INTRODUCTION AND SCOPE OF THIS PRIVACY STATEMENT

Data Controller: Vittrum Limited, trading as Vittrum Serviced Apartments, 20 Brunswick Place, Southampton, SO15 2AQ

ICO Reference Number: ZA444522

Telephone: 02380 016316    Email: info@vittrum.com

Vittrum Limited, trading as Vittrum Serviced Apartments, together “we” or “us”, want to give you the best customer experience possible. We will collect and use the personal information you share with us to fulfil our legal obligations and as part of our legitimate business interest.
This privacy statement aims to give you a clear view of how we use personal information that you provide, our dedication to protecting it, your rights and the options you have to control your personal information and protect your privacy. It also outlines what personal information we collect about you when you visit our website, office or when you get in contact with us via email or phone, how we use your personal information and the third parties we will share it with. We use personal information for various purposes, as described in detail below:

WHO COLLECTS YOUR PERSONAL INFORMATION
Vittrum Limited, controls the processing of any personal information collected from you as described above and below in this privacy statement. Vittrum Limited has its offices at 20 Brunswick Place, Southampton, Hampshire, SO15 2AQ, England.

PERSONAL INFORMATION WE COLLECT FROM YOU
“Personal information” is any information that relates to you and identifies you personally, either alone or in combination with other information available to us. Vittrum will collect various types of personal information needed so that we can help you find a serviced apartment. All personal information collected relating to transactions will (unless otherwise requested) be kept for the legal minimum required period of 6 years on our computer system. We will not share your personal data with any other third party not connected to the company without your explicit consent.

USE OF OUR SERVICES
When you use our services, and contact us via phone, email, or book through our homepage or visit our office, we will ask for personal information (at the moment of collection we will explain what information is required in order for us to provide the particular service, and what information you may choose to provide), as described below:

REGISTERING WITH US
You can register with us through our webpage: www.vittrum.com, by calling, emailing or visiting our office, or by conducting a property search on one of the accommodation portals we use and consequentially requesting more information on serviced apartments that we market online. If you choose to sign up with us, we will use your contact details to contact you in response to any inquiries you have made and to send you related information on the serviced apartment or similar properties that suit your search criteria. We will also use your registration information to contact you to verify your username and password if you sign up on our “My Account” service to create and manage your account. In addition, we will use any information you provide voluntarily to us in free text boxes to understand your preferences and to improve our services. It is necessary for the purposes of our legitimate business interests to undertake this analysis and to provide you with the best services possible.

FOR NEW BOOKING ENQUIRIES
If you have secured a service apartment via ourselves, we will ask for your permission so we can contact you in the future via phone and email. We will also ask you if we can send you relevant marketing information. We will keep a record of our correspondence with you, including any feedback you have provided on a property or on any of our services. All information is held on our back-office software systems. We will hold and process your personal data for the purposes of processing your request for a serviced apartment.

RIGHT TO DELETION
You have the right to request that all your personal data we hold is deleted. Such a request can be sent to the above address or email, where we will confirm deletion or if not possible, explain the legitimate or lawful reasons why such a request cannot be actioned within 7 working days of receipt.

RIGHT TO RECTIFICATION
You have the right to request that we amend any personal data we hold for you if you believe it is incorrect. Such a request can be sent to the above address or email, where we will confirm rectification or if not possible, explain the legitimate or lawful reasons why such a request cannot be actioned within 7 working days of receipt.

SUBJECT DATA ACCESS REQUEST
You have the right to request at any time, confirmation of the actual personal data we hold for you, and how this has been processed. Such a request can be sent to the above address or email which will be actioned within 7 working days of receipt.

COMPLAINT
In the first instance, if you have any complaint about how we hold or process your personal data, then please contact us at the above address or email. If you are still dissatisfied with our response, then you have the right to contact the Information Commissioners Office (ICO) at the following website https://ico.org.uk/ quoting our ICO registration number which can be found above.

INFORMATION WE COLLECT AUTOMATICALLY ONLINE
We will also collect personal information about you when you interact with our brand and websites and how you use them, as follows:

WEBSITE
Our website will collect personal information in this way, such as: your IP address, the date and time of the visit and how long you remained on our website, the referral URL (the site from which the visitor has come), the pages visited on our website, and information about the device and browser (such as, browser type and version, operating system, etc).

COOKIES AND SIMILAR DEVICES
We and our partners use various technologies to collect and store information when you visit our websites or use our apps, and this will include sending one or more cookies or other similar devices to your device. Click here for more information about our use of cookies and similar devices and how to disable them.

HOW WE USE YOUR PERSONAL INFORMATION
Vittrum Limited will create a profile for you with the information needed to provide you with our services. The personal information we collect from you as described above will be used so that we can analyse it where necessary for the following purposes detailed below:

• IMPROVING OUR SERVICES
  We will use your personal information to build a profile on you in order to understand how you use our services, to develop more interesting and relevant services, to improve our website, as well as to personalise the services we offer you. We process your personal information in this way as it is necessary for the purposes of our legitimate business interests in providing better services for you and our other customers.
• PROCESSING YOUR PAYMENTS
  We use relevant personal information, including your name, address and payment details, to process your payments, and to notify you of the status of your payments.
• PREVENTING FRAUD/MONEY LAUNDERING
  As part of the money launder legislation and security compliance we may require a proof of ID of Guests.
• TO PROVIDE CUSTOMER SUPPORT
  If you contact our customer support team (or if we contact you), we will use personal information such as your contact details and contact history to process your request and provide you with the best service possible. We will process your personal information in this way if it is necessary for the performance of a contract with Vittrum or if it is required for us to comply with any legal obligations. If it is not necessary to process your personal data for either of these reasons, we will process it as it is necessary for the purposes of our legitimate business interests in ensuring we can provide the best service possible.

MARKETING, PROMOTIONAL MATERIAL AND INFORMATIVE MATERIAL
To engage with you in relation to the promotional material and informative material we distribute electronically or by post we will use your personal information to provide you with the services you have requested from us. This will, if applicable, include the use of your personal information and your serviced apartment search criteria and subscription preferences. We will process your personal information in this way if it is necessary for the performance of a contract with Vittrum Limited. If it is not necessary for the performance of such a contract, we will process it as it is necessary for the purposes of our legitimate interests in providing these services appropriately and ensuring they function correctly. You can opt-in and opt-out using the link provided.

GENERAL MARKETING
You will be asked to opt-in before we contact you for marketing purposes. You can opt-in and opt-out through your My Account settings page or by clicking on the opt-in/opt-out link provided on all electronical marketing material we may send you. You can also update your preference setting on your My account page or on any of the newsletter or similar marketing material we send you. You can also contact us using the contact details set out above. If you have given us your consent to send you marketing communications or if we are permitted by law to send such communications without obtaining your consent, we use the information that you have provided to us when interacting with us for sending you personalised marketing messages about our services, events, promotions etc.

WHAT KIND OF CHANNELS
We will send direct marketing communications to you via the channel you choose, such as email, phone, sms, or social media. We ask for your consent, where required by applicable law, in order to use the contact details you have provided to us to send our personalised marketing communications.

WHAT KIND OF MESSAGES
The messages we will send you will be personalised and tailored to your individual preferences and interests. You can update your preferences at any time on the links provided. These direct marketing messages may contain information about our services, events, or promotions and news. We personalise these messages on the basis of that it is necessary for the purposes of our legitimate interests in ensuring that we provide the most appropriate information. We will, in certain circumstances, also use the channels for opinion research (such as to ask if you would like to participate in a survey) and to learn about your experience and improve your experience with us, including by sending you personalised messages.

RE-TARGETING
Our website use re-targeting technologies, which we will only use after you have provided your consent. This enables us to show our visitors, who were already interested in our services, advertisements from us on partner websites. We believe that the display of personalised, interest-based advertising is more interesting and relevant to our customers than advertising that does not have a personal connection. Re-targeting technologies analyse the information we collect about your interactions with our platform as described in relation to marketing above and information obtained from other parties, including your cookies, and display advertisements based on your past web-surfing behaviour. We will process your data for re-targeting purposes with your explicit consent. Please click here for further information on cookies and instructions on how to disable re-targeting.

ADS
We work with non-Vittrum companies who use tracking technologies to serve ads on our behalf across the Internet. These companies may collect personal information about your visits to our website and your interaction with our communications, including advertising. They will only collect this information to the extent you have consented to the placement of cookies for marketing purposes. Please click here for further information on cookies and instructions on how to change your cookie preferences.

OTHER PURPOSES
We will ask for your consent if we wish to use your personal information for purposes other than those listed in this privacy statement and as required to do so under applicable law. We will not use your personal information for other purposes before we have received such consent.

HOW WE SHARE YOUR PERSONAL INFORMATION
We treat your personal information with care and confidentiality and do not share it with third parties other than as set out within this privacy statement and explained below:

• WITH LEGAL AND LAW ENFORCEMENT
  We will disclose personal information where required by law or legal process, for the administration of justice, to protect your vital interest, for investigations by law enforcement or regulatory bodies, to protect and defend our property and legal rights, to protect the personal safety of our website users or by order of a valid injunction from a court or law enforcement agency.
• HOW WE PROTECT YOUR PERSONAL INFORMATION
  We are committed to protecting your personal information and implement appropriate technical and organisational security measures to protect it against any unauthorised or unlawful processing and against any accidental loss, destruction, or damage.
• INTERNATIONAL TRANSFERS OF YOUR PERSONAL INFORMATION
  Unless stated otherwise, we store and process your personal information in the European Union. There will, however, be occasions when we need to transfer your personal information outside of the European Economic Area (“EEA”) to a country is not regarded under European Law as providing the same level of data protection as the country in which you normally use our products and/or services. For example, if a reference you have provided doesn’t live in the European union. Some of the servers that our software providers use may also be outside of the European Union.
• INFORMATION ABOUT CHILDREN
  As a general rule, we do not enter into contracts or intentionally collect personal information about children/minors under the age of 18 except for their name and age if they are staying at one of our serviced apartments. If we become aware that we have inadvertently collected personal information about someone under the age of 18, we will take steps to delete the information as soon as possible, except where we are required by applicable law to keep it.

LINKS TO OTHER WEBSITES AND SERVICES

Our websites may contain links to third party websites, and some of our services provide you with access to third party services (such as social networks). We have no control over how third party websites and services process your personal information. We do not review third party websites and services, and we are not responsible for such third party websites and services or their privacy practices. Please read the privacy statements of any third party websites or services that you access from our websites or services.

OPTING OUT AND UNSUBSCRIBING FROM MARKETING MESSAGES
All our marketing communications contain an easy way to opt out from receiving future messages, such as a link through which you can unsubscribe. You may also opt out for particular channels (for example phone or SMS) as indicated in the message received in such channel or through your account settings. If you would like to opt out of receiving marketing messages you may use the unsubscribe link contained in the messages you have received, or alternatively you could contact us on: info@vittrum.com

LIST OF 3RD PARTIES
Contractors such as cleaning companies, handyman, plumbers, and electricians who may need to access the property during your stay
Back office software providers, IT companies who support our website and other business systems. Direct marketing companies who help us manage our electronic communications with you. Google/Facebook to show you products that might interest you while you’re browsing the internet. This is based on either your marketing consent or your acceptance of cookies on our websites. See our Cookie policy for details.

CHANGES TO THIS POLICY
At Vittrum we work hard to adhere to the fundamental principles of privacy and data protection. We therefore regularly review our online privacy statement in order to ensure that it is free of errors and clearly visible on our website, that it contains appropriate information about your rights and our processing activities, and that it is implemented and is compliant with applicable law. We may update this privacy statement from time to time to keep it up to date, to keep pace with new developments and opportunities relating to the Internet and to stay in line with applicable law.

TRANSFER OF DATA
We reserve the right to transfer your personal data to a new owner or controlling party should any part of the company ever be sold or transferred in the future.

CONTACT INFORMATION
If you have any questions about our use of your personal information, how to exercise your rights or about our privacy statement you are welcome to contact us at: info@vittrum.com
If you prefer to contact us by regular mail, please send your request to the following address:
Vittrum Limited, 20 Brunswick Place, Southampton, SO15 2AQ