Data Privacy & Security Policy

 

References to “OUR”, “US” or “WE” within this policy are to Speke Resort and Conference Centre. This Privacy Policy governs the collection and use of personal information by Speke Resort and Conference Centre. For more information about Speke Resort and Conference Centre, please see: www.spekeresort.com.

We are committed to protecting and respecting your privacy.  This Privacy Policy explains the types of personal information we collect, how we use that personal information, who we share it with, how we protect that information, and your legal rights in relation to your personal information. We are committed to abiding by this Privacy Policy, as well as the requirements of applicable laws, in the operation of our business.

Please read the following carefully as it explains our views and practices regarding your personal information, and how it is handled. By accessing or browsing our website or using our services or facilities, you confirm that you have read, understood and agree to this Privacy Policy in its entirety.  If you do not agree with the practices described in this Privacy Policy, you should not use our website or our services or facilities.

 

Who we are

For the purpose of applicable data protection laws, the data controller is Speke Resort of Speke Resort and Conference Centre, Wavamunno Road, P. O. Box 446, Kampala, Uganda

If you use our facilities and services, the entity which manages the relevant facility or service (“Country Manager”) will also be a data controller in respect of your personal data. A list of such facilities and services and the respective Country Manager can be found here.

Information covered by this Privacy Policy

This Privacy Policy covers all personal information collected and used by Speke Resort and Conference Centre.  In this Privacy Policy, “personal data” or “personal information” means information that (either in isolation or in combination with other information held by us) enables you to be identified as an individual or recognized directly or indirectly.  This may include your name, date of birth, nationality, gender, postal address, email address, phone number, credit card number, details of the preferences you express to us during your stay at one of our hotels (e.g. room type) dietary requirements, and technical information from the devices you use to access our website.

What information do we collect from you?

We may collect information about you from different sources as detailed below.

Information you give us

You may also choose to provide information in relation to your reservation, stay or visit to Speke Resort and Conference Centre. You may also give us information about yourself when you respond to a communication from us or by filling in forms (both online and offline), over the telephone and through written correspondence with us (e.g. in relation to guest registration cards, spa and fitness club membership applications, loyalty enrolment forms, or online booking forms).

The information you give us may include your name, postal address, email address, date of birth, payment card information, landline and/or mobile telephone number, preferences (e.g. room type), general feedback on your stay, dietary requirements, allergies, as well as other personal information.

Information we collect about you

We may collect information about your use of our facilities and services, your preferences in this regard, and details of purchases and bookings you make with us.

When you visit our website, we may use cookies and other technologies to automatically collect the following information:

technical information, including the Internet Protocol (IP) address used to connect your computer to the internet, your login information, browser type and version, device identifier, location and time zone setting, browser plug-in types and versions, operating system and platform, page response times, and download errors;

information about your visit, including the full Uniform Resource Locators (URL) clickstreams to, on and from our websites;

length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouseovers) and methods used to browse away from the page.

Information we receive and collect from other sources:

We may receive information about you from other websites operated by the Jumeirah group or from the other services that we provide.  We also work closely with third parties such as airlines, travel agents, tour operators and third party agents and may receive information about you from them.  We may also collect information about you from publicly available sources, including publicly available content on social media.

Cookies

Our website uses cookies and similar technology. A cookie is a small file of letters and numbers that our website places on your computer, or other equipment which you use to access our website. These cookies allow us to distinguish you from other users of our website.

You can read more about cookies and how to recognize them at www.aboutcookies.org.

Cookies perform many functions, such as allowing you to navigate between pages efficiently, remembering your preferences, and generally improving the user experience. They can also help to ensure that advertising that you see online is more relevant to you and your interests.

Your use of our website indicates your consent to the cookies described in this policy. Please see “How you can control cookies” below for more information on how to withdraw your consent at any time.

Type of cookie

What does it do?

First party cookies (cookies that belong to Jumeirah and that Speke Resort and Conference Centre places on your device)

  1. System cookies: these cookies allow us to personalize your experience when you visit our website. They help us to remember your account, settings and preferences, this means we can remember the language you prefer, the level of privacy you require and each of your previous actions on the website.
  2. Behaviour cookies: these cookies collect information on what you look at while you visit our website. This allows us to remember the different stages of your visit, for example the last hotel you viewed.
  3. Other cookies: these cookies collect information to support the analytics tools we use on the website, which in turn allow us to monitor the functionality and aggregated use of the website.

Third party cookies (cookies that another party places on your device through our website)

  1. Advertising cookies: these cookies are used to deliver adverts which are more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as to help measure the effectiveness of our advertising campaigns. They also remember when you have visited the website before. Sometimes we share anonymised information about your browsing activity with our advertising and creative partners. They may use this information to advertise products which may interest you, on other websites or to assist us develop future advertising campaigns.
  2. Analytics cookies: these cookies are used to identify you and to collect your relevant geographic, demographic and behavioural data. They tell us how popular a certain feature is, or whether you open an email we send.
  3. Optimisation cookies: these cookies allow us to monitor your use of the website in order to optimise your experience.

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) also use cookies, over which we have no control. How you can control cookies

Your web browser includes an option that allows you to refuse the setting of all or some cookies. However, if you do so, you may not be able to access parts of our website and it may make your browsing experience less enjoyable. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies as described above when you access our website. If you would like to delete any cookies on your computer please refer to your browser manufacturer’s instructions by clicking ‘help’ in your browser menu.

How do we use your personal information?

We may use your personal information to:

How do we use personal information for this purpose?

What is the legal basis for us processing your information in this way?

Provide you with services you request from Jumeirah, such as spa or gym services, concierge services, hotel bookings etc.

We will need to use your personal information where this is necessary for us to perform our obligations under a contract with you, for example where you have requested use of our spa or gym facilities or have made a booking at one of our hotels.

Using your personal information in this way is necessary for us to perform our contractual obligations to you.

Complete bookings you make through our website, such as hotel, spa and restaurant bookings.

We will need to use your personal information (such as your email address or dietary requirements) to assist you with any bookings you have made through our website.

Using your personal information in this way is necessary for us to perform our contractual obligations to you.

Manage your membership of the Jumeirah Sirius and/or the isme by Jumeirah programmes (our recognition and rewards programme).

We will need to use your personal information (such as your name, date of birth, telephone number and email and postal address) to administer the Jumeirah Sirius and isme by Jumeirah programmes, to communicate with you about the programmes, and to send you news of related special offers and promotions.

Using your personal information in this way is necessary for us to perform our contractual obligations to you.

Where contacting you to send you news of special offers and promotions, to the extent required by applicable law, we will ask for your consent before processing your information in this way.

Contact you to provide you with information about Jumeirah’s services and latest offers including tailoring such information to your interests (e.g. based on your browsing history and purchase history) (provided you have consented to this).

We will need to use your personal information (such as your email address or other contact details) to send you information about Jumeirah’s latest offers that you may be interested in. Please note we may also share your personal information with other entities in the Jumeirah group for this purpose.

It is in our legitimate interests to use your contact information and other personal data we receive and collect about you to send you details of Jumeirah’s latest services and offers that may be of interest to you, provided this is in line with your marketing preferences.

To the extent required by applicable law, we will ask for your consent before processing your information in this way.

Combine information we receive and collect (e.g. from your requests, preferences and purchase history) to understand your interests and preferences and provide you with a more personalised experience.

We may combine the information we receive and collect about you to better understand your interests and preferences, so that we can provide you with an experience that is tailored to those interests and preferences.

For example, we may do this by offering you use of certain facilities (such as spas and gyms) that you are most likely to be interested in, or sending you personalised offers or promotions by email (where you have agreed to receive our emails), or offering you advertising content that is relevant to your interests.

It is in our legitimate interests to personalise our services and advertising for you to better meet your needs as a customer, and to ensure that we provide the best service possible to our customers, provided this is in line with your marketing choices. We will look at your preferences that we derive from your purchase history and the preferences you communicate to us so that we can achieve this.

Comply with legal requirements and exercise or defend legal claims.

We may sometimes need to process personal information to comply with legal requirements to which we are subject (for example in relation to health and safety).

It is in our legitimate interests to process personal information for the purposes of exercising and defending legal claims. Processing personal information may also be necessary to ensure compliance with the Speke Resort and Conference Center legal obligations.

Process your payments and protect against fraudulent transactions.

We may need to process your personal information in order to keep your payments safe and secure and protect against fraudulent transactions.

It is in our legitimate interests to process personal information to keep our customers’ payments secure and to prevent fraud. Processing personal information in this way may also be necessary to ensure compliance with the Speke Resort and Conference Center group’s legal obligations.

Process your personal information where this is necessary to keep our website safe and secure.

We may need to process your personal information in order to keep our website safe and secure and protect against illegal or fraudulent activity such as cyber attacks.

It is in our legitimate interests to monitor how our website is used to detect and prevent fraud, other crimes and the misuse of our website.  This helps us to ensure that you can safely use our website.

Keep an up to date suppression list where you have asked not to be contacted, so we do not inadvertently re-contact you.

We understand that you may prefer for us not to contact you with details of our products, services, or promotions. We keep records of your preferences to ensure that we do not contact you if you have asked us not to.  We may need to process certain of your personal information (such as your name and email address) in order to do this.

It is in our legitimate interests to process personal information in order to maintain an up to date suppression list and ensure that we do not contact you where you have asked us not to.

Transfers of personal information

Speke Resort and Conference Centre

We may share your personal information with any member of Speke Resort and Conference Center in order to enable you to request our services, to process your payments, understand your preferences, send you information about products and services that may be of interest to you and conduct the other activities described in this Privacy Policy. Such group companies may be located outside the East African Community, in which case the section “Where we store your data” below will apply.

Our service providers

We use other companies, agents or contractors (“Service Providers”) to perform services on our behalf or to assist us with the provision of services to you. For example, we may engage Service Providers to provide concierge services, housekeeping and laundry services, marketing, advertising, communications, services in connection with IT services, to personalise and optimise our service, to analyse and enhance data (including data about users’ interactions with our services), and to provide legal, accounting, insurance, audit and other professional services.  In the course of providing such services, these Service Providers may have access to your personal information. However, these Service Providers are contractually bound only to use personal information to perform the services that we hire them to provide.  We will always use our best efforts to ensure that all the Service Providers we work with will keep your personal information secure.

Our partners, subject to your consent

We may share your personal data with our key partners, which include certain airlines and financial partners. For example, our airline Frequent Flyer Programmes enables our guests to earn miles for every stay, as well as benefit from exclusive special offers. Speke Resort and Conference Centre also has relationships with other companies including financial and luxury brands, whereby our customers can also benefit from exclusive experiences with our partnerships

Third parties permitted by law

In certain circumstances, we may be required to disclose or share your personal information in order to comply with a legal or regulatory obligation (for example, we may be required to disclose personal information to the police, or to judicial or administrative authorities).

We may also disclose your personal information to third parties in order to enforce our terms and conditions or other agreements, or to protect the rights, property or safety of Speke Resort and Conference Centre or the public.

Third parties connected with business transfers

We may transfer your personal information to third parties in connection with a reorganisation, restructuring, merger, acquisition or transfer of assets, provided that the receiving party agrees to treat your personal information in a manner consistent with this Privacy Policy.

Where we store your personal information

All information you provide to us via our website is stored on our secure servers.  Any payment transactions carried out via our website will be encrypted using Transport Layer Security (TLS) technology.

Speke Resort and Conference Centre Jumeirah has taken steps to safeguard the integrity of its communications and computing infrastructure, including by implementing authentication, monitoring, auditing, and encryption technology. Security measures have been integrated into the design, implementation, and day-to-day operations of this website as part of our continuing commitment to the security of electronic content and the electronic transmission of information. Despite our best efforts unfortunately the transmission of information via the internet is not completely secure.  Although we have strict procedures and security measures in place, we cannot guarantee the security of your data transmitted to our site.

Third party websites and apps

Our websites may contain links to and from third party websites.  Please note that if you follow a link to any of these websites, these websites will have their own terms of use and privacy policies and that we do not accept any responsibility of liability for these policies.  Please check these policies before you submit any personal data to these websites.

Your rights

You have the following rights with respect to the personal information that we hold about you.

Your right to access the information we hold about you

You can request access to the information we hold about you by contacting us using the contact details set out below.  Our file of your information will usually be made available to you within 30 days, although occasionally we may not be able to give you access to the personal information we hold about you (for example, we may not be able to give you access if it would unreasonably affect someone else’s privacy or if giving you access poses a serious threat to someone’s life, health or safety).  Please note that we may apply an administrative charge for providing access to your information in certain circumstances. Any such charge will be reasonable and we will advise you of the charge and obtain your consent before providing you with access to your personal information. Please note that if you request a copy of your data using electronic means (such as email), then we will provide a copy of your information in electronic form unless you ask us to do otherwise.

Your right to have your information corrected or deleted

If you have an account with us, you can sign into that account to update your personal information.  If you have problems updating the information on your account or if you would like us to delete your information, please email your request to the address set out below and we will action it as soon as possible.

Your right to object to us processing your personal information

You have the right to object to us processing your personal information, even where that processing is necessary for our legitimate interests (for example, where the processing is necessary for the legitimate commercial objectives we pursue in the course of our business), including the profiling we undertake to send you personalised offers, product recommendations and similar content. You also have the right to object to any results of a processing activity that prejudice your rights and that are conducted exclusively through automated systems.

You also have the right to ask us to stop processing your personal information for direct marketing purposes, including any profiling we undertake for the purposes of direct marketing.  We will in any case only send you marketing communications if you have previously agreed to this, but if you change your mind you can easily unsubscribe from our marketing communications at any time by following the instructions included in these marketing communications.

Please note that, if you have consented to receive offers from our partners, our partners are responsible for taking account of your rights, including your right to unsubscribe from receiving offers from them.

Your right to have your personal information transmitted to another organisation

Where we hold personal information about you with your consent or for the performance of a contract with you, you also have the right to ask us to provide you with the personal information we hold about you in a structured, commonly used and machine-readable format and, where technically feasible, to transmit that personal information to another organisation.

Making a complaint

You have the right to lodge a complaint with a local data protection authority in the East African Community. If you believe that we have not complied with applicable data protection laws.

The local data protection authority will differ depending on the country you are in.

Contacting us

If you want to exercise any of the rights set out above, have any questions or concerns about how we treat your personal information, you wish to ask us to stop processing your personal information, or you would like to request a copy of the personal information we hold about you, please contact us privacyoffice@jumeirah.com or by writing to us at:

Speke Resort and Conference Centre

Wavamunno Road,

P. O. Box 446, Kampala

Uganda

Call us:

+256 (0) 414 227 111

+256 (0) 417 716 000

Please include your reply address when you write to us.

How long do we keep your personal information?

Your personal information is stored by us and/or our Service Providers, strictly to the extent necessary for the performance of our obligations and strictly for the time necessary to achieve the purposes for which the information is collected, in accordance with applicable data protection laws.  When we no longer need to use your information, we will remove it from our systems and records and/or take steps to properly anonymise it so that you can no longer be identified from it (unless we need to keep your information to comply with legal or regulatory obligations to which we are subject).

Children

You must have reached the reached the minimum age as set out under applicable data protection laws to share your personal information with Speke Resort and Conference Centre, or you must have received permission from your parent or guardian to do so.

Changes to this Privacy Policy

We may update this Privacy Policy from time to time in response to changing legal, regulatory or operational requirements. We will notify you of any such changes (including when they will take effect). Your continued use of our website and / or services after any such updates take effect will constitute acceptance of those changes. If you do not consent to such updates, you should cease using Jumeirah’s website and services.