We understand that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all our customers and users and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
1. Information About Us
Our Business name: NuBreed Hotels Limited
Our place of incorporation and company number: England & Wales, 11867520.
Our Registered address: 27 Oxford Road, Horsham RH13 5EH.
Our Data Protection Officer: The Operations Director
Email address: dataprotection@NuBreedHotels.com
Telephone number: +44 0203 051 3307.
Postal Address: c/o NuBreed Hotels – 27 Oxford Road, Horsham RH13 5EH
2. What Does This Notice Cover?
This Privacy Information explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.
3. What is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers. The personal data that we use is set out in Part 5, below.
4. What Are My Rights?
Under the GDPR, you have the following rights, which we will always work to uphold:
a)The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 11.
b) The right to access the personal data we hold about you. Part 10 will tell you how to do this.
c) The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 11 to find out more.
d) The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. Please contact us using the details in Part 11 to find out more.
e) The right to restrict (i.e. prevent) the processing of your personal data.
f) The right to object to us using your personal data for a particular purpose or purposes.
g) The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
h) Rights relating to automated decision-making and profiling. Part 6 explains more about how we use your personal data, including automated decision-making AND/OR profiling.
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 11.
Further information about your rights can also be obtained from the Information Commissioners Office. If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioners Office.
5. What Personal Data Do You Collect?
Information you give us. This is information about you that you give us by filling in forms on this website, www.NuBreed Hotels.io (the “Company’s Site”) or otherwise in writing with us, or by corresponding with us by phone or e-mail. It includes information you provide when you register with the Company and information you provide to the Company’s third-party partners, agent, representatives or nominees, or when you subscribe to purchase tokens and when you report a problem with the Company’s Site.
The information you give us may include some or all of the following personal data (this may vary according to your relationship with us):
Date of birth;
Business name; (if a fund or a company)
Proof of address;
passport copy; and,
a second recognised form of photographic identification.
Information we collect about you. With regard to each of your visits to the Company’s Site we may automatically collect the following information:
Transactional information. We collect information about any transaction you may complete on the Company’s Site, including the dates, costs, locations and types of accommodation booked.
Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, and public keys;
Information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from the Company’s Site (including date and time), products you may have viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our customer service number.
Information we receive from other sources. This is information we receive about you if you use any of the other websites we operate or the other services we provide. In this case we will have informed you when we collected that data if we intend to share those data internally and combine it with data collected on this site. We will also have told you for what purpose we will share and combine your data. We may work with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies). We will notify you when we receive information about you from them and the purposes for which we intend to use that information.
6. How Do You Use My Personal Data?
Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. Your personal data may be used for one or more of the following purposes:
• Providing you with access to personalised and/or curated lists of hotels or other accommodation.
• Providing you with recommendations based on the experience of other similar travellers.
• Giving you access to information about the company and its activities.
• Communicating with you. This may include responding to emails or calls from you.
Information you give to us and we collect about you. We may also use information:
to administer the Company’s Site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
to improve the Company’s Site to ensure that content is presented in the most effective manner for you and for your computer;
to allow you to participate in interactive features of the Company’s service, when you choose to do so;
as part of our efforts to keep the Company’s Site safe and secure;
to measure or understand the effectiveness of advertising the Company serves to you and others, and to deliver relevant advertising to you; or
to make suggestions and recommendations to you and other users of the Company’s Site about goods or services that may interest you or them.
Information we receive from other sources. We will combine this information with information you give to us and information we collect about you or are given to us by your company. We will use this information and the combined information for the purposes set out above (depending on the types of information we receive). Marketing. With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email with information, news, and offers on our services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.
Automated Decision-Making and Profiling
We use the following automated systems for carrying out certain kinds of decision-making AND/OR profiling. If at any point you wish to query any action that we take on the basis of this or wish to request ‘human intervention’ (i.e. have someone review the action themselves, rather than relying only on the automated method), the GDPR gives you the right to do so. Please contact us to find out more using the details in Part 11.
The following automated decision-making method(s) may be used:
Recommendations for accommodation based on the profiles and experience of other travellers.
7. How Long Will You Keep My Personal Data?
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):
For as long as you or your company continue to use our services and for whatever period thereafter that is required to comply with applicable laws in the jurisdictions in which NuBreed Hotels operates.
8. How and Where Do You Store or Transfer My Personal Data?
We may store or transfer some or all of your personal data in countries that are not part of the European Economic Area (the “EEA” consists of all EU member states, plus Norway, Iceland, and Liechtenstein). These are known as “third countries” and may not have data protection laws that are as strong as those in the UK and/or the EEA. This means that we will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within Ireland and under the GDPR as follows.
Please contact us using the details below in Part 11 for further information about the particular data protection mechanism used by us when transferring your personal data to a third country.
The security of your personal data is essential to NuBreed Hotels, and to protect your data, we take a number of important measures, including the following:
Data is stored using encryption and uses a protocol that ensures no plain text personally identifiable data is stored on our provider’s servers.
9. Do You Share My Personal Data?
We will not share any of your personal data with any third parties, other than your company, for any purposes, subject to one important exception.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority. We may share your personal data with other companies in our group for communication purposes. This includes any holding company and its subsidiaries.
If any of your personal data is required by a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 8.
If any personal data is transferred outside of the EEA, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the United Kingdom and under the GDPR, as explained above in Part 8. In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
10. How Can I Access My Personal Data?
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”. All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 11. There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding. We will respond to your subject access request not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
11. How Do I Contact You?
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details (for the attention of the Data Protection Officer Email address: dataprotection@NuBreedHotels.com Telephone number: +44 0203 051 3307. Postal Address: c/o NuBreed Hotels – 27 Oxford Road, Horsham RH13 5EH
12. Changes to this Privacy Notice
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection. Any changes will be made available www.NuBreedHotels.com.
This Policy has been approved and authorised by the board of directors of the Company.
Date: 08 May 2019
Due for Review by: 08 May 2020
Position: Chief Executive Officer
Signature: Joe Wicks