Our Policy
Welcome to GHG’s mobile application (hereinafter referred to as the “App”). The App and related services are provided by HqO on behalf of GHG B.V. (collectively referred to as “we”, “us”, “our) to augment a tenant’s experience at our property through providing information, services, and functionality related to the property and are subject to the Terms of Service.
The protection and security of your personal data are important to us. Personal data is any information relating to an identified or identifiable natural person (“Personal Data”). This privacy policy (“Privacy Policy”) describes how we collect, use, share and protect your Personal Data which is collected through the App. This policy also explains your rights related to how your Personal Data is being processed.
- Name and contact details of the controller
GHG B.V.
c/o Jamestown Europe Management B.V.
39 Pilotenstraat
1059CH Amsterdam
Netherlands
GHG is managed and owned by Jamestown Europe: www.jamestownlp.com/jteu-imprint
- Name and contact details of the processor
HqO UK Limited
201 Borough High Street
London SE1 1JA
United Kingdom
- Contact details of the data protection officer
Jamestown Europe GmbH, located in Cologne, Germany, and Jamestown Europe Management B.V., located in Amsterdam, the Netherlands, have appointed an external data protection officer who can be reached through the following contact details.
Postal:
Jamestown Europe GmbH
Attn: Data Protection Officer
Marienburger Str. 17
50968 Cologne
Germany
Email: jteu-privacy@jamestown.de
Postal:
Jamestown Europe Management B.V.
Attn: Data Protection Officer
39 Pilotenstraat
1059CH Amsterdam
Netherlands
Email: jteu-privacy@jamestown.de
You may contact our data protection officer directly at any time with any questions or suggestions regarding data protection.
- Information We Collect:
When you interact with us through the App, we may collect Personal Data and other information from you, as further described below:
- Personal Data That You Provide: We collect Personal Data from you when you voluntarily provide such information, such as when you contact us with inquiries.
- Setting up an account via the App: When you download our App and set up an account, we will collect certain Personal Data from you such as your username and password.
- Usage of the App: The following information will also be collected via the App: your full name, email address, tenant status, location, your user ID, your building ID, time stamp, make and model of your device, operating system, operating system version, the services you engage with and your actions in relation to them.
- Aggregated Personal Data: In an ongoing effort to better understand and serve the users of the App, we conduct research on user demographics, interests and behavior based on the Personal Data and other information provided to us. This research may be compiled and analyzed on an aggregate basis, and we may share this aggregate data with our affiliates, agents and business partners. This aggregate information does not identify you personally. We may also disclose aggregated user statistics in order to describe our services to current and prospective business partners, and to other third parties for other lawful purposes.
- Our Use of Your Personal Data and Other Information:
We process the Personal Data you provide to us to enable us via the App to perform the contract we are about to enter into or have entered into with you, to ensure compliance with local legal and regulatory requirements and for the purposes of our legitimate business interests, including:
- to enable us to carry out our obligations arising from any contracts and to provide you with the information and services that you request from us;
- to enable us to respond to an enquiry or other request you make when you contact us via our App, including for customer services support;
- to notify you about any changes to the App;
- to enable us to issue a notice or corrective action to you in relation to the App, if required; and
- to help us improve the content and functionality of the App.
We do not subject you to decisions based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you. If we intend on using any Personal Data in any manner that is not consistent with this Privacy Policy, you will be informed of such anticipated use prior to or at the time at which the Personal Data is collected.
- Our Disclosure of Your Personal Data and Other Information
We do not sell your Personal Data to third parties, and we do not rent, or share your Personal Data with third parties for such third parties’ direct marketing. We consider this information to be a vital part of our relationship with you. There are, however, certain circumstances in which we may share your Personal Data with certain third parties without further notice to you, as set forth below:
- Business Transfers: As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, Personal Data may be part of the transferred assets.
- Related Companies: We may also share your Personal Data with our affiliates for purposes consistent with this Privacy Policy.
- Agents, Consultants and Related Third Parties: We, like many businesses, sometimes engage other companies to perform certain business-related functions. Examples of such functions include the operator of this App, mailing information, maintaining databases and processing payments. When we employ another company to perform a function of this nature, we only provide them with the information that they need to perform their specific function.
- Legal Requirements: We may disclose your Personal Data if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend our rights or our property, (iii) act in urgent circumstances to protect the personal safety of users of the App or the public, or (iv) protect against legal liability.
- Storing your Personal Data
Your Personal Data collected via the App will be stored on servers located in the European Union. We have taken steps to ensure that your Personal Data receives an adequate level of protection where it is processed and your rights continue to be protected. If you require more information, please contact us using the details in the “Contact Us” section below.
- Data Retention
We will only retain your Personal Data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements.
- Children
If you are under 16 years of age, you are not authorized to use this App. If you are between the ages of 16 and 18 years old, you may use the App only with the approval of your parent or guardian. We do not knowingly collect Personal Data from children under the age of 16. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children never to provide Personal Data on the App without their permission. If you have reason to believe that a child under the age of 16 has provided Personal Data to us through the App, please contact us, and we will endeavor to delete that information from our databases.
- Links to Other Web Sites
This Privacy Policy applies only to the App. The App may contain links to other websites not operated or controlled by us (the “Third Party Sites”). The policies and procedures we described here do not apply to the Third Party Sites. The links from the App do not imply that we endorse or have reviewed the Third Party Sites. We suggest contacting those sites directly for information on their privacy policies.
- Security
We take reasonable steps to protect the Personal Data provided via the App from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no transmission of information over the Internet can be guaranteed to be fully secure or error free. Therefore, you should take special care in deciding what information you send via the App. Please keep this in mind when disclosing any Personal Data to us.
- International Data Transfers
We have personnel and affiliates internationally, including in the United States, which means information we collect may be processed by us in the U.S., where data protection and privacy regulations may not offer the same level of protection as in other parts of the world, such as the European Union. When transferring data outside of the European Union, we apply suitable safeguards to protect the privacy and security of your Personal Data.
HqO and its affiliates comply with the requirements of the EU-U.S. Data Privacy Framework, the UK Extension to the EU-U.S. Data Privacy Framework, and the Swiss-U.S. Data Privacy Framework as set forth by the U.S. Department of Commerce (collectively, the “DPF”). HqO has certified to the U.S. Department of Commerce that it adheres to the DPF Principles with respect to personal information (as described below) that is transferred from the European Union and its Member States, the European Economic Area, the United Kingdom (and Gibraltar), and/or Switzerland to the United States. If there is any conflict between the terms in the DPF Policy or another applicable privacy policy and the DPF Principles, the DPF Principles shall govern. To learn more about the Data Privacy Framework and to view HqO’s certification, please visit: www.dataprivacyframework.gov.
- Changes to our Privacy Policy
The App and our business may change from time to time. As a result, we may periodically modify this Privacy Policy and will promptly post an updated Privacy Policy on https://www.hqo.com/ghg-privacy-policy/ showing the date of the update. Please check regularly for the most recent version of our Privacy Policy. If you disagree with any changes made to this Privacy Policy you will need to stop using the App. We will keep prior versions of this policy which you may request via email to jteu-privacy@jamestown.de.
- Your Rights
Where appropriate and where applicable by law, we shall provide you with the following individual rights with respect to your Personal Data: You may have the right to: (a) request access to the Personal Data we hold about you; (b) request that we correct any inaccurate Personal Data we hold about you; (c) request that we delete any Personal Data we hold about you; (d) restrict the processing of Personal Data we hold about you; (e) object to the processing of Personal Data we hold about you; (f) receive any Personal Data we hold about you in a structured and commonly used machine-readable format or have such Personal Data transmitted to another company; (g) not be subjected to automated decision making; and/or (h) lodge a complaint.
We may ask you for additional information to confirm your identity and for security purposes, before disclosing information requested to you. We will process any request in line with any local laws and our policies and procedures. We do not subject you to decisions based solely on automated processing, including profiling.
You have the right to lodge a complaint about how we process your Personal Data with the supervisory authority in your country. The supervisory authority responsible Jamestown Europe Management B.V. is:
Autoriteit Persoonsgegevens
PO Box 93374
2509 AJ Den Haag
Phone: +31 70 888 85-00
Fax: +31 70 888 85-01
Email: info(at)autoriteitpersoonsgegevens.nl
You can exercise your rights with respect to your personal data by contacting us via email or postal through the contact details shown at the beginning of policy.
If you wish to exercise any of your rights, please contact us using the information provide in the “Contact Us” section below.
- Contact Us
If you have any questions about this Privacy Policy or the practices described herein, please direct your inquiry to jteu-privacy@jamestown.de or by post to the addresses shown in Sections 1 and 3.