Privacy Policy

1. Keeping your data safe
   1. At AltoVita we are committed to keeping your personal data safe and secure, and handling it in accordance with our legal obligations. This Privacy Policy sets out in detail the purposes for which we process your personal data, who we share it with, what rights you have in relation to that data and everything else we think it’s important for you to know.
2. Who we are
   1. Kravluxe Limited trading as AltoVita, specialises in providing temporary accommodation. If you have a query in relation to how your data is processed, you can contact us by email or in writing.
   2. Email: Privacy@AltoVita.com
   3. Address: 48 Dover Street, London, England, W1S 4FF
   4. Registration number: ZB373218
3. Who’s in control
   1. It is important that you understand who is responsible for keeping your data safe.
   2. If you are a guest who books directly via our website requiring one of the services we offer, AltoVita will be the Data Controller.
   3. If you are a guest/transferee wanting to book one of the available properties via our Business to Enterprise (B2E) platform, AltoVita will be the Data Processor and the company using our B2E platform would be the Data Controller.
   4. All data collected by AltoVita is strictly used for the purpose of providing you with the service of finding and providing you with a temporary accommodation.
   5. As a Data Controller, we are responsible for deciding how and why your data is used and for ensuring that your data is handled legally and safely in a secure manner.
   6. As a Data Processor, we have an obligation to the Data Controller to complying with their requirements to ensure your data is only processed as per the agreed business relationship and for ensuring your data is handled legally and safely in a secure manner, per their requirements.
   7. As a Data Controller or Data Processor, AltoVita will never sell your information to third parties, or process your information for any reason that sits outside of the services you have requested.
   8. AltoVita have appointed a Data Protection Officer (DPO) who has ultimate responsibility for making sure your data is treated in accordance with this Privacy Policy and the law. Our DPO can be contacted by emailing Privacy@AltoVita.com
4. What data do we collect and where from
   1. We collect identifiable information about you directly from our website or from our clients via our enterprise platform. By ‘identifiable information’ we mean any information about an individual from which that person can be identified.
   2. We collect some data directly from you when you enquire for a property direct to AltoVita.com or via our B2E platform (Booking Data). This data includes the following:
      1. your full name;
      2. your email address;
      3. your date of birth;
      4. your check in and check out dates
      5. your phone number
      6. property requirements
      7. your postcode and address (if you choose to provide them); and
      8. your direct marketing preferences. Direct marketing means any method of communication which is directed to individuals for example, we may send you an email (if you opt in) to provide you with details of new properties where you may like to stay.
   3. We may also process the following types of identifiable information should you sign up to our email marketing or advertisements.
      1. your full name;
      2. your email address;
      3. The company your work for
      4. Your phone number
      5. Job Title
   4. We also collect information that you voluntarily provide to us when you contact us with queries, complaints, comments or praise (Voluntary Data)
   5. your card payment details (which will be collected directly by our third-party payment provider, Stripe, and will not be visible to us); The collection and processing of your card details and payment data is also governed by Stripe’s privacy policy, which you can find here: https://stripe.com/gb/privacy.
   6. We collect and analyse information about how you use AltoVita.com using cookies (Behavioural Data). You can find more detailed information about this in our Cookies Policy.
   7. We also collect some data about you from our third-party property suppliers (Third Party Data). This includes:
      1. If you checked into the property
      2. Any damage caused
      3. Any issues
      4. Household makeup and composition (for example, the number of adults and children in the household);
      5. Their unique identifier that they have assigned to you.
   8. We also collect publicly available information from social networking sites such as Facebook, Twitter, YouTube, Instagram, and LinkedIn, for example likes, shares, tweets and posts about AltoVita.com and AltoVita. This information is used for analysis purposes.
   9. The following data types may also be processed depending on the need of service you require.
      1. Proof of COVID vaccine/ negative result
      2. Age of Spouse and/ or children
      3. Car registration / rental registration
   10. We use Survey Data for the purposes of analysing insights and information to enable us to improve our products and services and to help us to build more accurate ad targeting segments for our users.
5. What do we use your data for?
   1. It is important that you understand how and why we use the personal data that we collect about you. This section sets out the different purposes for which we process personal data and which types of personal data we need for each purpose.
   2. Providing you with our services
      1. We use your Booking Data to set up, manage and administer booking, to respond to your queries, complaints or comments, any other services that you request from us.
      2. If you have made a direct payment via our website our payment processor Stripe can process your payments and deal with any related queries you may have.
      3. We use your Booking Data to contact you occasionally with service messages about your booking and other services you have signed up for, for example to provide you with contact information of your property supplier, reminders, when you are due to check in, check out, if there is an issue with your new property, or to contact you about a query you have submitted to us. We may also use your email address and/or other Booking Data to help us with database matching. For more detail about this see Database matching.
   3. We use your Voluntary Data to enable us to respond to queries, complaints or comments that you have and to make sure that these are appropriately dealt with, for example when you contact Bookings/ Reservations. Calls to our Bookings and Reservations teams are recorded for training and monitoring purposes and retained for 2 years. If Voluntary Data you provide includes any special categories of personal data (such as information about your health, race or religion), you must make sure before you provide this that you are happy for us to use that Voluntary Data for the purposes set out in this Privacy Policy.
   4. Improving our services
      1. We use Booking Data, Behavioural Data, Voluntary Data and Survey Data to help us monitor, analyse and improve our products and services. We use this data to help us understand which services are most interesting and enjoyable for our users and to help us identify errors and test features. This helps us to make sure that we are providing you with the best possible products and services.
   5. Marketing and advertising
      1. We use Booking Data, Behavioural Data, Survey Data and Third Party Data for marketing and advertising purposes. For more information on the ways in which we do this, please see How do we use your data for marketing and advertising purposes? below.
   6. We use Survey Data to:
      1. enable us to assess our performance and to improve our products and services including advertising
         1. inform our marketing and promotional activities such as our annual awards.
      2. inform and support our third-party suppliers (e.g. helping us to report to them about property booking performance).
   7. How we use anonymised data
      1. We use combined and anonymised data for certain purposes, such as to report booking and reservation numbers of property / geographical location and help us understand what type of property’s guests like and to share with property suppliers or our clients on the B2E platform. When used for these purposes, this data does not enable you or any other individual user to be identified.
6. How do we use your data for marketing and advertising purposes?
   1. Marketing and advertising are key parts of our activities as it enables AltoVita to not only provide you with the latest and best properties that may suit your needs but also helps improve our products and services. This section sets out the various types of marketing and advertising that we carry out and how your data is used for each type of activity. We do not target our marketing or advertisements to anyone who is under 18.
      1. Email marketing
         1. We will use your email address to send you email marketing (including our newsletter, information about new properties or services) where you have signed up to receive this from us.
         2. You can opt out of receiving marketing emails at any time by either following the instructions to unsubscribe in any of our email marketing or by contacting Privacy@AltoVita.com
         3. If you opt out of email marketing, we will still need to send you service communications by email from time to time, such as information about changes to our services and updates to our policies.
      2. Personalised advertising
         1. We sometimes use your name, location or your birth month to personalise advertisements from AltoVita. This means, for example, that you may see your first name in a flyer, invitation advertisement directly to you via email.
         2. If you have opted out of personalised advertising, the advertisements you see will not be tailored to you and your interests, but may be visible to see on social media posts such as LinkedIn
      3. Database matching
         1. We use email addresses (and/or Booking Data) to securely match our registered user database with other properties or events that might be of an interest to you.
      4. Promoting our own services on other platforms
         1. We may also promote our own content and features via third party platforms, such as social media sites like Facebook and LinkedIn.
         2. This usually works by us sending a hashed or encrypted identifier to the third-party platform which is then matched to that third party’s records to identify whether you are also a user of the third party’s platform. If you are identified as a user, this allows us to send you promotions for AltoVita services that we think you will be interested in via your homepage or profile on that platform.
         3. Once we have shown you a promotion for AltoVita services and features on a third-party platform, provided you have consented to the use of any cookies or equivalent technology, we may use a third-party service provider to measure whether or not you then access AltoVita.com You can choose to opt out of attribution tracking in our Cookies Policy.
7. Who do we share your data with
   1. There may be a time we are required to share your data with a third party to fulfil the service you have requested. In the event AltoVita is required to share your data with a third party, it will be in line with data protection requirements of a legal basis in doing so. As such third parties that may require access to your data may include.
      1. Property suppliers
      2. Local Governments
      3. Local Police
      4. Stripe (to process card payments)
8. Personal data of children
   1. AltoVita sites and services are not directed to children under the age of 18. You must be over 18 years of age to book a property with AltoVita. If children are travelling with you, we will need to know their age, but we do not require their personal details and you will never be asked for their information at any stage in the reservation process. We may ask simple questions to help form your requirements, for example, if you require a cot or a highchair. Contact us at Privacy@AltoVita.com if you believe that we have mistakenly or unintentionally collected information from a child under the age of 18.
9. How long do we keep your data for
   1. If you have a made a booking via AltoVita we will keep your personal data for a maximum of 6 years.
   2. If you have made a booking via our B2E platform we will keep your personal data for a maximum of 6 years.
   3. If you have not made a booking with AltoVita.com but have signed up to receive email notifications on services, marketing and or advertisements we will keep your personal data until you device to opt out.
   4. If you have applied for a job via AltoVita.com or we shall keep your data for a maximum of 12 months.
   5. Any Voluntary Data you submit to us will be retained for a period of one year from submission, after which it is anonymised or deleted.
10. What rights do you have
    1. You have several rights under Data Protection Law. These rights and how you can exercise them are set out in this section. We will normally need to ask you for proof of your identity before we can respond to a request to exercise any of the rights in this section and we may need to ask you for more information, for example to help us to locate the personal data that your request relates to.
    2. We will respond to any requests to exercise your rights as soon as we can and in any event within one month of receiving your request and any necessary proof of identity or further information. If your request is particularly difficult or complex, or if you have made a large volume of requests, we may take up to three months to respond. If this is the case, we will let you know as soon as we can and explain why we need to take longer to respond.
    3. A right to access your information
       1. You also have a right to ask us to send you a copy of all identifiable information that we hold about you (subject to some exceptions). A request to exercise this right is called a “Subject Access Request” (SAR) and must be made in writing to: Privacy@AltoVita.com or to: Data Protection Officer, AltoVita, 48 Dover Street, London, England, W1S 4FF
       2. We do not accept subject access requests made via third parties without a letter of authorisation from you sent directly to us confirming that you authorise the third party to act on your behalf. We do not accept SAR requests from platforms where we are required to set up an account to provide the response to the SAR.
    4. A right to object to us processing your information
       1. You have a right to object to us processing any personal data that we process. This includes all of your personal data that we process for all of the purposes set out in this Privacy Policy. As mentioned within this Privacy Policy, AltoVita will only process your data upon your consent however, you can withdraw your consent to this at any time.
       2. If we have compelling legitimate grounds to carry on processing your personal data, we will be able to continue to do so. Otherwise, we will cease processing your personal data.
       3. You can exercise this right by emailing Privacy@AltoVita.com.
    5. A right to ask us not to send you direct marketing materials.
       1. You can ask us not to send you direct marketing or advertising. You can do this by opting out of the advertising you no longer want to receive. In relation to email marketing, you can also opt out by using the “unsubscribe” option in any of our email marketing communications.
       2. You can also exercise this right by emailing Privacy@AltoVita.com.
    6. A right to have inaccurate data corrected.
       1. You have a right to ask us to correct inaccurate data that we hold about you. If we are satisfied that the new data you have provided is accurate, we will correct your personal data as soon as possible.
       2. You can exercise this right by emailing Privacy@AltoVita.com.
    7. A right to have your data erased
       1. You have a right to ask us to delete your personal data in certain circumstances, for example if we have processed your data unlawfully or if we no longer need the data for the purposes set out in this Privacy Policy.
       2. We will fully anonymise any personal data we hold about you as set out under ‘How long do we keep your data for’ above. This means that it will no longer identify you and ceases to be “identifiable information”.
       3. You can exercise this right by emailing Privacy@AltoVita.com.
    8. A right to have processing of your data restricted
       1. You can ask us to restrict processing of your personal data in some circumstances, for example if you think the personal data is inaccurate and we need to verify its accuracy, or if we no longer need the data but you require us to keep it so that you can exercise your own legal rights.
       2. Restricting your personal data means that we only store your personal data and don’t carry out any further processing on it unless you consent or we need to process the data to exercise a legal claim or to protect a third party or the public.
       3. You can exercise this right by emailing Privacy@AltoVita.com.
    9. A right to data portability o you have a right to data portability, which means that you can ask us to provide you with a copy any data that you have provided and which we hold in a commonly used re-usable format.
11. What is our legal basis for using your data?
    1. Data protection law says that we must tell you the legal basis that we rely on to process your personal data for the purposes that we have notified to you. This section tells you what that legal basis is in relation to each of the purposes set out above.
    2. Legitimate interests: We use your booking Data to service your requests and send you information relevant to your reservation. We may contact you to suggest alternative options if there is an issue with your booking or to ask if you would like to extend your current booking. We may also contact you to gauge your interest about other properties and services we offer.
    3. Performance of a contract: For all bookings made on our B2E platform we need your Booking Data you supply to execute our part of the contract between service provider and client. If you or a company on your behalf ask us to make a reservation, we process use your Booking Data to complete your reservation to satisfy our part of the contract as a service provider.
    4. Consent: We will ask for your consent to send you direct marketing content, such as our monthly newsletter containing special offers, exclusive rates and promotions. We may also send other marketing and advertisements as mentioned within this Privacy Policy.
12. Transferring personal information outside the EU
    1. AltoVita collects and transfers personal data outside the EU only: with your consent; to perform a contract with you; or to fulfil a compelling legitimate interest of AltoVita in a manner that has been carefully considered to not outweigh your rights and freedoms. AltoVita only does so under the contractual protections afforded under Standard Contractual Clauses for data transfers between EU and non-EU countries. This is to ensure that suitable safeguards to protect the privacy and security of your personal information is applied and to use it only consistent with your relationship with the AltoVita and the practices described in this Privacy Policy.
13. What if this policy changes
    1. We may make changes to this Privacy Policy from time to time. Any changes we make will be posted on this page. We may also notify you by email if significant changes are made.
14. Complaints
    1. This Privacy Policy is intended to provide you with information about what personal information AltoVita collects about you and how it is used. If you have any questions, please contact us at Privacy@AltoVita.com
    2. You have the right to lodge a complaint with the Information Commissioner’s Office. Further information, including contact details, is available at https://ico.org.uk or call 0303 123 111