STELLAR PRIVACY POLICY

Stellar Corporate Housing 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.

I. About us.

We are Stellar Corporate Housing Limited (company registration number: 687028) and our registered office is C/O Colleran Chartered Accountants, Olympic House, Pleasants Street, Dublin 8, D08 H67X, Ireland. Stellar Corporate Housing Limited sources serviced apartments based on your specific requirements and to do this we need certain informa@on from you.

II. What information do we collect from you?

We only ask for the information that is required to service your enquiry and reservation. We collect your name, telephone number and email address (if you do not provide this information, we may not be able to provide our services). We may also need to collect the names of other guests, providing they’re over 18 years of age. We also collect details about your accommodation requirements such as budget, length of stay and accommodation type. If your employer uses our services to book accommodation for you, we may collect this information from them, rather than directly from you. If you visit our offices, we may collect video, audio and sell images via security cameras located in public areas such as entrances and hallways. When you visit our website, we collect some cookie information regarding your use of the website, and this is used to help us improve the service we deliver. Cookie information can include your IP address, the browser you’re using and your language settings. Stellar Corporate Housing Limited does not store any of your payment information. Payment details are supplied directly to payment platform via a secure payment link which we provide you. This is a simple overview of the information we collect from you. If you’d like to know more, further information is available below.

III. Why do we collect your personal data and what do we do with it?

We primarily collect your personal details to service your accommodation request, and this can involve the following communications:

• Providing you with accommodation options via email

• Communicating with you about your requirements via phone and email

• Completing and administering your reservation via email

None of your personal information is shared unless you request that we reserve your chosen accommodation. If you would like to proceed with a reservation, then we will pass on the relevant personal information to the property provider. This will allow them to allocate an apartment to you and, if applicable, any other travellers in your group. We keep a copy of your correspondence and details of your reservation to enable us to manage the reservation process. This data is further kept for up to 6 years after your last booking for the purpose of auditing and to comply with regulatory bodies such as the Office of the Revenue Commissioners. Furthermore, if you have opted-in when making your enquiry, we will send you marketing materials such as our monthly newsletter that details promotions, special offers and discounted rates. Depending on your preferences, we may send you further correspondence from time to time. The CCTV images collected at our offices are used for business security, health and safety and fraud monitoring. We collect this data to comply with our insurance obligations and to keep our premises and data safe. CCTV data is stored for 10 days unless required for criminal or insurance investigations in which case it’s held for as long as necessary to fulfil that investigation.

IV. Information that we share.

We only share your information for the sole purpose of servicing your reservation. Once you have decided you would like to proceed with a reservation, we will then share your details with the property partner. We require our property partners to sign our terms and conditions which include strict data privacy requirements. Please note that, where the booking relates to a property which is outside of the EU, your information may be transferred to a country which does not have the same data protection standards in place if it is required in relation to the booking (although we require any property partners outside of the EU to comply with model data protection clauses which have been approved by the EU).

The property will receive the following personal information:

• Full Name

• Email Address

• Preferred Contact Number

• Other Guest Names (18 years and above)

• No. of Guests

We do not share your personal information with any other people or third parties. We may only have to disclose your information if we sell the business, introduce, or acquire another business, need to establish, make, or defend a legal claim, or if we are under a duty to disclose personal information to comply with legal obligations. We may also use third party service providers (such as IT and technology services) who will store or use your information, but only on our instructions and subject to strict data protection requirements.

V. Children’s personal data.

You must be over 18 years of age to reserve an apartment with Stellar Corporate Housing Limited. 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.

VI. Social media channels.

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 contact 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.

VII. Bases for processing personal information.

To process your information, we rely on the following legal bases:

• Performance of a contract: We need the personal information you supply to execute our part of the contract between us “the service provider” and you “the client”. If you ask us to make a reservation, we will use your information to complete and administer your reservation to satisfy our part of the contract as a service provider.

• 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 chosen apartment is not available or to ask if you would like to extend your current reservation. If you are a guest, or your employer is making the booking, we use your information as necessary for our legitimate interests in carrying out our contract with the client who made the booking.

• Consent: We will ask for your consent to send you direct marketing content containing relevant information, special offers, exclusive rates, and promotions. We may also send other marketing materials, and these are detailed further below.

VIII. How can you control your data?

You have the right to access and to review the personal information we hold for you. You can request an overview of this data by email at info@stellarcorporatehousing.com. When emailing, please provide ‘Personal information request’ in the subject line so we can expedite the process.

IX. Security of information.

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 encrypted. This helps ensure your data is not transferred in a readable format and can’t be unlawfully accessed in transit.

X. Your data rights.

As a user of our service, you have rights as an individual which you can exercise in relation to the information, we hold about you.

You have a right to be informed in a clear, transparent, and easily understandable way about how we use your personal information and about your rights. Therefore, we are providing you with the information in this policy. If you require any further information about how we use your personal information, please let us know.

You can request access to your personal information by making a ‘Personal information request’. We can tell you what information we hold about you, why we are holding it and who it may be shared with. If it has been shared, this will only have been with a property that you have made a reservation with. Further to this, you may request a full copy of the personal information we hold for you which we will send to you. You can do this by emailing info@stellarcorporatehousing.com.

You have the right to restrict the processing of your data. We only use your data to process your reservation and if you request us to restrict processing then this will take place after your reservation and stay has been completed. Further to this, if you feel your data has been processed incorrectly or unfairly then you have the right to object to the processing of this data. You can do this by emailing info@stellarcorporatehousing.com.

If you decide that you don’t want us to store your data anymore then you can request it to be deleted. You can do this by emailing info@stellarcorporatehousing.com and we will delete all your personal data. We will only retain your data if we’re under a legal obligation to do so or we need to keep it to establish, exercise or defend a legal claim, and you will always be informed in these scenarios.

If you want us to transfer your personal information to another party where you provided it to us and we are using it based on your consent, or to carry out a contract with you, and we process it using automated means , you can do this by emailing info@stellarcorporatehousing.com.

If you think that we are using your information in a way which breaches data protection law, you have the right to lodge a complaint with your national data protection supervisory authority (DPC).

In the limited circumstances where we are relying on your consent (as opposed to the other bases set out above) to the collection, processing, and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another compelling legitimate interest in doing so.

XI. Cookie policy.

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’re 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 location. This helps us 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.

We use the following cookies:

Strictly necessary cookies.

These are cookies that 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 reservations services. Strictly necessary cookies do not require consent as they provide functionality as requested by the browser.

Performance cookies.

They allow us to recognise and count the number of visitors to our webpages and see how these visitors navigate around our site. This helps us to improve the way our website works by optimising our page layouts, search tools and general usability.

Functionality cookies.

These are used to recognise when you return to our websites in the future. This enables us to personalise our content for you, greet you by your name and remember your preferences such as language settings and time zone.

Targeting cookies.

These cookies record your visit to our websites, the pages you have visited and the links you have followed. We will use this information to make our websites and the advertising we display more relevant to your interests. 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.allaboutcookies.org/.