Accommodation Users

At Situ Living Ltd, we respect your personal data.
This Fair Processing Notice explains how we use your personal data when arranging accommodation for you, supporting you during your say and managing any issues that may arise in connection with your accommodation.

Our contact details

Our head office address is:

Unit 3
Ulysses House
Ulysses Park
Heron Road
Exeter
EX2 7PH

For all data protection enquiries, please contact: [email protected].

 

What personal data do we collect about you and how will we use it? 

Personal data means any information about an individual from which that person can be identified.

When arranging accommodation and supporting your stay, we may collect, use, store and transfer different kinds of personal data about you, including:

  • your name, address, email address, telephone number and date of birth;
  • passport details, visa information and other identification documents where required;
  • travel information, including flight details where necessary;
  • information relating to accompanying family members where required for a booking or local registration purposes;
  • communications between you and Situ, including emails, support tickets and telephone calls;
  • information relating to accommodation issues or guest support requests;
  • information relating to complaints, incidents, emergencies or disputes arising during your stay.
  • dietary, accessibility or health-related information that you choose to provide.

This information may be provided directly by you or by the organisation arranging accommodation on your behalf.

We use this information to:

  • source and arrange accommodation;
  • facilitate check-in and check-out;
  • communicate with accommodation providers;
  • comply with local registration requirements;
  • provide guest support services;
  • resolve accommodation issues and complaints;
  • manage incidents and emergencies;
  • deliver and improve our services;
  • enable you to complete feedback or a survey
  • deal with complaints, resolve disputes, meet legal and regulatory requirements, and support any legal proceedings involving our business, you or our clients, suppliers, or service providers.
  • otherwise manage our relationship with you

Telephone calls may be recorded and transcribed for quality assurance, training, complaint handling and legal purposes.

In certain circumstances, our collection of your personal data may include the collection of Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data).

We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity.

 

How is your personal data collected?

We may collect personal data directly from you during the course of arranging and supporting your stays, or from:

  • your employer;
  • the organisation arranging accommodation on your behalf;
  • relocation management companies;
  • travel management companies;
  • accommodation providers;
  • emergency and planned alternative accommodation agencies;
  • and other service providers involved in your accommodation arrangements.

 

What is our legal basis for processing your personal data?

We need a legal basis in order to process your personal data.

Most of our processing is carried out because we have a legitimate interest in doing so. Our legitimate interests include:

  • arranging accommodation;
  • supporting guests during their stay;
  • resolving accommodation issues;
  • maintaining service quality;
  • protecting guests, clients and accommodation providers;
  • managing legal and business risks.

Some information may be processed on the legal basis that we need to comply with legal obligations, including local registration requirements imposed by applicable laws.

Where you choose to provide information relating to your health, accessibility requirements or dietary requirements, we will process that information only where necessary to support your accommodation requirements. We may share this information with accommodation providers where necessary to ensure that appropriate arrangements can be made. By providing this information to us for these purposes, you expressly consent to our processing of that information. You may withdraw this consent at any time.

You have the right to object to processing carried out on the basis of legitimate interests. Please contact us if you have any concerns.

 

Do we use any automated decision making?

We do not use any automated decision making.

 

Who do we share your personal data with?

We may share your personal data with:

  • accommodation providers and property managers;
  • the organisation arranging accommodation on your behalf, including employers, relocation management companies (RMCs), travel management companies (TMCs) and emergency and planned alternative accommodation agencies;
  • software, cloud and communications service providers,
  • channel management and property management systems
  • professional advisers, insurers and auditors;
  • regulators, law enforcement agencies and emergency services where required.

We will only share personal data where we believe there is an appropriate legal basis for doing so and where the disclosure is necessary for the relevant purpose.

 

Do we transfer your personal data outside of the UK, EU or EEA?

Yes.

We share your personal data within the Situ Group. This will involve transferring your data outside the UK to our overseas offices in the USA and Singapore.

As we arrange accommodation worldwide, your personal data may be transferred to accommodation providers and other service providers located outside the UK, EU or EEA.

Whenever we transfer your personal data out of the UK to countries which have laws that do not provide the same level of data protection as the UK law, we always ensure that a similar degree of protection is afforded to it by ensuring that appropriate safeguards are implemented.

 

How long do we keep your personal data for?

We only retain personal data for as long as necessary for the purposes for which it was collected.

Typically:

  • booking, communication, guest care, complaint and incident records will be retained for up to 7 years;
  • passport copies and registration documentation are generally retained for approximately 30 days unless a longer retention period is required by law.

Retention periods may be extended where necessary to establish, exercise or defend legal claims or where required by law.

 

Your rights as a data subject

Under UK GDPR you have the right to:

1.            Request access to your personal data.

2.            Request correction of inaccurate personal data.

3.            Request erasure of personal data in certain circumstances.

4.            Request restriction of processing.

5.            Object to processing.

6.            Request portability of your data where applicable.

7.            Withdraw consent where processing is based on consent.

8.            Complain to the Information Commissioner’s Office (ICO).

Further information about your rights can be found on the ICO website at www.ico.org.uk.

 

Data Protection Complaints

If you have a complaint or concern regarding the way your personal data is handled, you may contact us using the below details. We encourage you to contact us first so we can address your compliant promptly.

To make a data protection complaint, please email [email protected] or write to us at Data Protection Complaints, Situ, Unit 3, Ulysses House, Ulysses Park, Heron Road, Exeter, EX2 7PH. Please provide you contact details and a description of your complaint.

We will acknowledge receipt of your complaint and respond within a reasonable timeframe.

If you are not satisfied with our response, you have the right to complain directly to the Information Commissioner’s Office (ICO).

 

Changes to this notice

We may update this Fair Processing Notice from time to time. The latest version will always be available on our website.

Version 7