PRIVACY POLICY

Privacy Policy
Date of Last Revision: 17 May, 2018

This policy describes our practices when using personal information of:

our website (www.33nights.com) users and online customers;
other individuals, including the representatives of our business customers and suppliers (“business contacts”).
This policy will apply whether you have provided the information directly to us or we have obtained it from a different source, such as a third party.

We respect your privacy and we value the trust you’ve placed in us by sharing your information. This privacy policy sets out the way we use your information:

what we collect;
how we collect it;
how we use it;
why we use it;
who we share it with; and
the rights to which you may be entitled.

If you have any questions or anything in this policy is unclear, please get in touch at the following email address: info@33nights.com

DATA COLLECTION AND USAGE
We will collect and use your personal information for purposes set out in more detail in this section.

Your information may be shared with members of our group and some third parties as is set out in more detail below.

What we collect

Information that you give us to make a booking, including your contact details; your name, address, email address, the product/service purchased and your payment details.

How we use your data

We use this information to:

  • ·  Offer our products and services
  • ·  Manage and administer our services
  • ·  Process your booking
  • ·  Take payment from or give you a refund
  • ·  On-board you as a customer
  • ·  Help us ensure that our customers are genuine and to prevent fraud
  • ·  Provide an electronic copy of your booking confirmation and/or receipt
  • ·  Ask for feedback from on your recent purchase(s)

    Information about the way you use our services​ including the things that we’ve provided or you’ve purchased, when you’ve made the purchases\ and what you paid and how.

    How we use your data

    · Develop new services based on what we learn from your activity and the activity of other customers

    · Improve our services and efficiency of service delivery to help us meet your needs and expectations

    · Identify products, marketing and events that may be of interest to you

    · Personalise our service to you: to provide you with/make available, based on your activity and feedback

    · Statistical analysis and research with the purpose of allowing us to better understand the breakdown of our customers, the products/services being bought, the demographics of those buying our products/services, what attracts our customers to our products/services, where our customers have come from online (such as from links on other websites or advertising banners), and the way in which our website is used by different users groups

    Information when you communicate with us whether in person, through our website or via email, over the phone, through social media or via any other medium, including:

    · Your contact details (this may include your social media account if that’s the way you communicate with us

    · The details of your communications with us (including when you sent it, when we received it and where you sent it from (such as our website, via email, through social media)

· The details of our messages to you.

​We use this information to:

· Answer any issues or concerns

· Monitor customer communications for quality and training purposes

· Source new services which is based on the information/feedback you provide

· Improve our services based on the information and feedback you provide and the information and feedback provided by others which is similar to your information and feedback

· Personalise our service to you to take account of the information and feedback you have provided.

Information that we collect through your use of our website including:

· Device information such as operating system, unique device identifiers, the mobile network system; Hardware and browser settings

· Date and time of requests

· The requests you make

· The pages you visit on our website and search engine terms you use

· Provide and adapt our services to take account of the technical capabilities of our users

We use this information to:

· Develop new services based on the information being collected, the behaviours of our users and the technical capabilities of our users

· Improve our services to better suit the behaviours and technical capabilities of the users of our service · Identify issues with the website and user’s experience of it

· Monitor the way our website is used (including locations it is accessed from, devices it is accessed from, understanding peak usage times and analysing what functionality and information is most and least accessed).

Information that we collect from third party partners​, which includes: · Payment processing companies
· Your bank
We use this information​ to:

· Provide our services
· Manage and administer our systems
· Take payment from or give you a refund
· Help us ensure that our customers are genuine and to prevent fraud

· Personalise our service to you by complementing your behaviours and preferences

· Statistical analysis and research into our customer so that we can better understand our customers and allow us to develop and improve our services to meet the needs and preferences of our customers; and

· Combine this information with other types of information mentioned above to create holistic profile of our customers which allows us to make our services more personal and tailored to each customer’s preferences and habits.

Information that we collect incidentally from other sources or public sources​, including: · Information available in the media

· Information presented on our social media or wider social media platforms including Facebook and Instagram

We use this information​ to:
· Maintain market awareness
· Build and maintain social media branding

Information that we collect about our business contacts:

· Name and title, contact details, company name, business title, email address

· Communications with our business contacts

We use personal information about our business contacts to:

· Facilitate the smooth running of the business through communications with corporate customers and suppliers, for example, to communicate about the goods and services we receive from suppliers

· Invite our business contacts to events and exhibitions
· Carry out internal analysis and research to help us improve our services

· Build relationships with other organisations

· Provide communications to these individuals regarding bookings, our clients and their requirements in order to better service their requests.

S​pecial Categories of Information that you give us or that we receive where we have your consent.As explained below, we will use this information only if we have your explicit consent. When collecting

your explicit consent, we will explain how we will use your data.

LEGAL REQUIREMENTS

Sometimes we need to collect certain types of information for compliance with legal requirements. If this information is not provided we cannot agree to provide a product or service for you.

Your personal information may also be processed if it is necessary on reasonable request by a law enforcement or regulatory authority, body or agency or in the defence of legal claims. We will not delete personal information if relevant to an investigation or a dispute. It will continue to be stored until those issues are fully resolved.

WHY WE COLLECT YOUR INFORMATION

We collect and use your information (as detailed above) for a variety of reasons.

We need some information to enter into and perform our contract with you – for example your contact details, payment details and details relating to the product/service you have purchased from us.

Some information processing is required by law or in the public interest such as making sure we verify our customers’ identities such as your identification, payment details and the ages of travellers in order to manage inventory in the property.

Some information is processed because you’ve given your consent to that, which can be withdrawn by you at any time by contacting us at info@33nights.com. For example, we will only collect and process your categories of information where we have obtained your prior explicit consent.

Other information we collect because we have legitimate business interests. In particular, we have a legitimate business interest to use your information in:

· Understanding how our customers use our products, services and websites; · Understanding and responding to customer feedback;
· Researching and analysing the services our customers want;
· Improving our services;

· Understanding the type of products and services our customers purchase and how they use them; · Personalise our offers so we’re better able to provide offers and ideas that are relevant to you;
· Maintaining a public profile on both traditional and social media;
· Developing and maintaining relationships with vendors, partners and other companies and dealing with individuals who work for them.

HOW LONG WE KEEP YOUR INFORMATION

We will keep your information for as long as it is reasonably necessary. It will depend on factors such as whether you’ve any outstanding payments or your recent activities with us where you interacted with recent offers.
We will also routinely refresh our information to ensure we keep it up-to-date in order to provide a more tailored and personalized service to you.

INFORMATION WE SHARE

There are certain circumstances where we transfer your personal data to employees, contractors and to other parties.

We share information about you with other members of our group of companies so we can provide the best service across our group. They are bound to keep and use your information in accordance with this Privacy Policy.
We also share your information with certain contractors or service providers. They may process your personal data for us, for example, if we use a marketing agency.

Other recipients/service providers include advertising agencies, IT specialists, providers of cloud services, third party payment processors, social media platforms, email providers or outsourced call centres.

Our suppliers and service providers will be required to meet our standards on processing information and security. The information we provide them, including your information, will only be provided in connection with the performance of their function. They will not use your information for any purposes other than those outlined in this Privacy Policy.

We also share your information with certain third parties. We will do this either when we receive your consent or because we need them to see your information to provide products or services to you. These include anti-fraud databases, screening agencies and other partners we do business with such as other loyalty scheme members.

If we are not able to share information with certain third party partners who are also in our loyalty scheme, we will not be able to offer that service.

Your personal information may be transferred to other third party organisations in certain scenarios:

· If we reorganise our business or IT functions, information may be transferred to a vendor to continue to provide services to you

· If we’re required to by law, or under any regulatory code or practice we follow, or if we are asked by any public or regulatory authority – for example the Police;

· If we are defending a legal claim your information may be transferred as required in connection with defending such claim.

WHERE YOUR INFORMATION WILL BE HELD

When we share your information, your information may be transferred outside the European Economic Area.

We may, directly or indirectly through third-party entities around the world, process, store, and transfer all of the information you provide, including your personal information, as described in this Privacy Policy. Your personal data will be processed in the United Kingdom and/or in other states of the European Economic Area (EEA). From time to time we may also transfer your personal data to countries outside the EEA which do not offer data protection standards comparable to those within the EEA. If we transfer your personal data to a country outside the EEA we shall do so in full compliance with applicable data protection law.

We will only transfer data to jurisdictions outside the scope of the European General Data Protection Regulation (GDPR) where the appropriate safeguards set out in the GDPR are in place, in particular the use of Standard Contractual Clauses approved by the European Commission in the form set out in the Annex to Commission Decision 2010/87/EU.

We are happy to provide you with copies of the regulator-approved Standard Contractual Clauses, which you can request from us at ​info@33nights.com​.

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YOUR RIGHTS

You have certain rights in relation to your information. The availability of these rights and the ways in which you can use them are set out below in more detail.

We’ve listed the rights you have over your information and how you can use them below.

These rights will only apply in certain circumstances as they are limited by the relevant laws. They will generally not be available if there are outstanding contracts between us, if we are required by law to keep the information or if the information is relevant to a legal dispute.

· You can remove consent, where you have provided it, at any time. · You can ask us to confirm if we are processing your information.
· You can ask for access to your information.
· You can ask to correct your information if it’s wrong.

· You can ask us to delete your information.
· You have a right to be forgotten and you can ask that our systems stop using your information.
· You can ask us to restrict how we use your information.
· You can ask us to stop using your personal information, but only in certain cases.
· You have the right to complain to the relevant supervisory authority, in particular in the Member State

in the European Union where you are habitually resident, where you work or where an alleged infringement of data protection laws has taken place.

SECURITY

We are committed to keeping your personal information safe. We’ve got physical, technical and administrative measures in place to prevent unauthorised access or use of your information.

CHILDREN

We do not knowingly collect information from children or other persons who are under 18 years old. If you are under 18 years old, you may not submit any personal information to us or subscribe for the services.
If you believe we might have any personal information from or about a person under the age of 18, please contact us at info@33night.com

CHANGES TO THE POLICY

This policy will be changed from time to time.

If we change anything important about this policy (the information we collect, how we use it or why) we will highlight those changes at the top of the policy for a reasonable length of time following the change. We will also notify you in advance of the changes taking effect so that you understand what impact our changes may have on you.

COOKIE POLICY

If you have any questions about this policy please contact us at: info@33nights.com nformation About ‘Cookies’ & Why We Use ThemI
Like most sites, we use cookies on www.33nights.com

Cookies are small files stored by your browser in your computer when you visit our site. We use cookies to make your site visit efficient and ensure your checkout is easy. For example, if you don’t enable cookies on our site then you won’t be able to go back to search results. As well, some other features may not work as intended. We mostly use “session cookies” that are automatically deleted after each visit.

You can find more information about cookies, behavioural advertising and online privacy, and about how you can manage and delete them, at www.allaboutcookies.org or www.youronlinechoices.eu

Below is a list of types of cookies used on our site and what we do with those cookies.

Analytical / Performance Cookies
These cookies collect anonymous information about how you use our site, for example which pages you visit most often, whether you receive any error messages, and how you arrived at our site. Information collected by these cookies is used only to improve your use of our site and never to identify you. These cookies are sometimes placed by third-party providers of web traffic analysis services.

Targeting or Advertising
These cookies collect information about your browsing habits and inferred interests in order to make advertising more relevant to you. They are also used to measure the effectiveness of an advertising campaign. These cookies are usually placed by third-party advertising networks.

Functionality
These cookies remember choices you make, for example the country you visit our site from, your language, the device you are using and which pages you visit in order to improve your experience of our site and to make your visits and use more tailored and enjoyable. The information these cookies collecta are anonymised and cannot be used to track your browsing activity on other websites.

Cookies we use:

Facebook

We use Facebook cookies in order to display ads on their network that our visitors have shown an interest in or, may be interested in.

Analytical / Performance Cookie
To find out more about Facebook cookies: ​https://www.facebook.com/full_data_use_policyGoogle

In order to help Google manage their advertising and websites, Google offer many products, including AdSense, AdWords, Google Analytics, and a range of DoubleClick-branded services. When you visit a page that has one of the aforementioned products, either on one of Google’s sites or one of their partners’, various cookies can be used.

Google may use cookies for a number of purposes, such as to stop you from seeing the same ad over and over again, to detect and stop click fraud, and to show ads that are likely to be more relevant (such as ads based on websites you have previously visited).

Analytical / Performance Cookie

To find out more about Google cookies and you please visit: https://www.google.com/policies/privacy/

Instagram

Analytical / Performance Cookie

We use Instragam cookies in order to display ads on their network that our visitors have shown an interest in or, may be interested in.

To find out more about Instagram Marketing cookies, please visit:

https://help.instagram.com/155833707900388

At any time, you can prevent cookies from being set on your browser. For instructions on how to block, delete or disable any cookies, please consult your browser’s ‘Help’ or ‘Support’ section. Please note that by deleting our cookies or disabling future cookies you may not be able to access certain areas or features of our site.

Please consult the following links for information on cookie management and blocking according to your browser:

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Explorer: http://windows.microsoft.com/en-gb/internet-explorer/delete-manage-cookies#ie=ie-11. Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences Chrome: https://support.google.com/chrome/answer/95647?hl=en
Safari: https://support.apple.com/kb/PH19214?locale=en_GB

You can also find more information and manage cookie storage at: www.youronlinechoices.eu