Privacy Policy

This notice describes the general privacy policy (“Privacy Policy”) of General Hotel Management Ltd. (GHM). By visiting our website (www.ghmhotels.com), you are accepting the practices described in this notice as stated below.

SUMMARY OF HOW WE USE YOUR DATA

• What do we do with your information and what is the legal basis for this use? GHM uses your personal information to process and facilitate bookings, provide you with highly-individualised services at our resorts, respond to your requests for information, inform you of our products and services and other purposes as set out in this notice.

• Consent: Where we rely on your consent, such as for marketing our products and services to you, use of cookies, and collection and use of your sensitive personal data, you may withdraw this consent at any time.

• Cookies: Our site uses cookies to track visitors using our site, analyse trends and usage patterns for research and marketing purposes. You are not obliged to accept cookies.

• Your rights: You have certain rights to your personal information under applicable laws, including a right to object to some of the processing which GHM carries out.

WHAT INFORMATION DO WE COLLECT FROM YOU?

GHM collects certain information about you to operate effectively and provide you with the best experiences with our services. The specific kind of information collected will depend on the context of your interactions with GHM corporate office or any of the GHM hotels, and the services you use. The following are examples of the information that may be collected:

• User Account – When making a reservation, we may offer you the option to register for an account with us. We will ask you to select a username and password, and provide your name and contact information. In addition, if you choose to, you can include credit card information, room preferences and select the email newsletters to which you would like to subscribe.  We will only process your personal data in this way if you have provided consent for this type of processing.

• Contact information (including name, email address, mailing address, and phone number and/or other information provided through our websites);

• Payment information (including payment card numbers, billing address, and bank account information);

• Demographic data (including date of birth, gender, country of residence, and preferred language);

• Information related to your reservation, stay, or visit to any GHM property;

• Information necessary to fulfill your special requests and/or specific accommodations;

• Copies of your correspondence if you contact us;

• Your interests and preferences;

• Information related to your use and interaction with our website; and

• Images such as CCTV images, publicly available photographs and images captured at events or during your stay at any GHM property.

If you submit any personal information about others, for example, if you make a reservation for another individual, you represent that you have the authority to do so and you permit us to use the information in accordance with this Privacy Policy.

 HOW DO WE USE YOUR INFORMATION?

GHM collects your information to operate effectively and provide you with the best experiences with our services. GHM may collect, use, and disclose the information it collects for a variety of reasons, including for the following purposes:

• Fulfillment of Reservation and Other Purchases: We may process information relating to transactions that you enter into with us and/or through our website (“transaction data”). The transaction data may be processed for the purpose of completing your room reservation, supplying the purchased goods and services, customising our services to your preferences, seeking your feedback on your stay at our properties, and keeping proper records of those transactions.

• Guest Recognition Programs: To administer and operate GHM’s guest recognition program – Distinguished Program and Distinguished Elite Program. The data may be processed for the purposes of recording stay and on-property spend.

• Marketing Partnerships: To offer you periodic opportunities to sign up for (and enjoy privileges) from our marketing partners’ membership programmes (e.g. LHW’s Leaders Club, Preferred Hotels and Resort’s iPrefer Program, etc.)

• Response to Inquiries: We may process information contained in or relating to any communication that you send to us (“correspondence data”). The correspondence data may include the communication content and metadata associated with the communication. The correspondence data may be processed for the purposes of communicating with you and record-keeping.

• Internal Business Purposes: For our internal business purposes, such as data analysis, audits, developing new products, enhancing the website, improving our services, identifying usage trends and visiting patterns, determining the effectiveness of our promotions, and meeting contractual obligations. Additionally, we may aggregate your information with other guest information to conduct trend and statistical analysis.

• Administrative and Other Communications: To send you important information regarding our website, changes to our terms, conditions, and policies, or other administrative information (e.g., information about your travel reservations, such as reservation confirmations).

• Marketing and Promotions: To communicate news and promotions to you relating to GHM products and services and other products and services we think may be of interest to you, and to operate sweepstakes, contests, or other marketing or promotional activities.

• Online Surveys: Occasionally, we may conduct online surveys to better understand the effectiveness of our websites and to improve our services performance. Your participation in these surveys is voluntary. Information collected by us when you participate in a survey may include name, street address and e-mail address.

• Safety and Security: To maintain your safety and security as well as that of other guests and personnel, while you visit our managed hotels.

• Our Legal Duties: To comply with legal and regulatory requirements or demands in accordance with applicable law, a court order, subpoena, or other legal process.

• Additional Uses: We may also use your data other ways as described to you when you provide such information to us. 

Disclosure to Third Parties 

In order to conduct our business, and provide products and services to you, we may disclose the personal data that you voluntarily share with us to the following third parties:

• The Chedi Hotels such as The Chedi Al Bait, Sharjah, The Chedi Andermatt, The Chedi El Gouna, The Chedi Katara. The Chedi Muscat, The Chedi Lustica Bay, The Chedi Hegra, The Chedi Trojena (Upcoming), The Chedi Wadi Safar (Upcoming);

• Our business partners who may offer goods or services or information in relation to our business (including hotels, travel, leisure and entertainment, food and beverage, spa, conferencing, transportation, banking, telecommunication, insurance, and other consumer products and services);

• Our marketing service providers who provide marketing services on our behalf;

• Agents, contractors, sub-contractors or third party service providers (including the company provide the system for running the programme or the fulfilment house for arranging the membership card and other service providers who support on service delivery to members or provide administrative, telecommunication, computer or other services to us in connection with operation of our business), and/or

• Other third parties who may offer goods or services or information we think may be of interest to you, to provide services and products, process reservations and other transactions you request and to provide you with customer service.

We also rely on third party service providers to help us deliver products and services and programmes, offer products and services, and provide services in connection with our websites including communicating news and delivering promotional materials via e-mail and direct mail and administering sweepstakes and surveys.

We are committed to processing your personal information in accordance with applicable data protection laws. The legal basis for processing your personal information is made up of one or more of the following reasons:

• You have provided your consent to us to use your personal information;

• Our use of your personal information is necessary for the performance of our contract with you;

• Our use of your personal information is necessary to comply with applicable laws, regulations, court orders or other legal process;

• Our use of your personal information is necessary to protect your vital interests or of another natural person, for example, to respond to an emergency that threatens the life, health or safety of an individual; and

• Our use of your personal information is in our legitimate interest as a commercial organisation, for example, to improve our services and/or for data analytics and market research (including profiling and targeted advertising). 

Except as detailed in this Privacy Policy we will not disclose personal data to third parties outside The Chedi Hotels without your consent. 

WHAT ABOUT COOKIES?

We use tracking tools like browser cookies and web beacons to collect information from you. We collect information about users over time when you use this website or any apps that we may make available on our website. We may have third parties collect personal information this way. If you do not agree with how we use these cookies, you may control cookies through your browser settings. Please note that if you do set your browser to reject certain cookies, you may not be able to access all of the features on our website. 

DOES GHM SHARE INFORMATION ABOUT YOU?

As a hotel management company that operates in various continents and with the global geographical diversity of our business, it is essential that we share information across multiple jurisdictions in order to provide you with and to maintain the best possible service. The specific kind of information we share will depend on the context of your interactions with GHM, and the services you use. Accordingly, your personal information may be shared with the following parties insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy:

• to any hotel fully managed by us;

• to the representative or travel advisor that has supplied us with your personal information (for example, your travel agent, personal assistant, employer or spouse who has provided us with your details);

• to our trusted business partners to process it for us, based on our instructions and in compliance with our Privacy Policy and any other appropriate confidentiality and security measures;

• to our marketing and advertisement partners to provide you with more-relevant ads on our site and to encourage you to return to our site;

• to any third parties to the extent necessary in the event of a merger, or a sale of all or part of our business operations or assets. 

DOES GHM TRANSFER INFORMATION OVERSEAS?

As an international hotel management company and with the global geographical diversity of our business, it is essential that we share information across multiple jurisdictions in order to provide you with and to maintain the best possible services. By using and/or purchasing our goods and services, we may transfer your personal information across multiple jurisdictions. Accordingly, insofar as reasonably necessary for the purposes, and on the legal basis, set out in this policy, we may transfer and store your personal information:

• in or to Singapore where our corporate office is located;

• in those countries in which we manage and operate hotels and residences and/or operate sales offices, including (but not confined to) Oman, Switzerland, UK, Germany, Australia, India, China, Indonesia, Japan and the US.

• in such other countries where our third party service providers, advisors and consultants are located, which changes from time to time.

Such transfers may be to a country which may not provide the same level of privacy protection as that provided by the country in which the information was collected but we will take reasonable steps (including entering into data transfer agreements based on the European Commission model clauses, or requiring compliance with the EU-US Privacy Shield) to ensure that while your personal information is within our control, we will handle your personal information using reasonable security and confidentiality procedures to keep your personal information secure and confidential. 

HOW SECURE IS YOUR INFORMATION?

We implement reasonable administrative, organisational and technical safeguards and security measures to protect personal information within our possession and/or control from unauthorised access, acquisition, disclosure, destruction or alteration, accidental loss, misuse or damage. We regularly review and monitor such safeguards and security measures to ensure confidentiality and security of the information that you provide to us. 

HOW LONG WILL GHM RETAIN YOUR INFORMATION?

To the extent permissible by applicable law, we will retain your personal information only as long as reasonably necessary to fulfil the following:

• The purposes for which the personal information was provided;

• For marketing purposes, or with your consent, we will process and retain your data until you request for us to stop, plus a short period to process your request. We will keep a record of your request to not send you direct marketing or to process your data to avoid future marketing.

• For financial information, we will retain the information for as long as necessary for the purpose(s) for which it is collected and up to two months thereafter.

• For other personal data including registration data, we will not retain your data for longer than required for the purposes indicated.

• An identifiable and ongoing business need, including record keeping and accounting needs;

• A specific legal or regulatory requirements; and/or

• Retain records that may be relevant to any notified regulatory investigations, active and/or potential legal proceedings.

We will safely and securely delete, dispose of, and/or anonymised personal data if they are no longer necessary for the purposes indicated above. 

WHAT RIGHTS DO I HAVE?

In accordance with applicable laws, you may have rights in relation to your personal information. Such rights include:

• the right to ask us for a copy of your personal information;

• the right to delete or restrict (stop any active) processing of your personal information;

• the right to correct and update your personal information

• the right to access the personal information you provide to us for a contract or with your consent in a structured, machine readable format;

• the right to ask us to share (port) this data to another controller;

• the right to object to the processing of your personal information in some circumstances (such as where we do not have to process the information to meet a contractual or other requirement, or where we are using the data for direct marketing); and

• the right to withdraw your consent.

You may exercise these rights by contacting our data protection manager using the details set out in the “Opting Out” section below. You may also appeal our decision regarding your individual rights request (to the extent these rights are provided to you by law).

We reserve the rights to decline a request to access, correct or delete your personal information under certain circumstances as permitted by the applicable law. Examples include if fulfilling your request would reveal personal information about another person, where they would infringe the rights of a third party (including our rights) or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping. Relevant exemptions are included in applicable data protection laws. We will inform you of relevant exemptions we rely upon when responding to any request you make. 

OPTING OUT

If you do not wish to remain on our database and to receive our personalised mailings (electronic or otherwise) or other communications, please note that you may opt out of our database by using the “Unsubscribe” option at the footer of our email communications, or by sending an email to [email protected]. 

QUERIES OR COMPLAINTS

If you have any queries or complaints regarding this Privacy Notice or use of your personal information please contact our data protection manager using the contact details set out in the “Opting Out” section above. 

WHAT ABOUT LINKED WEBSITES?

The linking of third party websites to this website does not indicate any association with or endorsement by GHM. GHM does not assume responsibility or liability of any nature whatsoever for the activities conducted or information contained in the third party websites.

This Privacy Policy only addresses the collection, use and disclosure of personal information by us through your interaction with our services. This Privacy Policy does not address the policies of any third party websites linked to our website. GHM generally have no control over, and are not responsible for any third-party’s collection, use and disclosure of your personal information. Please contact these entities directly if you have any questions about their privacy policies.

Personal Data Received from EU 

For individuals in EU (“European Union”) from whom we collect personal data on our website, under applicable data protection laws (to the extent they apply to our website and to you) you shall have the following rights:

Access: You have the right to request a copy of the personal data we are processing about you, which we will provide back to you in electronic form. For your own privacy and security, in our discretion we may require you to prove your identity before providing the requested information. 

Rectification: You have the right to have incomplete or inaccurate personal data that we process about you corrected. Please note that you can always make certain adjustments to certain personal data directly through your online account. 

Deletion: You have the right to request that we delete personal data that we process about you, except we are not obligated to do so if we need to retain such data in order to comply with a legal obligation or to establish, exercise or defend legal claims. 

Restriction: You have the right to restrict our processing of your personal data where you believe such data to be inaccurate, our processing is unlawful or that we no longer need to process such data for a particular purpose, but where we are not able to delete the data due to a legal or other obligation or because you do not wish for us to delete it. 

Portability: You have the right to obtain personal data we hold about you, in a structured, electronic format, and to transmit such data to another data controller, where this is (a) personal data which you have provided to us, and (b) if we are processing that data on the basis of your consent (such as for direct marketing communications) or to perform a contract with you. 

Withdrawing Consent:  If you have consented to our processing of your personal data, you have the right to withdraw your consent at any time, free of charge.  This includes cases where you wish to opt out from marketing messages that you receive from us. 

Objection: Where the legal justification for our processing of your personal data is our legitimate interest, you have the right to object to such processing on grounds relating to your particular situation.  We will abide by your request unless we have compelling legitimate grounds for the processing which override your interests and rights, or if we need to continue to process the data for the establishment, exercise or defence of a legal claim. 

Complaint:  You have the right to lodge a complaint with the local data protection authority if you believe that we have not complied with applicable data protection laws. Please click here for a list of local data protection authorities in the other EEA countries.

CHANGES TO THIS PRIVACY POLICY

This Privacy Policy will be subject to change from time to time. The effective date of this current Privacy Policy is set out at the end of this document. Your use of this website constitutes your acceptance of the current terms as set out in this Privacy Policy. 

EFFECTIVE DATE: 17 March 2025