This website www.therelaishenley.com (“Website”) is made available to you by The Relais Henley Holding Limited, company no. 12871082, whose registered office is at 71 Queen Victoria Street, Floor 8, London, United Kingdom, EC4V 4AY, hereinafter referred to as the “Hotel”, “we” or “us”.
Examples of such information include but are not limited to:
- Contact information, and preferences.
- Information about your use of our hotels, and other services when you stay with us.
- Images of you in areas of our hotels covered by CCTV.
- Conversations you have when you call our hotel reservation, sales or reception teams.
- Information about anyone you’re travelling with or meeting.
- Information about the devices you use to interact with us.
More sensitive information may include, for example, when you tell us about dietary requirements, disabilities and accessibility requirements, religious beliefs. Where you provide us with sensitive information, we will only hold this information with your express permission. This information is stored securely with restricted access and handled with the greatest respect to 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.
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, but is not limited to, when you:
- Book a room online, or via email and/or telephone
- Create, use or manage an online account Sign up to our loyalty/membership programmes
- Visit our website or use our apps
- Fill out our online forms or registration cards
- Visit our hotel or use our hotel services, e.g., room service, gym or spa facilities
- Access the hotel internet
- Use our restaurants, lounges or bars
- Use social media login functionality
- Interact with us in online forums, by email, text, telephone, or on social media
- Post reviews of your stay or interaction with us
- Enter competitions or promotions.
We are only able to use your information if we have a legal reason for doing so. There are a number of legal grounds that enable data processing. Below are the most relevant legal reasons for which we use your information and which you should be aware of:
1) 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.
2) 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.
3) 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 at firstname.lastname@example.org.
4) 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 for at least 12 months and this may be disclosed or made available for inspection by any police officer or as otherwise required by applicable law in connection with the prevention or investigation of crime.
The reason we use your information will often be obvious from the way you interact 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:
- Provide you with the products and services you have requested including administering your booking and responding to your enquiries, complaints or requests.
- Manage our relationship with you.
- Allow you to participate in membership/loyalty programmes.
- Send you market research surveys (only with your consent).
- Tailor our services to your preferences (only with your consent).
- Make decisions about what direct marketing to show you based on how you have interacted with us (only with your consent).
- Improve our products and services online and offline.
- Allow you to interact with us online and offline.
- Monitor the use of our products, services and content.
- Verify your identity.
- Comply with legal obligations on us.
- Detect ad blockers and other technologies that affect the services we provide.
- Send you product or service-related communications.
- Allow social sharing functionality (only with your consent).
- Keep guests safe and ensure the security of our hotels.
- Ensure the acceptable use of our products and services.
- Facilitate payments and credit checks.
- Facilitate the restructuring or sale of the Hotel.
- Investigate and respond to disputes.
- Provide you with help and support where required.
We have secure systems and processes in place to ensure the personal information you provide us is kept safe. We store personal information on our secure electronic systems. Your information may be transferred to one of our reputable cloud-based service providers who may store and process this information outside the European Economic Area (EEA). We can assure you that we take all reasonable steps to ensure your data is handled securely under appropriate agreements with our suppliers. We will retain your information for as long as necessary for the uses set out in this Policy or while there is a legitimate business reason for doing so. If you ask us to delete your information before this time, we may not be able to do so for technical, legal, regulatory or contractual constraints. For example, where you wish to be suppressed from direct marketing, we would need to retain your information for this purpose. Where you ask for your account to be closed, we will do this as soon as possible subject to any terms and conditions relating to the account. Your information will be retained in order to comply with legal and regulatory obligations as well as for analysis, to prevent fraud, collect any monies owed, and to resolve disputes.
3rd Party Data Processors
There may be situations where we use data processors – companies who act on our behalf – to collect your information for us or to use the personal data we pass to them to provide your service. These processors can only use your information in accordance with our instructions and for the purposes in this Policy.
Travel Agents and Booking Partners
We collect information about you when it is provided to us by third parties. This might include online travel agents, travel websites, and other partners. This could be when you make bookings, review your stay online, or where you interact with anyone who promotes our brands. You should always read the privacy policies of travel companies or other third parties you use, as they will use your information in accordance with their own privacy policies. When you, or someone on your behalf, make a booking using a travel agent, booking platform or other third party, to use our services, they may pass us information about your booking, including information about anyone else on that booking. The same would be true where you use a third party to make enquiries about our products or services. Where you interact with third parties who promote our services for us, these third parties may pass us your information. When you post comments, reviews, or engage in discussions and polls about our products and services, we may receive this information from the platform you interacted with or from our partners who monitor how our hotel is performing. We may also obtain information about you from our partners and other companies that have your permission to share your information both online and offline, like insight providers. Sometimes we may want to improve our products and services by getting a better understanding about our customers and their preferences. In these situations, we may ask reputable insight providers to provide us information that may identify you. However, this would only be where you have specifically consented to that third party providing your information to us. Where we do receive information about you from other sources, we may combine it with information we already hold about you and use it in accordance with this Policy. Where we engage with credit reference agencies (for example if you were using our hotel facilities for a business event) we would only do this with your explicit consent.
Profiling and Preferences
We sometimes make decisions about what your interests are based on the way that you interact with us and the information we hold about you. For example, if you regularly stay with us and frequently choose a specific room or pillow type, then we might use this information improve your experience by pre-selecting certain features of your stay for you, so you don’t need to. Understanding your preferences and personalising your experience in this way allows us to deliver the very best service possible.
Do Not Track Signals or Browser/Device Settings
Our websites are not designed to respond to “do not track” signals or browser/device settings. Direct Marketing Where we have your consent, we may send you direct marketing communications about our products, services, events and offers.
communications may be sent by post, email, telephone, SMS and MMS, through social media messages (such as WhatsApp, Instagram, Twitter, and Facebook), including push notifications to your mobile devices, and via other electronic means such as when you visit our websites or use our apps. This may also include any websites and apps of our partners who are in our advertising networks. You will be able to opt-out of direct marketing by following the instructions in the communications you receive.
Product Related Communications
We may use your information to send you newsletters, bulletins, and other communications about your stay including triggered communications where you make changes to your account or other information about products and services you have signed up for. For example, with your consent, we may send you email or text messages about an upcoming stay with us in order to help you plan your visit and give you the best experience possible. Service communications will be sent to you regarding products and services you interact with. These are important messages relating to the products and services we provide to you.
Analysis and Product Development
We may use your information to improve the products and services we offer. For example, we may look at the preferences our guests have when they stay with us to offer more relevant personalisation to customers.
Detecting Ad Blockers
When you visit our website, we may check (by using script, code, cookies or other technical means) if you are using ad-blocker or other privacy tools. If we do detect one of these tools, we may ask you or ask your browser to ask you, if you would give us permission to ignore those settings and continue to serve adverts and/or collect your information using cookies and similar technologies. Information about your device and use of ad blockers may be stored or associated with your device and used to reinsert adverts and to understand how ad blockers and other privacy tools are being used by our visitors.
Linked Services, Third Party Sites and Content
Our website may, from time to time, contain links to other websites which are outside of our control and are not covered by this Policy. We do not accept any responsibility or liability for other sites’ privacy policies. If you access other websites using the links provided, please check their policies before submitting any personal information.
Payments and Credit Checks
Your information may be used to take payment for products and services and may be used to verify credit details related to payments.
Disclosures Required by Law
Your information will be disclosed where we are obliged by law to do so. We may also disclose your information where we are allowed by law to protect or enforce our rights or the rights of others and for the detection and prevention of crimes, such as fraud.
If you post or send offensive or inappropriate content anywhere on or to any of our websites or apps, or otherwise engage in disruptive behaviour on any of our websites or apps, we may use the information that is available to us about you to stop such behaviour. This may involve responding to or informing relevant third parties and law enforcement agencies about the content and your behaviour.
When you complete our registration forms or use our services, we may transfer your information to our processors - companies that carry out activities on our behalf, only on our instructions - outside the European Economic Area (EEA) to countries that may not have data protection rules that provide the same level of protection to your personal information as countries in the EEA. However, we will only transfer your information if we have appropriate measures in place to ensure the protection of your information in accordance with applicable data protection legislation. (For example, model contract clauses or Privacy Shield in the case of the USA). When you give us information about other individuals, you confirm that you have authority to act for them and have made them aware of the potential transfer of their information outside the EEA.
Training and Service Quality
If you contact us by telephone the conversation may be recorded and listened to for training and quality purposes.
Social Media Login
Sharing Personal Information
Where you provide your information to us, we may share it with our commercial partners and suppliers. What sharing takes place will depend on the activity that your information is being used for. Your information will only be shared and used in accordance with this Policy and where an agreement is in place to ensure that your information is protected. We won’t sell your personal information without your consent or share it with other organisations for their own marketing purposes.
Under certain circumstances, you have rights under data protection laws in relation to your personal data as follows:
- 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.
- To 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.
- To 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. It also enables you to request that we 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.
- To object to processing of your personal data where we are relying on a legitimate interest (or those 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.
- To request restriction of processing your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (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.
- To request 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.
- To 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.
If you wish to exercise any of the rights set out above, please contact us at email@example.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. If you wish to exercise any of those rights, we may need to request specific information from you to help us confirm your identity. 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 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 you have made a number of requests. In this case, we will notify you and keep you updated.
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.
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/.
Creation Date: 01 March 2021
Last Amended: 01 March 2021