Outlined in this policy are full, and we hope transparent details of what personal data (information that can be used to identify a person be it name, address, email, IP address or credit card etc) we collect and store about our current customers, past customers and potential customers along with details on how we use that data and who we share it with.
Personal Information (the collection, purpose and legal grounds for processing)
This refers to any information capable of identifying an individual. It does not include anonymised data.
All personal information that we hold on you is treated as highly confidential and every effort is made to ensure it is securely stored and safeguarded under the new terms of the General Data Protection Regulation 2018 that replaces the UK Data Protection Act 1998.
It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at email@example.com.
We will use any information we have on you, whether it has been collected through you having been a customer or signing up to our website or simply viewing our website (subject to the cookies you have consented to us storing on you), to do the following:
- To contact you
- To notify you of news, events and special offers by email if it is conserved to be of a legitimate interest
- To monitor your use of our website with cookies that you will need to enable to access our website – further information on which cookies we use are outlined later, along with how you can disable these should you wish to.
We may process the following categories of personal data about you:
- Communication Data that includes any communication that you send to us whether that be through the contact form on our website, through email, text, social media messaging, social media posting or any other communication that you send us. We process this data for the purposes of communicating with you, for record keeping and for the establishment, pursuance or defence of legal claims. Our lawful ground for this processing is our legitimate interests which in this case are to reply to communications sent to us, to keep records and to establish, pursue or defend legal claims.
- Customer Data that includes data relating to any purchases of goods and/or services such as your name, title, billing address, delivery address email address, phone number, contact details, purchase details and your card details. We process this data to supply the goods and/or services you have purchased and to keep records of such transactions. Our lawful ground for this processing is the performance of a contract between you and us and/or taking steps at your request to enter into such a contract.
- User Data that includes data about how you use our website and any online services together with any data that you post for publication on our website or through other online services. We process this data to operate our website and ensure relevant content is provided to you, to ensure the security of our website, to maintain back-ups of our website and/or databases and to enable publication and administration of our website, other online services and business. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business.
- Technical Data that includes data about your use of our website and online services such as your IP address, your login data, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website. The source of this data is from our analytics tracking system. We process this data to analyse your use of our website and other online services, to administer and protect our business and website, to deliver relevant website content and advertisements to you and to understand the effectiveness of our advertising. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business and to grow our business and to decide our marketing strategy.
- Marketing Data that may include data about your preferences in receiving marketing from us and your communication preferences. We process this data to enable you to partake in our special offers and promotions, receive any news that may be of interest to you based on a previous purchase or enquiry, to allow us to deliver relevant website content and advertisements to you and measure or understand the effectiveness of this advertising. Our lawful ground for this processing is our legitimate interests which in this case are to study how customers use our products/services, to develop them, to grow our business and to decide our marketing strategy.
We may use Customer Data, User Data, Technical Data and Marketing Data to deliver relevant website content and advertisements to you (including Facebook adverts or other display advertisements) and to measure or understand the effectiveness of the advertising we serve you. Our lawful ground for this processing is legitimate interests which is to grow our business. We may also use such data to send other marketing communications to you. Our lawful ground for this processing is also legitimate interests (namely to grow our business).
We need to collect potentially sensitive data about should you wish to book a spa treatment and for this we require your explicit consent for processing. This is done by providing you with an electronic form at the time of booking and on arrival at Spa 15 you will be presented with a hard copy of the form you completed electronically for you to sign.
Where we are required to collect sensitive personal data by law, or under the terms of the contract between us and you do not provide us with that data when requested, we may not be able to perform the contract eg. provide you with the spa treatment you have booked and as a result may have to cancel your booking.
We will only use sensitive data for the sole purpose it was collected, or a reasonably compatible/re-occurring purpose if necessary, for so long as that information remains accurate and up-to-date.
How we collect your personal data
We may receive data from third parties such as analytics providers such as Google based outside the EU, advertising networks such as Facebook based outside the EU, as well as using third parties that provide us with a platform to offer our guests/customers additional services eg. gift voucher sales, subscribe options and payment gateways.
Our lawful ground of processing your personal data to send you marketing communications is either your consent or our legitimate interests (namely to grow our business).
(Under the Privacy and Electronic Communications Regulations - PECR, we may send you marketing communications from us if (i) you made a purchase or asked for information from us about our goods or services or (ii) you agreed to receive marketing communications, and in each case, you have not opted out of receiving such communications since. Under these regulations, if you are a limited company or the soft ‘Opt-in’ rule is applied (the marketing is in line with similar products or services previously purchased/of interest), we may send you marketing emails without your consent providing the option to ‘Opt-out’ is also included.
You can also ask us to stop sending you marketing messages at any time by simply getting in touch with the hotel by telephone, email or via the contact form on our website. Alternatively, as outlined above, there is an ‘Unsubscribe’ link on every marketing message that we send out.
If you opt out of receiving marketing communications this opt-out does not apply to personal data provided as a result of other transactions, such as hotel room bookings, dinner reservations or spa appointments.
Disclosures of your personal data
We may have to share your personal data with the parties set out below:
- Service providers who provide IT, system administration and marketing services.
- Professional advisers including lawyers, bankers, auditors and insurers
- Government bodies that require us to report processing activities.
We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.
We have and will continue to review security measures that we have in place to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed without authorisation. We also allow access to your personal data only to those employees and partners who have a business need to know such data. They will only process your personal data on our instructions and they must keep it confidential.
We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach if we are legally required to.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
When deciding what the correct time is to keep the data for we look at its amount, nature and sensitivity, potential risk of harm from unauthorised use or disclosure, the processing purposes, if these can be achieved by other means and legal requirements.
For tax purposes the law requires us to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they stop being customers.
Your legal rights
Under data protection laws you have rights in relation to your personal data that include the right to request access, correction, erasure, restriction, transfer, to object to processing, to portability of data and (where the lawful ground of processing is consent) to withdraw consent.
If you wish to exercise any of the rights set out above, please email us at firstname.lastname@example.org.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive, or refuse to comply with your request in these circumstances.
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 disclosed to any person who has no right to receive it. We may also contact you to ask you for further 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 have made a number of requests. In this case, we will notify you.
Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
Whilst the procedures we have in place are designed to protect and secure all personal information we have stored on our database system, we cannot be held liable for any unauthorised access to the data you provide via our website.
Please be aware that we will provide your information if requested by any legal authority, such as the police or a court of law.
If you are a supplier or an employee please contact the hotel directly for further details on how your data is collected, stored, used and shared.