4. When do we disclose your personal data?
We may disclose or share your Personal Data as follows:
4.1 To Hotels.
The Personal Data you provide to us in connection with making a reservation is shared with the respective hotel for purposes of meeting your reservation request. The hotel may be managed by us but owned by an independent third-party Owner. After your stay, we retain your Personal Data, including the details of your stay and your preferences (e.g., room, type, interest, hobbies, amenities used) to provide you personalized service during your next stay, subject to your preferences.
4.2 To Affiliates.
We are part of a global enterprise and may disclose your Personal Data to other companies or hotels within our group, including in our offices in Hong Kong and in the European Economic Area in order to help render services to you associated with your stay at our hotels and to provide you marketing communications, consistent with your choices. The complete listing of our group companies is as follows:
Penta Hotel Holdings Limited (British Virgin Islands), Penta Hotels (Asia Pacific) Limited (Hong Kong); Penta Hotels Worldwide GmbH (Germany).
4.3 Commercial Service Providers and Suppliers.
We may outsource the processing of certain functions and/or information to third parties that provide services such as Services hosting, data analysis, payment and credit card processing, order fulfilment, customer service, e-mail delivery, financial services companies, delivery services, advertising networks, and information technology. We also share your Personal Data with third-party providers that provide services such as spa treatment, salons, and restaurants within our hotels, or event planners or organizers of any event you plan or host with us.
4.4 External Partners.
We may share your Personal Data with other partners, consultants and advisors who render services to us, including financial institutions, external auditors, lawyers, and credit card issuers.
4.5 Travel-Related Service Partners.
4.6 Social Media and Message Boards.
If you connect to one of our social media pages, we may disclose your Personal Data to your friends associated with your social medial account, to other website users, and to your social media account provider, in connection with your social sharing activities. We may make reviews, message boards, blogs and other user-generated content available to users. Any information disclosed in these areas is public information. You also should exercise caution when deciding to disclose your Personal Data in this context. We are not responsible for the privacy practices of other users including web operators to whom you provide information.
4.7 Business Transfers.
From time to time, a hotel may be sold by its Owner, and Penta may cease to manage such hotel. In those circumstances, we may include Personal Data collected about you, or control of that Personal Data, as a business asset in any such transfer. For example, if we cease to operate a hotel property we do not own, the Owner may continue to have and use your Personal Data for continued business purposes consistent with the hotel’s operations, including direct marketing. Additionally, we may disclose your Personal Data to a buyer or other successor in the event of a merger, sale or other transfer event, in which Personal Data held by us about our users is among the assets transferred.
4.8 Anonymized Data.
We may share aggregated data with third parties collectively in an anonymous way, which does not reveal Personal Data.
4.9 Legal Obligation.