Privacy and Cookie Policy

Table of Contents

• Introduction and Purpose of This Privacy Policy
• The Controller and Who We Are
• Your Personal Information
• How We Collect Your Personal Data
• Uses Made of Your Information
• Disclosure of Your Information
• Storing Your Personal Data
• Your Rights
• How to Complain
• Changes to Our Privacy and Cookies Notice
• Information About Our Use of Cookies
• Privacy Notice for Hotelhub Alexa Skills
• Terms of Use for Hotelhub Alexa Skills
• Contact

Introduction and Purpose of This Privacy Policy

This privacy and cookies notice (“notice”) aims to give you information on how Travel Centric Technology Ltd (“we”, “us”, “our”) collects and processes your personal data when: (i) you visit www.hotelhub.com (our “website”), regardless of where you visit it from; or; (ii) you are granted access to use our HotelHub solution (our “solution”). It will also tell you about your privacy rights and how the law protects you. The website is not intended for children and we do not knowingly collect data relating to children. It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them

The Controller and Who We Are

For the purpose of the General Data Protection Regulation (“GDPR”) and the Data Protection Act 2018, (collectively the “Data Protection Laws”) the Data Controller is Travel Centric Technology Ltd, registered in England and Wales under company number 06514088, with registered office address at 2nd Floor, Magna House, 18-32 London Road, Staines-Upon-Thames, TW18 4BP.

Your Personal Information

We collect and process some or all of the following types of information from you in the course of your use of the website or otherwise in relation to our solution:

Categories of data	Data processed
Identity Data	First name, surname.
Contact Data	Postal address, email address, telephone number.
Commercial Data	List of products and services from which you benefit.
Communication Data	Information you provide in the course of communications with us, e.g. when requesting further details of our solution or providing feedback.
Technical Data	Information in relation to your visits to the website and/or the solution, e.g.IP addressconnection and usage logstraffic datalocation dataresources accessed

We also collect, use and share “aggregated data” such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this 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). Nor do we collect any information about criminal convictions and offences

How We Collect Your Personal Data

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity Data or Contact Data by filling in forms on our website or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

• enquire about our services through our website;
• register with us for use of our solution;
• request marketing to be sent to you;
• enter a survey; or
• give us feedback or otherwise contact us.

Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy for further details.

Uses Made of Your Information

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose	Type of data	Lawful basis
Enquiry response	Identity Data, Contact Data, Communi-cation Data	Legitimate interest – to respond to enquiries through our website or by email, and to allow interested individuals to refer us to their organisation.
Account creation and service provision	Identity Data, Contact Data, Communi-cation Data	Legitimate interest – to register you and provide you with access as a user of the solution pursuant to a contract we have with your organisation.
Security	Identity Data, Contact Data, Technical Data	Legitimate interest – to keep your data and our solution secure.
Market-ing our services and solution	Identity Data, Contact Data, Commercial Data	Consent – we may contact you by electronic means (email or SMS) only if you have consented to such communication. If you do not want us to use your data in this way, please either (i) tick the relevant box situated on the form on which we collect your data; (ii) unsubscribe from our electronic communications using the method indicated in the relevant communication; or (iii) inform us at any time by contacting us at the contact details set out below.
Fraud prevention	Identity Data, Contact Data, Technical Data	Legitimate interest – to identify, monitor and prevent potential fraud
Troubleshooting	Technical Data	Legitimate interest – to track issues which may occur on our systems

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Disclosure of Your Information

We will only share your information with third parties listed below for the purposes described above in the “Uses made of your information” section.

We may pass your information to our third-party service providers, agents, subcontractors and other associated organisations for the purposes of completing tasks and providing services to you on our behalf.

We may disclose your personal data to any member of our corporate group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006 (where applicable).

We may also disclose your personal data to third parties:

• in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets; or
• if we or substantially all of our assets are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets; or
• if we are under a duty to disclose or share your personal data in order to comply with any legal obligation; or
• to protect our rights, property, or safety or that of our affiliated entities and our users and any third party we interact with to provide the website or the solution; or
• in relation to selected third parties only, only to the extent that you have consented to such selected third parties notifying you about certain goods or services, which may be of interest to you.

Other than as set out above, and save insofar as is necessary in order for us to carry out our obligations arising from any contracts entered into between you and us, we will not share your data with third parties without giving you notice by updating this notice.

Storing Your Personal Data

Security

We take appropriate measures to ensure that any personal data is kept secure, including security measures to prevent personal data from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal data to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We also depend on you to protect your information. Where required. please set up a strong password and keep it confidential. If you become aware of any breach of security, please notify us immediately.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to the website or the solution; any transmission is at your own risk.

The website and the solution may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and terms of use and that we do not accept any responsibility or liability for these policies and terms of use. Please check these policies before you submit any personal data to these websites.

Keeping your personal data up to date

It is important that the information you provide to us is accurate and up to date, and that you inform us without delay of any significant change.

If your personal details change you may update them by contacting us using the contact details below.

We will endeavour to update your personal data within seven (7) working days of any new or updated personal data being provided to us, in order to ensure that the personal data we hold about you is as accurate and up to date as possible.

How long we keep your personal data

We will hold the data set out above for a reasonable time having regard to the nature of the personal data and the purpose for which it was collected. In particular:

• Where we hold your personal data subject to a legal requirement (e.g. as required by HMRC), we will hold your data with the relevant legally required period;
• Where we hold your personal data in connection with the performance of a contract with one of our customers or suppliers, we will hold your data, and in particular any communications between you and us in relation to the negotiation or performance of the contract by either party for so long as that contract is in force;
• Where we hold your personal data in connection with the marketing or promotion of our business, or monitoring our commercial relationship with you, we will hold your data for up to 1 year, or for up to 1 year after you last communicated with us, if later;
• In respect of Technical Data, we hold your data for 1 year from the date of collection.

Where we store your personal data

All information we hold about you is stored on secure servers in the United Kingdom.

The data that we collect from you may be transferred to, and stored at, a destination outside the United Kingdom or European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff may be engaged in, among other things, the fulfilment of your orders, the processing of your payment details and the provision of support services.

Such countries do not have the same data protection laws as the United Kingdom and EEA. Whilst the European Commission has not given a formal decision that such countries provide an adequate level of data protection similar to those which apply in the United Kingdom and EEA, any transfer of your personal data will be subject to appropriate safeguards (as permitted under Article 46(5) of the General Data Protection Regulation) that are designed to help safeguard your privacy rights and give you remedies in the unlikely event of a misuse of your personal data.

If you would like further information, please contact us (see ‘Contact’ below). We will not otherwise transfer your personal data outside of the United Kingdom or EEA or to any organisation (or subordinate bodies) governed by public international law or which is set up under any agreement between two or more countries.

Your Rights

Under the General Data Protection Regulation you have a number of important rights free of charge. In summary, those include rights to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

• If you want us to establish the data’s accuracy.
• Where our use of the data is unlawful but you do not want us to erase it.
• Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals rights under the General Data Protection Regulation.

If you would like to exercise any of those rights, please:

• email, call or write to us (contact details provided below),
• let us have enough information to identify you (e.g. name, login details),
• let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill), and
• let us know the information to which your request relates, including any account or reference numbers, if you have them.

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. Alternatively, we could 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 could 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 and keep you updated.

How to Complain

We hope that we can resolve any query or concern you raise about our use of your information.

The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns/ or telephone: 0303 123 1113.

The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred.

Changes to Our Privacy and Cookies Notice

We reserve the right to modify this notice at any time. Any changes we may make to our notice in the future will be notified to you.

Information About Our Use of Cookies

We may collect Technical Data (as defined above) This is statistical data about our users’ browsing actions and patterns and does not identify any individual. We may, however, use such information in conjunction with the data we have about you in order to track your usage of our services.

The website uses cookies to distinguish you from other users. This helps us to provide you with a good experience when you browse the website and also allows us to improve it.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.

The cookies we use include:

• “Analytical” cookies. They allow us to recognise and count the number of visitors and to see how visitors move around the website when they are using it. This helps us to improve the way the website works, for example, by ensuring that users are finding what they are looking for easily.
• “Strictly necessary” cookies. These are cookies that are required for the operation of the website. They include, for example, cookies that enable you to log into secure areas of the website.

Please note that third party affiliates may also use cookies, over which we have no control.

Cookies which are strictly necessary for the core functionality of the website are enabled by default, and set automatically at the point you access the website.

Any cookies which are not strictly necessary for the functioning of the website will not be set unless you expressly consent to them through the cookie banner by clicking “accept”.

You may block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of the website.

Privacy Notice for Hotelhub Alexa Skills

This privacy notice (“notice”) governs your use of Travel Centric Technology Ltd (“we”, “us”, “our”)’s Alexa skills (“skills”). Please read this notice, our Terms of Use for HotelHub Alexa Skills, and all privacy policies that apply to your use of Alexa by Amazon Digital Services LLC and its affiliates (“Amazon”).

This notice is in addition to and supplements any and all privacy policies applicable to your use of our HotelHub functionality, including without limitation any policies you agreed to when setting up your MyHotelHub account. In the event of any conflict between this notice and any such other policies, the provisions in this notice will take precedence solely in respect of your use of our skills.

In this notice, the term “Alexa” means Amazon’s ‘Alexa’ Voice Service and any third party services included in it (including our skills) and any and all related software.

Any use by you of any of our skills will be deemed your acceptance of this notice, so if you do not agree with this notice, please do not use our Alexa skills.

For the purpose of the General Data Protection Regulation (“GDPR”) and the Data Protection Act 2018, (collectively the “Data Protection Laws”) the Data Controller is Travel Centric Technology Ltd, registered in England and Wales under company number 06514088, with registered office address at Centrum House, 36 Station Road, Egham, Surrey TW20 9LF.

The HotelHub skill is a notification service linked to users’ MyHotelHub account. When you use our skills to talk to Alexa, the voice input is sent to Amazon and our team where we use it to understand how our skills will benefit you and in order for our skills to provide appropriate responses.

Our skills do not collect or hold any data. Your MyHotelHub account collects and processes certain types of data in order to enable essential services that include, but are not limited to, confirmation, modification and cancellation of hotel bookings, in accordance with the relevant policies you agreed to when setting up your MyHotelHub account.

By telling our skills to read out notifications, you acknowledge that in doing so Alexa will have access to any data incorporated in such notifications, and accordingly your continued use of our Alexa skills will be deemed acceptance of such access.

Updates to our skills may enable analysis of the commands being given through the skill, frequency of such commands and more general analysis of how and when certain phrases are used, along with other analytics to help us to improve our skills. By using our skills you consent to such analytics by us and by Amazon (subject to its own policies).

We may make changes to this notice from time to time. This notice (as updated) can be found on the relevant HotelHub web page via web link and on the description page of the relevant HotelHub skill in the Alexa App or in the Alexa Store. Any use by you of any of our skills will be deemed your acceptance of this notice (as updated).

Terms of Use for Hotelhub Alexa Skills

These terms of use (“Terms”) govern your use of Travel Centric Technology Ltd (“we”, “us”, “our”)’s Alexa skills (“skills”). Please read these Terms, our Privacy Notice for HotelHub Alexa Skills, and all terms of use that apply to your use of Alexa by Amazon Digital Services LLC and its affiliates (“Amazon”).

These Terms are in addition to and supplement any and all terms applicable to your use of our HotelHub functionality, including without limitation any terms you have agreed to when setting up your MyHotelHub account. In the event of any conflict between these Terms and any such other terms, the provisions in these Terms will take precedence solely in respect of your use of our skills.

In these Terms, the term “Alexa” means Amazon’s ‘Alexa’ Voice Service and any third party services included in it (including our skills) and any and all related software.

Any use by you of any of our skills will be deemed your acceptance of these Terms, so if you do not agree with these Terms, please do not use our Alexa skills.

Our skills are made available free of charge. We do not guarantee that our skills, or any functionality offered by them, will always be available or will be uninterrupted. We may suspend or withdraw or restrict the availability of all or any part of our skills for business and operational reasons. We may also make changes to our skills from time to time.

Although we make reasonable efforts to keep our skills up to date and error free and free from bugs and viruses, we make no representations, warranties or guarantees, whether express or implied, in this regard. Further, our skills are offered as information only and are not intended to amount to advice on which you should rely. You are solely responsible for your use of our skills and any reliance placed on the information provided by them. You are responsible for configuring your information technology, computer programmes and platforms to access our skills and for your own virus or other protection software.

As our skills are provided via Amazon, you acknowledge that provision of our skills by us is subject to Amazon’s policies in place from time to time, and we have no control over such policies.

We may make changes to these Terms from time to time. These Terms (as updated) can be found on the relevant HotelHub web page via web link and on the description page of the relevant HotelHub skill in the Alexa App or in the Alexa Store. Any use by you of any of our skills will be deemed your acceptance of these Terms (as updated).

If you are a consumer, please note that these Terms, their subject matter and their formation, are governed by English law. You agree that the courts of England and Wales will have exclusive jurisdiction except that if you are a resident of Northern Ireland you may also bring proceedings in Northern Ireland, and if you are resident of Scotland, you may also bring proceedings in Scotland.

If you are a business, these Terms, their subject matter and their formation (and any non-contractual disputes or claims) are governed by English law. You agree that the courts of England and Wales will have exclusive jurisdiction.

Contact

All questions, comments and requests regarding this notice should be addressed to infosec@hotelhub.com.