You may be asked to provide personal data whilst you are in contact with us. Personal data is information that can be used to identify or contact you. You do not have to provide the personal data that we request, however, if you choose not to, we may not be able to provide you with the services that you have requested.
If we combine personal data with non-personal data, the combined information will be treated as personal data for as long as it remains combined. Personal data does not include data where the identity has been removed (anonymous data).
For the purpose of the General Data Protection Regulations ((EU) 2016/679) and any national implementing laws, regulations and secondary legislation and the Data Protection Act 1998 (“Data Protection Legislation”) the data controller is Supercity Aparthotels Ltd a company registered in England and Wales with company registration number 10723082 whose registered office is at 20-26 Rosebery Avenue, London, EC1R 4SX. Our main trading address is at 4 Norwich Street, London EC4A 1JS. Our Data Protection Registration Number is ZA445300.
Information we may collect from you and how we use it
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
- Financial Data includes bank account and payment card details (type, number, name on card, expiry date and CCV code). The financial data may be processed for the purposesof processing your booking (namely managing payments for accommodation bookings and charges and collecting monies). The legal basis for this processing is the performance of a contract and our legitimate interests (namely to recover debts due).
- Transaction Data includes details about payments from you and other details about accommodation you have booked with us. The transaction data may be processed for the purpose of processing your booking. The legal basis for this processing is the performance of a contract and our legitimate interests (namely our interest in the proper administration of our site and business).
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this site. The technical data may be processed for the purpose of administering and protecting our business and site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) and to deliver relevant website content. The legal basis for this processing is our legitimate interests (namely to grow our business and to inform our marketing strategy).
- Usage Data includes information about how you use our site, accommodation and services, which may include CCTV video footage. This usage data may be processed for the purposes of enabling you to complete a survey, to deliver relevant website content to you, to use data analytics to improve our website, marketing, customer relationships and experiences, for health and safety purposes and to make suggestions and recommendations to you about accommodation, services and information that may be of interest to you. The legal basis for this processing is the performance of a contract and our legitimate interests (namely to study how our site and accommodation is used and to grow our business and to keep our site updated and relevant). f
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences. The marketing and communications data may be processed for the purposes of sending you the relevant offers, discount codes, notifications and/or newsletters. The legal basis for this processing is consent.
In addition to the specific purposes for which we may process your personal data set above, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation, judicial proceedings, a court order or other legal process to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
Special Categories of Personal Data includes details about your information about your health. We may collect information about any disabilities (a Special Category of Personal Data) you have for the purpose of providing suitable accommodation to you. The legal basis for this processing is consent.
We do not collect information about criminal convictions and offences.
We may also provide you with information about accommodation, offers and services that are similar to those that you have already received or we feel may interest you. If you:
- have already concluded a contract with us (e.g. you have previously booked accommodation with us), we will only contact you by electronic means (email or text) with information about accommodation, offers and services similar to those which were the subject of a previous contract. If you do not want to be on our mailing list, you can opt out at any time by contacting us or unsubscribing by using the links provided in our electronic communications and at the point of providing your details.
- are a potential new customer (e.g. enquiring about accommodation), we will contact you by electronic means only if you have provided your explicit consent to this. If you are happy for us to use your personal data in this way, please tick the relevant box situated on the website page on which we collect your details. Again, if you do not want us to use your data in this way, you can opt out at any time by contacting us or unsubscribing by using the links provided in our electronic communications.
How is your personal data collected
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms (either online or in person when visiting our accommodation) or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- book accommodation;
- enquire about accommodation;
- subscribe to our email newsletter;
- complete a Check-In Form;
- sign in to our WIFI portal for complementary internet;
- request marketing to be sent to you;
- request a call back;
- enter a competition; or
- give us some feedback.
- Automated technologies or interactions. As you interact with our site, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.
- Third parties or publicly available sources. We may receive personal data about you from various third parties which include:
- Technical Data from analytics providers such as Google based outside the EU; and
- Contact, Financial and Transaction Data from providers of social media technical, payment and delivery services (which includes entering competitions through social media platforms).
Where we store your personal data
Some of the third parties which we work closely with are based outside of the European Economic Area (“EEA”) so their processing of your personal data will involve a transfer of data outside of the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- we will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission;
- where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe;
- where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
Change of purpose
Disclosure of your information
You agree that we may disclose your information (including personal data) to the following categories of third parties:
- suppliers and sub-contractors for the performance of any contract we enter into with them or you;
- online booking service providers (which includes Revmac Ltd (trading as Avvio)) and third party payment service providers;
- analytics and search engine providers that assist us in the improvement and optimisation of our site; and
- data storage providers, in connection with cloud storage and file hosting services.
Your personal data will not be shared with third parties for third party marketing purposes.
We may disclose your personal data to third parties:
- where we have your consent to do so;
- to process your payment for the accommodation;
- to provide and/or improve our services;
- in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
- if Supercity Aparthotels Ltd or substantially all of our assets are acquired by a third party, in which case personal data held by us about you will be one of the transferred assets; and
- if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or to protect the rights of Supercity Aparthotels Ltd, our customers, guests or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
Under Data Protection Legislation, in certain circumstances you have the following rights in relation to your personal data:
- Right to access. You have the right to request access to information held about you. We will provide you with a copy of your personal data held by us free of charge (providing your request is not excessive or for multiple copies, in which case we may charge a reasonable fee to cover our costs) and certain information about the processing of your personal data and the source of such data (if not directly collected from you by us). You also have the right to request that your personal data is transferred to a third party.
- Right to object to data processing. You may withdraw your consent to the processing of your personal data at any time by contacting us or ticking a box to opt out of receiving marketing materials. Upon receipt of your notification, we shall promptly stop any processing of your personal data and (if requested by you) erase such information if we are not required to retain it for legitimate business or legal purposes.
- Right to restrict processing. You may ask us to suspend the processing of your personal data in the following circumstances:
- if you do not think your personal data is accurate;
- where we are found to be processing unlawfully but you do not want us to erase your personal data;
- where you need us to continue holding your personal data to establish, exercise or defend legal claims; or
- you have objected to our use of your personal data but we need to verify whether we have overriding legitimate grounds to use it.
- Right of rectification and right of erasure. You have the right to request that we correct or erase any inaccuracies in your personal data if such information would be incomplete, inaccurate or processed unlawfully.
Where we are relying on consent to process your personal data, you may withdraw consent at any time. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.
You can also exercise these rights at any time by contacting us at email@example.com. We may reject requests that are unreasonable or require disproportionate effort (for example, such a request would result in a fundamental change to our existing practice) or risk the privacy of others.
Our site may, from time to time, contain links to and from third party websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Personal data retention
We may retain information about you, including personal data, for the period necessary to fulfil the purposes for which it was first collected unless a longer retention period is required or permitted by law.
In determining data retention periods, we take into considerations contractual obligations, legal obligations and the expectation and requirements of our customers. When personal data is no longer needed, we will securely delete or destroy it.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
If you have any cause for complaint about our use of your personal data, please contact us using the details provided above and we will do our best to solve the problem for you. If we are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office (www.ico.org).
Last updated: 14 June 2018