Your Privacy and GDPR
Description of processing:
The following is a broad description of the way we process personal data. We promise that we will:
- Value the personal information entrusted to us and make sure we respect that trust.
- Go further than just the letter of the law when it comes to handling personal information and adopt good practice standards.
- Consider and address the privacy risks first when we are planning to use or hold personal information in new ways, such as when introducing new systems.
- Be open with individuals about how we use their information and who we give it to and make it easy for individuals to access and correct their personal information.
- Keep personal information to the minimum necessary and delete it when we no longer need it.
- Have effective safeguards in place to make sure personal information is kept securely and does not fall into the wrong hands.
- Provide training to staff who handle personal information and treat it as a disciplinary matter if they misuse or don’t look after personal information properly.
- Put appropriate financial and human resources into looking after personal information to make sure we can live up to our promises and regularly check that we are living up to our promises and report on how we are doing.
This Privacy Notice explains in detail the types of personal data we may collect about you when you interact with us. It also explains how we’ll store and handle that data, and keep it safe.
We know that there’s a lot of information here, but we want you to be fully informed about your rights, and how we use your data; for example we will explain things such as our credit checking procedure, and how we store data.
It’s likely that we may need to update this Privacy Notice from time to time. We hope the following will answer any questions you have but if not, please do get in touch with us.
The law on data protection sets out a number of different reasons for which a company may collect and process your personal data, including:
In specific situations, we can collect and process your data with your consent. For example, when you tick a box or opt-in to receive email newsletters.
When collecting your personal data, we’ll always make clear to you which data is necessary in connection with a particular service.
Contractual obligationsIn certain circumstances, we need your personal data to comply with our contractual obligations.
If the law requires us to, we may need to collect and process your data. For example, we can pass on details of people involved in fraud or other criminal activity affecting the Partnership to law enforcement.
In specific situations, we require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom or interests. For example, we will use your booking history to send you or make available personalised offers. We also combine the history of many customers to identify trends and ensure we can keep up with demand, or develop new services. We will also use your address details to send you direct marketing information by post, telling you about products and services that we think might interest you.
When do we collect your personal data
- When you visit any of our websites, and use your account to buy products and services, or redeem vouchers on the phone or online.
- When you make an online booking and check out we collect transaction-based data.
- When you create an account with us.• When you purchase a product or service by phone but don’t have (or don’t use) an account.
- When you engage with us on social media.
- When you contact us by any means with queries, complaints etc.
- When you ask us to email you information about a product or service.
- When you enter prize draws or competitions.
- When you book any kind of appointment with us.
- When you choose to complete any surveys we send you.
- When you comment on or review our products and services.
- Any individual may access personal data related to them, including opinions.
- When you fill in any forms. For example, if you have an accident on our premises, we will need to collect your personal data.
- When you’ve given a third party permission to share with us the information they hold about you.
- We collect data from publicly-available sources (such as Land Registry) when you have given your consent to share information or where the information is made public as a matter of law.
- When you visit our premises or use our car park we have CCTV systems operated for the security of both customers and staff. These systems may record your image during your visit.
What sort of personal data do we collect?
- If you have an account with us: your name, gender, company name, billing address, orders and receipts, email and telephone number. For your security, this information is password protected.
- Details of your interactions with us via email, online transactions or visiting our premises. For example, we collect notes from our conversations with you, details of any complaints or comments you make, details of bookings you made, voucher redemptions, web pages you visit and how and when you contact us.
- Details of your booking preferences.For example, which of our rooms you prefer.
- Details of your visits to our websites and which site you came from to ours.
- Personal details which help us to recommend items of interest.
- Payment card information.
- Your comments and reviews.
- Your image may be recorded on CCTV when you visit our premises or car park.
- To deliver the best possible web experience, we collect technical information about your internet connection and browser as well as the country and telephone code where your computer is located, the web pages viewed during your visit, the advertisements you clicked on, and any search terms you entered.
- Your social media username, if you interact with us through those channels, to help us respond to your comments, questions or feedback.
How and why do we use your personal data?
We want to give you the best possible customer experience. One way to achieve that is to get the richest picture we can of who you are by combining the data we have about you. We then use this to offer you promotions, products and services that are most likely to interest you. The data privacy law allows this as part of our legitimate interest in understanding our customers and providing the highest levels of service.
Of course, if you wish to change how we use your data, you’ll find details in the ‘What are my rights?’ section below.
Remember, if you choose not to share your personal data with us, or refuse certain contact permissions, we might not be able to provide some services you’ve asked for.
For example, if you’ve asked us to let you know when we launch special offers, we can’t do that if you’ve withdrawn your general consent to hear from us.
Here is how we use your personal data and why:
- To process any bookings that you make by using our websites, in person, or over the phone. If we don’t collect your personal data during checkout, we won’t be able to process your booking and comply with our legal obligations. For example, your details may need to be passed to a third party to supply or deliver the product or service that you ordered, and we may keep your details for a reasonable period afterwards in order to fulfil any contractual obligations such as refunds, guarantees and so on.
- To respond to your queries, refund requests and complaints. Handling the information you sent enables us to respond. We may also keep a record of these to inform any future communication with us and to demonstrate how we communicated with you throughout. We do this on the basis of our contractual obligations to you, our legal obligations and our legitimate interests in providing you with the best service and understanding how we can improve our service based on your experience.
- To protect our customers, premises, assets and staff from crime, we may operate CCTV systems on our premises and car parks which record images for security. We do this on the basis of our legitimate business interests.
- To process payments and to prevent fraudulent transactions. We do this on the basis of our legitimate business interests. This also helps to protect our customers from fraud.
- If we discover any criminal activity or alleged criminal activity through our use of CCTV, fraud monitoring and suspicious transaction monitoring, we will process this data for the purposes of preventing or detecting unlawful acts. Our aim is to protect the individuals we interact with from criminal activities.
- With your consent, we will use your personal data, preferences and details of your transactions to keep you informed by email, web, text, telephone about relevant products and services including tailored special offers, discounts, promotions, events, competitions and so on. Of course, you are free to opt out of hearing from us by any of these channels at any time.
- To send you relevant, personalised communications by post in relation to updates, offers, services and products. We will do this on the basis of our legitimate business interest. You are free to opt out of hearing from us by post at any time.
- To send you communications required by law or which are necessary to inform you about our changes to the services we provide you. For example, updates to this Privacy Notice, product recall notices, and legally required information relating to your orders. These service messages will not include any promotional content and do not require prior consent when sent by email or text message. If we do not use your personal data for these purposes, we would be unable to comply with our legal obligations.
- To display the most interesting content to you on our websites, we’ll use data we hold about your favourite services and so on. We do so on the basis of your consent to receive notifications and/or for our website to place cookies or similar technology on your device.
- To administer any of our prize draws or competitions which you enter, based on your consent given at the time of entering.
- To develop, test and improve the systems, services and products we provide to you. We’ll do this on the basis of our legitimate business interests. For example, we’ll record your feedback on our products and our services.
- To comply with our contractual or legal obligations to share data with law enforcement.
- To send you survey and feedback requests to help improve our services. These messages will not include any promotional content and do not require prior consent when sent by email or text message. We have a legitimate interest to do so as this helps make our products or services more relevant to you.
Of course, you are free to opt out of receiving these requests from us at any time.
How we protect your personal data
We know how much data security matters to all our customers. With this in mind we will treat your data with the utmost care and take all appropriate steps to protect it.
We secure access to all transactional areas of our websites using ‘https’ technology.
Access to your personal data is password-protected, and sensitive data (such as payment card information) is secured by SSL encryption.
Your credit or debit card information provided during the ordering process is protected by 128-bit industry-standard Secure Sockets Layer (SSL) technology to provide encryption of personal information. This server encrypts information while it is being transmitted across the Internet so that unauthorised people cannot read it. Cookies are used on our sites where they are strictly necessary for the site functionality. They are used to aid navigation, and to keep track of your bookings If you log in to an account, your logged-in status is recorded in a temporary cookie. If you select the ‘Remember Me’ Option in the checkout, a cookie will be used to remember your details. You can turn off cookies by blocking them in your browser Privacy settings. If you turn off cookies, you will be unable to place bookings or benefit from the other features that use them.
We regularly monitor our system for possible vulnerabilities and attacks, and we carry out testing to identify ways to further strengthen security.How long do we keep your personal data.
Whenever we collect or process your personal data, we’ll only keep it for as long as is necessary for the purpose for which it was collected.
At the end of that retention period, your data will either be deleted completely or anonymised, for example by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning.
Some examples of customer data retention periods:
When you place a booking, we’ll keep the personal data you give us for five years so we can comply with our legal and contractual obligations.
If your order included a guarantee, the associated personal data will be kept until the end of the guarantee period.
Who do we share your personal data with?
We sometimes share your personal data with trusted third parties. For example, if we arrange services on your behalf from a third party, for fraud management, to handle complaints, to help us personalise our offers to you and so on. Here is the policy we apply to those organisations to keep your data safe and protect your privacy:
- We provide only the information they need to perform their specific services.
- They may only use your data for the exact purposes we specify in our contract with them.
Examples of the kind of third parties we work with are:
- IT companies who support our website and other business systems.
- Operational companies such as maintenance contractors.
- Direct marketing companies who help us manage our electronic communications with you.
- Google/Facebook to show you services that might interest you while you’re browsing the internet. This is based on either your marketing consent or your acceptance of cookies on our websites.
- Data insight companies to ensure your details are up to date and accurate.
- For fraud management, we may share information about fraudulent or potentially fraudulent activity in our premises or systems. This may include sharing data about individuals with law enforcement bodies.
- We may also be required to disclose your personal data to the police or other enforcement, regulatory or Government body, in your country of origin or elsewhere, upon a valid request to do so. These requests are assessed on a case-by-case basis and take the privacy of our customers into consideration.
- We may, from time to time, expand, reduce or sell our business and this may involve the transfer of divisions or the whole business to new owners. If this happens, your personal data will, where relevant, be transferred to the new owner or controlling party, under the terms of this Privacy Notice.
What are your rights over your personal data?
An overview of your different rights
You have the right to request:
- Access to the personal data we hold about you, free of charge in most cases.
- The correction of your personal data when incorrect, out of date or incomplete. For example, when you withdraw consent, or object and we have no legitimate overriding interest, or once the purpose for which we hold the data has come to an end (such as the end of a warranty).
- That we stop using your personal data for direct marketing (either through specific channels, or all channels).
- That we stop any consent-based processing of your personal data after you withdraw that consent.
- Review by a Director of any decision made based solely on automatic processing of your data (i.e. where no human has yet reviewed the outcome and criteria for the decision).
You have the right to request a copy of any information about you that we hold at any time, and also to have that information corrected if it is inaccurate. To ask for your information, please contact Nell Gwynn House Apartments, Nell Gwynn House, Sloane Avenue, London SW3 3AX or email email@example.com
To ask for your information to be amended, please contact our a member of our Customer Services team.
If we choose not to action your request we will explain to you the reasons for our refusal.
Your right to withdraw consent
Whenever you have given us your consent to use your personal data, you have the right to change your mind at any time and withdraw that consent.
Where we rely on our legitimate interest
In cases where we are processing your personal data on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation. We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal data.
You have the right to stop the use of your personal data for direct marketing activity through all channels, or selected channels. We must always comply with your request.
Checking your identity
To protect the confidentiality of your information, we will ask you to verify your identity before proceeding with any request you make under this Privacy Notice. If you have authorised a third party to submit a request on your behalf, we will ask them to prove they have your permission to act.
How can you stop the use of your personal data for direct marketing?
There are several ways you can stop direct marketing communications from us:
- Click the ‘unsubscribe’ link in email communications that we send you. We will then stop any further emails from that particular division.
- Write to Nell Gwynn House Apartments, Nell Gwynn House, Sloane Avenue, London SW3 3AX
Please note that you may continue to receive communications for a short period after changing your preferences while our systems are fully updated
Contacting the Regulator
If you feel that your data has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.
You can contact them by calling 0303 123 1113.Or go online to www.ico.org.uk/concernsIf you are based outside the UK, you have the right to lodge your complaint with the relevant data protection regulator in your country of residence.