PRIVATE POLICY

This Privacy Policy spells out the way in which Scalim SRL (having its registered office at 5 Rue de la Verrerie, 7330 Saint-Ghislain (Belgium) and registered with the Crossroads Bank for Enterprises (central business register) under number 0682.869.211, “Scalim”) collects and uses information from users of the Scalim MAH website (available at https://mah-hotel.com/ – the “Website”) as data controller, as well as the purposes of this collection and use. Scalim is committed to protecting your privacy, safeguarding the information you provide and using it only in accordance with the following provisions, and in accordance with the applicable legislation on privacy and personal data protection.

This Privacy Policy is subject to change, so you are kindly requested to check regularly.

What categories of data are processed ?

By accessing or using this Website, Scalim may process a number of personal data about you, such as

Personal data provided by you or generated by Scalim during the MAH.family registration process or when updating your data (« MAH.family Data »): your first and last name, e-mail address, language, telephone number; postal addresses, purchase and reservation history (reservation number and content, amount including VAT, applicable rates) and data relating to the benefits to which the MAH.family programme entitles you.
Personal data provided by you or generated by Scalim when you book a hotel room via our online reservation system available on the Website (« Booking Data »): your first and last name, gender (male/female), e-mail addresses, language, MAH. family (if applicable), your company name and VAT number (if applicable), billing address, telephone number, type of room booked, booking date, booking conditions, arrival and departure dates, room preferences or special requirements, promotional code (if applicable), rate(s) of the nights booked, payment data (such as the method of payment used (credit/debit card number, bank account information), amount and currency of payment, payment date).
Personal data relating to your use of the Website (« Service Data »): identifier of the device you use to visit the Website (“MAC” address, “Media Access Control”), data relating to the way you access the Website and the pages you visit thereon, information relating to your operating system and type of device, search criteria and products/services consulted, the IP address from which you connect to the Website.
Personal data in the context of your various requests (« Request Data ») via the contact page of the Website (your first and last name, e-mail address, telephone number, language, subject and content of your message, selected subject (hotel/restaurant-bar/coworking), date and time of your request, response(s) to your request).

What cookies are used ?

Cookies are used on some pages of the Website. Non-functional cookies will be installed only if you have given your explicit consent.

A cookie is a small text file sent to your computer or other device and stored on your hard disc or in the device’s memory. We use the following cookies to keep track of your visits, to tailor future visits to your preferences (if any) and in general to improve your browsing experience. By using these cookies, we provide a more personalized browsing experience on the Website.

You may refuse, delete or block these cookies at any time. However, some features of the Website that require the use of cookies may no longer be available.

For more information about the use of cookies please refer to our Cookie Policy.

What are the purposes of the processing ?

Scalim collecte, traite et utilise les données personnelles vous concernant uniquement pour les finalités précisées dans la présente Politique de Protection de la Vie Privée. Scalim traite vos Données Personnelles pour les finalités suivantes:

make the Website available to you and to manage it;
process, manage and execute your online room reservations;
answer all your requests for information and other requests, in particular via the contact form;
improve the content of the Website and your browsing experience;
manage your membership of MAH.family;
contact you by regular mail, email and/or text message on your mobile phone with promotional offers, new products or services, or MAH events that may be of interest to you (direct marketing), provided that you have specifically consented where such consent is legally required.

Furthermore, Scalim may process your Personal Data in order to monitor the use of the Website and the online reservation system, to analyse user habits, to develop additions or new features improving the Website, the online reservation system and the services and products offered by Scalim in general. Wherever possible, Scalim will process aggregated (being data that can neither identify you nor be linked to you, such as statistical data), pseudonymized or anonymized data, rather than personal data, when the purposes of such processing can be achieved in this way.

What are the legal bases for processing ?

The legal bases for the processing of personal data are:

the need for the legitimate interests pursued by Scalim (i.e. the provision of an optimal service to the users of the Website so as to meet the needs of these users, manage their requests and improve the Website as well as to ensure the security of the processing, to learn about the habits of its (potential) customers in order to be able to better target the advertising of its products or services, without infringing their fundamental rights and freedoms),
the need for Scalim to comply with the legal obligations incumbent upon it (e.g. accounting),
where applicable, the consent of users (in particular regarding affiliation with MAH.family and direct marketing by email or text message to your mobile phone), and
where necessary for the performance of a contract to which the user is a party or for the performance of pre-contractual measures taken at the user’s request (e.g. in connection with MAH.family membership or room reservations).

You are entirely free to decide whether to disclose your personal data. Please note, however, that failure to provide certain information may result in the inability to use certain services and features on the Website, including the reservation system.

Direct marketing

If you consent to the use of your personal data for direct marketing purposes (including promotional offers and advertising communications by e-mail and/or text message to your mobile phone), Scalim will use your personal data for the purposes to which you have consented until your consent is revoked. Scalim may send you promotional offers and advertising communications by e-mail and/or text message to your mobile phone (i) if you have provided your e-mail address or telephone number and (ii) if you have expressly consented, when providing your e-mail address or telephone number, to their use for direct marketing purposes (e.g. by affiliating with MAH.family on the Website). Promotional offers and commercial communications may be sent to you by ordinary mail unless you subsequently object.

Furthermore, these communications may be sent to you by e-mail if you are already a customer of Scalim, provided that you have given us your e-mail address in connection with the sale of a product or service, that these communications pertain to products or services similar to those already purchased and that you have not objected thereto, either at the time of collection of your data or subsequently.

If you no longer wish that your Personal Data are processed for direct marketing purposes, you have the right to withdraw your consent at any time, free of charge and without having to provide any justification. The procedure to follow in such a case is described in the section « What are your rights ? » section of this Privacy Policy.

Do we process special or « sensitive » personnal data ?

No. No special category of data or “sensitive” personal data about you (such as medical data) will be voluntarily collected or processed by Scalim and you are requested not to communicate such data via the contact page of the Website or via any other open field.

Are your personal data transferred to third parties ?

The personal data collected by Scalim are not transferred to third parties, with the exception of external service providers and subcontractors (for data hosting, hosting and maintenance of the Website, management of reservations, management of payments and sending of emails) for which Scalim has taken the appropriate measures to protect your personal data, and exclusively for the processing purposes described in this Privacy Policy.

In general, Scalim will not transfer your personal data to third parties, except for such transfers as (i) permitted by applicable law or (ii) mentioned in this section or elsewhere in this Privacy Policy. Your personal data may also be disclosed in the event of the sale or transfer by Scalim to a third party of all or part of its business or assets.

In particular, MEWS Systems B.V. (a company incorporated under Dutch law) acts as a subcontractor for our online room reservation system and processes your Reservation Data. We draw your attention to the MEWS Terms and Conditions applicable to our guests (https://www.mews.com/terms-conditions/guests). If you wish, you may create your own account with MEWS. In such a case, the MEWS Privacy Policy (available at https://www.mews.li/Platform/Document/PrivacyPolicy) will apply. When booking a room online via the MEWS platform, Stripe Payments Europe Ltd. (a company incorporated under Irish law) to process your payment data. We would like to draw your attention to Stripe’s service regulations (available at https://stripe.com/en-be/privacy) .

Insofar as this involves the transfer of your personal data to countries outside the European Economic Area which are not considered by the European Commission to provide an adequate level of protection of personal data, Scalim will ensure that appropriate contractual measures are put in place in accordance with applicable privacy and data protection legislation. A copy of these appropriate contractual measures can be obtained upon request.

Links to third party websites

The Website may contain hyperlinks to other websites or contact forms of third parties that are not subject to this Privacy Policy. Scalim recommends that you review the privacy policy applicable to those websites. Scalim assumes no responsibility for the personal data and privacy practices of these websites and encourages you to review their privacy policies before disclosing personal data to them.

How long are your personal data kept ?

Steps will be taken to ensure that your personal data are accurate, kept up to date and retained for no longer than is necessary for the purposes for which they were collected. Your personal data will be deleted by Scalim within 6 months after you unsubscribe from MAH.family or your last stay in our hotel, unless Scalim has a specific legitimate interest in storing your personal data for a longer period (e.g., in order to comply with a legal obligation). With respect to direct marketing, your personal data will be deleted once you withdraw your consent. Measures will also be taken to protect your personal data against unauthorized access, unlawful processing, accidental loss or destruction, or damage to your data. Any personal data contained in the periodic backups of Scalim or any of its subcontractors will not be deleted, provided that such personal data remains subject to the applicable confidentiality, data protection and security obligations until it is destroyed.

What are your rights ?

You have the right to access your personal data as collected and processed by Scalim and to request that they be corrected or deleted if incorrect or unnecessary.

You also have the right to request the restriction of or to object to processing as well as the right to portability (in certain cases).

Where applicable, you also have the right to withdraw your consent to any processing at any time. Such withdrawal of consent does not affect the lawfulness of the processing based on the consent given prior to such withdrawal.

To exercise these rights, please contact us by email at hello@mah-hotel.com, including a copy of any document which identifies you.

Furthermore, you may object to the processing of your data for direct marketing purposes, if applicable, at any time, free of charge and without justification by following the procedure described above.

You also have the right to lodge a complaint with a supervisory authority (in particular in the EU Member State in which you are normally resident, work or where the breach is alleged to have occurred) if you consider that the processing of your personal data constitutes a breach of data protection legislation. You can find the contact details of the Belgian Data Protection Authority on its website: https://www.autoriteprotectiondonnees.be/.

Whom do I contact if I have questions ?

If you have any questions or concerns about the Website or this Privacy Policy, please contact us at hello@mah-hotel.com or at 5 Rue de la Verrerie, 7330 Saint-Ghislain (Belgium).

Version 1.0 – Last update: 1 October 2020