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Zorca Hospitality Ltd, trading as The Zetter (Web), its licensees, franchisees, associates, parents, subsidiaries and affiliates (collectively “Zorca Hospitality Ltd”, ”The Zetter” or We) are committed to protecting and respecting your privacy.
Zorca Hospitality Ltd is a limited company registered in England under company number 12897221. Our registered office is at Marrable’s Hotel, 86-88 Clerkenwell Road, London, England, EC1M 5RJ.
This policy (together with our Terms and Conditions and any other documents referred to on it) set out the basis on which any personal data we collect from you, or that you provide to us, will be processed. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
For the purpose of the General Data Protection Regulation (GDPR), the data controller in respect of this website is The Zetter . Where you make a booking with us, other companies within The Zetter will also be processing your data.
THIRD PARTY RIGHTS
The website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
We use session cookies on our website to manage and run certain applications and functions, but these cookies expire after the user’s session in the website terminates. In addition, the Website uses:
- standard Google Analytics cookies to anonymously monitor traffic and usage of the website
- cookies from our media and advertising partners which allows us to collect the approximate location of the user (usually by way of IP address) and how the website is used
Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use additional cookies, over which we have no control.
INFORMATION WE COLLECT FROM YOU
We will collect and process the following data about you:
- Information you give us about you. This is information about you that you give us by filling in forms and making bookings or enquiries through the website or by corresponding with us by phone, e-mail or otherwise. It includes information such as your name, address, e-mail address and phone number, details of your employer (where you are booking as a business customer and or made by third party booker), financial information (such as debit and credit card details) and your purchase history (including room booking and requests for additional services).
- Information you give us about other people. Where you are making a booking on behalf of other people, you may be asked to provide details about them (such as their name, email address or other relevant details about them). You should only provide The Zetter with this information where you are authorised to do so.
- Information The Zetter collect about you. With regard to each of your visits to the website we will automatically collect technical information from you including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, the full Uniform Resource Locators (URL), your journey to, through and away from our website (including date and time), page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-movements), methods used to browse away from the page and any phone number used to call our customer service number.
- Information The Zetter receive from other sources. We work closely with third parties (including, for example, travel agencies, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive further information about you from them. We may also receive information on your from publicly available online and social media platforms (such as Facebook and LinkedIn).
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Our terms and conditions do not allow bookings to be made by or solely on behalf of any person under the age of 16.
Where you make a booking with us, you will have the option of entering the name of any guest below the age of 16, but this is not compulsory. You should only provide personal data relating to a child under the age of 16 where you have the right to do so, and you can consent to this being stored on our system. These details will only be used by us as part of the booking process and will be stored in accordance with this policy.
STORING YOUR INFORMATION
When you stay at a The Zetter property, your personal data will be stored in centralised systems which are under our control and accessible by authorised staff. These systems are encrypted to ensure security. All of our systems are compliant with relevant GDPR regulations.
Unless there is good reason to retain your personal data for a longer period (such as where you remain opted in to receiving marketing communications from us), your details will remain on our centralised systems for six years after your last stay with us.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
You may also request that we delete your data. For further information on this please see the YOUR RIGHTS section below.
USES MADE OF THE INFORMATION
The Zetter will use information held about you in the following ways:
- Information you give to us about You. The Zetter will use this information:
- to carry out our obligations arising from any booking made by you.
- to correspond with you regarding your booking and in response to any request from you.
- where we have legitimate grounds to do, to provide you with information about other products and services we offer that are similar to those that you have already purchased or enquired about.
- where we have legitimate grounds to do, to provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you.
- to notify you about changes to our service.
- Information you give us about other people. We will use this information:
- to carry out our obligations arising from any booking made by you.
- Information we collect about you. We will use this information:
- to administer the website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.
- to improve the website to ensure that content is presented in the most effective and informative manner for you and for your computer.
- to allow you to participate in interactive features of our service, when you choose to do so.
- as part of our efforts to keep the website safe and secure.
- to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you.
- to make suggestions and recommendations to you and other users of our 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. We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).
When you supply your personal data to us, you will be given the option of selecting to receiving marketing communications from either The Zetter and/or their selected third parties. Where you have agreed to receive marketing communications, you may opt out of receive such communications at any time by unsubscribing automatically or by contacting us at firstname.lastname@example.org .
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we wish to use your data for an unrelated purpose, we will notify you of this and explain the basis on which we are allowed to do so.
DISCLOSURE OF YOUR INFORMATION
The Zetter might share your personal information with:
- Any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006, our licensees, franchisees, associates and affiliates.
- Selected third parties including:
- business partners, franchisees, suppliers and sub-contractors for the performance of any booking with you.
- analytics and search engine providers that assist us in the improvement and optimisation of our site.
We might also disclose data to advertisers and advertising networks however we only provide them with aggregate information about our users and do not disclose information about identifiable individuals to them.
The Zetter may also disclose your personal information to third parties:
- In the event that The Zetter sell any business or assets, in which case we may disclose your personal data to the prospective buyer of such business or assets.
- If The Zetter sells all or substantially all its assets to a third party, in which case personal data held by it about its customers will be one of the transferred assets.
- In order to protect the rights, property, or safety of The Zetter , our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
WHERE WE STORE YOUR INFORMATION
All information you provide to us is stored on our secure remote (‘cloud) servers. Any payment transactions will be encrypted using SSL technology. You can identify when SSL technology is being used by the presence of a padlock symbol in the status bar of the browser.
Where The Zetter have given you (or where you have chosen) a password which enables you to access certain parts of the website, you are responsible for keeping this password safe and confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although The Zetter will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to the website; any transmission is at your own risk.
Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
We do not transfer your personal data outside the European Economic Area (EEA).
Right to revoke consent
If you consent to us processing personal data, you have the legal right to revoke such consent at any time. You can do so by emailing us at email@example.com . This will not affect the lawfulness of any processing carried out before you withdrew your consent, and we may continue to process your data where we do not need your consent in order to process the data (e.g., in order to fulfil your booking).
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 firstname.lastname@example.org . 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 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 email@example.com . Please note that we may not be able to delete your personal data where we still have a legal obligation to retain it.
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 the General Data Protection Regulation.
Right to object
You have the legal right to object to the processing of your personal data. We will only cease the processing if required to do so under the General Data Protection Regulation. You have the right to object at any time to our processing of your personal data for direct marketing purposes by either (i) opting out by using the option we provide in the relevant direct marketing message (e.g. an email newsletter), or (ii) by sending an email to firstname.lastname@example.org . 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.
General information relevant for all requests and queries
You must exercise your rights, as explained in this clause, in accordance with applicable law, if and when it applies. We will solely review your request or query in light of our obligations under the Act or any other applicable data protection laws. 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 endeavours to respond to your request as soon as is reasonably practical and usually with one month of the request. Depending on the type of request we may be 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 (i) charge you a fee, or (ii) 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 response.