Privacy Policy

Privacy Policy




Who are we?

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.

Who does this notice apply to?

This notice applies to individuals who are:

  • Customers: Individuals or entities who enter into agreements with Eko Hotels and Suites to the extent that Eko Hotels and Suites processes their personal data.
  • Users: Anyone who accesses or interacts with our website, applications, or any Eko Hotels and Suites products and services.
  • Suppliers: All vendors, contractors, partners, and service providers engaged by Eko Hotels and Suites, including those under consideration, to the extent that Eko Hotels and Suites processes their personal data.
  • Premises Visitors: Persons whose information is recorded at any Eko Hotels and Suites facility via visitor logs, management systems, CCTV, or similar monitoring tools.
  • Job Applicants and Recruitment Candidates
  • Employees
  • Other individuals who share personal data with Eko Hotels and Suites.

Important terms you need to understand

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.

What type of Personal Data does Eko Hotels and Suites collect?

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:

  • General Identifying Information
  • Demographic Information and Important Dates
  • Government-Issued Identification
  • Financial Information
  • Loyalty Program Information
  • Travel Information
  • Job Applicants Data
  • Employment Records
  • Medical Data

How do we get your Personal Data and why do we collect it?

  • Online Services: By performing such actions as, but not to, browsing, making a reservation, purchasing goods and services from our websites or Apps, communicating with us or otherwise connecting with us or posting to social media pages, or signing up for a newsletter or participating in a survey, contest, or promotional offer.
  • Customer Care Centres: We collect Personal Data when you make a reservation over the phone, communicate with us by email, online chat services or contact customer service.
  • Third Parties: We collect Personal Data from third parties such as Online Travel Agents and other authorised third parties.
  • Feedback Forms: We collect Personal Data and Other Data through feedback forms to evaluate customer satisfaction, understand preferences and experiences, respond to comments or concerns, and improve our products, services, and overall customer experience.
  • Site Visit: We collect your Personal Data when you visit or stay as a guest at one of our properties or use our services or through other offline interactions.

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.

Lawful Bases for Processing Personal Data

In accordance with the Nigeria Data Protection Act (NDP Act), we process your personal data based on the following the lawful bases:

  • Your consent: we process your personal data based on your consent, which you have given us for specific purposes.
  • We have a contractual obligation: to fulfil our contractual obligations to you, such as providing products or services.
  • We have a legal obligation: we process your personal data to comply with applicable laws, regulations, and court orders.
  • We have a vital interest: to protect your vital interests or those of others, such as in emergency situations.
  • We need it to perform a public task: we process your personal data to perform tasks that are in the interest of the public, i.e. collective welfare and well-being of society as a whole.
  • We have a legitimate interest: based on our legitimate interests, such as marketing and improving our services, while ensuring your rights and freedoms are protected.

Does Eko Hotels and Suites share my Personal Data with third parties?

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.

Do we transfer your Personal Data outside the country?

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:

  • The NDPC has declared the foreign country as having adequate data protection laws and practices.
  • A Cross-Border Data Transfer Instrument (CBDTI), such as Binding Corporate Rules (BCRs), Standard Contractual Clauses (SCCs), Codes of Conduct or Certification, is in place and approved by the NDPC.
  • In a defence or establishment of a legal claim.
  • You have provided your consent for this purpose.
  • It is necessary for us to perform the contractual agreement established with you as an individual.

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.

How long does Eko Hotels and Suites retain my Personal Data?

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.

Automated Decision Making

Eko Hotels and Suites does not use automated decision-making unless this is:

  • Necessary to enter into, or performance of a contract between the Individual and Eko Hotels and Suites;
  • permitted or required by law; or
  • based on the Individual’s explicit consent.

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.

How do we protect your Personal Data?

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.

Your Data Privacy Rights

Under data protection law, you have rights, including:

  • Your right of access: You have the right to request for copies of your personal data.
  • Your right to rectification: You have the right to request the rectification of the personal data you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
  • Your right to erasure: You have the right to ask us to delete your personal data in certain circumstances, such as when the data is no longer necessary for the purposes for which it was collected.
  • Your right to restriction of processing: You have the right to request that we limit the processing of your Personal Data in certain circumstances.
  • Your right to object to processing: You have the right to object to the processing of your Personal Data in certain circumstances.
  • Your right to data portability: You have the right to ask that we transfer the Personal Data you gave us to another organisation, or to you, in a structured, commonly used, and machine-readable format.
  • Right to withdraw consent: If processing is based on consent, you have the right to withdraw your consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.

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.

How to complain

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/

Changes to this privacy notice

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.