Select Apartments takes great care to preserve your privacy and safeguard any personal details you share with us. We aim to be clear when we collect your information and not do anything you wouldn’t reasonably expect. This policy explains how we collect and use your personal information. Examples of your personal information would include your name, address and email address.
Select Apartments is a serviced apartment agency, specialising in the business travel and relocation sectors. To enable us to achieve this, we hold information about our contacts within corporate client companies, suppliers of accommodation and business resources. We will also be advised of some personal data attributed to guests who are the end users of the accommodation arranged for them. This information is used to address the requirements of our corporate clients and manage the business relationship with them, to facilitate the bookings of accommodation and other services from our suppliers and to impart information related to the bookings to the guests (e.g. details of access, etc) where required.
By providing us with your personal information you are agreeing to this policy.
- using our services
- phoning us
- writing to us
- sending us an email
- sales activities
- signing up for our newsletters
- business cards provided to us by you
- networking or encounters at events
- applying for a job
How do we collect information?
We may collect information about you whenever you interact with us. For example, when you contact us to inquire regarding our services or to arrange accommodation, sign up to our newsletters, order services, open an account or engage with our social media accounts, you may specifically and knowingly provide us with your personal information.
If your employer is a client or supplier of Select Apartments, we may receive information from them to enable us to contact you on their behalf to fulfill our service agreement with them and we will only use it to contact you in your capacity as a representative of that organisation. In addition, we collect aggregated or anonymous information about the services you use and how you use them, like when you visit our website or view and interact with our content.
What information do we collect?
When you interact with us, we may ask you to provide us with your name, job title, address, email address, telephone number and areas of professional or sector interest. We would not ordinarily require you to provide us with any personal sensitive information, for example regarding your health or marital status.
If you are a guest or end-user of the accommodation we will normally receive some details about at least the lead individual in your party for administrative purposes. This may include details of special needs such as accessibility which need to be considered by us when selecting accommodation. Your details are passed on to the accommodation supplier for management of the booking.
Our client (your employer or arranger of accommodation) will pass on to you details of the accommodation booked for you which may also include details of services aimed at enhancing your stay that we offer to guests under the My Select branding; if you take up any of these offers we will collect your details with your consent in order to fulfil your requirements.
We may collect some, or all, of this information when you visit our website, depending on how you use it. We also monitor how people use our website, so we can improve it. However, you can use our website without giving us any personal information. If you visit our site anonymously, we may however still record information about:
- the areas of the website visited
- how you came to our website – e.g. through a link in an email or a search engine
- the type of device, browser, network location and internet connection used
- specific actions taken on the website, for example downloading our information resources.
We do this by using cookies, which you can learn more about in the specific section below.
If you register on our website, we may ask you to choose a password which enables you to access your account. You are responsible for keeping this password confidential and you should not share this password with anyone.
How do we use your information?
We may use your information in a number of ways and for a number of purposes including:
- To provide you with information or services that you have requested from us or that we feel may be of interest to you
- To send you service or account communications via email, for example where you place a booking for accommodation or other services, or to advise you of situations or other factors that may have impact on your booking
- To administer bookings and other services
- For internal record keeping relating to any feedback or complaints
- To contact you where you have been identified as a contact person in a client or supplier organisation (if we obtain your contact details in this way, we will only use them to contact you in your capacity as a representative of that organisation)
- To analyse and improve the operation of our website
- To comply with legal and regulatory requirements
If you provide personal data for a certain purpose, we may use the personal data in connection with the purpose for which it was provided. For instance, if you contact us by e-mail, we will use the personal data you provide to answer your question or resolve your problem and will respond to the email address from which the contact came.
We may use the information you have provided us with to contact you for marketing purposes by email if you have specifically provided your consent to for us to do so or where there is a ‘legitimate interest’ as detailed below.
We promise to make all reasonable efforts to keep your details secure and as required by law, we will never share your details with other organisations to use for their own or marketing purposes.
As of 25th May 2018, Select Apartments will operate a consent-based approach to marketing activities. From this date, all new contacts will be specifically asked whether they consent to our contacting them for marketing and information services. If they decline to consent, we will no longer contact them for marketing or information purposes.
You can withdraw your consent to be contacted by Select Apartments at any time. All of our communications provide a clear route for you to opt out and should you wish to change your communication preferences.
You can do this at any time by emailing firstname.lastname@example.org or writing to us at Select Apartments, Westbury House, 23/25 Bridge Street, Pinner, Middlesex, HA5 3HR.
Sharing of your information
Select Apartments does not share, transfer or sell personal information about any person with third parties for the purposes of marketing. Select Apartments may disclose your personal information to third parties when permitted by law including:
- with your consent
- to our suppliers in order for them to help us provide our services to you, this includes:
- our providers of accommodation and other services (including My Select options) for the administration of their supply of accommodation or other services
- third parties acting on our behalf to manage for example website, database or email broadcast
- our provider of file storage and management services if you email us directly
- our payment services provider, to process your payment
- the companies we engage to operate our email broadcasts, customer relationship management system and central business management systems
Select Apartments requires all suppliers with access to personal information collected or maintained by Select Apartments to demonstrate compliance with the relevant legislation.
- if we are under a duty to disclose or share your information in order to comply with any legal obligation, or in order to enforce or apply our Terms and other agreements; or to protect our rights, property, or safety, our users, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
Holding and storing your information
- We retain personal information we collect from you where we have an ongoing legitimate business need to do so, for example, to provide you with a service you have requested, meet contractual agreements, or to comply with applicable legal, tax or accounting requirements. All information is stored on the secure servers of our provider of file storage and management services or, where hard copy, in secure locked filing facilities. From our understanding of the GDPR regulations the data we hold would be a ‘low risk’ in relation to our contacts.
- We (through global third parties acting on our behalf to manage for example website, database, email broadcast or events registration) may also store or process information that we collect about you in countries outside the European Economic Area.
Select Apartments requires all administration and service suppliers with access to personal information collected or maintained by us to demonstrate contracted robust compliance with the relevant legislation and to provide us details of any security breach in a timely manner so that we can inform our contacts within the prescribed timeframe.
- Select Apartments will use all reasonable endeavours to ensure that all personally identifiable information relating to Select Apartments and received via the Internet or stored within our systems or physically on our premises is secure against unauthorised access.
We have in place technical and organisational security measures to prevent the loss or unauthorised access of your personal information. However, whilst we have used our best efforts to ensure the security of your data, please be aware that we cannot guarantee the security of information transmitted over the Internet.
If you have any questions about security, please contact us.
Consent and Legitimate Interests
Where we need your specific consent, we will always ensure that you are as fully informed as possible at the time on what we do with your information, with whom it may be shared and how long we will keep it. This is in line with the requirements of the relevant legislation. You can alter your preferences or withdraw your consent at any time as described below.
Whilst we must gain your consent to send emails to you if we have had no prior interaction with you, as required by Privacy and Electronic Communications Regulations, we can rely on Legitimate Interests to process personal data of contacts with whom there exists a relationship without requiring further consent so long as there is a balanced legitimate interest.
A Legitimate Interests Assessment has been carried out by Select Apartments and it is established that there is a balanced Legitimate Interest in place with regard to those employees of client organisations or supplier organisations, sole traders and other contacts with whom Select Apartments has had an existing business relationship, prior to 25th May 2018 so that we may continue to process this data without the further or renewed consent of the data subject, who may withdraw consent at any time by contacting us.
Job applicants and current and former employees
If you apply to work at Select Apartments, we will only use the information you give us to process your application and to monitor recruitment statistics. If we want to disclose information to someone outside of Select Apartments, for example if we need a reference, we will make sure we tell you beforehand, unless we are required to disclose this information by law.
If you apply for a job opportunity we will also collect information that will enable us to assess your suitability for the role. There is no automated process for selection of candidates.
If you are unsuccessful in your job application, we will hold your personal information for a maximum of six months after we’ve finished recruiting the post you applied for. After this date we will destroy or delete your information.
If you begin employment with us, we will put together a file about your employment. We keep the information in this file secure and will only use it for matters that apply directly to your employment.
Once you stop working for us, we will keep this file according to our record retention guidelines. You can contact us to find out more about this.
Your rights with regard to your personal data held by Select Apartments
You have a right to ask us to stop processing your personal information, and if it’s not necessary for the purpose you provided it to us for (e.g. to engage as a consumer of our agency services for accommodation or other services or as a supplier of accommodation services or other services) we will do so. Contact us by emailing us at email@example.com or writing to us at Select Apartments, Westbury House, 23/25 Bridge Street, Pinner, Middlesex, HA5 3HR. if you have any concerns.
You have a right to ask for copies of the personal information we hold about you, and details of how we use that information. If there are any discrepancies in the information we provide, please let us know and we will correct them.
You can also update your personal information or change your preferences for communications by emailing firstname.lastname@example.org or writing to us at Select Apartments, Westbury House, 23/25 Bridge Street, Pinner, Middlesex, HA5 3HR.
You have a right to be ‘forgotten’ by Select Apartments. This will involve us identifying and deleting or anonymising all data held by us about you and any suppliers we use to provide services to you and process our data, where this does not affect our ability to comply with applicable legal, tax or accounting requirements.
Select Apartments will not retain your personal information longer than necessary and will determine if there is no ongoing legitimate business need to process your personal information. If you work for a client or supplier organisation and we are informed by your employer that you no longer work for the company, or if mail is returned to that effect or there are two consecutive hard email bounces, we will either delete or anonymise your personal data. If you are a sole trader or individual, if mail is returned or there are two consecutive hard email bounces, or you do not open any emails for a period of 12 months we will contact you to request consent to continue to hold and process your information and subsequently, as appropriate, we will either delete or anonymise it.
If you are an end-user of the accommodation or other services whose information has been passed to us by our client who is acting on your behalf or you have submitted in order to benefit from the My Select programme, we will retain your information for period of no longer than six weeks following your departure from the accommodation or, in the case of any complaints or issues for as long as is necessary for the issue to be resolved.
Where deletion or anonymisation is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion or anonymisation is possible.
In relation to all of these rights, please contact us in the first instance, outlining your specific request. We will then advise you of the process. This will, as a minimum, involve you supplying us with proof of your identity to ensure that we only provide personal information to the right person.
We will always acknowledge your request within 5 working days and respond as fully as possible within one month of receipt. Where the request is complex we will always seek to fully respond within two months. We reserve the right to charge a fee for unfounded and excessive requests.
In certain circumstances (e.g. where required or permitted by law) we might not be able to provide you with access to some of your personal information, but where appropriate we will notify you of the reasons for this.
You have a right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority
Payment card information
If you use your credit or debit card to pay for example for an accommodation booking, we will ensure that this is done securely through a specialist third party ‘payment gateway’ in accordance with the Payment Card Industry Data Security Standard. You can find out more information about PCI DSS at https://www.pcisecuritystandards.org/pci_security/.
Our online ‘payment gateway’ provides a direct connection to a payment service provided by a bank. This means that your information goes directly to the bank and the bank passes your payment to us. Hence your payment card information is handled by the bank and not processed or held by us.
We use SagePay as our payment gateway and you can find out more about this at https://www.sagepay.co.uk.
Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work more efficiently as well as to provide information to the owners of the site.
We use a Google Analytics cookie on our website to record website usage. We do this to find out things such as the number of visitors to the various parts of the site. We collect this information in a way which does not identify anyone, we do not make any attempt to find out the identities of those visiting our website, and we do not share this information with anyone.
Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.aboutcookies.org or www.allaboutcookies.org.
To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout.
You can choose to block the cookies; however, you must be aware that doing so may mean that parts of the site will not work correctly.
Contacting Select Apartments
The Data Controller for Select Apartments is Simon Morrison, Managing Director.
FAO: Data Controller
Westbury House, 23/25 Bridge Street,
Pinner, Middlesex, HA5 3HR
Tel: 0845 055 6352
By continuing to use our website and carry out business with us you will be deemed to have accepted such changes.
This policy was last updated on 21st May 2018.