I. Data Collection
MEWS offers MEWS Navigator, an application through which you can use complementary services provided by MEWS and obtain effective access to tailored offers for hoteling and other services for your travel (hereinafter “MEWS Navigator”). In order to access the MEWS Navigator you must create a user account in MEWS Navigator and you must provide MEWS with certain personal data required for the registration process („User account“). The data provided to MEWS within registration process and further data provided by you to MEWS Navigator shall be further processed by MEWS as data controller.
II. Purpose of 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 obligations vis-à-vis its customers.
MEWS may process your personal data for the purpose of providing various services through MEWS Navigator in accordance with applicable terms and conditions including in particular:
- Registration and creation of User account and granting access to services of MEWS;
- Online check-in with hotels
- User data management
- Provision of information about user reservation and hotel
- Communication via in-app messenger
- Finalisation of online check in through QR code.
MEWS may further process personal data for the following purposes
- Evaluation and analysis of the market;
- Monitoring, evaluation, and enhancing the quality of services provided by MEWS; and
- Archiving of internal records.
MEWS processing of job applications
If you apply for any of our job positions through our website or other means we will process the personal data you provide us with for the purposes of evaluating your application and information contained therein to assess whether you are a suitable candidate for any of our open positions. Respective MEWS affiliate to which you applied for a job position shall be considered as data controller for this purpose.
Should you express your consent thereto, we will keep you CV in order to consider you for future positions at MEWS or its affiliates.
III. Data Categories
MEWS may process various personal data within MEWS Navigator for the purposes set out above, including:
- Contact details, such as name, address, phone number, e-mail address
- Information from your User account
- Reservation, online check in/check/out information
- Information about any additional services you order through MEWS Navigator
- Information about your subscriptions to marketing communication
- Communication with hotels through a built-in messenger app
- Any other information you decide to share with MEWS or hotels through MEWS Navigator
MEWS processing of job applications
Mews processes all personal data contained within your job application, CV, Cover Letter or any other documents you provide us with when applying for a position with us. This includes information such as your name, address, contact details but as well information about your education, professional history, certifications and any other information you include in your application.
IV. Legal Basis
Mews processes personal data on various legal basis.
Performance of contract or precontractual relations – if you create a User account with MEWS Navigator, you enter into an agreement for provision of services with MEWS. For MEWS to be able to provide you with services you request, MEWS processes your personal data within the MEWS Navigator. If you apply for any job position at MEWS or its affiliate your data is processed based on precontractual relationship between you and MEWS.
Consent – some additional information you input in MEWS Navigator is only processed and shared with hotels based on your consent. As well based on your consent we will keep you CV in order to consider you for future positions.
Legitimate interests of Mews - we process data based on our legitimate interest for analysing, improving and personalization of MEWS services and as well for protection of our legal rights. When data is processed based on the legitimate interest, we always evaluate whether such processing does not constitute an inadequate interference to your rights.
Legal obligations – 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.
V. Direct Marketing
MEWS may use your data for marketing purposes, i.e. in order to inform you of its services which may, according to your past preferences, be of interest to you. These communications shall strictly adhere to applicable legal regulations.
Advertising and marketing materials of the Contracting or other parties shall be sent to you only if you opted in for these 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 marketing e-mail or other form of communication. Opting out can be done via changing the settings of your User account or by directly contacting MEWS (please see contact details below). Should you opt out, MEWS shall retain only such data necessary for provision of services in accordance with the rules set out in this policy.
VI. Data Retention
MEWS shall not store your personal data for a longer period than what is necessary, given the purposes for which they were provided or collected. If you create a User account we will process your data for the period of your registration with MEWS Navigator. Subject to situations set out below, your personal data will be removed once you inform MEWS that you do not wish to use MEWS’ services anymore. MEWS shall retain only that of your data serving legitimate purposes (e.g., some data is required to be retained by legal regulations, some data is necessary to maintain the mutual relationship with you – for instance billing purposes, etc.) MEWS shall neither collect an excessive amount of personal data nor other information which is not relevant for the purposes for which the personal data is collected.
MEWS processing of job applications
VII. 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 following situations: (a) data is necessary for provision of services by MEWS to Contracting Parties (i.e. if you place such an order where provision of your personal data is indispensable to a Contracting party – e.g., within the reservation process), (b) data is necessary for provision of services by MEWS to you, (c) MEWS is obliged to provide the personal data on the basis of law or upon order by a public authority, or (d) it is specifically allowed by applicable legal regulations. Should the applicable legal regulations prohibit that, your personal data shall never be shared with any third party.
Personal data as described in letter (a) shall be provided exclusively to the Contracting parties enlisted on the website www.mewssystems.com, or to providers of infrastructure enlisted on the hotel website. The personal data is provided to these processors only based on mutually agreed contractual terms safeguarding security of personal data in line with applicable legal regulations.
Categories of Processors
- data centre, hosting
- marketing tools
- analytical tools
- 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 hotels for the sole purpose of making and managing your reservation as well as other services of the hotels available to you through Mews Navigator. Sharing of any other personal data or information may be shared with hotels based on your consent 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 use services and applications of third parties to manage HR processes, whereas these third parties are processors of your personal data and act upon instructions of MEWS as the data controller (b) MEWS is obliged to provide the personal data on the basis of law or upon order by a public authority, or (c) it is specifically allowed by applicable legal regulations. Should the applicable legal regulations prohibit that, your personal data shall never be shared with any third party.
VIII. 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 of MEWS.
The aim is to eliminate unauthorized or unlawful processing of your personal data, or accidental, unauthorized or unlawful access, use, transferring, processing, copying, transmitting, alteration, loss or damage of your personal data. Despite all efforts and meeting all rules set out by applicable legal regulations, it is not possible to guarantee the security of your data, if it is transferred or transmitted in an unsecured way.
MEWS protects your data 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 personal data. You should, inter alia, regularly change your passwords. On the other hand, you should not, inter alia, use predictable usernames and/or passwords, share your password with other persons, or grant access to your User account and/or disclose your personal data to other persons.
IX. Your rights
Where EU General Data Protection Regulation 2016/679 (“GDPR”) applies to the processing of your personal data you are entitled 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, who are 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 longer necessary 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-readable format 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 email@example.com.
XI. Contact Details
Please help MEWS ensure that your data is up-to-date. If you believe that some of the data processed by MEWS is incorrect, please contact MEWS at firstname.lastname@example.org.