Herald Hotels Limited respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data, about your privacy rights and how the law protects you.
Please also use the Glossary in paragraph 10 to understand the meaning of some of the terms used in this privacy notice.
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Important information and who we are
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Purpose of this privacy notice
This privacy notice aims to give you information on how Herald Hotels Limited collects and processes your personal data through your use of our website www.heraldhotels.com (website) and through the use of our services, including any data you may provide through the website when you purchase a product or service. We can also collect and process personal data through the contact we have with you (including when you fill out any contact forms on our website), and when we correspond with you via telephone, email and post.
We do not knowingly collect data relating to children.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
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Controller
Herald Hotels Limited is the controller and responsible for your personal data (collectively referred to as “we”, “us” or “our” in this privacy notice).
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Contact details
| Full name of legal entity: |
Herald Hotels Limited
company number 08544246 |
| Person who correspondence should be addressed to in respect of data protection: |
Sir James Devitt |
| Email address: |
James.devitt@heraldhotels.com |
| Postal address: |
Herald Hotels Ltd
4th Floor
26 Farringdon St
London
EC4A 4AB |
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 would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
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Changes to the privacy notice and your duty to inform us of changes
This version was last updated on the date stated at the beginning of this privacy notice.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
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Third-party links on our website
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.
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The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). For the full definition of personal data see paragraph 10.3.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
- Identity Data includes name, username or similar identifier and title.
- Contact Data includes postal address, email address and telephone numbers.
- Technical Data includes internet protocol (IP) address, and other technology on the devices you use to access our website.
- Profile Data includes enquiries made about the properties we are reviewing for you, your interests, preferences, feedback and survey responses, including information received and/or recorded during telephone conversations and meetings.
- Usage Data includes information about how you use our website, products and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
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If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services or goods). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
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How is your personal data collected?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity, Contact [and Financial] Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when:
- apply for our services;
- create an account with us;
- subscribe to our service or publications, including recommendations and information about available properties;
- request marketing to be sent to you; or
- enter a competition, promotion or survey.
- Automated technologies or interactions. When and if you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns and your Usage Data in respect of your use of our website. We collect this personal data by using cookies and other similar technologies. Please see our Cookie Policy, which can be accessed via our website www.heraldhotels.com/cookies-and-how-they-benefit-you for further details.
- Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
- Technical Data from the following parties:
- analytics providers; and
- search information providers,
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Equifax, Experian and Callcredit based inside the EU.
- Identity and Contact Data from data brokers or aggregators including those which specialise in the hotel industry.
- Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside the EU.
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How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
See paragraph 10.2 to find out more about the types of lawful basis that we will rely on to process your personal data.
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us (please see paragraph 1.3 for how to contact us).
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Purposes for which we will use your personal data
We use your personal data in the following ways:
- personal data that you provide to us is used to:
- provide you with the information, products and services that you request from us
- provide you with marketing information in accordance with your marketing preferences (see paragraph 4.2)
- manage and administer our business
- review and improve our service
- personal data that we receive from third parties is combined with the personal data that you provide to us and used for the purposes described above.
- personal data about your use of our website is used to:
- administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes
- to improve our website to ensure that content is presented in the most effective manner for you and for your computer or mobile device
- to allow you to participate in interactive features of our website, when you choose to do so
- to provide support services
- as part of our efforts to keep our site safe and secure
- to make suggestions and recommendations to you and other users of our site about properties that may interest you or them
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How we use your personal data for marketing
We will add your details to our marketing database if:
- you make an enquiry about our services
- you buy our services
- you have indicated to a third party that you would like them to pass us your contact details so that we can send you updates about our services and relevant properties
- you have registered an account with us and have indicated during the sign up process that you are happy to receive marketing communications
We may send you marketing communications by email, telephone or post.
You can ask us to only send you marketing communications by particular methods (for example, you may be happy to receive emails from us but not telephone calls), about specific subjects (for example particular categories or locations of properties) or you may ask us not to send you any marketing communications at all.
We may ask you to indicate your marketing preferences when you first contact us. You can check and update your current marketing preferences at any time by contacting us (see paragraph 1.3 for how to contact us).
We never share your personal data with third parties for marketing purposes.
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Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us (see paragraph 1.3 for how to contact us).
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. If this requires your consent, you are not required to give your consent just because we ask for it.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
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Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes set out in paragraph 4 above.
- External Third Parties
- We may share personal data in accordance with our legitimate interests or legal requirements to third parties such as IT and systems service providers and data security providers, professional advisers, taxation and regulatory authorities, and credit reference agencies.
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
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International transfers
We do not transfer your personal data outside the European Economic Area (EEA).
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Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
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Data retention
How long will you use my personal data for?
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.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
We may also be subject to contractual requirements that specify how long we can keep your personal data for.
In some circumstances you can ask us to delete your data: see request for erasure in paragraph 9.1.3 below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
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Your legal rights
- Under certain circumstances, you have rights under data protection laws in relation to your personal data, these are as follows:
- Request access to your personal data (commonly known as a “data subject access request”):
- This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of your personal data:
- This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data:
- This enables you to ask us to delete or remove personal data 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 data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data:
- You can object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing your personal data:
- This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request transfer of your personal data:
- If requested, we will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Right to withdraw consent:
- You can withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us (please see paragraph 1.3 for how to contact us).
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No fee usually required
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. Alternatively, we may refuse to comply with your request in these circumstances.
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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 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.
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Time limit to respond
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 and keep you updated.
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Glossary
- Controller means, unless otherwise provided by law, the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
- Lawful BasisLegitimate Interest means conducting and managing our business in our interests, or the interests of a third party. Our interests could include, for example, our internal administrative purposes, ensuring network and information security or for direct marketing. Whether a particular legitimate interest may exist can also depend on the relationship we have with you (for example, where you are a customer of ours).We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests or the interests of a third party. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us (please see paragraph 1.3 for how to contact us).
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
- Personal data means any information relating to an identified or identifiable natural person (data subject); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
- Processing means 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.
- Processor means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
