Orbirelo – Privacy Policy

Ariosi Group Limited takes your privacy seriously and We are committed to ensuring the privacy and safeguarding of your data. Our Privacy Policy describes how we collect and process your personal data in a format that is easy to understand. Please read the following information carefully to understand how we treat your data and what You can expect of Us as a data controller.

This Privacy Policy describes Ariosi Group Limited (company number 04588973) policies and procedures on the collection, use and disclosure of your information when You use the Service and tells You about your privacy rights and how the law protects You.

We use your Personal data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.

1. About us
   1. We are Ariosi Group Limited (company number 04588973), and our registered office is Building 7, Chiswick Park, 566 Chiswick High Road, London W4 5YG. We are registered as data controller with the Information Commissioner’s Office (ICO) with the registration number ZB296467.
   2. If You have any questions or comments about this privacy policy or any issue relating to how we collect, use, or disclose personal information, or if You would like to update the information We have about You, You may contact our Data Protection Officer:
   3. Ariosi Group Limited Attn: Data Protection Officer Email: support@orbirelo.com Address: Building 7, Chiswick Park, 566 Chiswick High Road, London W4 5YG.
2. Interpretation and Definitions
   1. Interpretation
      

      The words of which the initial letter is capitalised have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or plural.

   2. Definitions
      

      For the purposes of this Privacy Policy:

      ‘Personal data’

      is any information that relates to an identified or identifiable individual.

      ‘Processing’

      is any operation or set of operations which are performed on personal data or on sets of personal data, whether by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.

      ‘Restriction of processing’

      means the marking of stored personal data with the aim of limiting their processing in the future.

      ‘Profiling’

      means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular, to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.

      ‘Controller’

      means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.

      ‘Processor’

      means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

      ‘Consent’

      of the data subject means any freely given, specific, informed and unambiguous.

      ‘Account’

      means a unique account created for You to access our Service or parts of our Service.

      ‘Company’

      (referred to as either ‘the Company’, ‘We’, ‘Us’, or ‘Our’ in this privacy policy) refers to Ariosi Group Limited.

      ‘Cookies’

      are small files that are placed on your computer, mobile device or any other device by a website, containing the details of your browsing history on that website among its many uses.

      ‘Country’

      refers to the United Kingdom.

      ‘Device’

      means any device that can access the Service such as a computer, a cell phone or a digital tablet.

      ‘Service’

      refers to the Website accessible at orbirelo.com.

      ‘Service Provider’

      refers to any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analysing how the Service is used.

      ‘Usage Data’

      refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

      ‘Website’

      refers to the Website name, accessible from orbirelo.com.

      ‘You’

      refers to the natural or legal person accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

3. Principles Relating to Processing of Personal Data

   1. Ariosi Group Limited fully complies with Article 5 of the General Data Protection Regulation (GDPR) which requires that personal data shall be:

      • processed lawfully, fairly and in a transparent manner in relation to the data subject (‘lawfulness, fairness and transparency).
      • collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall, in accordance with Article 89(1), not be considered to be incompatible with the initial purposes (‘purpose limitation’).
      • adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed (‘data minimisation’).
      • accurate and, where necessary, kept up to date: every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay (‘accuracy’).
      • kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for a longer period insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific and historical research purposes or statistical purposes in accordance with Article 89 (1) subject to the implementation of the appropriate technical and organisational measures required by this Regulation in order to safeguard the rights and freedoms of the data subject (‘storage limitation’).
      • processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures (‘integrity and confidentiality’).
4. Collecting and Using your Personal Data
   1. Types of Data Collected
      

      We only ask for the information that is required to service your enquiry, reservation and our subsequent delivery of services that You explicitly agree to and contract from us.
      The two main types of data We collect from You are:

      Personal data

      Usage data

      Ariosi Group Limited does not store any customer payment information.

      1. Personal Data
         

         While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally Identifiable Information may include, but is not limited to:

         Email address

         Full name

         Preferred contact number

         Other guest names (18 years and above)

         Address

         
         
      2. Usage Data
         

         Usage Data is collected automatically when using the Service. It may include information such as your Device's Internet Protocol address (i.e., IP address), browser type, browser version, the pages of our Service that You visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

         When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, your mobile device’s unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.

         We may also collect information that your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.

      3. Use of Your Personal Data
         
         

         The Company may use personal data for the following purposes:

         To provide and maintain Our Service: including monitoring the usage of our Service.

         To manage your Account: to manage your registration as a user of the Service. The personal data You provide could give You access to different functionalities of the Service that are available to You as a registered user.

         For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items, or services You have purchased or of any other contract with Us through the Service.

         To contact You: by email, telephone calls, text messages, or other equivalent forms of electronic communication, such as informative communications related to the functionalities, products or contracted services.

         To provide You: with news, special offers and general information about other goods, services and events which We offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.

         To manage your requests: to attend to and manage your requests to Us.

         For business transfers: We may use your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred.

         For other purposes: We may use your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our products, services, marketing and your experience.

         
         
      4. Retention of Your Personal Data
         

         The Company will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with Our legal obligations (for example, if We are required to retain your data to comply with applicable laws), resolve disputes, and enforce Our legal agreements and policies.

         The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.

      5. Transfer of Your Personal Data
         1. Your information, including Personal Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those in your jurisdiction.
         2. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.
         3. The Company will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organisation or a country unless there are adequate controls in place including the security of your data and other personal information.
         4. We may share your personal information in the following situations:
            

            With Service Providers: We may share your personal information with Service Providers to monitor and analyse the use of our Service, and to contact You.

            For business transfers: We may share or transfer your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.

            With Affiliates: We may share your information with Our affiliates, in which case we will require those affiliates to honour this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.

            With your consent: We may disclose your personal information for any other purpose with your consent.

      6. Deletion of Your Personal Data
         

         You have the right to delete or request that We assist in deleting the Personal Data that We have collected about You.

         Our Service may give You the ability to delete certain information about You from within the Service.

         You may update, amend, or delete your information at any time by signing into your Account, if You have one, and visiting the account settings section that allows You to manage your personal information. You may also contact Us to request access to, correct, or delete any personal information that You have provided to Us.

         Please note, however, that We may need to retain certain information when We have a legal obligation or lawful basis to do so.

      7. Disclosure of Your Personal Data
         
         

         Business Transactions

         If the Company is involved in a merger, acquisition or asset sale, your Personal Data may be transferred. We will provide notice before your Personal Data is transferred and becomes subject to a different Privacy Policy.

         Law enforcement

         Under certain circumstances, the Company may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

         Other legal requirements

         The Company may disclose your Personal Data in the good faith belief that such action is necessary to:

         Comply with a legal obligation

         Protect and defend the rights or property of the Company

         Prevent or investigate possible wrongdoing in connection with the Service

         Protect the personal safety of users of the Service or the public

         Protect against legal liability

      8. What security and retention procedures does Ariosi Group Limited put in place to safeguard your personal data?
         

         We continuously review and update Our Website data security in accordance with legal requirements and web best practices. We take every reasonable measure to ensure your data is secure and only accessed by those requiring it to process your reservation.

         When you make a reservation and enter payment details, this information is encrypted. This helps to ensure your data is not transferred in a readable format and cannot be unlawfully accessed in transit.

5. Children's Privacy
   1. You must be over 18 years of age to book an apartment with Ariosi Group Limited. However, due to the nature of the services We provide, sometimes We may need to collect information from a child’s guardian about the child for the purposes of providing our service. Hence, if children are travelling with you, we will need to know their age, but we do not require their personal details and you will never be asked for their information at any stage in the reservation process. We may ask simple questions to help form your requirements, for example, if you require a cot or a highchair. We will not collect more information than necessary, and we will safeguard the information we collect from you about your child.
6. How does Ariosi Group make use of social media?
   1. We are active on various social media platforms and use these to communicate news, stories, blog posts and other relevant information in the industry and about our company. Sometimes We run competitions or ask for your replies and in these instances, We may need to make contact with you. For example, if You win a competition and We are contacting you about your prize. Your personal information will be treated according to this privacy policy and only used as necessary for Our legitimate interests in dealing with your correspondence or administering the competition You have entered.
7. Bases of processing personal information To process your information, We rely on the following legal bases:
   1. Legitimate interests: We use your information to service your requests and send You information relevant to your reservation. We may contact You to suggest alternative options when your selection is not available or to ask if You would like to extend your current reservation. We may also contact You if You are a relevant contact within Our industry to gauge your interest in our services.
   2. Performance of a contract: We need the personal information you supply to execute Our part of the contract between a service provider and client. If You ask Us to make a reservation, We will use your information to complete your reservation to satisfy Our part of the contract as a Service provider.
   3. Consent: We will ask for your consent to send You direct marketing content, such as Our monthly newsletter containing special offers, exclusive rates and promotions. We may also send other marketing materials, and these are detailed further below.
8. Links to Other Websites
   1. Our Service may contain links to other websites that are not operated by Us. If You click on a third-party link, You will be directed to that third-party’s site. We strongly advise You to review the Privacy Policy of every site You visit.
   2. We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.
9. How does Ariosi Group contact you?
   1. Our Service may contain links to other websites that are not operated by Us. If You click on a third-party link, You will be directed to that third-party’s site. We strongly advise You to review the Privacy Policy of every site You visit.
   2. We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

   3. Marketing

      With your consent, We will send You marketing materials that support Our business and are suited to your requirements. Your consent will be explicit, and You will know what types of marketing materials You are going to receive. You can manage the communication You receive from Us by selecting your preferences on Our website. You may receive the following types of marketing emails from us:
      
      

      1. Monthly newsletters. A newsletter detailing promotions, special offers, discounted rates, and other news relevant to your reservation.
      2. Company news. Keeps You up to date with Our company and industry news.
      3. Competitions. From time to time, We run competitions that give You the chance of winning prizes such as a free stay in a serviced apartment.

      You can withdraw your consent at any time by contacting Us at the email address listed at the end of this privacy policy. Consent can also be withdrawn by using the ‘Unsubscribe’ button that We include at the bottom of all Our marketing communications.

   4. Business to business

      If You are within Our key industries, then We may reach out to gauge your interest in Our services. If You receive communication from Us and do not wish to receive more, then simply hit the unsubscribe button at the bottom of the email.

   5. During the reservation process

      Ensuring you have the best possible stay is important to us so we may also contact you during your reservation to check that everything is as expected. We may also ask if you are interested in extending your reservation or if you have any future requirements that we can help with. If during the reservation process, the apartment you have chosen is not available, then we may contact you to discuss alternative options.

10. Your Data Rights

    Any individual whose personal data We hold and to whom the GDPR applies is entitled to eight data subject rights:
    
    

    1. The right to be informed.

       The right to information allows individuals (data subjects) to know what personal data is collected about them, why, who is collecting data, how long it will be kept, how they can file a complaint, and with whom will they share the data.

    2. The right of access.

       Individuals have a right to submit subject access requests and attain information from the organisation about whether their personal information is being processed.

    3. The right of rectification.

       The right to rectification allows the individuals to ask the organisation to update any inaccurate or incomplete data they have on them.

    4. The right to object to processing.

       The right to object allows individuals to object to the processing of personal data at any time, in certain situations and it will depend on the purpose of processing and the lawful base for processing.

    5. Rights in relation to automated decision-making and profiling.

       The data subjects have the right not to be subject to automated decision-making if it is producing a legal effect that significantly affects them. However, it will not apply if the processing is necessary for the performance of a contract, if it is authorized by the law, or if the processing is based on explicit consent.

    6. The right to be forgotten.

       The right to be forgotten is also known as the right to erasure. This right allows individuals to ask for their personal data to be deleted if:

       • the personal data is no longer necessary
       • an individual withdraws consent
       • the personal data have been unlawfully processed
       • Individual objects to the processing and the data controller has no reason to continue processing
       • Data erasure is necessary for compliance with a legal obligation
    7. The right to data portability.

       Data portability allows individuals to obtain their own personal data that they have previously provided to the organisation in a structured, commonly used and machine-readable format.

    8. The right to restrict processing.

       Individuals can request that an organisation limits the way it uses their personal data. Organisations may not be obliged to delete the data, but it may still have to refrain from processing it.

11. Changes to this Privacy Policy
    1. We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.
    2. We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the ‘Last updated’ date at the top of this Privacy Policy.
    3. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.
12. Contact Us
    1. If You have any questions about this Privacy Policy, You can contact us by email: support@orbirelo.com
13. Cookie Policy

    1. Tracking Technologies and Cookies

       Our website uses cookies for various web functions, and to help improve the user experience. A cookie is a small data file stored on your computer that comes from the web browser you are using. It can have a variety of uses and functionalities including storing information about your preferences, speeding up your searches and recognising you when you re-visit. Cookies are also used to track overall visits and visitor locations. This helps us to identify visitor numbers and patterns. Some cookies have a session-limited lifespan and are removed when you close your browser; whereas permanent cookies last a lot longer and sometimes indefinitely.

    2. Types of Cookie

       We use the following types of cookies:

       1. Strictly necessary cookies. These cookies are required for the operation of parts of our websites. They include, for example, cookies that enable you to log into secure areas of our websites or make use of reservation services. Strictly necessary cookies do not require consent as they provide functionality, as requested by the browser.

       2. Performance cookies. These cookies allow Us to recognise and count the number of visitors to our web pages and see how these visitors navigate around our site. This helps to improve the way our website works by optimising our page layouts, search tools and general usability.

       3. Functionality cookies. These cookies are used to recognise when a user returns to the Website in the future. This enables Us to personalise Our content for the user, greet them by their name and remember their preferences such as language settings and time zone.

       4. Targeting cookies. These cookies record users’ visits to Our websites, the pages visited by users and the links followed by them. These cookies also help us to see users’ points of entry and exit to Our Website.

       Some cookies may give Us a user’s browsing IP (Internet Protocol) address which is personally identifiable information. However, We do not use this to identify any individuals. Your IP address may be logged to help Us track where your browsing session is originating from and help Us gather wider statistics on Our visitor base.

       Controlling Cookies

       If you would like to read more information about cookies, or would like to find out about how to disable them, please visit https://www.aboutcookies.org/ if you would like to get more information about the specific cookies our Website uses, please contact support@orbirelo.com.