We appreciate your interest in our privacy policy. At eson2 property management, we take the protection of your data very seriously, and in the below we explain what data we collect when you use our website and services and how it is used.
General information
a) what law applies?
Our use of your personal data is subject to both the uks data protection act (dpa) and the eu
s general data protection regulation (gdpr), and of course we process your personal data accordingly.
B) what is personal data?
Personal data is any information relating to personal or material circumstances that relates to an individual. This may include a name, date of birth, e-mail address, postal address, or telephone number but also online identifiers such as ip addresses or device id`s.
C) what is processing?
“processing” means any operation or set of operations which is performed upon personal data, whether or not by automatic means. The term is broad and covers virtually any handling of data.
D) who is responsible for data processing?
The responsible party within the meaning of the dpa and the gdpr is on property management ltd t/a eson2 ltd of 26 cadogan square, sw1x 0jp, london, uk (eson2, we, us, or our). If you have any questions or if you wish to exercise your rights, please contact us using propertmanagement@eson2. Co. Uk or call +44 (0) 2039 417 034.
E) what are the legal bases of processing?
In accordance with the dpa and the gdpr, we have to have at least one of the following legal bases to process your personal data: i) you have given your consent, ii) the data is necessary for the fulfilment of a contract / pre-contractual measures, iii) the data is necessary for the fulfilment of a legal obligation, or iv) the data is necessary to protect our legitimate interests, provided that your interests are not overridden.
F) is there an obligation for me to provide data?
Not in general, however you are required to provide personal data that is necessary for our business relationship. Without this data, we will usually have to refuse to conclude the contract or will no longer be able to perform an existing contract and may have to terminate it.
Data we collect automatically
a) log data
each time you visit our website, our system automatically records the following data from the visiting device and stores it in a so-called log file: i) name of the retrieved file, ii) date and time of the visit, iii) amount of data transferred, iv) message about successful retrieval, type of browser and version used, v) ip address (identification of the user’s device), vi) operating system of the visiting device, vii) internet service provider of the visiting device, viii) website from which you access our website, and ix) which of our website pages you are accessing. The legal basis is our legitimate interest.
B) hosting
the hosting services used by us for the purpose of operating our website is eight8. In doing so eight8, processes inventory data, contact data, content data, usage data, meta data and communication data of customers, interested parties and visitors of our website and services, on the basis of our legitimate interests and the conclusion of contracts for our services.
C) content management system
we use the content management system (cms) of wordpress by automattic inc, to publish and maintain the created and edited content and texts on my website. This means that all content and texts submitted to our website is transferred to wordpress. The legal basis is our legitimate interest.
D) google maps
our website uses google maps api by google to visually display geographical information. When using google maps, google also collects, processes and uses data about visitors’ use of the map functions. The integration of google maps represents a legitimate interest.
E) cookies
we use so-called cookies on our website. Cookies are pieces of information that are transmitted from our web server or third-party web servers to your web browser and stored there for later retrieval. Cookies may be small files or other types of information storage. There are different types of cookies: i) essential cookies. Essential cookies are cookies to provide a correct and user-friendly website; and ii) non-essential cookies. Non-essential cookies are any cookies that do not fall within the definition of essential cookies, such as cookies used to analyse your behaviour on a website (analytical cookies) or cookies used to display advertisements to you (advertising cookies).
As set out in the uks privacy and electronic communications regulations (pecr) and the eu
s privacy and electronic communications directive (pecd), we need to obtain consent for the use of non-essential cookies. For further information on the cookies we use, please refer to our cookie policy. The legal basis for processing is our legitimate interest and your consent.
F) cookie consent
our website uses a cookie consent management tool to obtain your consent to the storage of cookies and to document this consent. When you enter our website, the following personal data is transferred to us via hu-manity: i) your consent(s) or revocation of your consent(s); ii) your ip address; iii) information about your browser; iv) information about your device; v) time of your visit to our website. The basis for processing is our legitimate interest.
G) economic analyses and market research
for business reasons, we analyse the data we have on our website. The analyses serve us alone and are not disclosed externally and processed using anonymous analyses with summarised and or anonymized values. For this purpose we use google analytics and you can find more information in our cookie policy. The legal basis is our legitimate interest and your consent.
Data we collect directly
a) contacting us
in addition to your name, company name, and e-mail address, ip address or telephone number, if provided, we usually collect the context of your message which may also include certain personal data. The personal data collected when contacting us is to handle your request and the legal basis is both your consent and contract.
B) when using our services
we process the personal data involved in your use of our services (property management, and our auxiliary services) in order to be able to provide our contractual services. This includes in particular our support, correspondence with you, invoicing, fulfilment of our contractual, accounting and tax obligations. Accordingly, the data is processed on the basis of fulfilling our contractual obligations and our legal obligations.
C) administration, financial accounting, office organisation, contact management
we process data in the context of administrative tasks as well as organisation of our business, and compliance with legal obligations, such as archiving. In this regard, we process the same data that we process in the course of providing our contractual services. The processing bases are our legal obligations and our legitimate interest.
D) portfolio and booking
to enable you to conveniently book your stay with us online, we use the services of travelstaytion pms (short lets) and travelstaytion pms and arthur online (long lets). Your data will be used exclusively for the contractual relationship established with the reservation, and for any pre- and post-sales service, for any pre- and post-stay mailing, and for any pre- and post-stay mailing.
If you wish to make a booking, it is necessary for the conclusion of the contract that you provide your personal data, which we require for the processing of your booking. Mandatory data required for the processing of contracts are marked separately, other data are voluntary. We process the data you provide to process your booking.
In the course of a booking or stay, we sometimes collect the following personal data:
master data (surname, first name, main residence, address, mail address, telephone number, professional and private contact data including, place of birth, date of birth, customer number, language and, if applicable, car registration number).
Data in identity documents (e. G. , travel document, identity card, driving licence etc. Including issuing authority and period of validity, nationality)
date of arrival and departure and duration of booking,
the services you have requested and personal preferences, as well as special needs and customer or special requests,
data on payment methods and in connection with payments, in particular with debit cards, credit cards and bank cards
customer feedback
the duration of storage is measured according to the duration of our business relationship, the consents you have given, and furthermore according to the statutory retention obligations and legal obligations applicable to us. We emphasise that in the case of regular cooperation for our best possible customer service, we strive to know your customer wishes already communicated to us so well that we can continuously and permanently satisfy you.
Social media
a) general
based on our legitimate interest, we are present on social media (facebook, instagram and linkedin). If you contact or connect with us via social media, we and the relevant social media platform are jointly responsible for the processing of your data and enter into a so-called joint controller agreement. The personal data collected when contacting us is to handle your request and the bases are both your consent and our legitimate interest.
B) when you visit our profiles and interact with us and others
when you visit our social media profiles, we, as the operator of the profile, process your actions and interactions with our profile (e. G. , the content of your messages, enquiries, posts or comments that you send to us or leave on our profile or when you like or share our posts) as well as your publicly viewable profile data (e. G. , your name and profile picture). Which personal data from your profile is publicly viewable depends on your profile settings, which you can adjust yourself in the settings of your social media account. The legal basis is our legitimate interest and your consent.
Marketing
where you have given us your separate consent to process your data for marketing and promotional purposes, we are entitled to contact you for these purposes through the communication channels for which you have given your consent.
You can give us your consent in a number of ways, for example by ticking a box on a form asking us for permission to send you marketing information, or sometimes your consent is implied from your interactions or contractual relationship with us. Where your consent is implied, this is based on you having a reasonable expectation of receiving a marketing communication as a result of your interactions or contractual relationship with us.
Direct marketing is usually in the form of emails but may also include other less traditional or new channels. These forms of contact are managed by us or by our appointed service providers. Any direct addressed marketing sent or carried out by us or on our behalf will include an option for you to opt out or unsubscribe.
General principles
a) who receives my data?
Within eson2, those that need your data to fulfil our contractual and legal obligations will receive access to it.
Processors used by us may also receive data for these purposes. These are companies in the categories of it services, telecommunications, and sales and marketing. Where we use processors to provide our services, we take appropriate legal precautions and corresponding technical and organisational measures to ensure the protection of personal data in accordance with the relevant legal provisions.
Data is only passed on to third parties within the framework of legal requirements. We only pass on users’ data to third parties if this is necessary, for example, for contractual purposes or on the basis of legitimate interests in the economic and effective operation of our business or you have consented to the transfer of data.
B) how long will my data be stored?
As far as necessary, we process and store your personal data for the duration of our business relationship, which also includes, for example, the initiation and execution of a contract.
In addition, we are subject to various storage and documentation obligations, which result from the minimum statutory retention periods. The retention and documentation periods specified there are two to eight years.
C) how do we secure your data?
Our website uses ssl or tls encryption to ensure the security of data processing and to protect the transmission of content or contact requests that you send to us. We have also implemented numerous security measures (technical and organisational measures) for example encryption or need to know access, to ensure the most complete protection of personal data processed through this website.
Nevertheless, internet-based data transmissions can always have security gaps, so that absolute protection cannot be guaranteed. Upon becoming aware of a data breach, we will notify all affected individuals whose personal data may have been compromised as expeditiously as possible after which the breach was discovered.
D) is data transferred to a third country or to an international organisation?
We process data in the course of operating our website. We do not normally transfer personal data to countries outside the uk and the eea. However, if we do, we ensure that the processing of your personal data is governed by processing contracts that include standard contractual clauses to ensure a high level of data protection.
E) what we do not do
we do not request personal data from minors and children;
we do not use automated decision-making including profiling; and
we do not sell your personal data.
Your rights and privileges
a) privacy rights
under the dpa and gdpr, you can exercise the following rights:
right to information
right to rectification
right to object to processing
right to deletion
right to data portability
right of objection
right to withdraw consent
right to complain to a supervisory authority
right not to be subject to a decision based solely on automated processing.
If you have any questions about the nature of the personal data we hold about you, or if you wish to exercise any of your rights, please contact us.
B) updating your information
if you believe that the information we hold about you is inaccurate or that we are no longer entitled to use it and want to request its rectification, deletion, or object to its processing, please do so by contacting us.
C) withdrawing your consent
you can revoke consents you have given at any time by contacting us. The legality of the data processing carried out until the revocation remains unaffected by the revocation.
D) access request
in the event that you wish to make a data subject access request, you may inform us in writing of the same. We will respond to requests regarding access and correction as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days, we will tell you why and when we will be able to respond to your request. If we are unable to provide you with any personal data or to make a correction requested by you, we will tell you why.
E) complaint to a supervisory authority
you have the right to complain about our processing of personal data to a supervisory authority responsible for data protection. The supervisory authority in the uk is the information commissioner’s office (ico), wycliffe house, water ln, wilmslow sk9 5af, uk www. Ico. Org. Uk. However, we would appreciate the opportunity to address your concerns before you contact the garante.
Validity and questions
this privacy policy was last updated on friday, 3rd of november 2023, and is the current and valid version. However, we want to point out that from time to time due to actual or legal changes a revision to this policy may be necessary. If you have any data protection questions, please feel free to contact us.