Privacy Policy

  1. PRIVACY POLICY Alternative Hospitality (Sinful House) also referred as AH(SH) takes the privacy of your Personal Data and other information very seriously.This Privacy Policy details Alternative Hospitality (Sinful House) policies with respect to the handling of personally identifiable information (“Personal Information”) submitted to or otherwise collected by Alternative Hospitality (Sinful House) based websites.

    Please read this Privacy Policy as it includes important information regarding your Personal Data and other information.

    Quick Summary
    The following provides a quick overview and index to this Privacy Policy.  You must read the detailed sections below the summary for the complete definition of the policy.

    1. Alternative Hospitality (Sinful House) and the Site Owner – Privacy is managed by Alternative Hospitality (Sinful House) and the Site Owner (contacted via this website). We may change this policy periodically. Check it regularly. If you do not agree, do not use the service.
    2. General Provisions – We will not sell or share your information to anyone except in the case of that the entire business is sold to another party. AH(SH) and the Site Owner make best efforts to enforce this Privacy Policy.
    3. Personal Information We Collect – see below for details.
    4. Credit Card Processing Data Security – We never see or store your credit card data. see below for details.
    5. Use of Cookies – We make limited use of cookies, mainly to manage your login. You may disallow cookies but then you can’t use the service.
    6. Use of Password – We can’t see your password.  It’s up to you to keep it secure.
    7. Posted Information – Some of your information is visible to other logged in users in so-called “public areas”. It’s your responsibility to not post private information to public areas.  AH(SH) and SIte Owner administrators can see all information you post.
    8. Updating and Correcting your information – all information your post can be updated by you either by yourself on your “edit profile” and “edit account” page, or on request to the Site Owner.
    9. Automatic collection of information –  Some information about your computer and network, such as IP address and type of computer and browser is collected automatically.
    10. Our use of your information – We use your information as required to run the AH(SH) service and to contact you when necessary. You can unsubscribe from marketing messages by clicking “Unsubscribe”.
    11. Retention of your personal information – We may retain some limited personal information for up to 180 days after you discontinue use of the AH(SH) service and delete your profile in order to resolve any possible credit card disputes, and to the performance of a task carried out in the public interest or in the exercise of official authority.
    12. Data Protection Officer – can be reached at [email protected] or through the Contact Us link on this website
    13. European Union Data Rights – AH(SH) and the Site Owner enforce and conform to the EU General Data Protection Regulation (GDPR) for EU citizens

    1. Alternative Hospitality (Sinful House) Limited
    1.0) Sinful House is an online service for managing events, memberships, member profiles, mass mailing, and websites, provided by Alternative Hospitality (Sinful House) Limited (AH(SH)), a Thai based Limited Liability Company (LC).

    1.1) Alternative Hospitality (Sinful House) provides the AH(SH) Service to the owners/operators of various websites (Site Owners). As such, your data privacy is managed both by Alternative Hospitality (Sinful House) and the Site Owner. Site Owners have agreed to terms and conditions that bind them to this PRIVACY POLICY while indemnifying Alternative Hospitality (Sinful House) against any deviations from this policy on their part.

    1.2) If you do not agree with this PRIVACY POLICY, you may not access or use the AH(SH) Service.  Each time you visit the AH(SH) Service or provide us with information, by doing so you are accepting the practices described in this PRIVACY POLICY.

    1.3) Please review this PRIVACY POLICY periodically as we may modify it from time to time. We reserve the right to modify this PRIVACY POLICY at any time, and we will notify you of any material changes to the Policy by posting the new Policy here. We encourage you to check this page periodically for any changes to the AH(SH) PRIVACY POLICY. Such changes and/or modifications shall become effective immediately upon posting thereof.

    1. General Provisions
      2.1) We are committed to maintaining the security of your information and have reasonable measures in place to protect against the loss, misuse and alteration of the information you provide, which is under our control. This PRIVACY POLICY is meant to ensure that all current and future information collected from our users is secure and we use best practices to protect our systems. While ‘perfect security’ does not exist on the Internet, our technical experts work hard to ensure your secure use of our services.

      While we make diligent effort to ensure the integrity and security of our network and systems, and as effective as these measures are, no security system is impenetrable. We cannot guarantee the security of our database, nor can we guarantee that the information you supply will not be intercepted while being transmitted to us over the internet. You assume the risk of such breaches to the extent that they occur despite our reasonable security measures;

      2.2) While this PRIVACY POLICY states our high standards for maintenance of Data and we will make efforts to meet them, we are not in a position to guarantee these standards. There may be factors beyond our control that may result in disclosure of data. As a consequence, we disclaim any warranties or representations relating to maintenance or nondisclosure of Data;

      2.3.1) This PRIVACY POLICY applies only to transactions and activities in which you engage, and data gathered, on the AH(SH) Service; This PRIVACY POLICY does not apply to other entities that we do not own or control or persons that are not our employees, agents or within our control;

      2.3.2) Your member profile information is stored securely. Some information is visible to other members of your AH(SH) hosted website while other information is visible to site administrators only. Personal Information you provide to us that is not for display on your Profile, such as your real name, full address, email address, will be kept strictly private, visible only to site administrators and door check-in staff as required. Alternative Hospitality (Sinful House) and the Site Owner does not sell, lease, or disclose any Personally Identifiable Information, and holds this information in the strictest privacy to be used only in the intent that it was disclosed.

      2.4) Alternative Hospitality (Sinful House) and the Site Owner may use Personal Information to customize and improve your user experience on the AH(SH) Service. We will make all reasonable efforts to NOT provide your Data to third parties unless

    • provided for otherwise in this PRIVACY POLICY;
    • we obtain your consent, such as when you choose to opt-in or opt-out to the sharing of Data;
    • a service provided on our site requires the interaction with or is provided by a third party, by way of example an Application Service Provider;
    • To comply with law or other legal obligations such as responding to subpoenas, or other requests from public and government agencies, including laws and other legal obligations outside a party’s country of residence
    • we find that your use of this AH(SH) Service violates our this PRIVACY POLICY, TERMS OF SERVICE, or other usage guidelines or as deemed reasonably necessary by us to protect our legal rights and/or property; or
    • As necessary to perform the AH(SH) Service and to complete payment transactions
    • With companies and vendors that help us to operate our business by providing services such as website hosting, fraud screening, data analysis, information technology and related infrastructure provision, customer service, email delivery, auditing and other similar services
    • To protect our rights, operations or property, or that of our users
    • To investigate, prevent, or take action regarding potential or suspected illegal activities, fraud, threats to the personal safety of any person, or violations of the AH(SH) Service terms and conditions
    • With a purchaser of all or a unit of either Alternative Hospitality (Sinful House) or the Site Owner (or the majority of either or its unit’s assets), a merger, acquisition, or internal reorganization of Alternative Hospitality (Sinful House) or the Site Owner, in which case that third party will be able to use the Data in the same manner as Alternative Hospitality (Sinful House) or the Site Owner can as set forth in this PRIVACY POLICY;
    1. Personal Information We Collect
      3.1) Personal Information you give us that is not for display on your Profile, such as your real name, full address, email address, will be kept strictly private, visible only to site administrators and door check-in staff as required. Whenever we ask for such information we make it clear on the website that it is not for display. Alternative Hospitality (Sinful House) does not sell, lease, or disclose any Personally Identifiable Information, and holds this information in the strictest privacy to be used only in the intent that it was disclosed.

      The AH(SH) Service and the Site Owner collects personal information for the following purposes:

    • Event Ticket and Membership Purchase transactions
    • Membership Application / Member Profile creation
    • Online Membership Agreements

    3.2) Event Ticket and Membership Purchase transactions may collect the following information:

    • First and Last Name
    • Other guest first and last names
    • Email Address
    • Phone Number
    • Credit Card Information (card name, card number, security code, billing address)
    • Configurable extra required attributes such as website screen name – the Site Owner may configure additional attributes they wish to collect, all of which shall be subject to this PRIVACY POLICY

    3.3) Membership Application / Member Profile may collect the following information:

    • First and Last name (visible only to site administrators and door checkin staff)
    • Screen name (visible to other members)
    • City, State, Postal Code, Country
    • Phone Number / Cell Carrier
    • Other Websites and Screen Names
    • ID Number (sometimes required – configurable by site owners)
    • Birthday (sometimes required – configurable by site owner)
    • Configurable extra required attributes such as website screen name – the Site Owner may configure additional attributes they wish to collect, all of which shall be subject to this PRIVACY POLICY

    3.4) Online Membership Agreements may collect the following information:

    • Email Address
    • Phone Number
    • First and Last Name(s)
    • ID Number(s)
    • Birthdays
    1. Credit Card Transaction Data Security
      4.1) All information sent and received using SSL Encryption All information entered into AH(SH) Service pages is protected by SSL encryption, including credit card information. All information is encrypted before being sent to AH(SH) Servers so that if a third party intercepts the internet traffic, they cannot decrypt the information.

      4.2) The AH(SH) Service never receives or stores your credit card information, but optionally saves your card information in a third party secure repository –  For online payments (Card Not Present transactions), the AH(SH) Service provides an option to save your card information.  Whether you choose this option or not, your card information is never sent to AH(SH) servers, nor is it ever stored in any AH(SH) database.

      The AH(SH) Service handles prepay (card not present) credit card transactions as follows:

    • You enter your card information on a payment form.
    • The payment form sends your card information by SSL to Authorize.net directly and exchanges it for a Single Use Token (SOT) which expires in 15 minutes.
    • The payment form then posts the transaction to AH(SH) servers including the SOT which is a pointer to your card information on file at Authorize.net
    • The AH(SH) server then performs various validations and sends the transaction securely to Authorize.net for authorization along with the SOT
    • net authorizes the payment using the card info that it has on file for that SOT
    • Even if someone were to intercept the SOT, they would need further secret keys to use it, and it expires in 15 minutes anyway.  This is a very secure, state of the art security scheme.
    • If you chose the option to Save Card Info, AH(SH) instructs Authorize.net to set up a customer payment profile in the Authorize.net Customer Information Manager.  Then the AH(SH) Service saves the ID of your payment profile in it’s own database with your customer record. This way, in the future when you go to a Checkout page, you get an option to pay with your saved card, even though no AH(SH) server has ever received or saved your card information in it’s own database.  Your card information is stored securely in the Auhorize.net Customer Information Manager.

    4.3) Card Present (a.k.a card swipes or chip card read) transactions never pass your card information to AH(SH) Servers 
    The AH(SH) Service handles Card Present transactions as follows:

    • Door checkin staff requests a payment from the payment device (chip card reader) using an internet request.
    • The card reader receives the request and lights up requesting payment of a certain amount
    • When the card is inserted or swiped, the payment device sends the transaction by SSL (encrypted) to the payment gateway servers directly.  The encrypted card information is never sent to AH(SH) Servers.
    • The AH(SH) Servers poll the payment gateway for transaction status.  If approved, AH(SH) saves a record of the payment along with the card type and last four digits of the card number.
    • AH(SH) Servers never receive or store your card information.

    4.4) PayPal Transactions redirect to PayPal.com for payment –  AH(SH) Servers never receive or store your credit card information (except for card type and last four digits.)  Payments are handled from PayPal web pages.

    4.5) Third Party Payment Gateways and Payment Processors
    Information forwarded to third party payment gateways including but not restricted Authorize.net, Paypal, RocketGate, PaySafe, and UsaEpay, as well as payment processors is limited to credit card information (including Name, Email, card number, expiration, security code and billing address) that is necessary to authorize payment and optionally to store card information on file for future use. You may visit the website of the gateway provider to understand their privacy and data retention policy.

    5. Use of Cookies
    We may cookies to identify traffic that comes through advertising and to facilitate a more user friendly experience. A cookie is a tiny data file that resides on your computer allowing AH(SH) to recognize you as a member when you return to our site using the same computer and web browser. This helps us to create a personalized experience for you when you visit our site. The use of cookies is a very common practice on the Internet. One of the primary purposes of cookies is to provide a convenience feature to save you time. This saves you time from typing in your user name and password each time you visit us. You have the ability to accept or decline cookies. Most Web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer;

    The AH(SH) Service makes the following very limited use of cookies:

    • Session Cookie – allows your browser to tell the AH(SH) Servers which session you have
    • Keep Me Logged In Cookie – allows your browser to stay logged in for up to two weeks
    • Google Analytics Cookie – created and controlled by Google Analytics for web traffic analysis
    • Facebook Login cookie – created by logging into FaceBook and optionally using your FB login for the AH(SH) Service

    You have the ability to accept or decline cookies. Most Web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you decline cookies, you will not be able to use the AH(SH) Service as a logged in member.

    6. Control Of Your Password
    6.1) By logging into the AH(SH) Service, you have full access to your personal information. As such, your personal information is secured by your password which is created by you. Your password is under your control. Neither Alternative Hospitality (Sinful House) nor Site Owners or their staff can access or retrieve your password. Do not share your password with anyone. It is your responsibility to keep your password confidential, and AH(SH) cannot be held liable for any loss or misuse of your password;

    6.2) You may not disclose your password to any third parties or share it with any third parties. If, despite the foregoing, you lose control of your password, you may lose substantial control over your personally identifiable information and may be subject to legally binding actions taken on your behalf. Therefore, if your password has been compromised for any reason, you should immediately change your password;

    6.3) We strongly urge you to periodically change your password to help reduce the risk of unauthorized access to your account information;

    6.4) If you forget your password, please use the Forgot Password link to generate a new password for you and send it by email. The AH(SH) Service will generate a random six digit password. You must reset that immediately after using it to login.

    7. Posted Information
    7.1) Logged-In Member Areas (Member Areas) – The AH(SH) Service allows you to post information that can be viewed by other logged-in members of the site. Personally Identifying Information such as real names, ID’s, birthdays, email address, and phone number are visible only to AH(SH) staff, Site Owners, and Site Owner’s authorized staff.  Other non-identifying information you post is generally visible to other logged in members.

    7.2) AH(SH) and the Site Owner have no control over the use of Personal Data that you voluntarily post in Member Areas of the Site, such as photos, comments and discussion boards (collectively, “Unsolicited Information”). All such Unsolicited Information shall be deemed to be non-confidential. You should be aware that if you voluntarily disclose Unsolicited Information online, that Unsolicited Information can be collected and used by others. For example, if you post your email address in comments sections or online forums, you may receive unsolicited messages from others;

    7.3) Alternative Hospitality (Sinful House) and the Site Owner reserve the right, in its sole discretion, to reject, refuse to post or remove any posting or communication (including email) by you, or to restrict, suspend, or terminate your access to all or any part of the AH(SH) at any time, for any or no reason, with or without prior notice, and without liability;

    7.4) We cannot control the actions of other users with whom you may choose to share your pages and information. Therefore, we cannot and do not guarantee that information and content you post on AH(SH) will not be viewed by unauthorized persons. We are not responsible for circumvention of any privacy settings or security measures of the AH(SH) Service. You understand and acknowledge that, even after removal, copies of your content may remain viewable in cached and archived pages or if other users have copied or stored your content;

    To learn more about social networking safety tips, visit the links below:
    http://onguardonline.gov/socialnetworking.htAH(SH)
    http://onguardonline.gov/socialnetworking_youth.htAH(SH)

    8. Updating/Correcting Personal Information
    8.1) You may correct or update your personal information by editing your profile information on the AH(SH) Service, or in some cases by requesting the Site Owner to update your information.

    8.2) Even if you update or remove your information from our live database, your personal data may be retained in backup files and archives.

    8.3) If you remove your profile, a summary version of your contact information is retained in order to contact you if necessary. If you wish for this information to also be removed, you may request that the Site Owner do so and they will comply to the extent possible.  Note that some data such as customer order history, including credit card transaction history, may not be removable for an extended period as it serves necessary business purposes such as responding to Chargebacks or refund requests.

    8.4) If for any reason you cannot log into the AH(SH) Service to view or correct your Personal Information, you may request access or a correction by sending an email request to AH(SH) at [email protected]. Please note, that consistent with local law, Alternative Hospitality (Sinful House) may retain Personal Information for auditing purposes, to troubleshoot problems, assist with investigations, enforce our policies or comply with legal requirements.

    9. Automatic Collection of Information
    9.1) We automatically collect certain information about your computer hardware and software. This information may include: your IP address, browser type, domain names, access times and referring Web site addresses. This information is used by AH(SH) for the operation of the service, to maintain quality of the service, and to provide help regarding use of AH(SH)’s sites;

    9.2) Like most websites, when you visit AH(SH) we automatically receive the URL of the site from which you came and the site to which you are going when you leave AH(SH). We also receive the Internet protocol (IP) address of your computer (or the proxy server you use to access the World Wide Web), your computer operating system and type of web browser you are using, as well as the name of your ISP. This information is used to analyze overall trends, gather broad demographic information for aggregate use, to help us improve the service, but is not linked to personally identifiable information;

    9.4) AH(SH) Web pages may contain action tags (also known as single pixel gifs or web beacons), to collect web site traffic data such as; cookie number, time and date of a page view and a description of the page on which the web beacon resides. We may use third-party advertising companies to serve ads on our behalf. These companies may employ cookies and action tags to measure advertising effectiveness, allow us to count visitors and deliver co-branded services;

    10. Our Use of Your Information
    11.1) AH(SH) may internally use personally identifiable information of our users to improve our marketing efforts, to statistically analyze site usage, to improve our content and product offerings as well as to customize our site’s content and layout. We believe these uses allow us to improve our site and better tailor your online experience to meet your needs;

    10.2) We may also use your email address to deliver information to you information that, in some cases, are targeted to your interests, such as targeted banners and promotions;

    10.3) AH(SH) or the Site Owner may also send periodic informational updates to members via email.  You may unsubscribe from any marketing messages easily by clicking the “Unsubscribe” link.

    10.4) We use personally identifiable information to resolve disputes, troubleshoot problems and enforce our AH(SH) MEMBERSHIP TERMS OF SERVICE;

    10.5) AH(SH) and the Site Owner may use your Personal Information, including email address and phone number, to reach you in order resolve credit card transaction disputes as well as any other customer support issues.

    11. Retention of Your  Personal Information
    11.1) We keep the information you have given us for as long as you are a member on an AH(SH) Service hosted website and beyond, unless you request that we delete that information. If you request that your information be deleted, we may still retain information necessary to resolve credit card transaction disputes for up to 180 days after your last credit card transaction. If you ever file a chargeback, we may retain certain personal address for up to 3 years in order to handle any possible further downstream activity around your chargeback.

    12. Data Protection Officer
    Please contact the AH(SH) Service’s Data Protection Officer for any questions related to our Privacy Policy by emailing [email protected], or by contacting the Site Owner through the Contact link on the help page of this website or other communication methods set out on this website.

    13. European Union User Rights
    European Union (EU) residents have the following statutory rights in relation to their personal data.

    13.1) The rights to data subject access include the following:
    • Know whether a third party holds any personal data about them.
    • Receive a description of the data held about them and a copy of the data.
    • Be informed of the purpose(s) for which that data is being processed, and from where it was received.
    • Be informed whether the information is being disclosed to anyone apart from the original recipient of the data; and if so, the identity of those recipients.
    • The right of data portability. Data subjects can ask that their personal data be transferred to them or a third party in machine readable format (Word, PDF, etc.). However, such requests can only be fulfilled if the data in question is: 1) provided by the data subject to the AH(SH) Service, 2) is processed automatically and 3) is processed based on consent or fulfillment of a contract.
    • If the data is being used to make automated decisions about the data subject, to be told what logic the system uses to make those decisions and to be able to request human intervention.

    The AH(SH) Service must provide a response to data subjects requesting access to their data within 30 calendar days of receiving the Data Subject Access Request unless local legislation dictates otherwise. Please contact the AH(SH) Service’s Data Protection Officer for assistance at [email protected] or through the Site Owner at the Contact Site Owner button on the Help Page of this website. In order to establish the correct User identity, the AH(SH) Service may require the User to provide official government issued proof of identity or require a secondary digital validation.

    You have the following choices to modify or delete your personal information from our database:
    Log in and modify or delete your profile

    Send an email to [email protected] or the Site Owner from the Help Page of this website for assistance.

    In the event that AH(SH) becomes aware that site security is compromised or nonpublic user information has been disclosed to unrelated third parties as a result of external activity, including but not limited to external security attacks, AH(SH) shall take reasonable measures which it deems appropriate, including but not limited to internal investigation and reporting, and notification to and cooperation with law enforcement authorities, notwithstanding other provisions of this Privacy Statement. If you become aware of such a breach, please fill in the appropriate form on the website, or email [email protected] or contact the Site Owner on the Help Page of this website to create an emergency support ticket. If AH(SH) becomes aware that a user’s personal information provided to AH(SH) has been disclosed in a manner not in accordance with this Privacy Statement, AH(SH) shall make reasonable efforts to notify the affected user, as soon as reasonably possible and as permitted by law, of what information has been disclosed, to the extent that AH(SH) knows this information.

    A message form is provided on the AH(SH) Service to permit Users to exercise their data rights, namely to do the following :
    I want the AH(SH) Service to delete my personal data and cancel my account
    I want the AH(SH) Service to transfer my data to me
    I want to know how the AH(SH) Service or my Site Owner is using my personal information
    I want to rectify incorrect data the AH(SH) Service and my Site Owner has about me
    I want the AH(SH) Service to stop using my information for direct marketing and profiling
    I want to object to the way the AH(SH) Service or my Site Owner is using my personal information

    13.2 Data Deletion – If users requires deletion of their data, we require Users to delete their account. When Users delete their account or decide to no longer participate in the Services, the following is how data deletion will be treated: Majority data deletion will occur upon User consent. Complete data deletion will occur post 180 days. Please see “Data Retention” below for additional details regarding data retention.

    Users, at any time, may request a deletion of their personal data. If such request is made, the account will be deactivated and will remain in backups and life-cycle we maintain to ensure we do not store data inside backups for more than 180 days.
    Users may email [email protected] or contact their Site Owner to request data deletion, cancel their User account or fill out the GDPR Data Subject Request form on the site.

    If Users fail to make payment for any premium plans, the AH(SH) Service will remove all paid features and return Users to the Free / Trial Plan. Please see section 7.5 of our ToS for User inactivity under the Free Plan. If the AH(SH) Service deletes an account due to inactivity, the above scenarios will apply.

    13.3 Data Subject Access Request Procedure (DSAR)
    A Data Subject Access Request (DSAR) is any request made by an individual or an individual’s legal representative for information held by the Company about that individual. The Data Subject Access Request provides the right for data subjects to see or view their own personal data as well as to request copies of the data.
    A Data Subject Access Request must be made in writing. In general, verbal requests for information held about an individual are not valid DSARs. In the event a formal Data Subject Access Request is made verbally to a staff member of the Company, further guidance should be sought from Data Protection Officer, who will consider and approve all Data Subject Access Request applications.
    A Data Subject Access Request can only be made via any of the following methods: email, post, or corporate website. DSARs made online must be treated like any other Data Subject Access Requests when they are received, though the Company will not provide personal information via social media channels.

    13.4) Requirements for a valid DSAR
    In order to be able to respond to the Data Subject Access Requests in a timely manner, the data subject should:
    • Submit his/her request using a Data Subject Access Request Form.
    • Provide the AH(SH) Service with sufficient information to validate his/her identity (to ensure that the person requesting the information is the data subject or his/her authorized person).
    Subject to the exemptions referred to in this document, the AH(SH) Service will provide information to data subjects whose requests are in writing (or by some other method explicitly permitted by the local law), and are received from an individual whose identity can be validated by the AH(SH) Service. Requests are more likely to be successful where they are specific and targeted at particular information.
    Factors that can assist in narrowing the scope of a search include identifying the likely holder of the information (e.g. by making reference to a specific department), the time period in which the information was generated or processed (the narrower the time frame, the more likely a request is to succeed) and being specific about the nature of the data sought (e.g. a copy of a particular form or email records from within a particular department).

    13.5) Exemptions
    An individual does not have the right to access information recorded about someone else, unless they are an authorized representative, or have parental responsibility.
    the AH(SH) Service is not required to respond to requests for information unless it is provided with sufficient details to enable the location of the information to be identified, and to satisfy itself as to the identity of the data subject making the request.
    In principle, the AH(SH) Service will not normally disclose the following types of information in response to a Data Subject Access Request: • Information about other people – A Data Subject Access Request may cover information which relates to an individual or individuals other than the data subject. Access to such data will not be granted, unless the individuals involved have previously given consent to the disclosure of their data in one of the scenarios detailed above, such as communications from other users.
    • Repeat requests – Where a similar or identical request in relation to the same data subject has previously been complied with within a reasonable time period, and where there is no significant change in personal data held in relation to that data subject, any further request made within a three month period of the original request will be considered a repeat request, and the AH(SH) Service will not normally provide a further copy of the same data
    • Publicly available information – The Company is not required to provide copies of documents which are already in the public domain, such as stories, forum contributions, and other User generated content.
    • Opinions given in confidence or protected by copyright law – the AH(SH) Service does not have to disclose personal data held in relation to a data subject that is in the form of an opinion given in confidence or protected by copyright law.
    • Privileged documents – Any privileged information held by the AH(SH) Service need not be disclosed in response to a DSAR. In general, privileged information includes any document which is confidential (e.g. a direct communication between a client and his/her lawyer) and is created for the purpose of obtaining or giving legal advice.

    13.6) Data Subject Access Request Refusals 
    There are situations where individuals do not have a right to see information relating to them. For instance: • If the information is kept only for the purpose of statistics or research, and where the results of the statistical work or research are not made available in a form that identifies any of the individuals involved.
    • Requests made for other, non-data protection purposes can be rejected.
    If the responsible person refuses a Data Subject Access Request on behalf the AH(SH) Service, the reasons for the rejection must be clearly set out in writing. Any individual dissatisfied with the outcome of his/her Data Subject Access Request is entitled to make a request to the Data Protection Officer to review the outcome

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