1. Information collected
1.1 We collect personal information:
1.1.1 from visitors to the Site;
1.1.2 from visitors to our premises; and
1.1.3 every time you email us your details or correspond with us by phone, e-mail or otherwise.
1.2 This includes information you provide when you register to use our Site, subscribe to our service, enquire about an event, place an reservation on our Site, participate in discussion boards or other social media functions on our Site or enter a competition, promotion or survey, and if you report a problem with our Site, and when you attend our premises. The information you give us may include details such as your name, address, e-mail address and phone number and financial and credit card information, event and dietary requirements information, or any special assistance you request and information about your health requirements and history and details about your religion and ethnicity.
1.3 With regard to each of your visits to our Site we may automatically collect the following information:
1.3.1. technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
1.3.2. information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our Site (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number;
1.4 This information helps us to build a profile of our users. Some of this data will be aggregated or statistical, which means that we will not be able to identify you individually.
1.5 Information we receive from other sources
We may receive information about you if you use any of the other websites we operate or the other services we provide. In this case, we will have informed you when we collected that data that it may be shared internally and combined with data collected on this Site. We are also working closely with third parties (including, for example, business partners, sub-contractors in technical, payment, and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them which we will add to the information which we already hold about you in order to help us provide goods and services and to improve your experience with us.
2. Information about other individuals
If you give us information on behalf of someone else, you confirm that the other person has appointed you to act on his/her behalf and has agreed that you can give consent on his/her behalf to the processing of his or her personal data and receive on his/her behalf any data protection notices.
We may monitor and record communications with you (such as telephone conversations and emails) for the purpose of quality assurance, improving our services, training, fraud prevention, and compliance.
4. Use of Personal Information
4.1 We process the personal information you have provided to us for the purposes of performing the agreement(s) we have with as a guest or customer to:
4.1.1 provide and manage bookings, reservations and events, including accommodation, restaurant, gym and leisure activity, and use of shared offices or any other activity;
4.1.2. provide reservation services;
4.1.3. carry out other obligations arising from any contracts entered into between you and us, including meeting any dietary or special assistance request you have made;
4.2 We also process personal information we have collected about you where we have a legitimate interest which is not outweighed by your rights and freedoms, specifically for the purposes of:
4.2.1. tailoring our services to your requirements and preferences;
4.2.2. making suggestions and recommendations to you and other users of our Site about goods or services that may interest you or them;
4.2.3. improving our Site to ensure that content is presented in the most effective manner for you and for your computer;
4.2.4. allowing you to participate in interactive features of our service, when you choose to do so;
4.2.5. administering our Site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
4.2.6. measuring or understanding the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
4.2.7. ensuring that content from our Site is presented in the most effective manner for you and for your computer;
4.2.8. conducting market research surveys and providing you with information about products and services we offer (where you have provided us with your consent to do so);
4.2.9. occasionally, establishing or defending legal claims;
4.2.10 protecting property, staff and users of our premises using CCTV or other security monitoring schemes.
4.3 Some of your data we will only process if you give us your consent, such as:
4.3.1. responding to and dealing with your queries, complaints and requests as a guest or customer, including meeting any dietary or special 4.3.2. assistance needs you have;
4.3.3. to provide you with the information, products and services that you request from us; and
4.3.4. to use any images or other data identifying you on our social media or other internal or otherwise publications.
4.4 In some cases, we need to process your data to comply with our legal obligations, such as:
4.4.1 our service;
4.4.2. to notify you under data protection law about changes to how we process personal data;
4.4.3 our efforts to keep our Site safe and secure in compliance with data protection law;
4.4.4 to record incidents and accidents that may occur during time spent at any of our premises, including if applicable any relevant dietary, health or special assistance information, and
4.4.5 to comply with any other health and safety or similar regulatory obligations
On rare occasions, we may also process data in emergency situations, or where requested in cooperation with police investigations.
4.5 Where we have received personal information from other sources, we may combine this information with information you give to us and information we collect about you. We may use this information and the combined information for the purposes set out above (depending on the types of information we receive).
5.1 We may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
5.2 We may share your information with selected third parties including:
5.2.1 business partners, suppliers and subcontractors for the performance of any contract we enter into with them or you; and
5.2.2 analytics and search engine providers that assist us in the improvement and optimisation of our Site.
5.3 We may disclose your personal information to third parties:
5.3.1. in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
5.3.2. if all, or substantially all, of our assets are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets; and
6. Data Retention
We will retain your information in line with our Data Retention Policy.
7.2 Where we store your Personal Data
All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using TLS technology Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
7.3 Third Parties
Our Site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
7.4 The Site is Not Directed at Persons Under the Age of 18
Our Site is not directed at persons under the age of 18, and we do not collect or maintain information from persons we know are under the age of 18, with the exception of details provided to us by a parent or guardian who has had access to this policy and understands how we process personal data.
8. Your Rights
You have the right to ask us not to process your personal data for direct marketing purposes. We will ask you when we collect your personal data if we can use your data for such purposes or if we can disclose your information to any third party for such purposes. You can opt-out of receiving such marketing at any time.
8.2. Access to Information
Data Protection Legislation gives you the right to access information held about you. Your right of access can be exercised in accordance with Data Protection Legislation, by contacting firstname.lastname@example.org.
8.3. Right to be Forgotten
In certain circumstances you can request us to delete all information we hold which identifies you. You can make this request at any time by contacting us at email@example.com but please note we may be compelled to maintain your information due to specific legislative or regulatory requirements, for example we keep copy invoices in case of an HMRC investigation.
8.4 Data Corrections
You have the right to require us to correct any inaccuracies in your data free of charge. You can also exercise this right at any time by contacting us at firstname.lastname@example.org and:
8.4.1. providing us with enough information to identify you (e.g. account number, username, registration details); and
8.4.2. specifying the information that is incorrect and what it should be replaced with.
8.5 Restriction of Processing
You can ask us to suspend the processing of your personal data in the following scenarios:
8.5.1. if you want us to establish the data’s accuracy;
8.5.2. where our use of the data is unlawful but you do not want us to erase it;
8.5.3. 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; and/or
8.5.4. you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
8.6 Data Transfer
You can request the transfer of automated information which you initially provided consent for us to use or where we used the information to perform a contract with you to yourself or to a third party in a structured, commonly used, machine-readable format.
8.7 Object to Processing
You can object to any of the processing listed in paragraph 4.2 above, or where we are relying on another of our legitimate interests (or those of a third party) in respect of your particular situation if you feel it impacts on your fundamental rights and freedoms, and we do not have compelling legitimate grounds to process your information which override your rights and freedoms.
8.8 Withdraw Consent
If you have consented to us processing your data, or asked us to, as set out in paragraph 4.3 above, you can change your mind at any time. This will not affect the lawfulness of any processing carried out before you withdraw your consent.
8.9 Complain to the Data Protection Regulator
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We always try to deal with your concerns in the first instance, so please contact us if you are dissatisfied with how your personal data has been handled.