Privacy Policy
Privacy Policy
Welcome to the Heeton UK’s privacy notice
Heeton 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.
- Important Information and who we are
- The data we collect about you
- How your personal data is collected
- How we use your personal data
- Disclosures of your personal data
- International transfers
- Data security
- Data retention
- Your legal rights
- Monitoring
Important information and who we are
Purpose of this privacy notice
This privacy notice aims to give you information on how Heeton 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 Heeton UK so when we mention Heeton", "we", "us" or "our" in this privacy notice, we are referring to the relevant company in the Heeton UK responsible for processing your data. Heeton Hospitality (UK) 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 website’s ‘Contact Us’ option.
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 8th May 2018
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.
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 for any purpose. 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.
Children’s Policy
We do not obtain personal data about children who are booked in to stay at our hotels. We only record the number of children staying in our hotels for our financial data and to comply with Fire Health & Safety Laws.
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.
How your personal data is 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; or
- 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. Please see Cookie usage and storage for further details.
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 or advertising providers such as TravelClick, etc, and Google based ones outside the EU.
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 or have entered 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.
Purpose 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 |
Type of data |
Lawful basis for processing including basis of legitimate interest |
|
To make a booking including reserving disability adapted accommodation |
(a) Identity
(b) Contact |
To enter a contract with you or perform our contract with you
Your explicit consent (disability requirements) |
|
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 |
(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and Communications |
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) |
|
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 |
(b) Contact
(c) Profile
(d) Marketing and Communications |
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)
|
|
To administer and protect our business including our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) |
(a) Identity
(b) Contact
(c) Technical |
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 UK restructuring exercise)
Necessary to comply with a legal obligation |
|
To deliver relevant website content and promotional information to you and measure or understand the effectiveness of our marketing |
(a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications
(e) Technical |
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) |
|
To use data analytics to improve our website, services, marketing, customer relationships and experiences |
(a) Technical |
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) |
|
To make suggestions and recommendations to you about our services that may be of interest to you |
(a) Identity
(b) Contact
(c) Technical
(d) Profile |
Necessary for our legitimate interests (to develop our products/services and grow our business) |
|
To deal with an accident or medical or another emergency |
(a) Identity (b) Special Requirements/ Special Categories of Personal Data |
To protect your or another individual's vital interests
|
|
To deal with issues, complaints or disputes arising out of our relationship with you, and to prevent or detect crime, including fraud |
(a) Identity
(b) Financial
(c) Technical
(d) Profile
(e) Special Requirements |
To establish, exercise or defend legal claims |
When we refer to legitimate interests, we mean the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. 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. 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).
We do not undertake automated decision making using your personal data.
Marketing/promotional offers
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
Where you have agreed to receive it, we may use your Identity, Contact, Technical and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you.
We will not share your personal data with any company outside the Heeton UK of companies for marketing purposes without your express consent.
You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by Contacting us at any time.
Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.
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.
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.
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.
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 Heeton UK 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 service, 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 Heeton as part of a UK 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 3D Leisure. They are an independent controller, so they too will have specific obligations under data protection law and their own privacy notice.
International Transfers
We share your personal data within the Heeton UK. All companies in the UK 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, this data is processed in 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.
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.
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 must 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.
Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
• Request access to your personal data.
• Request correction of your personal data.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer of your personal data.
• Right to withdraw consent.
If you wish to exercise any of the rights set out above, please Contact us .
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.
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 enable us to deal with your request or to speed up our response.
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 we have received several requests. In this case, we will notify you and keep you updated.
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. We will advise you if this is the case at the time you withdraw your consent.
Monitoring
We may monitor and/or record:
(a) telephone calls.
(b) transactions and activities at all points of contact]
(c) web, social media and app traffic and activities
These are to ensure that we carry out your instructions accurately, for training purposes and to improve our services, and to ensure security and prevent fraud. For the greater security of our guests and patrons, and to prevent and detect crime, we use CCTV in and around our premises. Contact us to obtain information about our use of CCTV.
Cookies policy
This cookies policy describes the way in which Heetoninns.com ("Site") operated by Heeton stores or accesses information on the device that you use to access the Site.
By using the Site, you are providing your consent to Heeton storing and using cookies in accordance with this cookies policy. However, you can adjust the settings on the browser you use to view the Site to remove or limit the types of cookies that it accepts. More information about this is set out in the section "Managing Cookies" below.
What are Cookies?
Cookies are small text files that are placed on your computer, mobile or another device that you are using to access that website, so that the website can remember and identify
it. They contain anonymous information and will typically include the name of the domain from which the cookie has come; the "lifetime" of the cookie; and a value, usually a randomly generated unique number.
They are widely used to make websites work, or work more efficiently, as well as to provide aggregate information to the owners of the site about their usage. For example, they enable a website to identify that when you move from one page to another you are not treated as a new user and so do not need to log on again. We also use cookies to help make your use of the Site clear and easy, to help improve the content of the Site and to personalise your visit.
Some websites will also use cookies to enable them to target their advertising or marketing based for example, on your location or browsing habits.
Cookies can be set by the owner of the website itself ("first party cookies") or by other websites that provide content (such as advertising) for the website that you are viewing ("third party cookies").
To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org.
How the Site uses Cookies
We may send a cookie which may be stored by your browser on your computer's hard drive. We may also use that information to recognise your computer when you visit our Site, and to personalise our Site for you.
Some cookies used on the Site are temporary and remain on your device until you leave the Site, at which point they are deleted. These are often called session cookies. Session cookies are typically used on the Site to allow you to carry information across pages of the Site and avoid having to re-enter information, and to allow you to access stored information whilst you are logged into a user account on the Site.
Other cookies used on the Site remain on your device once you have left the Site (though how long will depend on the lifetime of the specific cookie). These are often called persistent cookies. Persistent cookies are typically used on the Site to help it recognise your device when you return to it, and to help us improve the structure of the Site by compiling anonymous, aggregated statistics that allow us to understand how users use the Site.
The cookies used by the Site can be grouped into three categories.
Strictly necessary cookies. These are cookies that are required for the operation of the Site. They allow our web servers to respond to your actions on the Site and whilst browsing it. The Site will not work for you without these cookies.
Analytical cookies. These cookies allow us to see how visitors move around the Site when they are using it. This helps us to improve the way the Site works, for example, by ensuring that users are finding what they are looking for easily, and to analyse the effectiveness of our marketing campaigns.
Functionality cookies. These are used to recognise you when you return to the Site to remember your preferences, and also allow us to provide certain aspects of the Site's functionality.
To see a list of the cookies we use on the Site and what we use them for, please visit Cookie Setting. We may, from time to time, update or modify our cookies. If we do, we will update this list.
Managing Cookies
Disabling and Enabling Cookies
Most browsers allow you to refuse to accept cookies. Your browser may have a Help section or some other form of instructions which should explain how to do this. If you are using a smartphone, then the manufacturer should have instructions on its website explaining how to do this. Useful guidelines on how to do this for several popular computer browsers can be found on the ICO
Website. [www.ico.org.uk/for_the_public/topic_specific_guides/online/cookies].
Please note that if you do disable any cookies, this will have a negative impact upon the usability of many websites, including this one.
You can manage the cookie settings in the Cookie Settings section of your browser.