1 Collecting information on the Website
1.1 Master data
When you create a profile on the Website, we collect the following master data: Your username, your password and your email address. The purpose of the collection of this information is to identify you as user when you log on to the Website. Furthermore, you can choose to add more information to your profile, such as your photo and demographic information.
When you write a review of a company, we collect the information you state in the review, including which company you review, which purchase(s) the review concerns, and how you evaluate the company. Hotel Tech Report only reveals reviewer information to premium members through the review manager dashboard (your personal details will never be posted publicly). You have the right to remain anonymous to premium members and may do so by selecting "anonymous" at the time of writing your review.
1.4 IP adresses and browser settings.
When visiting the Website, the IP address and the browser settings of your computer are registered. The IP address is the numerical address of the computer used when visiting the Website. Browser settings are e.g. the type of browser you use, browser language, timezone etc. The IP address and browser settings are registered to enable HTR to trace the used computer in case of misuse or unlawful actions in connection with the visit on or use of the Website. Further, the IP address is used to derive your approximate location (city level).
1.5 Newsletter & Content
If you sign up for HTR's newsletters or opt-in to content such as Buyers Guides, gated research tools or other content, HTR registers the information supplied by you (e.g. your name, email address etc.). You agree that Hotel Tech Report may collect, use and disclose your personal data which you have provided in any form, for providing marketing material that you have agreed to receive, in accordance with our data protection policy. If you no longer wish to receive newsletters from HTR, you can unsubscribe by logging on to your profile and edit your information or via live chat on the website.
1.6 Information from other services, including Social Network(s)
As part of our services, we provide you with the possibility of connecting your profile on the Website with your profile on social networks such as Facebook, Google+, LinkedIn and Twitter ("Social Network(s)"). Some information about you will automatically be collected from Social Networks when connecting your HTR profile with your profile on Social Networks.
The information collected from Social Networks depends on what information you have made available on the network and your privacy settings for sharing such information on the network. Depending on the settings, we may e.g. collect the following information about you:
- Name and/or username
- E-mail address
- Date of birth
- Profile photo
When you request to have your HTR profile connected to a profile on a Social Network, you will be informed on which information we will collect from the network in question before your request is executed.
The purpose of collecting information from Social Networks is to connect members of your network, which are both users of HTR and of one or more of the Social Networks, and thereby both increase the confidence in the reviews made by the members of the network as well as create a better user experience on the Website.
HTR does not collect other personal identifiable information from visitors of the Website, unless the visitor provides the information to us.
2 How We Use Your Personal Information
We may use Personal Information as permitted by law, for the following business purposes:
To provide the Site and various functions related to services offered on the Site. When you create an account on the Site, we store and use the information you provide during that process. This may include your first and last name, your email address, the company you work for, and any other information you may provide during the account creation process.
- To fulfill any contact requests you make on the Site. When you request additional information on a certain third-party service or product listed on our Site, we will use the information you provide to connect you with the provider of that service or product.
- To engage in research and analysis related to the Site. We store and use information to identify and fix errors, understand how visitors use our Site, research and test different features, and analyze how visitors arrive at and use our Site.
- To personalize your experience. We store and use information provided by you, such as the software products and services you use or have used, or are researching on the Site, to personalize and make recommendations to you based on your provided information.
- To improve and understand usage of the Site. We store and use information about your use of the Site, such as your search activity, pages viewed, and the date, time and duration of your visits, to understand and improve usage of the Site.
- To comply with legal obligations. We use and share your information as necessary to respond to subpoenas, court orders, or other legal process; we also may use and share your information to establish or exercise our legal rights, to defend against legal claims, or as otherwise required by law.
- To expedite your software search. After delivering custom software recommendations, we may share your information with up to 3 partners who match your criteria to help expedite your search for the best providers. We only share this information with top vendors who have more than 25 reviews and >80% likelihood to recommend. We will never share your information with a business who does not come highly recommended by our community unless you explicitly request to connect with them.
We may use and share your personal information when we believe it is necessary to investigate, prevent, or take action regarding illegal or suspected illegal activities; to protect and defend the rights, property, or safety of Hotel Tech Report, our Site visitors and registered users, our licensees, and others.
We may use and share your personal information in connection with a corporate transaction, such as a divestiture, investment, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.
The information we collect and store relating to you is primarily used to enable us to provide our service. In doing so, we rely on the following legal bases:
Legitimate interest – We rely on our legitimate interests to manage our relationship with you. This entails responding to customer queries, sharing reviews with our vendors and the like.
Necessary for the performance of a contract – As outlined above, for every aspect of our service to which you express interest, we use the prescribed data to provide that service to you.
Necessary for compliance with a legal obligation – When it comes to payments-related information, such as invoices and any personal data included therein, we use that to satisfy our legal obligations.
Consent – We have a very informative newsletter which we share with interested customers. When you surf our website, we give you the option to subscribe to our mailing list.
3 Disclosure of personal data
3.1 Disclosure of data on the Website
Please note that your consent to these guidelines implies that your profile on the Website may not be anonymous.
Master data: When you create a profile on the Website, your username will be available for other users of the Website.
Other information: Other information provided by you on the Website, including photos and reviews, are automatically made available for other users of the Website. In some instances, the companies you review will also receive information about your review.
Geo-location: When you make a contribution to the Website your approximate city location (based on your computer's IP address, see section 1.4, or based on location data provided by your mobile phone or other device) is made available to other users of the Website.
Social Networks: If you connect to a Social Network, information such as your profile photo, your name, year of birth and approximate location will be collected from your profile on the Social Network and used to identify you on the Website. Consequently, all users of the Website will, subject to information available from the Social Network, be able to identify the reviews created by you.
If your contacts or your contact's contacts (jointly referred to as "Connections") on the Social Network also have connected with HTR, we may display on the Website how you are connected to these Connections through the Social Network.
3.2 Disclosure on services to which you connect your profile
If you choose to connect your HTR profile with profiles on a Social Network information and reviews, cf. 1.2 provided by you on the Website or data compiled by us about your use of the services on the Website (e.g. number of reviews) will be shared with and displayed in connection with your profile on the Social Network.
3.3 Disclosure to other services
A main purpose of HTR is to increase the exposure and the availability of the reviews made on the Website. Hence, we permit other services to show the reviews created on the Website thus increasing other consumers' knowledge of your reviews.
The categories of third parties to which the information is disclosed are:
- Search engines, including e.g. Google and Bing,
- Operators of consumer portals and business portals, including price comparison websites, shopping guides etc.
- Companies or services that have been reviewed on the Website or which have a relationship with HTR
- Operators of other similar websites or services where, in HTR's assessment, it will be relevant for the consumer to search for reviews.
Your review is disclosed as you make it available on the Website, which entails a disclosure of the following information:
- Your reviews, cf. section 1.2.
- Your job title
- Your username and, if available, profile photo as well as user demographics such as age and gender.
- Your approximate city location
3.4 Other disclosure
HTR may be required to disclose information by a court order from a competent court of law or public authority in accordance with the existing legislation.
4 Data controller
4.1 The information for which HTR is the data controller
HTR shall be data controller of the master data you enter in connection with your creation of a profile or registration for newsletters, i.e. your name, your password and your email address, as well as registration of your IP address.
Furthermore, HTR shall be the data controller of the information which is disclosed to other services.
4.2 The information for which you are the data controller
You shall be data controller of the content you choose to disclose on the Website and for the data disclosed on your profile on Social Networks, which is the consequence of the connection of your profile on the Website with your profile on the Social Network.
4.3 Links to websites
The Website contains links to other websites. Note that by clicking such links you will be transferred to other websites for which HTR is not the data controller. We thus recommend that you always read the personal data policy of these websites, as their procedure for collecting and processing personal data may be different from ours.
5 Data processor
HTR uses an external company for maintaining the technical operation of the Website. This company is the data processor with regards to the personal data for which HTR is the data controller.
By accepting this personal data policy, you accept that HTR also allows the data for which you are the data controller be processed by the same data processor.
The data processor shall solely act according to instructions from HTR. By accepting these terms and conditions, you authorize HTR to give such instructions to the data processor which are necessary for the processing of data in accordance with this personal data policy and for the purpose of use of the Website.
The data processor has made necessary technical and organizational safety measures against the information being accidentally or illegally destroyed, lost or deteriorated, and against the information coming to the knowledge of unauthorized persons, is misused or in other ways is processed in violation with the act on processing of personal data. On your request - and against remuneration of the data processor's current hourly rates at any time for such work - the data processor shall supply you with sufficient information to demonstrate that the above-mentioned technical and organizational safety measures have been made.
HTR may now or in the future process and/or store personal data in the U.S. If you access or use the Website from a location outside of the U.S., you consent to the transfer, storage and processing of your personal data in the U.S.
6 Security measures
HTR will use commercially reasonable efforts to see that the recorded data, including the personal information, under its control is handled using appropriate security measures. HTR regularly audits its system for possible vulnerabilities and attacks. However, since the internet is not a 100% secure environment, HTR cannot ensure or warrant the security of information you transmit to HTR. Emails sent via the Website are not encrypted, and HTR therefore advises you not to communicate any confidential information through these means.
7.1 What is a cookie?
Cookies are small information units which the Website places on your computer's hard disk, on your tablet or on your smartphone. Cookies contain information that the Website uses to make the communication between you and your web browser more efficient. The cookie does not identify you as an individual user but identifies your computer. There are two types of cookies - session cookies and persistent cookies. Session cookies are temporary bits of information which are deleted when you exit your web browser. Persistent cookies are more permanent bits of information that are stored and remain on your computer until they are deleted. Persistent cookies delete themselves after a certain period of time but are renewed each time you visit the website.
The Website uses session cookies and persistent cookies.
We use similar technologies for storing and accessing information in the browser or device which utilizes local units and local storage, such as HTML 5 cookies, Flash and other methods. These technologies can operate across all your browsers. In some cases, the use of these technologies cannot be controlled by the browser, but requires special tools. We use these technologies to store information to ensure the quality of reviews and to spot irregularities in the use of the Website.
7.2 What type of cookies do we use and for what purposes?
Measuring Website traffic i.e. number of visits on the Website, which domains the visitors come from, which pages the visitors visit on the Website and in which overall geographical area the visitors are located.
Improvement of the functionalities of the Website:
Optimizing your experience with the Website, which includes remembering your user ID and password when you return to the Website so you do not have to log in again.
Connect with Social Media:
We give you the possibility of connecting with Social Media, such as Facebook.
Ensuring the quality of reviews and to prevent misuse or irregularities in connection with writing reviews and using the Website.
Displaying specific advertisements on the Website which we believe you will find interesting.
7.3 Whom do we share data with?
For security and efficiency purposes, we deem it necessary to work with global companies that are best positioned to guarantee the security of the infrastructure we use to operate this website. These are:
Amazon Inc. – We utilize Amazon’s cloud offering for storage of the data entrusted to us;
Twillio Inc. – Delivery of our services happens through the e-mail service delivery service and API functionalities provided by SendGrid, a Twillio company;.
Stripe Inc. – All payments handled via our website are fuelled by Stripe’s payment processing capabilities;
Intercom Inc. – We use Intercom’s communication functionalities to fuel our dashboard and review manager;
Mailjet SAS – When it comes to e-mail marketing, we rely on Mailjet’s products and services;
Zapier Inc. – To make our platform run smoothly, we utilize Zapier’s integration functionalities and support;
Google Inc. – Our database management is based on Google’s office solutions.
Despite our best effort to seek to employ the services of reputable providers who have the necessary resources to maintain state of the art security measures of their infrastructure, we are not in a position to absolutely guarantee the secure transmission of data over the Internet. Yet, we are committed to fully utilize all available tools at all times to protect your data.
Moreover, as a California-based company, we process the data you provide to us in the United States, and we do so subject to the Federal, State and City laws that are applicable to us. That being said, any transfers of personal data from our vendors within the European Economic Area are governed by a comprehensive Data Processing Agreement and in reliance of the Standard Contractual Clauses approved by the European Commission.
7.4 Deletion of cookies
If you want to delete the cookies already on your equipment, you can, if you use a PC or a more recent browser, press CTRL + SHIFT + DELETE simultaneously. If the shortcuts do not work on your browser, please visit the support page for the browser in question. Please note that our Website will not work to its full extent if you delete the cookies.
8 Access, correction and deletion
Upon written request to HTR via the contact information stated in section 9, HTR shall inform you of the purpose of the processing; who receives the information and from where the information originates.
Requests regarding the above shall only be processed if more than 6 months have lapsed since your previous request, unless you can substantiate a special interest in obtaining the information earlier.
8.2 What rights do you have?
If you are in the European Economic Area, you have the following rights with respect to information that HotelTechReport holds about you. We undertake to provide you the same rights no matter where you choose to live.
Access - You can request a copy of the personal data we hold about you;
Rectification - If we have entered your personal data incorrectly, you can request that we fix it;
Opt-out - You can ask that we stop contacting you with information regarding our services (excludes all communication we may exchange for administrative or housekeeping purposes).;
Restriction - In the case we enter into an argument regarding the processing of your data, you can request that we stop processing it until the argument is resolved;
Complaint - You have the right to lodge a complaint with the supervisory authority in the country where you reside, work or where the alleged infringement took place;
Automatic decision-making - Not to be subject to and evaluated solely on the basis of automated processing;
Portability - To receive all of your own data in a commonly readable format or have that sent over to another entity of your choosing;
Erasure - You can request that we delete all your personal data (applies when data is processed on the basis of obtaining your consent, when no longer necessary and so forth);
Objection - In cases involving, for example, direct marketing, you could object to our processing of your personal data, if we continued sending you marketing communications after you have opted-out of receiving such communications.
When your profile is deleted, all the data associated with your user profile is deleted, including your master data and reviews on the Website. If you delete a review on the Website, the review is permanently deleted.
HTR reserves the right to block the access to your profile and/or delete your profile, if the profile or the content of your profile on the Website in our assessment is discriminating, racist, sexually-oriented, unethical, threatening, offensive, harassing or in other ways violates the legislation, third party rights or the purpose of the Website. If we block the use of your profile, you shall be informed hereon, as well as on the reason for blocking the access, by email to the address you have stated in your profile.
8.3 - How long do we keep data for?
We retain data for a period no longer than necessary to manage ongoing relationships with clients and for a reasonable period thereafter in case of challenge.
- we retain contracts, business contact details and the like for a period of 6 years from the contract completion date;
- we retain financial information for a period of 7 years from the date of completing each financial transaction for auditing purposes;
- we may hold business contacts such as e-mail addresses, telephone numbers and the like for a period of 3 years from the end-of-relationship date; or
- where we have ongoing client relationships exceeding these periods, we may retain data as necessary to manage such relationships;