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At [email protected], we are committed to working tirelessly towards maintaining our highly regarded and respected quality of service.
[email protected] (“We”) are further committed to ensuring that any of your Personal Data which we have with us, is protected and respected always.
Our use of your personal information is governed by this Privacy Notice and any other documents referred to in it.
WHAT DOES THIS POLICY DO?
This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.
Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
[email protected] is a Data Controller for the personal information that it collects and uses about you and a Processor for some data referred to us by any Third Party who you would have allowed, or enabled to use your data for a lawful purpose relating to our services. We will always treat your personal information as confidential and your personal information will only be shared with others in accordance with this Privacy Notice.
The Data Controller can be contacted at:
Data Protection Compliance, [email protected]
By visiting [email protected] you are accepting and consenting to the practices described in this policy. The General Data Protection Regulations are to safeguard your personally identifiable information or personal data. This privacy notice will be regularly reviewed and updated.
This Privacy Notice explains:
- What personal information is
- How we collect your personal information
- The types of personal information we collect
- How we use your personal information
- The legal basis for processing your personal information
- How we share your personal information
- How long we keep your personal information
- How we keep your personal information secure
- Overseas transfers of your personal information
- Your rights in relation to your personal information
- How to make complaints and how to contact us
If we need to change the way in which your personal information is used by us, this Privacy Notice will be updated and if the changes are significant, we will advise you.
WHAT IS PERSONAL INFORMATION?
Personal information is any information that, on its own identifies you, or can be put together with any other either information, can identify you or tell us something about you. This could include information such as name, email address, other contact details, date of birth, bank account details or any information about your needs or circumstances.
Some personal information is classified as “special” data under data protection legislation. This includes information relating to health, racial or ethnic origin, religious beliefs or political opinions and sexual orientation. This information is more sensitive, and we need to have further justifications for collecting, storing and using this type of personal information.
Any references to personal information in this privacy notice will include personal data, and where relevant, special categories of personal data.
Much of the personal information we process is information that you or someone acting on your behalf knowingly provides to us.
On this site, “[email protected]”, “our” and “we” each mean any permanent [email protected] Office or temporary location being used as such, in the United Kingdom, which collects and use your information in the manner set out in this Privacy Notice.
HOW DO WE COLLECT PERSONAL INFORMATION?
We may collect and process all or some of the following data about you when you contact us, enquire with us or interact with us.
We collect information about you (which can include documents) through a variety of different methods including from you directly and from third parties.
From you directly:
You may provide personal information and /or documents by:
- Completing forms on our websites or other online platforms which ARE under our direct control or direct management
- Completing forms on Signable (our online digital e-signature platform)
- By communicating with us by post, phone, email, sms text, watsapp, messenger or similar
- By supplying documents through any of these methods
From third parties:
We may receive personal information and/ or documents about you from various third parties such as (but not limited to):
- Websites or other online platforms which are NOT under our direct control or direct management
- Anyone making the booking on your behalf (such and en employer or spouse)
Some of the apartment buildings we operate in have CCTV which will record your image on entering and exiting the building
INFORMATION YOU GIVE US:
You may give us information about you by making a booking or filling in forms on our site [email protected] (“our site”) or by corresponding with us by phone, email or otherwise. This includes information you provide when you search for a serviced apartment, book a serviced apartment on our site and when you report a problem with our site. The information you give us at this point is likely to include your name, address, email address and phone number, financial and credit card information, special requirements such as those relating to any disability or medical condition which may affect the chosen arrangements and dietary restrictions (which may disclose your religious beliefs).
When you make a booking via our partner property management system – who then process this Data on our behalf you can be assured that this is via a secure https:// connection and any details provided are stored securely in the booking system. During this process, as a guest, you would create an account which you can login to and see details of reservations, as well as your data which is held there. This can be edited by you, giving you control.
TYPES OF PERSONAL INFORMATION WE MAY COLLECT:
The types of personal information that we may collect, receive and process, includes:
- your name, gender, personal and work contact phone number(s) and email addresses, business title, date and place of birth, image, nationality, home address, and passport and visa information;
- guest stay information, dates of arrival and departure, goods and services utilised, special requests made, observations about your service preferences, telephone numbers dialled, and faxes, texts and telephone messages received (if applicable);
- your credit or debit card details including billing address, and your bank account details;
- the name of your company if you are placing a business booking;
- information, feedback or content you transparently provide regarding your marketing preferences, in surveys, sweepstakes, contests, or promotional offers, or to our websites and those of third parties;
- in limited cases, information relating to the credit of customers (never without prior disclosure and authority);
- your vehicle registration number (where parking has been booked);
- the names of other guests (if over 16 years of age);
- information about your accommodation requirements such as budget, length of stay and accommodation type;
- such other information as we deem necessary and as set out in our terms of business from time to time and/or as required under The Immigration (Hotel Records) Order 1972.
When you wish to book an apartment with us we will ask you for the following documents:
Such documents as we deem necessary and as set out in our terms of business from time to time [this may include (but is not limited to) a copy of your passport and/or other identity document and a photograph of both sides of your payment card (but with part of the long PAN number obscured)] and/or as required under The Immigration (Hotel Records) Order 1972
Where we require a deposit from you and/or where you add extras to your booking we may also collect the following information from you to process the payment
- Your payment card details (although we will NOT store this information after processing your payment via one of our payment platforms (such as but not limited to Sagepay or Worldpay)
- Such other information as we may deem necessary.
The Immigration (Hotel Records) Order 1972 requires that we must collect the following information from guests
- Full name
For all who are not British, Irish or Commonwealth guests
- Passport number and place of issue (or other document which shows their identity and nationality)
- Details of their next destination (including the address, if known) on or before departure
PAYMENTS FOR AN APARTMENT
Subject to our right to collect payment card details as referred to above, your payment card details will normally be supplied by you directly to one of our payment platforms (such as but not limited to Stripe or Worldpay) via a secure payment link which we provide you.
Although we can access this information, we will NOT download or store this information outside of the payment platform.
Your payment card details will only be used as set out in our terms of business from time to time.
FAILED AND CANCELLED BOOKINGS
INFORMATION WE COLLECT ABOUT YOU:
With regard to each of your visits to our site we may automatically collect the following information:
- technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
- information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.
INFORMATION WE RECEIVE FROM OTHER SOURCES:
We may receive information about you if you use a website that we either operate or which directly processes Data on our behalf, via the other services we provide. We work closely with many third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers) and therefore we may receive information about you from them.
If you have booked through a third party website (such as, but not limited to Booking.com or Silverdoor) we may collect the above personal information from them (as booking agent on your behalf) rather than directly from you.
If an employer spouse or other third party has booked the apartment for you we may collect the above personal information from them (as booking agent on your behalf) rather than directly from you.
In the case of indirect bookings we may still ask you directly to verify such personal information as we may deem necessary to reserve the apartment for you.
We will only request as much Data from you that we require at certain stages in our business processes. This is good practice in GDPR terms.
WHY DO WE COLLECT THIS INFORMATION?
- To provide you with products and services. Each product and service have different information requirements. Therefore, the personal data we need, and what it is needed for, can differ.
- To provide you with information about products and services that we, believe will be of interest to you. We will only do this with your consent. You can withdraw your consent at any time by changing your marketing preferences or unsubscribing using the link at the bottom of the emails we send you (this could either be an “unsubscribe” link or a “manage my preferences” link), or by sending an email to [email protected]
HOW WE USE THIS INFORMATION:
We will only use your personal information lawfully. We use information held about you in the following ways:
INFORMATION YOU GIVE TO US:
We will use this information:
- we may use your name, address and credit/debit card details to process your serviced apartment booking even if this has been booked through an agent;
- we will use your details to provide you with the information, products and services that you request from us, to manage your booking, send you notifications and communicate with you generally.
- to provide you with information about other serviced apartments and/or services we offer that are like those that you have already purchased or enquired about;
- to ensure that content from our site is presented in the most effective manner for you and for your computer.
INFORMATION WE COLLECT ABOUT YOU:
We will use this information:
- to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- to improve our site to ensure that content is presented in the most effective manner for you and for your computer;
- to allow you to participate in any interactive features of our service, when you choose to do so;
- as part of our efforts to keep our site safe and secure;
- to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
- to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.
We may combine this information with information you give to us and information we collect about you. We may use this information and the combined information for the purposes set out above (depending on the types of information we receive).
In addition, if we are providing a service to you, or on your behalf, where we are required to do so by law, we may request a copy of your passport.
The lawful grounds (reasons) which we will typically use for processing your personal information are:
- Where we need to perform the contract between us (contractual obligation)
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests
- Where we need to comply with a legal or regulatory obligation
- With your permission and agreement (consent)
Where we need to perform the contract between us:
- We use the personal information to fulfil our contractual obligation to you in supplying a serviced apartment including (but not limited to) processing your payment, organising your key collection and check-in, and providing you with information on what to do on arrival and whilst a guest in the apartment
- Where parking has been booked we will pass your vehicle registration number onto any apartment management company and/or car park operator to ensure you can park on arrival and will not receive a parking penalty notice
- We will also pass guest names (if over 16 years of age) and contact details onto other third parties such as our administration teams, housekeeping and cleaning teams, maintenance contractors, and our security and reception teams for them to assist us in fulfilling our contractual obligation to you in supplying a serviced apartment
Where it is necessary for our legitimate interest:
We may process personal information that we hold to further our legitimate interests which may include the following activities:
- Communications with you before you make a booking and become a guest
- Communications with you after you make a booking and are a guest
- Record keeping for book-keeping, accounting, banking and tax reporting
- Occupancy and revenue reporting
- Monitoring client spend and credit
- Monitoring website performance
- Monitoring customer service performance
- Monitoring social media performance
- Debt recovery
- Fraud prevention
- Processing and replying to chargeback requests
- Processing and replying to refund requests
- Reporting guest misconduct
- Reporting suspected criminal activity, including but not limited to suspected activity involving fraud, drugs and child exploitation
- Asking you to leave a review
- Responding to a review from you
Where we need to comply with a legal obligation:
We may process personal information that we hold because we have to by law.
This will typically arise from our obligations under The Immigration (Hotel Records) Order 1972. This may also arise where we are requested directly (or by third parties) to supply personal information to the police and/or or other crime prevention and/or enforcement agencies/ authorities in connection with suspected criminal activity, including but not limited to suspected activity involving fraud, drugs and child exploitation. This may also arise where a local council requests information from us about the use of any of our apartments.
With your permission and agreement (consent):
Generally, we do not rely on consent as a legal ground (reason) for processing your personal data, other than in relation to sending marketing communications to you via post, phone, email, SMS, Whatsapp, Messenger or similar.
Marketing by [email protected]:
By choosing to stay with us you are expressly consenting (opting in) to receiving marketing communications from [email protected] (and any sister companies) before during and after the booking completes.
You have the right to stop the processing of your information for any and all direct marketing activity through all channels, or selected channels. We must always comply with your request because whenever you have given us consent to process your personal data, you have the right to change your mind and withdraw that consent at any time.
You can withdraw consent to marketing at any time by emailing us at [email protected].
You can also withdraw consent to marketing by click the unsubscribe button on any marketing email you may receive from us.
Marketing by third parties:
We do not share personal data with any third party for marketing purposes, if this however should there be a circumstance where this is required we will get your separate express opt-in consent before we share your personal data with any third party for marketing purposes.
Because the security of your personal information is important to us, Secured Socket Layer (“SSL”) software is used on our booking platform ‘Elina’ to encrypt the personal information that you provide to us. If your browser is SSL enabled (which most are), your transmission of personal information to this platform online will be encrypted. You can verify whether your personal information is transmitted using SSL encryption by confirming the symbol of a closed lock or solid key on the bottom bar of your browser window. Different browsers may use different symbols. You can also verify that your personal information will be encrypted using SSL encryption by making sure that the prefix for the web address listed for that page has changed from “http” to “https”. If you do not see the appropriate symbol and the “https” prefix, you should not assume