Privacy Policy

SACO is committed to the privacy and confidentiality of your information. This Privacy Policy describes our current policies and practices about our use of personal information.

Please take your time to read this Privacy Policy carefully. When using the SACO website, this Policy should be read alongside the Website Terms and Conditions.

 

  1. About us
  2. Our processing of your personal information
  3. Where you or your employer books a serviced apartment through SACO
  • Where you or your employer books a serviced apartment through one of our Partners
  • When you create a SACO/MyCo account or use the SACO Deloitte portal
  • Where you are a prospective customer and you or your employer submit an enquiry about a SACO or a Partner apartment. 
  • Where you are a SACO Partner or other business partner or service provider to SACO
  • Where you use the SACO website
  1. What marketing activities do we carry out?
  2. Automated Decision-Making
  3. How long do we keep your personal information for?
  4. What is our approach to sending information overseas?
  5. How do we protect your information?
  6. Your rights
  7. Contacting us
  8. Updates to this Policy

 

1. About us

This is the Privacy Policy of SACO The Serviced Apartment Company Limited, which trades as SACO ("SACO"). We are a company registered in England and Wales under registration number 07638220 of 6th Floor, Embassy House, Queen's Avenue, Bristol, BS8 1SB.

SACO is one of the UK’s leading providers of serviced apartments with an extensive network of properties in cities around the world. Our business was born because our founder loved the benefits of apartment living for business and leisure travel, as well as the value, choice and flexibility that simply isn’t available in traditional hotels.

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.

We also use third party apartment providers ("Partners") who supply serviced apartment services to our customers where an apartment is required in areas where SACO does not currently operate or does not have availability. Where you book one of our Partner's serviced apartments, we will use your personal information to book the apartment for you and provide your personal data to the relevant Partner to allow them to prepare the apartment for your arrival and to contact you if there are any issues. For this activity, our Partners are also "controllers" and this Privacy policy covers their processing of your personal data.

Any processing of your personal information by our Partners that is outside the scope of the above will be carried out in accordance with that Partner's Privacy Policy.

 

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.

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.

 

Where you or your employer books a serviced apartment through SACO

This section applies if you or your employer book a SACO 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 SACO.
  • 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 your serviced apartment

  • 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 establish or defend our legal rights.

 

What is the purpose for using your personal information

  • To manage your booking and booking preferences and to provide you with access to the apartment you have booked.
  • To communicate with you in respect of your booking and to answer any queries that you may have.
  • To provide improved quality, training and security (for example, through recorded phone calls to our contact numbers, or carrying out customer satisfaction surveys).
  • To obtain or maintain insurance cover, manage risks or obtain legal advice.

 

Legal grounds for using your personal information

  • It is necessary to enter into or perform your contract.
  • We have a business need (to run our business effectively and provide a high-quality service)
  • It is necessary to enter into or perform your booking contract.
  • We have a business need (to respond to all communications)
  • For business purposes such as operating and improving our website, ensuring the security of our website and services, and maintaining back-ups of our databases
  • We have a business need (to develop and improve the services we offer)
  • We have a business need (to ensure we are adequately insured and have an effective risk strategy in place)

 

Legal grounds for using your special category information

  • Your consent.
  • We need to establish, exercise or defend legal rights.
  • We have a business need (to run an efficient business)
  • We need to establish, exercise or defend legal rights.

 

Who will we share your personal information with?

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:

  • Other companies in the SACO Group, which comprise SACO Property Group, The Serviced Apartment Company Limited, Locke Hotels, The Wittenberg and The Moorgate.
  • 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.

 

Where you or your employer books a serviced apartment through one of our Partners

This section applies if you or your employer books a serviced apartment provided by one of our Partners through SACO.

 

What personal information will we collect?

By SACO 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 SACO.
  • 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.

 

By our Partners on arrival at your serviced apartment

  • Identity documents such as passport, driving licence and national insurance number where our Partners are legally obliged to collect this.
  • Details of your next destination where you provide this to our Partners.
  • Your full name and title.
  • Your unique booking reference number.
  • CCTV recordings of your arrival at the apartment where CCTV is in operation.

 

During or following your stay

  • Any feedback that you provide to SACO, 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 establish or defend our legal rights.

 

What is the purpose for using your personal information

  • To manage your booking and booking preferences and to provide you with access to the apartment you have booked. 
  • To communicate with you in respect of your booking and to answer any queries that you may have.
  • For business purposes such as operating and improving our website, ensuring the security of our website and services, and maintaining back-ups of our databases.
  • To provide improved quality, training and security (for example, through recorded phone calls to our contact numbers, or carrying out customer satisfaction surveys).
  • To obtain or maintain insurance cover, manage risks or obtain legal advice.

 

Legal grounds for using your personal information

  • It is necessary to enter into or perform your contract.
  • We have a business need (to run our business effectively and provide a high quality service).
  • It is necessary to enter into or perform your booking contract.
  • We have a business need (to respond to all communications).
  • We have a business need (to run an efficient business).
  • We have a business need (to develop and improve the services we offer).
  • We have a business need (to ensure we are adequately insured and have an effective risk strategy in place).

 

Legal grounds for using your special category information

  • Your consent.
  • We need to establish, exercise or defend legal rights.

 

Who will we share your personal information with?

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:

  • Other companies in the SACO Group, which comprise SACO Property Group, The Serviced Apartment Company Limited, Locke Hotels, The Wittenberg and The Moorgate.
  • 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.

 

Where you or your employer books a serviced apartment through one of our Partners

This section applies if you or your employer books a serviced apartment provided by one of our Partners through SACO. 

 

What personal information will we collect?       

By SACO 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 SACO.
  • 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.

 

By our Partners on arrival at your serviced apartment

  • Identity documents such as passport, driving licence and national insurance number where our Partners are legally obliged to collect this.
  • Details of your next destination where you provide this to our Partners.
  • Your full name and title.
  • Your unique booking reference number.
  • CCTV recordings of your arrival at the apartment where CCTV is in operation.

 

During or following your stay

  • Any feedback that you provide to SACO, 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 SACO and our Partners collect your personal information?

SACO

SACO will collect your personal information directly from you:

  • When you book a Partner managed serviced apartment with SACO via email, live chat or over the telephone;
  • During any subsequent communications we have with you, such as by email, live chat or telephone, or when you make a general enquiry.

 

SACO will also collect your personal information from your employer, if an enquiry is made by your employer on your behalf.

 

SACO will also collect your personal information from our Partner in relation to your stay at the Partner's apartment where this is relevant, for example in relation to any issues with your stay.

 

Partners

Our Partners will collect personal information directly from you:

  • When you arrive at the Partner apartment;
  • When you report any incidents or issues to the Partner.

 

Our Partners will collect personal information from SACO when SACO passes them the details of your booking.

 

What will SACO and our Partners use your personal information for?

We use your information for the following legal reasons depending on your circumstances.

 

SACO:

  • We need to use your personal information to enter into the booking contract with you. We will rely on this 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 your 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 establish or defend our legal rights.

 

Our Partners

  • Our Partners have a business need to use your personal information, for example to communicate with you and to answer any queries or deal with any issues you may have during your stay. When relying on this legal ground, our Partners are under a duty to assess your rights and to ensure that they do not use your information unless they can demonstrate a legitimate business need.
  • Our Partners have a legal or regulatory obligation to use your personal information. For example, in certain countries our Partners have legal obligations to charge visitors taxes and to record your onward destination.

 

What is the purpose for using your personal information?

  • To manage your booking and booking preferences and to provide you with access to the apartment you have booked. 
  • To communicate with you in respect of your booking and to answer any queries that you may have.
  • To comply with legal or regulatory obligations, for example to record payments of tourist taxes.
  • To obtain or maintain insurance cover, manage risks or obtain legal advice.
  • To provide improved quality, training and security (for example, through recorded phone calls to our contact numbers, or carrying out customer satisfaction surveys).
  • For business purposes such as operating and improving our website, ensuring the security of our website and services, and maintaining back-ups of our databases.

 

Legal grounds for using your personal information

  • It is necessary to enter into or perform your contract.
  • We have a business need (to run our business effectively and provide a high quality service).
  • It is necessary to enter into or perform your booking contract.
  • We and have a business need (to respond to all communications).
  • Our Partners have a legal obligation
  • We and our Partners have a business need (to ensure we are a adequately insured and have an effective risk strategy in place).
  • We and have a business need (to develop and improve the services we offer).
  • We have a business need (to run an efficient business).

 

Legal grounds for using your special category information

  • Your consent.
  • We need to establish, exercise or defend legal rights.

 

Who will we share your personal information with?

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:

 

SACO

  • With our Partners to help manage your booking.
  • Other companies in the SACO Group, which comprise SACO Property Group, The Serviced Apartment Company Limited, Locke Hotels, The Wittenberg and The Moorgate.
  • Service providers we have contracted with including 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.

 

Our Partners

  • With SACO where our Partners are required to report information about your stay or their management of an incident in which you were involved at a Partner apartment.

 

When you create a SACO/MyCo account or use the SACO Deloitte portal

This section applies where you sign up to create a SACO account or a MyCo account, or where you use the SACO Deloitte portal.

 

What personal information will we collect?

SACO account:

  • Name, title, address, phone numbers, email addresses, details of your recent trips, payment details.

MyCo account:

  • Your name, job title, business contact details and details of your recent trips.

SACO Deloitte portal:

  • Your name, job title and business contact address

 

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:

  • Create a SACO/MyCo account or book through the SACO Deloitte portal;

Contact us in respect of the management of your SACO/MyCo account or use of the SACO Deloitte portal. From your employer where you have authorised them to create an account or make ab booking on your behalf.

 

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 managing your account and assisting you with any enquiries that you have. 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 establish or defend our legal rights.

 

What is the purpose for using your personal information

  • To set up and manage your account  
  • To communicate with you in respect of your account and any bookings that you make

 

Legal grounds for using your personal information

  • We have a business need (to run our business effectively and provide a high quality service)
  • It is necessary to enter into or perform your booking contract.
  • We have a business need (to respond to all communications).
  • For business purposes such as operating and improving our services and ensuring the security of your account.
  • For business purposes such as operating and improving our services and ensuring the security of your account.

 

Legal grounds for using your special category information

  • Your consent.
  • We need to establish, exercise or defend legal rights.
  • We have a business need (to run an efficient business).

 

Who will we share your personal information with?

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:

  • Other companies in the SACO Group, which comprise SACO Property Group, The Serviced Apartment Company Limited, Locke Hotels, The Wittenberg and The Moorgate.
  • Service providers we have contracted with including 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.

 

Where you are a prospective customer and you or your employer submit an enquiry about a SACO or a Partner apartment. 

This section applies if you contact us with a query about booking a SACO or a Partner apartment,

What personal information will we collect?

  • Your name and title, address, telephone numbers and email addresses.
  • Your intended travel arrangements and any information that you provide us in relation to your booking preferences.
  • Recordings of telephone calls we make when you contact us by telephone.

 

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:

  • Contact us by email, live-chat or over the telephone with your query.

 

What will we use your personal information for?

We use your information for the following legal reasons:

  • We have a business need to use your personal information. This will include for the purpose of responding to your enquiries and assisting you with the booking process. 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 establish or defend our legal rights.

 

What is the purpose for using your personal information

  • To communicate with you in respect of your intended booking and to answer any queries that you may have.
  • To provide improved quality, training and security (for example, through recorded phone calls to our contact numbers).

 

Legal grounds for using your personal information

  • We have a business need (to respond to all communications).
  • We have a business need (to develop and improve the services we offer).

 

Legal grounds for using your special category information

  • Your consent.
  • We need to establish, exercise or defend legal rights.

 

Who will we share your personal information with?

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:

  • To our Partners where your query is in relation to a Partner apartment.
  • Other companies in the SACO Group, which comprise SACO Property Group, The Serviced Apartment Company Limited, Locke Hotels, The Wittenberg and The Moorgate.
  • Service providers we have contracted with including 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.

 

Where you are a SACO Partner or other business partner or service provider to SACO

This section applies if you are a SACO Partner, or other business partner or service provider to SACO.

What personal information will we collect?

  • General information such as your name, address, business phone numbers and email addresses.
  • Employment information such as job title, business cards and professional accreditations.
  • Your bank details and information obtained from checking sanction lists and credit checks.
  • Information which we have gathered from publicly available sources such as internet search engines and generally obtained as part of the due diligence process conducted by SACO.

 

How will we collect your personal information?

  • Directly from you.
  • From other companies in the SACO Group, which comprise SACO Property Group, The Serviced Apartment Company Limited, Locke Hotels, The Wittenberg and The Moorgate.
  • From publicly available sources such as internet search engines.
  • From service providers who carry out sanctions checks.

 

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 or perform the contract that we hold with you.
  • We have a valid business reason to use your personal information which is necessary for our everyday business operations and activities, for example to maintain business records and to carry out due diligence. In each case we assess our need to use this personal information for these purposes against your rights to privacy to ensure we are protecting your rights.

 

What is the purpose for using your personal information

  • To carry out due diligence on you
  • For business purposes and activities including to maintain business records and to carry out due diligence.
  • For compliance and monitoring purposes such as recording and managing complaints made against you by our customers.
  • To obtain or maintain insurance cover, manage risks or obtain legal advice.

 

Legal grounds for using your personal information

  • We have a valid business reason (to ensure that you can provide guarantees in terms of confidentiality and security measures you implement to protect the information we are sharing with you about our clients).
  • We have a valid business reason (to run our business efficiently and effectively)
  • We have a valid business reason (to ensure we are carrying out appropriate monitoring activities).
  • We have a business need (to ensure we are an adequately insured and have an effective risk strategy in place).

 

Who will we share your personal information with?

We will not sell or transfer your personal information to anyone unless we have a valid reason as set out above and we will only disclose it to the following parties:

  • Where you are providing a product or services to one of our customers on our behalf.
  • Other companies in the SACO Group, which comprise SACO Property Group, The Serviced Apartment Company Limited, Locke Hotels, The Wittenberg and The Moorgate.
  • Any third parties in the event of a sale, merger, reorganisation, transfer or dissolution of SACO's business.
  • Law enforcement agencies such as the police, HMRC and taxation authorities.

 

Where you use the SACO website

This section applies if you use or access the SACO website.

 

What personal information will we collect?                       

  • Name, address, email address and telephone number where you submit this information to us.
  • IP address and your geographical location.

 

How will we collect your personal information?

We collect your information:

  • Directly from our website and where you have submitted any information on our website.
  • Through our use of cookies. You can find more information about this in our cookies policy here
  • Through the use of Google Analytics.

 

What will we use your personal information for?

We use your information for the following legal reasons:

  • We have a business need to use your personal information, this will include identifying trends on our website, popular pages and areas that we can make it easier to use for customers in order to improve its performance. 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.

 

What is the purpose for using your personal information

  • To identify trends on our website, popular pages and areas that we can make it easier to use for customers to improve its performance.

 

Legal grounds for using your personal information

  • We have a business need (to review and enhance the performance of our website).

 

Who will we share your personal information with?

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:

  • Other companies in the SACO Group, which comprise SACO Property Group, The Serviced Apartment Company Limited, Locke Hotels, The Wittenberg and The Moorgate.
  • Service providers SACO have contracted with including our subcontractors and agents, auditors, our solicitors, actuaries, IT providers and database providers, marketing mailing providers and business suppliers.

 

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@sacoapartments.com. We also collect additional information in connection with your participation in any competitions that we run. 
  • We also use Facebook and LinkedIn marketing services in order to promote our serviced apartments on Facebook and LinkedIn.
  • We do not sell your information to third parties.

 

4. Automated Decision-Making

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.

SACO does not currently undertake automated decision making.

 

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 SACO 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?

SACO 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 SACO 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.

 

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@sacoapartments.com  or by writing to Daniel Carre-Bishop, Group Financial Officer, SACO The Serviced Apartment Company Limited,6th Floor, Embassy House, Queen's Avenue, Bristol, BS8 1SB.

 

10. Updates to this Privacy Policy

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 [here].

 

This Policy was last updated on 25 May 2018.