Privacy Policy

1. CLARIFICATIONS

The GDPR (General Data Protection Regulation) on data protection sets out a number of different reasons an entity may collect and process  clients personal data, including:

1.1. Consent

In specific situations, we can collect and process your data with your consent – e.g. when you tick a box online or sign 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.

1.2. 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.

1.3. 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.

1.4. 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 McNOAH Limited (trading as Proplynx) whose registered office is at 223 Regents Street, London W1B 2QD.  References in this policy to “we”, “our” or “us” are references to Proplynx and any subsidiaries or divisions of McNOAH Limited.

Registration no. 06884703

Registered in England & Wales

2. HOW PROPLYNX 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

3. WHAT DATA MIGHT PROPLYNX NEED?

Whilst we are working with you, we may collect the following data dependent on either the service agreement we signed with you or otherwise through your interaction with our website:

• 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/debit card details
• Your position/job title
• Your contact phone number
• Notes from conversations we might have with you
• Your passport details
• Websites through which you land on our site
• Cookies in your web browser
• Your photograph
• Names of people who you are traveling with, including the age of any children

4. HOW PROPLYNX USE YOUR INFORMATION

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 Stripe payment platform who use secure online platform for capturing and processing methods which protect you from fraud.  We do this on the basis of our contractual and legitimate business interests.  Where we take payments using a POS system, all data is encrypted, again which protect you from fraud.
• Where we use CCTV in our offices, we do this only to protect our customers, premises, assets and staff from crime.  And 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.
• To comply with our legal and contractual obligations, we will send you communications required by law or which are legally or contractually necessary e.g. significant updates to this Privacy Policy, and information relating to your bookings.  These messages are to inform you about changes to the service we provide you and will not include any promotional content and so do not require prior consent when sent by email or phone.
• 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 secure database and will only be accessed by our employees during the course of their employment for the purpose of providing our services.  Security permissions are set appropriately for employees to restrict access where necessary.

Data may also be stored on secure servers especially with our hosting companies.  We ensure that this data are kept safe using strict procedures and security features to prevent unauthorised access.

5. TRACKING TECHNOLOGIES

5.1. Cookies

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 cookies to better understand how users are navigating to and through our site and to provide you with useful additional functionality. If you do not wish us to store cookies on your device, then please visit this link: http://www.aboutcookies.org/default.aspx?page=2  which will give you detailed instructions on how to disable and delete cookies in your browser settings.

We use the following types of cookies on our site:

Session cookies

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.

Analytic cookies

We additionally make use of analytical cookies through Google Analytics. These cookies compile anonymous statistics that allow us to understand how visitors interact with our site, which pages they visited, and help us improve pages and contents. 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/analytics/docs/concepts/gaConceptsCookies.html)

__utma:

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

__utmb:

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.

__utmc:

Historically, this cookie operated in conjunction with the __utmb cookie to determine whether or not to establish a new session for the user.

__utmz:

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/dlpage/gaoptout which allows you to opt out of all their Analytics tracking for all websites as an add-on to most popular browsers

5.2. Third Party Cookies

Third Parties cookies on our site are usually buried in the embedded buttons for relevant parties e.g social medium and other relevant third party services. We also encourage users to share our contents via social media with their friends. By implication, most of these third parties also operate their own tracking technologies upon landing on their websites or when you logged into their services. While we do not control these cookies, you should always independently check these website for information about their respective cookies.

http://twitter.com/privacy

http://www.facebook.com/about/privacy

http://www.linkedin.com/static?key=privacy_policy

https://mailchimp.com/legal/privacy/

For more information about cookies and their uses, please visit http://www.aboutcookies.org.

Note that we reserve the right to amend our policy in line with best practice and changes in legislation.

5.3 Re-targeting Ads

We engage in online advertising to keep you inform of our services, new offerings and promotions. We may from time to time direct ads to you based on what we considered relevant to you in accordance to the history of your browsing and interaction with our website. We use networks such as Facebook and LinkedIn for our ad campaign and rely on their data gathering procedure which are processed in accordance to their own respective and independent data privacy policies and thus anonymous to us.

LinkedIn Privacy Policy: https://www.linkedin.com/legal/privacy-policy

To configure LinkedIn ads: https://privacy.linkedin.com/settings

Facebook Data Policy: https://www.facebook.com/policy.php

To configure Facebook ads: https://www.facebook.com/ads/about/?entry_product=ad_preferences

6. WHOM WE SHARE YOUR INFORMATION WITH

To be able to serve you as necessary, we may have to share your data with our carefully selected partners who we may from time to time liaise with in fulfilling our obligations to you in the course of delivering our committed services. While we have been very careful in choosing our partners, we ensure we partner only with qualified local service providers that can be treated as an extension of our company. By implication and depending on our service contract with you, we may have to share your information with other accommodation providers, credit card companies, mailing service providers, logistic companies including taxis and chauffeurs etc – the list continues. In anyway, the only reason for sharing your data with selected third party will always be in the course of serving you and the necessity to deliver, by us, your required services in the best way possible to your own benefit. Also in such instances, we will only provide to third party just limited information necessary to deliver the required service and which can only be used exclusively for the reason for which we have entrusted them with such information.

Except as allowed for in our privacy policy or otherwise by law, we will not share your data with any other third party.  We do not and will not under any circumstances sell your personal data to third party.

7. TRANSFER OF PERSONAL DATA TO COUNTRIES OUTSIDE OF THE EEA

Where it is necessary to transfer your personal data to countries outside of the EEA in the course of serving you or otherwise as legally required, we will ensure the third party operate a data protection policy operate at a level adjudged adequate to comply to a UK or US data privacy law. For countries within the EEA, the GDPR is in force and sharing your data with any third party is already required to comply legally with the tight GDPR data protection and privacy law.

8. HOW LONG YOUR PERSONAL DATA IS KEPT FOR

We will normally keep your personal data for a 3 years period after our contractual relationship with you is fully discharged. For financial data and as required by the HMRC and Companies House, we are required to keep financial data for 7 years and we will only keep data require for this purpose for such length of time while all other data will be securely destroyed when they come to the length of time for which they are legally required to be kept for.  .

In case you exercise your right to erasure (see section 1.9.8.), we will oblige your request but continue to hold some basic data (e.g name and or your employer) to satisfy our record keeping requirements and to effectively observe you ‘no-contact’ request. Please see our Data Retention Policy for more information.

9. YOUR RIGHTS REGARDING YOUR PERSONAL DATA

Under the GDPR, you have a number of rights regarding your personal data:

9.1. Right to be informed

This policy sets out the information you are entitled to receive regarding the personal data that we collect and store about you

9.2. Right of Access

You reserve the right to obtain confirmation that your data is being processed as well as access to the personal data that we hold about 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.

9.3. Right to rectification

You reserve the right to have personal data rectified where it is inaccurate or incomplete.  You may put this request in writing to privacy@proplynx.com.  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.

Where we have transferred your personal data to third parties, we will inform them of this erasure.

9.4. Right to restrict processing

You reserve 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.

9.5. Right to data portability

You reserve 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.

9.6. Right to object

You reserve 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 privacy@proplynx.com.

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.

9.7. 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.

9.8. Right to erasure

It is within your 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.

10. CONTACTS US

If you require any further information, question or concerns regarding this policy or the personal data that we hold and process about you, please contact us through privacy@proplynx.com. Or contact us at proplynx.com/contact-us.

Our overriding objective remains to deliver quality service at all time and to enable us do so, You Trust, We Serve.