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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.

Purpose/Activity

To make a booking including

reserving disability adapted

accommodation

 

To provide accommodation

and other services to you

including meeting your

specific health, disability and

dietary requirements, and to

collect and recover money

owed to us

 

To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey, or participate in a prize draw or competition

 

To administer and protect our

business including our

website (including

troubleshooting, data

analysis, testing, system

maintenance, support,

reporting and hosting of data)

 

To deliver relevant website

content and promotional

information to you and

measure or understand the

effectiveness of our

marketing

 

To use data analytics to improve our website, services, marketing, customer relationships and experiences

 

To make suggestions and recommendations to you about our services that may be of interest to you

 

To deal with an accident or medical or other emergency

 

To deal with issues, complaints or disputes arising out of our relationship with you, and to prevent or detect crime, including fraud

Type of data

(a) Identity
(b) Contact

 

 


(a) Identity

(b) Contact

(c) Financial

(d) Transaction

(e) Marketing and Communications

 

 

(a) Identity

(b) Contact

(c) Profile

(d) Marketing and Communications

 

(a) Identity

(b) Contact

(c) Technical

 

 

 

 

 

(a) Identity

(b) Contact

(c) Profile

(d) Marketing and Communications

(e) Technical

 

 

(a) Technical

(a) Identity
(b) Contact
(c) Technical
(d) Profile

 

(a) Identity (b) Special Requirements/Special Categories of Personal Data

(a) Identity
(b) Financial
(c) Technical
(d) Profile
(e) Special Requirements

Lawful basis for processing including basis of legitimate interest

To enter into a contract with you or perform our contract with you
Your explicit consent (disability requirements)

Performance of a contract with you
Necessary for our legitimate interests (to recover debts due to us)
Your explicit consent (for processing health, disability and dietary requirements)

Performance of a contract with you
Necessary to comply with a legal obligation
Necessary for our legitimate interests (to keep our records updated and to study how customers use our services)

Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
Necessary to comply with a legal obligation

Necessary for our legitimate interests (to study how customers use our services, to develop them, to grow our business and to inform our marketing strategy)

Necessary for our legitimate interests (to define types of customers for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

Necessary for our legitimate interests (to develop our products/services and grow our business)

To protect your or another individual’s vital interests

 

To establish, exercise or defend legal claims