Version: 1.0., Effective date: Dec. 5, 2019
I. Data Collection
MEWS as data processor
MEWS as data controller
II. Data Processing
MEWS processes your data, if it is necessary for the provision of its services, and generally, in order to fulfil all of its contractual obligations vis-à-vis its customers. Thus, MEWS can process the following data categories:
- Identification details (name, surname)
- Contact details, such as address, phone number, e-mail address
- Booking and accommodation details
- Information about any additional services you order through MEWS Services
- Information about your subscriptions to marketing communication
- Any other information you decide to share with MEWS through MEWS Services
By accessing and using MEWS Services, you enter into an agreement for provision of such services with MEWS. Thelegal ground for processing this data is Article 6 (1) b) GDPR (performance of contract or precontractualrelations). The purposes to process your personal data provision of relevant MEWS Services to you.
MEWS processes all personal data contained within your job application, CV, Cover Letter or any other documents youprovide us with when applying for a position with us. This includes information such as your name, address, contactdetails but as well information about your education, professional history, certifications and any other informationyou include in your application.
MEWS processing of job applications
We can process data for the purpose of evaluation and analysing of the market, monitoring, evaluation, improving andpersonalization of MEWS Services, customizing the content of websites according to your preferences, and as well forprotection of our legal rights. The legal ground for processing this data is legitimate interests of MEWS accordingto Article 6 (1) f) GDPR. When data is processed based on the legitimate interest, we always evaluate whether suchprocessing does not constitute an inadequate interference to your rights.
If you apply for any of our job positions at MEWS or its affiliate through MEWS website or other means, we willprocess the personal data you provide us with for the purposes of evaluating your application and informationcontained therein to assess whether you are a suitable candidate for any of our open positions. The legal ground forprocessing this data is is Article 6 (1) b) GDPR (performance of contract or precontractual relations).. RespectiveMEWS affiliate to which you applied for a job position shall be considered as data controller within the meaning ofArticle 4 (7) GDPR for this purpose.
We may keep you CV in our internal database in order to consider you for future positions at MEWS or its affiliatessubject to your consent according to Article 6 (1) a) GDPR. You can withdraw your consent at any time in your Useraccount or by sending the message to email@example.com.
MEWS may record the calls with its current or potential clients for the purpose of internal quality checks, as wellas for the purpose of handing internal exchange of information about MEWS prospect clients.
When we record the particular phone call between you and MEWS staff, we process the data that are provided by youdirectly during the phone call or data that are collected automatically such as your phone number. You are alwaysnotified about the recording at the beginning of a call and asked to provide your consent. If you do not provide uswith the consent, no recording is made. Also, you can withdraw your consent at any time by sending the message firstname.lastname@example.org.
In some instances, legal regulations impose obligations on us under which we are obliged to process personal data,such cases are for instance tax and accounting laws and provision of some data to public authorities based on law.Thus, we can process your data for the purpose of archiving internal records and fulfilling our legal obligations.Legal ground for processing such data is Article 6 (1) c) GDPR.
III. Cookies on our website
Additionally, cookies help us deliver online advertising that we believe is most relevant to you. Cookies are alsoused for profiling. Cookies can help us to understand how our website is being used, for example, by telling us ifyou get an error messages as you browse. For more information about cookies please visithttp://www.allaboutcookies.org
When you visit our website, you are informed through a cookie banner placed at the bottom of our website that wecollect cookies.
By enabling cookies in your browser, you acknowledge that MEWS may process data for the purposes of website’spersonalization, browsing experience optimalisation, analyzing your website’s behavior and delivering relevantadvertisements to you.
We use the following types of cookies: (i) essential cookies, which are essential for the provision of access to ourwebsites; (ii) functionality cookies, which are crucial for the proper functioning of our websites (if these cookiesare disabled, our website may not work properly); (iii) performance cookies, which do not identify you individually(until you enter your identification details in any of our forms) but help us to personalise your content inaccordance with your actions on our websites; and (iv) targeting/advertising cookies, which help make advertisementsmore relevant to visitors of our website.
If you wish cookies not to be collected, you may restrict, block or delete the cookies at any time by modifying yourbrowser configuration. Although each browser is parameterized differently, cookie configuration is normally locatedon the “Preferences” or “Tools” menu. If you turn off cookies, the functionality of our website may be limited (inthe case of essential cookies you may not be able to access our website).
If you wish to prevent new cookies from being installed or if you wish to delete existing cookies you can find theinstructions on the links below. The exact procedure depends on which browser you are using.
- a) Internet Explorer
- b) Firefox
- c) Google chrome
- d) Safari
IV. Direct Marketing
MEWS may use your data for marketing purposes, i.e. in order to inform you of its services which may, according toyour past preferences, be of interest to you. These communications shall strictly adhere to applicable legalregulations.
Advertising and marketing materials of the Contracting or other parties shall be sent to you only if you opted in forthese communications during the registration process, via e-mail or otherwise.
Your decision about direct marketing may be withheld in accordance with the opt-out rules described in each marketinge-mail or other form of communication. Opting out can be done via changing the settings of your User account or bydirectly contacting MEWS (please see contact details below). Should you opt out, MEWS shall retain only such datanecessary for provision of services in accordance with the rules set out in this policy.
V. Data Retention
MEWS shall not store your personal data for a longer period than what is necessary, given the purposes for which theywere provided or collected. If you create a User account we will process your data for the period of yourregistration with MEWS. Subject to situations set out below, your personal data will be removed once you inform MEWSthat you do not wish to use MEWS’ Services anymore. MEWS shall retain only that of your data serving legitimatepurposes (e.g., some data is required to be retained by legal regulations, some data is necessary to maintain themutual relationship with you – for instance billing purposes, etc.) MEWS shall neither collect an excessive amountof personal data nor other information which is not relevant for the purposes for which the personal data iscollected.
MEWS processing of job applications
Information of personal data of successful applicants are processed and retained in line with our employee privacypolicy. Personal data of unsuccessful applicants that provided us with their consent for considering them for futurepositions at MEWS are processed until the respective consent is withdrawn. Personal data of unsuccessful applicantsthat have not provided us their consent for retaining their personal data are retained for as long as the givenlegitimate interest of Mews to protect itself from legal claims and effectuate the hiring process.
MEWS shall not store data provided by you or collected automatically during the phone calls for a longer period thanwhat is necessary, given the purposes for which they were provided or collected. Moreover, you can withdraw yourconsent to process your data at any time by sending the message to email@example.com,in which case we will remove your data from our system.
VI. Data Sharing and transfer to third countries
Your personal data shall not be shared or provided without your consent to any third party except for the followingsituations: (a) data is necessary for provision of services by MEWS to Contracting Parties (i.e. if you place suchan order where provision of your personal data is indispensable to a Contracting party – e.g., within thereservation process), (b) data is necessary for provision of services by MEWS to you,(c) MEWS is obliged to providethe personal data on the basis of law or upon order by a public authority, or (d) it is specifically allowed byapplicable legal regulations. Should the applicable legal regulations prohibit that, your personal data shall neverbe shared with any third party.
Personal data as described in letter (a) shall be provided exclusively to the Contracting parties enlisted on thewebsite www.mews.com, or to integration providers or other service providers enlisted on hotel website. Thepersonal data is provided to these processors only based on mutually agreed contractual terms safeguarding securityof personal data in line with applicable legal regulations.
Categories of Processors
- data centre, hosting
- marketing tools
- tools for analytics and recording
- tools for running polls or surveys
- business management tools
- task management and communication tools
In order to allow you to manage various reservations made with hotels, MEWS may share your personal data with hotelsfor the sole purpose of making and managing your reservation as well as other services of the hotels available toyou through Mews Services. Sharing of any other personal data or information may be shared with hotels based on yourconsent only.
MEWS processing of job applications
Your personal data shall not be shared or provided without your consent to any third party except for when (a) we useservices and applications of third parties to manage HR processes, whereas these third parties are processors ofyour personal data and act upon instructions of MEWS as the data controller (b) MEWS is obliged to provide thepersonal data on the basis of law or upon order by a public authority, or (c) it is specifically allowed byapplicable legal regulations. Should the applicable legal regulations prohibit that, your personal data shall neverbe shared with any third party.
IX. Data Security
MEWS shall ensure that your personal data is stored securely. Therefore, it has introduced adequate physical,technical and organizational measures and plans to protect and secure all information collected via services ofMEWS.
The aim is to eliminate unauthorized or unlawful processing of your personal data, or accidental, unauthorized orunlawful access, use, transferring, processing, copying, transmitting, alteration, loss or damage of your personaldata. Despite all efforts and meeting all rules set out by applicable legal regulations, it is not possible toguarantee the security of your data, if it is transferred or transmitted in an unsecured way.
MEWS protects your data in particular in the following ways:
- Using cryptography, where necessary
- Using password protection, where necessary
- Restricting access to your personal data (i.e. access to your personal data is granted only to those employees or personnel of MEWS for whom the access is indispensable for the purposes described herein).
These measures do not deprive you from your duties to undertake proper steps in order to secure your own personaldata. You should, inter alia, regularly change your passwords. On the other hand, you should not, inter alia, usepredictable usernames and/or passwords, share your password with other persons, or grant access to your user accountand/or disclose your personal data to other persons. MEWS will never ask you for your password in any unsolicitedcommunication. Please notify our data protection officer immediately of any unauthorized use of your accountcredentials or any other suspected breach of security.
X. Your rights
Where EU General Data Protection Regulation 2016/679 (“GDPR”) applies to the processing of your personal data you areentitled under the GDPR to the following rights:
Right of access
You are entitled to be informed inter alia about what personal data MEWS processes about you, for what purposes, whoare the recipients of your personal data.
Right to rectification
You have a right for any of your incomplete, inaccurate or out-of-date personal data to be rectified.
Right to erasure (‘right to be forgotten’)
You are entitled to erasure of personal data that we have collected and processed about you.
Right to restriction of processing
In given cases such as when we process inaccurate personal data about you or you deem the processing as no longernecessary you may ask for a restriction of the processing.
Right to data portability
You have a right to receive personal data you provide us with in a structured, commonly used and machine-readableformat and have it transmitted to another controller where technically feasible.
Right to object
You are entitled to object, on grounds relating to your particular situation, at any time to processing of personal data that concerns you and is carried out in public interest or for the purposes of legitimate interests pursued by MEWS, including profiling.
The exercise of your rights may be limited shall MEWS be obliged to keep any of your personal data for the purpose of compliance with legal obligations, for the establishment, exercise or defence of legal claims or any other compelling reasons as provided by the relevant data protection law.
Should you wish to exercise any of your rights you may contact our data protection officer at firstname.lastname@example.org.
XII. Contact Details
Please help MEWS ensure that your data is up-to-date. If you believe that some of the data processed by MEWS isincorrect, please contact MEWS at email@example.com.