At Baseology we use your personal information in order to fulfil our commitment to providing an unparalleled student experience in connection with all of your interactions during your stay with us (the “Purpose”). As part of that undertaking, we are committed to safeguarding the privacy of the personal information that we gather.
During the application and registration processes you will be asked to provide some personal information for our records. The statement below explains how we as the data controller and in some instances processor will collect and process this data. Your application data will form part of your record with us.
This policy applies to personal information regarding students and to the use of that personal information in any form, whether oral, electronic and/or written.
This policy gives effect to our commitment to protect your personal information and has been adopted by all of the separate and distinct legal entities that manage, operate, or provide services to the various locations operating under or in connection with the Baseology brand around the world. This includes Baseology, its subsidiaries, and all of the separate and distinct legal entities that own the Baseology sites.
While this policy is intended to describe the broadest range of our personal information processing activities, those processing activities may be restricted by the laws of a particular country/region. In such a case, we may adjust our internal policies and/or practices to reflect the requirements of local law.
“Personal information” in this policy means information that identifies or is capable of identifying you as an individual. The types of personal information that we may process (which may vary by jurisdiction based on applicable law) include:
There may be instances in which the personal information that you provide to us or that we collect is considered Sensitive Personal Information under the privacy laws of some countries or regions, e.g. if you inform us of any special needs due to your health condition, which is necessary for us to accommodate your needs. In that case we will always obtain your consent before any such processing, in accordance with GDPR art. 9(2)(a).
Those laws define “Sensitive Personal Information” to mean personal information from which we can determine or infer an individual’s:
In some very rare instances, financial records may constitute Sensitive Personal Information where you are located. If we rely on consent to process your Sensitive Personal Information, you have the right to withdraw that consent at any time. We only process Sensitive Personal Information in your jurisdiction if and to the extent permitted or required by applicable law.
Save to the extent required by law, you are not obliged to provide Baseology with any of your Sensitive Personal Information.
Subject to applicable laws, we may collect, use, process and disclose portions of your personal information on the basis of GDPR art. 6(1)(b) for the entering or performance of our contract with you including to:
b) We may use the personal data described above for the following purposes on the legal basis of GDPR art. 6(1)(c) to ensure compliance with a legal obligation such as:
c) We may use the personal data described above for the following purposes on the legal basis of GDPR art. 6(1)(f) where it is for a legitimate interest such as:
When we process your personal information, as detailed above, we do this because of legal obligations we are subject to or because the information is required to fulfil contractual obligations to you and anyone authorised to be involved in making your accommodation or travel arrangements and our service vendors.
Baseology uses and retains your personal information for as long as is necessary to fulfil the purpose for which it is being processed, and in line with our legal and regulatory obligations. For example, reservation records are retained and accessible for a period of at least 6 months following the end of your stay with us, after which they will be securely archived and personal information in records may be maintained for longer periods if subject to a legal hold or to satisfy specific country/region requirements.
From time to time, we may disclose your personal information in accordance with applicable law.
Circumstances where we might make such disclosure (in addition to those described in Part 4 above) include:
Service Providers and Suppliers outside the Baseology group.
We may outsource the processing of information to third parties. When we do outsource the processing of your personal information to third parties or provide your personal information to third-party service providers, those third parties are required by us to provide the same level of protection for your personal information as provided in the terms and conditions of this Policy, with appropriate security measures. The categories of third-party service providers and suppliers to which your information may be transferred to include the following:
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Where we hold personal information about you or you participate in a Baseology survey, we may disclose this personal information to other companies to process the information in order to better understand your preferences and interests, thereby enabling us to provide a better service to you. If your personal information is used for direct marketing purposes, you have the right to object to that by contacting us using the contact information provided under Section 12 below. Further information about how we conduct direct marketing may be found at Section 9 below.
As we continue to develop our business, we may sell Baseology sites and or other assets, or cease being the manager or franchisor of a Baseology site. In those circumstances, we may include the personal information collected about you, or control of that personal information, as a business asset in any such transfer. Also, in the unlikely event that we, or substantially all of our assets, are acquired, personal information collected about you, or control of such information, may be one of the transferred assets.
We will disclose any personal information we have concerning you if we are compelled to do so by a court or lawfully requested to do so by a governmental entity, or if we determine it is necessary or desirable to comply with the law or to protect or defend our rights or property in accordance with applicable laws. We will also retain personal information collected and process such personal information to comply with accounting and tax rules and regulations and any specific data retention laws. We may share it with others for our own good governance obligations, or in order to enforce or to protect our rights, property, or safety, or that of our customers or other persons with whom we have a business relationship.
The majority of any processing of your personal information will be conducted within the country of your visit with us in accordance with applicable local laws.
However, as an international business, we have centralized certain aspects of our data processing activities in accordance with applicable laws, which will result in the transfer of your personal information from one country to another. The jurisdictions where that information will be processed may or may not have laws that seek to preserve the privacy of personal information. Nevertheless, whenever your personal information is transferred within the Baseology companies, your personal information will be processed in accordance with the terms and conditions of this Policy and applicable laws. Currently, Baseology operates in the following jurisdictions, all of which are bound by or have implemented the European Union data privacy regulations:
Additionally, some of the third-party suppliers to which we transfer your personal information may be based in different locations, some of which may have lower standards of data protection than in the country in which you stay with us. When we do transfer personal information to such third parties, we ensure appropriate safeguards are in place, and oblige those third parties to protect your personal information in accordance with the terms and conditions of this Policy, with appropriate security measures. These third parties broadly fall into two groups: (i) locally provided suppliers supporting individual Baseology Locations operating in the countries in which Baseology operate; or (ii) service providers, supporting Baseology as a whole, who may be located in our or outside of countries we operate in. For example, CCTV footage may be processed by our provider partners outside of the country you are staying with us.
If you access the Baseology website, you may wish to know the following:
You can browse without revealing who you are
You can always visit our websites without logging in or otherwise revealing who you are.
You may always choose what personal information (if any) you wish to provide to us. However, if you choose not to provide certain details, some of your experiences with us may be affected (for example, we cannot take a reservation without a name).
If you provide us with your contact details (e.g., postal address, email address, telephone number or fax number), we may contact you to let you know about the products, services, promotions and events offered that we think you may be interested in. Additionally, where you have consented to us doing so, we may also share your personal information with carefully-selected third parties, who may communicate directly with you. You can always choose whether or not to receive any or all of these communications by contacting us as described in Section 12 below or following the “unsubscribe” instructions contained in the communications.
If you have an account with us, we ask you to indicate your communication preferences at the time you apply or when you create your user profile. We may also ask you to indicate how you would like to receive any offers, marketing and promotional information (e.g., via email or regular mail) and whether you would be willing to participate in surveys. Once you have indicated your preferences, you can always change them.
In some jurisdictions, in addition to you agreeing to this Policy, data privacy laws may require us to obtain a separate consent before we send you information that you have not specifically requested. In certain circumstances, your consent may be implied (e.g., where communications are required in order to fulfil your requests and/or where you have volunteered information for use by us). In other cases, we may seek your consent expressly in accordance with applicable laws (e.g., where the information collected is regarded to be Sensitive Personal Information under local regulations).
We will abide by any request from you not to send you direct marketing materials. When such a request is received, your contact details will be “suppressed” rather than deleted. This will ensure that your request is recorded and retained unless you provide a later consent that overrides it.
Under data protection law in Europe, you have various rights in relation to the personal information about you that we process. These include:
Rights in relation to the existence of automated decision making and profiling.
Further details on your GDPR rights can be found here https://ec.europa.eu/info/law/law-topic/data-protection/data-protection-eu_en
With some limited exceptions, you have rights to access and update personal information held about you. If you want to inquire about any personal information we may have about you, you can do so by contacting us at the addresses set out in Section 12 below. Please be sure to include your full name, address and telephone number and a copy of a document evidencing your identity (such as an ID card or passport) so we can ascertain your identity and whether we have any personal information regarding you, or in case we need to contact you to obtain any additional information we may require to make that determination. Where you make more than one request in quick succession, we may respond to your subsequent request by referring to our earlier response and only identifying any items that have changed materially.
You may request that we correct, delete, and/or stop or restrict processing or using personal information that we hold about you by sending a letter or email to the addresses set out in Section 12 below. If we agree that the personal information is incorrect, or that the processing should be stopped, we will delete or correct the personal information. If we do not agree that the personal information is incorrect we will tell you that we do not agree, explain our refusal to you and record the fact that you consider that personal information to be incorrect in the relevant file(s).
You may also seek to exercise your right to data portability by contacting us at the addresses set out in Section 12 below.
Finally, you may in some circumstances have the ability to object to the processing of your personal information on the grounds of your particular situation. You may do so by contacting us at the addresses set out at Section 12 below. If we agree that you are entitled to so object, we will cease to process your personal information.
If you are unhappy with the way we have handled your request, you can escalate your concern to the Privacy Officer by sending an email to email@example.com.
This Policy may change. Where the Policy changes, we will take appropriate steps to bring the amendment to your attention.
If you have any questions about this Policy, about the processing of your data described, or any concerns or complaints with regard to the administration of the Policy, or if you would like to submit a request (in the manner described in Section 10 above) to exercise your rights in relation to the personal information that we maintain about you, please contact us by email at firstname.lastname@example.org.
Should you have any complaints that are not resolved by the processes described in this policy, you have the right to lodge a complaint with the relevant data privacy regulator of the country in which you are staying with us.
Email: email@example.com; or
Phone: +44 203 948 1244 (UK number, international call costs may apply)
We will do our best to respond to your request within 48 hours.