Website Privacy Notice
Hotel Hideaway Website Privacy Notice
We at Sulake Oy ("Hotel Hideaway", "we", "us" or "our") respect your privacy and recognize the importance of providing a secure environment for your personal data. Therefore, we are committed to being transparent about how we collect and process your personal data.
The purpose of this privacy notice ("Privacy Notice") is to inform you as a visitor about why and how we process your personal data (that is any information that can be linked or attributed to you, "Personal Data") when visiting our website. This includes information regarding with whom we will share your Personal Data, how long we will retain it, and which rights you have in relation to the processing.
This Privacy Notice applies whenever you use our Website. Please note that the explanations provided in this Privacy Notice relate exclusively to the processing of personal data regarding the Website. As explained below, when you visit Third Party Platforms they may be collecting your personal data for their own purposes. If you would like to learn more about the privacy practices of the respective partner websites through which our services and technology are provided, please review the Third Party Platform website's privacy statement.
If you would like to learn more about how we process your personal data when you play the Hotel Hideaway game, please visit Hotel Hideaway privacy notice: https://www.hotelhideawaythegame.com/privacy-policy
GENERAL INFORMATION
In this part of our Privacy Notice, you will find general information about how we process your Personal Data when you visit our website. For specific information with more details about our processing activities, please see the service specific information below.
1. Who is responsible for the processing of your Personal Data
Sulake Oy, Dagmarinkatu 6, 00100 Helsinki, Finland is responsible ("the Data Controller") for the processing of your Personal Data when you visit our Website.
2. What types of Personal Data do we process and how do we collect it?
When you visit our Website, as further explained, we collect, use, store and transfer different kinds of Personal Data. As a general principle, we do not collect and do not ask you to provide any "special categories of Personal Data", which is any particularly protected information such as data concerning health, religion, political opinions or philosophical beliefs, sexual preferences or orientation.
The information we collect depends on which of our services you use and how you use them. We process the following types of your Personal Data:
2.1. Personal Data provided by you
When you use our Website, you provide or be asked to give us certain information, including:
- Information provided in relation to our customer service: When you contact support by using our third-party customer support partner , we collect information about your request (subject and content of your request and any attachment you added) and your contact details (your name and email address).
2.2. Personal Data we receive from your use of our Website
When you visit our Website, we also process device-related information and information about how you interact with our website, including:
- Technical information: We collect information about your device/device settings you use for the purposes described below. The information includes your IP address, the date and time of your visit, the pages you accessed, the amount of data transferred, the referrer URL (if provided), and your browser and operating system information.
To learn more about which data is processed, please see the section with service specific information below.
3. Do we collect data from minors?
Hotel Hideaway is not targeted towards, nor intended for use by anyone under the age of 17. Therefore, we do not intentionally collect and/or categorize personal information from children. In the event that we learn that we have collected personal data from a user under 17 years of age within the scope of the processing activities explained in this Privacy Notice, we will delete that data as quickly as possible. If you believe that a user might be under the age of 17, please contact us.
4. For what purpose do we process your data?
We process your Personal Data for the following purposes:
4.1. Provision and improvement of our Website
to allow you to use our Website
to identify and correct any bugs/errors
4.2. Prevention of fraud and illegal activity
to enforce our policies and Terms and Conditions
to investigate fraud and illegal behaviour
4.3. Analytics and Reporting
- to understand usage of our Website across all our group companies to support strategy and growth
4.4. Communication
- to provide you with customer support based on your questions, requests, or complaints
4.5. Compliance with our legal or regulatory obligations
to comply with the applicable laws -including laws outside a visitor's country of residence
to comply with subpoenas, warrants, or other legal process
to respond to requests from public and government authorities including public and government authorities outside an end user's country of residence
to enforce our terms and conditions
to protect our operations or those of any of our affiliates
to protect our rights, privacy, safety or property, and/or that of our affiliates, visitors, or others
to allow us to pursue available remedies or limit the damages that we may sustain
Please see the section with service specific information below for a more detailed description of the purposes for which we process your Personal Data.
5. On which legal basis do we process your Personal Data?
When we act as a data controller, we process your Personal Data for the purposes described in this Privacy Notice, based on the following legal grounds:
Performance of a contract: We process your Personal Data for the performance of a contract or to take steps prior to entering into a contract to which you are a party, for example, in the context of customer service.
Compliance with legal obligations to which we are subject: We process your Personal Data to comply with legal obligations; for example, for tax and accounting purposes or legal disputes.
Legitimate interests: We also process your Personal Data to the extent that the processing is necessary for our legitimate interests or those of third parties while applying appropriate safeguards that protect your privacy. For example, we process your Personal Data for hosting our website or we transfer your personal data across all our group companies for administrative transfers as well as to determine the size of the user base of our Services.
Please see for additional information the section with service specific information below.
6. With whom do we share your Personal Data?
We will not disclose your Personal Data to any party who is not authorised to process them. To manage our services, we will share your Personal Data internally with members of our responsible departments and technical support and in each case only if access to your Personal Data is necessary for the performance of their roles.
Moreover, and only when necessary to fulfill the purposes mentioned above, we disclose your Personal Data to the following recipients or categories of recipients or allow the following third parties to collect your Personal Data in connection with your use of our Services. This Policy does not apply to those parties, and Sulake is not responsible for their collection or use of information.
Vendors and service providers: We use a variety of vendors and service providers as part of, and for the purposes of, providing our Website. These could include cloud storage and cloud computing services. These vendors and service providers are subject to security and confidentiality restrictions to ensure their processing of the data is consistent with this policy.
External service providers: We share your Personal Data with external service providers who perform services on our behalf, like video hosting services. Where we share your Personal Data with external service providers, we have appropriate agreements in place to ensure that your Personal Data is processed in compliance with applicable data protection laws.
Customer support service: We use a third-party customer support service to be able to respond to your queries in an orderly manner and on a timely basis. We also created a support page to provide you a page where you can find responses to the FAQs (https://hideaway.helpshift.com/hc/en/3-hotel-hideaway/?s=game&f=fansite-way&l=en). When you visit our FAQs page, you are directed to the platform of the third-party customer support service provider.
Social Media Providers: We added buttons of social media providers on our Website which directs you to our fan pages on various platforms (TikTok, Instagram, Twitter and Facebook). We do not collect, receive or process any personal data for this process as any interaction such as likes and shares are collected by Facebook. However, please note that upon clicking the button of the social media provider, they can place cookies on your browser or device based on your privacy preferences. As these cookies are not placed from our domain and to learn more about purposes and functions of the cookies, we recommend you to read the privacy notice of social media providers.
Instant Messaging Provider: We created a channel that allows you to discuss, contact us and keep up to date about Hotel Hideaway within a voice, video, and text chat application. When you click on the relevant button or the "Join our Discord" link, you will be directed to an invitation to join our Discord channel. Upon clicking the link or the button, Discord can place cookies or similar technologies on your device or browser depending on your privacy preferences. As these cookies are not placed from our domain and to learn more about purposes and functions of the cookies, we recommend you to read the privacy notice of Discord.
Application Stores: We added official buttons of Google Play Store and Apple App Store to our Website. The buttons allow us to provide you easy access to Hotel Hideaway by redirecting you to the official pages of the Hotel Hideaway application. Upon clicking the buttons, the app stores can collect information about your device and how you ended up at the page of Hotel Hideaway (i.e. referer URL). We recommend that you read the privacy notice of application stores.
Law enforcement, government authorities or courts: We disclose your Personal Data in response to lawful requests to public authorities, including law enforcement, government authorities, or courts.
Affiliates and group companies: We share information with our affiliated companies, i.e. companies within our corporate family, which are also subject to this policy. We also share your personal data with our group companies. Where we share your personal data with our group companies, we have appropriate agreements (an intra-company data sharing agreement) in place to ensure that your personal data is processed in compliance.
Other third parties: We also disclose your Personal Data in the event of any contemplated or actual reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business or assets (including in any insolvency or similar proceedings).
Please see the section with service specific information below for more information about the third parties we may share your data with. Furthermore, you can find the third parties your Personal Data may be shared below.
8. Where will my Personal Data be processed?
In general, your data is stored on servers outside the EU / EEA. We have implemented appropriate safeguards to protect your Personal Data when it is transferred outside the EU/EEA, including the execution of the European Commission's standard data protection clauses (also known as Model Clauses) to provide safeguards for your Personal Data.
For further information on, or to receive a copy of, the adequate safeguards adopted by us for the international transfer of your Personal Data, please contact us by email at privacy@sulake.com. We will process any request in line with any local laws and our policies and procedures.
9. How do we protect your Personal Data?
We have implemented appropriate technical and organizational security measures designed to protect your Personal Data against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. We update and test our security standards on an ongoing basis. In addition, we take reasonable steps to assure that third parties to whom we transfer your Personal Data provide sufficient protection of Personal Data.
10. How long do we store your Personal Data?
We will not retain your Personal Data longer than necessary to fulfill the purposes for which the data was collected or to fulfill our legal obligations or necessary for the establishment, exercise of defence of legal claims or resolving disputes. In addition to this, we determine our retention periods based on our accountability obligations (to be able to demonstrate that we complied with our obligations, e.g. preserving records when you exercised one of your data subject rights), statutory requirements in countries that we are legally present including statute of limitations, the need of Personal Data for any reference to our future actions (e.g. to be able to justify an action we took or to be able to handle payments to our partners or clients) and the need of Personal Data for business processes including but not limited to development of our product. Afterwards, we will delete or anonymize your Personal Data. Additional information on how long your Personal Data is stored by our service partners can be found in the respective third-party list available below.
11. What are your rights in respect of your Personal Data?
To the extent permitted by applicable data protection laws and regulations, you have the following rights in relation to your Personal Data:
Access the Personal Data we hold about you, including information such as, for example, the source and categories of data, the processing purposes, the recipients (or categories thereof) and the respective retention period.
Request an update or correction of your Personal Data so that it is always accurate.
Receive your Personal Data in a structured, commonly used and machine-readable format, including the right to transfer your Personal Data to another data controller.
Request the deletion of your Personal Data if you believe that retention is no longer necessary for the purposes indicated above.
Restrict the processing of your Personal Data for example, if you have contested the accuracy of your Personal Data, and for a period of time that is sufficient to allow us to verify its accuracy.
Withdraw your consent at any time if your Personal Data is processed with your consent. Please note that this will not affect the lawfulness of data processing based on consent granted prior to its withdrawal.
Object to the processing on specific grounds relating to your particular situation, in the event and to the extent that we process your Personal Data based on our legitimate interests. In such cases we will no longer process your Personal Data unless we have compelling legitimate grounds for the processing which override your interests, rights and freedoms, or for the establishment, exercise or defence of legal claims. You also have the right to object where we are processing your Personal Data for profiling. In that case, we will stop processing your Personal Data for such purposes.
You can exercise these rights by sending a request to the contact details set out below, providing your name, your email address as well as a description of your request. If you believe we have not complied with our obligations under applicable data protection laws and regulations, you can lodge a complaint with a competent data protection authority.
12. How can you contact us?
If you have any queries about this Privacy Notice or how we use your Personal Data, please contact our customer support via our Website or our Data Protection Officer via e-mail to privacy@sulake.com
13. How often do we update this Privacy Notice?
We regularly review and update this Privacy Notice. This Privacy Notice was last updated on 31 July 2024.
14. Additional Information for California Residents
This section for California residents supplements the information provided in this Privacy Notice and applies solely to visitors who reside in the State of California. We provide this section to comply with the California Consumer Privacy Act of 2018 (CCPA) and the regulations issued under it; accordingly, this section addresses the specific requirements of the CCPA and should be read together with this Privacy Notice.
We do not sell your Personal Data. However, we may share or provide access to each of the categories of Personal Data we collect as necessary for our business purposes. We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device. In particular, we have collected the following categories of personal information (envisaged by the CCPA) from consumers within the last twelve (12) months:
Category F -- Internet or other similar network activity (such as your interaction with our ads, your IP address)
Category G -- Geolocation data
The CCPA provides consumers (California residents) with specific rights regarding their personal information.
You have the right to access specific information i.e. you may request that we disclose certain information to you about our collection and use of your personal information over the past 12 months.
You have the right to know. Under the CCPA you have the right to request that we disclose to you what Personal Data we process about you.
You have the right to deletion which means that you may request that we delete any of your personal information we collected from you and retained, subject to certain exceptions. Under the CCPA, you have the right to opt out of any sale of your personal data. Please note that your right to opt out does not apply to our sharing of personal data with service providers, who are parties we engage to perform a function on our behalf and are contractually obligated to use the personal data only for that function.
Finally, you have a right to not be discriminated against for exercising your rights under the CCPA.
You can exercise these rights by sending a request to the contact details set out above, providing your name, your email address as well as a description of your request.
15. Additional Information for Brazil Residents
Under the Brazilian General Data Protection Law (the "LGPD"), you have the right to access, rectify, port, erase, and confirm that we process your data. If you have given consent about processing your data, you have the right to withdraw consent anytime.
SERVICE SPECIFIC INFORMATION
In this part of our Privacy Notice, you will find specific information on how your Personal Data is processed. For general information about data processes that apply, please see above.
Hosting
Our Website is hosted by external companies to provide its services to its clients. For example, every time you click on a link on our Website, the information allowing this request (e.g., device information and information on requested content) as well as online identifiers (your IP address) will be sent to the external servers. This data is used to show you the content you requested in a faster way. We process this data on the basis of our legitimate interest, to provide and improve our service and ensure its functionality.
Customer service
If you contact us for customer support by using our third-party customer support service provider, we process your name, email address and content of your support ticket. We store your requests as the request history helps us to solve a newer request and is stored to defend against possible future legal claims. We process this data on the basis of performance of contract to provide you with customer support, and store this data on the basis of our legitimate interest, to improve our services, and to be able to defend possible future legal claims.
Analytics
We use analytics services to understand the use of our Website and improve it. For this purpose, we use web server logs. When you visit our website, we will process your personal data related to the visit (your IP address, the date and time of your visit, the pages you accessed, the amount of data transferred, the referrer URL -if provided-, and your browser and operating system information.). We also process your IP address to determine the number of unique users of our Services within our group companies. We process your personal data in connection with this activity based on legitimate interest.
Third Parties of Hotel Hideaway Website
This list includes information about the third parties that your data may be shared with, in the way described in our Privacy Notice.
Under "Category", you will find information about the activity your Personal Data is processed for, such as for customer service. The "Third party" indicates what third party specifically processes your data for the respective category. For more information on how our third-parties process and store personal data, we refer to the privacy notice of the respective third party, which we have included in this list. In the third-party privacy notices, you will furthermore find information on how they collect and process your personal data.
| Category | Third party | Privacy Notice |
|---|---|---|
| Hosting | Amazon Web Services (AWS) | https://aws.amazon.com/privacy/ |
| Customer service | Keywords Studios Group (Helpshift) | https://www.helpshift.com/legal/privacy/ |
| Social Media Platform | TikTok Technology Limited | https://www.tiktok.com/legal/page/eea/privacy-policy/en |
| Social Media Platform | Meta Platforms Ireland Limited (Instagram) | https://help.instagram.com/155833707900388 |
| Social Media Platform | Meta Platforms Ireland Limited (Facebook) | https://www.facebook.com/privacy/policy/ |
| Social Media Platform | X Corp. | https://x.com/en/privacy |
| Instant Messaging Provider | Discord BV Netherlands | https://discord.com/privacy |