HOTELS QUALITY Privacy Policy and Your Privacy Rights

QUERYTEK Technologies SL (“HOTELS quality,” “we,” or “us”) is committed to protecting your privacy. We have prepared this Privacy Policy to describe to you our practices regarding the Personal Data (as defined below) we collect from users of HOTELS QUALITY’s websites and applications, including without limitation the services available at www.hotels-quality.com and mobile applications (collectively, the “Services”). The use of information collected through the Services shall be limited to the purpose of providing those services for which HOTELS QUALITY’s hospitality business customer has engaged HOTELS QUALITY, for instance our Feedback engine application. You are deemed to use the Services when you visit HOTELS QUALITY’s websites or use its applications, submit Personal Data through the Services or register for the Services. Any capitalized terms not defined in this Privacy Policy will have the meanings set forth in the HOTELS QUALITY Terms and Conditions of Use at www.hotels-quality.com/website/terms/?lang=en (as applicable the “Agreement”).

By using the Services, you agree to the terms of this Privacy Policy and you expressly consent to the processing of your Personal Data in accordance with this Privacy Policy. If you do not agree to our use of your Personal Data in accordance with this Privacy Policy, you are not permitted to use these Services. Your Personal Data may be processed in the country where it was collected and in other countries, including the United States, where laws regarding processing of Personal Data may be less stringent than the laws in your country. We do not intentionally gather Personal Data about visitors who are under the age of 13.

HOTELS QUALITY complies with the U.S. – E.U. and U.S. – Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use and retention of personal data from European Union member countries and Switzerland. HOTELS QUALITY has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view HOTELS QUALITY’s certification, please visit www.export.gov/safeharbor.

1. Types of Data We Collect From You

We collect Personal Data and Anonymous Data from you when you use the Services and/or when you send us communications. “Personal Data” means data that allows someone to identify or contact you, including your name, address, telephone number, e-mail address, and any other non-public information about you that is associated with or linked to any of the foregoing data. “Anonymous Data” means data that we create from Personal Data by excluding information that makes such data personally identifiable.

1.1 Data You Provide to Us. We receive and store any information you enter on the Services or otherwise provide to us. For example, but without limitation:

We collect Personal Data from you, such as your user name, password, first and last name, title, company name, e-mail address, telephone number, and postal address (i) when you create a Master Account or User Account, (ii) when you submit Personal Data through the Services, or (iii), when you create a Master Account or User Account or if you contact us for more information regarding our Services.

If you contact us by e-mail or through a form on the Services, we may collect your name and e-mail address, as well as any other content included in the e-mail or that you submit to us.

1.2 Data Our Customers Provide to Us. Some of our products allow our hospitality business customers (hotels and restaurants) to provide Personal Data to us from their guest management systems. This information may include your first and last name, title, company name, e-mail address, telephone number, and postal address, the hotels where you stayed and the dates of your stay, guest preferences you provided to our customer, such as preferred floor.

1.3 Data Collected Through Technology. We collect information about you based on or through your use of the Services.

Our servers (which may be hosted by a third party service provider) collect information related to your use of the Services, such as browser type and version, operating system, platform, Internet Protocol (IP) address (a number that is automatically assigned to your computer when you use the Internet, which may vary from session to session), domain name, and a date/time stamp for your visit.

We may use third party services to gather information about your visit to the Services, such as the pages and information you viewed. Some of these services provide lead generation services and may gather information about the domain name from which you are visiting the Services. We link this automatically collected data to personally identifiable information.

We, along with our marketing service providers use technologies such as: cookies, beacons, tags and scripts to analyze trends, administer the site, track users’ movements around the site and gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis.

1.4 Information You Choose to Share with Others. The Services may contain features that allow you to e-mail reviews of hospitality businesses from third party sites to other persons, to respond to surveys regarding guest satisfaction, to manage your stay with one of our Customers (for example to confirm your hotel reservation) and/or to collaborate on the Services with other Users (for example, to manage reviews). Hotels and other hospitality business may also use that information for their internal purposes and publish some types of information publicly. Any Personal Data that you include in such communications will be viewable by the recipient or those you collaborate with, as applicable. You may also link your User Account to third party services (for example, Twitter and Facebook). Any information, including Personal Data, that you choose to publish to a third party service will be viewable by its users, depending on your settings and/or preferences with that third party service. Such content is subject to the terms of use and privacy policy for that third party service. We may collect information about your third party service usage (for example, measuring the number of tweets you send).

2. Use of Your Data

In general, we use Personal Data that we collect from you to provide you with a customized experience, aid us in serving you better, and respond to your requests. In addition, we use your Personal Data to:

• Facilitate the creation of and secure your Master and/or User Account on our network;
• Identify you as a user in our system;
• Provide you the Services;
• Analyze request and usage patterns, diagnose problems with our server and administer our Services;
• Improve the quality of experience and provide you a personalized experience when you use the Services;
• Develop and improve the Services;
• Send you administrative notifications, such as security or support and maintenance advisories (the messages we send may contain code that enables our database to track your usage of the message, such as whether an e-mail was opened and/or what links (if any) were clicked);
• Respond to your inquiries, including as related to employment opportunities or other requests; and
• Send you messages or postal mail informing you of our products and services we believe may be of interest to you, such as new features and services, special offers, and updated information, and for other marketing purposes for us.

3. Disclosure of Your Data

Except as described below, we do not share your Personal Data with third parties:

We may share your Personal Data with other Users, persons, or services, as described in Section 1.4. If you are a guest at a hotel and you are using our Services in connection with your stay at that hotel, we may share your Personal Data with the hotel and any other data associated with your experience as a guest at their hotel.

Public content such as reviews and survey responses you provide through the Services may be hosted on our website(s) and applications. That content may also be distributed and republished through third party websites and applications. We will not provide your full name or other identifying information in connection with any reviews or survey responses. We may provide limited identifying information, such as your first name, last initial and hometown. We will not sell or share your survey responses with third party advertisers or marketers without your consent.

We provide copies of all information you provide through the Services, including Personal Data to your hotel. Your hotel may have separate agreements with you regarding sharing of your survey response information and Personal Data. If you have any questions about how your hotel handles your information you should contact them directly.

We are not responsible for content in the Services which has been provided by your hotel, such as survey questions and information about your stay at their property. If you have any questions about hotel-provided content, or if you are a guest of one of our hotel partners and would no longer like to be contacted by that hotel, please contact your hotel directly.

We may share your Personal Data with third party service providers under contract to perform functions on our behalf. Examples include sending postal mail or electronic messages, storing data, analyzing data, performing quality assurance, providing technical support, providing marketing assistance, verifying identity, processing employment applications, and providing customer service. These third parties may have access to your Personal Data only as needed to perform their functions.

We may transfer personal information to companies that help us provide our Services. Transfers to these third parties are covered by the provisions in this Privacy Policy regarding notice and choice, as well as the service agreements with our Customers.

We may share your Personal Data with any company that acquires our company or our assets. That company will possess the Personal Data collected by us and will assume the rights and obligations regarding your Personal Data as described in this Privacy Policy. We will notify you via email and/or a prominent notice on our Web site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.

We may share your Personal Data with our subsidiaries, joint ventures, or other companies under common control, in which case we will require them to honor this Privacy Policy.

We may disclose your Personal Data if we have a good faith belief that disclosure is necessary to: (1) comply with the law or with legal process served on us or to cooperate with any legal investigation; (2) protect and defend the rights or property of us or our users; (3) act in an emergency to protect someone’s safety; or (4) investigate any violation or potential violation of the law, this Privacy Policy, the Agreement, or any other agreements between you and HOTELS QUALITY.

We may share your Personal Data if you provide us prior consent to do so.

4. Use and Disclosure of Anonymous Data.

We have the right to use, and share with third parties, Anonymous Data for any purpose and in any manner.

5. Your Choices Regarding Your Personal Data

5.1 We offer you choices regarding the collection, use, and disclosure of your Personal Data. We may periodically send you messages about new services, products, or other noteworthy news, or that may contain advertisements for third parties. When you receive promotional communications from us, you may indicate a preference to stop receiving further communications from us and you will have the opportunity to “opt-out” by following the unsubscribe instructions provided in the message you receive, or by contacting us at soporte@hotels-quality.com. Despite your indicated email preferences, we may send you notices of any updates to our Agreement, Privacy Policy, or other terms for the Services.

5.2 Changes to Customer or User Personal Data. As a Customer or User, you may change any of your Personal Data in your Master Account or User Account by editing your profile through the Services or by sending us e-mail or postal mail at the address below. You may request us to delete your Personal Data by sending us an e-mail or postal mail at the address below, but please note that we may be required (by law or otherwise) to keep this information and not delete it (or to keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements). When we delete any information, it will be deleted from the active database, but may remain in our archives. We will respond to requests for access within 30 days.

We will retain your Personal Data (including the personal data we process on behalf of our Clients) for as long as your account is active or as needed to provide you services. We will retain and use your Personal Data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

5.3 If you used our guest-facing Services and you notify us that you wish to remove Personal Data that you provided or that we obtained from our customers or third parties, we will endeavor to do so. Please note that we may be required (by law or otherwise) to keep this information and not delete it or to keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements. You must contact Customers directly regarding removal of Personal Data held by them.

5.4 Removal of Content on Customer Request. Customers or third parties may also request us to edit or remove certain content in the Services from time to time. While we do not monitor or screen content as a rule, we reserve the right to edit or remove content for any reason in our sole discretion. If a Customer requests that we remove content, we will respond to its request within 30 business days.

6. Security.

We have commercially reasonable security measures in place to help protect against loss, misuse and alteration of your Personal Data in our possession. When you enter sensitive information (such as a login credentials) we encrypt the transmission of that information using secure socket layer technology (SSL). No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, while HOTELS QUALITY uses reasonable efforts to protect your Personal Data,  HOTELS QUALITY cannot guarantee its absolute security. If you have any questions regarding security you can contact us at soporte@hotels-quality.com.

7. Social Media Features.

These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. Social media features are either hosted by a third party or hosted directly on the Services. Your interactions with these features are governed by the privacy policies of the companies providing them.

You can log in to our site using sign-in services such as Facebook. These services will authenticate your identity and provide you the option to share certain personal information with us such as your name and email address to pre-populate our sign up form. Services like Facebook Connect give you the option to push information about your activities to the guest profile.

8. Links to Other Sites.

The Services contain links to other sites that are not owned or controlled by HOTELS QUALITY.  Please be aware that we are not responsible for the privacy practices of such other sites. We encourage you to be aware when you leave our site and to read the privacy statements of each and every Web site that collects personally identifiable information. This privacy statement applies only to information collected by the Services.

9. Testimonials.

We may post Customer testimonials on the Services, which may contain personally identifiable information. We obtain the Customer’s consent via email prior to posting the testimonial to post its name along with its testimonial. If you want your testimonial removed please contact us at soporte@hotels-quality.com.

10. Public Forums.

The Services may offer publicly accessible blogs or community forums. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your personal information from our blog or community forum, contact us at soporte@hotels-quality.com. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.

11. Changes.

We may amend this Privacy Policy from time to time. If we make material changes to the Privacy Policy, we will notify you by posting a prominent notice on our website and/or sending you an e-mail at your primary email address, as specified in your Master Account or User Account. Any changes to this Privacy Policy will be effective immediately for new users of our Services; otherwise these changes will be effective upon the earlier of thirty (30) calendar days following our dispatch of an e-mail notice to you or thirty (30) calendar days following our posting of a notice on our website(s) and application(s). You are responsible at all times for updating your Master Account or User Account to provide to us your most current e-mail address. If the last e-mail address that you have provided to us is not valid, or for any reason is not capable of delivering to you the notice described above, our dispatch of the e-mail containing such notice will nonetheless constitute effective notice of the changes described in the notice. Continued use of our Services following notice of such changes shall indicate your acknowledgement of, and agreement to be bound by, such changes. Except as otherwise provided in this Section, no amendment to this Privacy Policy will be valid.

12. Contacting HOTELS QUALITY.

We welcome your comments or questions regarding this Privacy Policy. Please e-mail us at soporte@hotels-quality.com or contact us at the following address:

QUERYTEK Technologies SL

Attn: Privacy Policy

Nuñez de Balboa 120, 28006 Madrid, SPAIN