The elbowroom escape Ltd Privacy Policy

This Privacy Statement was published May 25th, 2018.

 

The elbowroom escape team are committed to protect and respect your privacy in compliance with EU- General Data Protection Regulation (GDPR) 2016/679, dated April 27th 2016. This privacy statement explains when and why we collect personal information, how we use it, the conditions under which we may disclose it to others and how we keep it secure. This Privacy Statement applies to the use of our products and to our sales, marketing and customer contract fulfillment activities. It also applies to individuals seeking a job in The elbowroom escape.

Who are we?


The elbowroom escape is a multifunctional boutique venue and guest house.

Our headquarters’ registered office address is Donard, Co.Wicklow

The elbowroom escape Ltd is the data controller and our Data Protection Officer can be contacted by email: unsubscribe@the-elbowroom.com.

When do we collect personal data about you?


  • When you are using our products or services.
  • When you interact with us in person, through correspondence, by phone, by social media, or through our website.
  • When we collect personal information from other legitimate sources, such as social networks. We only use this data if you have given your consent to them to share your personal data with others.
  • We may collect personal data if it is considered to be of legitimate interest and if this interest is not overridden by your privacy interests. Before data is collected we make sure an assessment is made, ensuring that there is an established mutual interest between you and The escape elbowroom Ltd.

Why do we collect and use personal data?


We collect and use personal data mainly to perform customer service, direct sales & direct marketing. We also collect data about suppliers, partners, and persons seeking a job or working in our company.

We may use your information for the following purposes:

  • Send you marketing communications which you have requested. These may include information about our products and services, events, activities. This communication is subscription based and requires your consent.
  • Send you information about the products and services that you have purchased from us.
  • Perform direct sales activities in cases where legitimate and mutual interest is established.
  • Provide you content and venue details on events or appointments you signed up for.
  • Reply to a ‘Contact me’ or other web forms you have completed on one of our elbowroom escape website.
  • Follow up on incoming requests (customer support, emails, chats, or phone calls).
  • Perform contractual obligations such as order confirmation, license details, invoice, reminders, and similar.
  • Notify you about any disruptions to our services (system messages).
  • Contact you to conduct surveys about your opinion on our products and services.
  • Process a job application.

Our legal basis for collecting personal data


Collecting personal data based on consents

The collection of personal data based on consent from the data subject will be done by using “Consent Forms” that will store documentation related to the consent given by the individual. Individual consents will always be stored and documented in our systems.

Collecting personal data based on contracts

We use personal information for fulfilling our obligations related to contracts and agreements with customers, partners, and suppliers.

Collecting personal data based on legitimate interest

We may use personal data if it is considered to be of legitimate interest and if the privacy interests of the data subjects do not override this interest. Normally, to establish the legal basis for data collection, an assessment has been made during which a mutual interest between The elbowroom escape and the individual person has been identified. This legal basis is primarily related to our sales and marketing purposes. We will always inform individuals about their privacy rights and the purpose for collecting personal data.

What type of personal data is collected?


We collect name, phone number, title, date of birth and email address. We may also collect feedback, comments, and questions received from you in service-related communication and activities, such as meetings, phone calls, documents, and emails. From our website, we may collect IP-address and actions taken on the site.

If you apply for a job at The elbowroom escape, we collect the data you provide during the application process.

The elbowroom escape does not collect or process any special categories of personal data, such as public unique identifiers or sensitive personal data.

How long do we keep your personal data?


We store personal data for as long as we find it necessary to fulfill the purpose for which the personal data was collected, while also considering our need to answer your queries or resolve possible problems, to comply with legal requirements under applicable laws, to attend to any legal claims/complaints, and for safeguarding purposes.

This means that we may retain your personal data for a reasonable period of time after your last interaction with us. When the personal data that we have collected is no longer required, we will delete it in a secure manner. We may process data for statistical purposes, but in such cases, data will be anonymized.

Your rights to your personal data


You have the following rights with respect to your personal data:

  • The right to request a copy of your personal data that The elbowroom escape holds about you.
  • The right to request that The elbowroom escape corrects your personal data is inaccurate or out of date.
  • The right to request that your personal data is deleted when it is no longer necessary for The elbowroom escape to retain such data.
  • The right to withdraw any consent to personal data processing at any time. For example, your consent to receive e-marketing communications:
    • If you want to withdraw your consent to e-marketing, please make use of the link to manage your subscriptions included in our communication. Please note that you may still receive system messages and administrative communications from The elbowroom escape, such as appointment confirmations, system messages, and notifications about your account activities.
  • The right to request that The elbowroom escape provides you with your personal data and, if possible, to pass on this information directly (in a portable format) to another data controller when the processing is based on consent or contract.
  • The right to request a restriction on further data processing, in case there is a dispute in relation to the accuracy or processing of your personal data.
  • The right to object to the processing of personal data, in case data processing has been based on legitimate interest and/or direct marketing.

Any query about your Privacy Rights should be sent to unsubscribe@the-elbowroom.com

The use of cookies and beacons


We use cookies and web beacons (‘Website Navigational Information’) to collect information as you navigate the company’s website. Website Navigational Information includes standard information from your web browser, such as browser type and browser language; your Internet Protocol (“IP”) address; and the actions you take on the company’s websites, such as the web pages viewed and the links clicked.

This information is used to make websites work more efficiently, as well as to provide business and marketing information to the owners of the site, and to gather such personal data as browser type and operating system, referring page, path through site, domain of ISP, etc. for the purposes of understanding how visitors use a website. Cookies and similar technologies help us tailor our website to your personal needs, as well as to detect and prevent security threats and abuse. If used alone, cookies and web beacons do not personally identify you.

Do we share your data with anyone?


We do not share, sell, rent, or trade your information with any third parties without your consent, except what is described below:

If required by law:

We will disclose your personal information if required by law or if we, as a company, reasonably believe that disclosure is necessary to protect our company’s rights and/or to comply with a judicial proceeding, court order or legal process. However, we will do what we can to ensure that your privacy rights continue to be protected.

Use of sub-contractors (processors and sub-processors)

We may use sub-contractors to process personal data on our behalf, we are responsible for making sure they commit themselves to adhere to this Privacy Policy and applicable data protection legislation by signing a Data Processing Agreement.

If the sub-contractor processes Personal Data outside the EU/EEA area, such processing must be in accordance with the EU Privacy Shield Framework, EU Standard Contractual Clauses for transfer to third countries, or another specifically stated lawful basis for the transfer of personal data to a third country.

If a new subcontractor is signed or a change of subcontractor is performed related to our CRM Online service, the customers will be notified in line with our Terms of Service. A directory of approved sub-processors is available below.

Cloudbeds – A property management software that helps hotels, hostels, vacation rentals and inns save time and automate operations. Here is a detailed explanation of how the Cloudbeds Privacy Shield requirements align with the new GDPR guidelines

https://myfrontdesk.cloudbeds.com/hc/en-us/articles/360004950793-Cloudbeds-GDPR-and-Data-Privacy-Commitments

Stripe – Online payment processing for internet businesses. Stripe is a suite of payment APIs that powers commerce for online businesses. Here is a detailed explanation of how the Stripe Privacy Shield requirements align with the new GDPR guidelines

https://stripe.com/privacy-shield-policy
 

Booking.com – is an American company that owns and operates several travel fare aggregators and travel fare metasearch engines including namesake and flagship Booking.com . Here is a detailed explanation of how the Bookling.com Privacy Shield requirements align with the new GDPR guidelines

https://info.suite.booking.com/gdpr-updates-en

Hostelworld – is the largest online hostel-booking platform.Here is a detailed explanation of how the Hostelworlds Privacy Shield requirements align with the new GDPR guidelines.

https://www.hostelworld.com/securityprivacy.php

MailChimp – MailChimp is a marketing automation platform and an email marketing service. Here is a detailed explanation of how the MailChimp’s Privacy Shield requirements align with the new GDPR guidelines https://mailchimp.com/legal/privacy/?_ga=2.34292647.768341854.1526915394-1495087025.1498148478

 

Changes to this Privacy Statement


The elbowroom escape reserves the right to amend this Privacy Statement at any time. The applicable version will always be found on our websites. We encourage you to check this Privacy Statement occasionally to ensure that you are happy with any changes.

If we make changes that significantly alter our privacy practices, we will notify you by email or post a notice on our websites prior to the change taking effect.

Your right to complain with a supervisory authority


If you are unhappy with the way in which your personal data has been processed, you may, in the first instance, contact unsubscribe@the-elbowroom.com

If you remain dissatisfied, then you have the right to apply directly to the Data Protection Commissioner Canal House Station Road Portarlington  R32 AP23 Co. Laois.