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Privacy Policy

At Saughina Ubud, we are committed to working tirelessly towards maintaining our highly regarded and respected quality of service.
Saughina Ubud (“We”) are further committed to ensuring that any of your Personal Data which we have with us, is protected and respected always.

Our use of your personal information is governed by this Privacy Notice and any other documents referred to in it.

WHAT DOES THIS POLICY DO?


This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

Saughina Ubud is a Data Controller for the personal information that it collects and uses about you and a Processor for some data referred to us by any Third Party who you would have allowed, or enabled to use your data for a lawful purpose relating to our services. We will always treat your personal information as confidential and your personal information will only be shared with others in accordance with this Privacy Notice.

Data Protection Compliance, 
By visiting saughinaubud.zeevou.direct you are accepting and consenting to the practices described in this policy. The General Data Protection Regulations are to safeguard your personally identifiable information or personal data. This privacy notice will be regularly reviewed and updated. 
 
We are committed to ensuring the privacy of our guests and will use information you have provided to us in the process of booking a stay in our serviced apartments in accordance with this privacy policy. We will only collect information lawfully and we will only process information lawfully. 

This Privacy Notice explains:
  • What personal information is
  • How we collect your personal information
  • The types of personal information we collect
  • How we use your personal information
  • The legal basis for processing your personal information
  • How we share your personal information
  • How long we keep your personal information
  • How we keep your personal information secure
  • Overseas transfers of your personal information
  • Your rights in relation to your personal information

If we need to change the way in which your personal information is used by us, this Privacy Notice will be updated and if the changes are significant, we will advise you.

WHAT IS PERSONAL INFORMATION?


Personal information is any information that, on its own identifies you, or can be put together with any other either information, can identify you or tell us something about you. This could include information such as name, email address, other contact details, date of birth, bank account details or any information about your needs or circumstances.

Some personal information is classified as “special” data under data protection legislation. This includes information relating to health, racial or ethnic origin, religious beliefs or political opinions and sexual orientation. This information is more sensitive, and we need to have further justifications for collecting, storing and using this type of personal information.

Any references to personal information in this privacy notice will include personal data, and where relevant, special categories of personal data.
Much of the personal information we process is information that you or someone acting on your behalf knowingly provides to us.
This Policy also applies to the personal information about you that we receive from a third party, unless specifically covered by such third party’s privacy policy.

On this site, “Saughina Ubud”, “our” and “we” each mean any permanent Saughina Ubud Office or temporary location being used as such, in the United Kingdom, which collects and use your information in the manner set out in this Privacy Notice.

HOW DO WE COLLECT PERSONAL INFORMATION?


We may collect and process all or some of the following data about you when you contact us, enquire with us or interact with us.
We collect information about you (which can include documents) through a variety of different methods including from you directly and from third parties.
 
From you directly:
You may provide personal information and /or documents by:
  • Completing forms on our websites or other online platforms which ARE under our direct control or direct management 
  • Completing forms on Signable (our online digital e-signature platform)
  • By communicating with us by post, phone, email, sms text, watsapp, messenger or similar
  • By supplying documents through any of these methods
 
From third parties: 
We may receive personal information and/ or documents about you from various third parties such as (but not limited to):
  • Websites or other online platforms which are NOT under our direct control or direct management 
  • Booking.com
  • Airbnb
  • Anyone making the booking on your behalf (such and en employer or spouse)
  • Stripe
  • Paypal
 
CCTV:
Some of the apartment buildings we operate in have CCTV which will record your image on entering and exiting the building.

INFORMATION YOU GIVE US:


You may give us information about you by making a booking or filling in forms on our site saughinaubud.zeevou.direct (“our site”) or by corresponding with us by phone, email or otherwise. This includes information you provide when you search for a serviced apartment, book a serviced apartment on our site and when you report a problem with our site. The information you give us at this point is likely to include your name, address, email address and phone number, financial and credit card information, special requirements such as those relating to any disability or medical condition which may affect the chosen arrangements and dietary restrictions (which may disclose your religious beliefs).

When you make a booking via our partner property management system – who then process this Data on our behalf you can be assured that this is via a secure https:// connection and any details provided are stored securely in the booking system. During this process, as a guest, you would create an account which you can login to and see details of reservations, as well as your data which is held there. This can be edited by you, giving you control.

TYPES OF PERSONAL INFORMATION WE MAY COLLECT:


The types of personal information that we may collect, receive and process, includes:
  • your name, gender, personal and work contact phone number(s) and email addresses, business title, date and place of birth, image, nationality, home address, and passport and visa information;
  • guest stay information, dates of arrival and departure, goods and services utilised, special requests made, observations about your service preferences, telephone numbers dialled, and faxes, texts and telephone messages received (if applicable);
  • your credit or debit card details including billing address, and your bank account details;
  • the name of your company if you are placing a business booking;
  • information, feedback or content you transparently provide regarding your marketing preferences, in surveys, sweepstakes, contests, or promotional offers, or to our websites and those of third parties;
  • in limited cases, information relating to the credit of customers (never without prior disclosure and authority);
  • your vehicle registration number (where parking has been booked);
  • the names of other guests (if over 16 years of age);
  • information about your accommodation requirements such as budget, length of stay and accommodation type;
  • such other information as we deem necessary and as set out in our terms of business from time to time and/or as required under The Immigration (Hotel Records) Order 1972.

When you wish to book an apartment with us we will ask you for the following documents:
Such documents as we deem necessary and as set out in our terms of business from time to time [this may include (but is not limited to) a copy of your passport and/or other identity document and a photograph of both sides of your payment card (but with part of the long PAN number obscured)] and/or as required under The Immigration (Hotel Records) Order 1972 
Where we require a deposit from you and/or where you add extras to your booking we may also collect the following information from you to process the payment
 
  • Your payment card details (although we will NOT store this information after processing your payment via one of our payment platforms (such as but not limited to Sagepay or Worldpay) 
  • Such other information as we may deem necessary.
 
The Immigration (Hotel Records) Order 1972 requires that we must collect the following information from guests 
  • Full name
  • Nationality.
 
For all who are not British, Irish or Commonwealth guests
  • Passport number and place of issue (or other document which shows their identity and nationality)
  • Details of their next destination (including the address, if known) on or before departure

PAYMENTS FOR AN APARTMENT 
Subject to our right to collect payment card details as referred to above, your payment card details will normally be supplied by you directly to one of our payment platforms (such as but not limited to Stripe or Worldpay) via a secure payment link which we provide you. 

Although we can access this information, we will NOT download or store this information outside of the payment platform. 
Your payment card details will only be used as set out in our terms of business from time to time.
 
FAILED AND CANCELLED BOOKINGS
If you supply personal information and/or documents in connection with a failed and/or cancelled booking we will retain that information as set out in this privacy policy.

INFORMATION WE COLLECT ABOUT YOU:


With regard to each of your visits to our site we may automatically collect the following information:
  • technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
  • information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.

INFORMATION WE RECEIVE FROM OTHER SOURCES:


We may receive information about you if you use a website that we either operate or which directly processes Data on our behalf, via the other services we provide. We work closely with many third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers) and therefore we may receive information about you from them.

If you have booked through a third party website (such as, but not limited to Booking.com or Silverdoor) we may collect the above personal information from them (as booking agent on your behalf) rather than directly from you. 

If an employer spouse or other third party has booked the apartment for you we may collect the above personal information from them (as booking agent on your behalf) rather than directly from you. 

In the case of indirect bookings we may still ask you directly to verify such personal information as we may deem necessary to reserve the apartment for you.

We will only request as much Data from you that we require at certain stages in our business processes. This is good practice in GDPR terms.

WHY DO WE COLLECT THIS INFORMATION?


  • To provide you with products and services. Each product and service have different information requirements. Therefore, the personal data we need, and what it is needed for, can differ.
  • To provide you with information about products and services that we, believe will be of interest to you. We will only do this with your consent. You can withdraw your consent at any time by changing your marketing preferences or unsubscribing using the link at the bottom of the emails we send you (this could either be an “unsubscribe” link or a “manage my preferences” link), or by sending an email.

HOW WE USE THIS INFORMATION:


We will only use your personal information lawfully. We use information held about you in the following ways:

INFORMATION YOU GIVE TO US:


We will use this information:
  • we may use your name, address and credit/debit card details to process your serviced apartment booking even if this has been booked through an agent;
  • we will use your details to provide you with the information, products and services that you request from us, to manage your booking, send you notifications and communicate with you generally.
  • to provide you with information about other serviced apartments and/or services we offer that are like those that you have already purchased or enquired about;
  • to ensure that content from our site is presented in the most effective manner for you and for your computer.

INFORMATION WE COLLECT ABOUT YOU:


We will use this information:
  • to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
  • to improve our site to ensure that content is presented in the most effective manner for you and for your computer;
  • to allow you to participate in any interactive features of our service, when you choose to do so;
  • as part of our efforts to keep our site safe and secure;
  • to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
  • to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.

We may combine this information with information you give to us and information we collect about you. We may use this information and the combined information for the purposes set out above (depending on the types of information we receive).
In addition, if we are providing a service to you, or on your behalf, where we are required to do so by law, we may request a copy of your passport.

The lawful grounds (reasons) which we will typically use for processing your personal information are:

  • Where we need to perform the contract between us (contractual obligation)
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests
  • Where we need to comply with a legal or regulatory obligation
  • With your permission and agreement (consent)
 
Where we need to perform the contract between us:
 
  • We use the personal information to fulfil our contractual obligation to you in supplying a serviced apartment including (but not limited to) processing your payment, organising your key collection and check-in, and providing you with information on what to do on arrival and whilst a guest in the apartment 
  • Where parking has been booked we will pass your vehicle registration number onto any apartment management company and/or car park operator to ensure you can park on arrival and will not receive a parking penalty notice
  • We will also pass guest names (if over 16 years of age) and contact details onto other third parties such as our administration teams, housekeeping and cleaning teams, maintenance contractors, and our security and reception teams for them to assist us in fulfilling our contractual obligation to you in supplying a serviced apartment
 
Where it is necessary for our legitimate interest:

We may process personal information that we hold to further our legitimate interests which may include the following activities:
  • Communications with you before you make a booking and become a guest
  • Communications with you after you make a booking and are a guest 
  • Record keeping for book-keeping, accounting, banking and tax reporting 
  • Occupancy and revenue reporting
  • Monitoring client spend and credit
  • Monitoring website performance
  • Monitoring customer service performance
  • Monitoring social media performance
  • Debt recovery 
  • Fraud prevention
  • Processing and replying to chargeback requests 
  • Processing and replying to refund requests 
  • Reporting guest misconduct 
  • Reporting suspected criminal activity, including but not limited to suspected activity involving fraud, drugs and child exploitation
  • Asking you to leave a review 
  • Responding to a review from you

Where we need to comply with a legal obligation:

We may process personal information that we hold because we have to by law. 
This will typically arise from our obligations under The Immigration (Hotel Records) Order 1972. This may also arise where we are requested directly (or by third parties) to supply personal information to the police and/or or other crime prevention and/or enforcement agencies/ authorities in connection with suspected criminal activity, including but not limited to suspected activity involving fraud, drugs and child exploitation. This may also arise where a local council requests information from us about the use of any of our apartments.  

With your permission and agreement (consent):
 
Generally, we do not rely on consent as a legal ground (reason) for processing your personal data, other than in relation to sending marketing communications to you via post, phone, email, SMS, Whatsapp, Messenger or similar.
 
Marketing by Saughina Ubud:
 
By choosing to stay with us you are expressly consenting (opting in) to receiving marketing communications from Saughina Ubud (and any sister companies) before during and after the booking completes.

You have the right to stop the processing of your information for any and all direct marketing activity through all channels, or selected channels. We must always comply with your request because whenever you have given us consent to process your personal data, you have the right to change your mind and withdraw that consent at any time.

You can withdraw consent to marketing at any time by emailing us at .
You can also withdraw consent to marketing by click the unsubscribe button on any marketing email you may receive from us. 

Marketing by third parties:
We do not share personal data with any third party for marketing purposes, if this however should there be a circumstance where this is required we will get your separate express opt-in consent before we share your personal data with any third party for marketing purposes.
 

DATA SECURITY


Because the security of your personal information is important to us, Secured Socket Layer (“SSL”) software is used on our booking platform ‘Elina’ to encrypt the personal information that you provide to us. If your browser is SSL enabled (which most are), your transmission of personal information to this platform online will be encrypted. You can verify whether your personal information is transmitted using SSL encryption by confirming the symbol of a closed lock or solid key on the bottom bar of your browser window. Different browsers may use different symbols. You can also verify that your personal information will be encrypted using SSL encryption by making sure that the prefix for the web address listed for that page has changed from “http” to “https”. If you do not see the appropriate symbol and the "https" prefix, you should not assume that the connection is secure.

DISCLOSURE OF YOUR INFORMATION

We may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006. We may share your information with selected third parties including:
- Business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you (such as, but not limited to, apartment management companies, housekeeping and cleaning teams, maintenance contractors, security and reception teams, and car park operators).
- Analytics and search engine providers that assist us in the improvement and optimisation of our site.
- Credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you.
- Payment platforms (such as, but not limited to, Stripe and Worldpay) for the purpose of processing payments.
- Third party booking platforms (such as, but not limited to, Booking.com) where you have made your booking through them.
We may disclose your personal information 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.
- If Saughina Ubud or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
- If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements; or to protect the rights, property, or safety of Saughina Ubud, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

HOW LONG WE KEEP YOUR PERSONAL INFORMATION

We will only retain your personal information 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. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

OVERSEAS TRANSFERS OF YOUR PERSONAL INFORMATION

The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA") or the UK. It may also be processed by staff operating outside the EEA or UK who work for us or for one of our suppliers. By submitting your personal data, you agree to this transfer, storing or processing. Where we transfer your personal data outside the EEA or UK, we will ensure that it is protected and transferred in a manner consistent with legal requirements. This may include:
- Transferring your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
- Using specific contracts approved for use in the UK which give personal data the same protection it has in the UK.

YOUR RIGHTS

Under data protection legislation, you have the following rights in relation to your personal information: Right to be informed: You have the right to be provided with clear, transparent and easily understandable information about how we use your information and your rights. This is why we're providing you with the information in this Privacy Notice. Right of access: You have the right to obtain access to your information (if we're processing it), and certain other information (similar to that provided in this Privacy Notice). This is so you're aware and can check that we're using your information in accordance with data protection law. Right to rectification: You are entitled to have your information corrected if it's inaccurate or incomplete. Right to erasure: This is also known as 'the right to be forgotten' and, in simple terms, enables you to request the deletion or removal of your information where there's no compelling reason for us to keep using it. This is not a general right to erasure; there are exceptions. Right to restrict processing: You have rights to 'block' or suppress further use of your information in certain circumstances. When processing is restricted, we can still store your information, but may not use it further. Right to data portability: You have rights to obtain and reuse your personal data for your own purposes across different services in certain circumstances. Right to object to processing: You have the right to object to certain types of processing, including processing based on our legitimate interests and processing for direct marketing (which we do only with your consent). Right to withdraw consent: If you have given your consent to anything we do with your personal information, you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your personal information with your consent up to that point is unlawful). Rights related to automated decision making including profiling: You have the right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you. We do not carry out automated decision making or profiling. If you wish to exercise any of these rights, please contact us using the details provided below. 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 may 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.