Privacy Policy

General information

What is the purpose of this policy?

This privacy policy describes:

• who we are and our role;
• the personal data that we process about you;
• the reasons why and on the basis of which legal ground we process personal data; and
• how we process personal data.

You will also find herein all the relevant information about your rights and how to exercise these rights, as well as our contact information if you wish to contact us.

Who are we?

We are the company TEPE INVEST, registered with the Crossroads Bank of Enterprises under number 1038.158.237. Our contact and other relevant details are set out at the end of this privacy policy in our contact section.

We are the controller in relation to the personal data processed in accordance with this policy.

Relevant information on the processing of your data

Whose personal data do we process?

We may process data relating to you if you are or work for:

• one of our customers or one of our suppliers; and
• a person to whom we wish to promote our products and services or to whom we wish to sell them.

What personal data do we process and how do we collect them?

If you are staying or have stayed at Hotel Axis, we process:

• your name and surname(s);
• your address;
• your email address;
• your country or place of residence;
• your phone number and fax number;
• the name of the company you work for and your title;
• information on the credit card you use for the booking, namely the name of the card holder, card number, billing address of the card and expiry date of the card;
• details about your trip and your preferences, namely information on flights, flight numbers, arrival and departure dates as well as departure time and place and the destination, room preferences and other services; and
• other desires and interests you provide on the occasion of your booking or your stay.

If you work for a company with which we have an existing business relationship or wish to maintain such a relationship, we process:

• your name and surname(s);
• your address;
• your email address;
• your phone number and fax number; and
• the name of the company you work for and your title.

If you use our website, we process:

• technical information, including the IP address used to connect your computer to the internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; and
• information about your visit, including the full URLs accessed before, through and from our website (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, interaction information with these pages (such as scrolling, clicks and mouse-overs), as well as methods used to browse away from the page, and any phone numbers used to call our customer service number or social media handle used to connect with our customer service team.

We collect this information:

• directly from you, among others, during one of your visits to the reception desk of our premises, by the deposit of your business card at the reception desk, through our website, during a meeting or a telephone interview, at a trade show or exhibition, or in the context of the organisation of a competition; or
• from another source, namely the company you work for or the association of which you are a member, databases of online restaurant booking platforms, databases of our partners or associations of which we are a member, databases of our global hotel management system, and editors of print and audio-visual media.

Why and on what legal grounds we process your data

The legal basis on which we process your personal data is as follows:

• where it is necessary to obtain your prior consent to the processing concerned in order for us to be allowed to do it, we will obtain and rely on your consent in relation to the processing concerned;
• otherwise, we will process your personal data where the processing is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into such a contract;
• for compliance with a legal obligation to which we are subject; or
• for the purposes of the legitimate interests pursued by us or another person, provided that this will only be in circumstances in which those legitimate interests are not overridden by your interests or fundamental rights and freedoms which require protection of personal data.

In particular, if you are or work for a customer or supplier of the hotel, or a company with which we have or wish to maintain a business relationship, we process your personal data in order to:

• provide products and services to customers or other users of those goods and services;
• obtain goods and services from suppliers or service providers;
• manage and administer our relationships with customers, suppliers and other users of our goods and services; and
• inform you about our rooms, our spaces and our services, including promotions and new services, if you have agreed to receive such information.

When we inform you about our services, this can be done through communications (such as emails) or telephone calls for prospecting purposes. This may include making suggestions and recommendations about goods or services that may interest you or the person you work for, and will be subject to your stated preferences where relevant. In that situation, the processing of your data is based on your consent, which you can withdraw at any time (see the section on your rights).

We also process your data for the following purposes:

• to administer our website under our terms and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
• to improve our site to ensure that content is presented in the most effective manner for you and for your computer;
• to keep our website and other systems safe and secure; and
• to measure or understand the effectiveness of the advertising we submit to you and propose to third parties, and to propose relevant advertising.

If we plan to process your personal data for purposes other than those mentioned above, we will notify you beforehand.

How long will your personal data be retained?

If you are or work for a customer or a supplier, we retain your personal data for the duration of the contractual relationship and for a maximum of 3 years following your last booking, after which they will be deleted or archived, except if we must continue their processing in order to comply with legal obligations to which we are subject or for any other legitimate and lawful purpose.

If you are or work for a person with whom we have a business relationship or wish to maintain such a relationship, we will retain your personal data up to 3 years from the collection of your data, after which they will be deleted or archived, except if we must continue their processing in order to comply with legal obligations to which we are subject or for any other legitimate and lawful purpose.

Who has access to your personal data?

The following departments within our company have access to your personal data:

• the booking department;
• the commercial department (including marketing);
• the general management;
• the financial department (including purchases); and
• the IT department (internal or external).

We may also disclose your personal data, within the limits of this privacy policy, to appropriate third parties, including:

• our business partners, customers, suppliers and subcontractors for the performance of any contract we enter into or other dealings we have in the normal course of business with you or the person that you work for; and
• our auditors, legal advisors and other professional advisors or service providers.

In relation to information obtained via our website, we may also disclose your data:

• to Google (Google Analytics via Google Tag Manager) to produce statistics on how our website is used – only with your consent, see the “Cookies” section; and
• to the providers listed in the “Service providers and third parties” section, who process data on our behalf (e.g. hosting, email delivery, online booking).

We do not share personal data with advertisers or advertising networks.

Other disclosures we may make

We may disclose your personal data to third parties:

• in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets, subject to the terms of this privacy policy;
• if we (or a significant portion of our assets) are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets; and
• if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to protect the rights, property or safety of ourselves, our customers or others.

Where and how do we process your personal data?

We generally process your data within the European Economic Area ("EEA") and Switzerland. The European Commission has issued an adequacy decision for Switzerland. Some of our service providers (Google, Resend and Microsoft) are based in the United States or use facilities there, so data may be transferred to the United States. Any such transfer takes place only on the basis of the EU-US Data Privacy Framework (an adequacy decision of the European Commission) or the standard contractual clauses approved by the European Commission.

All personal data processed is stored securely. Any payment transactions are encrypted using the appropriate technology. Where we have given to you (or where you have chosen) a password which enables you to access certain parts of our website or systems, you are responsible for keeping this password confidential. We ask you not to share it with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our website and any transmission is at your own risk.

Once we have received your information, we will use strict procedures and security measures to prevent unauthorised access.

Cookies

We use cookies and similar technologies on our website. We only place cookies that are not strictly necessary after you have given your consent, which you can grant, refuse or change at any time via the cookie banner or the “Cookie Settings” link in the footer of our website.

• Necessary cookies and storage: required for the website and our online booking system (provided by Mews) to work. These include your cookie choice ("axis-cookie-consent", stored in your browser), the room and dates you pick in the booking bar (cookie "axis-booking-preferences", 30 days, only set once you make a selection there), a draft of the contact form until you send it ("axis-contact-draft", in your browser only) and your decision to load Google Maps ("axis-map-consent"). These entries do not leave your device (except the booking selection, which is sent along to our server) and cannot be disabled. The website also sets the session cookie "NEXT_LOCALE" to remember your language (deleted when you close your browser), and the Mews booking system may set the security cookie "__cf_bm" (30 minutes) via its provider Cloudflare to block automated traffic.
• Statistics cookies: Google Analytics (via Google Tag Manager, cookies "_ga" and "_ga_*", stored for up to 2 years) and the tracking feature of our booking system Mews measure how the website is used so we can improve it. Google Tag Manager is only loaded after you consent – before that, no connection to Google is made. The legal basis is your consent (Art. 6(1)(a) GDPR).

You can withdraw your consent to statistics cookies at any time, as easily as you gave it, via the “Cookie Settings” link in the footer.

Service providers and third parties

Hosting

Our website is operated by Vantaggio Hosting (vantaggio-hosting.ch, Switzerland). The servers are located in a data centre of Hetzner Online GmbH in Germany.

Each time the website is accessed, the server processes technically necessary data (IP address, date and time, page requested, browser type and operating system) in order to deliver the website and keep it secure. The legal basis is our legitimate interest in secure and stable operation (Art. 6(1)(f) GDPR). These logs are kept only as long as necessary for these purposes.

Contact form and email

If you write to us using the contact form, we process the details you provide (name, email address, optionally phone number and preferred dates, subject and message) in order to answer your enquiry. The legal basis is taking steps prior to entering into a contract (Art. 6(1)(b) GDPR) or our legitimate interest in responding to your enquiry (Art. 6(1)(f) GDPR).

The message is delivered via the email service Resend (Resend, Inc., USA) to our mailbox at Microsoft (Outlook/Hotmail). To prevent abuse, your IP address is held briefly (at most one hour) in the server's memory and is not stored permanently.

Online booking (Mews)

For online bookings we use the booking system provided by Mews. When you open the booking window, the data required for the booking is transmitted to Mews; payments are processed by the payment provider Datatrans (Switzerland). The legal basis is the performance or preparation of the accommodation contract (Art. 6(1)(b) GDPR). The booking system is loaded on every page so you can book at any time; its statistics feature is only active with your consent.

Google Maps

In the footer of the website you can choose to display a map from Google Maps (Google Ireland Limited, Ireland). The map is only loaded when you click “Load map”. Only then is data such as your IP address transmitted to Google, including to Google LLC in the United States, and Google may set cookies. The legal basis is your consent (Art. 6(1)(a) GDPR). Your decision is stored in your browser; you can withdraw it at any time by clearing the site data in your browser.

Google Tag Manager and Google Analytics

With your consent, we use Google Tag Manager and Google Analytics (Google Ireland Limited, Ireland) to produce statistics on how our website is used. This involves processing your IP address, device and browser information and the pages you visit, among other data; a transfer to Google LLC in the United States is possible. Advertising features are disabled. You can withdraw your consent at any time via the “Cookie settings” link in the footer.

External links and fonts

Links to Google Maps, Tripadvisor and other external websites only transmit data to the respective provider once you click them. The fonts used on our website are loaded from our own server; no connection to third parties is made.

Your rights

You have the following rights regarding the personal data relating to you that we process:

• you may request access to your personal data;
• when we are processing your personal data on the basis of the pursuit of one of our legitimate interests (including profiling), you have the right to object at any time to the processing of such data;
• you have the right to receive personal data relating to you that you have provided to us, in a structured, commonly used and machine-readable format, and to transmit it to another data controller when the processing is based on your consent or the performance of a contract and is carried out by automated means (right to portability). You may also obtain that the personal data in question are directly transmitted to another controller;
• you have the right to obtain a limitation of processing when you challenge the accuracy of the data, when the processing is illegal and you object to deletion of the data, when we no longer need your personal data for the purpose of processing but you need them to establish, exercise or defend your rights in court, or when you have objected to the processing during verification of whether our legitimate grounds prevail over yours; and
• you may request that incorrect data that we are processing be rectified.

In certain circumstances (normally where the personal data has been provided by you and it is no longer necessary for us to continue to process it), you may be entitled to request that we erase the personal data concerned.

When we are processing personal data on the basis of your prior consent, you may withdraw your consent at any time, after which we shall stop the processing concerned.

How to withdraw your consent or exercise your rights

You can withdraw your consent to any relevant processing of personal data, and exercise the rights described above, by emailing us at axishotel@hotmail.com or by writing to us at the address given below.

Please note that we may be required to ask you for further information in order to confirm your identity before we provide the information requested.

If you have a complaint about any processing of your personal data being conducted by us, you can contact us or lodge a formal complaint with the Data Protection Authority. The Data Protection Authority is the supervisory authority in Belgium. It may provide further information about your rights and our obligations in relation to your personal data, as well as deal with any complaints that you may have about our processing of your personal data.

Practical information

Changes to this privacy policy

Any future changes to our privacy policy will be posted on this page and will be notified to you by email. We thank you for reviewing it regularly for updates or changes.

Questions?

If you have any questions about your personal data or how we process them, or if you have concerns about a possible data breach, please email us at axishotel@hotmail.com.

Our contact details

• Hotel Axis, Leuvensesteenweg 749, 3071 Kortenberg, Belgium
• Contact person: Robert Petrosjan, GDPR controller
• Telephone: +32 2 759 30 33
• Email: axishotel@hotmail.com