Privacy Statement - Dwel Serviced Residences, Inc.

 

Introduction
Dwel Serviced Residences, Inc. recognizes that the personal information it receives is held in a position of trust. Dwel seeks to fulfill that trust by adhering to general principles regarding the protection of personal information. This Privacy Statement explains how we collect, use, share, and protect information for all purposes as listed above and mentioned in this Statement.

Scope
This Privacy Statement applies to the personal information of consumers that is collected or used by Dwel its affiliates or subsidiaries (“Dwel”). This Statement applies to all the personal information that Dwel collects when consumers interact with Dwel, such as when visiting our websites, using the products or services offered by Dwel, when purchasing Dwel products or services, when contacting customer service, and when interacting with Dwel as a business customer, supplier or business partner.

This includes, without limitation, all online and offline collections of all types of personal information. However, if some Dwel collections involve types of data with special requirement, Dwel will make it clear that the privacy notice concerned is different from this general privacy statement.

Information collection
Dwel may ask you to provide personal information for purposes including, but not limited to, the following:

  • Engaging Dwel products and services;
  • Activating or registering certain products and services or enhancing functionality;
  • Receiving information about Dwel products and services;
  • Participating in Dwel online communities, including our social media channels/pages;
  • Storing your preferences for future interactions and communications from Dwel;
  • Helping us to develop products and services and create campaigns that are designed around you, optimize customer services and continuously improve our websites;
  • Helping us to improve products and services, and allowing Dwel to keep you informed of, or involve you in new products and services;
  • Resolving product and customer services issues;
  • Registering visitors of Dwel facilities or Dwel organized events and conferences;
  • Contract or tender management; and
  • Receiving personalized messages, special offers and advertisements that are relevant to your personal interests, based on the information you have shared with us and on the information we have collected through cookies or similar techniques regarding your use of the Dwel websites/social media/blogs.

Dwel maintains physical, technical, and administrative safeguards to protect your personal information and only allows disclosures as permitted by law to assist in providing products or services. We may also collect product and service information and provide these statistics to others in an aggregate form where the information has been de-identified.

Personal information collected may include:

  • Contact information, such as name, address, email, telephone number, fax number, organization name, and/or job title
  • Unique identifiers and preference information such as username, password, marketing preferences, internet protocol (IP) address, browser type, operating system, computer or mobile device, or navigation and clickstream behavior for online interactions.
  • Resume including work history, professional qualifications, publications, awards, references, completed trainings, signature
  • Passport info for travel bookings or identification purposes, social security number (where required by law), bank account details, (emergency) contact persons, family information (where applicable and in accordance with local law)
  • Creditworthiness, VAT number, product, purchase information history, request documentation
  • Pictures, video and audio recordings where you have provided your permission
  • Sensitive personal information, such as health information or reports of an individual end-customer, i.e. concerning product claims and investigations, patient pre and post-operative outcomes for research & statistical purposes, or criminal records for due diligence procedures in accordance with applicable law.

Dwel will retain and use the personal information collected for above mentioned processes and processing purposes accordance with legal obligations.
 

Legal Basis
The legal basis Dwel uses to process personal information will be dependent on the processing purposes and the jurisdictional legal requirements. Where the personal information collected involved is of EU citizens, in general, we use the following basis:

  • Consent to use the personal information, i.e. where this involves (digital) direct marketing activities and where we would like to use a photo, video or audio recording with identifiable individuals for external publishing;
  • Establishment or performance of a contract, i.e. where we enter into a contract with a party and we collect contact information and signatures, as well as potential bank account details that may be linked to a representative of a company we do business with;
  • Compliance with a legal obligation, i.e. where we need to disclose consumer details for compliance with (local or industry) laws.
  • Legitimate interest of Dwel, i.e. where Dwel collects contact information and preferences, details for lodging and travel for customers.
  • Public interest or for the exercise of public authority in strictly limited cases, i.e. where we would be required to cooperate with the Police or other government bodies in case of illegal conduct;
  • For the establishment, exercise or defense of legal claims, i.e. for court cases;
  • Where the individual chooses to disclose the personal information publicly by its own initiative.

If you choose not to provide the personal information we reasonably require, it may hinder Dwel’s ability to provide the information or services you have requested.

Cross-border transfer
To the extent personal information is transferred out of the country where the owner of that personal information lives, such as to Dwel affiliates or business partners in other countries, including in the United States, different standards may apply to how your data is used and protected in those countries. Dwel has appropriate safeguards in place in accordance with applicable legal requirements to ensure that data is adequately protected irrespective of the country. This includes obtaining written assurances from any third party given access to your data so as to require them to adopt standards that ensure an equivalent level of protection for data as that adopted by Dwel and standardized corporate safeguards and contractual measures (based on the European Commission Model Clauses) for internal data transfers to Dwel affiliates in third countries which are deemed to provide an inadequate level of data protection.

Privacy statement for children
Dwel will not collect personal information from anyone we know to be under the age of 16 without the prior, verifiable consent from his or her legal representative. Such legal representative has the right, upon request, to view the information provided by the child and/or to require that it be deleted.

How long we keep information
Dwel will retain your personal information for as long as reasonably necessary to comply with legal obligations or for no longer as required for legitimate business purposes.

Information sharing
Dwel may share personal information we have collected with companies or agents doing technological maintenance or working on our behalf to help fulfill business needs, including providing customer services and distributing marketing communications. Dwel may also share personal information with our subsidiaries and affiliates.

Other service providers that may be used to perform certain functions on our behalf and to whom personal information may be disclosed in order to perform their intended function include call-center support, sending or processing postal or electronic mail or analyzing or hosting information on cloud-based servers.

Dwel does not share your personal information with unaffiliated third parties for their own direct marketing purposes.

Security
The security and confidentiality of your personal information matters to us. For this reason, Dwel has physical, technical and administrative controls in place to protect your Personal Information from unauthorized access, use and disclosure. Dwel evaluates these safeguards on an ongoing basis to help minimize risks from new security threats as they become known.

Rights
You may request details of personal data which we hold about you. If you believe that any personal information we are holding on you is incorrect or incomplete, please contact us as soon as possible, at the address below. We will promptly correct any personal information found to be incorrect.

You may always choose to object to the collection or use of your personal information or to have your information erased. If you would like a copy of the information held about you please or to exercise any other right, please contact us at [email protected].

Updates to Privacy Statement
This Privacy Statement may be amended at any time. If material changes are made in how personal information is collected, used, disclosed, or otherwise processed, this Statement will be updated and notices will be provided when/where appropriate. Any material changes to this Privacy Statement will be effective at the time of our posting of the notice of the update. Where required to do so by law, Dwel may seek your prior consent to any material changes we make to this Privacy Statement.

The Statement was last updated on [02-04-2019]

Contact
If you have any questions, concerns, or comments about this Privacy Statement, please contact us. Dwel will use reasonable efforts to respond to you as soon as possible.

Send mail to:
Dwel Serviced Residences, Inc.
Attn.: Data Privacy Director
2801 Merrilee Dr Suite H
Fairfax, VA 22031

Email:  [email protected]

If we fail to respond to you within a reasonable period of receiving it in writing, or if you are dissatisfied with the response that you receive from us, you may lodge a complaint with the data protection authorities in your home country.