Jinjiang Hotel Privacy Policy

 

Published:

Effective Date:

 

I. Introduction

II. How we collect and use your Personal Data

III. How we share your Personal Data

IV. How we transfer your Personal Data

V. How we protect your Personal Data

VI. How we store your Personal Data

VII. Your Rights

VIII. How we protect minors' Personal Data

IX. Your obligations

X. Changes to the Privacy Notice

XI. Contact information

ANNEX1 Third party SDK platforms 

ANNEX2 Additional privacy provisions applicable to processing of personal information of residents of certain countries

 

I. Introduction

This policy only applies to the Jin Jiang Hotel Reservation website operated by Shanghai Jin Jiang International E-commerce Company Limited, Guangzhou Branch (hereinafter referred to as we, us, our). We respect and recognize the importance of your privacy, and are committed to protecting the privacy, confidentiality and security of the personal data you provide to us or that we collect about you when you use our website [www.jinjianghotels.com.my/www.jinjianghotels.id/www.jinjianghotels.co.id/www.jinjianghotels.com.vn]  or our mobile application(s) and other online Site and services ("Site") by adhering to the following principles:the principle of consistency of authority and responsibility, the principle of clarity of purpose, the principle of opt-in consent, the principle of minimum use, the principle of ensuring security and the principle of participation of the subject, and the principle of openness and transparency. At the same time, we promise that we will take appropriate security measures to protect your Personal Data in accordance with the industry's mature security standards.

You will be asked to consent to the terms of this Privacy Policy when making a reservation, registering for becoming the Jinjiang membership, or otherwise corresponding with us via the Site or otherwise where required under applicable law. Subject to the requirements of applicable law, your continued use of the Site will constitute your deemed consent or acknowledgement to the terms of this Privacy Policy.

Please read and understand this Privacy Policy carefully.

 

II. How we collect and use your Personal Data

Personal Data refers to all kinds of information recorded electronically or by other means that can, alone or in combination with other information, identify a specific natural person or reflect the activities of a specific natural person. In the course of your use of the Jinjiang Hotel Reservation website, we will only collect and use the information that you voluntarily provide during or as a result of your use of the services for the following purposes described in this policy, in the following manner, in order to provide you with the services, to optimize our services, and to protect the security of your account:

1. Member registration and order fulfillment

(1) In order to complete the registration of your membership, we will ask you to provide your email address for the purpose of logging in to your account, identifying you, and providing you with functions or related services for which real-name authentication is required by statute (e.g., to enable content uploading, posting, sharing, and commenting through the Service).

(2) You can choose to register/join member in Site. At this time, after completing the registration of member, we may need to automatically generate your member nickname, member level, member card number, member avatar and member registration time and member points.

2. Points Calculation and Redemption

In order to record and calculate your Membership Points, we may collect the amount of your order and the use of your Membership Points on each Jin Jiang service.

3. Message notification

You understand and agree that we may send you Email notifications based on your email address in the course of our operations for the purpose of informing users of news, identity verification, security verification, research on user experience and communication of complaints and feedback; we may also send you Email notifications via your email address to provide you with commercial information such as services, feature introductions or activities that may be of interest to you. If you do not wish to receive such information, you can unsubscribe through the unsubscribe method provided in the SMS/message, or contact us to unsubscribe.

4. Hotel room reservation

You understand and agree that in order to enable you to reserve a room in the hotel of your choice, confirm the occupant's information, register your arrival and departure at the hotel, we will ask you to provide your name, Email Address document type and document number of you or the actual occupant (such as passport number or national ID number), hotel reservation information (such as the dates of your stay, meal plan, rate), personal preferences.

5. Cookies and other technologies

Cookies and device information identifiers and similar technologies are commonly used on the Internet. When you use the Service, we may use the relevant technology to send one or more cookies or anonymous identifiers to your device to collect, identify information about you when you visit, use the Site. We promise not to use cookies for any purpose other than those described in this Privacy Policy. Most browsers provide users with the ability to clear their browser cache data, and you can do so in your browser settings. If you do so, you may not be able to use the services or features provided by us that rely on cookies. We use cookies and similar technologies to fulfill the following functions or services: (1) to ensure the safe and efficient operation of our Site and services. We may set authentication and security cookies or anonymous identifiers that allow us to verify that you have logged on to the Services securely or that you are not experiencing misappropriation, fraud, or other wrongdoing. These technologies also help us to improve the efficiency of the Services and increase login and response times. (2) To help make your visit easier. The use of such technologies can also help you eliminate the need to repeat the steps and processes (such as form filling) that you use to fill in your Personal Data and enter your searches, thus helping you to have a more relaxed visiting experience. (3) To recommend, display and push content that may be of interest to you. We may use such technologies to understand your preferences and usage habits and to analyze data in order to improve our Site and services and to recommend information or features that may be of interest to you.

6. Changes in the purpose of collection and use of Personal Data

Please understand that as our business develops, related services may be adjusted and changed. When the new function or service is related to the function or service we currently provide, the Personal Data collected and used will usually have a direct or reasonable relationship with the original processing purpose. In scenarios where there is no direct or reasonable connection to the original processing purpose, we will collect and use your Personal Data, inform you again, and obtain your consent.

7. Potential Investors Data Collection

In order to be considered as a potential investor of our hotel, you acknowledgae and agree that you are required to provide us with your full name, email address, and the location of the property you intend to invest in. Upon receipt of the submitted data, we will contact you via the email address provided.

8. Personal Data exempted from consent and use by law

(1)  Necessary for the conclusion and performance of the contract between you and us;

(2) Those directly related to national security, national defense security and other national interests; and those directly related to public safety, public health, public information and other significant public interests;

(3) Directly related to the investigation, prosecution, trial and enforcement of sentences for crimes;

(4) For the purpose of safeguarding the life, property, reputation and other important legal rights and interests of you or other individuals, but it is difficult to obtain the consent of the person himself/herself;

(5) The Personal Data collected is disclosed to the public by you;

(6)  Collecting Personal Data from lawful publicly disclosed information, such as lawful news reports, governmental information disclosure, and other channels;

(7)  Necessary for maintaining the safe and stable operation of the Site or services provided, such as detecting and disposing of malfunctions in the Site or services;

(8)  Necessary for legitimate journalism;

(9)  If the Personal Data contained in the results of academic research or descriptions is de-identified when it is necessary to conduct statistical or academic research in the public interest and when the results are made available to the public;

(10) Other cases stipulated by laws and regulations.

 

III. How we share your Personal Data

1. Basic principles

(1) In order to ensure the provision of relevant services to you, we may share your Personal Data with our partners when necessary. However, unless otherwise provided by law, we will not share your Personal Data without your individual consent, unless the Personal Data shared is de-anonymized and the sharing third party is unable to re-identify the natural person subject of such information.

(2) We will only share Personal Data that is necessary to provide services to you for legitimate, legal, necessary, specific, and clear purposes. We will carefully assess the purpose of the third party's use of the shared information and its ability to provide security, and require them to follow the legal agreements related to the cooperation. If the third party uses the information for a purpose beyond the scope of the original authorized consent, they will need to obtain your consent again.

2. Synchronized display of member-related information

Unless otherwise specified, you may associate your membership with each Jin Jiang service. In order for us to provide you with a unified service, you authorize us to display your member-related information and content, i.e.,Email Address, member points information, on each service, but we will not share the aforementioned information with the operators of each service.

3. Commissioning

In order to analyze the usage of our services, develop new functions, maintain the services and improve your experience, we may commission our affiliates or third parties to process your information, including information about the terminal you use, the network you use and information about your usage behavior. We will conduct due diligence and sign contracts with the affiliates or third parties that we entrust to process your information to ensure that they comply with this Privacy Policy and relevant laws and regulations.

4. Changes in operations

As our business develops, we may undergo mergers, divisions, acquisitions, or asset transfers, and your Personal Data may be transferred as a result. In the event of such changes, we will notify you of the name and contact information of the recipient, and require the recipient to protect your Personal Data in accordance with laws and regulations and security standards no less stringent than those set forth in this Privacy Policy, and in the event of a change in the recipient's original purpose or method of processing, we will require the recipient to obtain your authorization and consent again.

5. Your publishing and sharing

You are aware and understand that if you post information, share information, or submit other content for viewing by others in the course of using the Service, such information may be accessible to the public or other users of our Service. Such information may appear in search engine results or on other publicly available platforms and may be crawled or accessed by third parties. As a result, some content may remain publicly accessible even after we delete your Personal Data stored on our servers at your request. We ask you to be careful about sharing your Personal Data.

 

IV. How we transfer your Personal Data

1. You understand and agree that we may transfer Personal Data to other jurisdictions as necessary for the purposes described in this Privacy Notice. In particular, we will transfer your Personal Data to the hotels you have booked which may be located in jurisdictions that may not provide the same level of data protection as the jurisdiction in which your Personal Data was originally collected. We may also transfer your data to Singapore because our main servers are located there.

2. When we transfer your Personal Data to other countries or jurisdictions, we will protect that data as described in this Privacy Notice and in accordance with applicable law. Where required under applicable law, we will put in place binding contractual obligations with the data recipient to safeguard your data protection rights. Furthermore, we will notify any data transfer and/or data transfer mechanisms to the competent Supervisory Authority where required under applicable law.

 

V. How we protect your Personal Data

1. We take the security of your Personal Data very seriously and will endeavor to take reasonable security measures to protect your Personal Data from improper use or unauthorized access, public disclosure, use, modification, damage, loss or leakage of the Personal Data you provide. We will use no less than market-accepted encryption technology (e.g. SSL), anonymization and related reasonably practicable means to protect your Personal Data, and security protection mechanisms to reduce the risk of malicious attacks on your Personal Data. Access to this information will be provided only to authorized individuals for legitimate business purposes. 

2. After the unfortunate occurrence of a Personal Data security incident, we will, in accordance with the requirements of laws and regulations, promptly inform you of: the basic situation of the security incident and its possible impact, the disposal measures that we have taken or will take, the suggestions that you can independently prevent and reduce the risk, and the remedial measures for you. We will promptly inform you of the situation related to the incident by email, letter, push notification, etc. When it is difficult to inform the subject of Personal Data one by one, we will take a reasonable and effective way to make a public announcement.

3. Please understand that, despite the above reasonable and effective measures and compliance with the standards required by relevant laws and regulations, due to technological limitations and the possible existence of a variety of malicious means, even if every effort is made to strengthen security measures, it is not possible to always ensure that 100% of the information is safe.

 

VI. How we store your Personal Data

1. Storage location

Your Personal Data will be stored on servers in Singapore.

2. Storage period

We retain your Personal Data for as long as necessary to provide you with our services, to comply with applicable laws, to resolve disputes with any party, and to accommodate our business needs, including the detection and prevention of fraud or other nefarious activity. All Personal Data we retain is subject to this Privacy Policy.  If you have questions about the length of time we retain a particular piece of Personal Data we process, please contact us using the contact information below.

Member Contact Email [itts@jinjianghotels.com.cn ] 

3. Deletion of information

We will delete your Personal Data in any of the following cases, unless otherwise specified in the relevant regulations:

(1) The purpose of the treatment has been achieved, cannot be achieved, or is no longer necessary to achieve the purpose of the treatment;

(2) The Personal Data processor stops providing Site or services, or the retention period has expired;

(3) Individual withdrawal of consent;

(4) The Personal Data processor handles Personal Data in violation of laws or administrative regulations or in violation of the agreement;

(5) Other cases stipulated by laws and administrative regulations. If the retention period stipulated by laws and administrative regulations has not expired or if deletion of your Personal Data is technically difficult to achieve, we will stop processing your Personal Data other than storing it and adopting the necessary safety protection measures.

 

VII. Your Rights

We attach great importance to the management of your Personal Data and make every effort to protect your rights to access, copy, rectify, supplement, delete, withdraw consent and authorization, cancel membership, and report complaints regarding your Personal Data, in order to enable you to have the ability to understand and protect the security of your Personal Data. Please understand that specific services may require your information in order to provide, when you withdraw your consent or authorization, we can not continue to provide you with the corresponding services, and will no longer handle your corresponding Personal Data. However, your decision to withdraw your consent or authorization will not affect our previous Personal Data processing activities based on your authorization. Generally, you have the following rights on how we process your personal data:

1. Setup Management

When you choose to use some of the features and services of the Service, we may ask you to authorize system notification permissions, which you can turn off in the settings page of your device system. If you refuse authorization, you will not be able to use the relevant features, but it will not affect your use of other features and services of the Service.

2. Information.

You have the right to be provided with clear, transparent and easily understandable information about how we use your Personal Data, and your rights. This is why we are providing you with the information in this Privacy Notice.

3. Accessing, rectifying, supplementing and deleting your Personal Data

You can access, rectify, supply and delete your Personal Data, such as your email address and points record (for inquiries only), through the relevant settings page within the Jin Jiang server. If you want to access, correct, supplement or delete your other Personal Data, you can contact us in the manner indicated in this Privacy Policy .

4. Copying and transferring your Personal Data

If you need to copy, transfer your Personal Data collected and stored by us in accordance with the conditions stipulated by laws and administrative regulations, you can contact us in the manner indicated in this Privacy Policy.

5. Withdrawing Consent.

 Wherever we rely on your consent, you will be able to withdraw that consent at any time you choose and at your own initiative by logging in to your Member account on our website (if you have one), for commercial communication directly by clicking unsubscribe to the email or by visiting our Privacy Center here. The withdrawal of your consent will not affect the lawfulness of the collection and processing of your data based on your consent up until the moment when you withdraw your consent. Please note that we may have other legal grounds for processing your data for other purposes, such as those set out in this Privacy Policy.

6. Account Cancellation

(1) If you do not want to enjoy the membership program of a particular Jin Jiang server, you can cancel your account at that server and your membership will be canceled as well.

(2) If you wish to cancel your membership directly, you may contact us in the manner indicated in this Privacy Policy. We will cancel your account within fifteen (15) business days after verifying your personal identity, security status, and device information, for which you may be required to submit identity verification information as prompted by us.

(3) In order to protect the security of your account, you need to wait for 30 days after canceling your membership before you can use the same email address to re-register for membership.

(4) You know and understand that the cancellation of membership is an irreversible action. After the cancellation of membership, your membership points will be zero, you will not be able to log in to Jinjiang server or retrieve any content or information through the member (even if you use the same email address to register for membership again).

(5) Please make sure that the membership account you apply to cancel was created by yourself in accordance with the agreement of the “Member Service User Agreement” and provided to you by us. We suggest that you backup the relevant information and data by yourself before canceling the membership, and please make sure that all services related to the membership have been properly handled. After the cancellation is completed, we will delete your Personal Data or anonymize it (except as otherwise provided by laws and regulations).

7. Automated decision-making in constraint information systems

In some business functions, we may make decisions based solely on non-human automated decision-making mechanisms, including information systems and algorithms. If these decisions significantly affect your legal rights, you have the right to request an explanation from us in the manner indicated in this Privacy Policy and we will provide appropriate remedies.

8. Rights of relatives of deceased members

If you are the next of kin of a deceased member, you may contact us in the manner indicated in this Privacy Policy in order to access the membership information of the deceased member and to process the membership-related points. You are aware and understand that in order to verify your identity, we may ask you to provide documents that can show kinship, death certificates of deceased users and other supporting materials. Please understand that you may not be able to change the email address of the logged-in member for the security of your account.

9. Responding to your other requests

In principle, we do not charge fees for reasonable requests, but we will charge a fee for costs incurred for requests that are repeated more than reasonably possible. We may refuse requests that are unnecessarily repetitive, require excessive technical means (for example, the development of a new system or a fundamental change in existing practices), pose a risk to the legal rights of others, or are highly impractical (for example, involving the backing up of information stored on magnetic tapes). In the following cases, we will not be able to respond to your request as required by law or regulation:

(1) related to the fulfillment of our obligations under laws and regulations;

(2) Directly related to national security and defense security;

(3) Directly related to public safety, public health, and significant public interest;

(4) Directly related to criminal investigations, prosecutions, trials and enforcement of sentences;

(5) There is sufficient evidence of subjective malice or abuse of your rights;

(6) For the purpose of safeguarding the life, property and other important legal rights and interests of the subject of the Personal Data or other individuals, but it is difficult to obtain the consent of the individual;

(7) Responding to your request will result in serious damage to the legitimate rights and interests of you or other individuals or organizations;

(8) Those involving trade secrets.

 

VIII. How we protect minors' Personal Data

1. We take the protection of minors' Personal Data very seriously. If you are a minor who is under the age of 18 (or minor of age depending on the country), we request you to ask your guardian to read this Privacy Policy carefully and to use our Site/services or provide information to us with the consent of your guardian.

2. We do not actively collect Personal Data from minors directly. In the event that we collect Personal Data from a minor with the consent of the guardian, we will only use, share, transfer, or disclose such information as permitted by law or regulation, with the consent of the guardian, or as necessary for the protection of the minor.

3. If it is proved that a minor has registered and used our Site/services without the consent of his/her guardian, the guardian may contact us through the means stated in this Privacy Policy and we will delete the Personal Data of the minor concerned as soon as possible after confirmation.

 

IX. Your obligations

1. We expect that you only communicate Personal Data about yourself to us. If you also communicate Personal Data about other people to us, then you must ensure that you comply with any legal obligations that may apply to your provision of the information to us, and to allow us, where necessary, to use, process and transfer that information.

2. We also expect that the Personal Data that you communicate to us are correct and that, if your Personal Data require updating, you will promptly inform us.

 

X. Changes to the Privacy Notice

In order to provide a better service, the Service will be updated and changed from time to time and we may revise this Privacy Policy from time to time. If we make significant changes that will affect you (for example, if we use your Personal Data for purposes other than those stated above), we will contact you in advance of the operation. When this Privacy Policy is updated, we will issue an updated version and remind you of the update by appropriate means.

 

XI. Contact information

If you think that your Personal Data rights may be infringed upon or you find clues of infringement of Personal Data rights, or if you have questions or suggestions about the protection of Personal Data when using this service, you can contact us by email: Member contact e-mail [itts@jinjianghotels.com.cn], we will review your questions or suggestions as soon as possible and respond within fifteen working days after verifying your membership status.

 

ANNEX 1 Third party SDK platforms

 

 

ANNEX 2 Additional privacy provisions applicable to processing of personal information of residents of certain countries

 

 

 


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