Why We Process Your Personal Information
To arrange Stay Alfred accommodations, there’s no avoiding the need for some personal information. We must know who you are so we can prepare for your stay, manage payment, and ensure you have a positive experience. Therefore, if you do not agree to the terms of this Policy, please do not use the Services.
Information We Process to Provide the Services
Our short-term rentals involve a few steps that require access to your personal information. First, we need to determine when and where you wish to stay. We also require your basic contact information when preparing a rental agreement, including your name, email address, and street address, and phone number. We may also ask you to submit and we may process data that is personal to you, including your age, gender, geographic location, and travel information. We will require you to select a user name and a password or PIN when registering as a user of the Services. We receive and store this information and use it to create a user profile and provide you with services. We may use your e-mail address or mobile phone number to contact you about your experience with the Service and notify you about company news and promotions.
When you use a mobile platform to access the Services, we may collect and record certain information such as your unique device ID, hardware type, media access control (“MAC”) address, international mobile equipment identity (“IMEI”), the version of your operating system (“OS”), and your location (based on your Internet Protocol (“IP”) address). This information is useful to us for troubleshooting and helps us understand usage trends and for providing you with the correct version of the application.
We may also receive information about you if you are a guest of someone else. Shortly before you arrive at your accommodations, we send out notifications using your email and phone number. These notifications provide information about how to access your accommodations and other information that will help you settle in to your stay. If you have arrived at the Services through the use of an Online Travel Agent website (“OTA”), the OTA may have provided us with some of your personal information. Upon successful completion of a reservation, we may transmit your personal information back to the OTA to inform them of the final reservation.
Data Privacy Rights Under General Data Protection Regulation (GDPR)
If you are a resident of the European Economic Area, you have the following rights with respect to your personal data:
Stay Alfred will take reasonable steps to allow you to correct, amend, delete, or limit the use of your personal data. Please contact us if you wish to learn what personal data we hold about you or would like to request deletion of your personal data. Once we have verified your identity, we will comply with all reasonable requests.
You may bring a complaint directly to us by emailing us at [email protected]. We take all of your concerns seriously and will review any written complaints received by us. We will cooperate with the appropriate regulatory authorities to resolve any complaints regarding your personal data.
You also have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority.
Why We Process Your Personal Information
The following list identifies why Stay Alfred uses your personal information when providing the Services:
A. Providing Accommodation Information. There are several steps involved in the booking process. We must first determine when and where you wish to stay so we can provide relevant information about accommodation options.
B. Booking Reservations. We need to know the identity of our guests so we can provide access to the accommodations and perform our obligations under the short-term rental agreement.
C. Public Records Searches. When arranging your stay, some of the properties containing our accommodations require a public records search for guests that are U.S. citizens. Conducting a search will require processing of your name and other basic contact information. We do not have the authority to provide accommodations to persons if a public records search returns a disqualifying background check. Your specific jurisdiction may include additional restrictions on the use of background checks in relation to past criminal convictions. If a U.S. citizen resides within the European Economic Area, we cannot conduct a background check that includes criminal convictions due to Article 10 of the GDPR.
D. Guest Notifications. We provide our guests with SMS or email notifications regarding the status of their accommodations. We also use these notifications to help guests understand the process of using our Services.
E. Payment. We use a third-party payment processor to facilitate the making of payments through the Services.
F. Customer Surveys & Research. We may use your contact information to ask you about your guest experience and about your use of the Services. We use this feedback to improve our guest experience and online Services.
G. Marketing. We use your information when developing and providing relevant marketing materials. Our goal is to only provide you with materials that are of interest to you.
Direct Marketing. We provide marketing materials to our users, including direct emails and other written materials.
Custom Audience Creation. We use personal data to understand the users of our Services. Based on this understanding, we develop and refine our models of our market segments and marketing personas. We use these models to provide social media marketing to a customized audience that includes people we believe will be interested in the Services.
H. Property Management Software. We use your personal information within third-party property management software to manage our short-term rental properties.
I. Profiling. We profile customer interests based on the information customers present during the booking experience. We may utilize information from third-parties when determining whether specific customers fit within a particular market segment. Our profiling and analysis processes are not fully automated.
K. Detecting and Preventing Fraud. We use your information to monitor for potentially fraudulent activities committed using the Services.
L. OFAC Compliance. The United States Treasury Department’s Office of Foreign Assets Control (“OFAC”) prohibits United States businesses from engaging in business transactions with certain individuals, businesses, and organizations, along with persons from certain countries. We are subject to these OFAC requirements and therefore must know your identity and use your information to confirm providing accommodations to you would not violate OFAC regulations.
M. Legal Obligations. In addition to the specific bases for disclosure of personal data set forth in this section, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject. To the extent we are legally required to disclose information to law enforcement, we will comply with such requests. We will not otherwise voluntarily disclose your information.
Our Legal Bases for Processing Personal Information
Performance of a Contract. We require access to your information for purposes A –B because without that information we would be unable to perform under our short-term rental agreements. These purposes include when we prepare the agreements relating to your accommodations upon your request and when we determine whether we can perform under a contemplated agreement. We also require access to your information when performing under the same agreements, otherwise we would be unable to identify the persons entitled to stay with us.
Legitimate Interests. Our use of your information is necessary for our legitimate interests under purposes C - K. We have a legitimate interest in providing an excellent user experience and we would be unable to provide notifications to our users relating to their accommodations without access to their personal information. We also have legitimate interests in providing customer support, evaluating and improving our Services (using Service Usage Statistics or direct customer feedback), and in detecting and preventing fraud, which helps protect us and our customers from harm. Additionally, we have a legitimate interest in conducting background checks for U.S. citizens because we otherwise could not provide access to some of our accommodations.
With respect to Profiling, we have concluded the processing of user information is not likely to result in a high risk because i) each user profile includes a limited level of detail; ii) the profiles only extend to interest in travel and related services; iii) the targeting of marketing materials is unlikely to have a significant effect on the user; and iv) our internal processes are intended to promote accuracy, fairness, and non-discrimination. We value your fundamental rights and freedoms and therefore do not engage in uses of your information where our legitimate interests are outweighed by your fundamental rights and freedoms.
Fulfilment of Legal Obligations. We also rely where applicable on compliance with legal obligations, including, but not limited to, purposes L – M, including law enforcement requests and United States Treasury Department Office of Foreign Assets Control compliance.
Where and How is my Personal Information processed?
Stay Alfred is located on the West Coast of the United States. Stay Alfred uses the services of the following processors when booking and providing your stay:
Transfers of Personal Data
Pursuant to the GDPR, all transfers of personal data are subject to either (i) an adequacy decision, or (ii) appropriate safeguards.
How long does Stay Alfred retain my Personal Information?
We will retain your personal information for the period necessary to fulfill the purposes outlined in this Agreement unless a longer retention period is required or permitted by law, for legal, tax or regulatory reasons, or other legitimate and lawful business purposes.
Can I Limit Stay Alfred’s Processing of my Personal Information? Can I Request Deletion of my Personal Information?
Yes, you may limit our processing of your data or request deletion by contacting us at [email protected]. However, if compliance with your request would prevent Stay Alfred from being able to provide the Services to you, then compliance with your request may require termination of any short-term rental agreements between you and Stay Alfred.
I Reached Stay Alfred Through an Online Travel Agent Website – Does that Website have Access to my Personal Information?
Yes, upon successful reservation of your accommodations, information about your reservation is transmitted back to the Online Travel Agent Website. The precise information transmitted during this process varies because OTA websites vary, but the information we transmit will generally include your name, contact information, and details relating to your accommodations.
Does Stay Alfred Process the Personal Information of Children?
Stay Alfred requires that all of its users be over 18 years of age. If you have concerns or believe Stay Alfred may have received personal information relating to a person under the age of 18, please contact us at [email protected].
How can I Access my Information? Can I Request a Correction?
Yes, you may obtain a copy or request a correction of your personal information by emailing [email protected]. You may also contact applicable regulatory authorities regarding our processing of your personal information.
Does Stay Alfred use my Personal Information for Automated Decision-Making?
Stay Alfred does not rely on fully automated decision-making that results in significant effects on the user.
California Consumer Privacy Act of 2018
If you are a California resident, you may have additional privacy rights regarding your personal data. These rights include the right to request disclosure of the categories of information collected, why that information is collected, and the types of third parties receiving access to your information. You may also request deletion of your data and obtain information relating to any sharing of information with third parties.
To the extent possible, users will receive equal service and price regardless of whether they exercise their privacy rights under the California Consumer Privacy Act of 2018. Stay Alfred does not sell the personal data of its users.
You may contact us regarding these rights by emailing us at [email protected].
Usage Statistics & Tracking
Cookies. Cookies are small text files that are transferred to your computer and/or device to remember things about your visit, such as your preferences or a user name and password. Information contained in a cookie may be linked to your personal information for purposes such as improving the quality of the Service or tailoring recommendations to your interests. You can disable cookies at any time, although it may prevent you from accessing or using some or all features of the Service.
Web Beacons. A “Web Beacon” is an object that is embedded in a web page that is usually invisible to the user and allows website operators to check whether a user has viewed a particular web page. Stay Alfred may use Web Beacons with the Services to count users who have visited particular pages and to deliver co-branded services. Web Beacons are not used to access users’ personally identifiable information; they are a technique Stay Alfred may use to compile aggregated statistics about usage of the Services. Web Beacons collect only a limited set of information including a cookie number, time and date of a page view, and a description of the page on which the Web Beacon resides.
You may not decline Web Beacons. However, they can be rendered ineffective by declining all cookies or modifying your browser setting to notify you each time a cookie is tendered and permit you to accept or decline cookies on an individual basis. Third parties are not permitted to use Web Beacons with the Services.