Privacy policy

Who holds it

Sherborne Apart-Hotel, Provulok Mykilskyi 9, Kyiv 01010, Ukraine, is responsible for the personal data described on this page. Anything on it — a question, a copy of your record, a deletion — goes to reservation@sherbornehotel.com.ua, or +380 44 280 3315.

What a booking records

Making a booking is the only thing on this site that asks you for anything. What it stores is:

• Your name, email address and telephone number, and the country you selected.
• The dates, how many adults and children, the apartment you were given and what the stay was priced at.
• Anything you typed into the message box — an arrival time, a train number, a cot, a dog, a quiet floor.
• The language you booked in, so that what we send you comes back in it.

That is the whole list. There is no account and no password: the booking reference on your confirmation is the credential, which is why it is worth keeping and worth not posting anywhere public.

Paying

The deposit is taken by Monobank, on Monobank's own payment page. Your card number, its expiry date and its security code are typed into their page and never reach this server — we could not store them if we wanted to.

What we send Monobank is the amount, your booking reference and a line naming the hotel and your dates. We do not send them your name, your email address or your telephone number.

What we keep is the invoice number Monobank issued, the amount, whether it succeeded, and the status message the bank sent back. That last one is what allows a payment to be reconciled or refunded three months later. Monobank is responsible for what happens on their own page, under their own terms.

Cookies, analytics and trackers

Server logs

The web server keeps an ordinary access log: the address a request came from, the time, the page asked for and the browser's own description of itself. Every web server keeps one, and it exists so that an attack or an outage can be looked into afterwards. It is not joined to a booking and nothing reads it for any other purpose.

The calendars, and what Booking.com is not told

The site publishes a calendar feed for each apartment so that a booking taken here closes the same dates on Booking.com. Those feeds carry dates and nothing else: every entry says only that the apartment is unavailable between two dates. No name, no email address, no telephone number, no price, no party size. Booking.com receives no guest data from us at all.

In the other direction, a reservation made on a channel arrives here as a range of dates against one apartment and a line of text the channel chose. It creates no guest record here and no payment record here.

Who else sees any of it

Three, and no more:

• Monobank, which processes the deposit, and which sees what is described above and nothing further.
• The company that hosts the server, and the off-site storage the database is copied to continuously so that a failed disk is not the end of your booking. Neither reads the data; both hold it.
• The Ukrainian authorities, where a hotel is required by law to keep and produce a register of who stayed and when.

Nothing is sold, nothing is passed on for advertising, and there is no mailing list — which is also why nothing here asks you to join one.

Why we are allowed to hold it

Your name, contact details, dates and payment record are held in order to perform the booking you asked for — Article 6(1)(b) of the GDPR. Without them there is no booking.

The guest register and the accounting record of a payment are held because Ukrainian hotel and tax law requires it — Article 6(1)(c).

Two records are held on legitimate interest, Article 6(1)(f): the staff audit log, which records which member of staff changed a rate, moved a date or cancelled a booking and when, and the server's access log. A hotel that cannot answer "who changed that, and when" cannot correct its own mistakes, and a server with no log cannot be defended.

How long we keep it

A booking record stays in place after the stay: it is the accounting record of a payment and part of the register the hotel has to be able to produce. A cancelled booking and an expired hold are marked as such rather than removed, so that the dates can still be reconciled afterwards. Nothing is deleted automatically.

Ask us to erase anything that the law does not require us to keep, and we will. Because the database is copied continuously to backup storage, an erasure works its way out of the backups as they roll over rather than the same second.

Your rights

Guests here are covered by two laws at once, and they give substantially the same rights: the EU General Data Protection Regulation, and Ukraine's Law on the Protection of Personal Data, because the hotel is in Kyiv. You may:

• Ask what we hold about you, and receive a copy of it.
• Have anything that is wrong corrected.
• Ask for it to be deleted. We delete everything except what the law requires us to keep, and we tell you what that was.
• Ask us to stop using it while a disagreement about it is settled.
• Receive the details you gave us in a form a machine can read.
• Object to anything held on legitimate interest — the audit log and the access log.
• Complain: in the EU, to the data protection authority of the country you live in; in Ukraine, to the Ukrainian Parliament Commissioner for Human Rights, who supervises personal data protection.

How to ask

Write to reservation@sherbornehotel.com.ua with your booking reference, or call +380 44 280 3315. A person reads both. We answer within thirty days and usually within the week, and there is no charge. We will ask you something only you and the booking would know, so that nobody can obtain your data by using your name.

Changes to this page

If this policy changes, the version published here is the one that applies. There is no notification list, because there is no mailing list.