request for airport transportation and notify the transportation vehicle of the details of your flight;
 Evaluate your suitability for spa treatments and services;
 Provide assessments and recommendations for appropriate treatments/medical procedures;
 Enroll your details in Sofitel’s database and apply changes when required;
 Identify and address your areas of concern;
 Process your payments and any refund request;
 Perform business functions such as reviews and approvals; and
 Comply with the requirements of audit and privacy compliance assessments/review

B.) When you want to become a part of our team:

 Consider and evaluate your suitability for employment and, with your permission, inform and consider you for future job opportunities that may be of interest to you;
 Communicate with you about your employment application;
 Recommend you to any hotel partner where you will be interested on applying to;
 Consider and evaluate your suitability for internship or student assistantship and, with your permission, inform and consider you for future job opportunities that may be of interest to you;
 Communicate with you about your internship/student assistantship application;
 For performance evaluation of the interns/student assistants including training and development monitoring; and
 Comply with the requirements of audit and privacy compliance assessments/review.

C.) When you are a vendor, a potential vendor, or a contractor:

 Evaluate your capability as a potential accredited supplier of Sofitel;
 Enroll details in Sofitel’s database and apply changes when required;
 Enable us to process orders and payments for your products/services;
 Comply with legal and regulatory requirements obligations;
 Perform such other processing or disclosure that may be required under laws and regulations;
 Perform business functions such as reviews and approvals; and
 Comply with the requirements of audit and privacy compliance assessments/review

What type of personal data do we collect?
We collect information to provide you with details and information regarding our product, services, and promotions. We process information also to respond to your enquiries or manage future interactive user function. The common type of data collected by Sofitel from you generally includes the following:

 Personal information such as full name, nickname, home addresses/billing address/shipping address, e-mail address, employment information, telephone, other personal contact numbers, username and password;
 Sensitive personal information such as age, nationality, marital status, gender, health restrictions, health, and government issued identification/documents which include identity (ID) cards, licenses, and social security number;
 Employment record such as educational background, employment history, certifications, trainings attended, evaluation, resume and income information of your previous jobs;
 Financial details such as credit history, bank account, credit card, and debit card information you have provided as a result of our transaction;
 Requests, interests, and/or preferences;
 Time and date of arrival and departure;
 Flight details; and
 Any feedback regarding your visit or stay in our hotel and/or any of our outlets.

You are responsible for ensuring that all data you submit to Sofitel, whether personal information or sensitive personal information, is accurate, complete, and up-to-date.

How do we collect, acquire, or generate your data?
We collect data when you:
 Fill-out our data collection forms:
 Enter your data in TrustYou, our survey platform;
 Disclose your personal information through phone calls, emails, SMSs, or verbal communication with our authorized representatives; and,
 Through third parties .

Do our websites use web analytics?
All our websites engage third-party service providers to analyze the web traffic data for us. This service does use cookies or web beacons.

Cookies are small files that our website puts on your personal computer (PC) to store information about your preferences. Cookies can improve your browsing experience by allowing our website to remember your preferences or letting you avoid signing in each time you visit our website. If you don’t want our website to store cookies on your PC, you can block cookies. But blocking cookies might prevent some pages from displaying correctly, or you might get a message from our website letting you know that you need to allow cookies to view our website.

For you to fully enjoy your visit and browsing experience, only non-identifiable web traffic data are collected and analyzed, including:

 Your internet protocol (IP) address,
 The search terms you used,
 The pages and internal links accessed on our site,
 Demographics (limited to
 The date and time you visited the site, including frequency of visits
 Geolocation,
 Your operating system, and
 Web browser type.

Use the options in your web browser if you do not wish to receive cookies or you wish to set your browser to notify you when you receive cookies. Click on the “Help” section of your browser to learn how to change your cookie preferences. If you disable all cookies, you may not be able to take advantage of all the features of this website.

What about the links to third-party websites?
From time to time, we will provide links to third-party web sites or advertisements which contain links to third-party sites. These links are provided as a service to you and we do not provide any personal data to these websites or advertisers, and, therefore, we will not accept responsibility for their privacy practices. These sites are operated by independent entities that have their own privacy policies which you should review as well. Sofitel’s Privacy Policy does not apply to such other sites or to the use that those entities make of your information. Sofitel has no control over the content displayed on such sites, nor over the measures, if any, that are taken by such sites to protect the privacy of your information.

Who do we share your personal data with?
As a general rule, we are not allowed to share your data to third parties, except in the limited circumstances listed below.
By giving your consent, you authorize Sofitel to disclose your personal data to accredited/affiliated third parties or independent/non-affiliated third parties, whether local or foreign in any of the following circumstances:
 As necessary for the proper execution of processes related to the purposes declared in this Privacy Policy.
 The use or disclosure is reasonably necessary, required or authorized by or under law (such as for criminal investigation, as requested by court of law).
This means we might provide your personal data to the following:
 Our affiliates, subsidiaries, partner companies, organizations, or agencies including their sub-contractors or prospective business partners that act as our service providers and contractors;
 Law enforcement and government agencies;
All third parties with which we share this personal data are required to use your personal data in a manner that is consistent with this Privacy Policy.

However, these companies may only use such personal data for the purposes disclosed in this Privacy Policy and may not use it for any other purpose.

What is our Privacy Policy regarding children?
Sofitel is very sensitive to privacy issues and is especially careful in its communications with children. Sofitel would never directly collect personal data from children without the parent’s consent.

Personal data pertaining to children and collected from their parents are used by Sofitel or other entities that provide technical fulfillment or other services to Sofitel (for example, services intended to improve our services/web sites, and fulfilling requests or administering promotions). These personal data are not sold.

Meanwhile, we urge parents to regularly monitor and supervise their children’s on-line activities.

How do we protect your personal data?
We take reasonable steps to ensure that the personal data we collect, use or disclose are accurate, complete, and up-to-date. We strictly enforce this Privacy Policy within Sofitel and we have implemented technological, organizational and physical security measures to protect your personal data from loss, misuse, modification, unauthorized or accidental access or disclosure, alteration or destruction. We put in effect safeguards such as the following:
 We keep and protect your personal data using a secured server behind a firewall, deploying encryption on computing devices and physical security controls.
 We restrict access to your personal data only to qualified and authorized personnel who hold your personal data with strict confidentiality.
 Any personal data that you provide on the Sofitel Manila website is initially processed and stored by Sofitel Manila using a secured connection, only authorized Sofitel Philippine Plaza Manila personnel can then access and download your personal data from the system.
 We reveal only the last four digits of your credit card numbers when confirming an order. Naturally, we transmit the entire credit card number to the appropriate credit card company during payment processing.
 It is important for you to protect your data against unauthorized access to your password and to your computer. Be sure to sign-off after using a shared computer.

Where and how long do we keep your personal data?
All data are preserved in accordance with the following retention standards:

1. If the data subject has an existing contract and transaction with Sofitel, the information will be retained all throughout the contract period and a maximum of 10 years after its completion.
2. If the data subject has no existing contract but has existing transactions with Sofitel, the information will be retained during the transaction and a maximum of 5 years after its fulfillment.
3. If the data subject has no existing contract and transaction with Sofitel, the information will be retained for a period of a maximum of 2 years.

Personal data are stored in our facilities located in the Philippines and are retained in accordance with the above parameters, industry standards, laws and regulations, unless you request that your personal data be deleted from our systems, databases and hardcopies immediately. Once deleted, your personal data will no longer be searchable or included in anonymous searches and will be completely removed from all the storage location

The Data Privacy Officer may, however, choose not to grant access or correct information based on the request following laws and regulations. He/she will give the individual a written notice that sets out the reason for the refusal.

What if there are changes in our Privacy Policy?
Sofitel may revise this Privacy Policy as the need arises or when dictated by issuances of the National Privacy Commission or any amendment to the Data Privacy Act. Any change to this Privacy Policy shall be duly posted in this website and will take effect immediately. Data subjects are encouraged to periodically check for such updates. Changes shall not be retroactively applied and will not alter how we handle personal data previously collected without obtaining your consent, unless required by law.

How you can access, correct and update the personal data we have about you?
To exercise your rights which include right to access, modify, erase, and object to processing your personal data within a reasonable time after such request or should you have any inquiries, feedbacks on this Privacy Policy, and/or concerns to Sofitel Manila, you may reach us through our “Contact Us” menu in this website: https://www.sofitelmanila.com/contact/, through a written letter, or through an email to our Data Protection Officer (DPO).

Our contact details are as follows:

Data Protection Officer
Ronald Q. Vallesteros
Sofitel Philippine Plaza Manila
CCP Complex, Roxas Blvd., Brgy. 76, Pasay, 1300 Metro Manila
Officer Tel. No.: +632 8573-5477
Email address: Ronald.VALLESTEROS@sofitel.com

You may also lodge a complaint before the National Privacy Commission (NPC). For further details, please refer to NPC’s website: https://privacy.gov.ph/mechanics-for-complaints/.
Any action to a request for correction, erasure and/or objection to process your personal data as it appears in our records is subject to applicable laws and/or the DPA, its IRR and other issuances of NPC.
This Privacy Policy was last amended on April 15, 2018.