The Harrington Collection is owned and controlled by Fin-Ex Property No.4 (UK) Limited. We are committed to protecting and respecting your privacy at all times in relation to our business
This policy and the terms and conditions on the website set 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. For the purpose of the Data Protection Act 1998 (the Act) Fin-Ex Property No.4 (UK) Limited acts as the data controller for The Harrington Collection.
Should you have any questions, queries or requests regarding your data in relation to The Harrington Residences please contact firstname.lastname@example.org.
1. About this document
2. Your consent
By using our websites, providing any personal data to us, or booking any stay with us whether short term or long-term, you confirm that you agree to and consent to the terms of this document, to the extent that your consent is required by any applicable law.
3. Copyright notice
All copy on our website including this document are copyrighted 2016 to Fin-Ex Property No.4 (UK) Limited.
4. About us
Fin-Ex Property No.4 (UK) Limited is registered with Companies House and fulfils its duties under all relevant legislation. Our registration number is 08551206 and we are registered at 1 Harrington Gardens, London. SW7 4JJ. We are registered with the Information Commissioner’s Office under the reference ZA131282. We comply with all relevant provisions of the Data Protection Act.
5. Contacting us
If you have any concerns about how your data is being used, our you wish to request the removal of your details from our databases please contact us at email@example.com. Should you wish to make a subject access request you can do so in writing however this will be subject to a £20 fee which is in line with ICO recommendations.
6. Our Commitment
The privacy of those that come into contact with our business is important to us. We may collect various types of personal data at different stages throughout dealings with The Harrington Residences. By reading the details below we hope that you will feel confident that we have strong privacy policies in place to make sure that the data that you do gift to us treated with respect and held in as secure a manner as possible laid out in recommendations from the ICO.
7.1 Our customers
7.2 Examples of who this policy covers
7.3 When we are data processor only
7.4 Terms used in this policy
8. What laws we comply with
We process your personal data in accordance with the following data protection law(s): The United Kingdom Data Protection Act 1998 (which covers protection of personal data generally) and The Privacy and Electronic Communications (EC Directive) Regulations 2003 of England and Wales (which covers, among other things, the use of telephone numbers, fax numbers and e-mail addresses for unsolicited direct marketing). Our regulator is the UK Information Commissioner: http://www.ico.org.uk/. We also comply generally with the laws of England and Wales in relation to the processing of your personal data, and not any other laws.
9. What types of personal data we process
This section summarizes the types of personal data about you that we process:-
9.1 Data concerning you as an individual
This includes name, age, photograph, gender, address, telephone, mobile, fax, e-mail, social networking contact details, proofs of identity and address, copies of passports, driving licences, and utility bills, card and other payment details, and financial information, results of searches carried out against you (such as to verify you identity, address, and credit status), your preferences, frequent flyer or travel partner program affiliation and member numbers, and any other information provided to us by or in relation to you which concern you as an individual.
9.2 Business Related Information
If you are an individual associated with a business or other organisation that is our customer, then your personal data may include the following information that we link to you: business or organisation details (such as name, address, telephone numbers, payment arrangements, financial information, etc.), your relationship with that business or organisation (such as owner, partner, director, shareholder, employee, or agent), and your contact details within that business (such as work address, work telephone and mobile numbers, work fax number, and work e-mail address).
9.3 Enquiry and Booking information
Information concerning enquiries and bookings made with or through us for both short-term (under 30 nights) or long-term (over 30 nights) stays, including where you are making the enquiry or booking or are the recipient of the stay to which the enquiry or booking relates. This information may include: records of enquiries and searches for serviced residence products made by or on your behalf, details of your personal interests, needs and other data relevant to your enquiry; details of results, quotes, proposals, estimates and other information given in response to enquiries; payment details (including card details); passport information and visa information; and sensitive information such as health, medical, dietary, mobility, disability, religious or other special conditions or requirements.
9.4 Performance information
Information generated concerning the performance of any booking or other contract made with or through us, including information relating to anything arising during a stay, and information relating to payments to be made.
9.5 Survey Information
Information collected or generated out of any surveys we conduct.
9.6 Competition Information
Information collected or generated out of any competitions or promotions we run.
9.7 Account, Registration and Loyalty Information
Information concerning any accounts, registrations, or memberships with us, or participation in any loyalty program.
Correspondence, communications and messages, including between you and us, and between us and third parties, including relating to any booking or booking enquiry, or performance of any contract.
9.9 Website Usage Information
We may collect information about your visits to, browsing of, and use of our website, unless your web browser blocks this. The range of data we collect will depend on how you interact with our website. This information may include: your IP address (a unique identifier allocated to your computer for your connection to the internet); your computer device details (PC, tablet, smartphone, watch etc.); the make and version of web browser (e.g. Internet Explorer, Firefox, Safari, Opera, Chrome) you are using; your operating system (e.g. Windows, Windows Phone, OSX, iOS, Android, Linux etc); your time-zone; your browser plug-ins; any web-page you came from, identified as the referrer web page address by your web browser; cookies; page response times; download error; pages and parts of pages you visit; usage you make of our website, including enquiries and searches undertaken, and registrations for accounts, forums etc.; services and products you viewed; length of visit to website and pages; page interaction information (such as scrolling, keys pressed, mouse clicks, touches, and mouse-overs).
10. How we collect or generate your personal data
This section sets out the ways in which we may collect or generate personal data concerning you.
10.1 Visiting our website
By visiting and using our website you or your computer may provide personal data. This includes: information which is automatically provided by your browser to our servers; information record on our web servers about your interaction with our website and pages viewed; information we capture or place on your computer or generate using cookies or other technologies on our website; and information you input into forms and fields on our website.
You can find this and further information about cookies at http://www.aboutcookies.org.
10.2 Data you provide
Your personal data will include data you provide (or later amend), whether: from correspondence with you; verbally to us over the phone or in person; by filing in any field or form on a website; by filling in any printed form we provide you with; by e-mail; from documents you provide use with; and from updates to any information to provide from time to time. This includes when you: register or subscribe for any service, account, members, or loyalty program, or make an enquiry or booking for a holiday or other travel services whether in person, by phone, through our website or otherwise; send us your comments or suggestions; subscribe to any newsletter or other publication; and request sales and advertising information, including brochures.
10.3 Data obtained from third parties
We may obtain personal data concerning you from third parties, including from: providers of any holidays, accommodation, other travel services which are enquired about or booked, and their intermediaries; credit, fraud, identity and other searches we may undertake, including searches with public records and regulatory and private organisations; from any business or organisation you are associated with; from telephone numbers identified by the telephone system when you telephone us.
10.4 Data generated by us
We and any suppliers or sub-contractors working for us may generate personal data relating to you, including in connection with responding to and dealing with any enquiry, booking or complaint; or in performing any booking or other contract with you; or through the analysis of your personal data or data gained from your use of our website. We will record that telephone calls have taken place between you and us and may at time record telephone calls with you. If recordings are made you will be informed during the conversation and may request these recordings at any time as part of a subject access request.
11. What do we use your personal data for?
This section sets out the uses which we make of your personal data:
11.1 Operate our website
To operate and provide the search, booking, accounts, review and other services, facilities and functions of our websites. This includes managing any accounts or registrations you have with our websites and making changes to your settings and profile at your request.
11.2 Provide information and respond to enquiries
To provide information to you about our website, systems and services, including to respond to booking enquiries and searches, and to keep you updated generally.
11.3 Bookings and other contracts
To enable you to make bookings, and to fulfill, provide, perform, administer, manage, and enforce all bookings, orders, and other contracts which relate to you (including if you are a passenger in a booking made by someone else), and to process any transactions authorised or made with us which relate to you.
To collect and make payments due and administer our accounts.
11.5 Communication with customers
To communicate with you concerning any enquiries, bookings, problems and complaints, and to respond to any submissions, enquiries or requests from you.
11.6 Record Keeping
To keep internal records and maintain reasonable archives, including concerning as to enquiries, bookings, contracts, and complaints.
11.7 Manage and Improve our business
To analyse, audit, provide, operate, administer, maintain and improve our business, website, systems, and services; to carry out surveys and analyse the results; to run promotions and competitions; undertake product or customer research/development; to assist us in and help us to improve our sales, editorial, advertising and marketing processes; to carry out other business development and improvement activities; and to provide training to our staff, sub-contractors and suppliers. For example, we may use your personal data to help us profile how our customers generally are using our websites and booking travel services with (or through) us. We may also use this information to ascertain interests so that we can better tailor our business offerings.
11.8 Direct marketing
To carry out direct marketing to you. See next section below for further information.
To report aggregate information concerning usage of our websites to our advertisers. We will normally create anonymous statistical data about browsing actions and patterns, and do not identify any individual.
11.10 Anything you have specifically consented to
For any purpose which we have obtained your consent to.
12. Use of your personal data for direct marketing
We do not use or disclose your personal data for direct marketing purposes unless we have obtained your consent to this, such as through an opt-in or opt-out tick box on any form or website of ours.
12.1 Direct marketing by us
12.2 Direct Marketing by Third Parties
Where you have consented to this, we may disclose your personal data which is contact data (such as name, e-mail, postal address, telephone, mobile or fax number) to any third parties selected by us. They will use this to carry out direct marketing in their own right and will use it to send you marketing materials, adverts and promotions relating to products and services they offer or which can be booked through them. You will be free to withdraw your consent to our disclosure of your personal data for this purpose at any time, by contacting us as detailed above. If you withdraw your consent, this will not affect any disclosures we have already made (i.e. we will not be able to remove your personal data from anyone we have disclosed it to), but we will tell you who they are on request, and you should contact them directly concerning this.
13. Disclosure of your personal data
We transfer your personal data to third parties in the following circumstances:-
13.1 Credit Checks etc.
We may disclose your personal data to third parties (including intermediaries) as necessary to carry out any checks concerning you or enforce any booking or contract with you (including credit, security, fraud and identity checks). This may include credit reference agencies and other companies for use in credit decisions, for fraud prevention and to pursue debtors.
13.2 Bookings and performance of contracts
We disclose your personal data to third parties (including intermediaries) as necessary to deal with any booking enquiry being made by or for you, to make any booking requested by or for you, to perform and administer any booking for you or other contract with or in respect of you. This may include; to apply for visas on your behalf, to collect payments to be made by you, to investigate and respond to complaints, and to enforce any booking or other contract with you. Such third parties may include any suppliers or sub-contractors and their agents (e.g. airlines, coach, ferry or train companies, hoteliers, hire companies, cruise companies, tour operators etc.).
13.3 Suppliers of travel and other services
We may disclose your personal data to any third party (e.g. supplier, contractor sub-contractor) we make any enquiries with concerning or engage or sub-contract to perform any booking or other contract, including to provide any travel, tour or other products or services we have agreed to provide to you. We may disclose your personal data to any supplier with whom we make any enquiry concerning or book any travel or other products and services for you as agent (whether as agent for you, someone representing you, or the supplier), such as a tour operator. Details of any third party tour operators or other third parties who will be responsible for or supply you with the travel services booked or enquired about, may be obtained from us on request, and may be stated in any tour or other brochure provided by us.
If any application is made through us for any travel or other insurance to cover you, we will pass your personal data on to the insurer. Information provided by you may be put on to a register of claims and shared with other insurers to prevent fraudulent claims.
13.5 Business Function Outsourcing
Where we use third parties to host, provide, operate or supply any part of our websites, databases, systems, business, or services, or carry out on our behalf any of our business functions or actions (including sending mail, processing payments, providing marketing assistance, providing customer and advertising analysis, and providing customer services), then we may provide your personal data to them as required for use for or processing as part of those purposes.
13.6 Public forums etc.
Where any facility on our website is clearly designed to make certain of your personal data public (e.g. posts you make to any public forum or reviews facility) then any personal data you provide in relation to that forum or other facility, which is provided in circumstance where it is clear that it is intended to be published, will be disclosed to the public accordingly, subject to moderation by us.
13.7 Legal requirements
We may supply personal data to a government authority or regulator where required to comply with a legal requirement, for the administration of justice, for the purposes of customs, visas and immigration, or where reasonably required to protect your vital interests or enforce any booking or other contract. We may disclose your personal data where otherwise required by or permitted by law.
13.8 Direct Marketing by third parties
We may disclose your personal data to third parties to carry out direct marketing to you, where you have given your prior consent, to third parties to carry out direct marketing. See the direct marketing section above.
13.9 Customer Representatives
If our customer is a business or organisation, and we are holding your personal data in your capacity as an associate of that business or organisation (including as agent, representative, contact, employee, officer, owner, partner, or director), then we may disclose to them that personal data. If our customer is making a booking or booking enquiry on your behalf, with your authority, then we may disclose to our customer your personal data as reasonably required in connection with such booking or enquiry, or the subsequent performance of or payment for any booking made.
13.10 Business acquirers
If our business is ever transferred to a third party, then your personal data will be transferred to the acquirer to enable them to continue our business.
14. How third parties will handle your personal data
Where we provide your personal data to a third party one of the following two circumstances will apply:-
14.1 Processing on our behalf
14.2 Processing on their own account
15. Location of your personal data
We (and any affiliate, subcontractor or other person processing your personal data on our behalf) may transfer, store and otherwise process your personal data anywhere in the world. Where we disclose your personal data to third parties, that disclosure may also involve a transfer of your personal data anywhere in the world, and those third parties may themselves transfer, store or otherwise process that information anywhere in the world. In each case, we will comply with any legal requirements concerning the transfer of your personal data by us to any third party outside the country where we are established, and where your personal data is still controlled by us or is being stored or otherwise processed on our behalf, our security measures (as detailed below) will also apply.
16. Keeping your data secure
16.1 Our security measures
16.1.1 Our general commitment
We are committed to doing what we reasonably can to keep your personal data secure, and we are obliged by law to put in place appropriate technical and organisational measures against unauthorised or unlawful processing of your personal data and against accidental loss or destruction of, or damage to, your personal data. We have accordingly implemented security policies, rules and technical measures with a view to achieving this.
16.1.2 Transmissions between your web browser and our servers
We use Secured Socket Layer (“SSL”) software in order to encrypt the personal information that you provide to us whilst it is in transit over the internet. This will work if your browser is SSL enabled (which most are). You can verify that this is working by looking for the symbol of a closed lock or solid key on the bottom bar of your browser window, and checking that the prefix for the web address in the browser address bar has changed from “http” to “https”.
16.1.3 Storage of your personal data
The personal information we collect from you online is stored by us and/or our service providers on databases protected through a combination of physical and electronic access controls, firewall technology and other reasonable security measures.
16.2 Your security measures
For your own privacy protection, we encourage you to maintain anti-virus and other malware protection software on your computers and other devices, and to maintain your own measures to protect your personal data. Please do not include sensitive personal data in any e-mails you may send to us, including payment card information. We also encourage you to be careful about who you give personal data to. We never contact you to ask you for sensitive personal data, such as payment card information, or sensitive personal data such as passport numbers or log-in details, and we will only ask you for such information in person or through our website, or by telephone in connection with a booking you are making or have made. Please let us know if you someone purports to contact you in our name.
17. How long do we keep your personal data for?
We keep your personal data for so long a is reasonably necessary for the purposes for which we use it, and if longer, for any duration required by law, and for statutory claims limitation periods where your personal data may be relevant to any possible liability we may have to you.
17.1 Deletion of your data
Should you wish your data to be removed from our system, you may request in writing for your data to be destroyed, which will be done within 21 days of receiving your written request. Your name and email will still be retained within our unsubscribe lists so that we can be assured of not contacting you again.
17.2 Deletion of your data subsequent to staying with us
If you have stayed with us, we retain the right to hold your data for a minimum of 30 calendar days subsequent to your departure date. After this period our deletion policy will revert to clause 17.1.
18. Your Rights
18.1 Access to your personal data
You may make a subject access request at any time in writing to the data controller at our registered address above. This will be subject to a £20 fee which is in line with ICO recommendations. The law does allow us, in certain cases to refuse your request, and we will advise you at the time if this is the case.
18.2 Use causing substantial distress or damage
You have the right to ask us to stop using your personal data for any purpose in any manner that is causing you or is likely to cause you unwarranted and substantial damage or distress, subject to exceptions.
18.3 Use for direct marketing
You have the right to ask us to stop using your personal data to carry out direct marketing to you.
18.4 Correction of inaccuracies
You have the right to ask a court to order us to rectify, block, erase or destroy any inaccurate personal data we hold about you. However we will do our best where possible to make sure that your records are kept up to date where you yourself cannot make the corrections.
You have the right to claim compensation for damage and (in certain cases) distress you suffer if we do not comply with the laws referred to above.
18.6 Complaints to applicable authority
The laws we comply with are regulated by the Information Commissioner (www.ico.gov.uk) in the United Kingdom. In addition to your rights above, it is open to you, if you have a complaint or concern, to seek assistance from such government regulator, who has powers to compel us to comply with applicable laws and fine us for non-compliance. However, before you do so, we would hope that you will contact us first to discuss any complaint or concerns you have.
20. Applicable Law And Disputes
This policy is subject to the law of England and Wales, and you must bring any claims against us (non) exclusively in the courts of England and Wales.