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Privacy Policy
PRIVACY NOTICE
1 About this notice
This notice (the “Privacy Notice”) provides information about how Elegant Hotels
Group plc, its subsidiaries and all of the hotels within the Elegant Hotels
Group of Brands Hotels (“Elegant Hotels”,
“we”,“us”, “our”) gathers and
uses personal information. We are committed to respecting the confidentiality
of the personal information you supply to us and all data will be processed in
accordance with applicable data privacy laws.
You have the right to be provided with clear,
transparent and easily understandable information about how we use your
information and your rights. This is why we are providing you with the
information in this Privacy Notice.
If you do not agree with our use of your
personal data as set out in this Privacy Notice, you should not submit your
personal information to us. However, if we already have your personal
information and if you wish to exercise your rights to prevent us using your
data, you should be aware that we may not be able to do business with you. For
more information on this, please see sections 4.1 and 7.
2
About us
We are Elegant Hotels Group plc 9537096 registered at 10 Norwich Street London EC4A 1BD for the purposes of data privacy legislation,
we will be a ‘controller’.
Should you have any questions or concerns about
this Privacy Notice or the processing of personal data we hold about you,
please contact us:
|
By post: |
Suite 250, Tamarind Cove Hotel, Paynes
Bay, St. James, Barbados, BB 24023 |
|
By phone: |
+1246 432 6572 |
|
By email: |
4
Your rights
You have certain rights in relation to your
personal data.
4.1
Your rights in
connection with personal information
Under certain circumstances, by law you have
the right to:
·
Object to processing of your
personal information where we are relying on a legitimate interest (or that of
a third party) and there is something about your particular situation which
makes you want to object to processing on this ground. You also have the right
to object where we are processing your personal information for direct
marketing purposes.
·
Request access to your personal
information (commonly known as a "data subject access request"). This
enables you to receive a copy of the personal information we hold about you and
to check that we are processing it lawfully.
·
Request correction of the
personal information that we hold about you. This enables you to have any
incomplete or inaccurate information we hold about you corrected.
·
Request erasure of your
personal information. This enables you to ask us to delete or remove personal
information 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 information
where you have exercised your right to object to processing (see above).
·
Request the restriction of
processing of your personal information. This enables you to ask us to suspend
the processing of personal information about you, for example if you want us to
establish its accuracy or the reason for processing it.
·
Request the transfer of your
personal information to another party in a machine-readable, commonly used and
structured format.
If you want to exercise any of these rights
then please contact us using the details at section 3. The
various rights are not absolute and each is subject to certain exceptions or
qualifications. For example, if you wish to withdraw your consent or object to
processing, we may need to discuss with you whether our use of your data needs
to continue for other lawful purposes, such as fulfilment of a legal or
contractual requirement.
We will respond to your request within one
month of receipt of your request. In some cases we may not be able to fulfil
your request to exercise the right before this date, and may need to request
more time. Where we cannot provide a full response to you for any reason, we
will let you know about this in our initial reply to your request.
4.2
Your duty to inform
us of changes
It is important that the personal information
we hold about you is accurate and current. Please keep us informed if your
personal information changes during your working relationship with us.
4.3
Fees
You will not have to pay a fee to access your
personal information (or to exercise any of the other rights). In some cases, we may charge a reasonable fee
if your request for access is clearly unfounded or excessive, or if you request
multiple copies of the information. Alternatively, we may refuse to comply with
the request in such circumstances.
4.4
What we may need from
you
We may need to request specific information
from you to help us confirm your identity and ensure your right to access the
information (or to exercise any of your other rights). This is another
appropriate security measure to ensure that personal information is not
disclosed to any person who has no right to receive it.
4.5
Right to complain
If you wish to request further information
about any of the above rights, or if you are unhappy with how we have handled
your information, please contact us on the contact details contained in section
3.
If you are not satisfied with our response to
your complaint or believe our processing of your information does not comply
with data protection law, you can make a complaint to the Information
Commissioner’s Office: https://ico.org.uk/global/contact-us/
or 0303 123 1113 or your national supervisory authority.
5
Information we
collect
We collect your personal information from a
variety of sources, as set out in this Privacy Notice. Where necessary we
collect information directly from you or indirectly from third parties, and
through your use of our website.
5.1
Information you provide to us
This section details the information we collect
about you in the course of your stay at one of our hotels, your use of our
website and otherwise in your interaction and correspondence with us and our representatives.
We will collect:
·
basic personal details
including your name and address (and proof of name and address), email address,
telephone number, any other contact details you supply, nationality,
citizenship, date of birth and family connections;
·
financial and payment details;
·
passport details or other forms
of identification;
·
details on your reason for
travel;
·
records of communications
including recordings of phone calls and electronic communications with our
staff and meeting notes (see below for more details); and
·
certain health and medical
information.
5.2
Information we
collect from other sources
We will receive information about you from
third parties such as tour operators, travel agents and other third party
travel companies. We will collect the following information from third parties:
·
basic personal details including
your name, address, email address, telephone number and other contact details;
·
financial and payment details; and
·
Your flight information
5.3
Information from your
use of our website
We collect information about your use of our
website and the devices you use. We collect information on:
·
how often you access our
website;
·
your geographic location when
you accessed our website;
·
the way in which you navigate
around it;
·
how long you spend on
particular pages;
·
the operating system, hardware,
software versions, browser configuration, display size, browser configuration
of the devices you use;
·
traffic patterns, visits from
other web sites or to third-party web sites linked to the our website, use of
particular services; and
·
connection information such as
IP addresses.
We also use cookies to log your behavioural
information. For more information on our use of cookies, please refer to the
details contained in section 14 for use of cookies on our website. In
particular, please note that cookies may be held by our third party website
provider.
5.4
Security Surveillance
We make use of Security Surveillance at our
premises and may retain recordings.
6
How we use the
information we collect
6.1
General uses of information
The information which we collect and what we
use it for will depend on the nature of our business relationship with you. We
use your information:
a) to provide you with the accommodation which you have requested and
to fulfil our contractual obligations towards you;
b) to fulfil our contractual obligations to third parties to whom you
have provided your information and through whom you have booked your stay with
us;
c) for our internal business administration and record keeping
purposes;
d) to respond to your enquiries submitted through our website;
e) to detect, prevent and address technical issues;
f)
to notify you about changes to
our website and/or services;
g) to comply with applicable laws, respond to governmental inquires,
requests from public authorities, regulatory or law enforcement agencies.
h) comply with valid legal process, protect the rights, privacy, safety
or property of Elegant Hotels, site visitors, guests, employees or the public;
i)
to protect our legal or
business interests and limit any damages that we may sustain; and
j)
respond to an emergency.
6.2
Information for marketing
purposes
We use your information to identify products,
services and events that we think may be of interest to you.
You have the right to ask us not to send you marketing messages by
email, post, telephone or any combination of these at any time. You can also let us
know at any time that you wish to change your mind and to start receiving such
messages.
You can do this:
·
by replying directly to the
marketing message;
·
in case you wish to withdraw
from all marketing communications, you can also unsubscribe from all marketing
by clicking the appropriate link in any email you receive from Elegant Hotels;
or
·
at any time by contacting us
(see section 3).
Periodically, we will remind you (possibly
along with other communications) that you may unsubscribe if you no longer wish
to receive communications from us. If you choose to unsubscribe, we will cease
to send you such communications as mentioned above.
7
Our bases for
collecting and using the information
We are entitled to use your personal data in
the ways set out in this Privacy Notice on the following bases:
·
the use of personal data in
this way is necessary for the performance of a contract with you for provision
of our products and/or services or to take steps at your request prior to entering
into such a contract;
·
we have legal obligations that
we have to discharge;
·
the use of your personal data
is necessary for our legitimate interests in:
·
ensuring the quality of the
products and services we provide to you;
·
collecting information for
marketing purposes;
·
communicating with you;
·
the physical security of our
premises (with regard to Security Surveillance); and
·
statistical analysis;
·
you have consented to such use;
and/or
·
to establish, exercise or
defend our legal rights for the purposes of legal proceedings.
We process your sensitive and special
categories of information, which for a stay at one of our hotels would most
likely include information concerning:
·
food or other allergies;
·
physical medical conditions
which may affect your stay; or
·
religious considerations you
would like Elegant Hotels to take into account during your stay with us.
Special categories of information may also
include other data concerning your health, personal data revealing your racial
or ethnic origin, political opinions, religious or philosophical beliefs, or
data concerning sexual orientation. We will process such personal information where
we have asked for your explicit consent, there is a need to process to protect
your health or wellbeing, or otherwise where this is necessary for the
establishment, exercise or defence of legal claims.
In the case that you have obviously made
information public (e.g. on social media) we will process sensitive/special
categories of information for the purposes of carrying out our legal
obligations.
If provision of your personal information is a
legal or contractual requirement or a requirement necessary to enter into a
contract with us, and you choose not to provide it, we may not be able to
perform some of the tasks we need to in order to provide certain products or
services to you.
If you do choose to provide your consent, you
can withdraw it at any time by contacting us (see section 3).
8
Sharing your
information
We will not disclose your personal information
to third parties except as detailed in this Privacy Notice.
Where necessary, we disclose your personal data
to third parties that are specifically engaged by us to provide services to us,
in which case we will require those parties to keep that information
confidential and secure and to use it solely for the purpose of providing the
specified services to us. The following is a list of the types of third parties
who process your personal data on our behalf:
·
Website and IT providers and
suppliers;
·
Third party API technology
providers
·
Digital Media partners
·
Loyalty and rewards programme
providers;
·
Training Platform Provider
·
Customer Relationship
Management (CRM) provider
·
we may share information with the
following entities which we have appointed to process data on our behalf in
order to allow us to provide products or services that you have requested:
·
sponsors of contest, competitions,
sweepstakes and prize draws, webcasts or downloads. The registration data for
such events is to be used by us as part of the user information gathered at the
time, and may be shared with the sponsor and others, subject to this Privacy
Notice and the sponsor’s privacy notice. We may also share your information
with third party vendors involved in the administration of such events. For
contests, competitions, sweepstakes and prize draws, please read the official rules or terms and conditions carefully before
submitting your information.
·
we may provide your information
to third parties engaged by us to provide services to us:
·
professional advisers, including
accountants, auditors, compliance consultants, legal advisers and tax advisers;
·
fraud prevention agencies;
·
courier companies;
·
insurance brokers.
·
we may disclose to law
enforcement agencies and regulators, government departments or competent
authorities of the UK or of other countries any personal data (including tax
status, identity or residency or other personal and payment information,
documents or self-certifications) where we are under a duty to disclose or
share your information in order to comply with any legal or regulatory
obligation, or if we reasonably consider that this is necessary to help prevent
or detect fraud or other crime or to protect our rights, property, or safety, or
that of our customers or others. Such disclosure may be made directly to such
regulators or competent authorities or made indirectly to our advisers or
providers who will make such filings or disclosures on our behalf;
·
if we are under a duty to
disclose or share your information with HM Revenue & Customs (HMRC) or
other tax authorities, who may transfer it to the government or the tax
authorities in another country where you may be subject to tax. Such disclosure
may be made directly to such regulators or competent authorities or made
indirectly to our advisers or providers who will make such filings or
disclosures on our behalf; and
·
if you have consented to any disclosure
to a third party.
9
Where we store
your information
We transfer, use and store your personal
information outside of the European Economic Area (“EEA”) and the laws of some of these destination countries may not
offer the same standard of protection for personal information as countries within the EEA. It will
also be processed by staff operating outside the EEA who work for us or for one
of our suppliers (for example, those who supply support services to us).
We currently transfer data to the following
countries outside of the EEA:
·
United States of America
·
Barbados
·
St. Lucia
·
Antigua and Barbuda
10
Keeping your
information
We will keep your information only for as long
as necessary depending on the purpose for which it was provided. Details of
retention periods for different aspects of your personal information are
available in our retention policy, which you can request by contacting us (see
section 3).
When determining the relevant retention
periods, we will take into account factors including:
·
our contractual and business
relationships with you;
·
legal obligations under
applicable law to retain data for a certain period of time;
·
statute of limitations under
applicable law(s);
·
(potential) disputes; and
·
guidelines issued by relevant
supervisory authorities.
11
Security
We acknowledge that the information you provide
may be confidential and will maintain the confidentiality of and protect your
information in accordance with our normal procedures and all applicable laws.
We employ appropriate technical and organisational security measures to help
protect your personal data against loss and to guard against access by
unauthorised persons.
In addition, those employees, agents,
contractors and other third parties who process your personal data will only do
so on our instructions and they will be subject to a duty of confidentiality.
Unfortunately, the transmission of information
via the internet is not completely secure. Although we will do our best to
protect your personal data [for example by encrypting our outgoing email
communications,] we cannot guarantee the security of your data [transmitted to
our website]. Any transmission is at your own risk. Once we have received your
information, we will use procedures and security features to try to prevent
unauthorised access.
12
Links to other
websites
Links on our website may take you to third party
sites over which we have no control. While such links
are provided for your convenience, you should be aware that the information
handling practices of the linked websites might not be the same as ours. You
should review any privacy notices on those linked websites. We are not
responsible for any linked websites.
13
Changes to our Privacy
Notice
We
reserve the right, at our discretion, to change, modify, add to, or remove
portions from, our Privacy Notice. We will notify you via email of any changes
where we are required to do so. You should review this Privacy Notice
periodically for any changes. Changes to this Privacy Notice are effective when
they are posted on this page.
14 Use of cookies on our website
What is a cookie?
Cookies are small data files that many internet
sites automatically download to a user’s computer, phone or tablet’s hard
disk. They are primarily used to collect
standard internet log information and visitor behaviour information. This information is used to track visitor use
of a website, improve the functionality of a website and to compile statistical
reports on website activity.
What cookies will this website use and for what
purpose?
This website uses cookies to store information on
your computer phone and/or tablet. By
storing information such as location and web pages visited, Elegant Hotels can improve your browsing experience and the
quality of the services we provide you.
These cookies are set when you submit a form or interact with this
website by doing something that goes beyond clicking on simple links. We
also use some non-essential cookies to anonymously track visitors or enhance
your experience of this website. The
cookies that this website uses include:
· Single session
cookies. These enable this website to keep track of your
movement from page to page in order to ensure that you will not be asked for
the same information you have previously given during your visit to this
website. These cookies allow you to
proceed through this website quickly and easily without having to authenticate
or reprocess each new area you visit. We
may use such cookies to analyse user behaviour, such as which pages have been
visited during the session, in order to improve your overall experience, for
example by enabling us to determine and display more relevant content.
· Persistent cookies.
These
cookies enable us to collect information such as the number of visitors to this
website and the pages visited (in aggregate) in order to analyse user
behaviour. This information is collected
in an anonymous form and will be collated with similar information received
from other users to enable us to compile reports in order to develop and
improve user experience by displaying more tailored and relevant content.
Information
tracking
We may use third party technology, such as Google
Analytics, to provide us with information about how you use
this website. This may include the use
of cookies to collect anonymous information, including the
number of visitors to this website, where they have come to this website from,
the pages they visit and the length of time they have spent on this
website. We may use this information to
compile statistics and to help us to improve our website and the services we
offer. Google’s privacy policy is available
at http://www.google.com/policies/privacy.
This data is collected primarily for monitoring the
usage and performance of our website. We may use your IP address and track
browser types to build a profile of our users.
Further information about cookies
For further information about cookies, visit www.aboutcookies.org or www.youronlinechoices.eu.
You can set your web browser not to accept cookies
and the above websites tell you how to remove cookies from your browser. However, some of our website features may not
function as a result. The way in which
you adjust your browser security setting varies from browser to browser.
15 Children’s Privacy and Parental Consent
Please be aware
that Elegant Hotels has designed this website to be used for information only
purposes by all ages. However, as with any website parental consent is
encouraged.
You must be at
least 18 years old to make reservations and/or submit personal information on
our website.
Should Elegant
Hotels become aware that we received personal data from children without
verification of parental consent, we take secure steps to remove that
information from our servers. Elegant Hotels will not knowingly provide this
data to any third party for any purpose whatsoever, and any subsequent
disclosure would be due to the fact the user under 18 used the website and
submitted personal information without solicitation by or permission from
Elegant Hotels.