Smart Order Booking Engine Privacy Policy
1. Introduction
Hong Kong Smart Order Technology Co., Limited, a Hong Kong corporation, together with its subsidiaries and affiliates (collectively, "Smart Order," "we," "us," or "our"), provides the Smart Order Booking Engine (the "Booking Engine").
The Booking Engine enables individuals to search for accommodation, view room availability and rates, make and manage reservations, submit booking requests, and use related booking functions.
This Privacy Policy explains how personal information is collected, used, disclosed, stored, and protected when you use the Booking Engine.
In this Privacy Policy:
"Property" means the hotel, accommodation property, or other hospitality business that you select or with which you make a reservation through the Booking Engine.
"Guest" means the person making a reservation and any other person whose information is included in the reservation.
"Personal information" means information relating to an identified or identifiable individual.
Smart Order provides the technology used to operate the Booking Engine. The selected Property provides the accommodation and is responsible for fulfilling the reservation.
2. Scope
This Privacy Policy applies to personal information processed through the Booking Engine, including when you:
Search for rooms, rates, packages, or availability;
Make a reservation;
Modify or cancel a reservation;
Submit information about yourself or another Guest;
Make or arrange a payment, deposit, refund, or booking guarantee;
Submit a request or message relating to a reservation; or
Contact Smart Order about the operation of the Booking Engine.
A Property may separately collect personal information outside the Booking Engine, including during check-in, check-out, payment, or the provision of accommodation and related services. The Property's processing of such information may be governed by its own privacy practices.
3. Personal Information Collected Through the Booking Engine
The information collected depends on the booking process and the functions you use.
3.1 Contact and Guest Information
This information may include:
Full name;
Email address;
Telephone number;
Postal or billing address;
Nationality;
Country or region of residence;
Names of accompanying Guests;
Number of adults and children; and
Other identification or contact information required for the reservation.
3.2 Reservation Information
This information may include:
Selected Property;
Arrival and departure dates;
Number of rooms and Guests;
Room type;
Rate plan;
Package or additional service selected;
Promotion or booking code;
Estimated arrival time;
Reservation number;
Booking status;
Modification and cancellation records;
Guest preferences;
Special requests; and
Other information submitted as part of the reservation.
Special requests may reveal information relating to health, accessibility, dietary requirements, religion, or other sensitive matters. Please provide such information only where it is necessary for the Property to fulfil your request.
3.3 Payment and Transaction Information
Depending on the booking and payment arrangement, the following information may be processed:
Payment method;
Billing information;
Payment, deposit, refund, or booking guarantee amount;
Currency;
Transaction status;
Payment or transaction reference; and
Information used to verify a transaction or prevent fraud.
Payment information may be processed by the Property, Smart Order, or an authorised third-party payment service provider.
If payment information is entered on a page operated by a third-party payment provider, that provider will process the information in accordance with its own privacy policy and terms.
3.4 Communications
We may process information contained in:
Booking enquiries;
Requests or messages submitted to the Property;
Questions about the Booking Engine;
Customer support communications;
Complaints or dispute-related communications; and
Feedback submitted through the Booking Engine.
3.5 Device and Usage Information
When you access or use the Booking Engine, certain technical information may be collected automatically, including:
IP address;
Browser type;
Device type;
Operating system;
Language and time-zone settings;
Session and cookie identifiers;
Referring page;
Pages viewed and functions used;
Date, time, and duration of access;
Approximate location derived from the IP address;
Error reports and diagnostic data; and
Security and activity logs.
3.6 Information Received from Other Sources
Information connected with a reservation may also be received from:
The selected Property;
Payment service providers;
Reservation and booking systems;
Customer support and communication providers;
Security and fraud-prevention providers; and
Other service providers involved in processing the reservation or operating the Booking Engine.
4. Information About Other Guests
If you make a reservation for another person or provide information about an accompanying Guest, you confirm that you are authorised to provide that information for the purposes of the reservation.
You should make the other Guest aware that their personal information may be processed by Smart Order, the selected Property, and relevant service providers as described in this Privacy Policy.
5. How Personal Information Is Used
Personal information collected through the Booking Engine may be used to:
Display room availability, rates, packages, and booking options;
Create and confirm reservations;
Modify or cancel reservations;
Provide reservation information to the selected Property;
Process or facilitate payments, deposits, refunds, and booking guarantees;
Send reservation confirmations, reminders, modification notices, and cancellation notices;
Communicate Guest preferences and special requests to the Property;
Respond to booking enquiries and support requests;
Handle complaints, refunds, payment issues, and booking disputes;
Verify transactions and prevent fraud, misuse, and unauthorised activity;
Maintain the availability, security, and reliability of the Booking Engine;
Diagnose and resolve technical problems;
Measure and improve Booking Engine performance and usability;
Maintain booking, payment, transaction, and support records;
Protect the rights, property, safety, and security of Guests, Properties, Smart Order, and other parties;
Establish, exercise, or defend legal claims; and
Comply with applicable legal, regulatory, tax, accounting, and reporting obligations.
Where applicable law requires consent for a particular processing activity, the relevant information will be processed only after the required consent has been obtained.
6. Disclosure to the Selected Property
Information necessary to process and fulfil a reservation will be provided to the selected Property.
The Property may use this information to:
Review and confirm the reservation;
Modify or cancel the reservation;
Prepare for the Guest's arrival;
Provide accommodation and related services;
Communicate with the Guest;
Process payments, deposits, refunds, and other charges;
Fulfil preferences and special requests;
Handle enquiries, complaints, and disputes; and
Comply with applicable legal and regulatory requirements.
After receiving the information, the Property may process it for its own purposes in accordance with applicable law and its own privacy practices.
Questions concerning the accommodation, reservation fulfilment, stay, charges imposed by the Property, or the Property's use of personal information should be directed to the relevant Property.
7. Other Disclosures of Personal Information
Personal information may also be disclosed to the following recipients where reasonably necessary.
7.1 Service Providers
Service providers may support the operation of the Booking Engine by providing:
Hosting and data storage;
Payment processing;
Email, SMS, and other booking communications;
Customer support;
Security and fraud prevention;
Error monitoring and technical diagnostics;
Performance measurement;
Technical maintenance; and
Reservation and system integrations.
Service providers acting on behalf of Smart Order are permitted to process personal information only as necessary to provide the relevant services and are subject to applicable contractual and confidentiality obligations.
7.2 Legal and Safety Disclosures
Personal information may be disclosed where reasonably necessary to:
Comply with applicable laws, regulations, court orders, or lawful government requests;
Respond to legal proceedings;
Investigate suspected fraud, misuse, or security incidents;
Protect the rights, property, safety, or security of Smart Order, a Property, a Guest, or another person; or
Establish, exercise, or defend legal claims.
7.3 Business Transactions
If Smart Order is involved in a merger, acquisition, financing, restructuring, transfer of assets, or similar transaction, personal information may be disclosed to relevant advisers and transaction participants, subject to appropriate confidentiality and data protection safeguards.
8. Cookies and Similar Technologies
The Booking Engine may use cookies and similar technologies to:
Provide essential booking functions;
Maintain the booking session;
Retain booking selections while you move between pages;
Remember language, currency, and other preferences;
Protect the Booking Engine against fraud and unauthorised activity;
Identify and resolve technical problems;
Measure Booking Engine performance; and
Understand and improve how the Booking Engine is used.
Some cookies are necessary for the Booking Engine to function. Where required by applicable law, optional cookies will be used only after you have made the relevant choice or provided consent.
You may manage cookies through the controls provided in the Booking Engine or through your browser settings. Blocking certain cookies may prevent some Booking Engine functions from operating correctly.
9. International Data Transfers
Smart Order, the selected Property, and service providers involved in operating the Booking Engine or processing a reservation may be located in different countries or regions.
Personal information may therefore be transferred to, accessed from, or stored outside the country or region in which you are located.
Where required by applicable law, reasonable and appropriate safeguards will be used to protect personal information transferred across borders. Where required by applicable law, Smart Order will provide additional notices and obtain separate consent before transferring personal information across borders.
10. Data Retention
Personal information collected through the Booking Engine will be retained only for as long as reasonably necessary to:
Create and manage reservations;
Provide booking-related communications and support;
Maintain booking, payment, and transaction records;
Process cancellations, refunds, complaints, and disputes;
Prevent fraud and protect Booking Engine security;
Enforce applicable agreements;
Establish, exercise, or defend legal claims; and
Comply with applicable legal, tax, accounting, and regulatory obligations.
Retention periods may vary depending on the type of information, reservation status, legal requirements, contractual requirements, and applicable limitation periods.
When personal information is no longer reasonably required, it may be deleted, anonymised, or securely disposed of.
11. Data Security
Smart Order uses reasonable technical and organisational measures designed to protect personal information processed through the Booking Engine against unauthorised or accidental access, processing, disclosure, alteration, loss, erasure, or destruction.
These measures may include access controls, encryption, monitoring, backup procedures, security testing, and confidentiality requirements, where appropriate.
No electronic transmission or storage system can be guaranteed to be completely secure.
12. Privacy Rights
Depending on your location and applicable law, you may have the right to:
Ask whether your personal information is being processed;
Request access to or a copy of your personal information;
Request correction of inaccurate or incomplete personal information;
Request deletion of personal information;
Request restriction of certain processing;
Object to certain processing;
Withdraw consent where processing is based on consent;
Request certain information in a portable format; and
Lodge a complaint with an applicable privacy or data protection authority.
These rights may be subject to legal conditions, limitations, and exceptions. Identity verification or additional information may be required before a request is processed.
If your request concerns a reservation, payment made to a Property, cancellation, refund, stay, special request, or the Property's use of personal information, please contact the relevant Property using the contact information displayed in the Booking Engine or booking confirmation.
If your request concerns the operation of the Booking Engine or Smart Order's processing of personal information, please contact Smart Order using the privacy contact option provided in the Booking Engine.
13. Children's Privacy
The Booking Engine is intended to be used by persons who have the legal capacity to make a reservation.
Information about a child may be included in a reservation where it is provided by a parent, legal guardian, or other authorised adult and is reasonably necessary to arrange accommodation or related services.
Smart Order does not knowingly collect personal information directly from children for purposes unrelated to processing or supporting a reservation.
14. Third-Party Payment and Other Services
The Booking Engine may connect you to payment services or other services operated by third parties.
A third-party service may collect and process personal information independently under its own privacy policy and terms. You should review the applicable privacy information before submitting personal information directly to a third-party service.
Smart Order is not responsible for the independent privacy practices of third-party services.
15. Changes to This Privacy Policy
Smart Order may update this Privacy Policy from time to time to reflect changes to the Booking Engine, data-processing practices, or applicable requirements.
The updated Privacy Policy will be made available in the Booking Engine with a revised "Last Updated" date.
Where required by applicable law, additional notice will be provided or consent will be obtained before a material change takes effect.
16. Contact
For questions concerning a reservation, payment made to a Property, cancellation, refund, stay, or the Property's handling of personal information, please contact the relevant Property using the contact information displayed in the Booking Engine or booking confirmation.
For questions concerning this Privacy Policy, the operation of the Booking Engine, or Smart Order's handling of personal information, please contact Smart Order using the privacy contact option provided in the Booking Engine. Privacy Contact: pms.support@smartorder-jp.com