Your personal information allows us to provide the products and services you have asked for, as well as enabling us to improve those products and services by understanding your interests and preferences. By understanding what you like (and what you don’t) we are able to personalise your experience, show relevant adverts and improve your stay.
Who we are
Hot-el-apartments Ltd (“we”, “our”, “us”) is the data controller. The company is registered in Scotland under company registration number SC568381, at the office address: 20 Canonmills, Edinburgh, EH3 5LH.
Hot-el-apartments Ltd is fully compliant with GDPR (General Data Protection Regulation). Please refer to the separate GDPR statement for more details.
Legal basis for using your information
All organisations need a legal reason to use your personal information, if they don’t have one, they can’t use it. There are a number of legal grounds that enable data processing. It’s quite complicated but below are the most relevant grounds you should be aware of.
With your consent (C)
There are some activities where we process personal information with your consent, which you are able to withdraw at any time, although if you do, we may not be able to provide the product or service you have requested. For example, where we want to send you marketing messages by email, we would ask your permission first and you could opt-out at any time. We will indicate in the Policy where we rely on consent.
To fulfil a contract (A)
We also process your personal information in order to fulfil a contract we have with you. For example, when you book a stay with us, we will process your information to administer that stay.
For a legitimate interest (LI)
Sometimes we may use your information to help achieve our business objectives but only where that activity doesn’t negatively affect your rights. For example, we might use your information to analyse occupancy rates of our properties and adjust room rates.
To comply with legal obligations (LO)
There may be situations where we need to use your information to comply with legal obligations. For example, we are required by law to keep records of who is in our properties in case there is an emergency, so we can make sure you’re safe.
What information do we collect?
When you interact with our products and services we collect information about you and that particular interaction. Generally, this may include:
· Your personal details;
· Contact information, and preferences;
· More sensitive information, for example when you tell us about disabilities;
· Information about your use of our properties, and other services when you stay with us;
· Images of you in areas of our properties covered by CCTV;
· Information about anyone you’re travelling with or meeting, if that information is provided to us; and
· Information about the devices you use to interact with us.
· Where you provide information to us about other people, you need to make sure you have their permission to do so.
When and how we collect your information
We collect information you provide to us directly and indirectly when interacting with our products and services, including when you stay with us.
This may include when you:
· Book a room online, over email or on the phone;
· Create, use or manage an online account;
· Sign up to our Newsletter and promotions;
· Visit our website
· Fill out our online forms or registration cards;
· Visit our properties;
· Access internet at one of our properties;
· Interact with us via online forums, by email, text, or on social media;
· Post reviews of your stay or interaction with us;
· Complete our market research/customer surveys; and
· Enter competitions or promotions.
There may be situations where we use data processors – companies who act on our behalf – to collect your information for us. These processors can only use your information in accordance with our instructions and for the purposes in this Policy.
Travel agents and partners
We collect information about you when it is provided to us by third parties. This might include online travel agents, travel websites, and other partners. This could be when you make bookings, review your stay online, or where you interact with anyone who promotes our brand. You should always read the privacy policies of travel companies or other third parties you use, as they will use your information in accordance with their own privacy policies.
When you, or someone on your behalf, make a booking using travel agent, booking platform or other third party to use our services, they may pass us information about your booking, including information about anyone else on that booking. The same would be true where you use a third party to make enquiries about our products or services.
Where you interact with third parties who promote our services for us, these third parties may pass us your information. When you post comments, reviews, or engage in discussions and polls about our products and services, we may receive this information from the platform you interacted with or from our partners who monitor how our brand is performing. Sometimes we may want to improve our products and services by getting a better understanding about our customers and their preferences. In these situations, we may ask reputable insight providers to provide us information that may identify you. However, this would only be where you have specifically consented to that third party providing your information to us. Where we receive information about you from other sources, we may combine it with information we already hold about you and use it in accordance with this Policy. We may receive updated information about you from organisations that provide services to you. For example, we might be updated if you move home so that we can keep our records up to date or receive updated payment details to ensure that you can continue to use our products and services. Alternatively, we may be updated if your flight is late, so that we can anticipate your arrival time with us more accurately.
How we use your personal information
The reason we use your information will often be obvious from the way you interact with us. For example, if you book a room at one of our properties, we would use that information to administer your stay with us. However, our uses of your information may not always be so obvious. You can find out more below. When you provide your information to us, we may use it to:
Use of personal information
Legal basis for processing (where there is more than one, the exact grounds will depend on the activity - see the section above for an explanation of each)
Provide you with the products and services you have requested, including administering your booking, responding to any enquiries, complaints or requests you may have
C, LI, A
To manage our relationship with you
C, LI, A
Allow you to receive monthly newsletters
C, LI, A
Send you market research surveys
Tailor our service to your preferences, where you tell us about them
LI, C, A
Make decisions about what direct marketing to show you based on how you have interacted with us
Improve our products and services online and offline, including our website
Allow you to interact with us online and offline, in forums, on social media and elsewhere
LI, C, A
Monitor the use of our products and services and content
Verify your identity
LI, A, LO
Provide linked services, like joint promotions with partners
C, A, LI
Conduct analysis, system testing and statistical research
Comply with legal obligations placed on us
Detect ad blockers and other technologies that affect the services we provide
LI, A, C
Manage our properties efficiencies and H&S compliance
Send you product or service related communications, service messages
LO, LI, C ,A
Send you direct marketing, where you have consented
Allow social sharing functionality
C, LI, A
Keep guests safe and ensure the security of our properties
Conduct data matching and audience insight activities
Ensure the acceptable use of our services
Facilitate payments and credit checks
LO, A, C, LI
Facilitate the restructuring or sale of all or part of our business
LO, LI, C, A
Investigate and respond to disputes
LI, LO, C
Provide you with help and support where it may be required. For example, we contact you to provide assistance if you do not complete the booking process or experience technical difficulties, where we have your contact details
Further Information on how we use your information
We sometimes use your information for reasons that we think you might want a bit more detail on, so to help we have added more information to these below.
In addition to sending you information about the products and services you use (product communications) and in-life communications while you stay with us, where we have your permission we may send you direct marketing communications about our products, services, events and offers.
Direct marketing communications may be sent by post, email, telephone, SMS and MMS, through social media (such as WhatsApp, Instagram, Twitter, and Facebook), messages including push notifications to your mobile devices, and via other electronic means such as when you visit our website.
We may send you direct marketing while you have an ongoing relationship with us and for a reasonable time after you have used one of our products or services.
You will be able to opt-out of direct marketing by following the instructions in the communications you receive or changing your device settings.
Product related communications and “in-life” updates
We may use your information to send you newsletters, bulletins, and other “in-life” communications (about your stay), and triggered communications where you make changes to your account or other information about products and services you have signed up for.
For example, we may send you email or text messages about an upcoming stay with us in order to help you plan your visit and give you the best experience possible. You’ll be able to opt-out of these.
Service communications will be sent to you regarding products and services you interact with. These are important messages relating to the products and services we provide to you.
Analysis and product development
We may use your information to improve the products and services we offer. For example, we may look at the preferences our guests have when they stay with us to offer more relevant personalisation to customers.
Detecting ad blockers
When you visit our websites, we may check (by using script, code, cookies or other technical means) if you are using ad-blocker or other privacy tools. If we do detect one of these tools, we may ask you or ask your browser to ask you if you would give us permission to ignore those settings and continue to serve adverts and/or collect your information using cookies and similar technologies.
Information about your device and use of ad blockers may be stored or associated with your device and used to reinsert adverts and to understand how ad blockers and other privacy tools are being used by our visitors.
If we provide a service that is dependent on age or residency we have an obligation to verify relevant information.
Payments and credit checks
Your information may be used to take payment for products and services and may be used to verify credit details related to payments.
Disclosures required by law
Your information will be disclosed where we are obliged by law to do so. We may also disclose your information where we are allowed by law to protect or enforce our rights or the rights of others and for the detection and prevention of crimes, such as fraud.
If you post or send offensive or inappropriate content anywhere on or to our website, or otherwise engage in disruptive behaviour on our website, we may use the information that is available to us about you to stop such behaviour. This may involve responding to or informing relevant third parties and law enforcement agencies about the content and your behaviour.
When you complete our registration details or use our services, we may transfer your information to our processors - who carry out activities on our behalf, only on our instructions. However, we will only transfer your information if we have appropriate measures in place to ensure the protection of your information in accordance with applicable data protection legislation. When you give us information about other individuals, you confirm that you have authority to act for them and have made them aware.
Training and quality
If you contact us by phone or on chat the conversation may be recorded and listened to for training and quality purposes.
Sharing with our processors
There may be situations where we use data processors – companies who act on our behalf – to process your information for us. These processors can only use your information in accordance with our instructions and for the purposes in this Policy.
Sharing with commercial partners
We may share your information with third parties for their own purposes, including direct marketing, where we have told you about this and you have given permission. As above, this may include sharing information with whom we have licensed a brand and/or property management system.
Sale of our business
If we restructure or sell all or part of our business or business operations, we may transfer your information as part of that activity, including, but not limited to, where we transfer or cease to manage (or license the use of a brand at) a property. Where this is the case your information will be used in accordance with this Policy, unless you are notified otherwise.
Access and Control
Updating your information
Please ensure you keep your information up to date by logging into your account and modifying it. Alternatively, you can tell us when you check-in that your information has changed and we will update it for you.
Controlling direct marketing
You can change your mind about receiving direct marketing from us or change your preferences by logging into your account, if you have one, opting-out in any marketing or product communication you have received from us or emailing us using the contact details below.
Controlling other communications
You can control the communications you receive from us, such as product related communications, by logging into your account, by following the instructions in any relevant communication.
Requesting copies of your information
You may request a copy of your personal information which we may hold about you. You may also ask us to correct any inaccuracies in your personal information. This right may be restricted by law where disclosing information may result in the personal information of other individuals being disclosed and it would be unreasonable to do so.
Where we may rely on consent to use your information, you have the right to withdraw that consent for that processing activity at any time. However, we may have the right to rely on an alternative legal basis for the processing activity and will inform you of that.
If you do withdraw consent we may not be able to provide you with the product or service you have requested.
You may have the right to object, erase, or restrict our processing of your information - for example, where we process your personal information because this is in our legitimate interests, you may object to this. We will carefully consider your request as there may be circumstances which require us to, or allow us to, continue processing your data.
Complaining to the regulator
If you have any comments, concerns or complaints about our uses of your information we would ask that you contact us first, so that we can try and resolve any matter. However, where we are unable to help, you are entitled to complain to the Information Commissioner’s Office in the United Kingdom or the data protection regulator in your country of residence, who will be able to liaise with the UK Information Commissioner in the UK.