'We look after people'... and your personal data!
1.1. What does it all mean?
1.2. How we might collect your personal data
1.3. What data might we need?
1.4. How and why we use your personal data
1.5. Tracking Technologies
1.6. Links to other websites
1.7. Sharing your personal data
1.8. Transfer of personal data to countries outside of the EEA
1.9. How long your personal data is kept for
2.0. Your rights regarding your personal data
1.1. WHAT DOES IT ALL MEAN?
The UK’s Data Protection Act 2018 and the EU GDPR (General Data Protection Regulation) on data protection set out a number of different reasons a company may collect and process your personal data, including:
In specific situations, we can collect and process your data with your consent – e.g. when you tick a box online or sigh up to receive email or postal communication from us. When collecting your personal data, we’ll always make clear to you which data is necessary in connection with a particular service and have given details on this in section 1.4.
1.1.2. Contractual obligations
In some instances, we need your personal data to comply with our contractual obligations. For example, if you book housing with us, we need certain details from you in order to make the booking and we may need to pass your details to a taxi company so that they can collect you from the airport.
1.1.3. Legal compliance
We may be legally bound to collect and process your data. For example, if someone is involved in any criminal activity or fraud affecting us, we need to pass details to law enforcement.
1.1.4. Legitimate interest
We require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom or interests. For example we may use your booking history or personal data in order to offer you a more personalised experience when you stay with us.
We are committed to protecting and respecting your privacy.
This policy sets out the basis on which your personal data will be processed by us. We are committed to protecting your personal information and to being transparent about what information we hold. This policy does not include information about the privacy of our employee’s data which can be obtained from our HR department.
For the purpose of the GDPR the data controller is Portland Brown Ltd whose registered office is at 22 Stokes Croft, Bristol, BS1 3PR. References in this policy to “we”, “our” or “us” are references to Portland and any subsidiaries or divisions of Portland Brown Ltd.
Registration no. 5452350
Registered in England & Wales
1.2. HOW WE MIGHT COLLECT YOUR PERSONAL DATA
We may collect your personal data in a number of ways including:
- When you submit a booking enquiry online
- When you phone, email or send direct mail
- When you complete a registration card when you come to stay with us
- When you engage with us on one of our social media platforms
- When you visit our website (through cookies and other tracking technologies)
- When you have given a third party permission to share information they hold about you with us
- When you comment about or review our products and services
- When you enter a competition or prize draw or fill in a survey
- When you visit one of our offices which have CCTV systems that may record your image
1.3. WHAT DATA MIGHT WE NEED?
Whilst we are working with you, we may collect the following data dependent on the service you require:
- Your full name
- Your address
- Your email address
- Your date of birth
- Your IP address
- Search terms you entered on our website
- Comments or product/service reviews
- Information you may have told us that suggests your preferences
- Your credit card details
- Your position/job title
- Your contact phone number
- Notes from conversations we might have with you
- Your passport details
- Websites you came from when visiting ours
- Cookies in your web browser
- Your image
- Names of people who you are travelling with, including the age of any children
1.4. HOW AND WHY WE USE YOUR PERSONAL DATA
When you engage with us, we want to give you the best possible experience. By collecting data about you, it allows us to offer a great and tailored service.
We will process your personal data in order to fulfil our contractual requirements to provide corporate housing services to you. We interact with you in a variety of ways, depending on the service you require, i.e. Global Mobility Manager, Guest, Supplier etc. There is a contractual requirement for you to provide the information detailed in section 1.2. (dependent on the service you require) and without collecting this data we are not able to fulfil our obligations which may result in us not being able to provide services to you.
We may also process your data in line with legitimate interests. This means that we may contact you regarding products or services which we believe you may be interested in due to your previous interactions with us. But don’t forget, you can opt-out of receiving such contact at any time.
Here are some of the ways we may use your personal data:
- Our teams need to be able to respond to your queries, complaint or process a refund so we need your contact information in order to respond. We will keep a record of your information including notes on how we communicated with you and what was discussed. We do this on the basis of our contractual obligations to you, our legal obligations and our legitimate interests in providing you with exceptional customer service and helping us improve this service to you.
- We keep your personal data to maintain, update and safeguard you and to protect our business from fraud or other illegal activities. We’ll also monitor your browsing activity in order to identify and resolve any problems and protect the integrity of our websites. We’ll do all of this as part of our legitimate interest.
- When you make a booking with us or need to make a payment to us for ad hoc charges and wish to do this by credit card, your card details are collected by our third party payment processors SagePay who use secure online capture and processing methods. This helps to protect you from fraud. We do this on the basis of our contractual and legitimate business interests. Where we take payments using the iZettle system, all data is encrypted, again to protect you from fraud.
- In our offices, we use CCTV to protect our customers, premises, assets and staff from crime. We do this on the basis of our legitimate business interests.
- If we discover any criminal activity or alleged criminal activity through our use of CCTV, fraud monitoring and suspicious transaction monitoring, we will process this data for the purposes of preventing or detecting unlawful acts. We aim to protect the individuals we interact with from criminal activities.
- We will use your personal data, preferences and details of your bookings to keep you informed about relevant products and tailored special offers, discounts, promotions, competitions and events by email and post. As ever, you can always opt out of hearing from us through these channels at any time.
- If you enter a competition or prize draw run by us we will use your information to contact you in the event of you winning based on your agreement to the terms and conditions of the competition at the time of entry. The personal data relating to your competition entry will be processed in line with this agreement unless you are drawn as a winner in which case the terms and conditions of the competition may require a longer period of retention for marketing purposes.
- To display the most interesting content to you on our website we’ll use data we hold about your interactions with us and so on. We do so on the basis of your consent for our website to place cookies or similar technology on your device e.g. we might display a list of properties you’ve recently looked at or offer you recommendations based on any data you’ve shared with us.
- We use your data to develop and improve our systems. We’ll do this on the basis of our legitimate business interests, survey feedback etc.
- To comply with our contractual or legal obligations to share data with law enforcement.
Your data will be stored in our CRM database and will only be accessed by our employees during the course of their employment for the purpose of providing corporate housing services. This database is password protected and security permissions are set appropriately for employees to restrict access where necessary.
Data may also be stored on secure servers. We ensure that this data is kept safe using strict procedures and security features to prevent unauthorised access.
1.5. TRACKING TECHNOLOGIES
Cookies are small encrypted text files that are sent to your browser from the websites you visit and are stored on your device.
We use the following types of cookies on the website:
These are temporary cookies that remain until you leave our website or close the browser window. We use these to carry information across pages of our website and in some cases, to prevent data from needing to be re-entered into forms.
We additionally make use of analytical cookies through Google Analytics. These cookies help us compile anonymous statistics that allow us to understand how visitors are using our website, which pages are being visited, and help us improve it and its content. These cookies do not identify visitors personally.
Our use of Google Analytics will set the following cookies on your device (information taken from http://code.google.com/apis/an...)
This cookie is typically written to the browser upon the first visit to your site from that web browser, and is used to determine unique visitors to a site and is updated with each page view
This cookie is used to establish and continue a user session with your site. When viewing a page, the Google Analytics code attempts to update this cookie. If it does not find the cookie, a new one is written and a new session is established. Each time a user visits a different page on your site, this cookie is updated to expire in 30 minutes, thus continuing a single session for as long as user activity continues within 30-minute intervals.
Historically, this cookie operated in conjunction with the __utmb cookie to determine whether or not to establish a new session for the user.
This cookie stores the type of referral used by the visitor to reach your site, whether via a direct method, a referring link, a website search, or a campaign such as an ad or an email link. It is used to calculate search engine traffic, ad campaigns and page navigation and is updated with each page view.
Google offers an opt-out tool available at https://tools.google.com/dlpag... which allows you to opt out of all their Analytics tracking for all websites as an add-on to most popular browsers
1.5.2. Third Party Cookies
Our website also carries embedded 'share' buttons to enable users of the site to easily share articles with their friends through a number of popular social networks. Other third parties that we use may also operate tracking technologies on their websites.
These sites may also set cookies when you are also logged in to their service. We do not control the dissemination of these cookies and you should check the relevant third party website for more information about these cookies.
To read more about cookies, what they mean, what they can be used for and why we have made this statement, please visit http://www.aboutcookies.org. We may amend this policy in line with future changes in legislation or best practice.
1.5.3 Targeting/Advertising Cookies
These are cookies that record your visit to our sites, the pages you have visited and the links you have followed. They collect information about your browsing habits and track the volume of visitors and number of times an advert is displayed and clicks such adverts receive. We will use this information to make our sites and the advertising sent to you and displayed on them more relevant to you and your interests. We may also share this information with certain third-party business partners for analytical purposes such as Google and to enable them (and other parties) to serve personalised advertisements to you. These cookies are also used to limit the number of times you see an advert as well as help measure the effectiveness of advertising campaigns. They are usually placed by third party advertising networks or technology providers. They remember the websites you visit and that information may also be shared with other parties e.g. advertisers.
Facebook Data Policy: https://www.facebook.com/polic...
Learn about opting out of Facebook ads: https://www.facebook.com/ads/a...
Learn about opting out of LinkedIn ads: https://privacy.linkedin.com/s...
Learn about opting out of Google ads: https://policies.google.com/te...
1.6. LINKS TO OTHER WEBSITES
1.7. SHARING YOUR PERSONAL DATA
In order to fulfil our contractual obligations of providing corporate housing services it may be necessary to share your data with selected third parties. These may include preferred suppliers (where we have an obligation to provide services in locations where we do not operate our own stock) as well as contractors and suppliers as follows; taxi providers, IT companies, mailing houses, credit card processing services and so on. This list is not exhaustive and we may change or add to this list in order to continue to provide you with the best service. We only provide what they need and they cannot use your data for anything other than the purposes that we have instructed them to use it. Your data is deleted or rendered anonymous if we stop working with them.
We will not share your data with any other third party, except as allowed for in other privacy policies or required by law. We do not sell your personal data to third parties under any circumstances.
1.8. TRANSFER OF PERSONAL DATA TO COUNTRIES OUTSIDE OF THE EEA
Countries within the European Economic Area (EEA) are governed by the GDPR and therefore if any of your personal data is transferred to third parties within the EEA they will be required to comply with and safeguard your data in line with the GDPR.
Where it is necessary to transfer your personal data to countries outside of the EEA (in order to fulfil our contractual obligations or for legal reasons), your data will only be transferred to third parties whose data protection laws have been assessed as adequate by the EU or where adequate safeguards are in place.
1.9. HOW LONG YOUR PERSONAL DATA IS KEPT FOR
We will keep your personal data for a period of 3 years after our contract to supply corporate housing services to you comes to an end.
In some cases, we may need to keep your data for up to 7 years to satisfy our financial reporting requirements to HMRC and Companies House. Only data that is required for this purpose will be kept. All data will be securely destroyed when it is no longer required.
If you exercise your right to erasure (see section 1.9.4.), we will continue to hold some data (your name and the company that you work for) for our record keeping purposes i.e. to make sure we know you don’t want to hear from us. Further information is available in our Data Retention Policy.
2.0. YOUR RIGHTS REGARDING YOUR PERSONAL DATA
Under the GDPR, you have a number of rights regarding your personal data:
2.0.1. Right to be informed
This policy sets out the information you are entitled to receive regarding the personal data that we collect and store for you
2.0.2. Right of Access
You have the right to obtain confirmation that your data is being processed as well as access to the personal data that we hold for you.
Where you make such a request, we will respond as soon as possible and at the latest within one month of receipt of your request and this information will be provided free of charge.
If we consider that your request is unfounded or excessive, we reserve the right to charge a reasonable fee for providing such information. We may also extend the time taken to respond to you fully.
2.0.3. Right to rectification
You have the right to have personal data rectified where it is inaccurate or incomplete. You may put this request in writing to [email protected] Where a request is made, the data will be rectified as soon as possible and at the latest within a month of receiving your request.
Where applicable, we will notify relevant third parties of any changes to ensure that the data they are processing is rectified.
2.0.4. Right to erasure
You have the right to have your personal data erased if it is no longer necessary in relation to the purpose for which it was collected/processed. Where possible we will comply with all requests to erase your data, save for data that is necessary to meet any statutory requirements or our record keeping purposes.
Where we have transferred your personal data to third parties, we will inform them of this erasure.
2.0.5. Right to restrict processing
You have the right to request that we restrict processing your personal data if you believe that the data we hold is inaccurate. You can request that we restrict processing whilst we verify the accuracy of data that we hold. You may also request that we restrict processing if you have issues with how your data is being processed. This restriction may be put in place whilst we consider whether our legitimate grounds to processing your data supersede your request for restriction.
Where we have transferred your personal data to third parties, we will inform them of this restriction.
2.0.6. Right to data portability
You have the right to receive a copy of your personal data and/or have this data transmitted to another data controller. We will comply with any such requests as far as is reasonable but it may not be possible to transmit data in a way that is compatible with systems of another controller.
2.0.7. Right to object
You have the right to object to us collecting, storing and processing your personal data. Where an objection is made to us processing your data for direct marketing purposes, we will deal with this as soon as possible (and without unnecessary delay) and cease all marketing activities. You can tell us that you don’t want to receive marketing information by using the ‘unsubscribe’ link in any email communication that we send to you or by emailing [email protected]
In cases where we are processing your personal data on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation. We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal data.
2.0.8. Rights related to automated decision making including profiling
We do not operate any systems using automated decision making or profiling in relation to providing you with housing services.
If you have any questions or concerns regarding this policy or the personal data that we hold and process for you, please contact us by emailing [email protected]
Remember, we are all about looking after people so if you have any questions or concerns, just give us a call.