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Privacy statement

June 2021

1. Introduction

The Student Hotel s.a.r.l. (‘TSH’) operates activities in the business of hospitality, which includes offering hotel services, food and beverage facilities and co-working spaces. TSH is committed to protecting the privacy of all guests who interact with us at any moment during their TSH experience. We treat all the personal data of our guests with great care and we always act in accordance with the applicable national and international data protection legislation including the General Data Protection Regulation (GDPR).

This privacy statement is designed to fully inform you about our privacy practices including the collection of personal data, how we use it and the rights that exist for you to fully be in control of it. We love to interact with our guests so that we can learn and continue to improve the services we offer to the TSH community, which means data is exchanged and used on many occasions including: when you use our mobile applications, visit our websites, make a reservation or visit one of our hotels, food & beverage locations (‘The Commons’), co-working spaces (‘TSH Collab’), the gym or any other property that belongs to TSH.

2. Who we are

This Privacy Statement applies to the processing of personal data by The Student Hotel Group s.a.r.l. and more specifically the relevant subsidiary that determines the particular purpose of the personal data that is processed. In practice the primary data controller will be either TSH Online B.V., TSH Trademark B.V., TSH Management B.V. or TSH Southern Europe S.L. and the relevant TSH location you are engaging with.

TSH Online B.V. is a limited liability company registered under the laws of the Netherlands with its statutory seat in Amsterdam, the Netherlands, and its office at Aambeeldstraat 34 (1021KB) Amsterdam, PO Box 9082 (1006AB) Amsterdam, registered with the Dutch Chamber of Commerce under number 69978689 . TSH Online B.V. is the legal entity that acts as the primary data controller for all IT activities performed by TSH subsidiaries

TSH Trademark B.V. is a limited liability company registered under the laws of the Netherlands with its statutory seat in Amsterdam, the Netherlands, and its office at Aambeeldstraat 34 (1021KB) Amsterdam, PO Box 9082 (1006AB) Amsterdam, registered with the Dutch Chamber of Commerce under number 69978670. TSH Trademark B.V. is the legal entity that acts as the primary data controller for all marketing and brand related activities performed by TSH subsidiaries.

TSH Management B.V. is a limited liability company registered under the laws of the Netherlands with its statutory seat in Amsterdam, the Netherlands, and its office at Aambeeldstraat 34 (1021KB) Amsterdam, PO Box 9082 (1006AB) Amsterdam, registered with the Dutch Chamber of Commerce under number 55241247. TSH Management B.V. is the legal entity that acts as the primary data controller for all Northern European TSH subsidiaries.

TSH Southern Europe S.L. is a limited liability company registered under the laws of Spain with its statutory seat in Barcelona, Spain, and its office at Calle de Sanchi de Avila 22, 08018, registered under the number B 62647631. TSH Southern Europe Management S.L. is the legal entity that manages and acts as the primary data controller for all Southern European TSH subsidiaries.

3. Changes

We may change this Privacy Statement to reflect changes at any time. The most recent version of the Privacy Statement is reflected by the version date located in the top left of this document. All updates and amendments are effective immediately upon notice, which we may give by posting a revised version of this Privacy Statement on the Website. We encourage you to review this Privacy Statement often to stay informed of changes that may affect you, as your continued use of our services signifies your continuing awareness of this Privacy Statement.

4. What personal data do we collect and why?

The type of data that TSH collect and for what purposes depends on the type of service you have signed up to and the location where the service will be provided.

Browsing TSH websites
If you visit a TSH website, we use cookies, which we store on your computer, phone or tablet. Cookies are small text files, and we use the information contained in these files for the essential functioning of our sites, non-essential function to improve user experience, performance / analytics and advertising. Many analytic activities concern primarily anonymized data to help us analyze how users use the websites so that TSH can improve the functionality and the content.

Amongst other data, we process the following personal data from visitors to our websites:

  • website visit and use;
  • IP address;
  • duration and time of visit to the website;
  • use of social media.

We will use this in accordance with the cookie preferences you select in the cookie setting banner, for example to provide relevant offers on other websites you visit via online and third-party advertisements. We may also use this information for remarketing purposes to remind and assist you with potential bookings that were left incomplete.

Subscribing using forms (online and offline)
When you subscribe to a newsletter, event, deal, competition, waiting list, program or classroom online or offline you will be requested to provide certain data, which may include:

  • name;
  • e-mail;
  • event you’re interested in;
  • residence;
  • city;
  • gender;
  • phone;
  • date of birth; and
  • other data that may be requested for the purpose of the form.

We use this information to contact you about the relevant topic you have indicated you are interested in. We will only contact you when we believe there is a legitimate interest to do so based on the interest and information you have declared.

We may also use this information to perform marketing activities regarding TSH more generally. We will only use the information submitted for marketing if you have provided consent for us to do so. You can unsubscribe from marketing e-mails at any time by clicking the unsubscribe link contained in the e-mail.

When you join as a TSH Collab member
When you apply to join as a member of TSH Collab, you will provide us with data which may include:

  • Name;
  • e-mail;
  • phone;
  • home address;
  • membership details; and
  • payment details.

If you register a business address at the Collab office address it may be necesarry to provide additional information in order for TSH to comply with legal requirements.

This information will be used for processing the membership application, billing purposes, to comply with legal obligations and to allow us to communicate with you about your membership, including sending surveys to understand how we can improve the service offered. TSH may use a payment token whereby your payment details are stored as a secure unique payment token enabling simplified payment processes for future payment transactions associated with your account.

We will also use this information to send general marketing e-mails about other TSH material but only if you have given us consent. You can unsubscribe from marketing e-mails at any time by clicking the unsubscribe link contained in the e-mail.

When you make a reservation at the Commons restaurant
When you make a reservation at the Commons, you will provide us data, which may include:

  • Name;
  • e-mail;
  • phone;
  • reservation details;
  • dietary preferences; and
  • payment details

This information will be used for processing the reservation and to communicate with you about the reservation.

We will also use this information to send general marketing e-mails about other TSH material but only if you have given us consent. You can unsubscribe from marketing e-mails at any time by clicking the unsubscribe link contained in the e-mail.

When you make a hotel booking as a hotel guest or short / extended stay guest
When you make a reservation as a hotel guest or a short stay / extended guest at TSH, you will provide us with data, which may include:

  • name;
  • e-mail;
  • phone;
  • home address;
  • date of birth;
  • nationality;
  • ID information;
  • stay preferences;
  • the dates you are staying with us;
  • signature; and
  • payment details.

Depending on the location you have booked to stay additional data may also be required. This information will be used for processing the hotel booking, billing purposes, complying with legal obligations and to allow us to communicate with you about your booking, including sending surveys to understand how we can improve the service offered.

TSH may use a payment token whereby your payment details are stored as a secure unique payment token enabling simplified payment processes for future payment transactions associated with your account.

We will also use this information to send general marketing e-mails about other TSH news, events and deals but only if you have given us consent to do. You can unsubscribe from marketing e-mails at any time by clicking the unsubscribe link contained in the e-mail.

When you make a hotel booking as a semester guest
When you make a reservation as a semester guest, you will provide us with data, which may include:

  • Name;
  • email;
  • Phone;
  • home address;
  • place of birth;
  • date of birth;
  • nationality;
  • ID information;
  • stay preferences;
  • the dates you are staying with us;
  • signature;
  • payment details;
  • TSH Life Account;
  • registration of your university; and
  • registration with local municipality.

Furthermore, you may provide us with the contact details of your parents and/or guarantor ensuring that they are aware that such data will be shared. Depending on the location you have booked to stay as a semester guests’ additional data may also be required.

These details will be used to process the booking, billing purposes, complying with registration requirements, sending communications during the course of your stay, sending satisfaction surveys to understand how we can improve the services offered and enrolling you in the TSH Alumni program at the end of your first semester guest experience.

TSH may also use a payment token whereby your payment details are stored as a secure unique payment token enabling simplified payment processes for future payment transactions associated with your account.

We will also use this information to send general marketing e-mails about other TSH news, events and deals but only if you have given us consent to do. You can unsubscribe from marketing e-mails at any time by clicking the unsubscribe link contained in the e-mail.

When you make payments for TSH services on behalf of guests and contracting parties
When you make payments for services on behalf of TSH Guests or contracting parties you will provide payment information that will be processed to complete the payment that is due

When using the TSH LIFE App
When you make use of the TSH LIFE App, we collect the following types of data:

  • we use cookies, which we store on your device. Cookies are small text files, and we use the information contained in these files for essential functions in the App and non-essential functions to improve user experience and perform analytics. Analytic services are provided by third parties and involve only the processing of anonymized data, which generates generic data such as how many users have downloaded the app.
  • profile information that you provide for your user profile (e.g. first and last name, picture, phone number, interests);
  • user content (e.g., photos, comments, and other materials) that you post publicly within the TSHF LIFE App;
  • your preferred payment method. The payment intermediary will ask you to provide some payment data;
  • communications between you and TSH. For example, you may send us maintenance requests. We may send you service-related e-mails (e.g. account verification, changes/updates to features, technical and security notices).
  • laundry transactions when using the App to pay for laundry services.
  • when using the TSH bike sharing system TSH will process location data from the user’s mobile device temporarily to ensure that the bike can only be initially unlocked within a permitted radius of the hotel and can only be officially returned within a permitted radius of the hotel. The functionality of the location data indirectly informs TSH that a user is at a hotel when the bike is initially unlocked and officially returned. TSH does not collect or process any location data from the user’s device when the bike is in use. A record of time is kept confirming the time the bike was unlocked and returned to ensure the bike terms of use are respected. All data will be automatically overridden once the bike has been returned in accordance with the bike terms of use and a new user unlocks the bike.
  • When using the TSH bike sharing system TSH will keep a record of where the bike is locked using the location of the bike lock (not the user’s device), which will only be used if needing to retrieve a bike that has not been returned in accordance with the bike terms of use.

When attending TSH events and using the hotel facilities
When you attend events and make use of the TSH facilities you may be requested to provide personal data for example using the photobooths in the hotel lobbies or logging into the guest Wifi.

This information will be used for the processing activity specified when collecting the personal data.

It may also be used to send general marketing emails about other TSH news, events and deals but only if you have given us consent to do so. You can unsubscribe from marketing e-mails at any time by clicking the unsubscribe link contained in the e-mail.

When joining a “TSH Community” program that enables access to TSH services at discounted rates
When you sign up to a “TSH Community” program you will be required to provide your name and email address. This information will be used to process your subscription and generate a digital or physical card that can be shown to prove your subscription when visiting a TSH property to experience your wonderful benefits. It may also be used to send general marketing emails about other TSH news, events and deals but only if you have given us consent to do so by giving consent to receive such information during the subscription sign up process.

After your TSH experience
After what we hope is only your first TSH experience we will continue to store your personal data in a profile that is strictly accessible by TSH and its affiliates. Should you return to TSH in the future, we want to be able to offer the best possible service, including the ability to customize your stay based on your previous personal preferences. We will only do this to the extent that we believe we have a legitimate interest to do so which in every case will be to improve the service we can offer to you in the future across all our locations and services.

In the case of Semester Guests, you will be automatically enrolled into the TSH Alumni program and gain access to TSH Community perks and benefits. TSH is enthusiastic about staying in touch with our Semester Guests because the relationship between alumni Semester Guests and TSH can be mutually beneficial. You are part of an exciting, global network of people with inspiring ideas and we want to help keep that connection alive. You can of course unsubscribe anytime you like by following the link contained in the bottom of the email or contacting privacy@thestudenthotel.com.

5. Legal grounds for the processing activities identified

Based on the contractual agreement

a. To manage your booking through any of the channels provided to this effect and to process your registration as a TSH guest (Hotel, Collab or The Commons) and for the subsequent business relations with you.

b. Managing, maintaining and effectively controlling the relationship resulting from having contracted the TSH goods or services.

c. To proceed to charge the designated amounts in the event of a booking cancellation outside the established time frame, as appropriate.

d. To manage guests stay at TSH, in addition to providing the services requested during their visit, which includes, among other aspects, preparation of the visit and dealing with any requests made during your stay. For this purpose, we may request data, such as, hotel room requests, organize directions and to prepare the appropriate food menus. This also includes invoicing and charging for services consumed during your stay.

e. To ensure the bike is unlocked in the correct location and returned to the correct location and proceed to apply the relevant charges in accordance with the TSH Bike terms of use.

Based on legal obligations

a. Notify the public authorities or regulatory or government bodies in those cases where it is necessary to so under law, local by-laws or in compliance with regulatory requirements.

b. Legally obligated by law to collect and process personal data (e.g. maintain a hotel guest night register and maintain fiscal data that is required to comply with national fiscal requirements)

Based on TSH legitimate interests

a. Carry out commercial actions and/or advertising communications through any medium including electronic or equivalent communications relating to goods or services offered by TSH.

b. Create profiles based on the personal data available to TSH to ascertain the goods and services most appropriate to your profile, thus maximizing their results and in this way offering you the best of any goods and services of interest to you.

c. To create payment tokens that substitute sensitive payment data with a non-sensitive equivalent, referred to as a token, enabling simplified payment processes during future payment transactions. This enables you to make future payments without needing to provide complete payment information for a second or third time etc.

d. To carry out customer satisfaction surveys with the goods and/or services you have contracted to assess your satisfaction so that TSH can improve its processes and services.

e. To manage, process and respond to any possible complaints or claims. It is in the TSH legitimate interests to maintain the quality of its service and to use the recordings, should it be necessary to protect its legal position in the event of any possible conflict.

f. To send operational relevant information about the TSH product you have purchased or event you have attended.

g. To assess what students or employees have entered into a TSH service agreement as a consequence of a partnership agreement between TSH and an educational partner or corporate partner.

e. To enroll Semester Guests into the TSH Alumni Program and Newsletter.

Based on your explicit consent

a. Should you so authorize (typically using an opt-in tick box), TSH may send marketing material about goods and services other than those that you have contracted or subscribed. TSH may contact you about relevant good and services after a contractual relationship has ended.

b. Should you so authorize on the cookies banner, TSH may monitor cookies and use that information to advertise products/services that may be of interest to you.

c. Should you give consent for TSH to process your data in a different way that is explained at the time of receiving your consent.

6. Who has access to your personal data?

We handle your personal data discretely and access is strictly limited to TSH and our third party partners who have a need to know such information to effectively fulfill our contractual obligations towards you, when it is necessary to perform functions you have granted consent for us to do or any other identified legal ground under data protection law such as an identified legitimate interest. For example, if you subscribe to a TSH service as a consequence of third party advertising or using a referral code TSH may inform the partner who referred you that you have subscribed to a TSH service on the basis of having identified a legitimate interest that informs the partner that the referral has been successful.

7. Your rights

We want to make sure that you are fully in control of your personal data. You have multiple rights and we want to ensure they are respected. If you wish to exercise any of the rights listed below, please make your request by sending an e-mail from the email address that you used when signing up for a TSH service to:

Please state clearly in the subject heading what type of request you are making including as much detail as you can to assist us complete your request as quickly as possible. Please confirm as a minimum:

  • Type of TSH service you signed up for (Hotel, Collab or the Commons)
  • Location
  • Dates
  • Supporting evidence to help identify the correct profile (e.g. booking confirmation)

If in doubt about your identity, we are entitled to ask you to provide proof of your identity first. We will complete your request within 4 weeks.

Right of access
If you want to know what personal data we have collected and/or processed from you, you can request TSH to provide an overview. We will provide you with an overview of your personal data that we collect and/or process.

Rectification
If you believe that the personal data that we process is incorrect, inaccurate or incomplete, you may ask us to change or remove such personal data.

Erasure (‘Right to be forgotten’)
If you want us to remove the personal data we have collected and/or processed from you, you can request TSH to erase your personal data.

Restriction
Instead of requesting erasure, you may also request us to restrict the way we are processing your personal data if this right to restriction does not conflict with a processing activity that is required for the performance of the contract, required by law and does not outweigh a TSH legitimate interest.

Portability
If you want to transfer the processed personal data to another controller of your choice, you may request us to provide you with a copy of your personal data in a structured, commonly used, and machine-readable format.

Object
You have always the right to object against the processing of your personal data by TSH. If it concerns a processing activity that requires consent you are always entitled to remove your consent. If you no longer wish to receive email messages or any other electronic messages from us, then you can deregister for these by clicking on the unsubscribe button in an email message received. You can also unsubscribe by contacting us in accordance with the instructions above.

Limitations of your rights
When a data subject request is made TSH will as a standard policy provide this service free of charge, however in exceptional cases TSH reserves the right to charge a reasonable fee. Data subject requests will only be implemented after the individual making the request have validated their identity, which confirms that they are indeed the subject that the request concerns. This can be achieved by sending the request from the same email address that was used when signing up to a TSH service.

Finally, in certain situations TSH may be entitled to legally refuse requests. If TSH believe there are legitimate grounds that override the interest of the data subjects request, then TSH may reasonably refuse to fulfill the request. TSH will always justify in writing why that is the case.

Right to contact the supervisory body
If you believe your data request is not being handled correctly we kindly request that you contact the DPO by emailing privacy@theatudenthotel.com. If you disagree with the outcome of the DPO’s handling of your complaint, you can submit a complaint to the Dutch Data Protection Authority directly. The Dutch Data Protection Authority will handle the complaint or request.

The appropriate authority in the Netherlands is:

Autoriteit Persoonsgegevens
Postbus 93374
2509 AJ DEN HAAG

8. How do we protect your personal data?

TSH have taken appropriate technical and organizational measures to prevent loss or unlawful processing of personal data including but not limited to:

Physical Access Controls: TSH have taken reasonable measures to prevent physical access, such as security personnel and secured buildings to prevent unauthorized persons from gaining access to Personal Data or have ensured third party partners operating data centres on our behalf are adhering to such controls.

System Access Controls: TSH have taken reasonable measures to prevent Personal Data from being used without authorization. The controls vary based on the nature of the processing undertaken and may include, among other controls, authentication via passwords and/or two-factor authentication, documented authorization processes and logging of access on several levels.

Data Access Controls: TSH take reasonable measures to ensure that Personal Data is accessible and manageable only by properly authorized staff; application access rights are established and enforced to ensure that persons entitled to use a system only have access to Personal Data to which they have privilege of access and a companywide policy that Personal Data cannot be read, copied, modified or removed without authorization in the course of processing.

Transmission Controls: TSH have taken reasonable measures to ensure that it is possible to check and establish to which entities the transfer of Personal Data by means of data transmission facilities is envisaged so Personal Data cannot be read, copied, modified or removed without authorization during electronic transmission or transport.

Input Controls: TSH have taken reasonable measures to provide that it is possible to check and establish whether and by whom personal data has been entered, modified or removed from a system.

Data Backup: Back-ups of the databases are taken on a regular basis and are secured and encrypted to ensure that Personal Data is protected against accidental destruction, loss or unauthorized disclosure.

Logical Separation: Data collected for different TSH services and purposes is logically segregated in TSH systems to ensure that personal data that is collected and processed for the particular purpose it was collected for by TSH.

Security Audit: TSH are implementing a maturity plan that will continuously improve security standards and are working towards a standardized ISO certification.

9. Transfer of personal data to other countries

TSH will endeavor to process your data solely within the European Union (‘EU’) by saving your data on a server located in the EU wherever possible. For many of our business purposes we use cloud-based services. Therefore, for technical and organizational reasons, it may be necessary that your personal data is transferred to servers located in other countries outside of the EU. TSH have implemented internal processes to ensure that your personal data will only be sent to parties and/or countries with an adequate level of personal data protection.

10. How long do we keep your data?

We will not keep your personal data for longer than is necessary for the purposes for which we use it. We are required by law to keep some data for a certain minimum period of time. For example, it could be that after you have checked out of the hotel, we have to keep certain personal data for administrative purposes or due to a legal obligation. Wherever possible, we will pseudonymize or anonymize your personal data to the fullest extent possible.

11. Links to other websites

The Websites may contain links to other websites we do not control. Therefore, we will not be responsible for the content of these websites, nor for the processing of personal data that may occur on these websites.

12. Questions

If you have any questions about this Privacy Statement, please email: privacy@thestudenthotel.com.