Privacy Policy

Last update on the 29^th 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 personal rights of its clients, hence it prepared this Privacy Policy. This Privacy Policy describes how the Company and other hotels, 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 be 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 synchronizing reservations among the hotels and helps to organize your stay at the hotel, manages a global database of MOZART HOTEL GROUP guests, and also manages the loyalty program.
• Each hotel is processing your Personal Data for the performance of contractual conditions with you such as reservation, invoicing, payment processing, the performance of marketing activities and to comply with legal obligations such as tourist taxation and local migration rules.

The guarantees and principles provided in this privacy policy are applicable to LIRIKOS invest and all the hotels operated under the MOZART HOTEL GROUP trademark. We will do our utmost to ensure that all hotels comply with the applicable data protection laws and this Privacy Policy in relation to the processing of your Personal 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 “GDPR”). 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 subject,
• 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 Personal Data.

For any questions concerning the processing of your Personal Data, please contact the Company whose contact details stated in clause 16 of this Privacy Policy. Please read this Privacy Policy carefully to understand how and for what purposes we process your Personal Data.

1. Definitions

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 the controller.

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, posta@uoou.cz, +420 234 665 800 (GDPR infoline).

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 or destruction.

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 Privacy Policy and in accordance with the principles of lawfulness and transparency. 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, postcode, 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 cardholder;
• the 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 Value (CVV2).)

2.2. Upon using hotel services, Guests shall fill in a hotel registration card, in which they agree with the 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 fulfillment of obligations as defined in the given laws:

• first name and surname
• address
• 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 states,
• as well as Switzerland, as a state with similar legal status.

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 enforce claims.

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 a 5-year period as necessary for the exercise of rights and fulfillment 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 a 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 utmost to ensure that all of our partners comply with the applicable data protection laws and this Privacy Policy in relation to the processing of your Personal Data.

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, the 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 fulfill services that are part of such program; to enable direct communication between hotels within MOZART HOTEL GROUP, and between MOZART HOTEL GROUP and you;
• 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 a 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 facilities. 

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 further transfer. You may exercise these rights by contacting us at 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 data:

• 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 agreement.

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 regulations.

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 protection. 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 gdpr@internationalprague.cz.

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 stays at our hotel, such as gifts, discounts 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 hotels 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 you. 

Our website uses cookies and other technologies (such as “pixel tags,” “web beacons,” “clear GIFs”, links in emails, JavaScript, device IDs assigned by Google or Apple, or similar technologies) to relate 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 an aforementioned manner and for the aforementioned purpose. 

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 don't 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 procedure).

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 gdpr@internationalprague.cz.

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 reception of hotels.

• For the processing of payment card numbers and other financial data, we use services of TravelClick services. For more details, you may apply to TravelClick Privacy Policy;
• For the collecting of information about your usage of the Site, we use Google analytics services. For more details, you may apply to Google Privacy Policy;
• For the purpose of processing emails, we use the services of MailChimp. For more details you may apply to MailChimp Privacy Policy;
• For the processing of your reviews and comments about hotels of MOZART, we use the services of ReviewPro. For more details, you may apply to ReviewPro Privacy Policy

12.Changing, accessing, and portability of your Personal Data

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 unsubscribe@internationalprague.cz. 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 other purposes, such as those set out in this Privacy Policy.

12.2. Right to access and rectify your data

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 gdpr@internationalprague.cz. You may also request a copy of the Personal Data processed as described in this Privacy Policy.

12.3. Right to erasure

In accordance with GDPR, you have the right to the erasure your Personal Data processed by us as described in this Privacy Policy in case 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 described in this Privacy Policy and no other legal ground for processing applies. Should you wish to have your Personal Data erased, please file a request via email at unsubscribe@internationalprague.cz.

12.4. Right to restriction of processing

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 purpose.

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 Authority. 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 gdpr@internationalprague.cz 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 you 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 to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is 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 unsubscribe@internationalprague.cz. You can also unsubscribe from our marketing emails by clicking on the unsubscribe link in the emails sent to you. For MOZART HOTEL GROUP.

15.Modifications of Privacy Policy

The Company may modify this Privacy Policy from time to time. When we make material changes to this Privacy Policy we will post a link to the revised Privacy Policy on the homepage of our website, and if you have registered for any of your products or services, will also inform you through a communications channel that you have provided. 

You can tell when this Privacy Policy was last updated by looking at the link and at the date at the top of the Privacy Policy. Any changes to our Privacy Policy will become effective upon posting of the revised Privacy Policy on the website. Use of the website, any of our products and services, and/or providing consent to the updated Privacy Policy following such changes constitutes your acceptance of the revised Privacy Policy then in effect.

16.Contact information

If you have any questions about this Privacy Policy or how the Company or MOZART HOTEL GROUP processes your Personal Data, please contact us by email at gdpr@internationalprague.cz or by mail to LIRIKOS Invest s.r.o., Koulova 1501/15, Dejvice, Praha 6, 160 00, Czech Republic.