Aimbridge Employee Privacy Notice

Last updated: 16 September 2024

Aimbridge Hospitality EMEA ("Aimbridge", "we" or "us") has issued this Employee Privacy Notice (“Notice”) to describe how we handle personal information that we hold about our staff together with staff employed by hotels that Aimbridge manage (collectively referred to as "you" or "Employees").

The term "Employee" or "staff" and all references to "employment" shall apply equally to all those who work on a non-permanent basis, including contingent workers, temporary and contract workers, independent contractors, consultants, professional advisors, secondees and interns. Note, (a) designation as a “Employee” under this Notice and/or for the purposes of any data protection laws is not, of itself, an indication of the existence of a contract of service or employment relationship for any other purpose or under any other law; and (b) nothing in this Notice shall be construed as forming part of the contractual relationship between us and you.

This Notice applies to all of Aimbridge's parent companies, entities, operating divisions, subsidiaries, affiliates, and branches and any additional subsidiary, affiliate or branch of Aimbridge that we may subsequently form insofar as they engage Employees in the EMEA region.

The controller(s) of your personal data detailed in this Notice depends on your relationship with us. If you are employed by an Aimbridge entity, then that entity will be the controller. If you are employed by a hotel owner (or agent) and an Aimbridge entity is the hotel management company for the hotel you are employed at, then the Aimbridge entity that is managing the hotel will be the controller.

If you work in the UK, the controller is Interstate United Kingdom Management Limited (and its subsidiaries).

If you work in the EU, the controller is the Aimbridge entity who employs you or where you are employed by a hotel owner (or agent) the Aimbridge entity that manages your hotel.

In addition, our other group entities may process your data as a controller in line with this Notice. Please note that Aimbridge is our brand name and your employing entity may have a different name.

Table of contents

  1. Introduction
  2. Personal data we collect and process
  3. How we use your personal data (our purposes) and our lawful basis for processing it
  4. Who we share your personal data with
  5. How we keep your personal data secure
  6. International data transfers
  7. Data retention
  8. Your data protection rights
  9. Updates to this Privacy Notice
  10. How to contact us

We recommend that you read this Notice in full to ensure you are completely informed about how we collect, process, share and protect your personal data. However, if you only want to access a particular section of this Notice, then you can click on the relevant link above to jump to that section.

1. Introduction

Aimbridge respect the privacy rights of individuals and are committed to handling personal data responsibly and in accordance with applicable law. This Notice sets out the personal data that we collect and process about you, the purposes of the processing and the rights that you have in connection with it.

If you are in any doubt regarding the applicable standards, or have any comments or questions about this Notice, then please contact us using the contact details under the “How to contact us” heading below.

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2. Personal data we collect and process

In the course of your work with Aimbridge or an Aimbridge managed hotel, we will process personal data about you and your dependents, beneficiaries and other individuals whose personal data has been provided to us.

Sources of personal data

We collect this personal data from the following different sources:

  • Information that you provide directly
    When your working relationship starts with us, the initial information about you that we process is likely to come from you directly: for example, contact details, bank details and information on your immigration status and whether you can lawfully work. We may also require references and information to carry out background checks.

    In the course of your work or engagement, you may be required to provide us with information for other purposes such as sick pay and family rights (e.g. maternity and paternity leave and pay). If you do not provide information that you are required by statute or contract to give us, you may lose benefits or we may decide not to engage you or to end your contract. If you have concerns about this in a particular context, you should speak to HR.
  • Information from third parties
    In the course of your work with us, we may receive personal data relating to you from others, including from recruitment agencies, referees, background checking agencies and other third parties. We may also receive personal data relating to you from your GP or other medical advisor, occupational health providers, pension administrators, customers or other organisations you routinely work with, external training and/or survey providers, personality testing providers, insurance brokers, insurers and their appointed agents (where they are involved), local tax authorities and payroll agents, workplace benefit providers, tax/financial advisers and hotel owners by whom you are employed (where applicable).
  • Information that we collect indirectly
    We collect your personal data indirectly, including through our company's IT systems and other devices as well as through CCTV on our premises or managed premises.
  • Information that we collect from publicly available sources
    We may collect information about you from news sources and/or social media platforms, for example in connection with any investigation or formal procedure concerning the same (for instance, for the investigation of an allegation that an employee has breached our rules on social media use or conduct generally).

Categories of personal data

The table below describes the categories of personal data we collect from and about you and your dependents, beneficiaries and other individuals as well as the source of that information.

Data Categories Personal Data Description Source
Identity Data Name or alias, gender, data or birth, passport number, driver’s licence number, social security number or other government-issued identification number, tax registration number and other details in and copies of identity documents. Directly from you
Contact Data Home and business address, personal and work telephone number, personal and work email addresses, emergency contact details (including emergency contact person and their telephone number). Directly from you
Work Data Job title/position, office location, employment contract, performance and disciplinary records, grievance procedures, sickness/holiday records, payroll number, clock in/out time, contracted hours, uniform items issued, if e-learning has been completed, accidents, leave (including parental and adoption leave), family rights and working days and hours. Directly from you; Third parties; Automatic collection
Pension Data National insurance number, date commenced scheme, earnings for the period, employee contributions and employer contributions. Directly from you
Background Data Age, date of birth, marital status, gender, pronouns, academic/professional qualifications, education, CV/résumé, and criminal records data (for vetting purposes, where permissible and in accordance with applicable law).

We will obtain references (verbal or written) for each Employee. We would expect you to provide us with the contact details / permission of who to contact. You can do this as part of the recruitment system (Recruit Genie platform). We may also receive the outcome of any criminal records checks that you apply for to assess your suitability for a role.
Directly from you; Third parties
Family Data Including information relating to your next-of-kin, spouse, partner, dependents and other family members (in particular, their names and dates of birth and details of entitlements under relevant benefit schemes). Directly from you
Payroll Data Banking details, tax information (such as tax registration number), withholdings, salary, benefits, expenses, company allowances, stock and equity grants. Directly from you; Third parties
Audio/Visual Data Photographs and other audio-visual information used for workplace initiatives and promotional materials. Directly from you; Third parties
Sensitive Personal Data As a general rule, we try not to collect or process any Sensitive Personal Information about you, unless authorised by law or where necessary to comply with applicable laws, or with your consent.

This includes information that reveals your racial or ethnic origin, religious, political or philosophical beliefs, genetic data, biometric data for the purposes of unique identification including facial and fingerprint data, trade union membership, information about your health (including mental health) and disability, vaccination status or sexual orientation and information regarding background and criminal record checks.
Directly from you; Third parties (from medical professionals)
Communication Data Contact details and content of communications when you communicate with us. Directly from you; Automatic collection
IT Data Information required to provide access to company IT systems and networks (and information collected by / through those systems) such as IP addresses, log files and login information. IT Data may also include other information about activities you engage in on Aimbridge property, equipment, accounts, systems and networks.

For more information, please see section 5 below How we keep your personal data secure.
Automatic collection
Security and Access Data Closed-circuit television (CCTV) footage in public or common areas in our premises and near our premises (such as in car parking areas and in which case footage may include vehicle licence plates). It may also include other information obtained through electronic means such as security records (e.g. swipe card records, building entry / exit data to which Aimbridge may from time to time have access). Automatic collection; Third parties (where used for CCTV, security and access systems)
Survey Data Answers to survey questions, date and time survey completed and IP address. Although this data will usually be aggregated, technically (even though we do not intend to look at this data), you may be identifiable from your IP address when completing a survey. Automatic collection; Directly from you

If you are a contingent worker, the type of personal information we process is limited to that needed to manage your particular work assignment with Aimbridge.

Please note that whilst we will always endeavour to respect your right to privacy in the workplace, our right to monitor your use of Ambridge IT systems limits expectation of privacy while at Ambridge's premises or using Ambridge equipment, information technology systems, networks, and electronic communication tools. Please also note that this Notice does not establish, and should not be construed to mean, that all Employees will have access to, or will participate in, the systems, networks, data, programs and other business activities described in this Notice.

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3. How we use your personal data (our purposes) and our lawful basis for processing it

We use the personal data that we collect from and about you for a variety of work-related purposes described in this Notice or for purposes that we explain to you at the time we collect your information.

Purposes and lawful basis for processing personal data

The following table provides more details on our purposes for processing your personal data and the related legal bases. The legal basis under which your personal data is processed will depend on the data concerned and the specific context in which we use it.

Purpose/Activity Type of personal data Lawful basis (see lawful basis descriptions below)
Administering your contract including entering it, performing it and changing it Identity Data; Contact Data; Work Data; Communications Data
Including information on your terms of employment or engagement, your pay and benefits, your participation in pension arrangements, life and medical insurance and any bonus or share scheme.
Performance of a contract with you; Legal obligation; Legitimate interests
Contacting you or others on your behalf Identity Data; Contact Data; Communications Data; Spouse and Dependent data Performance of a contract with you; Legitimate interests
Managing your hours and payroll administration Identity Data; Contact Data; Payroll Data; Sensitive Personal Data (specifically biometric data where you choose to use this option for logging your hours via the clocking-in device)
Including your bank account details, salary, pension contributions and details of other benefits, and information on tax and social security / national insurance, information on attendance, holiday and other leave and sickness absence.
Performance of a contract with you; Legal obligation; Legitimate interests; In some cases, consent
In relation to Sensitive Personal Data: with your consent.
Supporting and managing your work and performance and any health concerns Work Data; Sensitive Personal Data (specifically health data); IT Data
Including information connected with your work, anything you do at work and your performance including records of documents and emails created by or relating to you and information on your use of our systems including computers, laptops or other devices. Management information regarding you including notes of meetings and appraisal / performance records. Information relating to your compliance with our policies. Information concerning disciplinary allegations, investigations and processes and relating to grievances in which you are or may be directly or indirectly involved. To the extent required or permitted by local law, information concerning your health, including self-certification forms, medical and occupational health reports.
Performance of a contract with you; Legal obligation; Legitimate interests
In relation to Sensitive Personal Data: Employment obligations, Occupational health and working capacity, or in limited cases, Consent.
Arranging internal and external training for Employees Identity Data; Work Data
We will set you up using your personal data by manually entering your personal data into our payroll learning management system so that we can provide you with training.
Legitimate interests
Accounting and financial planning Identity Data; Payroll Data Legitimate interests; Legal obligations
Changing or ending your working arrangements Identity Data; Contact Data; Work Data
Including information connected with anything that may affect your continuing employment or the terms on which you work including any proposal to promote you, to change your pay or benefits, to change your working arrangements or to end your employment.
Performance of a contract with you; Legitimate interests
Physical and system security Security and Access Data; IT Data
Including CCTV images and records of use of swipe and similar entry cards / systems. To the extent required or permitted by local law, records of your use of our systems including computers, phones and other devices and passwords. In some premises, where selected by the individual, we use facial recognition or fingerprints to log in and out on our time and attendance devices and fingerprint scanning for till access. This biometric data is Sensitive Personal Data.
Legitimate interests; Legal obligations; In some cases, consent
In relation to Sensitive Personal Data: with your consent.
Providing information to third parties in connection with transactions that we contemplate or carry out Work Data
Including information on your contract and other work data that may be required by a party to a transaction such as a prospective purchaser, seller or provider of outsourced services.
Legitimate interests
Monitoring of diversity and equal opportunities Background Data; Sensitive Personal Data
Specifically, to the extent required or permitted by local law, information on your nationality, racial and ethnic origin, gender, sexual orientation, religion, disability, age and other diversity markers.
To the extent we are required to collect this data under applicable law, in compliance with our legal obligation; where collection is not required by law, in our legitimate interests or in limited cases with your consent.
In relation to Sensitive Personal Data: Employment obligations, Consent, or substantial public interest.
Monitoring and investigating compliance with law, regulations, policies, codes of practice and rules both generally and specifically Contact Data; Work Data; Background Data; Ethics Reporting Data; IT Data; Security and Access Data; Payroll Data; Communications Data; Sensitive Personal Data
We expect our Employees to comply with our policies and rules and monitor our systems to check compliance. If we have specific concerns about compliance, we may check systems and other data to look into those concerns (e.g. log in records, records of usage and emails and documents, CCTV images). We may from time to time conduct investigations if we receive any report of non-compliance with the law and regulations or with our codes of practice, policies and rules.
Legitimate interests; Legal obligation
In relation to Sensitive Personal Data: Employment obligations, Legal Claims, or in limited cases substantial public interest.
Disputes and legal proceedings Contact Data; Work Data; Payroll Data; IT Data; Communications Data; Sensitive Personal Data
Any other information relevant or potentially relevant to a dispute or legal proceeding affecting us.
Legitimate interests; Legal obligation
In relation to Sensitive Personal Data: Legal Claims.
Day to day business operations including marketing and customer relations Identity Data (name); Contact Data; Work Data; Audio/Visual Data
Specifically, information used on global or local internal or external directories to identify what you do and how you can be contacted (to enable collaboration with Employees and others) and specifically to maintain our global directory of Employees. Any other information relating to the work you do for us, your role and contact details including relations with current or potential customers or clients. This may include a picture of you for internal or external use.
Legitimate interests
Carrying out surveys on our Employees Survey Data
Every year, Aimbridge will invite Employees to take part in an engagement survey via a third-party provider. We will typically aggregate survey responses and do not require details of specific persons responding. However, if you are completing a survey electronically even if no direct identifying information is provided, you technically might be identifiable from your IP address. We are only interested in looking at the aggregated information and not any information linking individuals to survey responses.
Legitimate interests
Maintaining appropriate business records during and after your work or engagement with us Work Data
Other information relating to your work, anything you do at work and your performance relevant to such records.
Contract; Legal obligation; Legitimate interests
Emergency medical treatment Family Data; Health Data
Any other information required to notify your close contact(s) of any incident at or in connection with work and to allow responsible people to administer emergency medical treatment.
Vital interests
Acquisitions, divestitures and integrations; restructuring and relocation Contact Data; Work Data; Background Data; Ethics Reporting Data; IT Data; Security and Access Data; Payroll Data; Communications Data; Sensitive Personal Data
Information will be processed and potentially shared with a third party (such as a purchaser of the business) relating to your role - as relevant to the particular context.
Legitimate interests
In relation to Sensitive Personal Data: Employment obligations, or in limited cases Consent.
Sharing information in our social media groups e.g. on Facebook and LinkedIn Identity Data; Audio/Visual Data Legitimate interests; Or, with your consent.
Employee monitoring Identity Data; Work Data; Sensitive Personal Data; Communication Data; IT Data; Security and Access Data Legitimate interests
In relation to Sensitive Personal Data: Consent.

Lawful basis for processing descriptions

Depending on our purpose for collecting your information, we rely on one of the lawful bases described in the table below (i.e. legally permitted reasons under GDPR/UK GDPR).

Lawful basis Description
Contract We require certain personal data to carry out our contractual duties and exercise our contractual rights as an employer.
Consent In certain circumstances, we may ask for your consent (separately from any contract between us) before we collect, use, or disclose your personal data, in which case you can voluntarily choose to give or deny your consent without any negative consequences to you. In general, processing of your data in connection with your work or engagement with Aimbridge will not be conditional on your consent. But there may be occasions where we do specific things such as providing a one-off voluntary benefit and rely on your consent to our doing so.
Legitimate interests We may use or disclose your personal data for the legitimate interests of either Aimbridge or a third party, but only when we are confident that your privacy rights will remain appropriately protected. If we rely on our (or a third party's) legitimate interests, these interests will normally be to: operate, manage, administer our respective businesses effectively and properly. Where we require your data to pursue our legitimate interests or the legitimate interests of a third party, it will be in a way which is reasonable for you to expect as part of the running of our business / organisation and which does not materially affect your rights and freedoms.
Legal obligation To comply with laws or to fulfil certain legal obligations. For example, providing a safe place of work.
Public interest There may be instances where processing your data is necessary to perform a specific task in the public interest. In general, processing of your data will not be processed on this ground, but there may be some limited instances, for example prevention and detection of crime, or for diversity and inclusiveness monitoring purposes. Processing of sensitive personal data would only be carried out if it were in the substantial public interest.
Vital interests Although unlikely, it may be necessary to process your data (including Sensitive Personal Data such as health data) to protect someone’s life. In general, we will not process your data on this ground but there may be rare occasions when we need to do so, for example, if we need to process personal data to save your life and administer emergency medical treatment.
Employment obligations Processing of your data where necessary for the purposes of your or our legal obligations and rights in relation to employment such as avoiding unlawful discrimination.
Legal claims To establish, make or defend legal claims.
Public health To protect against serious cross-border threats to health.
Occupational health and working capacity To provide occupational health and to assess working capacity.

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4. Who we share your personal data with

We take care to allow access to personal data only to those who require such access to perform their tasks and duties, and to third parties who have a legitimate purpose for accessing it. Whenever we permit a third party to access personal data, we will implement appropriate measures to ensure the information is used in a manner consistent with this Notice and that the security and confidentiality of the information is maintained.

We share your personal data with the following categories of recipients:

  • our group companies who operate in the UK, Europe and around the world in order to administer human resources, Employee compensation and benefits at an international level on our HR system, as well as for other legitimate business purposes such as IT services/security, tax and accounting, and general business management;
  • third party service providers and partners on a "need to know basis" and in accordance with applicable data privacy law, we make certain personal information available to third parties who provide services to us, if it is necessary for our legitimate interests as an organisation or the interests of a third party (but we will not do this if these interests are over-ridden by your interests and rights in particular to privacy). We may also disclose your personal data if you consent, where we are legally required to disclose, and/or in connection with criminal or regulatory investigations. Specific examples of such third parties and the circumstances in which your personal data may be disclosed to them are set out in the table below.
  • Your employer to the extent that you are employed by a hotel managed by Aimbridge.
  • any competent law enforcement body, regulatory, government agency, court or other third party (such as our professional advisers) where we believe disclosure is necessary (i) as a matter of applicable law or regulation (e.g. to provide certain salary information to tax authorities), (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person;
  • a buyer (and its agents and advisers) in connection with any actual or proposed purchase, merger or acquisition of any part of our business as permitted by law and/or contract, provided that we inform the buyer it must use your personal data only for the purposes disclosed in this Notice;
  • any other person with your consent to the disclosure (obtained separately from any contract between us).

Our key service providers are listed in the table below:

Service Providers Services Personal data
Recruit Genie
McQuaig
Insights Discovery
Applicant tracking system and psychometric testing systems. Identity Data; Contact Data; Background Data
Workplace Pension
Personal Pension
Personal schemes
Group Insurance policies including healthcare, life, travel.
Benefit plan service providers (including pension and medical insurance providers) Contact Data; Identity Data; Family Data; Sensitive Personal Data (such as health data); Background Data (such as gender, age, and month and day of birth)
Concur Expense administration support services Contact Data; Identity Data; Payroll Data
Various IT services Providers of IT and communications infrastructure (including for data storage purposes) and/or provide business continuity services Contact Data; Identity Data; IT Data; Work Data; Background Data; Family Data; Payroll Data; Audio/Visual Data; Sensitive Personal Data; Communication Data
Various T&A service providers Providers of devices and services for tracking time and attendance metrics. Contact Data; Identity Data; Work Data; Sensitive Personal Data; Audio/Visual Data; IT Data; Security and Access Data
Corporate traveller Travel and/or travel permit co-ordinators / services (in connection with work-related travel) Contact Data; Identity Data; Family Data; Sensitive Personal Data (such as allergies, disabilities and vaccination status)
Litmos E-learning platform Contact Data; Work Data (such as learning and performance records); IT Data; Communication Data
Qualtrics Employee engagement survey services Contact Data; Identity Data; Communication Data
Worknest Auditors, advisors, legal representatives and similar agents in connection with the advisory services they provide to us for legitimate business purposes Contact Data; Identity Data; Work Data; Background Data; Family Data; Payroll Data; Audio/Visual Data; Sensitive Personal Data; Communication Data
Health Assured
AXA
Employee Assistance programme with access to Occupational health services Contact Data; Identity Data; Work Data; Sensitive Personal Data

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5. How we keep your personal data secure

We use appropriate technical and organisational measures to protect the personal data that we collect and process about you. The measures are designed to provide a level of security appropriate to the risk of processing. Specific measures we use include encrypting your personal data in transit and at rest; using an industry standard framework as part of any Information Security programme; employing advance malware protections; implementation of other reasonable security defences (including vulnerability management, access management and recovery/resilience measures).

Aimbridge will carry out automated monitoring of its IT and communications systems through automated tools such as anti-malware software, website filtering and spam filtering. It will also carry out monitoring of its physical premises, for example by using CCTV and badge scans.

The primary purpose of this monitoring is to protect Aimbridge, Employees, customers and business partners, for example:

  • for general network operation and security, including in particular the security of Aimbridge's IT systems and assets, and the optimal operation of its network and devices;
  • for proof of business transactions and archiving;
  • for the protection of confidential information and intellectual property;
  • for investigating breaches of internal policies, fraud or other unlawful or wrongful activity, or to respond to a particular personnel or company incident;
  • for business continuity (such as monitoring business-related emails following an Employee's departure); and
  • for physical security of its premises.

We will also monitor through the use of a time and attendance machine when you arrive to and leave work. The purpose of this is to accurately capture your hours of work when you clock in and out. You can select the method by which you do this. We also use similar log in systems for access control purposes, such as to activate access to tills in the hotel bar area.

Monitoring activities are likely to be continuous and ongoing. However, they will always be proportionate, for legitimate purposes and as required or permitted by applicable law. Before undertaking any monitoring activities, we will consider your reasonable expectations of privacy and assess whether there are any less invasive options.

You should be aware that any message, files, data, document, facsimile, telephone conversations, social media post or instant message communications, or any other types of information transmitted to or from, received or printed from, or created, stored or recorded on our IT and communications systems and assets are presumed to be business-related and may be monitored by us in accordance with applicable law.

You must clearly identify private emails and messages by adding the term "private & confidential" in the email or message's subject line, and/or storing those emails/messages/files in a separate folder marked "private & confidential". Where we must access content that is clearly identifiable as being private, we will do so only if there is a particular risk or threat to the company, or person, or we have been legally authorised to do so, for example by a court order.

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6. International data transfers

As we operate at a global level, and our parent company is based in the US, in some cases, where your personal data is transferred to another Aimbridge Group company or third party, it is processed in countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country (and, in some cases, may not be as protective).

Where we transfer your personal data to countries and territories outside of the European Economic Area and the UK, we will take appropriate safeguards to ensure that your personal data will remain protected in accordance with this Privacy Notice and applicable data protection laws.

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7. Data retention

We retain the personal data we collect from you where we have an ongoing legitimate business need to do so (for example, to comply with applicable legal, tax or accounting requirements).

For Employees who leave Aimbridge or the hotel managed by Aimbridge, we will hold their personal data for up to 7 years after their termination date.

We may retain your personal information for longer than the period specified above to respond to work-related inquiries or to deal with any legal matters (e.g., judicial or disciplinary actions), document the proper termination of your employment or work relationship (e.g., to tax authorities), or to provide you with ongoing pensions or other benefits.

Details of retention periods for different aspects of your personal data not specified above are available from us on request by contacting us using the contact details provided under the “How to contact us” heading below.

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8. Your data protection rights

Individuals located in the UK and EEA have the following data protection rights. To exercise any of them see specific instructions below or contact us using the contact details provided under the “How to contact us” heading below.

  • You may access, correct, update or request deletion of your personal data.
  • You can object to processing of your personal data, ask us to restrict processing of your personal data or request portability of your personal data, (i.e. your data to be transferred in a readable and standardised format.
  • If we have collected and processed your personal data with your consent, then you can withdraw your consent at any time by using the contact details provided under the “How to contact us” heading below. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal data conducted in reliance on lawful processing grounds other than consent.
  • You have the right to complain to a supervisory authority about our collection and use of your personal data. For more information, please contact your local supervisory authority. Contact details for supervisory authorities in Europe are available here and for the UK here. Certain supervisory authorities may require that you exhaust our own internal complaints process before looking into your complaint.

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

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9. Updates to this Privacy Notice

We may update this Notice from time to time in response to changing legal, regulatory, technical or business developments. When we update our Notice, we will inform you via a company-wide email and indicate at the top of the Notice when it was most recently updated. We encourage you to check back at this website periodically in order to be aware of the most recent version of this Notice.

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10. How to contact us

If you have any questions or concerns about our use of your personal data, please contact us using the following details: privacy.EMEA@aimbridge.com or alternatively, you can raise any concerns with your line manager, or local HR representative.

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