PRIVACY POLICY

This Privacy Policy will help you understand what data we collect, why we collect it, and what we do with it.

1. INTRODUCTION

1.1 We are committed to safeguarding the privacy of our website visitors.

1.2 This policy applies where we are acting as a data controller with respect to the personal data of our website visitors; in other words, where we determine the purposes and means of the processing of that personal data.

1.3 We will ask you to consent to our use of cookies in accordance with the terms of this policy when you first visit our website. OR By using our website and agreeing to this policy, you consent to our use of cookies in accordance with the terms of this policy.

1.4 Our website incorporates privacy controls which affect how we will process your personal data. By using the privacy controls, you can specify whether you would like to receive direct marketing communications and limit the publication of your information.

1.5 In this policy, “we”, “us” and “our” refer to, Data Protection Officer. For more information about us, see Section 13.

2. HOW WE USE YOUR PERSONAL DATA

Unless you voluntarily submit your information to us by completing an enquiry form or using our services, we will be unable to personally identify you.

2.1 In this Section 3 we have set out:

(a) the general categories of personal data that we may process; are name, address, email address, telephone number, company and other data that could directly or indirectly identify you.

(b) the purposes for which we may process personal data; and

(c) the legal bases of the processing.

2.2 We may process data about your use of our website and services (“usage data“). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is consent OR our legitimate interests, namely monitoring and improving our website and services. Third party services such as Google Analytics are used to collect standard internet log information and compile reports using details of visitors behaviour to improve our website. We also utilise WordPress.com which is run by Automattic Inc to publish our website who could collect anonymous information about our site visitors. These third parties collect information to inform our research and marketing decisions such as the pages you visit, how long you spend on each page, how you got to the site, and what you click on while visiting the site.

2.3 We may process your information included in your personal profile on our website (“profile data“). The profile data may include your name, address, telephone number, email address, profile pictures, gender, date of birth, relationship status, interests and hobbies, educational details and employment details. The profile data may be processed for the purposes of enabling and monitoring your use of our website and services. The legal basis for this processing is consent OR our legitimate interests, namely the proper administration of our website and business OR the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

2.4 We may process information that you post for publication on our website or through our services (“publication data“). The publication data may be processed for the purposes of enabling such publication and administering our website and services. The legal basis for this processing is consent OR our legitimate interests, namely the proper administration of our website and business OR the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

2.5 We may process information contained in any enquiry you submit to us regarding goods and/or services (“enquiry data“). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is consent.

2.6 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data“). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent OR the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

2.7 We may process information contained in or relating to any communication that you send to us (“correspondence data“). The correspondence data may include [the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.

2.8  We may process personal contact details. This data may include name, email telephone number. The source of this data is Linkedin, Newsletter broadcasts, Networking. This data may be processed for long-term nurture with your initial consent. The legal basis for this processing is consent OR our legitimate interests, namely OR the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

2.9  We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely [the protection and assertion of our legal rights, your legal rights and the legal rights of others.

2.10  We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.

2.11  In addition to the specific purposes for which we may process your personal data set out in this Section 3, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

2.12  Please do not supply any other person’s personal data to us, unless we prompt you to do so.

3. PROVIDING YOUR PERSONAL DATA TO OTHERS

3.1 We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.

3.2 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

4. WE MAY DISCLOSE YOUR ENQUIRY DATA

to one or more of those selected third party suppliers of goods and services identified on our website for the purpose of enabling them to contact you so that they can offer, market and sell to you relevant goods and/or services. Each such third party will act as a data controller in relation to the enquiry data that we supply to it; and upon contacting you, each such third party will supply to you a copy of its own privacy policy, which will govern that third party’s use of your personal data.

4.1 In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

5. INTERNATIONAL TRANSFERS OF YOUR PERSONAL DATA

5.1 In this Section 5, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).

5.2 We and our other group companies have offices and facilities in India and Gibraltar. The European Commission has made an “adequacy decision” with respect to the data protection laws of each of these countries. Transfers to each of these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission, a copy of which can be obtained from here.

5.3 The hosting facilities for our website are situated in USA and India. The European Commission has made an “adequacy decision” with respect to the data protection laws of each of these countries. Transfers to each of these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission, a copy of which you can obtain from here.

5.4 You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.

6. RETAINING AND DELETING PERSONAL DATA

6.1 This Section 6 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

6.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

6.3 We will retain your personal data as follows:

(a) Name, Email and Phone will be retained for a minimum period of 1 month following 25th May 2018, and for a maximum period of 6 years following 25th May 2018. Depending on the level of involvement with the Company.

6.4 In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the following criteria:

(a) the period of retention of a name, email, a phone number will be determined based on company communications.

(b) If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by writing to us or emailing info@ecohotels.global 

(c) We retain information for all active clients and site visitors until a request for deletion or anonymisation has been received subject to exceptions if there is an unresolved issue on the account (for example an unpaid invoice), for genuine business interests including fraud prevention and if we are required to by relevant laws.

7.   AMENDMENTS

7.1 We may update this policy from time to time by publishing a new version on our website.

7.2 You should check this page occasionally to ensure you are happy with any changes to this policy.

7.3 We may notify you of changes to this policy [by email or through the private messaging system on our website.

8.   YOUR RIGHTS

8.1 You may instruct us to provide you with any personal information we hold about you.

(b) the supply of appropriate evidence of your identity [(for this purpose, we will usually accept a photocopy of your passport certified by a solicitor or bank plus an original copy of a utility bill showing your current address).

8.2 We may withhold personal information that you request to the extent permitted by law.

8.3 You may instruct us at any time not to process your personal information for marketing purposes.

8.4 In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt out of the use of your personal information for marketing purposes.

OR

9.   YOUR RIGHTS

9.1 In this Section 8, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

9.2 Your principal rights under data protection law are:

(a) the right to access;

(b) the right to rectification;

(c) the right to erasure;

(d) the right to restrict processing;

(e) the right to object to processing;

(f) the right to data portability;

(g) the right to complain to a supervisory authority; and

(h) the right to withdraw consent.

9.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.

9.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.

9.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: [the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed]. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: [for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims].

9.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

9.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.

9.8 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.

9.9 You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

9.10  To the extent that the legal basis for our processing of your personal data is:

(a) consent; or

(b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.

9.11  If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.

9.12  To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

9.13  You may exercise any of your rights in relation to your personal data by written notice to us

COOKIES POLICY

Last Updated: May 2018.

IMPORTANT NOTICE: PLEASE READ CAREFULLY BEFORE USING THIS WEBSITE:

This policy explains how cookies are used on this website. The policy may be amended from time to time. When we do, we will let you know by appropriate means such as by posting the revised policy on this page with a new “Last Updated” date. By using this site you agree to the placement of cookies on your computer in accordance with the terms of this policy. If you do not wish to accept cookies from this site please either disable cookies or refrain from using this site.

1. WHAT ARE COOKIES?

A cookie is a text-only string of information that a website transfers to the cookie file of the browser on your computer’s hard disk so that the website can recognise you when you revisit and remember certain information about you. This can include which pages you have visited, choices you have made from menus, any specific information you have entered into forms and the time and date of your visit.

2. TYPES OF COOKIES

There are two main types of cookies:

  • Session cookies: these are temporary cookies that expire at the end of a browser session; that is, when you leave the site. Session cookies allow the website to recognise you as you navigate between pages during a single browser session and allow you to use the website most efficiently. For example, session cookies enable a website to remember that a user has placed items in an online shopping basket.
  • Persistent cookies: in contrast to session cookies, persistent cookies are stored on your equipment between browsing sessions until expiry or deletion. They, therefore, enable the website to “recognise” you on your return, remember your preferences, and tailor services to you.

In addition to session cookies and persistent cookies, there may be other cookies which are set by the website which you have chosen to visit, such as this website, in order to provide us or third parties with information.

3. OUR USE OF COOKIES

We currently use and may use in the future, the following types of cookies on this website.

We use session cookies to:

  • help us maintain security and verify your details whilst you use the website as you navigate from page to page, which enables you to avoid having to re-enter your details each time you enter a new page.

We use persistent cookies to:

  • help us recognise you as a unique user when you return to our website so that you do not have to input your details multiple times as you move between our pages or services
  • remember how you have customised your use of this site, such as your preferred currency and time zone
  • collect and compile anonymous, aggregated information for statistical and evaluation purposes to help us understand how users use the website and help us improve the structure of our website.

Many cookies are designed to give you optimal usage of the web. For example, we use cookies to enable you to improve your user experience when using our website, e.g. a cookie which recognises if your browser supports specific technology features. This helps, for example, in enabling web pages to be loaded more quickly when you request the download of a large file.

In addition to cookies which send information to us, we also use cookies which collect information and send it to third parties. An example of this is Google Analytics. We use Google Analytics to help collect and compile information like the number of visitors to the site, where visitors have come to the site from and the pages they visited. Visit Google’s site for an overview of privacy at Google and information on how to opt out of the Google Analytics cookie. Where this site allows such cookies to be set or you access other websites from this site using the links provided, the operators of these websites will use cookies in accordance with their own cookies policy, which may differ from ours.

As with first-party cookies, you are able to block third-party cookies through your browser settings.

Some of our cookies may collect and store your personal information, such as your name or email address. We are committed to respecting and protecting your privacy and will ensure that all personal information collected by us is kept and treated in accordance with our privacy policy. A link to this policy is available in the footer of this portal or alternatively at our website.

4. REFUSING COOKIES ON THIS SITE

Most browsers are initially set to accept cookies. However, you have the ability to disable cookies if you wish, generally through changing your internet software browsing settings. It may also be possible to configure your browser settings to enable acceptance of specific cookies or to notify you each time a new cookie is about to be stored on your computer enabling you to decide whether to accept or reject the cookie. To manage your use of cookies there are various resources available to you, for example, the “Help” section on your browser may assist you. You can also disable or delete the stored data used by technology similar to cookies, such as Local Shared Objects or Flash cookies, by managing your browser’s “add-on settings” or visiting the website of its manufacturer. As our cookies allow you to access some of our website’s features we recommend that you leave cookies enabled. Otherwise, if cookies are disabled, it may mean that you experience reduced functionality or will be prevented from using this site altogether.

5. COOKIES USED BY OUR SERVICE PROVIDERS

5.1  Our service providers use cookies and those cookies may be stored on your computer when you visit our website.

5.2  We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google’s privacy policy is available at: https://www.google.com/policies/privacy/.

5.3 We publish Google AdSense interest-based advertisements on our website. These are tailored by Google to reflect your interests. To determine your interests, Google will track your behaviour on our website and on other websites across the web using cookies. OR [We publish Google AdSense advertisements on our website. To determine your interests, Google will track your behaviour on our website and on other websites across the web using cookies. This behaviour tracking allows Google to tailor the advertisements that you see on other websites to reflect your interests (but we do not publish interest-based advertisements on our website).] You can view, delete or add interest categories associated with your browser by visiting: https://adssettings.google.com. You can also opt out of the AdSense partner network cookie using those settings or using the Network Advertising Initiative’s multi-cookie opt-out mechanism at: http://optout.networkadvertising.org. However, these opt-out mechanisms themselves use cookies, and if you clear the cookies from your browser your opt-out will not be maintained. To ensure that an opt-out is maintained in respect of a particular browser, you may wish to consider using the Google browser plug-ins available at: https://support.google.com/ads/answer/7395996.

6. MANAGING COOKIES

6.1Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can h, however, obtain up-to-date information about blocking and deleting cookies via these links:

(a) For Chrome click HERE

(b) For Firefox click HERE

(c) For Opera click HERE

(d) For Internet Explorer click HERE

(e) For Safari click HERE (Safari)

(f) For Edge click HERE

6.2  Blocking all cookies will have a negative impact upon the usability of many websites.

6.3  If you block cookies, you will not be able to use all the features on our website.

7. OUR DETAILS

7.1  This website is owned and operated by Eco Hotels UK Plc

7.2  We are registered in England and Wales under registration number 06584439, and our registered office is at 16 Berkeley Street, Mayfair, London, W1J 8DZ.

7.3 Our principal place of business is at as above.

7.4  You can contact us:

(a) by post, to the postal address given above;

(b) using our website contact form;

(c) by telephone, on the contact number published on our website from time to time; or

(d) by email, using the email address published on our website from time to time.

8. DATA PROTECTION OFFICER

8.1   Our data protection officer contact details are Himanil Bose, himanil@pointmarketing.co, 020 3907 3833.