Legal

Data privacy policy 24/5/2018

Introduction

Central London Apartments Ltd (cenlonap.co.uk) is committed to protecting your privacy and maintaining the security of any private information you provide. Central London Apartments Ltd (cenlonap.co.uk) adhere to the requirements of the data protection legislation in the UK.

We do not share, rent, sell, or otherwise use any personal information you have given us to any third party without your permission, except when required by law, subpoena or other legal process or in order to protect the safety of the public. Any information you give us is held with the utmost care and security, and will not be used in ways to which you have not consented. Since this policy may change over time as we modify or expand our services, we suggest that you check from time to time in order to understand how we treat your personal information. Your use of this website and its services constitute your agreement to the terms of our privacy policy. If we decide to change these polices, we will post those changes so that you are always aware of what personal information we collect, how we use it and under what circumstances we disclose it.

Your continued use of this website and its services constitute your agreement to any such changes. If you have any questions about privacy on cenlonap.co.uk please contact stay@cenlonap.co.uk.

 

How we use your personal data

In this section we outline how we may process your personal data. All personal data we process falls into one or more of the following categories:

Booking data
Financial data
Enquiry data
We may process your booking data (“booking data“). The booking data may include your name, address, phone number, email address. The booking data will be processed for the purposes booking an apartment for you. The legal basis for this processing is the performance of a contract between you and us.

We may process financial information (“financial data”) you share with us. The financial data may include your bank details and name. The financial data may be processed for the purposes of processing your booking, receiving of rent and receiving and returning of deposit. The legal basis for this processing is the performance of a contract between you and us.

We may process information contained in any enquiry you submit to us regarding apartments (“enquiry data“). This enquiry data may be processed for the purposes of providing clarification and answering your enquiry. The legal basis for this processing is the performance of a contract between you and us and to ensure we are responding to your enquiry.

Providing your personal data to others
We do not, and will not, sell any of your personal data to any third party – including your name, address, email address or bank details.

Financial transactions relating to your booking. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds.

In addition to the specific disclosures of personal data set out in this Section 3, we may disclose your personal data with law enforcement and fraud prevention agencies, so we can help tackle fraud or where such disclosure is necessary for compliance with a legal obligation to which we are subject, in order to protect your vital interests or the vital interests of another natural person, or in connection with the establishment, exercise or defence of legal claims, whether in court or not.

How long we retain your data

Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

After all business and financial arrangements have finished between you and CLA, we will erase your data at the end of that tax year.

In certain circumstances we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, to resolve disputes and enforce our agreements.

Your rights

You have a number of rights in respect to your personal data. We have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights. You may exercise any of your rights in relation to your personal data by emailing us on stay@cenlonap.co.uk

1. Right of access – You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data.
2. Right to rectification – You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
3. Right to erasure – In certain circumstances you have the right to the erasure of your personal data without undue delay. However, there are exclusions of the right to erasure, such as where processing is necessary for exercising the right of freedom of expression and information, for compliance with a legal obligation, or for the establishment, exercise or defence of legal claims.
4. Right to restriction on processing – In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: (a) you contest the accuracy of the personal data; (b) processing is unlawful but you oppose erasure; (c) we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and (d) you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: (a) with your consent; (b) for the establishment, exercise or defence of legal claims; (c) for the protection of the rights of another natural or legal person; or (d) for reasons of important public interest.
5. Right to objection to processing – You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: (a) the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or (b) the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless (a) we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or (b) the processing is for the establishment, exercise or defence of legal claims.
   You also have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
6. Right to data portability – In certain circumstances, you have the right to receive your personal information in a structured, commonly used and machine-readable format and to transmit that information to another controller to enable it to use the data. The right to data portability applies (a) to personal data you have provided to us as data controller, (b) where the processing is based on the your consent or for the performance of a contract and (c) when processing is carried out by automated means. If you request this information, we will transmit the data directly to another controller, if this is technically feasible. We are, however, not required to adopt or maintain processing systems that are technically compatible with other controllers. Also, if the personal data concerns more than one individual, we must consider whether providing the information would prejudice the rights of other individuals.
   In case you exercise your right to data portability, we will endeavor to respond to your request within one month, but if your request is complex or we receive a number of similar requests at the same time, it might take us longer, in which case we will inform you within one month of the receipt of the request and explain why we think an extension is necessary.
7. Right to withdraw consent – To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time.
8. Right to complain – In the event that you wish to make a complaint about how we process your personal data, please contact us in the first instance at stay@cenlonap.co.ukand we will endeavour to deal with your request as soon as possible. If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement. Our supervisory authority is the Information Commissioner’s Office. You can contact them on https://ico.org.uk/.

Data protection officer

If you have any concerns or questions about how we protect your privacy, please contact the team on stay@cenlonap.co.uk