Privacy Shield Statement

SilverDoor Limited respects your privacy, and we are committed to responsibly handling your personal data. SilverDoor complies with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States. SilverDoor has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov.

Collection of Data

At SilverDoor, we collect personal information from the following groups of people:

  1. Clients. Those staying in or looking for Serviced Apartment/Corporate Housing accommodation. 
  2. Employees. Those that work for the company either through direct engagement with the client/traveller or indirectly through services like HR, IT and Marketing.
  3. Third parties. Our property partners who provide Serviced Apartment/Corporate Housing accommodation.

Collection occurs, for example, when a potential client visits our website and provides personal information by submitting an enquiry form. For more information on the types of data we collect and when, please visit https://www.silverdoorapartments.com/policies/privacy/ to view our full, public privacy policy.

Privacy Shield Principles

SilverDoor’s privacy practices regarding the processing of client personal information comply, as appropriate, with the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability.

1. Notice

SilverDoor provides information in this Policy and the company’s online privacy policy at https://www.silverdoorapartments.com/policies/privacy/ about how we use personal information. This information includes the following:

We collect, process and use your personal information only as a part of our business relationship with you and your company, if applicable.

SilverDoor collects personally identifiable information about individuals when such individuals specifically provide this information to us on a voluntary basis or while requesting information on our services. We may disclose personal information to our property partners to provide the services required. SilverDoor must reply to lawful requests from public authorities, including meeting national security or law enforcement requirements, for disclosure of personal information.

SilverDoor does not sell, lease, or rent personal information to or from third parties.

2. Choice

SilverDoor offers clients the opportunity to choose whether their personal information should be (1) disclosed to a third party, or (2) to be used for a purpose that is materially different than that for which it was originally collected or subsequently authorised by you. We will never use your data for any reason you haven’t been made aware of unless required to by law or an authoritative body.

3. Accountability for Onward Transfer

SilverDoor provides clients with an opportunity to opt out of sharing their personal information with third-party controllers except as permitted or required by applicable law and in accordance with our role as a data controller. We require third-party controllers to whom we disclose personal information to contractually agree to:

SilverDoor has liability for onward transfers to third parties unless we can prove we were not a party to the events giving to rise to the damages.

3. Security

To protect the personal information we collect and store, we have in place reasonable and appropriate technical and operational security measures to prevent loss, misuse, unauthorised access, disclosure, alteration, and destruction, taking into account the risks involved in the processing and the nature of the personal information.

4. Data Integrity and Purpose Limitation

SilverDoor will only collect personal information that is relevant to providing our services and we will not use it in a way that is incompatible with these purposes unless such use has been subsequently authorised by you. We will take reasonable steps to ensure that the personal information we collect is needed for our services, and accurate, complete and current.

SilverDoor will retain client’s personal information for as long as it serves a purpose that is compatible with the reasons for which it was collected or subsequently authorised by the client. We will also only retain your data if we are 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. We may also retain archive data for statistical and continuity purposes.

We may occasionally contact you to determine that your data is still accurate and current.

5. Access and Other Rights

Clients have the right to access their personal information. Accordingly, to the extent SilverDoor acts as a controller, where appropriate, we provide clients with reasonable access to the personal information we maintain about them. We also provide a reasonable opportunity for data subjects to correct, amend or request to delete the information where it is inaccurate or has been processed in violation of the Privacy Shield Principles. We may limit or deny such access and related activity where the burden or expense of providing access would be disproportionate to the risks to your privacy in the case in question, or where the rights of persons other than you would be violated.

We reserve the right to verify your identity before any request relating to your personal information is processed by us.

6. Recourse, Enforcement and Liability

Since we are committed to protecting your privacy as set forth in this policy, if you think we are not in compliance with our policy, please write to us at the address provided below for any questions or concerns.

SilverDoor Americas Inc.
Attn: Information Security Manager
Address: Union Tower West, 1801 Wewatta Street, Suite 11087, Denver CO 3 80202

By email: [email protected]

SilverDoor will take steps to investigate and resolve the complaints and disputes regarding the use and disclosure of personal information in accordance with the Privacy Shield Principles.

If a data subjects’ complaint cannot be resolved through SilverDoor’s internal processes, you may contact JAMS at https://www.jamsadr.com/eu-us-privacy-shield, which is an independent third-party dispute resolution body, and they will investigate and assist you free of charge.

A binding arbitration option may also be available to you in order to address residual complaints not resolved by any other means. We are subject to the investigatory and enforcement powers of the United States Federal Trade Commission (the “FTC”). You can learn more about the FTC’s role in enforcement of the Privacy Shield at https://www.commerce.gov/.

Contact Information

If you have any questions or comments about this Notice or any issue relating to how we collect, use or disclose personal information, or if you would like to update information we have about you, you may contact us.

SilverDoor Americas Inc.
Attn: Information Security Manager
Address: Union Tower West, 1801 Wewatta Street, Suite 11087, Denver CO 3 80202

By email: [email protected]

Changes to this Policy

In general, changes will be made to this Policy from time to time to address new or modified laws, changes to EU-US Privacy Shield Framework or new or modified business procedures. However, we reserve the right to amend this Policy at any time.

Effective: 15/05/2020