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Privacy Policy

A) INTRODUCTION

This document is intended to provide you with important information regarding how we process the personal data that we hold for you. This includes details of exactly what data we hold, how it is stored, how we use it and why we hold it.

We have to collect and use information about people with whom we deal as part of the services we offer. This personal information must be handled and dealt with properly, however it is collected, recorded and used, and whether it be on paper, in computer records or recorded by any other means.

We regard the lawful and correct treatment of personal information as very important to our successful operation and to maintaining confidence between us and those with whom we carry out business. We will ensure that we treat personal information lawfully and correctly.

To this end we fully endorse and adhere to the principles of the General Data Protection Regulation (GDPR).

This policy applies to the processing of personal data in manual and electronic records kept by us in connection with our services as described below. It also covers our response to any data breach and other rights under the GDPR.

This policy applies to the personal data of our guests, employees, contractors and companies or individuals that we work with in conjunction with our day to day activities. These are referred to in this policy as relevant individuals.

B) DEFINITIONS

“Personal data” is information that relates to an identifiable person who can be directly or indirectly identified from that information, for example, a person’s name, identification number, location, online identifier. It can also include pseudonymised data.

“Special categories of personal data” is data which relates to an individual’s health, sex life, sexual orientation, race, ethnic origin, political opinion, religion, and trade union membership. It also includes genetic and biometric data (where used for ID purposes).

“Criminal offence data” is data which relates to an individual’s criminal convictions and offences.

“Data processing” is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

C) DATA PROTECTION PRINCIPLES

Under GDPR, all personal data obtained and held by us must be processed according to a set of core principles. In accordance with these principles, we will ensure that:

  1. processing will be fair, lawful and transparent
  2. data be collected for specific, explicit, and legitimate purposes
  3. data collected will be adequate, relevant and limited to what is necessary for the purposes of processing
  4. data will be kept accurate and up to date. Data which is found to be inaccurate will be rectified or erased without delay
  5. data is not kept for longer than is necessary for its given purpose
  6. data will be processed in a manner that ensures appropriate security of personal data including protection against unauthorised or unlawful processing, accidental loss, destruction or damage by using appropriate technical or organisation measures
  7. we will comply with the relevant GDPR procedures for international transferring of personal data

D) TYPES OF DATA HELD

We collect personal information when you book with us or request or use our services. This includes hotel visits, using our websites or apps, or corresponding with us. We may also receive personal data about you from another source. This includes:

  • Personal Identifiers – title, name, marital status, postal and email addresses, postcode, IP addresses and contact telephone numbers. We may also collect the names of those who are part of a group booking where necessary, and the age of children to meet your needs and enable us to confirm any restrictions that may apply to a room booking.
  • Business-to-Business Information – for corporate customers and corporate business leads and contacts: job title, business address and business email address.
  • Transaction Information – payment, reservation and booking details.
  • Customer special requests and feedback including complaints – via call centres, emails and online free text fields.

Third parties that we receive personal data from may include:

  • Travel agents, booking agents, other agents, tour operators and schools.
  • Corporate customers and public information sources such as Companies House or similar registers in the jurisdictions of our operations.
  • Comparison and review websites.
  • Social networks.
  • Market researchers.
  • Marketing service providers and advertising technology providers.
  • Government and law enforcement agencies.
  • Other licensees in accordance with licensing requirements.

E) YOUR RIGHTS

You have the following rights in relation to the personal data we hold on you:

  1. the right to be informed about the data we hold on you and what we do with it.
  2. the right of access to the data we hold on you. More information on this can be found in the section headed “Access to Data” below and in our separate policy on Subject Access Requests”.
  3. the right for any inaccuracies in the data we hold on you, however they come to light, to be corrected. This is also known as ‘rectification’.
  4. the right to have data deleted in certain circumstances. This is also known as ‘erasure’.
  5. the right to restrict the processing of the data.
  6. the right to transfer the data we hold on you to another party. This is also known as ‘portability’.
  7. the right to object to the inclusion of any information.
  8. the right to regulate any automated decision-making and profiling of personal data.

F) RESPONSIBILITIES

In order to protect the personal data of relevant individuals, those within our business who must process data as part of their role have been made aware of our policies on data protection.

G) LAWFUL BASES OF PROCESSING

We acknowledge that processing may be only be carried out where a lawful basis for that processing exists and we have assigned a lawful basis against each processing activity.

Where no other lawful basis applies, we may seek to rely on the clients consent in order to process data. However, we recognise the high standard attached to its use.

We understand that consent must be freely given, specific, informed and unambiguous. Where consent is to be sought, we will do so on a specific and individual basis where appropriate.

H) ACCESS TO DATA

As stated above, clients have a right to access the personal data that we hold on them. To exercise this right, clients should make a Subject Access Request. We will comply with the request without delay, and within one month unless, in accordance with legislation, we decide that an extension is required. Those who make a request will be kept fully informed of any decision to extend the time limit.

No charge will be made for complying with a request unless the request is manifestly unfounded, excessive or repetitive, or unless a request is made for duplicate copies to be provided to parties other than the individual making the request. In these circumstances, a reasonable charge will be applied.

Further information on making a subject access request is contained in our Subject Access Request policy.

I) DATA DISCLOSURES

The Company may be required to disclose certain data/information to a third party. The circumstances leading to such disclosures may include to assist law enforcement or a relevant authority to prevent or detect crime or prosecute offenders or to assess or collect any debt, tax or duty. These kinds of disclosures will only be made when strictly necessary for the purpose.

J) DATA SECURITY

All our employees are aware that hard copy personal information should be kept in a locked filing cabinet, drawer, or safe.

Employees are aware of their roles and responsibilities when their role involves the processing of data. All employees are instructed to store files or written information of a confidential nature in a secure manner so that are only accessed by people who have a need and a right to access them and to ensure that screen locks are implemented on all PCs, laptops, etc., when unattended. No files or written information of a confidential nature are to be left where they can be read by unauthorised people.

Where data is computerised, it has been coded, encrypted or password protected both on a local hard drive and on a network drive that is regularly backed up. If a copy is kept on removable storage media, that media must itself be kept in a locked filing cabinet, drawer, or safe.

K) THIRD PARTY PROCESSING

Where we engage third parties to process data on our behalf, we will ensure, via a data processing agreement with the third party, that the third party takes such measures in order to maintain the Company’s commitment to protecting data.

L) INTERNATIONAL DATA TRANSFERS

The Company does not transfer personal data to any recipients outside of the EEA.

M) REQUIREMENT TO NOTIFY BREACHES

All data breaches will be recorded on our Data Breach Register. Where legally required, we will report a breach to the Information Commissioner within 72 hours of discovery. In addition, where legally required, we will inform the individual whose data was subject to breach.

More information on breach notification is available in our Breach Notification policy.

N) TRAINING

All employees receive training covering basic information about confidentiality, data protection and the actions to take upon identifying a potential data breach.

All employees who need to use the computer system are trained to protect individuals’ private data, to ensure data security, and to understand the consequences to them as individuals and the Company of any potential lapses and breaches of the Company’s policies and procedures.

O) HOW TO CONTACT US WITH ANY QUESTIONS

Please use the below details if you would like to contact us. Our office hours are 9am – 5pm Monday – Friday. Our office is closed on Saturday and Sundays and all UK bank holidays and also for the period between Christmas and New Year.

Deuce Hotels Ltd, Second Floor, 30-40 Museum Street, Warrington WA1 1HU

Tel: 01925 387 127
Email: management@deuce-hotels.com