Updated May 2018
Outlined in this policy are full, and we hope transparent details of whatpersonal data (information that can be used to identify a person be it name,address, email, IP address or credit card etc) we collect and store about ourcurrent customers, past customers and potential customers along with details onhow we use that data and who we share it with.
Personal Information (thecollection, purpose and legal grounds for processing)Thisrefers to any information capable ofidentifying an individual. It does not include anonymised data.
All personal information that we hold on you istreated as highly confidential and every effort is made to ensure it issecurely stored and safeguarded under the new terms of the General DataProtection Regulation 2018 that replaces the UK Data Protection Act 1998.It is very important thatthe information we hold about you is accurate and up to date. Please let usknow if at any time your personal information changes by emailing us at email@example.com.
We will use any information we have on you, whetherit has been collected through you having been a customer or signing up to ourwebsite or simply viewing our website (subject to the cookies you haveconsented to us storing on you), to do the following:
We will never rent, sell or share your name orcontact details with any other organisation outside of the KaleidoscopeCollection.
We may process thefollowing categories of personal data about you:
· Communication Data that includes any communication that yousend to us whether that be through the contact form on our website, throughemail, text, social media messaging, social media posting or any othercommunication that you send us. We process this data for the purposes ofcommunicating with you, for record keeping and for the establishment, pursuanceor defence of legal claims. Ourlawful ground for this processing is our legitimate interests which in thiscase are to reply to communications sent to us, to keep records and toestablish, pursue or defend legal claims.
· Customer Data that includes data relating to any purchasesof goods and/or services such as your name, title, billing address, deliveryaddress email address, phone number, contact details, purchase details and yourcard details. We process this data to supply the goods and/or services you havepurchased and to keep records of such transactions. Our lawful ground for this processingis the performance of a contract between you and us and/or taking steps at yourrequest to enter into such a contract.
· User Data that includes data about how you use ourwebsite and any online services together with any data that you post for publicationon our website or through other online services. We process this data tooperate our website and ensure relevant content is provided to you, to ensurethe security of our website, to maintain back-ups of our website and/ordatabases and to enable publication and administration of our website, otheronline services and business. Our lawful ground for this processing is ourlegitimate interests which in this case are to enable us to properly administerour website and our business.
· Technical Data that includes data about your use of ourwebsite and online services such as your IP address, your login data, detailsabout your browser, length of visit to pages on our website, page views andnavigation paths, details about the number of times you use our website, timezone settings and other technology on the devices you use to access ourwebsite. The source of this data is from our analytics tracking system. Weprocess this data to analyseyour use of our website and other online services, to administer and protectour business and website, to deliver relevant website content andadvertisements to you and to understand the effectiveness of ouradvertising. Our lawful ground for thisprocessing is our legitimate interests which in this case are to enable us toproperly administer our website and our business and to grow our business andto decide our marketing strategy.
· Marketing Data that may include data about your preferences inreceiving marketing from us and your communication preferences. We process thisdata to enable you to partake in our special offers and promotions, receive anynews that may be of interest to you based on a previous purchase or enquiry, toallow us to deliver relevant website content and advertisements to you andmeasure or understand the effectiveness of this advertising. Our lawful ground for this processing is ourlegitimate interests which in this case are to study how customers use ourproducts/services, to develop them, to grow our business and to decide ourmarketing strategy.
We may use Customer Data, User Data, Technical Dataand Marketing Data to deliver relevant website content and advertisements toyou (including Facebook adverts or other display advertisements) and to measureor understand the effectiveness of the advertising we serve you. Our lawfulground for this processing is legitimate interests which is to grow ourbusiness. We may also use such data to send other marketing communications toyou. Our lawful ground for this processing is also legitimate interests (namelyto grow our business).
We may receive data from thirdparties such as analytics providers such as Google based outside the EU,advertising networks such as Facebook based outside the EU, as well as usingthird parties that provide us with a platform to offer our guests/customersadditional services eg. gift voucher sales, subscribe options and paymentgateways.
Marketing communications Ourlawful ground of processing your personal data to send you marketingcommunications is either your consent or our legitimate interests (namely togrow our business). (Under the Privacy andElectronic Communications Regulations - PECR, we may send you marketing communications fromus if (i) you made a purchase or asked for information from us about our goodsor services or (ii) you agreed to receive marketing communications, and in eachcase, you have not opted out of receiving such communications since. Underthese regulations, if you are a limited company or the soft ‘Opt-in’ rule isapplied (the marketing is in line with similar products or services previouslypurchased/of interest), we may send you marketing emails without your consentproviding the option to ‘Opt-out’ is also included.
You can also ask us to stopsending you marketing messages at any time by simply getting in touch with thehotel by telephone, email or via the contact form on our website.Alternatively, as outlined above, there is an ‘Unsubscribe’ link on everymarketing message that we send out.
If you opt out of receivingmarketing communications this opt-out does not apply to personal data providedas a result of other transactions, such as hotel room bookings, dinnerreservations or spa appointments.
Disclosures of yourpersonal dataWe may have to share yourpersonal data with the parties set out below:
• Service providers whoprovide IT, system administration and marketing services.
• Professional advisersincluding lawyers, bankers, auditors and insurers
• Government bodies thatrequire us to report processing activities.
We require all thirdparties to whom we transfer your data to respect the security of your personaldata and to treat it in accordance with the law. We only allow such thirdparties to process your personal data for specified purposes and in accordancewith our instructions.
Data SecurityWe have and will continueto review security measures that we have in place to prevent your personal datafrom being accidentally lost, used, altered, disclosed, or accessed withoutauthorisation. We also allow access toyour personal data only to those employees and partners who have a business needto know such data. They will only process your personal data on ourinstructions and they must keep it confidential.
We have procedures in placeto deal with any suspected personal data breach and will notify you and anyapplicable regulator of a breach if we are legally required to.
Data retentionWe will only retain yourpersonal data for as long as necessary to fulfil the purposes we collected itfor, including for the purposes of satisfying any legal, accounting, orreporting requirements.
When deciding what thecorrect time is to keep the data for we look at its amount, nature andsensitivity, potential risk of harm from unauthorised use or disclosure, the processing purposes, ifthese can be achieved by other means and legal requirements.
For tax purposes the lawrequires us to keep basic information about our customers (including Contact,Identity, Financial and Transaction Data) for six years after they stop beingcustomers.
Your legal rightsUnder data protection lawsyou have rights in relation to your personal data that include the right torequest access, correction, erasure, restriction, transfer, to object toprocessing, to portability of data and (where the lawful ground of processingis consent) to withdraw consent.
If you wish to exerciseany of the rights set out above, please email us firstname.lastname@example.org.
You will not have to pay afee 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, or refuse to comply with your request in thesecircumstances.
We may need to requestspecific information from you to help us confirm your identity and ensure yourright 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 anyperson who has no right to receive it. We may also contact you to ask you forfurther information in relation to your request to speed up our response.
We try to respond to alllegitimate requests within one month. Occasionally it may take us longer than amonth if your request is particularly complex or you have made a number ofrequests. In this case, we will notify you.
Third-party linksOur website may includelinks to third-party websites, plug-ins and applications. Clicking on thoselinks or enabling those connections may allow third parties to collect or sharedata about you. We do not control these third-party websites and are notresponsible for their privacy statements. When you leave our website, weencourage you to read the privacy notice of every website you visit.
Whilst the procedures we have in place are designedto protect and secure all personal information we have stored on our databasesystem, we cannot be held liable for any unauthorised access to the data youprovide via our website.
Please be aware that we will provide yourinformation if requested by any legal authority, such as the police or a courtof law.
NB. If you are a supplier or anemployee please contact the hotel directly for further details on how your datais collected, stored, used and shared.
18-19 Pulteney Road Partof the Kaleidoscope Collection
Bath BA2 4EZ
The County is situated just a gentle stroll from Bath Spa's "World Heritage Site" attractions, with splendid views over the city's famous Recreation Ground, Bath Abbey and beyond.