Poshtel International ApS Privacy Policy

 

Dear visitor,

Your privacy is important to us and we are committed to protecting it and to make you aware of our practices regarding the privacy of your information. Poshtel Popup® takes your privacy seriously. We created this privacy to demonstrate our firm commitment to your privacy and describe what personal data we process, and how we process your personal data. We promise that we will take steps to use your personal data only in ways that are compatible with this Privacy Policy and applicable laws.

 

“Data subjects” are individuals who are staying in our suites and using our Services. In this Privacy Policy, we sometimes refer to our data subjects as “You”. “You” may be a visitor to one of our websites, a user of one or more of our Services ( “User” ), or a customer of a User ( “Customer” ). We’ll do our best to clarify who we are referring to at various points in the policy. “Personal data” in terms of this Privacy Policy means any information relating to an identified or identifiable natural person (“Data Subject’).

 

Processing means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction. We will never sell your personal data. Also, we will not transfer your personal data to third parties except for what is stipulated in this Privacy Policy.

 

We process your personal data when you use our services (“Services”), mainly to provide, administer, improve and maintain the Services, communicate with you, handle your bookings, and improve your experience.

 

If you provide us with another person’s personal data, you are responsible that we are allowed to process such Personal Data in accordance with this Privacy Policy and applicable laws and therefore you are responsible for obtaining consent from the Data Subject(s).

Data controller:

Poshtel International ApS

CVR: 38221299

Svanevaenget 30

2100 Copenhagen Denmark

(“Poshtel Popup®”)

Sometimes, data controller and/or processor or joint controller of personal data we are processing may be different entities within the Poshtel Popup® group.

 

1. When we collect your personal data

  1. We process Personal Data directly from you when you use our services or from companies within our group or partners (i.e. OTAs and traditional travel agencies). We may also process your personal data via cookies, web beacons, customer service, and customer surveys. Data we collect may differ depending on the purpose of data.

2. What personal data do we process and why?

We process personal data to:

 

I) HANDLE BOOKINGS

When you book our suite via our website, online travel agents (OTAs), by email or telephone we are processing following data:

  • Name and Surname
  • Contact details: email, phone, address
  • IP address (when you book or our website)
  • Payment card information
  • Preferences, requests and needs
  • Sensitive personal data (i.e. if you book a room adapted for persons with disabilities (allergies, food preferences)
  • Other data you voluntarily provide (in regards to your staying at Poshtel Popup® and persons you travel with or make a booking for)

 

  1. When you book our experiences or meeting facilities we are processing following data:
  • Name and Surname
  • Contact details: Phone number, email, and address
  • Payment card information
  • Preferences, requests and needs
  • IP address (when you book or our website)
  • Booking history
  • Other data details you voluntary provided during the booking process

We are processing your Personal Data to identify you as an individual, charge you for the Services, in order to discover, and prevent, fraud in conjunction with payment card payments, handle and deliver our Services in accordance with our terms and conditions.

We may transfer your personal data and other information about your booking to our partners and/or suppliers outside our group, within and outside EU/EEA.

Legal grounds for processing: The processing of this personal data is necessary to fulfill an agreement between Poshtel Popup® and you.

Retention period: 120 days after your stay, unless you are a member of Poshtel Popup® community. In such case, we may keep your personal data during your membership period and 12 months thereafter, cf. section II) below.

 

II) HANDLE MEMBERSHIP

When you request on our website we process following information:

  • Name and Surname
  • Contact details: email address, telephone number, address
  • Login details for your membership profile
  • IP address
  • Booking details and booking history
  • Preferences and other requests or needs
  • Sensitive personal data regarding for instance health (e.g. if you book room adapted to 
disabled guests)
  • Membership details, e.g. membership number
  • Other details you have added to your membership profile

 

If you are or become a member of Poshtel Popup® community, we process your Personal Data in order to provide, handle, administer, follow up and maintain your membership. This includes for instance our processing of your Personal Data in order to inform, communicate and respond to requests or inquiries from you regarding your membership. We may also contact you to request that you ensure that your details are correct and up to date. This enables us to give you more flexible and personalised offers and experiences. By using your membership profile we can give you relevant offers and information about our Services that we send to you.

 

Legal grounds for processing: The processing of this personal data is necessary to fulfil an agreement between Poshtel Popup® and you.

Retention period: Data is processed during the membership period and 12 months upon termination.

 

III)  HANDLE CONTRACT REQUESTS

When you request landowners agreement, partnership agreement, and/or investment agreement or other agreement via filling out the form on our website we process following information:

  • Name and surname
  • Phone number
  • Email
  • Country
  • Other information you provide (i.e. type of contract you request)

 

If you use contact form on our website to request landowners agreement, partnership agreement we process your data in order to contact you and send you requested agreement(s). For this purpose, we may use survey tool, such as “Typeform”.

 

Legal grounds for processing: The processing is based on Poshtel Popup’s® legitimate interest of handling potential partnership inquiries

Retention period: Six months upon closing potential partnership inquiry, unless we enter into landowners’ agreement, partnership agreement and/or investment agreement.

 

IV) HANDLE NEWSLETTER AND OTHER DIRECT MARKETING

We may process your Personal Data to send you newsletter in order to notify you about our offers, products or services, via email, posts and other digital media if you use our Services. You may at any time contact us at legal@poshtel.io or unsubscribe in the newsletter or other marketing message if you want no longer to receive our newsletter and other direct marketing. If you wish that we cease processing your Personal Data we will delete or anonymise your Personal Data and we will also cease sending you newsletters and other direct marketing.

 

Legal grounds for processing: Based on your consent.

Retention period: Until you inform us you wish us to cease processing your Personal Data.

 

V) HANDLE CUSTOMER SERVICE INQUIRY

If you contact our customer support (i.e. by email, phone, social media channels) we may process your Personal Data in order to respond, assist and follow up on your inquiries or handle your complaints. For this purpose, we may process following data:

  • Name and Surname
  • Contact details: Email, phone number, address
  • Booking details
  • Technical information (i.e. about your computer, or phone)
  • Sensitive data (i.e. medical data if you have any food allergies or if you book a room ¼adapted for people with disabilities)
  • Booking & purchase history
  • Other Personal Data you provide during your customer service inquiry

 

Legal grounds for processing: The processing is based on Poshtel Popup’s® legitimate interest of handling customer service inquiries.

Retention period: Six months upon closing potential partnership inquiry, unless we enter into landowners’ agreement, partnership agreement and/or investment agreement.

 

VI) PROFILING

In order to provide you with better Services that are tailored upon your personal needs and preferences, we analyse personal data we receive from you.

Legal grounds for processing: The data Processing is based on our legitimate interest in using data for improving our Services based on our customers’ preferences.

 

VII) RECRUITMENT

If you apply for a job on our website (or other communication channels, such as LinkedIn), we process your data to evaluate your application and recruitment i.e. to check your background and/or references. Please do not send us in your job application any sensitive Personal Data (medical data, race etc.)□For the purpose of evaluation of your application and recruitment we may transfer your data to other companies within the Poshtel Popup® group and/or our suppliers. If we hire you, certain Personal Data will be in our Employees record and part of our Employment agreement.

 

Legal grounds for processing: Based upon our legitimate interest to handle recruitment process.

Retention period: Your Personal Data is retained during the hiring process. If Poshtel Popup® doesn’t hire you, we may keep the information up to 24 months upon termination of the hiring process.

 

VIII)  LEGAL OBLIGATIONS

We may process your Personal Data if we are compelled by law, court or public authority i.e. in regards to auditing and tax legislation. In such case, we may process following data:

  • Name and Surname
  • Contact details: Phone, Email, Address
  • Booking details
  • Booking history and receipts
  • Payment data

 

Legal grounds for processing: Data processing is based upon a legal obligation.

Retention period:

 

IMPROVEMENT AND ASSESSMENT OF OUR SERVICES, PRODUCTS AND SYSTEMS

We may process your Personal Data to improve the quality and range of our Services or to detect system (including network) errors and optimize our IT systems (i.e. when you use our wi-fi or website). For this purpose we use analytics tools on our website. The output of the analytics is anonymous. In regards to this purpose, we may process following data:

  • Name and Surname
  • Contact details: Email, Phone, Address
  • Booking details
  • IP address
  • Technical information (i.e. about your phone and/or computer, operating system)
  • Membership Data

 

Legal grounds for processing: We process this Personal Data based on our legitimate interest of being able to improve and develop our Services

Retention period: We may keep this data 36 months upon receiving.

 

3. Security and Transfer of Personal Data:

We protect your Personal Data from unauthorised disclosure and preventing unauthorised parties from gaining access to, or knowledge of, this data. Only employees/consultants whose job function requires will have the access to your Personal Data. We are taking technical and organisational security measures to protect your data (such as encryption, firewalls and password protection) and using our best efforts to provide ongoing education to our employees/consultants in regards to GDPR implementation. In case of any highly risky security breach (such as identity theft), we will notify you as soon as

 

Please do your part to help us. You are (also) responsible for controlling access to emails and other communication channels between you and Poshtel Popup®. We are not responsible for the functionality, privacy, or security measures of any other organisation.

 

We will never sell your Personal Data. Furthermore, we will not make available or share personal data to third parties with the exception for what is stated throughout this Privacy Policy. When we utilise external suppliers or partners, we are regularly entering into data processing agreements to maintain high level of protection of your Personal Data and to ensure your Personal Data is processed in accordance with applicable legislation and that our supplier/partner has taken the necessary technical ¼and organisational actions to be able to protect the rights and freedoms of you as a Data

 

Furthermore we may share personal data to:

  • Courts/Public Authorities – if we are required to do so by law, court order or if withholding such personal data would hinder any ongoing legal
  • Debt collectors – in the event you don’t pay us for the Services provided, based on our legitimate interest of receiving our payments for Services
  • Merger or Acquisition or re-organisation – in case we sell our business partly or in full we may transfer your Personal Data to the new entity.

 

4. Cookies

Our website makes limited use of cookies. “Cookies” are small text files that are stored on a local computer hard drive that contain information related to your use of a site. A cookie can’t read data off of your computer hard disk or read cookie files created by other Web sites. Cookies do not damage your system. Cookies help websites provide visitors with customised features. Our site uses cookies to deliver content specific to your interests, location, and for other purposes. Personal Data collected via cookies may be anonymised and used in aggregate form for the purpose of using for statistics, analysis and further development of our Services. See more information in our Cookie Policy (as updated from time to time.

 

5. Third party applications and websites

Our Service may contain third-party links, include third-party integrations, or be a third-party-branded service that’s being provided by another company where we have no control in. This Privacy Policy is only applicable to Poshtel Popup® Services. By going to those links, using the third-party integration, or using a third-party-branded service, you may be providing information (including personal information) directly to the third party. We are not responsible for the content of any linked applications or websites and the processing of Personal Data of such applications or websites

 

6. Your rights

Your rights in regards to your Personal Data are granted by GDPR and national privacy laws. If you want to use your rights, please contact us at legal@poshtel.io . Your rights are following:

 

a.  Access to your personal data

You have right to obtain information from us whether we process your Personal Data and where is you Personal Data stored and to access your Personal Data. This means that you have the right to demand transcripts regarding the processing that we have maintained over your Personal Data. You also have the right to receive a copy of the personal data that are being processed. You have the right to, once a year and through written application, free of any charges receive a transcript regarding what personal data is stored in regards to you, the purpose of the storage and processing as well as to whom said information has been made accessible. You also have, within the transcripts, the right to be informed of the period of time in which the personal data will be stored and what criteria we have used to determine said period of time.

 

b. Request for rectification

Up on your request, or at our own initiative, we will correct, de-identify, delete or complete any information that has been found to be wrongful, incomplete or misleading. We are not responsible for any issues caused by your incorrect Personal Data, if you omitted to inform us.

 

c. Withdrawal of consent effective from withdrawal and onwards

In regards to Personal Data we are processing based on your consent, you may at any time, withdraw your consent. Such withdrawal, however does not affect the lawfulness of processing based on your previously given consent.

 

d.  Objection to processing for the purpose of direct marketing

If you do not want us to process your personal data for direct marketing, you always have the right to object to such processing. This is done either by unregistering in each specific email or by sending us an email at legal@poshtel.io. When we have received your objection we will cease the processing of personal data for any such marketing. You also have the right to report our processing of your personal data to any public authority responsible for monitoring the application of the GDPR, for example The Danish Data Protection Agency in Denmark. However, we do recommend that you contact us first so that we can try solving the matter in a more efficient and timely manner.

 

e. Objection to certain processing

When we are processing your Personal Data based on our legitimate interest, you have right to object. However, if we have legitimate grounds for processing that override your integrity interest, we may continue processing your Personal Data.

f. “Right to be forgotten”

You have the right to demand deletion of your personal data. This means that you have the right to demand that your personal data is removed if it is no longer necessary for the objectives for which it was gathered. There may exist legal requirements stating that we may not immediately delete personal data (for example in terms of auditing and taxation related legislation). We will in any such case cease the processing being done for any other reasons than to adhere to the legislation of GDPR.

 

7. Contact

If you have any questions about this Privacy Policy, or your Personal Data, please contact us at legal@poshtel.io

 

8. Complaints

Complaints regarding Poshtel Popup® processing of personal data can be directed to: Danish Data Protection Agency,

 

BORGERGADE 28, 5,

DK-1300 COPENHAGEN K, DENMARK,

TELEPHONE (+45) 3319 3200

E-MAIL dt@datatilsynet.dk

 

This Privacy Policy is last updated on the 12th of June 2018. We may update it from time to time and when we do so, we will notify you and publish new terms on our website.

 

Copyright © 2017-2018 Poshtel International ApS