Klarent Privacy Policy

WELCOME TO KLARENT HOSPITALITY PRIVACY POLICY

Klarent Hospitality 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 whenever that information is provided to us. This includes when you, or someone on your behalf, request information from us, contact us (or we contact you), make a booking, use our website(s)/apps, link to or from our website(s)/apps, connect with us via social media, through our contact centre or hotels, or any other engagement we have with you (regardless of where you are based). It also tells you about your privacy rights and how the law protects you.

1. IMPORTANT INFORMATION AND WHO WE ARE

2. THE DATA WE COLLECT ABOUT YOU

3. HOW IS YOUR PERSONAL DATA COLLECTED

4. HOW WE USE YOUR PERSONAL DATA

5. DISCLOSURES OF YOUR PERSONAL DATA

6. INTERNATIONAL TRANSFERS

7. DATA SECURITY

8. DATA RETENTION

9. YOUR LEGAL RIGHTS

1. IMPORTANT INFORMATION AND WHO WE ARE

PURPOSE OF THIS PRIVACY NOTICE

This privacy notice aims to give you information on how Klarent Hospitality collects and processes your personal data in our dealings with you, including in providing accommodation and other services to you, including any data you may provide through our website.

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.

CONTROLLER

This privacy notice is issued on behalf of the Klarent Hospitality so when we mention Klarent Hospitality “, “we”, “us” or “our” in this privacy notice, we are referring to the relevant company in the Klarent Hospitality Group responsible for processing your data. Klarent Hospitality Limited is the controller and responsible for this website.

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

CONTACT DETAILS

Our full details are:

Email address: DPO@Klarenthospitality.com

OR

Postal address:

Data Protection Officer

Klarent Hospitality Limited The Savoy Tower 77 Renfrew Street Glasgow G2 3BZ

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.

CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES

This version was last updated on June 2022.

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.

THIRD-PARTY LINKS

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.

2. 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).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

· Identity Data includes first name, last name, username or similar identifier, , title, date of birth and gender.

· Contact Data includes billing address, home address, email address and telephone numbers.

· Special Requirements Data includes disability and or dietary requirements.

· Financial Data includes payment card details.

· Transaction Data includes details about payments from you and other details of your bookings, stays and other services you have purchased from us.

· Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website/or any apps.

· Profile Data includes your username and password, services provided to you, your feedback and survey responses.

· Marketing and Communications Data includes your preferences as to whether you are happy to receive marketing from us and, if so, your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

In the normal course, we will only collect Special Categories of Personal Data about you, this includes details about your or information about your dietary and health needs and disabilities (“Special Requirements Data”) to the extent that it is volunteered by you or on your behalf and is needed to cater to your requirements during your stay with us or other use of our facilities or services. We may also, however, need to process such information in the event of an accident or a medical or other emergency during your stay or your other use of our facilities.

We do not obtain personal data about children who are booked in to stay at our hotels. We record only the number of children staying in our hotels.

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. In this case, we may have to cancel a service you have with us, but we will notify you if this is the case at the time.

3. 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, via this website/apps, on social media or otherwise. This includes personal data you provide when you:

· Make a booking at one of our hotels, whether for overnight stays, functions or conferences.

· Check in to one of our hotels.

· Attend a function, conference or otherwise use the facilities at one of our hotels.

· Create an account on our website.

· Sign up to our Loyalty/Rewards scheme.

· Subscribe to our newsletter and/or other publications.

· Request a brochure or other promotional or marketing materials to be sent to you.

· Enter a competition, or respond to a promotion or survey.

· Give us some feedback.

· Automated technologies or interactions. As you interact with our website/apps or via social media, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.

· Third parties acting on your or your employer’s behalf. We may receive personal data about you if a booking is made for you by another person, who may be a family member or travelling companion, or a travel agent or other intermediary, working for you or, where you are travelling on business, your employer or other third party on your behalf.

· Other third parties or publicly available sources. We may receive personal data about you from various third parties and public sources. For example:

· Technical Data from analytics providers such as Google based outside the EU.

· analytics providers such as DoubleClick and Google based outside the EU.

4. 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.

· In the case of any accident or a medical or other emergency, to protect your or another individual’s vital interests, where you or they are not able to give consent.

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to:

· Sending direct marketing communications to you.

· Information about your health, any disabilities and dietary requirements that you volunteer to us to enable us to accommodate your needs during your stay.

You have the right to withdraw consent at any time by contacting us by contacting us at DPO@klarenthospitality.com.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please Contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

5. DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the categories of parties set out below for the purposes set out in the table in paragraph 4 above.

• Other companies in the Klarent Hospitality Group based within the European Economic Area involved in providing services to you, whether directly or providing underlying infrastructure services.
• External third parties, including:
• Business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you. These include contractors who provide services provided to you such as Wi-Fi, providers of our call centre services, the system through which travel agents make bookings, as well as the providers of our IT infrastructure.
• Analytics and search engine providers that assist us in the improvement and optimisation of our services and website.
• Professional advisers, including lawyers, banks, auditors and insurers.
• HM Revenue and Customs, regulators and other authorities.
• Entities involved in credit checking and anti-fraud activities, crime prevention/detection, risk assessment and management and dispute resolution.
• If you visit Klarent Hospitality as part of a group event or meeting, information collected for meeting and event planning may be shared with the organizers of those meetings and events, and, where appropriate, guests who organize or participate in the meeting or event.
• Third parties 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.

Where these third parties are our processors, we require them to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party processors 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.  Some of the third parties mentioned above, for example many professional advisers and HM Revenue and Customs, are controllers who, like us, are subject to specific obligations under data protection law, and who will have their own privacy notices setting out how they deal with personal data.

Where there are health clubs in our hotels, these are operated by a separate third party company.  They are an independent controller, so they too will have specific obligations under data protection law and their own privacy notice.

6. INTERNATIONAL TRANSFERS

We share your personal data within the Klarent Hospitality Group. All companies in the Group are currently based in the European Economic Area (EEA).

Though we do not seek actively to transfer personal data outside the EEA, some of the external third parties we deal with are based outside the EEA or process personal data outside the EEA, so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we look to ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• Transferring your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.  We do this (for example) in connection with our providers for booking through travel agents [(the US)].
• Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

7. 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. Processors we appoint 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.

8. 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 seven years after the transition in question. We also need to keep information for that period to be able to deal with any dispute.

In some circumstances you can ask us to delete your data: see Request erasure 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.

9. YOUR LEGAL RIGHTS

You have the right to:

• 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 the personal data that we hold about you. 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 where we are relying on our 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 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 of your personal data. This enables you to ask us to suspend the processing of your personal data in the following situations: (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 the transfer of your personal data to you or to a third party. 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.

• 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.

If you wish to exercise any of the rights set out above, please contact our DPO at DPO@Klarenthospitality.com

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.