We value your privacy.

1. Introduction

This privacy policy applies to all users and entities of The Cover, its subsidiaries, and all of the members clubs, hotels, co-working facilities and restaurants within the portfolio of brands to which it provides operational or management services. The Cover takes your privacy very seriously and treats all your personal data with great care and in accordance with applicable data protection legislation. This privacy policy will inform you as to how we process and look after your personal data and your rights in relation to personal data you provide to us, whether collected from you as a user of our website and/or our (personal) web applications, an email subscriber, a hotel guest, an event attendee, a visitor to our restaurants or members clubs.

It is important that you read this privacy policy together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you, so that you are fully aware of how and why we are using your data. This privacy policy supplements the other notices and is not intended to override them.

2. Who are we?

This website ('Site') is operated by Sircle Collection B.V., a company also trading under the name Room 432, registered in The Netherlands under registration number 34369785 ('The Cover', 'we', 'us' and/or 'our'). Our registered address is Nieuwezijds Voorburgwal 271, 1012 RL Amsterdam. You can contact us as indicated under the 'Contact' section on the Site.

The data controller responsible for your personal data is The Cover, a company with whom you contract as a customer, member or membership applicant ('The Cover', 'we', 'us' and/or 'our').

3. What is this privacy policy for?

As stated in the Introduction this privacy policy applies to personal data that we collect from you as a user of this Site or as a membership applicant, member or customer ('you' or 'your' being interpreted accordingly). It provides information on what personal data we collect, why we collect the personal data, how it is used and the lawful basis on which your personal data is processed, and what your rights are under the applicable data protection and privacy laws, including the General Data Protection Regulation, Regulation EU 2016/679 ('GDPR').

The Cover collects the abovementioned personal information of its members and guests for specified, explicit purposes only and will not process this personal information in a manner that is incompatible with those purposes.

'Personal data' as used in this Privacy Policy means any information that relates to you from which you can be identified.

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to fulfil your reservation). In this case, we may have to cancel a service you have with us, but we will notify you if this is the case at the time.

By using our Site or submitting your personal data you are taken to accept the terms of this privacy policy, so we kindly ask you to read it carefully.

4. How is your personal data collected?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your identity, contact and financial data by filling in online forms or by corresponding with us by post, phone, e-mail or otherwise. This includes personal data you provide when you:

  • make a reservation;
  • attend an event at one of our locations;
  • receive any services from us;
  • use our Wifi service at one of our locations;
  • subscribe to our service or publications;
  • request marketing to be sent to you;
  • enter a competition, promotion or survey; or
  • give us some feedback.

Automated technologies or interactions. As you interact with our website, we may automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources, such as technical data regarding:

  • analytics providers;
  • advertising networks; and
  • search information providers.

Contact, financial and transaction data from providers of technical, payment and delivery services used by you in relation to your use of our website or at any of our locations.

Identity and contact data from data brokers or aggregators.

We also use CCTV surveillance in order to prevent our services and facilities from being used for illegal purposes and to protect our employees and customers at our locations. Personal data in this context may be processed by The Cover and its subsidiaries for these purposes.

5. Personal data that The Cover collects for its membership services

We collect the following personal data about you:

  • Membership application

The personal details you provide when submitting a membership application and when you register through the Site. This includes your name, address, email address; business address and phone number; date of birth; country; a picture of yourself; information about your work and other information that you elect to provide to support your application and other information that you elect to disclose in your user profile on the Site.

If your membership application has not been accepted at that time, we will remove your personal details from our database within one year from the date your application was received. If your membership expires, we will remove your personal details within 1 year from the expiry date or, if applicable law requires a longer period, after expiry of such period.

If you are under 30 years old, we will require you to attach to your application a copy of your passport, driving licence or birth certificate in order to allow us to verify whether you are eligible to the reduced under-30-years membership fee, pursuant to our house rules.We also collect information about your debit/credit card and bank account information provided by you to our payment service providers. We require this information for the purpose of recording and processing your membership application (and administering your membership). For further details, please also refer to the section below headed 'payment information'.

  • Reservation information

Guest information, such as your first and last name, e-mail address, billing and payment information (for further details, please also refer to the section below headed 'payment information'). Personal data collected in relation to reservations will be processed in accordance with a privacy policy provided at the time of requesting a reservation. Please ensure that you read our privacy notice on the reservation website that we may provide to you when we collect, or process, your personal data.

  • Site and The Cover digital channels with regard to information and services

Any content you generate on our upload to the Site or generate, upload or make available such content through our digital channels. We also collect information regarding your use of the Site and our digital channels, e.g. how you engage with Site and our digital channels, including how you interact with content we show to you and how you use and interact with the offered services from The Cover. We also infer your preferences, including your interests for the purpose of personalized content. We will also process your personal data in order to inform you about our existing services and opportunities and any new services and opportunities that relates to The Cover.

  • Location Information

We may also use GPS technology to determine your current location. Some of our location-enabled services require your personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose.

  • Capacity planning and tracing information

We also collect information regarding your visits to our various The Cover locations, its restaurants, spas, work spaces and gyms for capacity planning purposes and to comply with government guidelines, regulations and mandates.

  • Other information

Personal details you choose to give when corresponding with us by phone or email; participating in user/customer/member surveys, or otherwise visiting and interacting with this Site or any other websites we operate; and personal data that you provide to us when you visit one of our locations or other premises. We can also combine personal data that you provide to us with other information we collect about you when you make a reservation through third-party services, such as online restaurant-reservation or travel-fare aggregator websites necessary to process your requests.

6. Automatically collected personal data

Log data
When you visit our Site, our servers record information ('log data'), including information that your browser automatically sends whenever you visit the Site. This log data includes your Internet Protocol ('IP') address (from which we understand the country you are connecting from at the time you visit the Site), browser type and settings, the date and time of your request.

Cookies
Our Site uses cookies (small text files placed on your device) and similar technologies to distinguish you from other users. This is to provide you with a good user experience when you browse our Site, and allows us to improve its features. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For detailed information on the cookies and similar technologies we use, please check out our cookie policy.

7. How we use your personal data

We use your personal data in the following ways:

  • To acknowledge, confirm and deal with your membership application (and where necessary put you on The Cover waiting list). Such use of your data is necessary in order to implement your request to become a member; 
  • Once you are a member, we use your personal data to provide you with membership services, administer your membership account and contact you regarding your use of the services. Such use is necessary to respond to and/or implement your request, and for the performance of the contract between you and us; 
  • To complete and fulfil your reservation and stay, for example, to process your payment, ensure that your room or work space is available, and provide you with related customer service, including sending confirmations or pre-arrival messages, assist you with meetings, events or celebrations. Such use is necessary for the performance of the contract between you and us; 
  • To personalize the content you receive and provide you with tailored content that will be of interest to you;
  • To notify you about changes to our services and provide you with user support and enforcement regarding our terms, conditions and policies;
  • To contact you in connection with user/customer/member surveys, and use any information you choose to submit in response (provided that you gave us your consent to being contacted in this way at the time you provided us with the personal data).
  • To communicate with you about your visit to our Site and other digital channels, The Cover locations, spas, restaurants, gyms and work spaces.
  • In order to comply with our legal obligations, we may use your personal data to help us detect abuse, fraud and illegal activities on the Site.
  • The Cover may provide you, or permit selected third-party service providers to provide you, with information about goods and/or services, events and other promotions we feel may interest you as a member or membership applicant. We (or such third-party providers) will contact you by email only with your consent, which was given at the time you provided us with the personal data. We will get your express opt-in consent before we share your personal data for marketing purposes with any company outside The Cover.
  • For marketing purposes. The Cover strives to provide you with choices regarding certain personal data uses, especially around advertising and marketing. We have established the following personal data control mechanisms:
  • Promotional offers from us: you will receive marketing communications from The Cover, including newsletters and marketing emails relating to our services, if (i) you have requested information from us, (ii) used our services, or (iii) provided The Cover with your details when you entered or registered for a promotion and, in each case, you have not opted out of receiving that marketing information.
  • Opting out: you can ask The Cover to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

We also use your personal data if we think it is necessary for certain legitimate business interests, which include the following: 

  • In case we were asked to deal with any enquiries or complaints you make;
  • To (a) comply with any legal obligations, (b) respond to requests from competent authorities and/or government bodies; (c) enforce our house rules; (d) protect our operations or those of any of The Cover locations and its subsidiaries; (e) protect our rights, safety and properties; and (f) enforcing or defending legal rights, or preventing damage.
  • To administer our Site, to better understand how visitors interact with our websites and ensure that our Site is presented in the most effective manner for you and for your computer/device;
  • To conduct analytics to inform our marketing strategy and enable The Cover to enhance and personalize the experience we offer to our members, customers and our communications. This includes creating customer or member profiles to enable personalized direct marketing communications;
  • To improve, promote and develop the Site and promote programs and campaigns on the Site.
  • To provide postal communications, which we think will be of interest to you;
  • To share personal data for administrative purposes; for providing membership services; and in relation to our sales and marketing activities; 
  • If you ask us to delete your data or to be removed from our marketing lists and we are required to fulfil your request, to keep basic data to identify you and prevent further unwanted processing;
  • For internal business/technical operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes and as part of our efforts to keep our Site, network and information systems secure;
  • We may anonymize, aggregate and de-identify the data that we collect and use such anonymized, aggregated and de-identified data for our own internal business purposes, including sharing it with our current and prospective members, business partners, agents and other third parties for commercial, statistical and market research purposes, for example to allow those parties to analyse patterns among groups of people, and conducting research on demographics, interests and behavior.
  • To contact you in case you may have been in contact with a person who has or is displaying symptoms of COVID-19 and to comply with government guidelines, regulations and mandates.

We may use your personal data for other purposes, which you consented to at the time of providing your data including but not limited to provide you with location-based services (where those services are available in your jurisdiction and you choose to share your precise location with us). 

Legitimate interest

As used in this Privacy Policy, 'legitimate interests' means the interests of The Cover and its subsidiaries in conducting and managing our organization. When we process your personal data for our legitimate interests, we make sure to consider and balance any potential impact on you, and your rights under the applicable data protection laws. Our legitimate interests do not automatically override your interests. We will not use your personal data for activities where our interests are overridden by the impact on you, unless we have your consent or those activities are otherwise required or permitted to by law. You have the right to object at any time regarding the processing of your personal data that is based on our legitimate interests, on grounds relating to your particular situation.

8. Security

Where we have given you (or where you have chosen) a password or login that enables you to access certain restricted parts of our Site, you are responsible for doing everything you reasonably can to keep these details secret. You must not share your password or login details with anyone else.

Unfortunately, the transmission of information over the internet or public communications networks can never be completely secure. We will take appropriate technical and organizational security measures to protect the personal data that you submit to us against unauthorized/unlawful access or loss, destruction or damage, although we cannot fully guarantee the security of personal data that you provide to us online.

9. Disclosure of your information

We share your personal data with third parties in the following situations:

Service providers:
The Cover, like many businesses, sometimes hires selected third parties who act on its behalf to support its operations, such as (i) card processing or payment services; (ii) credit reference agencies to protect against possible fraud; (iii) IT suppliers and contractors (e.g. data hosting providers or delivery partners) as necessary to provide IT support and enable us to provide membership services and other goods/services available on this Site or to members; (iv) web analytics providers; (v) providers of digital advertising services; and (vi) providers of CRM, marketing and sales software solutions. Pursuant to our instructions, these parties may access, process or store your personal data in the course of performing their duties to us and solely in order to perform the services we have hired them to provide.

Business transitions:
If all or part of our company is sold, merged or otherwise transferred, we may transfer personal data held by us about our members as part of that transaction.  We may also transfer your personal data to the owners of The Cover managed by us.

Legal and Regulatory Authorities:
We may from time to time make your personal data available to legal and regulatory authorities, to our accountants, auditors, lawyers or similar professional advisers or to other third parties, when this is required by law, necessary to permit us to exercise our legal rights, to comply with our legal obligations, or necessary to take action regarding illegal activities or to protect the safety of any person.

10. Payment information

Any credit/debit card payments and other payments you make through our Site will be processed by our third-party payment providers. The payment data you submit will be securely stored and encrypted by our payment service providers using up to date industry standards. Please note that aside from card information tokenization we do not directly process or store the debit/credit card data that you submit ourselves.

We may arrange that card or payment data you submit in support of a membership application or subscription fee is stored for the purpose of processing your application, initiating your membership and collecting your subscription fees if your initial application is successful. If you are put on to a membership waiting list, please note that this data may be stored for later use to initiate your membership and subscription.

We store and use this card or payment information for the purpose of processing any future payments that you make as a member for additional goods and services. We will store this data in accordance with our legal obligations under applicable law, and only for so long as legally permitted.

You may choose to opt out of us holding your card or payment data, although this means that you will need to re-supply us with card/payment details to initiate your membership subscription fee, or for the purpose of making any future purchases.

11. Your choices and rights

Certain applicable data protection laws give you specific rights in relation to your personal data. In particular, if the processing of your personal data is subject to the GDPR, you have the following rights in relation to your personal data:

Access request rights

You have the right to request that we provide to you the following information about our collection and use of your personal information:  

  • The (categories of) personal information we have collected about you;
  • The categories of sources for the personal information we have collected about you (e.g., use of cookies, third party, etc.);
  • Our business or commercial purpose for collecting that personal information;
  • The categories of third parties with whom we share or have shared that personal information;
  • The specific pieces of personal information we collected about you (also called a data portability request); and
  • Information regarding any disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion, rectification and restriction request rights

You have the right to request that we delete, restrict or, if you believe that our processing of your personal data is incorrect or inaccurate, change any of the personal information collected from you and retained, subject to certain exceptions. Once your verifiable request is confirmed, we will delete, restrict or change, as the case may be, and direct our service providers to delete, restrict or change your personal information. Your request to delete the personal information collected may be denied if it is necessary for us to retain your information under one or more of the exceptions listed in the GDPR.

Data Portability Rights

In some cases, you may receive your personal data provided by yourself in a structured, commonly used and machine-readable format. You may reuse it elsewhere.

Right to object

Where we process your personal data based on a "legitimate interest", you may have the legal right to object to the processing of your personal data.

Right to revoke consent

Where we process personal data based on your consent, you have the right to revoke such consent at any given time. However, this will not affect the lawfulness of processing of your data before we received notice that you wished to revoke your consent.

Post-mortem right to privacy

You have the right to set instructions regarding the storage, deletion or communication of your personal data after your death.

Right to complain

You have the legal right to lodge a complaint with the competent data protection authority.

When handling any data access, erasure, or correction requests, we will first confirm the identity of the individual making the request or query and consider our obligations under applicable data protection laws and regulations. Such requests are usually provided free of charge, however, a reasonable fee may be applied to cover our administrative costs for requests that are manifestly unfounded, excessive or repetitive.

12. Personal data retention

We will keep your personal data only for as long as is reasonably necessary for the purposes outlined in this Privacy Policy, or for the duration required by any legal, regulatory, accounting or reporting requirements, whichever is longer. In particular, we retain membership records for seven years after expiration or termination of your membership. We retain information submitted through the Site and the other websites we operate for two years following account closure or contact with you, as applicable. When you consent to receive marketing communications, we will keep your data until you unsubscribe.

Upon expiry of the applicable retention period we will securely destroy your personal data in accordance with applicable laws and regulations. In some circumstances we may anonymise your personal data so that it can no longer be associated with you, in which case it is no longer personal data.