Privacy Policy

Information we may collect from you

• Information that you provide by filling in forms on apartments.ehthele.com (“our site”) to use our products and services. This includes information provided when registering to use our site, subscribing to our newsletter, posting material or requesting further services, booking a room, including preferences about the room and its location, information about disabilities and dietary requirements. We may also ask you for information when you enter a competition or promotion sponsored by Ehthele Ltd., and when you report a problem with our site.
• Enquiries made when you contact our reservations team to make a booking or use the facilities at any of our properties. Facilities include, but are not limited to, meeting rooms, bars and/or restaurant, function rooms, and guest Wi-Fi.
• Records or correspondence should you contact us.
• Optional surveys we may ask you to complete that we use for research purposes.
• Details of transactions you carry out through our site and in the fulfilment of your booking.
• Information collected when you have provided your consent, in order to:
• Subscribe to any of our marketing communication.
• Complete customer surveys, enter competitions or provide feedback. Information collected when we do business with you, which will usually include: Full or partial contact details including names and addresses (including business details if you are making a corporate booking), telephone and email details.
• Details about diet, disability or any other preferences that you may have concerning special requirements. Payment card information should you choose to use this form of payment for purchasing or guaranteeing use of our products and services.
• Your birthdate and other significant dates for making special offers to you around your birthday and other anniversaries.
• Passport and/or identity details for our guests visiting from overseas.
• Information and personal data collected automatically.
• Website data collected through our site.
• We automatically log information about you and your computer or mobile device when you access our site. The information about your use of our site comprises http header information that your browser transmits to our webserver, information collected through the use of cookies and log information. For example, when visiting our site, we log your computer or mobile device operating system name and version, manufacturer and model, browser type, browser language, screen resolution, the website you visited before browsing to our site, pages you viewed, how long you spent on a page, access times and information about your use of and actions on our site.

Information and personal data collected automatically

Website data collected through our site

• We automatically log information about you and your computer or mobile device when you access our site. The information about your use of our site comprises http header information that your browser transmits to our webserver, information collected through the use of cookies and log information. For example, when visiting our site, we log your computer or mobile device operating system name and version, manufacturer and model, browser type, browser language, screen resolution, the website you visited before browsing to our site, pages you viewed, how long you spent on a page, access times and information about your use of and actions on our site.

CCTV recordings

• We operate CCTV systems. These are in operation and video recordings may be made. This activity is carried out for security and service reasons for the better management of Ehthele Private Suites and security for all its clients and staff.

How we use and store your personal information

Storage of your personal data, regardless of when or who you book Ehthele Private Suites through, will be made in:

• Centralised systems which are under the control of Ehthele Private Suites and accessible by authorised staff of Ehthele Private Suites or our suppliers, and some local systems controlled solely by Ehthele Private Suites.
• Information we collect about you is used to process your bookings, answer your queries, process your gift card purchases, provide our hotel and restaurant facilities and services, and enable you to manage your website user account. With your consent where appropriate, we will contact you via our marketing and sales channels (email/phone/post) about other related products and services we provide which we think may be of interest to you. Our marketing communications are generally sent by email but we may sometimes use other methods of delivery such as by post or SMS.

Personal data is mainly collected, stored and processed in two different stages:

Before you visit our hotel

• Our Site – When you visit our site (apartments.ehthele.com), we collect information about your use of our site. This includes both information we collect directly from you, and information we collect about your behaviour. This information may constitute ‘personal data’ under applicable law. We use this information to provide you with (personal) offers, both on our Website and via advertisements on other websites you visit.
• General Advertising – We may use other companies to serve third-party advertisements when you visit and use our site. These companies may collect and use click stream information, browser type, time and date, subject of advertisements clicked or scrolled over during your visits to our site and other websites in order to provide advertisements about goods and services likely to be of interest to you. These companies typically use tracking technologies to collect this information. Other companies’ use of their tracking technologies is subject to their own privacy policies.
• Targeted Advertising – We use our site information to provide you with (personal) offers, both on our site and via advertisements on other websites you visit. In order to serve offers and advertisements that may interest you, we may display targeted advertisements on our site, or other digital properties or applications in conjunction with our content based on information provided to us by our users and information provided to us by third parties that they have independently collected. We do not provide personal data to advertisers when you interact with an advertisement.

When you visit, or have visited Ehthele Private Suites

• Transactional Communications – When you make a reservation, you will have to provide us with your name, email address, phone number, the dates you are staying with us and a credit card token or other payment information as applicable. We use this personal data to process the reservation, for billing purposes, and to allow us to communicate with you about your reservation. When you stay in Ehthele Private Suites, we will collect personal data about your preferences, use of our services, and location.

We may at each of the stages outlined above use your personal data but only when and to the extent the law allows us to. Most commonly, we will use your personal data in the following circumstances where:

• We need to perform the contract we are about to enter into or have entered into with you.
• It is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• We need to comply with a legal or regulatory obligation.
• You have provided your consent.

Legal bases that allow for the processing of your personal data

• For your convenience, we have made an overview of activities that involve the processing of your personal data, and the corresponding legal basis/legal bases that allow us to process this data.

IP Addresses

• We may collect information about your computer, including your IP address, operating system and browser type.
• We collect this information for system administration and to report aggregate information to our advertisers.
• This is statistical data about our users’ browsing actions and patterns, and does not identify any individual.

Security

• We employ appropriate security measures to protect the loss, misuse and alteration of the information under our control.
• For the Ehthele sites, we employ Secure Sockets Layer (SSL) software, which encrypts information you input, as an additional security measure.
• Where possible, your personal data will be encrypted and stored on a virtual private server that is secured by means of state of the art protection measures
• As no online data transmission can be guaranteed to be totally secure, we (like all web sites) cannot guarantee 100% security of any information you transmit to us on our site.
• A strictly limited amount of staff has access to your personal data.

Sharing your data

We may share your personal data as follows:

• Third Parties Designated by You – We may share your personal data with third parties where you have provided your consent to do so.
• Our Third Party Service Providers – We may share your personal data with our third party service providers who provide services such as payment processing, information technology and related infrastructure provision, business support (operational and administrative), customer service, the processing and delivery of marketing communications to you, email delivery, auditing and other similar services. These third parties are only permitted to use your personal data to the extent necessary to enable them to provide their services to us. They are required to follow our express instructions and to comply with appropriate security measures to protect your personal data. Third parties are subject to confidentiality obligations and may only use your personal data to perform the necessary functions and not for other purposes.
• Affiliates – We may share some or all of your personal data with our affiliates, in which case we will require our affiliates to comply with this Privacy Statement. In particular, you may let us share personal data with our affiliates where you wish to receive marketing communications from them.
• Other Disclosures – We may share personal data as we believe necessary or appropriate:
• • To comply with applicable laws
  • To comply with lawful requests and legal process, including to respond to requests from public and government authorities to meet national security or law enforcement requirements
  • To enforce our Privacy Policy; and
  • To protect our rights, privacy, safety or property, and/or that of you or others.
• We do not share your data with any third parties outside of the above processing arrangements and we do not share your data with any business external to our group for their own marketing purposes. From the data we collect, you should only ever receive marketing communications from ourselves.
• We use Mailchimp as our marketing platform. By subscribing, you acknowledge that your information will be transferred to Mailchimp for processing.

International data transfers

• For your convenience, we have made an overview of activities that involve the processing of your personal data, and the corresponding legal basis/legal bases that allow us to process this data.

Legal bases that allow for the processing of your personal data

• In some instances, it is necessary to transfer your personal data overseas. Any transfers will be made in full compliance with all aspects of the applicable regulations.
• For many of our business purposes, we use cloud-based services. Therefore, for technical and organisational reasons, it is necessary that your personal data is transferred to servers located in the UK, or to other servers located within the EEA.
• Our email marketing provider is Mailchimp, as we send out email campaigns data is passed through Mailchimp’s servers which are located in the USA.

Your rights

You can also exercise your rights at any time by contacting us at suite@ehthele.com or by writing to us at Ehthele Ltd., 146 Strand, London WC2R 1JD, UK.

The GDPR provides the following rights for individuals:

• Right to revoke consent – If we process personal data on the basis of your consent, you have the legal right to revoke such consent at any time. We will then cease the relevant processing activity going forward.
• Right of access to your information – If you want to know what personal data we have collected or process about you, you may request us to provide a copy of your personal data by sending an email to apartments@ehthele.com We will ask you to identify yourself. We will not provide you with a copy of your personal data to the extent that the rights and freedoms of others are or may be adversely affected.
• Right to rectification and erasure of data, and restriction of processing – If you believe that our processing of your personal data is incorrect, inaccurate, unlawful, excessive, incomplete, no longer relevant, or if you think that your data is stored longer than necessary, you may ask us to change or remove such personal data or restrict such processing activity, by sending an email to suite@ehthele.com.
• Right to data portability – You have the right to receive your personal data, which you have provided to us, in a structured, commonly used and machine-readable format, in accordance with Article 20 of the General Data Protection Regulation.

Right to object – You have the legal right to object, on grounds relating to your particular personal situation, at any time to the processing of your personal data. Furthermore, you have the right to object at any time to our processing of your personal data for direct marketing purposes or to profiling. You can do this by either

• Opting out by using the option we provide in the relevant direct marketing message (e.g. an email newsletter), or
• By sending an email to suite@ehthele.com or writing to us at Ehthele Ltd., 146 Strand, London WC2R 1JD, UK
• For the sake of clarity – Without prejudice to the foregoing we are at all times entitled to send you messages that do not constitute direct marketing, i.e. service messages.
• General information relevant for all requests and queries
• Nothing in this Privacy Statement is intended to provide you with rights beyond or in addition to your rights as a data subject under applicable mandatory data protection law.

We will use reasonable endeavors to respond to your request or query within one month. We are entitled to extend this term by another two months if the complexity of the situation so requires. If your request is manifestly unfounded or excessive, we may either Charge you a fee or refuse to process your request.

• With respect to access requests, we may also charge you for extra copies. If we decide not to honour your request or answer your query, we will explain our reasons for doing so in our reply.

Protection & Storage of your data

• We have used and will continue to use reasonable endeavours to protect your personal data against loss, alteration or any form of unlawful use. Where possible, your personal data will be encrypted and stored on a virtual private server that is secured by means of state-of-the-art protection measures. A strictly limited amount of people have access to your personal data.
• 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.

Retention of information

• We will only retain your personal data for the period necessary to fulfil the purposes outlined in this Privacy Policy. This may be up to 4 years, unless a longer retention period is required or permitted by law (which is typically the case in the context of our obligations under tax law).
• Should you choose to unsubscribe from our mailing list, please note that your personal data may still be retained on our database to the extent permitted by law.

Access to information

• The Act gives you the right to access information held about you. Your right of access can be exercised in accordance with the Act.
• In order for us to provide you with details of the information we hold about you, or to enable you to correct or transfer information, you are required to complete a Data Subject Information Request form, obtained by emailing suite@ehthele.com .

Changes to our privacy policy

• Any changes we may make to our Privacy Policy in the future will be posted on this page.
• Where appropriate, we will notify you of changes to our policy by email.

Contact

If you have questions, comments or requests regarding this Privacy Policy, contact us by email at suite@ehthele.com or by writing to us at Ehthele Ltd., 146 Strand, London WC2R 1JD, UK.