Last update on the 29th January 2019
LIRIKOS Invest, s.r.o., Id. No. 03583678, with its registered
office at Koulova 1501/15, Dejvice, 160 00 Praha 6, registered at the Municipal Court in
Prague, Section C, File No. 234092 (hereinafter: “Company”, “Controller”) respects the
which are operated under the MOZART HOTEL GROUP trademark, collect, use or otherwise process
your Personal Data.
IMPORTANT TO KNOW
The hotel you are booking through this website may not probably
owned by LIRIKOS Invest s.r.o or its affiliated companies. Other MOZART HOTEL GROUP hotels
are operated under the cooperation agreements between the LIRIKOS Invest s.r.o and hotel’s
owners. That is why, your Personal Data collected during the stay at the hotel will be
processed by two controllers: the hotel (as the hotel operating company) and LIRIKOS Invest
s.r.o (as the administrator of the website). Purposes of data processing may vary, but in
general it is as follows:
- LIRIKOS Invest s.r.o is processing your Personal Data
because it manages a global booking platform, which allows to synchronize reservations
among the hotels and helps to organize your stay at the hotel, manages a global database
of MJZART HOTEL GROUP guests, and also manages the loyalty program.
- Each hotel is processing your Personal Data for performance
of contractual conditions with you such as reservation, invoicing, payment processing,
performance of marketing activities and to comply with legal obligations such as tourist
taxation and local migration rules.
are applicable to LIRIKOS invest and all the hotels operated under the MOZART HOTEL GROUP
trademark. We will do our upmost to ensure that all hotels comply with the applicable data
The list of the hotels operated under the Mozart Hotel Group trademark is regularly updated
and located at the bottom of the page.
The Company operates in accordance with the Act No. 101/2000
Coll. on the Data Protection and with the Regulation (EU) 2016/679 of the European
Parliament and of the Council, on the protection of natural persons with regard to the
processing of personal data and on the free movement of such data (hereinafter as
This Policy is developed to explain our practices regarding the
Personal Data we collect from you or about you at https://mozart-group.com/
(collectively, the "website").
The most important principles of processing your Personal Data
are lawfulness and transparency, that is why we use Personal Data only if:
- We obtain the consent of the data subject,
- It is necessary for performance of a contract with data
- It is required for compliance with a legal obligation,
- It is necessary in order to protect the vital interest of
the data subject,
- The Company has a legitimate interest in usage of the
For any questions concerning the processing of your Personal
Data, please contact the Company whose contact details stated in clause 16 of this Privacy
and for what purposes we process your Personal Data.
Controller: A legal person,
LIRIKOS Invest, s.r.o., Id. No. 03583678, with its registered office at Koulova 1501/15,
Dejvice, 160 00 Prague 6, registered at the Municipal Court in Prague, Section C, File No.
234092 who determines the purposes and means of the processing of Personal Data and the
company which is operating the hotel where you stay.
Consent of the data subject: means any
freely given, specific, informed and unambiguous indication of the data subject's wishes by
which he or she, by a statement or by a clear affirmative action, signifies agreement to the
processing of Personal Data relating to him or her;
Processor: A natural or legal
person, public authority, agency or other body which processes Personal Data on behalf of
Recipient: A natural or legal
person, public authority, agency or another body, to which the Personal Data are disclosed,
whether a Third Party or not.
Third Party: A natural or legal
person, public authority, agency or body other than the data subject, controller, Processor
and persons who, under the direct authority of the controller or processor, are authorized
to process Personal Data.
Supervisory Authority: An
independent public authority which is established by a Member State pursuant to Article 51
of the GDPR. Specifically, the Office for Personal Data Protection Pplk. Sochora 27, 170 00
Prague 7, Czech Republic, email@example.com, +420 234 665 800
Personal Data: Any information
relating to an identified or identifiable natural person (“Data Subject”). An identifiable
natural person is one who can be identified, directly or indirectly, in particular by
reference to an identifier such as a name, an identification number, location data, an
online identifier or to one or more factors specific to the physical, physiological,
genetic, mental, economic, cultural or social identity of that natural person.
Processing: Any operation or set
of operations which is performed on Personal Data or on sets of Personal Data, whether or
not by automated means, such as collection, recording, organization, structuring, storage,
adaptation or alteration, retrieval, consultation, use, disclosure by transmission,
dissemination or otherwise making available, alignment or combination, restriction, erasure
MOZART HOTEL GROUP: The Company
and its subsidiaries, including but not limited to PRESIDENT MANAGEMENT Kft.
(Hungary); CIFCON GmbH (Austria); LIRIKOS Invest s.r.o. (Czech Republic) based in the
European Economic Area (EEA), but also foreign subsidiaries which are operating hotels under
the MOZART HOTEL GROUP trademark in other countries outside of EEA.
Standard Contractual Clauses: Sets
of standard contractual clauses for transfers as adopted by the European Commission for the
international transfer of Personal Data.
Personal Data Breach: A breach of
security leading to the accidental or unlawful destruction, loss, alteration, unauthorized
disclosure of, or access to, Personal Data transmitted, stored or otherwise processed.
2. Personal Data that we collect and process
The Company collects and processes your Personal Data only where
permitted by law. We only collect Personal Data relevant for the purpose described in this
Personal Data may include:
2.1.In the case of online reservation the Company requests/can
request that the Guest makes the following data available:
- title (optional)
- first name,
- last name;
- address (address, town, post code, country)
- e-mail address;
- phone number;
- mobile phone number (optional)
- type of credit card / debit card;
- number of credit card / debit card,
- name of credit card / debit card holder;
- expiry date of credit card / debit card;
- CVC/CVV code of credit card / debit card (in case of
MasterCard: Card Validation Code(CVC2), in case of Visa International: Card Verification
2.2.Upon using hotel services, Guests shall fill in a hotel
registration card, in which they agree with processing of their Personal Data. The Company
shall manage such data in order to fulfil its obligations prescribed in the relevant legal
regulations (particularly regarding the laws related to immigration control and tourism tax)
as well as to verify the completion of services and/or to identify the Guests for as long as
required by the competent authority to manage the fulfilment of obligations as defined in
the given laws:
- first name and surname
- citizenship (exclusively for statistical purposes, with the
managed data not able to be traced back to the specific person)
- place and date of birth.
The law prescribes the management of the
following data with regard to citizens of third countries:
- natural personal identification data, and additionally,
- identification data of the travel document (passport)
- address of the hotel
- beginning and ending date of the hotel stay
- visa number, certificate of registration,
- time and place of entry into the country.
Citizens of third countries: All persons who
are not citizens of a member state of the European Economic Area, including displaced
persons. Member states of the European Economic Area are:
- member states of the European Union;
- Iceland, Liechtenstein and Norway as participating member
- as well as Switzerland, as a state with similar legal
Providing the required data by the Guests is
a precondition for using hotel services. By signing the registration card, Guests consent to
the Company processing the personal data provided by filling in the registration card in
order to verify that the contract was concluded and/or performed, as well as to possibly
2.3.For room reservations, the Company can
only use the given bank card, credit card and bank account data to such an extent and for
5-year period as necessary for the exercise of rights and fulfilment of obligations. Data is
handled by the Company's contractual bank partners. Information about their data handling
policies can be found on the websites of the competent Bank. On request, the Company will
inform the Guests of specific Bank.
2.4.Also we may ask for information about
your joint travelers, including their names and additional information. We may also collect
information such as in-app messages and SMS.
In addition to the information we collect
from you directly, we may also infer information about you based on the information you
provide to us or from Other Information we collect.
3. Personal Data collected from third parties
It is important for us to keep your Personal Data up to date and
accurate at all times, why we may import Personal Data about you from external sources such
as public registers. When the law requires that consent be obtained for the processing
of certain types of Personal Data or for certain forms of processing, consent will be
obtained from you before processing takes place.
We may also collect information about you from third parties,
including information from airlines, payment systems and other partners; from online social
services consistent with your settings on such services; and from other third-party sources
that are lawfully entitled to share your data with us. The Company uses and shares this
information only for the purposes described in the relevant contracts with the third parties
which are contractually obligated to protect your Personal Data. We will do our upmost to
ensure that all of our partners comply with the applicable data protection laws and this
4. Use of collected Personal Data
We use your Personal Data in different ways where permitted:
- to improve and personalize the services you expect from MOZART
HOTEL GROUP, to offer you the high level of hospitality in-room and throughout our hotels,
conduct marketing events;
- We use your Personal Data to maintain and improve this
website, websites of our hotels, including improving your online experience and ensuring
content is presented on the websites. To administer the website and for internal
operations, data analytics, research, testing, statistical and survey purposes; as part
of our efforts to keep the website safe and secure;
- We also use your Personal Data to administer the loyalty
program; to fulfil services that are part of such program; to enable direct
communication between hotels within MOZART HOTEL GROUP; and between MOZART HOTEL GROUP
- We may use your Personal Data to provide you with
information about meeting and event planning;
- Where permitted we may use your Personal Data to provide or
offer you hotel services;
- We may use your Personal Data to improve our services and
to ensure that our website, products, and services are of interest to you. We also use
your Personal Data to provide you with the high level of hospitality and services
throughout our hotels.
- We use your Personal Data to notify you about changes to
our services, the website and this Policy.
At our hotel you can benefit from additional services and
facilities, such as breakfast, room service, minibar, pool, restaurants and bars, spa
treatments, laundry services, parking, taxi requests, free Wi-Fi, etc. In the event you make
use of additional services or facilities at the hotel, your Personal Data may be processed
to (i) manage the booking and use of such additional hotel services and/or facilities; (ii)
administer any advance bookings of additional services and/or facilities to your file; (iii)
personalize returning guests’ arrival to the hotel and the choice of room amenities and room
features; and (iv) manage the expenses incurred for such additional services and/or
You are entitled, at any time and without charge, to request us
to refrain from processing your Personal Data for marketing purposes or revoke your consent
thereto. Also, you have a right to get your Personal Data for the further transfer. You may
exercise these rights by contacting us by the address which is stated below.
5. Personal Data we share
MOZART HOTEL GROUP operates in many countries we endeavor to
provide you with the same level of services throughout the world. Thus, we have to share
your Personal Data with other recipients to the following conditions:
1. We share your data with a number of
authorized people and departments within MOZART HOTEL GROUP subsidiaries for the purpose to
offer you the best level of hospitality in our hotels.
The following teams may have access to your
- Hotel staff;
- Reservation staff using hotel reservation tools;
- IT departments;
- Marketing departments;
- Legal services if applicable
In particular, the data related to your
stays, preferences, satisfaction and, if the case may be, your loyalty program membership
are shared between the MOZART HOTEL GROUP hotels. This data is used to improve the quality
of hospitality service and your experience in each of these hotels. In this context, your
data is processed jointly by the Controller and other hotels. In order to pursue this
legitimate interest, whilst safeguarding your rights and liberties, a specific joint
transfer agreement describes the obligations and responsibilities of the Controller and
other MOZART HOTEL GROUP hotels. You may, at any time, object to the sharing of this data
between the hotels by contacting the Controller whose details stated in the clause 16 of
this Policy. You can also request a summary of the key points of the joint transfer
2. With service providers and partners: your
Personal Data may be sent to a third party for the purposes of supplying you with services
and improving your stay, for example:
- External service providers: IT sub-contractors, booking
services, banks, credit card issuers.
We rely on third parties to provide services
and products on our behalf and may share your Personal Data with them as appropriate.
All our service providers are contractually obligated to protect your personal information
and may not otherwise use or share your Personal Data, except as required by law or stated
in the contract.
3. With local authorities: We may be
obliged to send your information to local authorities if this is required by law or as part
of an inquiry. We will ensure that any such transfer is carried out in accordance with local
6. International Data transfers
The Controller may transfer your Personal Data to internal or
external recipients who may be in countries offering different levels of personal data
To provide a necessary level of security and data protection
MOZART HOTEL GROUP employs appropriate measures to ensure secure transfer of your personal
data to the Controllers(hotels) located in a country offering a different level of privacy
from that in the country where the personal data was collected (outside of EEA).
Your data may be sent, in particular as part of the reservation
process, to MOZART HOTEL GROUP hotels located outside of the European Union, in particular
in the following countries: Russia, Ukraine.
In case you wish to obtain more details about our data transfer
safeguards and the mechanisms in place, you may contact us at firstname.lastname@example.org
7. Loyalty Program
The loyalty program of the MOZART HOTEL GROUP is applicable
throughout the hotels of the MOZART HOTEL GROUP. The loyalty program is managed by the
Controller in cooperation with other subsidiaries which are working under the MOZART HOTEL
GROUP trademark. The loyalty program provides you with a number of benefits during your stay
at our hotel, such as gifts, discount for housing, restaurant and massage services. You may
join the loyalty program by filling the registration form at the front desk of any of the
hotel of MOZART HOTEL GROUP. In such context, we may process your Personal Data in order to
be able to i) create your personal account; ii) provide you with information on your current
status in the loyalty program; iii) register your bookings and award points to your
membership card; iv) inform you about your rewards once you reach a certain points level;
and v) inform you about any changes to the loyalty program.
8. Other information
When you visit and interact with the website, the Company
collects information that does not directly identify you about your use of the site, such as
a catalog of the site pages you visit, and the number of visits to our web (“Other
Information”). We use Other Information to deliver you email, online (on our sites and other
sites) and mobile advertisements. The Company may also use Other Information to allow
third-party partners to recognize you as a MOZART HOTEL GROUP’s client when you visit the
partner’s website or app, or to recognize you as one of their customers when you visit
MOZART HOTEL GROUP websites or apps so that they may provide more relevant offers to
Google or Apple, or similar technologies) to relation to its digital services.
The Company uses “Google Analytics”, a web analysis service from
Google, Inc. ("Google"). Google Analytics uses so-called cookies, i.e. text files, which are
stored on your computer and facilitate an analysis of your usage of the website. The data
generated by the cookie relating to your use of this Site (including your IP address) is
usually transmitted to a Google server in the USA, where it is stored. Google uses this data
on behalf of the website operator to evaluate usage of the website, to produce reports on
website activity for the website operator, and to perform further services connected to
website usage and internet usage. Google may also transfer this information to third parties
where required by law or insofar as third parties process this data on behalf of Google.
Under no circumstances will Google associate your IP address with other Google data. You can
prevent the installation of cookies by setting your browser software appropriately; please
note however that, in this case, you will not be able to make full use of the functionality
of our website. By using this website, you agree that the data relating to you which has
been collected may be processed by Google in the aforementioned manner and for the
Because Other Information does not personally identify you, such
information may be disclosed for any purpose where permitted by law. In some
instances, we may combine Other Information with Personal Data. If we do combine any Other
Information with Personal Data, the combined information will be treated by us as Personal
Data in accordance with this Statement.
9. Sensitive information
The term "sensitive information" refers to information related
to your racial or ethnic origin, political opinions, religious or philosophical beliefs,
trade union membership, health, sex life, or sexual orientation, genetic information,
criminal background, and any biometric data used for the purpose of unique identification.
We do not generally collect sensitive information unless it is volunteered by you. We may
use health data provided by you to serve you better and meet your particular needs (for
example, information that you state in the “Notes” section during the reservation
10.Personal Data from minors
We do not knowingly collect personal information from
individuals under 18 years of age. As a parent or legal guardian, please do not allow your
children to submit Personal Data without your permission.
In the event we learn that we have collected Personal Data from
a child under the age of 18 without verification of parental consent, steps will be taken
promptly to remove that information. If you believe that we have or may have information
from or about a child under 18 years of age, please contact us at email@example.com
11.Protection of Personal Data
The Company takes reasonable measures to: (i) protect Personal
Data from unauthorized access, disclosure, alteration or destruction, and (ii) keep Personal
Data accurate and up-to-date as appropriate. We also seek to require our partners and
service providers with whom we share Personal Data to exercise reasonable efforts to
maintain the confidentiality of Personal Data about you.
The Company uses SSL cryptography on its websites for online
reservations. Any information shared by the data subject with the Company, its subsidiaries
or partners shall be encrypted automatically and be protected when transferred through the
network. When the information is received by our server, it is decoded by using an
individual private key. SSL enables the browser to connect to the website and establish a
secure communication channel in a transparent manner. SSL is the most widely used and most
successful cryptographic system. In order to use the system, the data subjects simply need
to verify their browsers' compatibility.
The Company shall ensure transparency to control and establish
how and what personal data are transferred by applying data transferring devices, who and
when entered which data into the system, and shall also make sure that the system can be
restored in the case of a failure. Reports are generated with regard to errors occurring in
the course of automated processing. The Company shall manage personal data confidentially,
and shall not disclose them to unauthorized persons. The Company shall particularly protect
personal data from unauthorized access, modification, transfer, publication, deletion or
destruction as well as from accidental destruction, harm and inaccessibility due to
modification of the applied technology. The Company shall take all security measures in
order to ensure the technical protection of personal data.
For online transactions, we use reasonable technological
measures to protect the Personal Data that you transmit to us via our website.
Unfortunately, however, no security system or system of transmitting data over the Internet
can be guaranteed to be entirely secure.
For your own privacy protection, please do not send payment card
numbers or any other confidential personal information to us via email.
We will not contact you by mobile/text messaging or email to ask
for your confidential personal information or payment card details. In case of receiving a
request about your payment card information by e-mail or SMS, please, do not reply, most
probably you are communicating with swindlers.
We have an Internal regulation regarding GDPR for our personnel
which is available for our guests at the receptions of hotels.
- For the processing of payment card numbers and another
financial data we use services of TravelClick service. For more details you may apply to
- For the collecting of information about your usage of the
- For the purpose of processing emails we use services of
- For the processing of your reviews and comments about
12.Changing, accessing and portability of your Personal
GDPR grants specific rights, summarized below, which you may
exercise free of charge, subject to statutory exceptions. These rights may be limited, for
example if fulfilling your request would reveal Personal Data about another person, or if
you ask us to delete information which we are required by law to keep or have compelling
legitimate interests in keeping.
12.1. Right to withdraw consent
Wherever we rely on your consent, you will be
able to withdraw that consent at any time you choose and at your own initiative on our
website (if you have one) or by contacting us at firstname.lastname@example.org.
Also, in every letter received from us you will find a link to unsubscribe from the
newsletter. The withdrawal of your consent will not affect the lawfulness of the collection
and processing of your data based on your consent up until the moment where you withdraw
your consent. Please note that we may have other legal grounds for processing your data for
12.2. Right to access and rectify your
You have the right to access, review, and
rectify your Personal Data. You may be entitled to ask us for a copy of your information, to
review or correct it if you wish to rectify any information like your name, email address,
passwords and/or any other preferences, you can easily do so by logging in to your account
on our website (if you have one) or by contacting us at email@example.com. You may
12.3. Right to erasure
In accordance with GDPR, you have the right
it is no longer needed for the purposes for which the Personal Data was initially collected
or processed or in the event you have withdrawn your consent or objected to processing as
you wish to have your Personal Data erased, please file a request via email at firstname.lastname@example.org.
12.4. Right to restriction of
Under certain circumstances described in
GDPR, you may ask us to restrict the processing of your Personal Data. This is for example
the case when you contest the accuracy of your Personal Data. In such event, we will
restrict the processing until we can verify the accuracy of your data.
12.5. Right to object to processing
Under certain circumstances described in
GDPR, you may object to the processing of your Personal Data, including where your Personal
Data is processed for direct marketing purposes. If you object the processing form marketing
purposes, the Company will not process your Personal Data anymore for this
12.6. Right to data portability
Where you have provided your Personal Data
directly to us and where the processing is based on your consent or the performance of a
contract between you and us, you have the right to receive the Personal Data processed about
you in a structured, commonly used and machine-readable format, and to transmit this data to
another service provider.
Should you have unresolved concerns, you have the right to lodge
a complaint with a Supervisory Authority where you live or where you believe a breach may
have occurred. We encourage you to come to us in the first instance but, to the extent that
this right applies to you, you are entitled to complain directly to the relevant Supervisory
We will make all required updates and changes within the time
specified by applicable law and, where permitted by law, may charge an appropriate fee to
cover the costs of responding to the request. Such requests must be submitted by email at email@example.com or in
writing to the following postal address: LIRIKOS Invest s.r.o., Koulova 1501/15,
Dejvice, Praha 6, 160 00, Czech Republic. To protect your confidentiality, we can only
respond to such requests to the email address that you have registered or otherwise provided
to us. Please remember that if you make such a request, we may not be able to provide you
with the same quality and variety of services to which you are accustomed.
In addition, in some circumstances based on applicable law, you
may request that we cease sharing personal information about you with our business partners
or that the Company ceases using personal information about you by contacting via email. We
will seek to honor those requests consistently with applicable law.
13.Retaining Personal Data
The Company retains your Personal Data for the period necessary
required or permitted by applicable law.
We will destroy your Personal Data as early as practicable and
in a way that the Personal Data may not be restored or reconstructed.
If it is printed on paper, Personal Data will be destroyed in a
secure manner, such as by cross-shredding or incinerating the paper documents or otherwise
and, if saved in electronic form, the personal information will be destroyed by technical
means to ensure the information may not be restored or reconstructed at a later time.
14.Choices of marketing communications
If you have given us your contact information (postal address,
email address or phone number), we may want to inform you in accordance with any preferences
you have expressed, and with your consent where required, about our products and services or
invite you to events via email, online advertising, social media, telephone, text message,
push notifications, in-app alerts, our customer service call center, and other means.
If you have explicitly consented to receive our newsletters or
marketing communications, including in relation to MOZART HOTEL GROUP, we may, from time to
time, contact you with information about our services and latest offers and process your
Personal Data for this purpose.
If you no longer want to receive our newsletters or marketing
communications, please let us know by sending us an email at firstname.lastname@example.org
You can also unsubscribe from our marketing emails by clicking on the unsubscribe link in
the emails sent to you. For MOZART HOTEL GROUP.
products or services, will may also inform you though a communications channel that you have
Company or MOZART HOTEL GROUP processes your Personal Data, please contact us by email at email@example.com
or by mail
to LIRIKOS Invest s.r.o., Koulova 1501/15, Dejvice, Praha 6, 160 00, Czech Republic.