In the context of the booking process – whether this takes place online on one of our brand websites, through an online booking channel, via a travel agent, through our call center, or directly at the apartment – we process your Personal Data for the purpose of (i) enabling you to reserve the apartment of your choice; (ii) verifying the availability to administer the booking; (iii) sending you a booking confirmation; and (iv) sending you pre-arrival emails. You may unsubscribe from pre-arrival emails at any time by clicking on the unsubscribe link in the emails sent to you.

Processed data categories:

Address, Booking details (including reservation number), Date of arrival and departure, Email address, First name / Last name, First name / Last name of adult co-guest(s), Payment card type, number and expiration date, Telephone number, Title

Source of data:

Depending on the booking mechanism used:

- Directly from you through the online booking form

- Through the online booking channel you used to make the booking

- From your travel agent

- From the call

Ground for processing:

Processing is necessary to take steps to enter into and perform a contract.

Interrupted or incomplete online booking process (abandoned cart):

When you are booking online but for some reason are not able to finalize the booking process, we process your Personal Data for the purpose of enabling you to easily continue the online booking process by sending you an email with a link to the online booking form, which is pre-filled on the basis of the data you had already provided in the form.

Processed data categories:

Address, Date of arrival and departure, Email address, First name / Last name, First name / Last name of adult co-guest(s), Payment card type, number and expiration date, Telephone number, Title

Source of data:

Directly from you through the online booking form

Ground for processing:

It is in E&E Apartment's legitimate interest as a business to re-market an interrupted or incomplete booking process. In this context, E&E Apartment business interests prevail over yours.

Guest satisfaction surveys:

We may send you guest satisfaction surveys by email during or after your stay to enable us to measure the performance of our apartments. You may unsubscribe from our guest satisfaction survey emails at any time by clicking on the unsubscribe link in the emails sent to you.

Processed data categories:

Country of residence, Date of arrival and departure, Email address, First name / Last name, Nationality, Stay details.

Source of data:

Depending on the booking mechanism used:

- Directly from you through the online booking form

- Through the online booking channel you used to make the booking

- From your travel agent

- From the call

Ground for processing:

Processing is necessary to ensure and follow up on the good performance of the contract you have with us.

Service emails Analytics:

In the context of service emails, which includes guest satisfaction survey emails and any pre-arrival emails concerning your booking, we may process and collect your Personal Data, and notably, whether you have opened and actioned a service email, for analytical purposes in order to measure the click-through rate and improve the content of our service emails. You may unsubscribe from our service emails at any time by clicking on the unsubscribe link in the service emails sent to you.

The information below describes the types of data we process for this purpose, where we get your data from, the ground we rely on to carry out the processing, and who we may share your data with.

Processed data categories:

Email address, Email clicking behavior, Email opening behavior, First name / Last name.

Source of data:

From our email analytics service provider.

Ground for processing:

It is in E&E Apartment's legitimate interest as a business to understand the email clicking behavior of its guests in order to determine whether improvements are needed. In this context, E&E Apartment business interests prevail over yours.

When staying at the apartment of your choice, we will collect and process your Personal Data for the purposes of (i) registering your arrival and departure at the apartment; (ii) assigning you a key to your apartment. (iii) obtaining a credit card guarantee or apartment deposit to ensure payment of your stay; (iv) managing (and archiving) your apartment registration card; (v) creating or updating your profile in our apartment management system; (vi) assessing your eligibility for an apartment upgrade and managing this if applicable; (vii) managing payment of your stay; (viii) establishing, printing or sending an invoice for your stay; and (ix) paying a commission to your travel agent (if applicable).

In the event you have booked the apartment but do not show up – without canceling – on the date of arrival communicated, we will process your Personal Data for the purposes of (i) canceling your stay and any other reservation you may have made; and (ii) managing, processing and settling any outstanding payment that may be due.

Processed data categories:

Address, Bookings (restaurant, event, theater, etc.), Date of arrival and departure, Email address, First name / Last name, First name / Last name of adult co-guest(s), Payment card type, number and expiration date, Telephone number, Title

Source of data:

Depending on the booking mechanism used:

- Directly from you through the booking form

- Through the online booking channel you used to make the booking

- From your travel agent

- From direct call

- From the apartment, you made a direct booking with

- Directly from you through the apartment registration card

Ground for processing:

Processing is necessary to perform the contract you have with us.

Credit limit reports:

To ensure payment for all guests staying in the apartment, each apartment guest is asked for a credit card or deposit upon arrival. In order to ensure that you do not exceed your credit limit during your stay, we produce a credit limit report multiple times a day for the purposes of verifying whether your credit limit has been exceeded. These credit limit reports may contain your Personal Data. Please note that in limited circumstances these credit limit reports may be subject to one of our internal financial audits, and may therefore be accessed by members of our internal audit department, in order to ensure that our apartment follows the apartment's internal guidelines and policies.

Processed data categories:

Date of arrival and departure, First name / Last name, Payment card type, number, and expiration date

Source of data:

Depending on the booking mechanism used:

- Directly from you through the booking form

- Through the online booking channel you used to make the booking

- From your travel agent

- From direct call

- From the apartment, you made a direct booking with

- Directly from you through the apartment registration card

Ground for processing:

Processing is necessary to ensure the performance of the contract you have with us.

Apartment stay:

When you stay in one of our apartments, we endeavor to make your stay as pleasant as possible. This requires processing your Personal Data for the purposes of providing specific services during your apartment stay. These services include (i) housekeeping and maintenance; (ii) returning lost or forgotten items to you; and/or (iii) managing your and your co-guests preferences, such as dietary requirements and pillow preferences, in order to provide you with a better service during your stay with us.

Processed data categories:

Address, Consumption habits, Date of arrival and departure, Dietary requirements, Email address, First name / Last name, First name / Last name of adult co-guest(s), Other preferences, Payment details (for the purpose of returning lost or forgotten items), Telephone number

Source of data:

Depending on the booking mechanism used:

- Directly from you through the booking form

- Through the online booking channel you used to make the booking

- From your travel agent

- From direct call

- From the apartment, you made a direct booking with

- Directly from you during your stay at the apartment.

Ground for processing:

It is in E&E Apartment's legitimate interest as a business to organize its day-to-day apartment maintenance activities, to personalize the services it provides, and/or to be able to identify the owner of a lost or forgotten item. Taking into account the limited Personal Data processed and shared for such purpose(s), E&E Apartment business interests prevail over yours.

Apartment additional services:

In many of our apartments, you can benefit from additional services and facilities, such as breakfast, room service, minibar, laundry services, parking, taxi requests, free Wi-Fi, etc. In the event you make use of additional services or facilities at one of our apartments, your Personal Data may be processed to (i) manage the booking and use of such additional apartment services and/or facilities; (ii) administer any advance bookings of additional services and/or facilities to your file; (iii) personalize returning guests’ arrival to the apartment and the choice of room amenities and room features; and (iv) manage the expenses incurred for such additional services and/or facilities.

Processed data categories:

Consumption habits, Date of arrival and departure, Dietary requirements, Email address, First name / Last name, First name / Last name of adult co-guest(s), Payment card type, number and expiration date, Title

Source of data:

- Directly from you through the online booking form

- Through the online booking channel you used to make the booking

- From your travel agent

- From direct call

- Directly from you through the apartment registration card

- Directly from you when making your additional service/facility request with the apartment personnel.

- Through the online booking platform for additional services and facilities

Ground for processing:

Processing is necessary to take steps with a view to entering into a contract and/or to performing the contract.

We may process your Personal Data obtained through social media platforms (including Facebook, Instagram, LinkedIn, Weibo and Twitter) or online reviews (including on TripAdvisor) concerning our E&E Apartment brands for the purposes of (i) addressing your questions or complaints; (ii) monitoring our online reputation; and (iii) improving our services and identifying opportunities on which we can focus.

Some of our social media pages allow users to submit their own content. Please remember that any content submitted to one of our social media pages can be viewed by the public, and you should be cautious about providing certain personal information (e.g., financial information or address details) via these platforms. We are not responsible for any actions taken by other individuals if you post personal information on one of our social media platforms (e.g., Facebook or Instagram). Please also refer to the respective privacy and cookie policies of the social media platforms you are using.

Processed data categories:

- Any Personal Data you may decide to share with us or published on social media or in other online reviews about us

Source of Data:

- Directly from you through publicly accessible social media pages, online booking channels or other (review) websites

- From our online reputation monitoring service provider

Ground for processing:

- It is in E&E Apartment legitimate interest as a business to process the Personal Data you have chosen to address to us or make publicly available on social media platforms, online booking channels or other (review) websites in order to improve our services and identify business opportunities. In this context, E&E Apartment business interests prevail over yours..

Social media contests:

From time to time, we may organize a contest on one of our social media pages. If you choose to participate in such contest, we will process your Personal Data for the purpose of organizing and managing the social media contest and picking the winner(s).

Processed data categories:

- This depends on the data fields in the contest concerned, but almost always includes the following categories of data:

Address, Email address, First name / Last name, Telephone number

Source of Data:

- Directly from you through our social media pages

Ground for processing:

- Processing is necessary to take steps to enter into and perform a contract as you accept the terms and conditions of the contest.

If you are in the EU, EU Privacy Law grants specific rights, summarized below, which you can in principle exercise free of charge, subject to statutory exceptions. These rights may be limited, for example if fulfilling your request would reveal Personal Data about another person, or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping. To exercise any of your rights, you can file a request via email at eeapartments@siol.net

Should you have unresolved concerns, you have the right to lodge a complaint with a Supervisory Authority where you live or where you believe a breach may have occurred. We encourage you to come to us in the first instance but, to the extent that this right applies to you, you are entitled to complain directly to the relevant Supervisory Authority.

Right to withdraw consent:

Wherever we rely on your consent, you will be able to withdraw that consent at any time you choose and at your own initiative by logging in to your account on our website (if you have one) or by contacting us at eeapartments@siol.net . The withdrawal of your consent will not affect the lawfulness of the collection and processing of your data based on your consent up until the moment where you withdraw your consent. Please note that we may have other legal grounds for processing your data for other purposes, such as those set out in this Privacy Policy.

Right to access and rectify your data:

You have the right to access, review, and rectify your Personal Data. You may be entitled to ask us for a copy of your information, to review or correct it if you wish to rectify any information like your name, email address, passwords and/or any other preferences, you can easily do so by logging in to your account on our website (if you have one) or by contacting us at eeapartments@siol.net . You may also request a copy of the Personal Data processed as described in this Privacy Policy.

Right to erasure:
In accordance with EU Privacy Law, you have the right to erasure of your Personal Data processed by us as described in this Privacy Policy in case it is no longer needed for the purposes for which the Personal Data was initially collected or processed or in the event you have withdrawn your consent or objected to processing as described in this Privacy Policy and no other legal ground for processing applies. Should you wish to have your Personal Data erased, please file a request via email at eeapartments@siol.net

Right to restriction of processing:

Under certain circumstances described in EU Privacy Law, you may ask us to restrict the processing of your Personal Data. This is for example the case when you contest the accuracy of your Personal Data. In such event, we will restrict the processing until we can verify the accuracy of your data.

Right to object to processing:

Under certain circumstances described in EU Privacy Law, you may object to the processing of your Personal Data, including where your Personal Data is processed for direct marketing purposes.

Right to data portability:

Where you have provided your data directly to us and where the processing is carried out by automated means and based on your consent or the performance of a contract between you and us, you have the right to receive the Personal Data processed about you in a structured, commonly used and machine-readable format, and to transmit this data to another service provider.

Appropriate technical and organizational measures are implemented in order to ensure an appropriate level of security of your Personal Data, including but not limited to encryption techniques, physical and IT system access controls, obligations of confidentiality, etc.

In the event Personal Data is compromised as a result of a Personal Data Breach we will make the necessary notifications, as required under applicable laws.

We do not knowingly collect or solicit Personal Data from anyone under the age of 18 or knowingly allow such persons to book the apartment. In the event we learn that we have collected Personal Data from a child under the age of 18 without verification of parental consent, steps will be taken promptly to remove that information. If you believe that we have or may have information from or about a child under 18 years of age, please contact us at eeapartments@siol.net

We only share or disclose information as described herein, including with Third Parties.

Your Personal Data will also be shared with government authorities and/or law enforcement officials if required for the purposes above, if mandated by law or if required for the legal protection of the Controller(s) legitimate interests in compliance with applicable laws. In addition, we may share your Personal Data and other information with a successor to all or part of our business, where this is in our legitimate interests in facilitating a business sale and in this context our business interests prevail over yours. For example, if parts of our business or assets are sold, we may disclose user information as part of that transaction, subject to applicable law.

We retain your Personal Data for as long as is required to fulfil the activities set out in this Privacy Policy, for as long as otherwise communicated to you or for as long as is permitted by applicable law. For example, we may retain your Personal Data if it is reasonably necessary to comply with any legal obligations, meet any regulatory requirements, resolve any disputes or litigation, or as otherwise needed to enforce this Privacy Policy and prevent fraud and abuse.

To determine the appropriate retention period for the information we collect from you, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of the data, the purposes for which we process the Personal Data, and whether we can achieve those purposes through other means, and the applicable legal requirements.

If you click on a link to a Third Party website, you will be taken to a website we do not control and our Privacy Policy will no longer be in effect. Your browsing and interaction on any other website is subject to the terms of use and privacy and other policies of such Third Party website. Read the privacy policies of other websites carefully. We are not responsible or liable for the information or content on such Third Party websites.

We reserve the right to modify and update this Privacy Policy from time to time. We will bring these changes to your attention should they be indicative of a fundamental change to the processing or be relevant to the nature of the processing or be relevant to you and impact your data protection rights.

Questions, comments, remarks, requests or complaints regarding this Privacy Policy are welcome and should be addressed to eeapartments@siol.net