WHAT KIND OF DATA WE COLLECT
Personal data, or personal information, means any information about an individual, which can be used to identify that person. It does not include data where the identity has been removed (anonymous data).
We collect a variety of personal information about our guests, customers and visitors to our website.
CATEGORIES THAT THIS PERSONAL DATA FALLS INTO:
- Identity Data includes title, gender, first name, maiden name, last name, marital status, date of birth, username or similar identifier and an encrypted version of your login/password. If you interact with us through social media, this may include your social media user name.
- Contact Data includes billing address, delivery address, email address and telephone numbers.
- Financial Data includes payment card and direct debit/bank account details.
- Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
- Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses, as well as any data which we have added (for example, using analytics and profiling).
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
- Usage Data includes information about how you use our website, products and services.
- Tracking Data includes information we or others collect about you from cookies and similar tracking technologies, such as web beacons, pixels, and mobile identifiers.
- Marketing and Communications Data includes your preferences in receiving direct marketing from us and our third parties and your communication preferences.
We do not ordinarily collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data) nor do we collect any information about criminal convictions and offences. The only exceptions to this are: (i) if you provide health data to us as part of a spa booking, we will use this to perform our contract with you, and we need your explicit consent to use your health data as part of that or (ii) you have made the special category data obviously public.
THE WAY WE COLLECT DATA
We may collect or receive data in lots of different ways.
You may give us data in person when you are a guest at one of our hotels, for example when you:
- check-in and check-out;
- make use of our accommodation, facilities and services;
- make use of our concierge services;
- attend our events;
- enter a competition, promotion or survey;
- complete a contact details card; and/or
- give us your business card.
You may give us data remotely when you interact with us via this website, by post, phone or email, or through chat or social media, for example, when you:
- sign up to receive our newsletter or other direct marketing;
- make enquiries or request information, or correspond with us generally;
- create an account on our website;
- book accommodation, hospitality, spa treatments or services;
- engage with us on social media;
- enter a competition, promotion or survey;
- leave comments or reviews; and/or
We may get some data automatically, for example, we could collect data about your equipment, browsing or the way you use this website. We may also collect data when you click on one of our adverts (including the ones you see on third party websites or social media). The systems we use for guest management may also collect data automatically to help create a guest profile, which in turn gives us a better understanding of how we can improve your experience with us.
We may get some data from third parties as part of the booking process for our accommodation, hospitality, spa treatments or services at our hotels. For example, when you:
- use third party booking services for accommodation, restaurants, hospitality, spa treatments or other services; and/or
- are our guest as part of a group or corporate booking.
We may receive data about you from various other types of third parties, including:
- from technology partners who help us run our website and mailing list sign-ups;
- from providers of payment and fraud prevention services;
- from analytics providers, advertising networks and search information providers;
- from data partners;
- from feedback and review partners;
- from publicly available sources;
- from social media, where privacy settings are set to public;
- from third parties to whom you have given permission to share your data with us; and/or
- from any third parties who are permitted by law to share your personal data with us.
WE USE YOUR PERSONAL DATA : HOW AND WHY
We use your personal information in a number of ways, including providing and personalizing the services you request and expect from us, to offer you a high level of hospitality, conduct direct marketing and sales promotions and as set forth below in more detail. We will collect your consent prior to processing your data where required by applicable law.
We are obligated to collect certain data, including your name, address, payment information, and, in certain countries, travel document information, in order to process your reservation. Failure to provide this information will result in our inability to process your reservation. We may use your personal information to provide you with information about meeting and event planning. We may use your personal information to provide or offer you newsletters, promotions and featured specials, as well as other marketing messages in accordance with any communications preferences you have expressed. We use your information to provide in-stay messaging, account alerts, and reservation confirmations and to send you marketing messages. We may provide these communications via email, postal mail, online advertising, social media, telephone, text message (including SMS and MMS), push notifications, in-app messaging, and other means. We may also collect information from your payment card, which can be appended to personal information and used by us to recognize what type of card you have, the bank or network of the card, and present and/or send you targeted marketing messages based on your payment method and in accordance with your communication preferences. We may use your personal information to improve our services and to ensure that our site, products, and services are of interest to you. We may aggregate your personal information with data from third-party sources for purposes of keeping information up to date and analytics. We also rely on information from third parties in order to provide better, more personalized service. For example, if you connect your social media services or other accounts to our services, we may use this information to make your experiences with us more personal and social, or share and use it as described elsewhere in this Statement.
We may process your personal data for more than one legal basis depending on how we are using it. Whenever we process data for these purposes we will ensure that we always keep your personal data rights in high regards and take account of these rights.
CHOOSING NOT TO GIVE US YOUR PERSONAL DATA
When you make a booking with us for accommodation, hospitality, spa treatments or other services, we may need to collect some of your personal data by law, or under the terms of a contract we have with you. This means that if you decide not to give us your data, we might not be able to provide the service, and may have to cancel your booking or gift shop purchase. We will let you know if this is the case at the time, so you can decide what you’d like to do.
THE LEGAL BASES FOR USING PERSONAL DATA - EXPLAINING
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
• Where we need to perform the contract we are about to enter into or have entered into with you. For example, when you make a booking at one of our hotels, that’s a contract.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. For example, when we carry out fraud screening as part of the check-out process or take steps to keep our website secure.
• Where we need to comply with a legal or regulatory obligation. For example, keeping records of our sales for tax compliance.
When we are considering legitimate interests, we make sure we think about and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
Unless it is necessary for a reason allowable in the GDPR, we will always obtain explicit consent from a data subject to collect and process their data. Where consent is given, a record will be kept documenting how and when consent was given. If the personal data is not obtained directly from the data subject, then this information will be provided to the data subject within a reasonable period after the data are obtained. Where the personal data collected and processed is required to fulfill a contract with the data subject, explicit consent is not required. This will often be the case where the contract cannot be completed without the personal data in question e.g. a dining or room reservation cannot be made without a name, email address and credit card details.
If the personal data is required to be collected and processed to comply with the law, then explicit consent is not required.
WHEN WE SHARE YOUR PERSONAL DATA AND HOW WE DO IT
We may share personal data with the following categories of third parties:
- suppliers and service providers (such as outsourced service providers for administration and hotel management (e.g. booking and reservation systems, customer relationship management systems), technology and media services providers, payment processing and fraud prevention providers, fulfillment partners for the gift shop)
- auditors and professional advisers like bankers, lawyers, accountants and insurers and
- Government, regulators and law enforcement.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We do not share your personal data outside Europe.
Cookies help us to provide you with a good experience when you use our website and also allow us to improve our website and services. We use the following categories of cookies:
- Strictly necessary cookies. These are cookies which are needed to make the website work properly. For example, cookies enable you to log in, make a booking or and make secure payments.
- Functionality cookies. These are used to recognize you when you return to our website. This helps us to personalize our content for you and remember your preferences.
- Analytical/performance cookies. These allow us to recognize and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
- Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. This forms part of Tacking Data and we may also share this information with third parties for this purpose.
The data received from our website cookies is anonymized data, therefore individuals cannot be identified.
We can use strictly necessary and functional cookies without consent. We gain your consent for other cookies via the banner that you see the first time you visit our website. You can choose not to consent. You can also block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies.
However, if you do not consent, or use your browser settings to block all cookies (including essential cookies), you may not be able to access all or parts of our site.
Please be aware that if you delete your cookies we will no longer know that you’ve opted out of online behavioral advertising, so our adverts can still appear to you on other websites.
If you do not wish to receive such cookies from us, please adjust your browser’s settings accordingly
Adjusting your browser’s cookie settings
If you are using Internet Explorer 11, 10, 9, 8, 7, 6
- Choose Tools then
- Internet Options
- Select the Privacy tab,
- Under settings, select Advanced
- Check Override automatic cookie handling
- Check and choose if you want to allow, block or be prompted for first and third-party cookies.
If you are using Internet Explorer 5.0 or 5.5:
- Choose Tools, then
- Internet Options
- Click the Security tab
- Click on Custom Level
- Scroll down to the sixth option to see how cookies are handled by IE5 and change to Accept, Disable, or Prompt for action as appropriate.
If you are using Internet Explorer 4.0
- Choose View, then
- Internet Options
- Click the Advanced tab
In Internet Explorer 3.0:
You can View, Options, Advanced, then click on the button that says Warn before Accepting Cookies.
If you are using Chrome
- At the top right, click More and then Settings
- At the bottom, click Advanced
- Under “Privacy and security,” click Content settings
- Click Cookies
- From here, you can,
- Turn on cookies: Next to “Blocked,” turn on the switch
- Turn off cookies: Turn off Allow sites to save and read cookie data
If you are using Safari
- Choose Preferences
- Click Privacy, then do any of the following:
- Always block cookies: Select ‘Block all cookies’
- If you are using Firefox
- Select Options from the right side of the drop-down menu.
- Click Privacy & Security tab
- In History, select the use custom settings for history option in the drop-down menu of the panel’s History section.
- There will you will have the option to tick or untick, always use private browsing mode, remember my browsing and download history, remember search and from history, accept cookies from web sites or clear history when Firefox closes.
MARKETING AND ADVERTISING
You could see our adverts in lots of different places. If you see one of our adverts on a website and in social media, it may not be directed specifically at you and may simply be there because we’ve bid for the space.
You may choose to opt in to receive our newsletter on our website. We may also be able to send you relevant direct marketing about our hotel, services and events unless you choose to opt out when making a booking with us, visiting our hotel.
Here are some examples of our direct marketing activities which may be directed specifically at you:
- our newsletter via email;
- invitations and promotions by post, to tell you about special events at our hotel; and/or
- phone calls, to tell you something that might be relevant to you or your business.
We also work with partners to try and promote the reach of our adverts, using analytics and retargeting. To make sure the adverts you see on websites and social media are relevant, we use Tracking Data to see what you’ve looked at. Tracking Data, and in particular cookies, help us to do this by telling us which adverts will be most relevant to you and potential new guests on website and social media. The cookies used for this purpose are often placed on our website by specialist organizations – and this is also why when you’ve been on our website, you might see content from our website again. This includes retargeting.
Cookies can also tell us if you’ve seen a specific advert, and how long it’s been since you have seen it. This is helpful, because it means we can control the effectiveness of our adverts and control the number of times people might be shown our adverts. Cookies also help us understand if you’ve opened a marketing email because we don’t want to send you things you won’t find interesting.
Almost all the cookies that relate to advertising are part of third party online advertising networks. We do not control cookies which are set by advertising networks.
SECURITY OF DATA
Any personal data in hard copy format will be kept in a locked filing cabinet, drawer or safe, with restricted access. Confidential paper records will not be left unattended or in clear view anywhere with general access. All electronic devices are password-protected to protect the information on the device in case of theft. Digital data is coded, encrypted or password-protected, on a network drive that is regularly backed up on and off-site. All members of staff are provided with their own secure login and password, and every computer regularly prompts users to change their password. Emails containing sensitive or confidential information are password-protected if there are unsecure servers between the sender and the recipient. The security of our computer and storage systems, and access to them, is continuously monitored.
WE KEEP YOUR PERSONAL DATA FOR A CERTAIN PERIOD
We will only keep your personal data for as long as we need to fulfill the purposes we collected it for, including for satisfying any legal, accounting, or reporting requirements.
To decide how long we should keep your personal data for, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or sharing of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law we have to keep basic information about our guests and customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances we may remove your identity from your personal data (so that it can no longer be associated with you) for statistical purposes, in which case we may use this information indefinitely without further notice to you.
YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
Request access to your personal data: This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of your personal data: This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data: This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing, where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data: This enables you to object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which overrides your rights and freedoms.
Request restriction of processing your personal data: This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Right to withdraw consent: Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not shared with anyone who doesn’t have the right to receive it. We may also contact you to ask you for more information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you’ve made a number of requests. In this case, we will let you know and keep you updated.