{"id":3,"date":"2020-08-27T21:11:51","date_gmt":"2020-08-27T21:11:51","guid":{"rendered":"https:\/\/www.kenshouniquestay.com\/?page_id=3"},"modified":"2020-10-09T10:00:49","modified_gmt":"2020-10-09T10:00:49","slug":"privacy-policy","status":"publish","type":"page","link":"https:\/\/www.kenshostay.com\/ee\/privacy-policy\/","title":{"rendered":"Privacy Policy"},"content":{"rendered":"
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Updated on 23rd September 2020<\/span><\/p>\n

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Privacy Policy<\/b><\/p>\n

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  1. \n
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    1. Introduction and summary<\/b>\n
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      1. We are Kensho O\u00dc (henceforth also referred to as “Kensho”), a private limited liability company registered in Estonian commercial registry under code 14956274 and having our registered office at Soo 7-6, Tallinn, Estonia.<\/span><\/li>\n
      2. Your use of our Services is subject to your acceptance of our Terms of Service and this Privacy Policy. If you disagree with any provisions of either document, you must not use our Services.<\/span><\/li>\n
      3. We shall only process your personal data if:<\/span>\n
          \n
        1. you have given us consent to do so for one or more specific purposes; you may withdraw your consent at any time;<\/span><\/li>\n
        2. it is necessary for the performance of our contractual obligations towards you; the law requires us to do so; or<\/span><\/li>\n
        3. we have a legitimate interest to do so. This includes processing your data for scientific research purposes, statistical purposes and direct marketing purposes, all of which are subject to additional safeguards.<\/span><\/li>\n<\/ol>\n<\/li>\n
        4. We will let you know what kinds of data we process about you, and for what purposes and how we process it. This policy will also explain what are your specific rights in regards to your personal data, and how you can exercise those rights. For more information, refer to Article (5) of this policy.<\/span><\/li>\n
        5. If you have any questions or complaints about this policy or the ways in which we process your personal data, you can contact our Data Protection Officer by email info@kenshouniquestay.com. If you find that your rights have been violated, you can lodge a complaint with the competent supervisory authority (Estonian Data Protection Inspectorate), whose contact details are available from <\/span>http:\/\/www.aki.ee\/<\/span><\/a>.<\/span><\/li>\n
        6. Kensho may amend this Privacy Policy in the future. In the event changes are made, we will be sure to post changes at the website <\/span>www.kenshouniquestay.com<\/span><\/a> and at other places we deem appropriate.<\/span>\n

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        7. Definitions<\/b>\n
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          1. \u2018personal data\u2019 means any information relating to an identified or identifiable natural person (\u2018data subject\u2019); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person; \u2018your personal data\u2019 means personal data relating to you;<\/span><\/li>\n
          2. \u2018processing\u2019 means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not 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;<\/span><\/li>\n
          3. \u2018restriction of processing\u2019 means the marking of stored personal data with the aim of limiting their processing in the future;<\/span><\/li>\n
          4. \u2018profiling\u2019 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 personal health, preferences and interests;<\/span><\/li>\n
          5. \u2018pseudonymisation\u2019 means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person;<\/span><\/li>\n
          6. \u2018filing system\u2019 means any structured set of personal data which are accessible according to specific criteria, whether centralised, decentralised or dispersed on a functional or geographical basis;<\/span><\/li>\n
          7. \u2018controller\u2019 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;<\/span><\/li>\n
          8. \u2018processor\u2019 means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller;<\/span><\/li>\n
          9. \u2018recipient\u2019 means a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing;<\/span><\/li>\n
          10. \u2018third party\u2019 means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data;<\/span><\/li>\n
          11. \u2018consent\u2019 of the data subject means any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her;<\/span><\/li>\n
          12. \u2018personal data breach\u2019 means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed;<\/span><\/li>\n
          13. \u2018genetic data\u2019 means personal data relating to the inherited or acquired genetic characteristics of a natural person which give unique information about the physiology or the health of that person<\/span><\/li>\n
          14. \u2018biometric data\u2019 means personal data resulting from specific technical processing relating to the physical, physiological or behavioural characteristics of a natural person, which allow or confirm the unique identification of that natural person, such as facial images;<\/span><\/li>\n
          15. \u2018data concerning health\u2019 means personal data related to the physical or mental health of a natural person, including the provision of health care services, which reveal information about his or her health status;<\/span><\/li>\n
          16. \u2018main establishment\u2019 means:<\/span>\n
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            1. as regards a controller with establishments in more than one Member State, the place of its central administration in the Union, unless the decisions on the purposes and means of the processing of personal data are taken in another establishment of the controller in the Union and the latter establishment has the power to have such decisions implemented, in which case the establishment having taken such decisions is to be considered to be the main establishment;<\/span><\/li>\n
            2. as regards a processor with establishments in more than one Member State, the place of its central administration in the Union, or, if the processor has no central administration in the Union, the establishment of the processor in the Union where the main processing activities in the context of the activities of an establishment of the processor take place to the extent that the processor is subject to specific obligations under this Regulation;<\/span><\/li>\n<\/ol>\n<\/li>\n
            3. \u2018representative\u2019 means a natural or legal person established in the Union who, designated by the controller or processor in writing pursuant to Article 27, represents the controller or processor with regard to their respective obligations under this Regulation;<\/span><\/li>\n
            4. \u2018enterprise\u2019 means a natural or legal person engaged in an economic activity, irrespective of its legal form, including partnerships or associations regularly engaged in an economic activity;<\/span><\/li>\n
            5. \u2018group of undertakings\u2019 means a controlling undertaking and its controlled undertakings;<\/span><\/li>\n
            6. \u2018binding corporate rules\u2019 means personal data protection policies which are adhered to by a controller or processor established on the territory of a Member State for transfers or a set of transfers of personal data to a controller or processor in one or more third countries within a group of undertakings, or group of enterprises engaged in a joint economic activity;<\/span><\/li>\n
            7. \u2018supervisory authority\u2019 means an independent public authority which is established by a Member State pursuant to Article 51;<\/span><\/li>\n
            8. \u2018supervisory authority concerned\u2019 means a supervisory authority which is concerned by the processing of personal data because:<\/span>\n
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              1. the controller or processor is established on the territory of the Member State of that supervisory authority;<\/span><\/li>\n
              2. data subjects residing in the Member State of that supervisory authority are substantially affected or likely to be substantially affected by the processing; or<\/span><\/li>\n
              3. a complaint has been lodged with that supervisory authority;<\/span><\/li>\n<\/ol>\n<\/li>\n
              4. \u2018cross-border processing\u2019 means either:<\/span>\n
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                1. processing of personal data which takes place in the context of the activities of establishments in more than one Member State of a controller or processor in the Union where the controller or processor is established in more than one Member State; or<\/span><\/li>\n
                2. processing of personal data which takes place in the context of the activities of a single establishment of a controller or processor in the Union but which substantially affects or is likely to substantially affect data subjects in more than one Member State.<\/span><\/li>\n<\/ol>\n<\/li>\n
                3. \u2018relevant and reasoned objection\u2019 means an objection to a draft decision as to whether there is an infringement of this Regulation, or whether envisaged action in relation to the controller or processor complies with this Regulation, which clearly demonstrates the significance of the risks posed by the draft decision as regards the fundamental rights and freedoms of data subjects and, where applicable, the free flow of personal data within the Union;<\/span><\/li>\n
                4. \u2018information society service\u2019 means a service as defined in point (b) of Article 1(1) of Directive (EU) 2015\/1535 of the European Parliament and of the Council;<\/span><\/li>\n
                5. \u2018international organisation\u2019 means an organisation and its subordinate bodies governed by public international law, or any other body which is set up by, or on the basis of, an agreement between two or more countries.<\/span>\n

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                6. General provisions<\/b>\n
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                  1. Grounds for processing<\/span>\n
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                    1. We shall only process your personal data if and to the extent that at least one of the following applies:<\/span><\/li>\n
                    2. you have given consent to the processing of your personal data for one or more specific purposes;<\/span><\/li>\n
                    3. processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract;<\/span><\/li>\n
                    4. processing is necessary for compliance with a legal obligation to which we are subject;<\/span><\/li>\n
                    5. processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by your interests or fundamental rights and freedoms which require protection of personal data, in particular where you are a child. Note that our legitimate interests include processing your data for scientific research purposes and statistical purposes, and for direct marketing purposes. These special cases are covered in Articles 3.6 and 4.8 of this Policy;<\/span><\/li>\n<\/ol>\n<\/li>\n
                    6. Conditions for consent<\/span>\n
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                      1. When we request your consent in the context of a written declaration which also concerns other matters, the request for consent shall be presented in a manner which is clearly distinguishable from the other matters.<\/span><\/li>\n
                      2. You shall have the right to withdraw your consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal. It shall be as easy to withdraw as to give consent.<\/span><\/li>\n
                      3. If you are a child younger than 16 years, then the consent must be given or authorised by the holder of parental responsibility over you, and we shall make reasonable efforts to verify the identity of the person giving or authorising the consent. Note that some Member States have reduced this minimum age; however, such reduced minimum is not below 13 years. Note also that this shall not affect the general contract law of Member States such as the rules on the validity, formation or effect of a contract in relation to a child.<\/span>\n

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                      4. Processing which does not require identification<\/span>\n
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                        1. Where we can to demonstrate that we are not or no longer in a position to identify the data subject, Articles 4.2 to 4.7 shall not apply except where you, for the purpose of exercising your rights under those articles, provide additional information enabling your identification.<\/span>\n

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                        2. International data transfers\u00a0<\/span>\n
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                          1. We may transfer your personal data to a controller, processor or recipient in a third country or an international organisation where the Commission has decided, by means of implementing act, that the third country, a territory or one or more specified sectors within that third country, or the international organisation in question ensures an adequate level of protection.<\/span><\/li>\n
                          2. We may also transfer your personal data to a third country or international organisation subject to appropriate safeguards, such as<\/span>\n
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                            1. binding corporate rules approved by the competent supervisory authority;<\/span><\/li>\n
                            2. standard data protection clauses adopted by the Commission; or<\/span><\/li>\n
                            3. contractual clauses between us and the controller, processor or recipient, if authorised by the competent supervisory authority.<\/span><\/li>\n<\/ol>\n<\/li>\n
                            4. We shall only recognise any judgment of court or tribunal or any decision of an administrative authority of a third country requiring us to transfer or disclose personal data if such judgment or decision is based on an international agreement, such as a mutual legal assistance treaty, in force between the requesting third country and the Union or a Member State, without prejudice to other grounds for transfer pursuant to this Chapter.<\/span><\/li>\n
                            5. In the absence of an adequacy decision pursuant to paragraph 1 or appropriate safeguards pursuant to paragraph 2, a transfer or a set of transfers of your personal data to a third country or an international organisation shall take place only on one of the following conditions:<\/span>\n
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                              1. you have explicitly consented to the proposed transfer, after having been informed of the possible risks of such transfers for you due to the absence of an adequacy decision and appropriate safeguards;<\/span><\/li>\n
                              2. the transfer is necessary for the performance of a contract between you and us or the implementation of pre-contractual measures taken at your request;<\/span><\/li>\n
                              3. the transfer is necessary for the conclusion or performance of a contract concluded in your interest between us and another natural or legal person; or<\/span><\/li>\n
                              4. transfer is necessary for the establishment, exercise or defence of legal claims.<\/span><\/li>\n<\/ol>\n<\/li>\n
                              5. Where a transfer could not be based on a paragraphs 1 to 4, a transfer of personal data to a third country or an international organisation may take place only if the transfer is not repetitive, concerns only a limited number of data subjects, is necessary for the purposes of compelling legitimate interests pursued by us which are not overridden by the interests or rights and freedoms of the data subjects, and we have assessed all the circumstances surrounding the data transfer and have on the basis of that assessment provided suitable safeguards with regard to the protection of personal data. We shall inform the supervisory authority of the transfer. We shall, in addition to providing the information referred to in Article 4.1, inform you of the transfer and on the compelling legitimate interests pursued.<\/span>\n

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                              6. Scientific research and statistics<\/span>\n
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                                1. Processing for scientific research purposes or statistical purposes shall be subject to appropriate safeguards for your rights and freedoms. Those safeguards shall ensure that technical and organisational measures are in place in particular in order to ensure respect for the principle of data minimisation. Those measures may include pseudonymisation provided that those purposes can be fulfilled in that manner. Where those purposes can be fulfilled by further processing which does not permit or no longer permits the identification of data subjects, those purposes shall be fulfilled in that manner.<\/span>\n

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                                2. Security of personal data<\/span>\n
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                                  1. Kensho uses account information in a password-protected environment as a security measure to protect your data. We use administrative, physical, and technical safeguards to protect data.\u00a0 We maintain a high level of data protection via safeguards such as data backup, audit controls, access controls, and data encryption. We use industry standard SSL\/TLS encryption to enhance security of electronic data transmissions.\u00a0<\/span><\/li>\n
                                  2. In addition, Kensho urges you to take precautionary measures in maintaining the integrity of your data.<\/span><\/li>\n
                                  3. We employ strict technical and organisational (security) measures to protect your personal data from access by unauthorised persons and against unlawful processing, accidental loss, destruction and damage both online and offline. These measures include:<\/span>\n
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                                    1. training relevant staff to ensure they are aware of our privacy obligations when handling personal data;<\/span><\/li>\n
                                    2. administrative and technical controls to restrict access to personal data;\u00a0<\/span><\/li>\n
                                    3. technological security measures, including fire walls, encryption and anti-virus software;<\/span><\/li>\n
                                    4. back-up systems;<\/span><\/li>\n
                                    5. login access blocks in case of loss or theft of devices;<\/span><\/li>\n
                                    6. physical security measures, such as staff security badges to access our premises.<\/span><\/li>\n<\/ol>\n<\/li>\n
                                    7. If you use our Kensho services (e.g booking engine) through a potentially non-secure internet connection, such use is at your own risk. It is your responsibility to check beforehand on your employer\u2019s or such other site\u2019s privacy and security policy with respect to Internet use.<\/span><\/li>\n
                                    8. Kensho is not responsible for your handling, sharing, re-sharing and\/or distribution of your Protected Information or Personally Identifiable Information. Moreover, if you forward Protected Information or Personally Identifiable Information electronically to another person on or off the Kensho, we are not responsible for any harm or other consequences from third party use or re-sharing of your information.<\/span><\/li>\n
                                    9. All data are stored securely and are accessible to a very limited number of employees and contractors as required. Those with access to this data adhere to strict guidelines regarding user data security and privacy.<\/span><\/li>\n
                                    10. Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.<\/span><\/li>\n
                                    11. We will not sell, distribute or lease your personal information to third parties unless we have your permission or are required by law to do so. We may use your personal information to send you promotional information about third parties which we think you may find interesting if you tell us that you wish this to happen.<\/span>\n

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