Eko Hotels and Suites (“Eko Hotels and Suites”, “We”, or “Our”) values you as our customer and is committed to protecting your privacy. This Privacy Notice outlines our practices regarding the collection, use, and disclosure of your Personal Data.
We are responsible for your personal data that you may provide to us, as referenced in our terms and conditions or any communications we send you.
This notice applies to individuals who are:
Familiarity with these definitions will help you interpret this notice in line with the Nigeria Data Protection Act 2023 (NDP Act).
| Term | Definition |
|---|---|
| Data Subject | An identified or identifiable natural person who can be directly or indirectly identified by reference to identifiers or factors specific to their physical, physiological, genetic, mental, economic, cultural, or social identity. |
| Local Regulatory Requirements | Any legal, statutory, regulatory, licensing, guideline, ministerial or national-security directive, or data-sovereignty rule with which Eko Hotels and Suites must comply in jurisdictions where we operate or where personal data is processed on our behalf. |
| Data Sovereignty | The principle that personal data is subject to the laws and governance structures of the country in which it is processed. |
| NDP Act | The Nigeria Data Protection Act 2023. |
| NDPC | The Nigeria Data Protection Commission. |
| Personal Data | Any information relating to an identified or identifiable natural person, including but not to name; identification numbers or symbols; contact details; location data; online or unique identifiers (e.g., IP, MAC, IMEI); biometric data; private correspondence; opinions or preferences; and sensitive personal data. |
| Processing | Any operation performed on personal data (manual or automated) including collection, recording, organisation, structuring, storage, adaptation, retrieval, consultation, use, disclosure, dissemination, alignment, combination, restriction, erasure, or destruction. |
| Sensitive Personal Data | A subset of personal data that is inherently more sensitive, such as data revealing racial or ethnic origin; political opinions; religious or philosophical beliefs; trade-union membership; criminal records; genetic or biometric data; health information; or details about a person’s sex life or sexual orientation. |
We currently collect and process the following information:
We collect Personal Data in accordance with the law, and to provide you with exemplary services. Personal Data is information that may identify you as an individual or relate to you as an identifiable individual. We collect and process the following types of Personal Data about you:
Most of the Personal Data we process is provided to us directly by you for one of the following reasons:
| Purpose | Description of Activities Associated With Purpose |
|---|---|
| Booking & Guest Registration | There are a number of activities associated with this purpose, such as: facilitating reservations and bookings of hotel accommodations and related services; engaging in pre-arrival communications (logistics, changes, preferences, etc.); and processing payments and security deposits. |
| On-Site Reception & Stay Services | There are a number of activities associated with this purpose, such as: facilitating check-in and check-out; processing payments; providing concierge, luggage storage and parking services; administering and facilitating access to Wi-Fi, TV and other connectivity services; facilitating in-room dining housekeeping services; handling customer requests, inquiries and complaints. |
| Meetings & Events | There are a number of activities associated with this purpose, such as: communicating with planners and participants about meetings or events; facilitating booking Events and associated participant reservations via all booking channels; engaging in pre- and post- Event communications (logistics, accommodations, changes, payments, etc.); preparing for and coordinating Events in accordance with group, planner, or participant instructions, expectations and preferences; assigning guest rooms; facilitating catering; collecting or processing payments, security deposits, and commissions; handling group, planner, or participant requests, inquiries and complaints; and communicating with participants before, during, and after Events. |
| Eko Hotels and Suites Operations & General Business | There are a number of activities associated with this purpose, such as: administering customer-care services to facilitate and address inquiries, comments and complaints about any of our services (such as in person, through phone lines, email, or on social media); administering the Online Services (including troubleshooting, data analysis, testing, system maintenance, support, reporting and the hosting of data); monitoring and analysing usage of services to improve services, marketing, programs, overall customer experience, gathering feedback, carrying out pilot programs for potential new services and both developing new and improving existing services. |
| Emergency & Incident Response | There are a number of activities associated with this purpose, such as: providing for the security of on-site services; responding to, handling and documenting on-site accidents and medical and other emergencies; actively monitoring properties to ensure adequate incident prevention, response and documentation (including CCTV); requesting assistance from emergency services; and sending notifications and alerts in the event of incidents or emergencies (such as via SMS, email, call, audio-visual device prompts, etc.). |
| Legal & Compliance | There are a number of activities associated with this purpose, such as: complying with applicable laws; complying with legal processes; responding to requests from public and government authorities; meeting national security or law enforcement requirements; enforcing our terms and conditions; protecting our operations; protecting the rights, privacy, safety, or property of the Eko Hotels and Suites Group, guests, visitors and other relevant individuals; and allowing us to pursue available legal remedies and limiting the damages that Eko Hotels and Suites may sustain. |
| Spa, Wellness, & Beauty Services | There are a number of activities associated with this purpose, such as: facilitating reservations and bookings; services and treatments; processing payments; arranging requested professionals for specific treatments and services; and handling customer requests, inquiries and complaints. |
| Fitness & Recreation Services | There are a number of activities associated with this purpose, such as: facilitating reservations and bookings; determining eligibility for services; honouring restrictions and providing appropriate and safe activities and services; providing consistent and personalised service based on past usage and preferences expressed by the individual; processing payments; and handling customer requests, inquiries and complaints. |
| Food & Beverage Services | There are a number of activities associated with this purpose, such as: processing payments and handling customer requests, inquiries, and complaints. |
| Loyalty Programs, Accounts, & Relationship Management | There are a number of activities associated with this purpose, such as: registering users in loyalty and other client account programs and payment card programs; determining eligibility for various programs and related services; administering loyalty programs; providing consistent and personalised offers and services based on past usage and preferences expressed or exhibited by members; ensuring access to Eko Hotels and Suites’ Websites and Apps; processing payments; notifying members about changes to programs, terms and conditions; and handling members’ requests, inquiries and complaints. |
| Marketing, Advertising, and Promotions | There are a number of activities associated with this purpose, such as: communicating about products and services that may be of interest to guests; providing personalised advertisements for products and services, facilitating participation in promotions, analysing data to gain insights and create customer marketing segments; and handling customer requests, inquiries and complaints. |
| Recruitment | This includes analysis of CVs, interviews, communication with job applicants, and other processes related to recruitment. |
| Employment | This includes processing of payrolls, employee management, administration of trainings, etc. |
In accordance with the Nigeria Data Protection Act (NDP Act), we process your personal data based on the following the lawful bases:
Eko Hotels and Suites may work with carefully selected third parties (e.g., service providers) to deliver or improve our services. In those cases, Eko Hotels and Suites shall ensure that your personal data is processed in compliance with the NDP Act, and we put in place binding agreements and safeguards to protect your information.
Eko Hotels and Suites will transfer your Personal Data outside Nigeria only if such transfer is permitted by, and is in accordance with Local Regulatory Requirements such as the NDP Act and the NDP Act GAID, and for the purposes described in this Policy. Eko Hotels and Suites will only transfer personal data outside Nigeria where:
Additionally, Eko Hotels and Suites will take all necessary steps to ensure that the Personal Data is handled and transmitted in a safe and secure manner. These measures include conducting data protection impact assessments (DPIA) to identify and mitigate the risks that such transfer could pose to the rights and freedoms of data subjects.
Eko Hotels and Suites only retains Personal Data as long as necessary to fulfil the purposes for which the data was collected, or to ensure compliance with applicable law. When we destroy your personal data, we either anonymise/de-identify it so it can no longer be linked back to you; or permanently delete it using secure methods designed to prevent any future recovery.
Eko Hotels and Suites does not use automated decision-making unless this is:
Automated decision-making means a decision that produces legal effects concerning an Individual or significantly affects the Individual and which is based solely on automated processing (no human intervention in the process of decision-making) of Personal Data intended to assess certain personal aspects relating to the Individual. Moreover, Eko Hotels and Suites shall implement suitable measures to safeguard the Individual’s rights and freedoms and legitimate interests.
We have strict security measures to protect your Personal Data. We check your identity when you get in touch with us, and we follow our security procedures and apply suitable technical measures to protect your information.
Under data protection law, you have rights, including:
The request for the right to data portability is only applicable when processing is based on contract or consent. This request could also require a fee, depending on the nature of such a request.
Please get in touch with us at Privacynotice@ekohotels.com if you wish to make a request.
If you have any concerns about our use of your Personal Data, you can make a complaint to us at Privacynotice@ekohotels.com
You can also reach out to the Nigeria data protection authority, the Nigeria Data Protection Commission (NDPC), to raise a complaint about the use of your personal data. You can find their details at https://ndpc.gov.ng/
Eko Hotels and Suites may modify this Privacy Notice from time to time to reflect our current privacy practices. When we make changes to this notice, we will revise the “effective” date at the top of this notice.