The Serviced Apartment Limited (www.theservicedapartmentgroup.com and www.facultyapartments.co.uk ) recognise the importance of protecting the privacy of certain general information (“data”) and specific personal information (“Personal Data”) collected about our customers (referred to as “Customers”, “you”, or “your”) and consequently respect your privacy. This privacy statement discloses what information we gather, how we use it, and how to correct or change it. At TSAG, it is our intention to give you an understanding about how we collect your information and the use we make of it in the course of our business.
TSAG has reviewed its policies, processes, procedures and practices to ensure that they meet legislation introduced within the European Economic Area (EEA), which includes the European Union (EU), in line with the EU Data Protection Directive (95/46/EC) and the EU Telecommunications Data Protection Directive (97/66EC) (“the Directives”), and in accordance with UK implementing legislation such as the Data Protection Act 1998, the Telecommunications (Data Protection and Privacy) (Direct Marketing) Regulations 1998, the Regulation of Investigatory Powers Act 2000 and the Telecommunications (Lawful Business Practice) (Interception of Communications) Regulations 2000, and we will continue to ensure that our policies, processes, procedures and practices comply in all respects with any future laws and regulations in relation to your privacy.
The purpose of this document is to inform you of the policies that have been put in place to protect your interests in this respect.
- Fair and lawful information-handling
- Legitimate purposes
We will only collect, record, process and store data which are needed to fulfil our contractual obligations towards our Customers and Property Owners.
- Data quality
We will employ effective procedures and safeguards to ensure that data we hold on you are adequate, relevant and not excessive in relation to the purposes for which they were obtained, as well as accurate and up-to-date. Where we become aware of any inaccuracies in data we hold, we will correct and, where appropriate, delete incorrect data.
Retention periods are in place to ensure that data are only stored whilst they are required for the purposes in question or to meet legal and regulatory requirements. Where data are no longer required, we will ensure that they are disposed off in a secure manner.
- Information to you
When we collect data from you, we will identify ourselves and inform you of the purpose(s) for which we are collecting data.
- Special restrictions on the use of sensitive data
We will not normally seek data on your racial or ethnic origins, political opinions, religious or other beliefs, trade-union membership, physical or mental health, sex life or criminal convictions. When we do collect such data, it will be limited to data which are:
required to be kept by law
- needed for legal proceedings or to establish, exercise or defend legal rights (including protection against fraud);
- clearly and strictly necessary to fulfil a contract between you and us (or between you and a company we represent); or
needed to protect your vital interests or the vital interests of another person (for instance, if medical data are urgently required after an accident and you cannot give your consent).
- Your rights
You have the right to require us to cease the communication of advertising or marketing materials to you, and we will ensure that your request is complied with. This includes the right to withdraw your consent to third-party direct-marketing use of your data at any time.You have the right to see all data that we hold on you. Should you wish to have access to all or a particular part of your data, please contact us at The Serviced Apartment Group, 2 Suffolk Court, Suffolk Place, Cheltenham, GL50 2QG. Such access will be granted in accordance with the requirements of applicable national legislation and subject to any discretionary allowance for HP to make a charge payable by you to cover TSAG’s administration costs incurred in providing you with such data. Such payment is to be made on application for access to your data and is to be no more than the maximum stipulated by applicable national legislation. The information will be forwarded to you within an appropriate period of time in accordance with applicable national legislation, but in any event no more than 40 days from the date of such request for access.Where any discrepancies are discovered following your enquiry, we will take immediate steps to validate and, where appropriate, correct our records. We will confirm the actions taken in writing to you within an appropriate period of time in accordance with applicable national legislation, but in any event no more than 40 days after receiving your request to amend our records.
- Direct marketing
We may market to you directly through any media to keep you informed of further offers which may be of interest to you (unless you write to us asking us to exclude you from such offers or alternatively telephone or e-mail us to that effect or you have done so previously and such exclusion is still operative) and for our own administration, market analyses and operational reviews. (If you use more than one e-mail address to communicate with us, please notify us of each e-mail account you use.)We may make contact with you by post, e-mail or telephone, for the purposes set out herein (unless you notify us either in writing or by telephone or e-mail that you object to being contacted in a particular stated way). (If you use more than one e-mail address to communicate with us, please notify us of each e-mail account you use.)We will always act according to your wishes and preferences. Whenever we directly market to you by telephone or email, we will comply beforehand with the requirements of applicable national legislation under and by which you have recorded your desire not to be contacted by telephone and/or email, as the case may be, for the purposes of direct marketing by any organisation. If you have notified such desire according to the laws of your country of domicile, then we will not call you unless you subsequently notify us directly (either in writing, or by telephone or e-mail) that this no longer applies.
TSAG is the sole controller in the EEA/EU Member States of all data held in relation to your use of our Web sites and all processing of data relating to your requirements and requests is therefore subject to and in accordance with the EU Directives and subject additionally to the data protection laws and regulations of your country of domicile. If no such laws and regulations exist in your country of domicile, then all processing of data relating to your requirements and requests is subject to United Kingdom data protection laws and regulations only. Where any local country’s laws and regulations relating to data protection and privacy conflict with or are inconsistent with the EU Directives, then the EU Directives shall prevail.
TSAG gathers two types of information about Customers: data that Customers provide through optional, voluntary registration on our Web sites; and data TSAG gathers through aggregated tracking, mainly by tallying page views throughout our Web sites. Such information enables us to tailor our content to fit Customers’ needs better and to help market our services and to understand our audience.
- How does TSAG collect information?
We collect data by specifically requesting it from you. Generally, this occurs when you register at one of our Web sites or request information or a service. For example, we may need to know your name, e-mail address, mailing address and contact telephone number, facsimile number and other related information. This allows us to process and fulfil your requirements and requests. Usually, the TSAG Web sites use your data to operate the Web sites and to deliver services.We will maintain records relating to your use of our Web sites (including information about you provided by yourself ). We shall be entitled to process those data for the purpose of providing your requirements and requests, for TSAG’s own administration, market analyses and operational reviews, and to keep you informed of further aspects of TSAG and its operation which may be of interest (unless you write to us asking us to exclude you from such further contact or alternatively telephone or e-mail us to that effect or you have done so previously and such exclusion is still operative). (If you use more than one e-mail address to communicate with us, please notify us of each e-mail account you use.)Usage tracking
Use of Internet Protocol (“IP”) Addresses
- With whom does TSAG share my information?
- How can you control the usage of information?
In the event that you change your mind or some Personal Data changes (such as your e-mail address), we will provide a way to correct, update or remove the Personal Data that you give us. We do not pass on any data to any third parties (with exception of rules applied in above paragraph). If a Customer wishes to update Personal Data or objects to any usage provided herein for any reason, he/she may e-mail the requested change.You are entitled to receive a copy of any data held by us on you in accordance with the requirements of applicable national legislation. The information will be forwarded to you within an appropriate period of time in accordance with applicable national legislation, but in any event no more than 40 days from the date of such request for access.Where any discrepancies are discovered following your enquiry, we will take immediate steps to validate and, where appropriate, correct our records. We will confirm the actions taken in writing to you within an appropriate period of time in accordance with applicable national legislation, but in any event no more than 40 days after receiving your request to amend our records.
- What happens when you link to a third party Web site?
You should be aware that when you are on TSAG ‘s Web sites you could hyperlink or be directed to other Web sites that are beyond our control and/or outside our service. For example, if you “click” on a banner advertisement or an TSAG Web site search result, the “click” may transfer you off the HP Web site. .These other Web sites may send their own cookies to Customers, and collect or solicit data and Personal Data.TSAG do not control such third party Web sites and, therefore, are not responsible for their content or the hyperlinks or advertising they choose to place on such Web sites. TSAG’s inclusion of hyperlinks to these third party Web sites does not imply any endorsement of the material on such Web sites or any association with their operators. TSAG’s policy does not extend to anything that is inherent in the operation of the Internet, which is beyond TSAG’s control.Please keep in mind that whenever you give out information on-line (for example, via message or bulletin boards or chat rooms) that information can be collected and used by people you do not know. While TSAG strive to protect their Customers’ data and Personal Data, as well as privacy, we cannot guarantee the security of any information you disclose on-line, and you disclose such information at your own risk.We will not send you e-mails that you do not want, but we cannot guarantee that Providers, or other third parties authorised by us, to whom your details are sent will not do so.
- Is my information secure from others using the TSAG Web sites?