1. About us ►
Locke is a design led aparthotel for those who want to challenge the status quo and experience the unique and authentic. Locke immerses you in its neighbourhood’s culture through spaces that connect you to a community of like-minded locals and travellers.
Locke – aparthotels for the modern traveller.
As a serviced apartment 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.
2. Our processing of your personal information ►
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
On arrival at your serviced apartment
During or following your stay
What special category information will we collect? ►
How will we collect your personal information? ►
Directly from you:
What will we use your personal information for? ►
We use your information for the following legal reasons:
3. What marketing activities do we carry out? ►
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 email@example.com. 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:
5. How long do we keep personal information for? ►
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.
6. What is our approach to sending your personal information overseas ►
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. You can find out more about this [here].
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.
7. How do we protect your information? ►
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.
8. Your 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 download our data request forms here. Please download the forms, complete them and either upload the form on the page, or send with a copy of your valid photo ID to firstname.lastname@example.org.
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 at https://ico.org.uk/. Please note that exercising this right and lodging a complaint will not affect any other legal rights or remedies that you have.
9. Contacting us ►
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 DCarre-Bishop@edyngroup.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 our website www.lockeliving.com.
This Policy was last updated on 16th September 2019.
Who will we share your personal information with? ►