This privacy statement is valid for SFA Ltd. The privacy and confidentiality of your information are important to us. We will not disclose your personally identifiable information to third parties without your consent unless we are legally required to do so or the data transfer is necessary for the implementation of the contractual relationship.
SFA is known as Controller, according to the General Data Protection Regulation (GDPR), Art 4, (7) which describes it as a “natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data”.
42 Pine Tree Hill
Telephone: +44 (0)1483 382238
3. How to Contact Us?
If you have comments or questions regarding our data privacy practices or this Online Privacy Statement or you would like to update your information, modify your communication preferences, or if you do not want to receive marketing communications from us in the future, you can contact us at: firstname.lastname@example.org
4. Types of information that we collect
The types of personally identifiable information that we collect may include your name, home, work and email addresses, telephone and fax numbers, credit card information, date of birth, gender, and lifestyle information, such as room preferences, leisure activities, and other necessary information to fulfil special requests (e.g., health conditions that require special room accommodations).
We may also collect non-personally identifiable information about you, such as your use of our website, communication preferences, travel habits, aggregated data relative to your stays, and responses to promotional offers and surveys. You may be offered the choice not to submit your personal information or to decide what forms of communication you want to receive from us. However, doing so may cause certain transactions to become affected. For example, not providing a name will prevent the processing of reservations.
5. How we will use your information
We will use your email address to send a confirmation and, if necessary, might use other information to contact you for helping in processing the reservation. We will also use your email address to:
• Send you pre-arrival confirmation details;
• Send you copies of your bills when you request them;
• Send you periodic satisfaction or market research surveys.
We also may use your information collected on the Site to:
• Respond to your questions or suggestions;
• Improve the quality of your visit to our site.
Note: You can opt-out of any of these promotions by emailing us directly.
Although we will make no more marketing use of information you have asked to be deleted, occasionally, information that you request to be removed will be retained in certain files for a certain period of time in order to properly resolve disputes or to troubleshoot problems. In addition, some types of information may be stored indefinitely on back-up systems or within log files due to technical constraints, or financial or legal requirements.
When you visit our website, some browsing-related information on your device (computer, smartphone, tablet etc.) is likely to be recorded in files called "cookies" and stored on your device.
What are the different types of cookies and how do we make use of it?
• Strictly necessary cookies: these cookies are essential in order to browse some websites and use all of their features (the user's operating system support, display etc.). Without these cookies, features such as the display will not have optimum functionality. Note: these cookies collect purely technical data and do not identify you personally;
• Performance cookies: these cookies help us improve a user's experience by helping us understand how they use our website (most frequently visited pages, applications used etc.). These cookies do not identify you individually;
• Functionality cookies: in order to make browsing easier, these cookies store certain user preferences (language, username, country etc.);
• Store some of the information that you fill in on our online forms to help us personalize your subsequent visits to our website;
• Put security measures in place (for example asking you to reconnect to a page or service after a certain amount of time has elapsed);
• Targeting/advertising cookies: these cookies enable a user to receive targeted advertisements based on their interests, but they also limit the number of times that the advertisements appear;
• Collect statistics. These relate mainly to the number of times you visit our website and your use of the different services that we provide (sections and content viewed, links), with the aim of improving their relevance and usability;
• Affiliate cookies: these cookies enable third parties ("affiliates") that publish marketing campaigns on their websites to be paid on behalf of the "web merchant";
• Cookies from social networks: these third-party Cookies let you communicate the content of our site to others, as well as your opinion in relation to our site. This is the case with the "Share" and "Like" buttons on "Facebook," "Twitter," "LinkedIn," "Viadeo," etc.
Our cookies are limited to our website only and are not designed to follow you when traveling on the internet after leaving our website. We track the usage of our website in order to better meet your needs and to help make it easier for you to find information in the future. Please note that in addition to our cookies, various third parties may also place cookies on your computer's hard drive. We are not responsible for the presence or absence of third-party cookies, or for the technological capabilities or practices employed by third parties in connection with third-party cookies.
If you would prefer not to have the benefits of cookies, your internet browser or other third party software on your workstation can be adjusted to treat cookies in different ways. Depending upon the type of browser you are using, you may be able to configure your browser so that: (i) you are prompted to accept or reject cookies on an individual basis; or (ii) you may be able to prevent your browser from accepting any cookies at all. You should refer to the supplier or manufacturer of your Web browser for specific details about cookie security. However, you should also understand that rejecting cookies might affect your ability to perform certain transactions on our website and our ability to recognize your browser from one visit to the next.
6. Method of Collection of Information
We do not collect personally identifiable information when you browse our website, unless you voluntarily and knowingly provide such information.
Information may be collected as part of:
* fulfilling reservation or information requests
We endeavour to collect information only with your knowledge and with your permission if necessary.
7. Data Transmission
We may disclose your information to others with that purpose in the following ways:
• When we have received your consent to do so;
• When we communicate with employers, relocation companies, travel agencies, companies or organizations, who have made reservations, agreed to make payments, arranged for discounts, or purchased services on your behalf or if you use our services under a corporate or other commercial account;
• If you seek to have your rental charges invoiced to your employer or any other third party, we may disclose personally identifiable data about you to that employer or third party and to any companies that assist the third party in processing invoices;
• When we report to credit card issuers, credit reporting and fraud checking agencies and debt collection agencies;
• If you choose to do business with us through, or with the assistance of, your employer's or any third party's travel agent, relocation company or other intermediary, we may disclose personally identifiable data about you to the employer or other intermediary to make, modify or cancel a reservation made by or with the assistance of the agent, to respond to questions or comments made by the agent on your behalf, to facilitate any other task which the employer or intermediary advises us that you intend for the agent to fulfil, or that such an agent would, as a matter of industry practice, typically fulfil;
• In situations where sharing or disclosing your information is required in order to offer you services you desire;
• When companies or service providers that perform business activities on our behalf require such information (e.g., credit card processing, customer support services, market research administration or database management services);
• When a housing complex or other property leaves our system and access to your personally identifiable information is necessary to facilitate business operations or meet contractual obligation;
• In the event we are merged with, acquired by, or acquire another company;
• To comply with legal or regulatory requirements or obligations in accordance with applicable law or court order, and otherwise as we believe to be necessary or appropriate to satisfy any law, regulation or other governmental request, to operate our website properly, or to protect or defend our rights or the rights or well-being of our employees, users or others or if you are involved (or are suspected by governmental authorities or our security functions to be involved) in any illegal activity, even without a subpoena, warrant or court order; or
• In case of emergency such as to safeguard the life, health, or property of an individual. If information is shared as mentioned above, we will limit the scope of information that is furnished to the amount necessary for the performance of the specific function.
We may confirm personal information you provide us on applications and forms, or as a resident of one of our communities, with third parties, such as your bank, employer, present mortgage company or landlord, utility providers, government entities, credit agencies, and other businesses where you have an account or a credit card. Unless otherwise precluded by legal process, we require third parties to protect your personally identifiable information and abide by applicable privacy laws and regulations.
The nature of our business and our operations may require us to transfer your information, including personally identifiable information, to other group companies, properties, centres of operations, data centers, or service providers that may be located in countries outside of your own. Although the data protection and other laws of these various countries may not be as comprehensive as those in your own country, we will take appropriate steps to ensure that your personally identifiable information is protected and handled as described in this Privacy Statement.
As part of our commitment to keep you informed, we may contact you via mail, e-mail, telephone, or by other means to confirm your departure date, ensure your customer satisfaction, notify you of new products and services, or upcoming special offers, events, enhancements, or other relevant information that may be of interest to you. You may also receive mailings or other communications from carefully selected partners, such as our referral partners or our customer satisfaction surveyors.
We may offer you the option to decline any or all of these communications by following the directions included in our emails or other communications, or by contacting us directly. We strive to keep all our customers and visitors informed and equally able to take advantage of the benefits offered by us and our strategic marketing partners. However, if you reside outside of the United States, certain data privacy regulations may require us to obtain your permission before we send you information that you have not requested from us.
In some cases, your permission will be implied from the nature of the service requested or transaction undertaken. For example, we may collect and use personally identifiable information that you volunteer, or behavioural data or information collected in the aggregate. In addition, your permission will be deemed given for communications from us that are necessary to fulfil transactions and services that you request.
9. Your Rights
You have the right to information, correction, deletion, limitation of processing, opposition to processing, and data portability. If processing is based on your consent, you have the right to revoke it with effect for the future. According to Art 21 (1) of the GDPR, you have the right to file an objection at any time for reasons arising out of your particular situation against the processing of personally identifiable information relating to you, pursuant to Article 6 (1) of the GDPR (data processing in the public interest) or Article 6 par. 1 f GDPR (data processing for the protection of a legitimate interest); this also applies to a profiling based on this provision. In the event of your objection, we will no longer process your personally identifiable information unless we can establish compelling and legitimate grounds for processing that outweigh your interests, rights and freedom, or if the process aids the enforcing, exercising or defending of legal claims.
If we process your personally identifiable information for the purpose of direct advertising, you have the right according to Article 21 par. 2 GDPR to object at any time to the processing of personally identifiable information relating to you for the purpose of such advertising; this also applies to profiling, where appropriate, insofar as it is associated with such direct advertising. In the event of your objection to processing for the purpose of direct advertising, we will no longer process your personally identifiable information for these purposes. You also have the right to complain to a relevant data protection supervisory authority about our processing of your personally identifiable information.
10. Data Security
We would like our Site visitors to feel confident about using the Site to plan and purchase their accommodations, so we are committed to protecting the information we collect. We have implemented a security program to keep information that is stored in our systems protected from unauthorized access. Our Sites are hosted in a secure environment. The Sites servers/systems are configured with data encryption, or scrambling technologies, and industry-standard firewalls. When you enter personal information during the reservation process, or during a customer’s email sign-up, your data is protected by Secure Socket Layer (SSL) technology to ensure safe transmission.
11. General Information
Children's Privacy & Parental Consent
Links Provided To Other Sites
We may provide links to a number of other web sites that we believe might offer you useful information and services. However, those sites may not follow the same privacy policies as us. Therefore, we are not responsible for the privacy policies or the actions of any third parties, including without limitation, any web site owners whose sites may be reached through this Site, nor can we control the activities of those web sites. We urge you to contact the relevant parties controlling these sites or accessing their on-line policies for the relevant information about their data collection practices before submitting any personal information or other sensitive data.
Social networks, which offer these application buttons, can identify you by these buttons, even if you did not click on one of them when you visited our site. Indeed, some Cookies allow the social network concerned to follow your navigation on our site whenever your social network account is activated on your device when at the same time, you are on our site. We have no control over the procedures social networks use to collect information about your navigation on our site. Please read these social networks privacy policies regarding personal data. These should allow you to exercise certain privacy options with these social networks, in particular by adjusting your user accounts for each of these networks.
Co-branded Pages and Third-Party Service Providers
Portions of our website is operated by third-party service providers ("Providers"). Providers may place cookies on your computer in order to store information or store your account login. Our agreement with Providers requires the information to be kept confidential and disclosed only to Providers employees who require such access in the course of their assigned duties. We may change the provider from time to time and will transfer stored information to the new providers subject to similar restrictions.
We also may use pixel tags, sometimes called Web beacons, to count how many people visit certain Web pages. Information collected from invisible pixels is used and reported in the aggregate and does not contain personally identifiable information. We may use this information to improve marketing programs and content. We and our email service provider also use pixel tags to:
• Track customer response to our advertisements and website content;
• Determine your ability to receive HTML-based email messages. Our email service provider includes a pixel tag, which they refer to as a coded sensor in all of the HTML-based messages sent on our behalf. The sensor activates when the email message is opened and flags the email address of the user as one that is capable of receiving HTML-based email messages. This capability helps our service provider to send the email in a format you can read. The sensor does not collect or use any other information. If you cannot receive HTML, you will not receive a functioning sensor;
• Know how many users open an email and allow our service provider to compile aggregated statistics about an email campaign for us; and
• Allow us to better target interactive advertising, enhance customer support and website usability, and provide offers and promotions that we believe would be of interest to you.
Other personal information