Rightrooms (Global) Ltd understands that your privacy is important to you and that you care about how your personal data is used and shared online. We respect and value the privacy of everyone who visits and/or makes use of this website, www.rightrooms.co ("Our Site") and will only collect and use personal data in ways that are described here, and in a manner that is consistent with Our obligations and your rights under the law.
Definitions and Interpretation
In this Policy, the following terms shall have the following meanings:
- "Account" means an account required to access and/or use certain areas and features of Our Site;
- "Cookie" means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in section 13, below;
- "Cookie Law" means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003 and applicable United Kingdom data protection and privacy regulation;
- "Personal data" means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us via Our Site or otherwise. This definition shall, where applicable, incorporate the definitions provided in the EU Regulation 2016/679 - the General Data Protection Regulation ("GDPR") and United Kingdom data protection and privacy regulation; and
- "We/Us/Our" means Rightrooms (Global) Ltd.
Information About Us
- Our Site is owned and operated by Rightrooms (Global) Ltd, a limited company registered in England under company number 12010613, whose registered address is Mutual House, 70 Conduit Street, London, W1S 2GF, United Kingdom.
- Our VAT number is 341097808.
- Our Data Protection Officer is Fiona Halton, who can be contacted by email using the contact details below in section 14.
What Does This Policy Cover?
As a data subject, you have the following rights under the GDPR, which this Policy and Our use of personal data have been designed to uphold:
The right to be informed about Our collection and use of personal data;
The right of access to the personal data We hold about you (see section 12);
The right to rectification if any personal data We hold about you is inaccurate or incomplete (please contact Us using the details in section 14);
The right to be forgotten - i.e. the right to ask Us to delete any personal data We hold about you (We only hold your personal data for a limited time, as explained in section 6 but if you would like Us to delete it sooner, please contact Us using the details in section 14);
The right to restrict (i.e. prevent) the processing of your personal data;
The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);
The right to object to Us using your personal data for particular purposes; and
Rights with respect to automated decision making and profiling.
If you have any cause for complaint about Our use of your personal data, please contact Us using the details provided in section 14 and We will do Our best to solve the problem for you. If We are unable to help, you also have the right to lodge a complaint with the United Kingdom's supervisory authority, the Information Commissioner's Office.
For further information about your rights, please contact the Information Commissioner's Office or your local Citizens Advice Bureau.
What Personal Data Do We Collect?
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How Do We Use Your Personal Data?
All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under the United Kingdom data protection and privacy regulation and the GDPR at all times. For more details on security see section 7, below.
Our use of your personal data will always have a lawful basis, either because it is necessary for Our performance of a contract with you, because you have consented to Our use of your personal data (e.g. by subscribing to emails), or because it is in Our legitimate interests. Specifically, We may use your data for the following purposes:
Providing and managing your Account;
Providing and managing your access to Our Site;
Personalising and tailoring your experience on Our Site;
Supplying Our products and services to you (please note that We require your personal data in order to enter into a contract with you);
Personalising and tailoring Our products and services for you;
Replying to emails from you;
Supplying you with emails that you have opted into. You may unsubscribe or opt-out at any time by pressing unsubscribe on any correspondent email, or contact Us using the contact details below in section 14 and requesting it;
Analysing your use of Our Site and gathering feedback to enable Us to continually improve Our Site and your user experience;
With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email with information, news and offers on Our products and services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003 and United Kingdom data protection and privacy regulation.
Third parties whose content appears on Our Site may use third party Cookies, as detailed below in section 13. Please refer to section 13 for more information on controlling Cookies. Please note that We do not control the activities of such third parties, nor the data they collect and use and advise you to check the privacy policies of any such third parties.
You have the right to withdraw your consent to Us using your personal data at any time, and to request that We delete it.
We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Data will therefore be retained for the following periods (or its retention will be determined on the following bases):
We shall as a default keep your data on file for 24 months of your last activity.
You can as a user/potential traveller delete your account at any time, which will delete your data from our database.
How and Where Do We Store and/or Transfer Your Personal Data?
We only keep your personal data for as long as We need to in order to use it as described above in section 6, and/or for as long as We have your permission to keep it.
The security of your personal data is essential to Us, and to protect your data, We take a number of important measures, including the following:
limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality;
procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner's Office where We are legally required to do so;
We may store or transfer some or all of your personal data to countries that are not part of the European Economic Area (the "EEA" consists of all EU member states, plus Norway, Iceland, and Liechtenstein). These including the United Kingdom are known as "third countries" and may not have data protection laws that are as strong as those in the EEA. This means that We will endeavour to take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be under the GDPR as follows:
We share your data within the group of companies of which We are a part. Where this involves the transfer of personal data outside the United Kingdom or the EEA, our group ensures that personal data is protected by requiring all companies within the group to follow the same rules with respect to personal data usage. These are known as "binding corporate rules". More information on binding corporate rules is available from the European Commission.
We may share your data with external third parties that are based outside of the EEA. The following safeguards are applied to such transfers:
We will only transfer your personal data to third countries whose levels of data protection are deemed 'adequate' by the European Commission. More information is available from the European Commission.
We use specific contracts with external third parties that are approved by the European Commission for the transfer of personal data to third countries. These contracts require the same levels of personal data protection that would apply under the Data Protection Legislation. More information is available from the European Commission.
Please contact us using the contact details below in section 14 for further information about the particular data protection mechanisms used by Us when transferring your personal data to a third country.
Do We Share Your Personal Data?
We may share your data with other companies in Our group to supply better services attached to our core business. This includes Our holding company and its subsidiaries.
We may sometimes contract with third parties to supply products and services to you on Our behalf. These may include payment processing, delivery of goods, search engine facilities, advertising, and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law.
We may compile statistics about the use of Our Site including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymised and will not include any personally identifying data, or any anonymised data that can be combined with other data and used to identify you. We may from time to time share such data with third parties such as prospective investors, affiliates, partners, and advertisers. Data will only be shared and used within the bounds of the law.
Any transfers of your personal data to third-party data processors used by Us that are not located within the United Kingdom or the EEA will follow the principles laid out in section 7.
In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal requirements, a court order, or a governmental authority.
What Happens If Our Business Changes Hands?
How Can You Control Your Personal Data?
In addition to your rights under the GDPR and the United Kingdom data protection and privacy regulation, set out in section 4, when you submit personal data to Us via Our Site or otherwise, you may be given options to restrict Our use of your data. In particular, We aim to give you strong controls on Our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails and at the point of providing your details and by managing your Account).
Your Right to Withhold Information
You may access certain areas of Our Site without providing any data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.
How Can You Access Your Personal Data?
You have the right to ask for a copy of any of your personal data held by Us (where such data is held). Under the GDPR, no fee is payable and We will provide any and all information in response to your request free of charge. Please contact Us for more details using the contact details below in section 14.
By using Our Site you may also receive certain third party Cookies on your computer or device. Third party Cookies are those placed by websites, services, and/or parties other than Us. Third party Cookies are used on Our Site for Advertising purposes. For more details, please refer to section 6, above, and to section 13.6 below. These Cookies are not integral to the functioning of Our Site and your use and experience of Our Site will not be impaired by refusing consent to them.
All Cookies used by and on Our Site are used in accordance with current Cookie Law.
Before Cookies are placed on your computer or device, you will be shown a popup or push notification requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling Us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Site may not function fully or as intended.
Certain features of Our Site depend on Cookies to function. Cookie Law deems these Cookies to be "strictly necessary". These Cookies are shown below in section 13.6. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser's settings as detailed below in section 13.10, but please be aware that Our Site may not work properly if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.
The following first party Cookies may be placed on your computer or device:
Name of Cookie Purpose Strictly Necessary _cfduid Used to identify trusted web traffic yes _rightrooms_mvp_session Used to identify user sessions yes
Third party Cookies may be placed on your computer or device by Our service providers, including but not limited to organisations that are assisting us with the operation of our email services, Our chat- and customer support services, and Our marketing services. You can choose not to let Us place third party Cookies on your computer or device, and You are able to at any time delete Cookies on your computer or device
Our Site uses analytics services provided by Google. Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling Us to better understand how Our Site is used. This, in turn, enables Us to improve Our Site and the products and services offered through it. You do not have to allow Us to use these Cookies, however whilst Our use of them does not pose any risk to your privacy or your safe use of Our Site, it does enable Us to continually improve Our Site, making it a better and more useful experience for you.
The analytics service used by Our Site uses the following Cookies to gather the required information:
Name of Cookie Provider Purpose _ga Google Analytics Registers unique ID used to generate statistical data _gat Google Analytics Used to throttle request rate _gid Google Analytics Registers unique ID used to generate statistical data
In addition to the controls that We provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third-party Cookies. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.
It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.
Last updated: 16.11.20