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  • HITEC Special: Does EU GDPR Affect U.S. Hospitality Companies?

    By Alvaro Hidalgo. The EU General Data Protection Regulation has set a path towards protecting personal data which many other countries will follow. In a global industry such as hospitality, it should be a primary objective to take the steps towards compliance.

  • HFTP Report: Hospitality Data Security — Strategy for Data Protection and Regulation Compliance

    This guide from Hospitality Financial and Technology Professionals (HFTP(R)) covers safeguards that can be implemented in hospitality businesses today, tips on how to continuously improve security and data regulation compliance.

  • HFTP GDPR Guidelines: Privacy Policies for Hotels

    This document offers points to consider in the development of a hotel’s privacy policy. In view of the multiple organisational and legal structures under which hotels operate, as well as the complexity of the third party landscape that may be part of the complete guest experience, this document serves as a guideline only.

  • HFTP GDPR Guidelines: Hospitality Guest Registration Cards

    This document offers recommendations for guest information collection on the guest registration card along with consent for use. It can be used as a guideline for loyalty cards, health data, export of data outside of the EU, privacy policies and direct marketing.

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Privacy vs security: first fines reveal shift in data protection landscape

eyefortravel.com·Requires Registration ·15 August 2018
Over two months since ‘GDPR Day’, most organisations are still successfully processing personal data, but travel companies beware. With regulation now enforceable, consumers more empowered and security – a small part of GDPR – becoming an increasing focus, the Information Commissioner’s Office is keen to show it has teeth. Since May, several fines have been levied against companies making everything from annoying sales calls to not being rigorous with privacy and security. While the ICO has not fined any companies under the EU GDPR or UK Data Protection Act 2018 yet (the breaches happened before May 25), the value of these fines does appear higher.
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What You Missed in London

4hoteliers.com·15 August 2018
This report also hits on Travel's most important topics such as AI, blockchain, GDPR and more, this is your chance to level the playing field on your competition.
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In a post GDPR world, first-party data is more important than ever

clickz.com·14 August 2018
At the beginning of the summer, the General Data Protection Regulation went into effect, requiring marketers in the EU to obtain explicit consent from consumers before collecting and using their data. Companies refusing to comply could be fined up to 20 million Euros, which has been a motivating factor for brands around the world to update their policies and focus on educating the public about how their data is being used. The post In a post GDPR world, first-party data is more important than ever appeared first on ClickZ.

9 Reasons Why Your Business Can't Ignore SMS Marketing

The SMS Works Ltd ·13 August 2018
Mobile marketing is no longer the impressionable young upstart it was 15 years ago.It's matured and the use of sms by the hospitality sector has grown and continues to grow at a steady rate.Consumers are no longer surprised to receive offers from venues that they've opted into, in fact they have come to expect them.According to research by SAP, 70% of people feel that SMS is a good way for an organisation to get their attention.If your business hasn't yet taken the plunge, there's a whole opportunity to generate eyebrow raising response rates that will impress even the most cynical of marketers.Here are the top 9 reasons, to roll up your sleeves and dive into the world of mobile marketing.1. Killer Open RatesNo direct response marketing channel can compete with the astonishing read rate of SMS. 90% of all SMS are still read within the first 3 mins (mobileSQUARED).Despite the explosive growth of messaging apps and in app notifications, SMS still has the power to make us stop what we're doing and check the SMS inbox.It makes some sense, when was the last time you ignored a text?2. SMS has the highest response of any communication channelIf only email response rates could match those of SMS.According to Cellit, SMS can boast response rates that are 6-8 times higher than email.Compared to any other way of getting your message across, SMS open and response rates are one of the marvels of the marketing world.3. SMS is here to stayEvery week I read a new article telling us how SMS is on the verge of meltdown and will soon be swept aside as messaging apps take control.In fact, when messaging apps first appeared around 10 years ago, many industry pundits reckoned the writing was on the wall for SMS.While it's undeniably true that messaging has rapidly overtaken SMS for person to person use, the use of SMS in business is still growing steadily and is predicted to do so for another few years.According to Zion research, the A2P messaging market (application to person) will grow by 4% a year until 2020 when it will reach a global total of $70 billion.4. SMS is still the only universal messaging platformZero learning curve.Nothing to download, no web connection or data issues.Every mobile phone ever built can send and receive texts.We understand it, we don't need to learn it and we still get a buzz from receiving them.5. There's a low spam rateJust a few years ago, I used to receive dozens of junk texts a week?It was infuriating to put it mildly.Spam SMS seems to have almost completely dried up, in large part due to the implementation of stringent new rules around the sending of marketing texts.In the EU, since GDPR became law in May 2018, regulators have increasing powers to punish the rule breakers.They can and do hand out large fines to organisations who break the rules. The new rules mean that our SMS inboxes remain largely spam free.6. SMS marketing is trackableEvery mobile marketing text sent receives a delivery report, letting you know whether the message has been delivered or not.Dead numbers can be removed from your list, so that no further effort is made to text them.Links in your texts can be shortened and click through / engagement tracked, so you can measure exactly how your campaigns are performing.7. Uncompromised by advertisingMessaging apps offer far more flexibility than SMS which is so basic and clunky in comparison. You can't for example, create groups or send pictures easily.The issue with messaging apps is that the platform must generate revenue through in app advertising.The business model depends on advertisers seeing a return on their ad spend, users need to click away from the messaging to view the ads.So, ads are a necessary distraction that encourage users to move away from the messaging app and visit an advertiser's website.By contrast, SMS operates in a cocoon. You're either viewing or sending texts with no tempting exit doors.8. Your competitors are using SMS"If you're not using mobile marketing to attract new customers to your business, don't worry -- your competitors are already using it and are getting those customers instead." Jamie Turner, 60SecondMarketer.comWhatever sector you operate in, it's likely that other companies will be using SMS as way of communicating with their customers.While it's not a smart idea to get too obsessed with what competitors are up to, you don't want to let them dominate one of the most responsive communication channels.9. You can get up and running fastOne of the joys of SMS is that you don't need to involve every department in your company to get a campaign off the ground.There's no artwork to get bogged down in or media buying agency to consult. You can simply extract the mobile data, compose your text and your message can be landing on customers' mobiles within the hour.ConclusionThe hospitality sector is perfectly placed to take advantage of the humble text and many businesses have been doing so for over 20 years.But if you haven't yet got involved, it's not too late to start. When it's done well, the benefits can be genuinely transformative.What's your experience of SMS marketing in your business? Have you used it to drive customers to your venue or have you steered well clear?Let us know your thoughts in the comments below.
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Some Companies Are Ignoring GDPR Risk

CFO Magazine· 9 August 2018
During the six-year lead-up to the May 25, 2018, effective date of the European Union’s General Data Protection Regulation (GDPR), much attention was focused on the onerous financial penalties for noncompliance.
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10 Steps Marketers Can Take to Prepare for 'California's GDPR

MarketingProfs·Requires Registration ·26 July 2018
If you're tired of hearing about GDPR, just wait until you start dealing with CCPA. The California Consumer Privacy Act is coming... and, marketers beware, it will change everything. If you collect consumer data in California, you need to prepare for a slew of new data management obligations. And, considering that one in eight Americans resides in the Golden State, it's highly likely the CCPA applies directly to your organization.

HFTP CEO Frank Wolfe Honored as Most Influential Hospitality Association CEO 2018

HFTP ·25 July 2018
Frank I. Wolfe, CEO for Hospitality Financial and Technology Professionals (HFTP), was recognized as Most Influential Association CEO 2018 in Hospitality by the European-based corporate finance publication Acquisition International (AI). Published by AI Global Media, AI is a monthly magazine that seeks to inform and shape the global corporate conversation through a combination of high quality editorial rigorous research and an experienced and dedicated worldwide network of advisors experts and contributors."This is truly an honor, but is really a testament to our talented staff as well as the HFTP Global Board of Directors and our Executive Committee. The past few years have been marked by significant progress for HFTP, as we have established long-planned events that place us as an internationally influential organization. This honor is a notable recognition for all the efforts we have put in," says Mr. Wolfe. "We have also made available our signature services such as quality education and resources to the global hospitality finance and technology community. I am proud that our efforts have been recognized by such an esteemed publication, but I also know that we have much more to accomplish."Recipients of the brand new honor are internally researched, shortlisted, judged and selected. The publication's in-house research team looks into the global industry thoroughly in order to determine those most deserving of the accolade. Some factors the team takes into consideration include the nominee's significant achievements over the past calendar year, company and career profile, commitment towards innovation and company performance under the individual's leadership.Wolfe has been with HFTP since March 1991, and assumed the CEO position in 1994. He has overseen the positive evolution and growth of the association. Under Wolfe, HFTP has made a number of bold moves towards global expansion, new club conferences, and many organized clusters of members around the world. In 2017, HFTP also expanded its Hospitality Industry Technology Exposition and Conference (HITEC), the largest hospitality technology conference brand in the world with two additional events in Europe and Dubai, in addition to its annual North American event. He also spearheaded the hospitality-specific search site Pineapplesearch.com and HFTP news sites, topic specific sites for hospitality finance, technology, club, food and beverage, GDPR and the HFTP association.To read more about Frank Wolfe, including articles he has written, visit his bio page on the HFTP web site. For more information about HFTP, visit www.hftp.org.About HFTP Hospitality Financial and Technology Professionals (HFTP), established in 1952, is a hospitality nonprofit association headquartered in Austin, Texas USA with offices in Hong Kong, United Kingdom, The Netherlands and Dubai. HFTP is recognized as the spokes group for the finance and technology segments of the hospitality industry with an international network of members and stakeholders. HFTP uniquely understands the industry's pressing issues, and assists its stakeholders in finding solutions to their challenges more efficiently than any organization. HFTP offers expert networks, educational resources, career development programs, research, leadership opportunities and conferences and events. HFTP produces international events throughout the year, including the world's largest hospitality technology tradeshow and conference brand: HITEC. The association also owns the world's only hospitality-specific search engine: PineappleSearch.com. For more information about HFTP, visit www.hftp.org.For the latest news, visit the HFTP News page at news.hftp.org and the HFTP Connect blog at blog.hftp.org.Follow HFTP on social media Facebook (@HFTPGlobal); LinkedIn; Twitter (@HFTP); Instagram (@HFTP_HITEC). Stay tuned to HFTP's industry-specific, informational news sites: HFTP News, HITEC Bytes, HFTP Club Bytes, HFTP Finance Bytes, HFTP GDPR Bytes and HFTP FB Bytes. HFTP event photos are available on Flickr, and HFTP event videos are available on YouTube.###

Nigel Allport joins For-Sight Guest CRM as Head of Business Development

For-Sight Guest CRM ·25 July 2018
Edinburgh -- After a record breaking year of new client acquisition and the on-boarding of a number of renowned UK and Ireland hotel groups and prestigious Independent properties, For-Sight Guest CRM today announced the appointment of Nigel Allport as Head of Business Development to oversee its ambitious growth plans over the next three years.Speaking following Allport's appointment, For-Sight Founder and Director Allan Nelson said that "I have known Nigel for a number of years and have always been impressed with his success and professionalism" adding, "his reputation in European hospitality technology is simply unmatched and he is the perfect appointment to lead our sales effort in the UK, Ireland and continental Europe".Experienced in hotel guest CRM, Allport has worked with a diverse client portfolio consisting of top tier hotel brands, luxury and boutique hotel chains, hotel management companies, resorts, franchises and independents, and business partners. Commenting on his appointment, Allport said "I am absolutely thrilled to have joined For-Sight Guest CRM at a time when they are enjoying un-paralleled success with their CRM and Data Analytics platform adding that in a post GDPR world, For-Sight's experience of data management including laser segmentation and guest profiling is a clear differentiator for hotels seeking a competitive edge".Nelson concluded, "For-Sight are very excited to welcome Nigel on board and are delighted that he is already making headway, the impact of which, is already being seen and we are excited at the contribution he will make to our growth strategy in the coming years". About For-SightFrom UK based Forth Communication Ltd, For-Sight Guest CRM helps hotels, groups and management companies leverage their data to establish & retain guest relationships. A combination best of breed technology and excellent customer service, means the business has become well established in the Hotel CRM space with a reputation to match.For further details please contact: Jenny Duffy Forth Communication Ltd Tel: 0131 467 4467 Email: jenny.duffy@forth.co.uk
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GDPR Compliance Deadline Has Come and Gone; What Does it Mean for Hotels?

Beekeeper ·24 July 2018
SAN FRANCISCO, CA -- The European General Data Protection Regulation (GDPR) compliance deadline has passed, and it now requires every hotel in the world to have guidelines in place that protect European Union (EU) residents' personally identifiable information against security breaches. While a lot has been discussed to help hoteliers become compliant, many are wondering "what comes next?" Dr. Amir Ameri, Data Protection Officer for Beekeeper, a GDPR-compliant developer of a digital workplace app hailed as the "Most Innovative Technology" for 2018 and the "People's Choice" by actual users and buyers, is providing answers to some of hoteliers most frequently asked questions.Q: How quickly will regulators levy major fines if a hotel or hospitality-related business is not GDPR compliant?A: Before a fine is levied, an offence must be established. This may be due to an incident impacting personal data of an employee or a guest or a defined regulatory audit. Hence, establishing an offence in this matter would require evidencing several criteria, performing audits, assessing the knowledge of the offender to the offence, i.e. establishing intent and the level of due diligence the offender had met. Taking all factors into consideration, previous court rulings in the EU have taken time to give a ruling in data protection and privacy matters. Article 83 states: "In any event, the fines imposed shall be effective, proportionate and dissuasive." This will be case dependent and influenced by the legal proceedings in the jurisdiction in question as defined by the regulatory body.Q: Will the GDPR regulation help or hinder future innovation?A: In my opinion, not only will GDPR regulation significantly help future innovation, but it will also establish an absolute maximum of the necessary level of "trust" required to have a flourishing use of any future innovation.Q: Will the GDPR regulation help or hinder my hotel's global marketing efforts?A: Understanding that establishing "trust" is the cornerstone of any successful marketing effort, there is nothing better than upholding a basic "undeclared human right" in any company's effort to commercialize their product. Adapting to new processes and marketing efforts will be necessary, but it's also addressing an important need in the minds of most consumers.Q: What do hotels need to do to maintain their opt-in-subscriptions? What will this mean to customer loyalty and bottom line revenues for the future?A: It is helpful if businesses/hotels recognize that personal data is not a free commodity and there is an ownership title associated with the personal data to the data subject. Safeguarding this is all GDPR requires. Incentives, or any form of compensatory measures of interest to the data subject, may result in maintaining a higher customer loyalty. It is important to note, however, that customer loyalty and bottom line revenues were only impacted for businesses/hotels with a model to use a "free commodity = personal data" to generate income. As we all know, in a free economy, this itself is considered an unfair distribution of resources and a disadvantage for a healthy economy and it is not tolerated in many countries.Q: What happens if there is a third-party breach? For example, a hotel uses WhatsApp to stay connected to their employees. What happens to that hotel if WhatsApp is not compliant? Is it liable for the breach or is WhatsApp solely responsible?A: One of the points that GDPR addresses clearly is the responsibility of each party in the processing life cycle. In this respect, although GDPR has a "pass through" approach, it is the responsibility of the controller to be transparent towards the data subject and manage such risks with the processors and the involved third parties. For example, having a data processing agreement in place between the involved entities, performing risk assessments and taking other risk mitigating measures are the norm in managing this type of risk. In the example stated, since the hotel is considered as the controller, certainly the hotel will be audited to establish whether it had performed its due diligence towards managing this risk or not. Basic assumption is that the data subject was informed and consented to in the first place to allow WhatsApp to have possession of their personal data. If not, clearly the hotel will be held liable in a first instance.Q: Understanding that GDPR is not a one-off compliance effort (like the rush to fix the Y2K Millennium Bug) and continuous changes will need to be made, is there a grace period on updates? Will there be a global schedule specifying when updates need to be made? How does a company know if it's up-to-date with all the recent regulations?A: GDPR is the law and became enforceable on May 25th, 2018. The grace period for meeting GDPR requirements started in April 2016, with a 2-year period allowed for compliance. Although, it has happened in the past that regulators have "extended" enforceability timelines, to date, I am not aware of any extension periods for the start of enforcement of GDPR.
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Coffee Chat: APEX Hotels & HEBS Digital

Max Starkov | The HeBS blog·24 July 2018
HEBS Digital’s Executive Vice President Jason Price chatted with APEX Hotels’ Digital Manager Steven Howe, based in the UK, to discuss Steven’s career, GDPR, and the latest from APEX Hotels.

HFTP Annual Convention 2018 Online Registration Now Open, Keynotes Announced

HFTP ·24 July 2018
Hospitality Financial and Technology Professionals (HFTP) has opened online registration for its Annual Convention, which it has produced since 1952. Following the traditional event format, the event will offer a variety of educational sessions, networking and vendor opportunities. HFTP has secured two keynote speakers who will discuss topics relating to productivity, engagement, collaboration and communication in the workplace: Colette Carlson and Curt Steinhorst. The HFTP Annual Convention will take place from October 24-26 at the brand new Omni Louisville Hotel in Louisville, Kentucky USA.HFTP Annual Convention full registration attendees will have access to three days of education, two days of table top exhibits, a Welcome Reception and a formal HFTP Tribute to Success dinner and dance. The 2018 schedule of events is available on the HFTP website, and will be continuously updated until the event. Additionally, Annual Convention will feature a business meeting and the HFTP Helps Silent Auction benefiting the HFTP Foundation during the HFTP Tribute to Success. The HFTP Greater Louisville Chapter will also host a social night event on October 25, 2018 at the Kentucky Derby Museum to support the HFTP Helps fundraiser."HFTP is excited to host Annual Convention in Louisville, Kentucky this year," said HFTP CEO Frank Wolfe. "Annual Convention is created specifically with our association's members best interests in mind - join us this October for hospitality education, networking, exhibits, vendor interaction, fundraising, fun social events and more."The dynamic event program will provide relevant industry information for hospitality professionals. Vendor interaction this year will allow attendees to meet with participating companies at table top exhibits. Exhibits will be open to attendees on Wednesday evening during the Welcome Reception, as well as during breaks and lunch on the following Thursday.Visit the Annual Convention page on the HFTP website for complete information about all conference events, including the program schedule, hotel and travel details and more. For more information about HFTP's Annual Convention and other global activities, contact the HFTP Meetings & Special Events Department at education@hftp.org or visit www.hftp.org.Coming up, HFTP's Florida Regional Conference will take place July 25-27, 2018 at the Sarasota Westin in Sarasota, Florida USA - immediately followed by HFTP's inaugural Club Forum which will take place July 28, 2018 at the same location. HITEC Dubai will take place December 5-6 at the Madinat Jumeirah in Dubai, UAE. For more information about HFTP's international events, visit www.hftp.org and www.hitec.org or contact the HFTP Meetings & Special Events Department at education@hftp.org.About HFTP Hospitality Financial and Technology Professionals (HFTP), established in 1952, is a hospitality nonprofit association headquartered in Austin, Texas USA with offices in Hong Kong, United Kingdom, The Netherlands and Dubai. HFTP is recognized as the spokes group for the finance and technology segments of the hospitality industry with an international network of members and stakeholders. HFTP uniquely understands the industry's pressing issues, and assists its stakeholders in finding solutions to their challenges more efficiently than any organization. HFTP offers expert networks, educational resources, career development programs, research, leadership opportunities and conferences and events. HFTP produces international events throughout the year, including the world's largest hospitality technology tradeshow and conference brand: HITEC. The association also owns the world's only hospitality-specific search engine: PineappleSearch.com. For more information about HFTP, visit www.hftp.org.For the latest news, visit the HFTP News page at news.hftp.org and the HFTP Connect blog at blog.hftp.org.Follow HFTP on social media: Facebook (@HFTPGlobal); LinkedIn; Twitter (@HFTP); Instagram (@HFTP_HITEC). Stay tuned to HFTP's industry-specific, informational news sites: HFTP News, HITEC Bytes, HFTP Club Bytes, HFTP Finance Bytes, HFTP GDPR Bytes and HFTP FB Bytes. HFTP event photos are available on Flickr, and HFTP event videos are available on YouTube.
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Relationship Marketing and GDPR: Avoiding the Traps of Personalization Data and Targeting Tech

MarketingProfs·Requires Registration ·23 July 2018
The General Data Protection Regulation (GDPR) came into effect in the European Union on May 25. The regulation is meant to protect consumer privacy and consumer data, as well as the processes that use that data to make decisions about consumers.
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BA's GDPR confusion gets the Twitter treatment

Tnooz·23 July 2018
Implementing the EU’s General Data Protection Regulation (GDPR) was always going to be a challenge for travel companies, but a recent social media storm centred around British Airways would suggest that even the biggest travel brands are not completely on top of the new requirements.
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British Airways shows everyone how not to GDPR

hotelmarketing.com·23 July 2018
The company’s social media staff have been caught unintentionally encouraging customers to post personal data into a public forum. Let’s all take a minute to appreciate the view in the British Airways social media cockpit, where staffers at the coalface of the airline’s Twitter account have presided over a wildly unusual ‘interpretation’ of Europe’s new data protection rules.

HFTP Announces Three New Global Chapters and Expands Student Chapter Networks

HFTP ·18 July 2018
Hospitality Financial and Technology Professionals (HFTP) is excited to announce that three new, local chapters have recently been chartered: HFTP Greater Louisville Chapter, HFTP New York University Student Chapter and HFTP Kansas State University Student Chapter. HFTP chapters provide a wide array of benefits to an association's membership -- not the least of which is the collaborative building of knowledge and camaraderie among local and like-minded industry professionals.HFTP's local chapters help industry professionals in the area expand their network, increase educational opportunities and build strong face-to-face connections with peers. Moreover, HFTP chapters give association members support, tools and resources to advance in their hospitality career."We are pleased to welcome these three new chapters to HFTP," said HFTP CEO Frank Wolfe. "HFTP is determined to efficiently serve its members across the globe, so we are excited to provide more expanded networks in additional local areas."HFTP currently has more than 76 local chapters providing opportunities for networking and education throughout the world. HFTP members can attend chapter meetings to connect with their local network of HFTP members and share solutions with professionals in the community. Chapters hold regular educational and social meetings, as well as participate in projects to benefit area charities.HFTP's Greater Louisville Chapter is currently is led by: Chapter President Joshua Bergen, CHAE, CHTP, controller at VENZA; Chapter Vice President Deuce Sapp, CIO at Al J. Schneider Company; Chapter Treasurer Ashley Barke, senior tax manager at MCM CPAs & Advisors; Chapter Secretary Paul West, hospitality technology consultant at Technical Solution Services.HFTP's New York University Student Chapter is currently is led by: Chapter President Hartanto Yuwo, CHIA, student at New York University; Chapter Vice President Harini Premnath, student at New York University; Chapter Treasurer Xinyi Zhu, student at New York University; Chapter Secretary Yixuan Li, student at New York University; Chapter Faculty Adviser Recep "Richie" Karaburun, clinical assistant professor at New York University.HFTP's Kansas State University Chapter is currently is led by: Chapter President Neda Shabani, student at Kansas State University; Chapter Vice President Prasanna Kansakar, student at Kansas State University; Chapter Treasurer Vahid Behzada, student at Kansas State University; Chapter Secretary Dalton Hahn, student at Kansas State University; Chapter Faculty Adviser Arslan Munir, Ph.D., assistant professor at Kansas State University.For more information about HFTP chapters, visit www.hftp.org. For more information about HFTP's new chapters, read this blog on HFTP Connect.About HFTP Hospitality Financial and Technology Professionals (HFTP), established in 1952, is a hospitality nonprofit association headquartered in Austin, Texas USA with offices in Hong Kong, United Kingdom, The Netherlands and Dubai. HFTP is recognized as the spokes group for the finance and technology segments of the hospitality industry with an international network of members and stakeholders. HFTP uniquely understands the industry's pressing issues, and assists its stakeholders in finding solutions to their challenges more efficiently than any organization. HFTP offers expert networks, educational resources, career development programs, research, leadership opportunities and conferences and events. HFTP produces international events throughout the year, including the world's largest hospitality technology tradeshow and conference brand: HITEC. The association also owns the world's only hospitality-specific search engine: PineappleSearch.com. For more information about HFTP, visit www.hftp.org.For the latest news, visit the HFTP News page at news.hftp.org and the HFTP Connect blog at blog.hftp.org.Follow HFTP on social media: Facebook (@HFTPGlobal); LinkedIn; Twitter (@HFTP); Instagram (@HFTP_HITEC). Stay tuned to HFTP's industry-specific, informational news sites: HFTP News, HITEC Bytes, HFTP Club Bytes, HFTP Finance Bytes, HFTP GDPR Bytes and HFTP FB Bytes. HFTP event photos are available on Flickr, and HFTP event videos are available on YouTube.
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Free webinar: Your Data Security in a Post-GDPR World

Toedt, Dr. Selk & Coll. GmbH ·11 July 2018
It is no surprise. Hotels use a plethora of different software, all of which store guest data in various formats. How could hotels possibly keep track of all this data in a way where they could provide it back to the guest, or worse, delete all the guest's data upon request?dailypointTM is launching an all new webinar on July 13th to help hotels navigate their data in this new, post-GDPR era. In it, Michael Toedt, Managing Partner and CEO at dailypointTM will explain:What the new GDPR regulations areWhat the implications are for hotelsBest practices for hotels to handle the requirementsHow to simplify compliance with all your data in one, centrally managed sourceThe webinar will take place on July 13th at 10am CEST in German and at 11:30am CEST in English. Register now, as space is limited.

HFTP to Host Inaugural, Invitation-Only Club Forum in Sarasota, Florida This Month

HFTP ·11 July 2018
Hospitality Financial and Technology Professionals (HFTP) is hosting its inaugural HFTP Club Forum on July 28, 2018 at the Sarasota Westin in Sarasota, Florida USA - immediately following HFTP's Florida Regional Conference that is taking place from July 25-27, 2018 at the same location. HFTP's Club Forum is an executive-level event designed to provide club professionals with the opportunity to connect with industry peers, share ideas and discuss hot topics.The invitation-only event will be facilitated by Dr. Larry Ross, emeritus professor and former Anne and Bill France Distinguished Professor of Business in the Barney Barnett School of Business and Free Enterprise at Florida Southern College in Lakeland, Florida. The focus of this year's event is the Uniform System of Financial Reporting for Clubs. Attendees will have the opportunity to discuss the strengths and weaknesses, as well as, suggest changes and additions for the upcoming revised version."HFTP is excited to host this executive-level event for club professionals," said HFTP CEO Frank Wolfe. "Designed with intent to explore pressing industry issues, the HFTP Club Forum will serve as another great networking and educational opportunity for its club attendees."Attendees will be able to earn up to eight hours of continuing education credits at the HFTP Club Forum - a link for the CPE reporting will be provided at the conference.Online registration is open for the HFTP Florida Regional Conference, which precedes the HFTP Club Forum. HFTP is no longer accepting applications to register to attend the HFTP Club Forum. In addition, HFTP has several upcoming events. The HFTP Annual Convention is October 24-26, 2018 at the Omni Louisville Hotel in Louisville, Kentucky USA. HITEC Dubai will take place December 5-6 at the Madinat Jumeirah in Dubai, UAE. And HITEC Europe is April 10-11, 2019 at Palau de Congressos in Palma (Mallorca) Spain. HITEC Minneapolis is June 17-20, 2019 at the Minneapolis Convention Center in Minneapolis, Minnesota USA.For additional information about HFTP Club Forum, contact Linnet Baskett, director of club engagement & regionals at HFTP. For more information about HFTP's international events, visit www.hftp.org and www.hitec.org or contact the HFTP Meetings & Special Events Department at education@hftp.org.About HFTP Hospitality Financial and Technology Professionals (HFTP), established in 1952, is a hospitality nonprofit association headquartered in Austin, Texas USA with offices in Hong Kong, United Kingdom, The Netherlands and Dubai. HFTP is recognized as the spokes group for the finance and technology segments of the hospitality industry with an international network of members and stakeholders. HFTP uniquely understands the industry's pressing issues, and assists its stakeholders in finding solutions to their challenges more efficiently than any organization. HFTP offers expert networks, educational resources, career development programs, research, leadership opportunities and conferences and events. HFTP produces international events throughout the year, including the world's largest hospitality technology tradeshow and conference brand: HITEC. The association also owns the world's only hospitality-specific search engine: PineappleSearch.com. For more information about HFTP, visit www.hftp.org.For the latest news, visit the HFTP News page at news.hftp.org and the HFTP Connect blog at blog.hftp.org.Follow HFTP on social media: Facebook (@HFTPGlobal); LinkedIn; Twitter (@HFTP); Instagram (@HFTP_HITEC). Stay tuned to HFTP's industry-specific, informational news sites: HFTP News, HITEC Bytes, HFTP Club Bytes, HFTP Finance Bytes, HFTP GDPR Bytes and HFTP FB Bytes. HFTP event photos are available on Flickr, and HFTP event videos are available on YouTube.###
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Is GDPR Legislation Coming to U.S. Hotels?

Hotel Online·10 July 2018
Privacy legislation is dominating the news cycle these days-and it's unlikely to slow down. Now, as U.S. companies are adjusting to the requirements of the European Union's General Data Protection Regulation, the State of California has introduced new laws that will apply to California companies or companies doing business in California.
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Travel Managers Should Get Used to Data Privacy Restrictions

skift.com - Travel Services·10 July 2018
For most organizations, it’s business as usual after Europe’s new privacy measures embodied in the General Data Protection Regulation (GDPR) came into effect on May 25. That is largely because of the efforts of the major travel suppliers and industry associations.
Article by Michael Toedt

GDPR complaints are on the rise. Are you prepared?

Toedt, Dr. Selk & Coll. GmbH · 9 July 2018
As an indicator of what is to come, let's look at what's been happening outside of the hospitality industry. Regulators in the UK, France, Austria, and across Europe are reporting a sharp increase in data protection complaints and breach notifications since the GDPR came into effect. The majority of these complaints were filed against tech giants like Google and Facebook.Isabelle Falque-Pierrotin, the head of French data protection regulator, CNIL, told Politico: "The general public is interested about all the transparency obligations, consent and all the new rights."What does this mean for the hospitality industry? Should hotels be concerned? Only time will tell, however, with maximum fines up to EUR20m or 4% of a company's global turnover - whichever is higher, hotels must be prepared if complaints come their way.So how can hotels prepare? First, they must have a proper way to manage all guest data. Since most hotels use multiple different systems that all store guest data in different formats, this can quickly become a burden. One way to simplify the storage of data is to centrally manage all guest data in one system. In this scenario, if a guest requests that his or her data is retrieved, edited, or removed, the hotel can simply fulfill the request at the click of a button.Centralized data management has further benefits for hotels. It allows them to truly understand their guests and use their data in meaningful ways. Imagine the possibilities when data from a hotel's PMS, POS, WLAN, newsletter system, Outlook, booking engine, channel manager, questionnaires, website etc. are all in one place. The possibilities to personalize marketing, upsell communications and guest services are limitless. Centralized data management transforms data into revenue.Learn more about how to leverage your hotel's data in the post-GDPR landscape in an all new webinar hosted by Michael Toedt, Managing Partner and CEO at dailypointTM. The webinar will cover:What the new GDPR regulations areWhat the implications are for hotelsBest practices for hotels to handle the requirementsHow to simplify compliance with all your data in one, centrally managed sourceFurther operational benefits of central data managementThe webinar will take place on July 13th at 10am CEST in German and at 11:30am CEST in English. Register now, as space is limited.
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What GDPR Means for You and Your Restaurant

Modern Restaurant Management· 6 July 2018
The European Union’s new General Data Protection Regulation (GDPR) recently went into effect. The set of rules were created to govern the privacy and security of personal data and were put out by the European Commission. Even though the GDPR is set in Europe, it still has serious implications for a number of companies in the United States. Who Is Affected? Regardless of the location of your company, you will be affected by the GDPR if: You collect personal data or behavioral information from someone located in a EU country You’re based outside of the EU but provide goods or services to the EU, including free services You are established within the EU, regardless of where you process and collect personal data (including cloud-based processing performed outside of the EU for an EU-based company) With that being said, clearly the new regulation will cause a rippling around the world.
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The Impact of California Consumer Privacy Act of 2018 on Businesses andConsumers

Duff on Hospitality Law· 5 July 2018
On Thursday, June 28, 2018, the California Consumer Privacy Act of 2018 (the Act) passed with resounding support from both Republicans and Democrats, who voted in favor of the bill 73-0-7 in the Assembly and 38-0-3 in the Senate. The Act, which takes effect on January 1, 2020, imposes requirements on the processing and protection of personal data similar to, and in some cases, more extensive than the requirements under the EU General Data Protection Regulation (GDPR), which went into effect on May 25, 2018.

Personal data protection and the hospitality industry in France

In Extenso Avocats, a subsidiary of the DELOITTE Group · 3 July 2018
France has just adopted the modifications to the Data Protection Act ndeg78-17, integrating the new General Data Protection Regulation (GDPR) measures. As a reminder, the GDPR - ndeg2016/679 of the European Parliament and of the Council, voted the 27 April 2016 - is a regulation in EU law on the protection of individuals with regard to the processing of personal data and on the free movement of such data. The act came into effect in all EU member states on the 25 May 2018.The CNIL has already indicated that it will take into account the "efforts undertaken" by companies in their compliance process, and that no sanctions will be applied until the end of 2018 regarding provisions directly resulting from the regulation. This does not, however, exclude the pronouncement of sanctions in case of breach of the provisions already in force under the Data Protection Act (far from being complied with everywhere).It is clearly not too late to look at how the regulation can be applied in your own company.There are a number of ways of implementing GDPR in hotels and restaurants, and the regulation can be viewed as yet another administrative constraint or as an inevitability and an opportunity. Indeed, it should be remembered that its very name embraces personal data protection issues, yet it also covers the free movement of such data. Given this, the regulation not only seeks to protect the personal data of businesses and their clients, prospects or employees, it also allows for the free movement of these data. This free movement merely has to be controlled and regulated to avoid misuse, errors or accidents in data processing - the like of which has been seen several times over the past few years (Google, Facebook, Darty, Hertz, Direct Energie and so many others)[i].Top of the list of the sectors concerned is the hospitality industry...The regulation provides for thresholds to take into account the situation and business activity of SMEs or intermediate-size companies. Not all hotel and restaurant businesses are necessarily affected, but if they automatically store and conserve customer data - on preferences, for example (in order to send promotional offers or improve satisfaction during a later visit) - then they are directly concerned. Likewise, if customers can make a reservation through the company website, then the regulation also applies, since the question of the use and compliance of booking platforms (e.g. La Fourchette, Booking.com) evidently arises, as does that of holding records for inspection by the police or maintaining Cardex files.In the same way, the processing, use and safeguarding of payment methods must be carefully examined. In addition, if hotels and restaurants use video surveillance, they must also examine how such systems could impact on the privacy of their customers and employees.What measures can hotel operators - and to a lesser extent, restaurant operators - take to serenely anticipate these regulatory obligations after the 25 May 2018?Beyond implementing a unified legal framework at the European level, the objectives of the GDPR include:A strengthening of the individual rights of natural persons, already instigated by a number of decisions such as the Google Spain judgment sanctifying the right to erasure, or Darty's recent fine further to a security breach in the confidentiality of customer loyalty card data[ii]Compliance based on transparency and accountability;Shared and specified responsibilities (the outsourced service provider becomes accountable, just as the contracting party);The strict supervision of data transmission outside the European Union;Regulated, incremental and stricter financial penalties.Hotel and restaurant operators should take particular note, since they will move from a reporting regime with an a posteriori penalty to a new regime based on anticipation and accountability. The consequences are multitude, as we will see later. Although this change means fewer reporting obligations, it also reflects the strengthening, or even the creation, of a number of obligations for all hospitality operators (and companies, in general) that process their customers' personal data.These obligations mainly focus on anticipation, information, transparency and security and documentation. HOTEL AND RESTAURANT OPERATORS MUST ANTICIPATE: In case of complaints, security breaches or CNIL controls, business must generally be able to justify their having applied the universal "privacy by design" principle, meaning that they have integrated respect for the privacy of natural persons into data processing right from the start. This principle requires considering the lawfulness of the data processing, conducting preliminary impact studies when necessary, and potentially obtaining the consent of individuals whose data have been collected and informing them of their rights.HOTEL AND RESTAURANT OPERATORS MUST INFORM: Henceforth, an obligation of transparency is imposed on hospitality operators who manage, store, host, process or sell personal data. Take, for example, hotel and restaurant customers who are natural persons, and whose data are collected - these individuals must be notified as to the purpose of the data processing and informed of their rights in terms of data access, rectification, erasure and portability.HOTEL AND RESTAURANT OPERATORS MUST PROTECT:Everything must be done to protect the data held by a company, in accordance with the "security by default" principle. Going beyond the required and optimal protection, businesses must allow data to be traced, and any security breach has to be declared to the CNIL within a very short time frame (72 hours, as stipulated by the regulation). Penalties for breach of these obligations will be reinforced (up to either 4% of annual global turnover or 20 million euro), although there is an emphasis on making the sanction proportional.AND LASTLY, HOTEL AND RESTAURANT OPERATORS MUST DOCUMENT: In certain cases, maintaining a Record of Data Processing Activities is obligatory.Hotel and restaurant operators are directly concerned by GDPR if:They employ 250 employees or more.And/ or they processes personal data en masse or automatically.And/ or this processing concerns sensitive data and/ or could infringe individual rights and freedoms. Each of these criteria must be assessed separately, and in certain cases, hospitality operators are required to maintain a Record of Data Processing Activities. Indeed, the sector is especially impacted by GDPR, given its various business activities: organisation and information systems, HR management, sales and marketing (prospection, promotion, customer record management, etc.), supplier management and, of course, hospitality IT management.The hospitality sector is specifically targeted, whether or not data are conserved in the company's computer server and/ or stored and/ or hosted and/or reprocessed by a subcontracting party. Hotel and restaurant customer records can no longer contain any old data and must respect certain conditions. These personal data, already considered by some as the new "black gold", can be coveted by malevolent competitors or by hackers for resale or ransom (WannaCry ransomware, for instance). At a time when cyberattacks are on the rise, the sector must ensure the protection of its customers' personal data, as well as those of its employees (who are also covered by the new directive). There is no doubt that a hotel or restaurant's e-reputation also depends on whether or not it complies with the regulations.In concrete terms, an audit is necessary to evaluate a business's practices and to pinpoint the risks. Further to the audit, an action plan must be instigated to potentially maintain a Record of Data Processing Activities that groups and describes the business's personal data processing practices, or if the maintenance of such a record is not mandatory, to implement minimal GDPR compliance procedures. This requires the assistance of a multidisciplinary technical and legal advisory structure - one that is well-established and specialised in the hospitality sector - so that the process can be correctly handled at the best possible cost.It is, of course, never too late to comply.[i] CJUE, gde ch., 13 May 2014, aff. C-131/12, Google Spain SL and Google Inc./ Agencia Espanola de Proteccion de Datos and Gonzales,CNIL Resolution ndegSAN - 2017-006 of the 27 April 2017 imposing a fine on FACEBOOK INC. and FACEBOOK IRELANDCNIL Resolution ndegSAN-2018-001 of the 8 January 2018 imposing a fine on ETABLISSEMENTS DARTY ET FILSCNIL Resolution ndegSAN-2017-010 of the 18 July 2017- HERTZCNIL Decision MED ndeg 2018- 007 of the 5 March 2018 serving notice on DIRECT ENERGIE and CNIL Resolution ndeg 2018-082 of the 22 March 2018 and decision issued to make public the formal notice to DIRECT ENERGIE[ii] CJUE, gde ch., 13 May 2014, aff. C-131/12, aforementioned Google SpainCNIL Resolution ndegSAN-2018-001 of the 8 January 2018, aforementioned DARTY ET FILS
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AirGain New Time-Table Feature & Flight Comparison to Empower Airlines with Competitor Intelligence on Various Time Windows

RateGain ·28 June 2018
London -- RateGain Technologies, the market leader in big data solutions for Travel and Hospitality industries, today, announced new product updates on AirGain,the airfare competitor intelligence tool. In the new set of releases, AirGain has focused on giving a broader compset intelligence to the airlines with full context at a glance.The new features like time-table and flight comparison view would display the most important data and insights that every Revenue Manager needs to make the right pricing decision. Following are highlights of the latest release:Time Table View-Users can now view departing schedules of all the itineraries from all the competing channels in a timetable format. Each date on the table view provides with information on airline code, the rate and the channel with the cheapest availability. Users can also see all the different channels an itinerary is available on through the tooltip.Flight Comparison - Cheapest View: This view compares airlines between an O&D on different departure dates. Cheapest View picks up the cheapest data point for each channel along with picking one data point for one departure date of each channel and ignoring the rest.Flight Comparison - Default view: This view allows airlines to analyze all different itineraries and monitor rates offered by different channels. Also, in addition to subscribers own parity check, this new feature also outlines the parity trend line for the comp set across different channels.Reverse crawling: With this feature, the subscriber gets access to fresh data for the nearest departure dates which are more prone to changes.According to Dr. Anand Medepalli, CPO, RateGain, "We are excited to roll out new updates in AirGain2.2 for Quarter-1. In this multiple product update releases, our effort has been to provide insights and data points beyond the known comp-set intelligence. These are the important information plugs which needs to be factored and taken into account while strategizing the pricing of the airlines. All these new features will automatically be updated for our existing airline clients. Along with this release, we are also happy to share that from 25th May onwards, all business processes and systems at RateGain are in compliance with the EU GDPR law. As a global organization, RateGain has updated its privacy policy which details how do we use and process the information that we collect. We are proud to be one of the first rate-intelligence and distribution solutions companies to appoint a Data Protection officer in compliance with the EU GDPR law."AirGain, the next-gen Pricing Intelligence Solution was launched in November 2017, with an aim to offer real-time big data pricing intelligence and exhaustive market data to the airlines. The tool takes care of critical business challenges faced by the industry such as inaccurate or delayed pricing, understanding ancillaries pricing and tackling the airline rate parity issues, enabling airlines to make smarter business decisions. We currently monitoring 14000+ routes and 4 Million+ data points for around 40 Airlines across the globe.Forward-Looking StatementsCertain statements in this release are forward-looking statements, which involve a number of risks, uncertainties, assumptions and other factors that could cause actual results to differ materially from those in such forward-looking statements. All statements, other than statements of historical fact are statements that could be deemed forward-looking statements, including but not limited to the statements containing the words 'planned', 'expects', 'believes',' strategy', 'opportunity', 'anticipates', 'hopes' or other similar words. The risks and uncertainties relating to these statements include, but are not limited to, risks and uncertainties regarding impact of pending regulatory proceedings, fluctuations in earnings, our ability to manage growth, intense competition in IT services, data services and consulting services including those factors which may affect our cost advantage, wage increases in India, customer acceptance of our services, products and fee structures, our ability to attract and retain highly skilled professionals, our ability to integrate acquired assets in a cost-effective and timely manner, time and cost overruns on fixed-price, fixed-timeframe contracts, client concentration, restrictions on immigration, our ability to manage our international operations, reduced demand for technology in our key focus areas, disruptions in telecommunication networks, our ability to successfully complete and integrate potential acquisitions, the success of our brand development efforts, liability for damages on our service contracts, the success of the companies /entities in which we have made strategic investments,

Alexa for Hotels - The Good, The Bad and The Creepy

Puzzle Partner Ltd. ·28 June 2018
This past week marked another successful HITEC, the culmination of which left hospitality experts with a lot to think about as it relates to industry-wide innovations positioned to make major waves in 2018. One of the more notable discussion points is the mainstream integration of voice-powered assistants (AI technology) into hotels. In fact, Amazon.com Inc recently announced that it has partnered with Marriott International Inc to help increase guest access to amenities with Alexa, through its voice-controlled device Echo, in an attempt to expand its presence in the hospitality industry. This is an exciting prospect for hotels, as implementing Alexa in a hospitality setting could assist in a personalizing room settings, ordering room service, housekeeping, calling the concierge and so much more. Of course, in the same excited breath that we speak to the potential conveniences which Alexa (and other voice-activated tech) can provide, we have to consider the on-going concern of data security. Especially with the recent implementation of GDPR, the protection of guest data and the proper attainment of documented consent for all data collection should be paramount. However, voice-activated devices are admittedly trudging into uncharted waters, as their ability to gain uninhibited access into user's conversations and preferences comes into question.With this in mind, we've delved into the good, the bad (and even the creepy) that is in store for hoteliers eager to branch into the world of Alexa for hotels. The Good Alexa for hotels offers a wide range of exciting possibilities, including room temperature regulation, turning on lights, sending emails, ordering room service or housekeeping, asking for local recommendations and so much more. Alexa will offer 24-7, efficient and hands-free customer service for every guest, tapping into the desire for increased personalization without over-extending hotel staff. Ideally, Alexa should help hoteliers provide a seamless guest experience as part of the myriad of programs and devices in place to improve hotel operations, and better connect with and serve guests. According to Marriott International, consumer feedback has been overwhelmingly positive thus far. And as far as guests readily engaging with the device? That's been promising as well. According to Volara, for every 1,000 occupied room nights, it is automating an average of 240 item/service requests and 700 guest questions about the hotel and surrounding area. Throughout these pilot programs with Alexa, guests requesting for the device to be removed from their rooms has also been very low. Volara CEO David Berger assures, "We are not capturing transcripts or recordings, and we don't know guests' identity. Just their room number. Meanwhile, Amazon, which does capture recordings once a person says "Alexa," to improve the devices' natural language processing capabilities, does not have access to the guest's identity or room number, ensuring that the information is always anonymous.The Bad Speech-recognition software is by no means new, with the likes of Siri often being used as our iPhone-enabled personal assistant while on the go. However, as the capabilities of speech-recognition and AI evolve within technology such as Alexa, Google Home, smart refrigerators and hotel rooms, the technology continuously becomes smarter. Using real-time experiences (machine learning) to identify and respond to user needs more accurately, these devices are continually collecting and analyzing data. Essentially, in order to serve us, these devices must learn about us -- a concept which may leave some users feeling unsettled or subject to invasive data collection.The concern here is that it's not always clear when Alexa is listening, although it's noted that"Amazon and Google insist their smart speakers do not record voices until someone directly addresses the device with a 'wake word' such as 'Alexa' or 'okay, Google. However, It is possible to accidentally 'wake' such devices, which means it is not always clear when they are listening."Further to suspicions of idle data collection, it's also unclear who should have access to what data, since multiple individuals will typically use the device at different times, which makes for complex privacy boundaries. We also have to consider the fact that the evolving capabilities of voice-powered assistants on such a public scale leaves room for error -- there are bound to be some initial learning curves that leave users feeling vulnerable. An example of such a privacy mishap recently unfolded in Portland, Oregon, when a local woman had private conversations secretly recorded by the voice-controlled Amazon virtual devices in her home. Those conversations were then sent to a random contact in Seattle. While cases like these are a rarity, the user-friendly simplicity of the device which makes it so popular to the general public, also means the security protocol may mirror that simplicity when it should be more complicated. As we'll delve into more later in this article, Alexa is triggered into action by a 'wake word', an exchange which could easily be misinterpreted and mis-triggered. For those of us particularly concerned about Alexa accidentally "listening in," an easy fix is to unplug or mute the device in moments you know you won't need its service. So the question becomes, can we trust Alexa?As the technology continues to improve, we can only hope that these virtual assistants become better equipped to identify different types of information with varying layers of security to prevent private information from being mistakenly shared. As mentioned above, user concerns regarding the misuse of their private information should (mostly) be put to rest, as any information collected is anonymous aside from room number.The CreepyAs Alexa's popularity has picked up momentum, so have the odd-ball stories circulating the web claiming witness to strange or otherwise unexplainable reactions from the device. These include, but aren't limited to, sudden laughter, unsolicited and seemingly random replies, or Alexa speaking without being woken up by a wake word.On one forum, a married couple described the time in which Alexa interjected into their dispute."My wife and I were arguing about something. No clue what it was, but it was getting a little heated. I don't know what Alexa thought she heard, but she suddenly interjected with, "Why don't we change the subject?" It was just unexpected and relevant enough to be creepy. We both heard it, and we both still talk about it years later. There was nothing in the app logs." Another woman detailed that her Mother's Alexa suddenly turned on one day (started glowing) and her Mom asked, "Alexa, what are you doing?" to which Alexa replied, "I'm trying to learn new things." Her Mom replied, "No one told you to do that" and Alexa replied "okay" before turning back off. Of course, while we may love to assume Alexa has an ulterior motive aligned with some sort of Sci-Fi horror movie, there is a reasonable explanation for these occurrences. ZDNetnotes that the most likely cause of an Alexa spontaneous reaction is a misinterpretation of sound. Given how sensitive Alexa has to be to process wake words, sometimes Alexa will react to a sound (even one we might not hear or notice) and interpret that as a wake word or command of some sort. After all, Alexa's sound processing system has to be able to take the sound waves and do its best to interpret what the humans speaking are asking for.AI technology and voice-powered assistants are undeniably one of the hottest topics following the close of HITEC 2018, and there's no doubt they will continue to be a prominent focal point moving forward. Love it or hate it, Alexa is likely coming to a hotel room near you -- and I don't know about you, but I'm interested to see the way in which this technology evolves within our industry.
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The GDPR compliance - The hidden benefits of compliant hotel

Hotelogix Blog·27 June 2018
Now that the GDPR compliance laws have been implemented, getting your hotel GDPR compliant has become a mandate. And as you are faced with this daunting task of managing your customers data to ensure that their data is protected, there are a few points that can help your business.

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