Native Privacy Policy

1. Introduction

In the following, we provide information about the collection of personal data when using

• our website https://nativeplaces.com and https://book.nativeplaces.com
• our profiles in social media.

Personal data is any data that can be related to a specific natural person, such as their name or IP address.

1.1 Contact details

The controller within the meaning of Art. 4 para. 7 UK General Data Protection
Regulation (GDPR) is Native Places Limited, Bayley Street 11-13, London, United Kingdom, email: enquiries@nativeplaces.com. We are legally represented by Rasmus Storup Steen, Stephan Thoennissen.

Our data protection officer can be reached via heyData GmbH, Schützenstraße 5, 10117 Berlin, www.heydata.eu , E-Mail: datenschutz@heydata.eu.

1.2 Scope of data processing, processing purposes and legal bases

We detail the scope of data processing, processing purposes and legal bases below. In
principle, the following come into consideration as the legal basis for data processing:

• Art. 6 para. 1 s. 1 lit. a UK GDPR serves as our legal basis for processing operations for which we obtain consent.
• Art. 6 para. 1 s. 1 lit. b UK GDPR is the legal basis insofar as the processing of personal data is necessary for the performance of a contract, e.g. if a site visitor purchases a product from us or we perform a service for him. This legal basis also  applies to processing that is necessary for pre-contractual measures, such as in the case of inquiries about our products or services.
• Art. 6 para. 1 s. 1 lit. c UK GDPR applies if we fulfill a legal obligation by processing personal data, as may be the case, for example, in tax law.
• Art. 6 para. 1 s. 1 lit. f UK GDPR serves as the legal basis when we can rely on legitimate interests to process personal data, e.g. for cookies that are necessary for the technical operation of our website.

1.3 Data processing outside the EEA

Insofar as we transfer data to service providers or other third parties outside the EEA, the security of the data during the transfer is guaranteed by adequacy decisions of the EU Commission, insofar as they exist (e.g. for Great Britain, Canada and Israel) (Art. 45 para. 3 UK GDPR).

In the case of data transfer to service providers in the USA, the legal basis for the data transfer is an adequacy decision of the EU Commission if the service provider has also certified itself under the EU US Data Privacy Framework.

In other cases (e.g. if no adequacy decision exists), the legal basis for the data transfer are usually, i.e. unless we indicate otherwise, standard contractual clauses. These are a set of rules adopted by the EU Commission and are part of the contract with the  respective third party. According to Art. 46 para. 2 lit. b UK GDPR, they ensure the security of the data transfer. Many of the providers have given contractual guarantees that go beyond the standard contractual clauses to protect the data. These include, for example, guarantees regarding the encryption of data or regarding an obligation on the part of the third party to notify data subjects if law enforcement agencies wish to access
the respective data.

1.4 Storage duration

Unless expressly stated in this privacy policy, the data stored by us will be deleted as soon as they are no longer required for their intended purpose and no legal obligations to retain data conflict with the deletion. If the data are not deleted because they are required for other and legally permissible purposes, their processing is restricted, i.e. the  data are blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons.

1.5 Rights of data subjects

Data subjects have the following rights against us with regard to their personal data:

• Right of access,
• Right to correction or deletion,
• Right to limit processing,
• Right to object to the processing ,
• Right to data transferability,
• Right to revoke a given consent at any time .

Data subjects also have the right to complain to a data protection supervisory authority about the processing of their personal data. Contact details of the data protection supervisory authority is available at https://ico.org.uk/.

1.6 Obligation to provide data

Within the scope of the business or other relationship, customers, prospective
customers or third parties need to provide us with personal data that is necessary for the establishment, execution and termination of a business or other relationship or that we are legally obliged to collect. Without this data, we will generally have to refuse to conclude the contract or to provide a service or will no longer be able to perform an existing contract or other relationship.

Mandatory data are marked as such.

1.7 No automatic decision making in individual cases

As a matter of principle, we do not use a fully automated decision-making process in accordance with article 22 UK GDPR to establish and implement the business or other relationship. Should we use these procedures in individual cases, we will inform of this separately if this is required by law.

1.8 Making contact

When contacting us, e.g. by e-mail or telephone, the data provided to us (e.g. names and e-mail addresses) will be stored by us in order to answer questions. The legal basis for the processing is our legitimate interest (Art. 6 para. 1 s. 1 lit. f UK GDPR) to answer inquiries directed to us. We delete the data accruing in this context after the storage is no longer necessary or restrict the processing if there are legal retention obligations.

1.9 Customer surveys

From time to time, we conduct customer surveys to get to know our customers and their wishes better. In doing so, we collect the data requested in each case. It is our legitimate interest to get to know our customers and their wishes better, so that the legal basis for the associated data processing is Art. 6 para. 1 s. 1 lit f UK GDPR. We delete the data when the results of the surveys have been evaluated.

2. Newsletter

We reserve the right to inform customers who have already used services from us or purchased goods from time to time by e-mail or other means about our offers, if they have not objected to this. The legal basis for this data processing is Art. 6 para. 1 s. 1 lit. f UK GDPR. Our legitimate interest is to conduct direct advertising (recital 47 UK GDPR). Customers can object to the use of their e-mail address for advertising purposes at any time without incurring additional costs, for example via the link at the end of each e-mail or by sending an e-mail to our above-mentioned e-mail address.

Interested parties have the option to subscribe to a free newsletter. We process the data provided during registration exclusively for sending the newsletter. Subscription takes place by selecting the corresponding field on our website, by ticking the corresponding field in a paper document or by another clear action, whereby interested parties declare their consent to the processing of their data, so that the legal basis is Art. 6 para. p. 1 lit. a UK GDPR. Consent can be revoked at any time, e.g. by clicking the corresponding link in the newsletter or notifying our e-mail address given above. The processing of the data until revocation remains lawful even in the event of revocation.

Based on the consent of the recipients (Art. 6 para. 1 s. 1 lit. a UK GDPR), we also measure the opening and click-through rate of our newsletters to understand what is relevant for our audience.

• We send newsletters with the tool Klaviyo of the provider Klaviyo, Inc., 125 Summer St, Floor 6 Boston, MA 02111, USA . The provider processes content, usage, meta/communication data and contact data in the process in the USA. Further information is available in the provider’s privacy policy at https://www.klaviyo.com/privacy/policy .

3. Data processing on our website

3.1 Informative use of our website

During the informative use of the applications, i.e. when visitors do not separately
transmit information to us, we collect the personal data that the browser transmits to our server in order to ensure the stability and security of our applications. This is our legitimate interest, so that the legal basis is Art. 6 para. 1 s. 1 lit. f UK GDPR.

These data are:

• IP address
• Date and time of the request
• Time zone difference to Greenwich Mean Time (GMT)
• Content of the request (specific page)
• Access status/HTTP status code
• Amount of data transferred in each case
• Website from which the request comes
• Browser
• Operating system and its interface
• Language and version of the browser software.

This data is also stored in log files. They are deleted when their storage is no longer necessary, at the latest after 14 days.

3.2 Web hosting and provision of the website

Our website is hosted by Vercel. The provider is Vercel Inc., 340 S Lemon Ave Unit 4133 Walnut, CA, USA. In doing so, the provider processes the personal data transmitted via the website, e.g. content, usage, meta/communication data or contact data, in the EU. Further information can be found in the provider’s privacy policy at https://vercel.com/legal/privacy-policy.

It is our legitimate interest to provide a website, so the legal basis of the described data processing is Art. 6 para. 1 s. 1 lit. f UK GDPR.

Our website is hosted by Kinsta. The provider is Kinsta Inc., 8605 Santa Monica Blvd #92581, West Hollywood, CA 90069, USA. In doing so, the provider processes the personal data transmitted via the website, e.g. content, usage, meta/communication data or contact data in the USA. Further information can be found in the provider’s privacy policy at https://kinsta.com/de/legal/datenschutzpolitik/.

It is our legitimate interest to provide a website, so the legal basis of the described data processing is Art. 6 para. 1 s. 1 lit. f UK GDPR.

The legal basis of the transfer to a country outside the EEA are adequacy decision. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed because the EU Commission has decided as part of an adequacy decision in accordance with Art. 45 para. 3 UK GDPR that the third country ensures an adequate level of protection.

We use the content delivery network Cloudfront (Amazon AWS) for our website. The provider is Amazon Web Services, Inc., P.O. Box 81226 Seattle, WA 98108-1226 USA . The provider thereby processes the personal data transmitted via the website, e.g. content, usage, meta/communication data or contact data in the USA. Further information can be found in the provider’s privacy policy at
https://d1.awsstatic.com/legal/privacypolicy/AWS_Privacy_Notice__German_Translation.pdf.
We have a legitimate interest in using sufficient storage and delivery capacity to ensure optimal data throughput even during large peak loads. Therefore, the legal basis of the described data processing is Art. 6 para. 1 s. 1 lit. f UK GDPR.

Legal basis of the transfer to a country outside the EEA are adequacy decision. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed because the EU Commission has decided as part of an adequacy decision in accordance with Art. 45 para. 3 UK GDPR that the third country ensures an adequate level of protection.

We use the content delivery network Kinsta for our website. The provider is Kinsta Inc., 8605 Santa Monica Blvd #92581, West Hollywood, CA 90069, USA . The provider thereby processes the personal data transmitted via the website, e.g. content, usage, meta/communication data or contact data in the USA. Further information can be found in the provider’s privacy policy at https://kinsta.com/de/legal/datenschutzpolitik/ .

We have a legitimate interest in using sufficient storage and delivery capacity to ensure optimal data throughput even during large peak loads. Therefore, the legal basis of the described data processing is Art. 6 para. 1 s. 1 lit. f UK GDPR.

Legal basis of the transfer to a country outside the EEA are standard contractual clauses. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed by standard data protection clauses (Art. 46 para. 2 lit. c GDPR) adopted by the EU Commission in accordance with the examination procedure under Art. 93 para. 2 of the UK GDPR, which we have agreed to with the provider.

3.3 Contact form

When contacting us via the contact form on our website, we store the data requested there and the content of the message. The legal basis for the processing is our legitimate interest in answering inquiries directed to us. The legal basis for the processing is therefore Art. 6 para. 1 s. 1 lit. f UK GDPR. We delete the data accruing in this context after the storage is no longer necessary or restrict the processing if there are legal retention obligations.

3.4 Bookings via our website

Users can make bookings via our website. In doing so, we process the following personal data as part of the booking process:

• IP-address
• Name
• E-mail address
• Phone number (optional)
• Address
• Company name (if applicable)
• Date of arrival and expected departure
• Number of accompanying persons

The data is processed to fulfill the contract concluded with the respective guest (Art. 6 para. 1 p. 1 lit. b UK GDPR).

3.4.1 Online Check-In Process

We offer a facilitated check-in process online. For this purpose, we offer guests two options:

• Option 1: The check-in is carried out by verifying the ID document and reading the information from the document on the basis of a data protection consent given before the start of the check-in (Art. 6 para. 1 sentence 1 lit. a) UK GDPR). For this purpose, we use the service provider Incode (Incode Technologies, Inc., 221 Main Street, Suite 520, San Francisco, CA 94105, USA). The provider processes First and last name, E-Mail address, information about the guest’s stay, all information included in the ID document and a copy of the ID document. The processing takes place exclusively in the European Union. The purpose of the processing is, on the one hand, to offer guests a quick and convenient way to carry out self-check-in, namely to complete it directly via the Numa applications. On the other hand, the purpose of the processing is also to prevent crime, protect property and ensure the accountability of guests.
• Option 2: Alternatively, guests can choose to check in via video call (similar to a
  physical reception desk in a hotel). The purpose of the processing is the operation
  of a digital operation of our business. In this case, the following personal data is
  processed: First and last name, E-Mail address, and information about the guest’s
  stay. The legal basis for this processing is therefore Art. 6 para. 1 s. 1 lit. f. We have a legitimate interest to maintain a digital operation of our accommodation.

For guests who are not UK citizens, we process identification documents to comply with our legal obligations under the Immigration (Hotel Records) Order 1972. Accordingly, the lawful basis for this processing is Article 6(1)(c) of the UK GDPR. We are required to retain specific details, including full name, nationality, and passport number, for a period of 12 months.

The copy of the ID document is kept for 7 days after the upload by the guest for the purposes of ensuring the correctness of the information collected, and subsequently deleted.

3.5 Payment processors

For the processing of payments, we use payment processors who are themselves data controllers within the meaning of Art. 4 No. 7 UK GDPR. Insofar as they receive data and payment data entered by us in the ordering process, we thereby fulfill the contract concluded with our customers (Art. 6 para. 1 s. 1 lit. b UK GDPR).

These payment processors are:

• Stripe Payments Europe, Ltd., Ireland

3.6 Third parties

3.6.1 Google Analytics

We use Google Analytics for analytics. The provider is Google LLC, 1600 Amphitheatre Parkway Mountain View, CA 94043, USA. The provider processes usage data (e.g. web pages visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses) in the USA in the USA.

The legal basis for the processing is Art. 6 para. 1 s. 1 lit. a UK GDPR . The processing is based on consent. Data subjects may revoke their consent at any time by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation.

The transfer of personal data to a country outside the EEA takes place on the legal basis adequacy decision. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed because the EU Commission has decided as part of an adequacy decision in accordance with Art. 45 para. 3 UK GDPR that the third country ensures an adequate level of protection.

The data will be deleted when the purpose for which it was collected no longer applies and there is no obligation to retain it. Further information is available in the provider’s privacy policy at https://business.safety.google/privacy/.

3.6.2 Google Tag Manager

We use Google Tag Manager for advertising, for analytics. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. The provider processes usage data (e.g. web pages visited, interest in content, access times) in the USA in the USA.

The legal basis for the processing is Art. 6 para. 1 s. 1 lit. a UK GDPR . The processing is based on consent. Data subjects may revoke their consent at any time by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation.

The transfer of personal data to a country outside the EEA takes place on the legal basis adequacy decision. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed because the EU Commission has decided as part of an adequacy decision in accordance with Art. 45 para. 3 UK GDPR that the third country ensures an adequate level of protection.

We delete the data when the purpose for which it was collected no longer applies.
Further information is available in the provider’s privacy policy at
https://business.safety.google/privacy/.

3.6.3 Klaviyo (webforms)

We use Klaviyo (webforms) for quizzes and forms, for email marketing. The provider is Klaviyo, Inc., 125 Summer St, Floor 6 Boston, MA 02111, USA. The provider processes meta/communication data (e.g. device information, IP addresses), contact data (e.g. e-mail addresses, telephone numbers) in the USA in the USA.

The legal basis for the processing is Art. 6 para. 1 s. 1 lit. a UK GDPR . The processing is based on consent. Data subjects may revoke their consent at any time by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation.

The transfer of personal data to a country outside the EEA takes place on the legal basis standard contractual clauses. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed by standard data protection clauses (Art. 46 para. 2 lit. c UK GDPR) adopted by the EU Commission in accordance with the examination procedure under Art. 93 para. 2 of the UK GDPR, which we have agreed to with the provider.

The data will be deleted when the purpose for which it was collected no longer applies and there is no obligation to retain it. Further information is available in the provider’s privacy policy at https://www.klaviyo.com/privacy/policy.

3.6.4 CookieYes

We use CookieYes to manage consents. The provider is CookieYes Limited, 3 Warren Yard Warren Park, Wolverton Mill, Milton Keynes, MK12 5NW, United Kingdom. The provider processes meta/communication data (e.g. device information, IP addresses) in Great Britain in Great Britain.

The legal basis for the processing is Art. 6 para. 1 s. 1 lit. f UK GDPR . We have a legitimate interest in managing the consent of website visitors to cookies in a simple manner.

The transfer of personal data to a country outside the EEA takes place on the legal basis adequacy decision. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed because the EU Commission has decided as part of an adequacy decision in accordance with Art. 45 para. 3 UK GDPR that the third country ensures an adequate level of protection.

The data will be deleted when the purpose for which it was collected no longer applies and there is no obligation to retain it. Further information is available in the provider’s privacy policy at https://www.cookieyes.com/privacy-policy/.

3.6.5 heyData

We have integrated a data protection seal on our website. The provider is heyData
GmbH, Schützenstraße 5, 10117 Berlin, Germany. The provider processes
meta/communication data (e.g. IP addresses) in the EU.

The legal basis of the processing is Art. 6 para. 1 s. 1 lit. f UK GDPR. We have a legitimate interest in providing website visitors with confirmation of our data privacy compliance. At the same time, the provider has a legitimate interest in ensuring that only customers with existing contracts use its seals, which is why a mere image copy of the certificate is not a viable alternative as confirmation.

As the data is masked after collection, there is no possibility to identify website visitors. Further information is available in the privacy policy of the provider at
https://heydata.eu/en/privacy-policy .

4. Data processing on social media platforms

We are represented in social media networks in order to present our organization and our services there. The operators of these networks regularly process their users’ data for advertising purposes. Among other things, they create user profiles from their online behavior, which are used, for example, to show advertising on the pages of the networks and elsewhere on the Internet that corresponds to the interests of the users. To this end, the operators of the networks store information on user behavior in cookies on the users’ computers. Furthermore, it cannot be ruled out that the operators merge this information with other data. Users can obtain further information and instructions on how to object to processing by the site operators in the data protection declarations of the respective operators listed below. It is also possible that the operators or their servers are located in non-EU countries, so that they process data there. This may result in risks for users, e.g. because it is more difficult to enforce their rights or because government
agencies access the data.

If users of the networks contact us via our profiles, we process the data provided to us in order to respond to the inquiries. This is our legitimate interest, so that the legal basis is Art. 6 para. 1 s. 1 lit. f UK GDPR.

4.1 Facebook

We maintain a profile on Facebook. The operator is Meta Platforms Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. The privacy policy is available here: https://www.facebook.com/policy.php. A possibility to object to data processing arises via settings for advertisements: https://www.facebook.com/settings?tab=ads.We are joint controllers for processing the data of visitors to our profile on the basis of an agreement within the meaning of Art. 26 UK GDPR with Facebook. Facebook explains exactly what data is processed at  https://www.facebook.com/legal/terms/information_about_page_insights_data. Data subjects can exercise their rights both against us and against Facebook. However, according to our agreement with Facebook, we are obliged to forward requests to Facebook. Data subjects will therefore receive a faster response if they contact Facebook directly.

4.2 Instagram

We maintain a profile on Instagram. The operator is Meta Platforms Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. The privacy policy is available here: https://help.instagram.com/519522125107875.

4.3 LinkedIn

We maintain a profile on LinkedIn. The operator is LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland. The privacy policy is available here:
https://www.linkedin.com/legal/privacy-policy?_l=de_DE. One way to object to data processing is via the settings for advertisements:
https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.

5. Changes to this privacy policy

We reserve the right to change this privacy policy with effect for the future. A current  version is always available here.

6. Questions and comments

If you have any questions or comments regarding this privacy policy, please feel free to contact us using the contact information provided above.