1. Important information and who we are
2. The data we collect about you
3. How your personal data is collected
4. How we use your personal data
5. Disclosures of your personal data
6. Data security
7. Data retention
8. Your legal rights
1. Important information and who we are
Our website is not intended for children and we do not knowingly collect data relating to children.
Ashdale Hotels Limited is a limited company which owns and operates 3 hotels in the UK, Ashdale Hotels is the collective term for the business operation of these hotels.
Our full details are:
Full name of legal entity: Ashdale Hotels (uk) Limited
Name or title of person to contact: Mr Martin Wicks
Email address: firstname.lastname@example.org
Postal address: Dower House, Bond End, Knaresborough, North Yorkshire, HG5 9AL
Telephone number: 01423 863 302
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.
This version was last updated on 24 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.
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, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender. In some cases, we may also collect passport and driving licence numbers, national identity cards and date of birth information.
- Contact Data includes home address, billing address (which may be a business address), delivery address, email address and telephone numbers.
- Health Data includes information about allergies, health requirements and allergies that are pertinent to bookings and events and when you use our health club, spa facilities or restaurants, this could include details of specific medical or health conditions.
- Financial Data includes bank account and payment card details.
- Transaction Data includes details about bookings, payments to and from you, voice recordings, room preferences, special requests and other details of products and services you have purchased or requested from us such as WiFi and food purchases.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, device type, 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 our website.
- Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
- Usage Data includes information about how you use our website, products and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
As highlighted above, we do collect some Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). We may also collect information about criminal convictions and offences.
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 goods or services). In this case, we may have to cancel a product or 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, Health and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes:
As a customer when you:
- enquire about or book rooms or events with us;
- ask us to make specific arrangements for you in relation to bookings or events (e.g. birthdays, weddings, travel arrangements, concierge services etc);
- use the spas in our hotels;
- apply for our products or services including to sign up for “The Birthday Club” or “Hazlewood Babies”
- create a personal or business account directly or via our website;
- subscribe to our service or publications;
- request marketing to be sent to you;
- enter a competition, promotion or survey; or
- give us some feedback or make a complaint;
As a supplier:
- When you market to us or transact business with us;
- When you tender for business;
- When you apply for employment or work with us;
- During your employment or work for us;
- In relation to references we are asked to provide for you.
- Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
- Technical Data from the following parties:
(a) analytics providers such as Google based inside and outside the EU;
(b) advertising networks inside and outside the EU; and
(c) search information providers such as Google inside and outside the EU.
- Contact, Financial and Transaction Data from partners (including our health clubs), travel companies and agents such as Best Western, Expedia, Booking.com, TripAdvisor and other travel and booking agencies or platforms, including restaurant booking agencies;
- Contact, HR and Financial Data from employment agencies, background check providers, former employers and sometimes benefits providers.
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as PayPal based inside the EU.
- Identity and Contact Data from data brokers or aggregators based inside the EU.
- Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside the EU.
Purposes for which we will use your personal data
We collect and use your personal data as a customer for the purpose of dealing with your bookings and requests, tailoring our services to your requirements, providing you information about products and services we offer and to improve our service to you.
Where you are a supplier or potential we use the data for the purposes of managing the supply and performance of the supply or for evaluating the use the suppliers, including for evaluating tenders.
For employees and workers, we use the data for the purposes of recruitment and employing you.
In all cases, we also use personal data for the purposes of satisfying any legal, accounting, or reporting requirements.
For customers, 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 view the Contact details at the top of this document 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.
Type of data
Lawful basis for processing including basis of legitimate interest
To register you as a new customer including introducing you to loyalty schemes
(a) Performance of a contract with you
To process and deliver your order including:
(a) Performance of a contract with you
To manage our relationship with you which will include:
(a) Performance of a contract with you
To enable you to partake in a prize draw, competition or complete a survey
(a) Performance of a contract with you
To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
(a) 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)
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions, promotional offers and recommendations to you about goods or services that may be of interest to you
Necessary for our legitimate interests (to develop our products/services and grow our business)
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:
Promotional offers from us
We may use your Identity, Contact, Technical, Usage 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 products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
We will not sell your personal information to third parties and will only disclose information to our selected business partners and service providers for the purpose of facilitating your stay at any hotel owned by us. These parties are contractually prohibited from using personal information for any purpose other than the purpose we specify.
You can ask us or third parties to stop sending you marketing messages at any time by emailing email@example.com
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience or other transactions.
Our website uses ‘cookie’ technology. A cookie encrypts strings of text that a website stores on a user’s hard drive (but it does not access your hard drive). In order to improve our website, services and build profile information about visits to our website, we may from time to time send you cookies.
Whilst you do not need to allow your browser to accept cookies in order to browse much of our website or access our services, we strongly recommend that your cookies are enabled if you wish to proceed with a booking at any of our hotels.
The type of cookies that we use are referred to as ‘session’ cookies and ‘persistent’ cookies. Session cookies are temporary and are automatically deleted once you leave the website. Persistent cookies remain on your computer hard drive until you delete them. Usage of the cookie is in no way linked to any personally identifiable information apart from what you voluntarily provide us in your dealings with us.
Most browsers allow you to turn off the cookie function. If you want to know how to do this please look at the help menu on your browser. As previously mentioned, this will restrict your ability to perform transactions, use certain functions and access certain content on our website.
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 view the Contact details at the top of this document.
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.
4. Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
- Internal Third Parties as set out in the Glossary.
- External Third Parties as set out in the Glossary.
- Ashdale (UK) Limited.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers 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.
5. Data security
We treat the information that you provide to us as confidential information. We work to protect the security of your information during the transmission by using Secure Sockets Layer (SSL) software, which encrypts the information that you input. This allows your computer to communicate with our server in a way that is designed to prevent eavesdropping, tampering, or message forgery. You will also know when you are in a secure mode when the padlock or key icon in lower right-hand or left hand corner of the computer screen appears in the locked position. In addition, the first characters of the site address will change from ‘http’ to ‘https’ when accessing the server.
Whilst we take all reasonable steps to protect your personal information, data transmission over the Internet cannot be entirely secure. We therefore cannot guarantee the security of the information you disclose online and the use of our facilities (e.g. email) is at your own risk.
We will not be liable for any damages or losses suffered directly or indirectly arising out of or in connection with unauthorised access, loss or corruption of personal data which you provide to us on this website unless we have been found to be negligent.
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. They 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.
6. 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 they cease being customers for legal and tax purposes.
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 policy to you.
7. 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 view the Contact details at the top of this document.
No fee usually required
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.
What we may need from you
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 speed up our response.
Time limit to respond
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.
Legitimate Interest means 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). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us with the Contact details at the top of this document.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
External Third Parties
- Service providers including Zone Wifi and others acting as processors based in and outside the EU to provide IT, Marketing and system administration services, including WiFi.
- Subcontractors such as external caterers, health clubs, couriers, taxis, flower, gift, music, audio and event supply, production & management companies (including other organisations you may ask us to book on your behalf).
- Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based who provide consultancy, banking, legal, insurance and accounting services.
- Local travel information providers, training providers, health & safety experts& fire protection services.
- HM Revenue & Customs, DVLA, Licensing authorities/Courts, the Police, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
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 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.
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 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.
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.