This Privacy Statement applies to the processing by Peel Hotels Ltd of your (our guests) personal data. Peel Hotels Ltd takes your privacy very seriously and treats all your personal data with great care. Peel Hotels Ltd acts in accordance with the applicable data protection legislation.
When you visit our website (or subdomains) (the “Website”), make a reservation, contact us, purchase products from us or visit one of our properties, we collect information from and about you. Some of the information we collect may be classed as personal data under data protection legislation, that is, “any information relating to an identified or identifiable natural person”.
This Privacy Statement describes which personal data is collected and for which purposes this personal data is processed by Peel Hotels Ltd. It also states which rights you have under applicable data protection legislation.
We will act as “controller” in respect of your personal data processed by us or on our behalf. Where we engage a third party to process your personal data on our behalf, that third party will be “processor” and will act in accordance with our instructions and in compliance with applicable data protection legislation.
Anyone processing personal data for us or on our behalf must comply with the following principles which state that personal data must be:
- processed lawfully, fairly and transparently - lawfulness, fairness and transparency.
- collected for specified, explicit and legitimate purposes and not processed in a manner incompatible with those purposes - purpose limitation.
- adequate, relevant and limited in relation to those purposes - data minimisation.
- accurate and, where necessary, up to date - accuracy.
- not kept for longer than necessary for those purposes - storage limitation.
- processed with appropriate security, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage - integrity and confidentiality.
We must also be able to demonstrate that we comply with these principles - accountability.
PARTICULARLY IMPORTANT INFORMATION
WHO WE ARE: For the purpose of applicable data protection legislation, the data controller of your personal data is Peel Hotels Ltd, 7th Floor, 20 St Andrew Street, London EC4A 3AG
DATA PROTECTION CONTACT: Our Data Protection Administrator can be contacted at firstname.lastname@example.org .
MUST READ SECTIONS: We draw your attention in particular to the sections entitled “International Data Transfers” and “Your Rights.”
2. COLLECTING YOUR PERSONAL DATA
Peel Hotels Ltd collects information about you in the following ways.
Information you give to us. This includes personal data collected:
- Through our Website when you register, login, commence or complete an online transaction to use our products and services.
- When you contact our reservations team to make a booking or use the facilities at any of our properties.
- When you have provided your consent, in order to:
- sign up to any of our loyalty programmes;
- subscribe to any of our marketing communications
- complete customer surveys, enter competitions or provide feedback.
- When we do business with you, which will usually include:
- Contact details including name and address (including business details if you are making a corporate booking), telephone and email details.
- If you have special requirements then it may also be necessary to collect details about diet or disability or any other preferences that you may have.
- Car parking arrangements at our properties may also make it necessary for us to collect your car registration number for your visit to us.
- We collect payment card information from you should you choose to use this form of payment for purchasing or guaranteeing use of our products and services.
- We may also (with your consent) collect your birthdate and other significant dates for making special offers to you around your birthday and other anniversaries.
- For our overseas guests, we may also collect passport details.
Information Automatically Collected. This includes information and personal data collected:
- Through CCTV at our properties. We operate CCTV systems (including video and image recording) at our properties. This activity is carried out in the interest of security for all our clients and staff and for the better management of Peel Hotels Plc’s properties and services.
- Special categories of personal data – Further restrictions apply to special categories of personal data including race, ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, health, sex life and sexual orientation, and criminal convictions. We will not process these kinds of personal data unless we can meet the necessary requirements for doing so.
3. WHY DO WE PROCESS YOUR PERSONAL DATA?
Regardless of which Peel Hotels Ltd property that you visit, your personal data will be stored in (i) centralised systems which are under the control of Peel Hotels Ltd and accessible by authorised staff of Peel Hotels Ltd or our service providers, and (ii) some local systems controlled solely by the relevant Peel Hotels Ltd property.
We use the information we collect about you to process your bookings, answer your queries, process your gift card purchases, provide our hotel and restaurant facilities and services (including hotel rooms, meeting rooms, spas, bars, restaurants, function rooms and guest Wi-Fi), enable you to manage your website user account and provide loyalty programmes. With your consent (which you will always be free to grant, withhold or withdraw at any time), we may contact you via our marketing and sales channels (email/ phone/SMS/ post) about other related products and services we, or our group business, provide which we think may be of interest to you. In certain circumstances we may assume that current and recent customers have consented to receiving such marketing communications by email or SMS provided we offer an unsubscribe or opt-out option each time.
We mainly collect, store and process personal data at two different stages: (i) when you have contacted us in advance of deciding to visit one of our properties and (ii) when you visit, or have visited, one of our properties.
i. Before you decide to visit one of our properties
When you visit our Website (www.peelhotels.co.uk), we collect information about your use of the Website. This includes both information we collect directly from you, and information we collect about your behaviour. This information may constitute 'personal data' under applicable law. We may use this information to provide you with (personal) offers, We do not share visitor data with any third party advertisers.
ii. When you visit or have visited one of our properties
When you make a reservation, you will have to provide us with your name, email address, phone number, the dates you are staying with us and a credit card token or other payment information as applicable. We use this personal data to process the reservation, for billing purposes, and to allow us to communicate with you about your reservation. When you stay in one of our properties, we will collect personal data about your preferences, use of our services, and location.
Overview of activities under stage (i) and (ii):
We may at each of the stages outlined above use your personal data but only when and to the extent 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.
- Where you have provided your consent.
We will take all appropriate technical and organisational measures to prevent unlawful or unauthorised processing of, and accidental loss of or damage to, personal data.
We will ensure we put in place adequate procedures and technologies to maintain the security of all personal data from the point of collection to the point of destruction. Personal data will only be transferred to a “processor” in accordance with equivalent procedures and policies.
4. SHARING YOUR DATA
We may share your personal data as follows:
- Third Parties Designated by You. We may share your personal data with third parties where you have provided your consent to do so.
- Our Third Party Service Providers. We may share your personal data with our third party service providers who provide services such as payment processing, information technology and related infrastructure provision, business support (operational and administrative), customer service, the processing and delivery of marketing communications to you, email delivery, auditing and other similar services. These third parties are only permitted to use your personal data to the extent necessary to enable them to provide their services to us. They are required to follow our express instructions and to comply with appropriate security measures to protect your personal data. Third parties are subject to confidentiality obligations and may only use your personal data to perform the necessary functions and not for other purposes.
- Affiliates. We may share some or all of your personal data with our affiliates e.g. to the extent necessary to enable them to provide their services to us, in which case we will require our affiliates to comply with this Privacy Statement. In particular, you may let us share personal data with our affiliates where you wish to receive marketing communications from them.
- Corporate Restructuring. We may share personal data when we do a business deal, or negotiate a business deal, involving all or a part of our business or assets. These deals can include any sale, merger, financing, acquisition, or bankruptcy transaction or proceeding.
- Other Disclosures. We may share personal data as we believe necessary or appropriate: (a) to comply with applicable laws; (b) to comply with lawful requests and legal process, including to respond to requests from public and government authorities to meet national security or law enforcement requirements; (c) to enforce our Privacy Statement; and (d) to protect our rights, privacy, safety or property, and/or that of you or others.
We do not share your data with any third parties outside the above processing arrangements and we do not share your data with any business external to our group for their own marketing purposes. From the data we collect, you should only ever receive marketing communications from our own brands and hotels.
5. INTERNATIONAL DATA TRANSFERS
In some instances it is necessary to transfer your personal data overseas. Any transfers will be made in full compliance with all aspects of the applicable regulations.
For many of our business purposes we use cloud based services. Therefore, for technical and organizational reasons, it may be necessary that your personal data is transferred to servers located in in the US, or to servers located in countries outside of the UK or the EEA. When we transfer the data to a country outside of the UK or the EEA that does not offer an adequate level of data protection, we will ensure compliance with applicable law by way of EU Model Clauses, EU-US Privacy Shield-certification, or other legally accepted safeguards, as applicable.
6. YOUR RIGHTS
The GDPR provides the following rights for individuals:
Right to revoke consent
If we process personal data on the basis of your consent, you have the legal right to revoke such consent at any time. We will then cease the relevant processing activity going forward unless we are required and permitted to continue under another legal justification.
Right of access to your information
If you want to know what personal data we have collected or process about you, you may request us to provide a copy of your personal data by sending an email to email@example.com. We will ask you to identify yourself. We will not provide you with a copy of your personal data to the extent that the rights and freedoms of others are or may be adversely affected.
Right to rectification and erasure of data, and restriction of processing
If you believe that our processing of your personal data is incorrect, inaccurate, unlawful, excessive, incomplete, no longer relevant, or if you think that your data is stored longer than necessary, you may ask us to change or remove such personal data or restrict such processing activity, by sending an email to firstname.lastname@example.org.
Right to data portability
You have the right to receive your personal data, which you have provided to us, in a structured, commonly used and machine-readable format, in accordance with Article 20 of the General Data Protection Regulation.
Right to object
You have the legal right to object, on grounds relating to your particular personal situation, at any time to processing of your personal data. Furthermore, you have the right to object at any time to our processing of your personal data for direct marketing purposes or to profiling. You can do this by either (i) opting out by using the option we provide in the relevant direct marketing message (e.g. an email newsletter), or (ii) by sending an email to email@example.com, or (iii) writing to:
Customer Service Team
Peel Hotels Ltd
C/O Midland Hotel
Bradford BD1 4HU
For the sake of clarity: without prejudice to the foregoing we are at all times entitled to send you messages that do not constitute direct marketing, i.e. service messages.
Right of information
General information relevant for all requests and queries
Nothing in this Privacy Statement is intended to provide you with rights beyond or in addition to your rights as a data subject under applicable mandatory data protection law.
We will use reasonable endeavours to respond to your request or query within one month. We are entitled to extend this term by another two months if the complexity of the situation so requires. If your request is manifestly unfounded or excessive we may either (i) charge you a fee, or (ii) refuse to process your request. With respect to access requests we may also charge you for extra copies. If we decide not to honour your request or answer your query, we will explain our reasons for doing so in our reply.
7. PROTECTION AND STORAGE OF YOUR DATA
We have used and will continue to use reasonable endeavours to protect your personal data against loss, alteration or any form of unlawful use. Where possible, your personal data will be encrypted and stored on a virtual private server that is secured by means of state of the art protection measures. A strictly limited amount of people have access to your personal data.
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.
9. RETENTION OF INFORMATION
We will only retain your personal data for the period necessary to fulfil the purposes outlined in this Privacy Statement. This may be up to seven years, unless a longer retention period is required or permitted by law (which is typically the case in the context of our obligations under tax law).
Should you choose to unsubscribe from our mailing list, please note that your personal data may still be retained on our database for other purposes and/or as otherwise permitted by law.
We are committed to resolve any complaints about our collection or use of your personal data. In case you have any questions in relation to this Privacy Statement or our practices in relation to your personal data you may send an email to firstname.lastname@example.org. We hope to resolve any complaint brought to our attention, however if you feel that your complaint has not been adequately resolved, you reserve the right to contact your local data protection supervisory authority, which for the UK, is the Information Commissioner’s Office.
We have done our best to make sure that this Privacy Statement explains the way in which we process your personal data, and rights you have in relation thereto. We may change this Privacy Statement from time to time to make sure it is still up to date and we will notify you if we make any material updates. We may also notify you in other ways from time to time about the processing of your personal information.
While every effort is made to ensure that the information contained in this site is correct, Peel Hotels Ltd makes no warranty express or implied as to the nature or accuracy of any such material to the extent permitted by applicable law. Some of the photographs displayed on this site are for example purposes only and do not represent work carried out by Peel Hotels Ltd.
Peel Hotels Ltd may make changes to any content and information contained on this site, at any time without notice. By using this website you assume the risk that the information on this website may be incomplete, inaccurate, out of date or may not meet you requirements. Use of this site constitutes your acceptance of these Terms and Conditions.
The legal ownership and any copyright or other intellectual property rights in the site and its design, text, graphics, software and all other material on the site belong to Peel Hotels Ltd or its agents at all times, unless otherwise stated.
You may only download material or view and/or print a single hard copy for private or non-commercial use and no part of the site or its material shall otherwise be produced, transmitted or made available on a network without the prior written permission of Peel Hotels Ltd.
Any framing of or linking to this site is prohibited without the prior written permission of Peel Hotels Ltd. Peel Hotels Ltd is not responsible for the content or reliability of any websites linked to from its site
While Peel Hotels Ltd endeavours to ensure that this site is normally available 24 hours a day, we shall not be liable if for any reason this site is unavailable at any time or for any period. Access to this site may be suspended temporarily and without notice in the case of system failure, maintenance or repair or for reasons beyond our control.
Peel Hotels Ltd shall not be liable for any loss of income profits goodwill data contracts or any type of special indirect or consequential loss arising from the use inability to use or misuse of this site or any linked sites. Peel Hotels Ltd does not warrant that this site or the server that makes it available are free of viruses or other harmful components.
The contents and use of this site are governed by English Law.
TERMS OF BUSINESS
For further information on 'Terms of Business' please contact Peel Hotels Ltd by post at Peel Hotels Ltd, 19 Warwick Avenue, London W9 2PS.
Peel Hotels Ltd registered in England and Wales, Company Registration No: 03473990. Registered for VAT number 865 5146 05. Registered Office Address: C/O Thrings Llp, 20, St. Andrew Street, London, England, EC4A 3AG. Trading Address: Peel Hotels Ltd, 19 Warwick Avenue, London W9 2PS.