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Privacy Policy & CSR

Last updated: 14/02/23

Summary

We respect your right to privacy and treat any information you give to us with care. This Privacy Policy describes how we collect, use, share, store or otherwise process the information we hold about you. We are committed to ensuring the personal data you provide is used for the purpose it was collected and is kept secure Your personal information allows us to provide the products and services you have asked for, as well as enabling us to improve those products and services by understanding your interests and preferences. By understanding what you like (and what you don’t) we are able to personalise your experience, show relevant adverts and improve your stay.

Who we are

Clermont Hotel Management Limited (“we”, “our”, “us”) is the data controller when you provide information to any of our brands, including: Thistle, Thistle Express, The Clermont Hotel, and Guoman Hotels.

What information do we collect?

When you interact with our products and services, for example when browsing our website or booking a hotel room, we collect information about you and that particular interaction. Generally, this may include your personal data which means personal details from which you can be identified or are identifiable, for example:

Where you provide us with sensitive details, for example in relation to requirements you may have regarding accessibility to our hotels, we will only hold this information with your express permission. This information is stored securely with restricted access and handled the greatest respect for your privacy. Where you provide information to us about other people, you need to make sure you have their permission to do so or that you can speak on their behalf, for example, in the case of children.

When and how we collect your information

We collect information you provide to us directly and indirectly when interacting with our products and services, including when you stay with us.
This may include when you:

Legal basis for using your information

All organisations need a legal reason to use your personal information, if they don’t have one, they can’t use it. There are a number of legal grounds that enable data processing. It’s quite complicated but below are the most relevant grounds you should be aware of.

With your consent

There are some activities where we process personal information with your consent, for example, where we want to send you marketing messages by email, we would ask your permission first and you could opt-out at any time by clicking on the unsubscribe link on the email or updating your account preferences. We will indicate in the Policy where we rely on consent.

To fulfil a contract

We also process your personal information in order to fulfil a contract we have with you. For example, when you book a stay with us, we will process your information to administer that stay.

For a legitimate interest

Sometimes we may use your information to help achieve our business objectives but only where that activity doesn’t negatively affect your rights. For example, we might use your information to analyse occupancy rates of our hotels and adjust room rates or to send you details of special offers or other information about our hotels. You can object to us relying on our legitimate interest to use your personal data in these ways at any time through your account preferences or by getting in touch with us using the contact details below.

To comply with legal obligations

There may be situations where we need to use your information to comply with legal obligations. For example, we are required by law to keep records of who is in our hotels in case there is an emergency, so we can make sure you’re safe.

How we use your personal information

The reason we use your information will often be obvious from the way you interact with us. For example, if you book a room at one of our hotels, we would use that information to administer your stay with us. However, our uses of your information may not always be so obvious. You can find out more below. When you provide your information to us, we may use it to:

Use of personal information Legal basis for processing (where there is more than one, the exact grounds will depend on the activity - see the section above for an explanation of each)
Provide you with the products and services you have requested, including administering your booking, responding to any enquiries, complaints or requests you may have Consent, Legitimate Interest, Contract
To manage our relationship with you Consent, Legitimate Interest, Contract
Allow you to participate in loyalty programmes Consent, Legitimate Interest, Contract
Send you market research surveys Consent, Legitimate Interest
Tailor our service to your preferences, where you tell us about them Consent, Legitimate Interest, Contract
Make decisions about what direct marketing to show you based on how you have interacted with us Legitimate Interest
Improve our products and services online and offline, including our websites and apps Legitimate Interest
Allow you to interact with us online and offline, in forums, on social media and elsewhere Consent, Legitimate Interest, Contract
Monitor the use of our products and services and content Legitimate Interest, Legal Obligation
Verify your identity Legitimate Interest, Contract
Conduct analysis, system testing and statistical research Legitimate Interest, Legal Obligation
Comply with legal obligations on us Legitimate Interest, Legal Obligation
Detect ad blockers and other technologies that affect the services we provide Consent, Legitimate Interest, Contract
Manage our hotels efficiency, including regulating the use of utilities, lighting and heating based on occupancy Legitimate Interest
Send you product or service related communications, service messages Legal Obligation, Consent, Legitimate Interest, Contract
Send you direct marketing, where you have consented Consent, Legitimate Interest
Allow social sharing functionality Consent, Legitimate Interest, Contract
Keep guests safe and ensure the security of our hotels Legal Obligation, Legitimate Interest
Conduct data matching and audience insight activities Legitimate Interest
Detect ad blockers Legitimate Interest
Ensure the acceptable use of our services Legitimate Interest, Legal Obligation
Facilitate payments and credit checks Legal Obligation, Consent, Legitimate Interest, Contract
Facilitate the restructuring or sale of all or part of our business Legal Obligation, Consent, Legitimate Interest, Contract
Investigate and respond to disputes Consent, Legitimate Interest, Contract
Provide you with help and support where it may be required. For example, we contact you to provide assistance if you do not complete the booking process or experience technical difficulties, where we have your contact details Legitimate Interest, Contract

 

Updating your information

Please ensure you keep your information up to date by logging into your account and modifying it. Alternatively, you can tell us when you check-in that your information has changed and we will update it for you.

Controlling direct marketing

You can change your mind about receiving direct marketing from us or change your preferences by logging into your account, if you have one, opting-out in any marketing or product communication you have received from us or emailing us using the contact details below.

Requesting copies of your information

You may request a copy of your personal information which we may hold about you by getting in touch with us using the contact details below. You may also ask us to correct any inaccuracies in your personal information. This right may be restricted by law where disclosing information may result in the personal information of other individuals being disclosed and it would be unreasonable to do so.

Withdrawing consent

Where we may rely on consent to use your information, you have the right to withdraw that consent for that processing activity at any time by logging into your account, if you have one, opting-out in any marketing or product communication you have received from us or emailing us using the contact details below. However, we may have the right to rely on an alternative legal basis for the processing activity so that we are able to provide you with the product or service you have requested and, in that case, will inform you of that.

Other rights

You may have the right to object, erase, or restrict our processing of your information - for example, where we process your personal information because this is in our legitimate interests, you may object to this. We will carefully consider your request as there may be circumstances which require us to, or allow us to, continue processing your data.

Complaining to the regulator

If you have any comments, concerns or complaints about our uses of your information we would ask that you contact us first, so that we can try and resolve any matter. However, where we are unable to help, you are able to complain to the Information Commissioner’s Office in the United Kingdom or the data protection regulator in your country of residence, who will be able to liaise with the UK Information Commissioner in the UK. Details for the UK Information Commissioner can be found at https://ico.org.uk/

Changes to our Privacy Policy

From time to time we may make changes to this Policy. This might be in relation to changes in the law, best practice, changes to the services we provide or collection and use of your personal information. We will always display clearly when the Policy was last updated and where appropriate, notify you of any relevant changes.

Contact

If you would like to get in touch with us, please contact

By Email: data.protection@clermonthotel.group

By Post: The Data Protection Officer, Clermont Hotel Management Limited, 110 Central Street, London EC1V 8AJ