Locke is a new kind of hotel. Beautifully designed, one of a kind and locally inspired. Made to be lived in, not just slept in. Where home meets lifestyle hotel. Work meets life. People connect with themselves, and the community.
As an aparthotel provider, we collect and process data so that we can manage your booking, deal with your booking enquiries, improve your experience when using our website and where relevant, deal with any issues that you may have. This makes us a "controller" of your personal data.
We will collect and use different personal information about you for different reasons, depending on our relationship with you.
Sometimes we will receive “special categories of personal information” (which is information relating to your health, racial or ethnic origin, religious or philosophical beliefs) where you provide this to us as part of a special request in connection with your stay. Where you provide us with your special category personal information we will use this to provide you with advice and to help you find a serviced apartment that is suitable to your needs.
Where you provide personal information to us about other individuals (for example, members of your family or other guests staying in the apartment) we will also be controller of their personal information and we are responsible for protecting their personal information and using it appropriately. This Policy will therefore apply to those individuals and you should refer them to this Policy.
In order to make this Policy as user friendly as possible, we have split it into different sections. Please click on the section below that best describes your relationship with us and the service you receive from us.
This section applies if you or your employer book a Locke serviced apartment.
What personal information will we collect?
At booking stage
- Your full name and title, address, telephone numbers and email addresses, date of birth and gender.
- Identity documents such as passport, driving licence and national insurance number.
- Employment status and related information such as job title.
- Details of your special requests which are relevant to your booking.
- Details of your previous stays or bookings with Locke.
- Vehicle registration number.
- The number of adults and children that will be staying in the apartment with you.
- Details of the payment card that you use to make the booking, including the type of card, expiry date and last four digits.
- Your smoking preferences.
- Recordings of telephone calls we make when you book over the telephone
On arrival at the aparthotel
- Identity documents such as passport, driving licence and national insurance number.
- Details of your next destination if you provide this to us.
- Your full name and title.
- Your unique booking reference number.
- CCTV recordings of your arrival at the apartment.
During or following your stay
- Any feedback that you provide to us, including any complaints that you may have.
What special category information will we collect?
- Information about your health if relevant to your booking (for example whether you have a physical disability that would require you to have wheelchair access to an apartment).
- We will also collect information that you provide to us through a special request as part of your booking where you deem it relevant, for example which reveals or is likely to reveal your race or ethnicity, religious or philosophical beliefs, political views or data concerning your sex life or sexual orientation
How will we collect your personal information?
Directly from you:
- when you book one of our apartments through our website or over email
- when you book one of our apartments over the telephone;
- during any subsequent communications we have with you, such as by telephone, email or live chat or when you make a general enquiry.
- We will also collect your personal information from:
- your employer, if the booking is made by your employer on your behalf.
What will we use your personal information for?
We use your information for the following legal reasons:
- We need to use your personal information to enter into the booking contract with you. We will rely on this legal reason for all activities that are connected to your booking and without using your personal information we would be unable to do, such as confirming your booking details following confirmation of payment.
- We have a business need to use your personal information. This will include for the purpose of operating and improving our website, ensuring the security of our website and services, maintaining back-ups of our databases, and responding to your enquires. When relying on this legal ground, we are under a duty to assess your rights and to ensure that we do not use your information unless we can demonstrate a legitimate business need.
- When we use your “special category information" (such as information about your health), we will ask for your explicit consent. We are also permitted to use your special category information if we need to in order to establish or defend our legal rights.
When you subscribe to our email notifications and/or newsletters we will send you the relevant notifications and/or newsletters – but only if you’ve agreed. You can unsubscribe from this type of communication at any time by clicking the link in the footer of the email, or emailing us on firstname.lastname@example.org. We also collect additional information in connection with your participation in any competitions that we run.
We also use Facebook marketing services in order to promote our serviced apartments on Facebook and Instagram.
We do not sell your information to third parties.
Automated decision making refers to a situation where a decision is taken using personal information that is processed solely by automatic means (i.e. using an algorithm or other computer software) rather than a decision that is made with some form of human involvement.
Locke Hotels does currently undertake automated decision making. We do this in several ways:
- Automatically sending you pre- and post- stay emails based on the dates of your stay.
- Assigning apartments/ apartment types based on any special requirements that have been received (such as a wheelchair accessible room).
- Automatically assigning specific rooms based on arrival date and availability.
- We also may send email communications based on your chosen language; this will be done on an automatic basis.
- Should you stay with us on more than one occasion our systems will tag you as a returning customer. This allows us to offer a more personalised service based on previous stays.
We will only keep your personal information for as long as reasonably necessary to fulfil the purposes set out in Section 3 above and to comply with our legal and regulatory obligations. We set out below examples of the retention periods that we apply:
- Where you book an apartment through one of our Partners, the personal information that we collect from you and from the relevant Partner will be retained for 7 years.
- Where you submit an enquiry through our website but do not proceed to book a Locke Hotels or a Partner apartment, we will retain your personal information for 12 months.
- If you would like further information about how long we will keep your personal information for, please contact us using the details set out in section 9.
We will transfer your personal information outside of the European Economic Area ("EEA") when we transfer information to our Partners located outside of the EEA where you have enquired about that Partner's apartment or are looking to book that Partner's apartment.
We are also entitled under European data protection laws to transfer your personal information to countries outside the EEA in the following circumstances:
It is necessary for the performance of the contract we have with you.
It is necessary to protect your vital interests i.e. it is a life or death situation.
There may also be some instances where your personal information is transferred to countries outside the EEA such as when we transfer information to third party suppliers who are based outside the EEA or when third parties who act on our behalf transfer your personal information to countries outside the EEA.
Where such a transfer takes place, we will take the appropriate safeguarding measures to ensure that your personal information is adequately protected. We will do so in a number of ways including:
Entering into data transfer contracts and using specific contractual provisions that has been approved by European data protection authorities otherwise known as the "standard contractual clauses";
Transferring personal data to companies in the United States who are certified under the "Privacy Shield". The Privacy Shield is a scheme whereby companies certify that they provide an adequate level of data protection;
We will only transfer personal data to companies in non-EEA countries who have been deemed by European data protection authorities to have adequate levels of data protection for the protection of personal information.
If you would like further information regarding our data transfers and the steps we take to safeguard your personal information, please contact us using the details set out in section 9.
Locke Hotels ensure that all our systems are protected using secure passwords and multi-factor authentication mechanisms. All customer data is held within secure data centres using industry standard protection and encrypted where applicable. All data access is segmented by role and user rights.
You have several data protection rights which entitle you to request information about your personal information, to dictate what we do with it or to stop us using it in certain ways.
If you wish to exercise the rights set out below, please contact us at any time using the details set out in section 9. There will not normally be a charge for this.
We respect your rights in relation to personal information we hold about you, however we cannot always comply with your requests, for example:
We may not be able to delete your information if we are required by law to keep it for a longer period of time; or
If we delete your information we would not have the necessary information we need to complete your booking or manage your Locke Hotels account.
The right to access your personal information
You can request a copy of the personal information we hold about you and certain details of how we use it.
Your personal information will normally be provided to you in writing unless you request otherwise or where you have made a request by electronic means such as email, we will provide such information in electronic form where possible.
The right to withdraw your consent
Where we rely on consent as the legal ground to use your personal information, you are entitled to withdraw that original consent.
The right to rectification
We make reasonable efforts to keep your personal information where necessary up to date, complete and accurate. We encourage you to ensure that your personal information is accurate so please regularly let us know if you believe that the information we hold about you may be inaccurate or not complete. We will correct and amend any such personal information and notify any third party recipients of necessary changes.
The right to restriction of processing
Subject to the circumstances in which you exercise this right, you can request that we stop using your personal information, such as where you believe that we no longer need to use your personal information.
The right to data portability
Subject to the circumstances in which you exercise this right, you can request that we port across personal information you have provided to us to a third party in a commonly used and machine-readable format.
The right to erasure
You can request that we delete your personal information. For example, where we no longer need your personal information for the original purpose we collected it for or where you have exercised your right to withdrawn consent.
Whilst we will assess every request, this request is subject to legal and regulatory requirements that we are required to comply with.
The right to object to direct marketing
You can request that we stop sending you marketing messages at any time by clicking on the "unsubscribe" button in any emails that we send to you or by contacting us using the details set out in section 9.
Please note that even if you exercise this right because you do not want to receive marketing messages, we may still send you service related communications where necessary.
You can complete a data request form here.
The right to make a complaint with the ICO
Where you believe that we have breached data protection laws when using your personal information, you can complain to the Information Commissioner's Office (ICO). For more information visit the ICO's website. Please note that exercising this right and lodging a complaint will not affect any other legal rights or remedies that you have.
If you would like further information about the ways we use your personal information, further clarity on how we use your personal information or anything referred to in this Policy, please contact our Group Financial Officer at email@example.com or by writing to Daniel Carre-Bishop, Group Financial Officer, Edyn Limited,6th Floor, Embassy House, Queen's Avenue, Bristol, BS8 1SB.
We are continually improving our methods of communication and alongside with changes in the law and the changing nature of technology, our data practices and how we use your data will change from time to time. If and when our data practices change, we will notify you and we will provide you with the most up-to-date Policy. You can view it by checking back here - www.lockeliving.com.
- We do not share or distribute your personal information other than to the following third parties and only under the limited circumstances we have set out above:
- Service providers we have contracted with including payment service providers, our subcontractors and agents, auditors, our solicitors, actuaries, IT providers and database providers, marketing mailing providers and business suppliers.
- Any third parties in the event of a sale, merger, reorganisation, transfer or dissolution of our business.
- Law enforcement agencies such as the police, HMRC and taxation authorities.
This Policy was last updated on 16th September 2019.