Privacy Policy

This “Privacy policy” describes the way FrontDesk Master Ltd, 45 Greystoke Road, CB1 8DT Cambridge, United Kingdom collects, processes and protects your personal data in relation to providing you with property management system, channel manager, booking engine and all related services branded FrontDesk Master or HostelSystem (“Services”), where personal data is processed.

The FrontDesk Master Privacy policy applies to Services provided by FrontDesk Master through the  website, related applications and tools which incorporate this policy notwithstanding the fact of whether these Services are provided via website, mobile device, TV, computer or other device capable of intermediation of FrontDesk Master services.

The FrontDesk Master Privacy policy does not apply to services provided by FrontDesk Master with their own privacy policy.

By providing us with your data, you warrant to us that you are over 13 years of age.

I. What data do we collect. For What Purpose.

FrontDesk Master processes your data, if it is necessary for the provision of its Services, and generally, in order to fulfill all of its obligations vis-à-vis its customers or potential customers.

FrontDesk Master may collect and process the following Information when you are using the Services or FrontDesk Master website:

Communication Data that includes any communication that you send to us whether that be through the contact form on our website, through email, text, social media messaging, social media posting or any other communication that you send us. We process this data for the purposes of communicating with you, for record keeping and for the establishment, pursuance or defense of legal claims. Our lawful ground for this processing is our legitimate interests which in this case are to reply to communications sent to us, to keep records and to establish, pursue or defend legal claims.

Customer Data that includes data relating to any purchases of services such as your name, title, billing address, delivery address email address, phone number, contact details, purchase details and your card details. We process this data to supply the goods and/or services you have purchased and to keep records of such transactions. Our lawful ground for this processing is the performance of a contract between you and us and/or taking steps at your request to enter into such a contract.

User Data that includes data about how you use our website and any of our Services (online or desktop) together with any data that you post for publication on our website or through other online services. We process this data to operate our website and Services and ensure relevant services and support is provided to you, to ensure the security of our Services, website, to maintain back- ups of our Services and/or databases and to enable administration of our website, Services and business. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and provide you with our Services.

Technical Data that includes data about your use of our website and Services such as your IP address, your login data, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website. The source of this data is from our analytics tracking system. We process this data to analyze your use of our website and other online services, to administer and protect our Services and website, to deliver relevant Services, content and advertisements to you and to understand the effectiveness of our advertising. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our Services, website and our business and to grow our business and to decide our marketing strategy.

Marketing Data that includes data about your preferences in receiving marketing from us and our third parties and your communication preferences. We process this data to enable you to partake in our promotions, to deliver you relevant Services, website content and advertisements to you and measure or understand the effectiveness of this advertising. Our lawful ground for this processing is our legitimate interests which in this case are to study how customers use our Services, to develop them, to grow our business and to decide our marketing strategy.

Cookies. As is true of most websites, we gather certain information automatically. This information may include Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, date/time stamp, and/or clickstream data to analyze trends in the aggregate and administer the site. FrontDesk Master and its partners use cookies or similar technologies to analyze trends, administer the website, track users’ movements around the website, and to gather demographic information about our user base as a whole. You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on our website or service.

Log Data. When you use our Services, we may record the information about the activity details such as your device, software, IP, browser type, the web pages you visited before you came to our website, information you searched on our website, location, date and time of the activity and other interactions with our Services.

We may use Customer Data, User Data, Technical Data, Cookies and Marketing Data to deliver relevant Services, website content and advertisements to you (including Facebook adverts or other display advertisements) and to measure or understand the effectiveness of the advertising we serve you. Our lawful ground for this processing is legitimate interests which is to grow our business. We may also use such data to send other marketing communications to you. Our lawful ground for this processing is either consent or legitimate interests (namely to grow our business).

Sensitive Data. We do not collect any Sensitive Data about you. Sensitive data refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. We do not collect any information about criminal convictions and offences.

Where we are required to collect personal data by law, or under the Terms and conditions agreement of our Services, and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to enable Services for you). If you don’t provide us with the requested data, we may have to terminate a service you have ordered but if we do, we will notify you at the time.

We will only use your personal data for a purpose it was collected for or a reasonably compatible purpose if necessary. For more information on this please email us at [email protected]. In case we need to use your details for an unrelated new purpose we will let you know and explain the legal grounds for processing. We may process your personal data without your knowledge or consent where this is required or permitted by law. We do not carry out automated decision making or any type of automated profiling.

II. How do we collect Personal Data

We may collect data about you by you providing the data directly to us (for example by filling in sign up, registration, free trial or request a demo forms on our site or by sending us emails, chat or text messages, etc.). We may automatically collect certain data from you as you use our website by using cookies and similar technologies.

We may receive data from third parties such as analytics providers such as Google based outside the EU, advertising networks such as Facebook based outside the EU, such as search information providers such as Google based outside the EU, providers of technical, payment and delivery services, such as data brokers or aggregators.

We may also receive data from publicly availably sources such as Companies House and the Electoral Register based inside the EU.

FrontDesk Master may use your data for marketing purposes, i.e. in order to inform you of its services which may, according to your past preferences, be of interest to you. These communications shall strictly adhere to applicable legal regulations.

Advertising and marketing materials of the Contracting or other parties shall be sent to you only if you opted in for these communications during the registration process, via e-mail or otherwise.

Your decision about direct marketing may be withheld in accordance with the opt-out rules described in each marketing e-mail or other form of communication. Opting out can be done via changing the settings of your User account or by directly contacting FrontDesk Master (please see contact details below). Should you opt out, FrontDesk Master shall retain only such data necessary for provision of services in accordance with the rules set out in this policy.

III. Marketing Communications

Our lawful ground of processing your personal data to send you marketing communications is either your consent or our legitimate interests (namely to grow our business).

Under the Privacy and Electronic Communications Regulations, we may send you marketing communications from us if (i) you used our Services or asked for information from us about our Services or (ii) you agreed to receive marketing communications and in each case you have not opted out of receiving such communications since. Under these regulations, if you are a limited company, we may send you marketing emails without your consent. However, you can still opt out of receiving marketing emails from us at any time.

Before we share your personal data with any third party for their own marketing purposes we will get your express consent.

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you OR by emailing us at [email protected] at any time.

If you opt out of receiving marketing communications this opt-out does not apply to personal data provided as a result of other transactions, such as Service licensing.

IV. Data Sharing

1. With Third Parties:

We may share your information with trusted third-party business partners, for instance, for the purpose of enhancing our Services. If you do not want us to share your personal information with these companies, contact us at the contact information below.

2. With Service Providers:

We may share your information with third parties who provide services on our behalf to help with our business activities.  These companies are authorized to use your personal information only as necessary to provide these services to us, to which these services may include:

• Payment processing
• Providing customer service
• Sending marketing communications
• Conducting research and analysis
• Providing hosting or/and cloud computing infrastructure

We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.

3. With Public Authorities or Law Enforcement:

In certain situations, FrontDesk Master may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We may also disclose your personal information as required by law, such as to comply with a subpoena or other legal process, when we believe in good faith that disclosure is necessary to protect our rights, when we believe there is a violation to our Terms and conditions agreement, protect your safety or the safety of others, investigate fraud, or respond to a government request. If FrontDesk Master is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our website, of any change in ownership, uses of your personal information, and choices you may have regarding your personal information. We do not sell, rent or share personal information with third parties without your prior consent.

V. International Transfers (Users Residing in Europe)

We share your personal data within our group of companies which may involve transferring your data outside the European Economic Area (EEA).

Countries outside of the European Economic Area (EEA) do not always offer the same levels of protection to your personal data, so European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria.

Some of our third parties service providers are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is in place:

We will only transfer your personal data to countries that the European Commission have approved as providing an adequate level of protection for personal data by; or

Where we use certain service providers, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe; or

If we use US-based providers that are part of EU-US Privacy Shield, we may transfer data to them, as they have equivalent safeguards in place.

If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.

VI. Data Security

FrontDesk Master shall ensure that your personal data is stored securely. Therefore, it has introduced adequate physical, technical and organizational measures and plans to protect and secure all information collected via services of FrontDesk Master.

The aim is to eliminate unauthorized or unlawful processing of your personal data, or accidental, unauthorized or unlawful access, use, transferring, processing, copying, transmitting, alteration, loss or damage of your personal data. Despite all efforts and meeting all rules set out by applicable legal regulations, it is not possible to guarantee the security of your data, if it is transferred or transmitted in an unsecured way.

FrontDesk Master protects your data in the following ways:

• Using cryptography, where necessary
• Using password protection, where necessary
• Restricting access to your personal data (i.e. access to your personal data is granted only to those employees or personnel of FrontDesk Master for whom the access is indispensable for the purposes described herein).

These measures do not deprive you from your duties to undertake proper steps in order to secure your own personal data. You should, inter alia, regularly change your passwords. On the other hand, you should not, inter alia, use predictable usernames and/or passwords, share your password with other persons, or grant access to your User account and/or disclose your personal data to other persons.

VII. Data Retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

When deciding what the correct time is to keep the data for we look at its amount, nature and sensitivity, potential risk of harm from unauthorized use or disclosure, the processing purposes, if these can be achieved by other means and legal requirements.

For tax purposes the law requires us to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) after they stop being customers.

In some circumstances we may anonymize your personal data for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

VIII. Your Legal Rights

Under data protection laws you have rights in relation to your personal data that include the right to request access, correction, erasure, restriction, transfer, to object to processing, to portability of data and (where the lawful ground of processing is consent) to withdraw consent.

You can see more about these rights at:

https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/

If you wish to exercise any of the rights set out above, please email us at [email protected].

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive or refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you.

IX. Changes of Privacy Policy

FrontDesk Master may, from time to time, change and update the terms of this Privacy policy. We will inform you via email or via your User account, if we make changes to this Privacy Policy that we believe materially reduce your rights. By continuing to use the Services after those changes become effective, you agree to be bound by the revised Privacy Policy.

X. Contact Details

Should you wish to know more about FrontDesk Master, its protection of your privacy, or about this Privacy policy, you can contact FrontDesk Master at [email protected] .