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Privacy & Cookies Policy

WELCOME TO THE PRIVACY POLICY OF SEVEN HOTELS LIMITED

We are committed to preserving the privacy, integrity and security of the personal information we hold about our customers and those who contact us. We have developed this Privacy Policy to explain how we manage and use this personal information and to ensure we comply with our legal obligations under applicable data protection laws.

It is important that you read this privacy policy carefully so that you are fully aware of how we collect and process personal information.

STRUCTURE OF THIS POLICY

This privacy notice is provided in a layered format so you can click through to whichever of the specific areas set out below are of interest or relevance to you.

SEVEN HOTELS LIMITED – WHO WE ARE

This Privacy Policy covers the personal information collected and held by SEVEN HOTELS LIMITED. Seven Hotel is a luxury boutique hotel located in a heart of Essex, 7 Clifton Terrace, Southend-on-Sea, SS1 1DT. (see our website at http://www.sevenhotel.co.uk).

PERSONAL INFORMATION WE COLLECT AND HOLD AND THE PURPOSE FOR WHICH WE USE IT

This Privacy Policy applies to all personal information collected by Seven Hotels Limited, by whatever means, both about its customers and about its contacts. The first section below applies to customers and explains under 4 separate headings what personal information we collect about customers, how we collect it, what we use it for and the legal basis on which we rely to do so. The second section below provides all the same information for our contacts, again under 4 separate headings.

CUSTOMERS

What information do we collect?

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 as follows:

    • Identity Data includes first name, last name, username or similar identifier, ages, when you email, phone, live chat or otherwise, we may collect information such as your first name, last name, email address and phone

number. We may ask for your date of birth to send you birthday offers or anniversary offers.

    • Contact Data includes billing address, invoicing address, email address and telephone numbers.
    • Financial Data includes bank account and payment card details. We use a third-party payment provider to collect financial data and all credit card information for all transactions that go through Our Website. It follows

secure encrypted processes a standard for the e-commerce industry.

    • Transaction Data includes details about payments and other details of our 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.

  • Profile Data includes your username and password, reservations made by you, your interests, preferences, feedback and survey responses.
  • Usage Data includes information about how you use our Website and Services.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
  • Interaction Data includes any information that you might provide to any discussion forums on the social media sites.
  • Cookies Data like many websites, we use “cookies” to enhance your experience and gather information about visitors and visits to our websites. Please refer to the “Do we use ‘cookies’?” section below for information about cookies and how we use them and what kind.
  • Third Parties and Information we receive from other sources. We may receive information about you if you use any of the other websites we operate or through the Services we provide. In this case we will have informed you when we collected that data that it may be shared internally and combined with data collected on our Website. We are also working closely with third parties (including, for example, business and our hotel partners, sub-contractors, advertising networks, analytics providers, search information providers, software suppliers) and may receive information about you from them.
  • Analytics includes third-party analytics services (such as Google Analytics) to evaluate your use of the Website, compile reports on activity, collect demographic data, analyse performance metrics, and collect and evaluate other information relating to our Website and internet usage. These third parties use cookies and other technologies to help analyse and provide us the data. By accessing and using the Website, you consent to the processing of data about you by these analytics providers in the manner and for the purposes set out in this Privacy Policy.

WHAT DO WE USE OUR CUSTOMERS’ PERSONAL INFORMATION FOR?

We intend to use your personal information for the following purposes:

(i) to fulfil your bookings and/or to provide services or facilities you request from us;

(ii) to collect payment from you;

(iii) to administer and manage our relationship with you, which may include asking you to complete surveys or feedback forms;

(iv) where you have made a reservation with us, to send you information before your visit to confirm the reservation and to provide you with other information relating to your reservation which we think you may find of interest;

(v) to send you information relating to the loyalty club (if you are a member) (such as loyalty club redemptions and vouchers) and relating to your membership of our clubs (if you are a member);

(vi) to send you marketing and promotional material where we think this may be of interest to you (unless you have objected to receiving this by contacting us using the contact details set out under “HOW TO CONTACT US”.

(vii) where required by law;

(viii) where necessary to protect your health or wellbeing or that of another individual.

Occasionally we may also rely upon the following legal bases for processing: –

(i) it is necessary for us to comply with a legal obligation on us; and/or

(ii) it is necessary to protect your vital interests or those of another individual.

WHAT DO WE USE OUR CONTACTS’ PERSONAL INFORMATION FOR?

We intend to use your personal information for the following purposes: –

(i) to fulfil your requests for information;

(ii) to send you marketing and promotional material where we think this may be of interest to you (unless you have objected to receiving this by contacting us using the contact details set out under “HOW TO CONTACT US” below or by emailing info@thesevenhotel.co.uk

(iii) where it is required by law; and

(iv) where necessary to protect your health or wellbeing or that of another individual.

MARKETING TO YOU

You may receive marketing communications from us: –

(i) if you have specifically requested that information from us; or

(ii) by email, text or post, if you are a customer and you have not opted out of receiving that marketing (which you may do by contacting us using the contact details set out under “HOW TO CONTACT US” below or by emailing info@thesevenhotel.co.uk )

Please note, 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 using the contact details set out under “HOW TO CONTACT US” below or by emailing info@thesevenhotel.co.uk

IF YOU FAIL TO PROVIDE PERSONAL INFORMATION REQUESTED

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 in with you (for example, to provide you with services). In this case, we may have to cancel a service you have booked with us but we will notify you if this is the case at the time.

SHARING YOUR PERSONAL INFORMATION WITH OTHERS

We will not disclose personal information we hold about you to any third party except where required by law or as follows: –

(i) to companies in the Macdonald Hotels & Resorts group;

(ii) to third parties who provide services to us, and act as data processors for us;

(iii) to professional advisers including lawyers, bankers, auditors and insurers;

(iv) to HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances.

Also in the event that we sell any business or assets, we may disclose personal information we hold about you to the prospective and actual buyer of such business or assets. 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 Policy.

Please note that 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.

TRANSFERRING YOUR PERSONAL INFORMATION OUTSIDE THE EEA

We do not intend to transfer any personal data we hold about you to a country outside the European Economic Area (“EEA”).

If, however we do transfer your personal data out of the EEA, we shall ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards applies: –

  • the countries to which it is transferred have been deemed to provide an adequate level of protection for personal data by the relevant regulators;
  • we have put in place with the transferee specific contracts approved by the relevant regulators which give personal data similar protection to that it has in Europe; or
  • if the transferee is in the US, it is registered with the Privacy Shield (or any similar replacement scheme) which requires it to provide similar protection to personal data as is required in Europe.

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. 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.

HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION FOR?

We will only retain your personal information 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.

In some circumstances you can ask us to delete your data: see under YOUR RIGHT TO ACCESS YOUR PERSONAL INFORMATION AND YOUR OTHER RIGHTS/to 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.

We will take all reasonable steps to destroy, or erase from our systems, all the personal information we hold about you when it is no longer required.

YOUR RIGHT TO ACCESS YOUR PERSONAL INFORMATION AND YOUR OTHER RIGHTS

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 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; or

  • 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 by using the contact details set out below under “HOW TO CONTACT US” below or by emailing info@thesevenhotel.co.uk

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 several requests. In this case, we will notify you and keep you updated.

MANAGING YOUR PERSONAL INFORMATION

We want you to give choices regarding use of your personal information for marketing and advertising purposes. We have established a privacy centre where you can view and make certain decisions about your personal data use and if you wish to access this please email us at info@thesevenhotel.co.uk. Moreover, if at any time you believe that any personal data we are holding about you is inaccurate, out-of-date or incomplete, please tell us by emailing us at info@thesevenhotel.co.uk and we will rectify this.

CHANGES TO THIS POLICY

We may need to make changes to this Privacy Policy from time to time to take account of changes in law or the needs of our business. Please refer to this page regularly to see any changes or updates to this Policy.

THIRD-PARTY LINKS

This 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.

HOW TO CONTACT US

If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact us using the details set out below:

COMPLAINTS

If you are not satisfied with our response to any queries or complaints you raise with us or believe we are not processing your personal data in accordance with the Data Protection laws you have the right to lodge a complaint at the Information Commissioner’s Office (ICO) (https://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.

SEVEN HOTEL SOUTHEND COOKIE NOTICE

When you visit our web site www.thesevenhotel.co.uk you are initially given a “cookie”, and your computer is assigned an ID number. A cookie is a commonly used piece of software that tracks an individual user’s preferences, and is capable of enhancing your visit to the site.

Cookies allow us to provide a customised experience without you having to remind us of your preferences each time you visit our site.

The ID number allows us to log your session, so that we may better assist you should you need some individualised service or support. Once you enter personal information on the web site, we associate your ID number with your contact information so we can recognise you on a future visit. We also use it to keep track of information that appears to be of particular interest to you.

If you log in as a registered user, our cookies may collect personal information for marketing purposes and to make content on www.thesevenhotel.co.uk more relevant and easier to use. We do not share your activity on www.thesevenhotel.co.uk with other third parties, nor do we collect information from other websites you may visit.

To find out more about how Seven Hotel uses your personal information, please see our Privacy Notice.

We use cookies for different purposes:

Strictly Necessary Operations

These cookies are strictly necessary to allow us to operate the Seven Hotel website, online services or interactive applications. If you do block them through your browser settings, we cannot guarantee how our websites, online services or interactive applications will perform for you.

These cookies do not gather any information about you that could be used for marketing or tracking your browsing history on other websites, services or applications.

FUNCTIONAL

We use cookies and other technologies to honour choices you have made on how you would like Seven Hotel platforms to function when you access them.

For example, we use functional cookies to remember personal information such as your language preference when you visit our websites to make your experience more convenient and personal.

These cookies are not strictly necessary, but can enhance your experience.

PERFORMANCE/ANALYTICS

We use cookies, in an anonymous manner that does not identify you, to:

• analyse the performance of our sites;

• maintain, operate, and continually improve our sites; and

• collect and maintain aggregate web site data (such as the number of visitors to a particular site), which helps us see which areas are popular with our users and which are not. Among other things, this helps us improve and update the site, based on such data as total number of visitors and pages viewed.

For example, we may obtain information from communications you request, including whether you opened or forwarded an email or clicked on any of its content. This tells us about our communications’ effectiveness and helps us deliver information that you find interesting.

These cookies are not strictly necessary.

MANAGING YOUR COOKIE SETTINGS

If you do not want to accept cookies, you can block them by adjusting the settings on your internet browser. Please note that because this is a setting on your browser, this adjustment may also block cookies for any website you visit. You can visit www.aboutcookies.org, which provides detailed information on managing cookies in popular browsers.

Blocking cookies may affect your ability to benefit from the conveniences afforded by the use of cookies, may affect your ability to use certain customisation features associated with creating a user profile, and, in the case of cookies that are strictly necessary for the website to operate properly, may affect your experience of the website.

Third Party Advertising and Online Behavioural Advertising

You may be provided with advertisements for Seven Hotel Southend and services on third-party websites and mobile services based on your online behaviour.

In addition, our advertising network partners may place and use cookies on Seven Hotel Southend sites and on other third-party websites to collect information about your activities in order to provide you with online advertisements that are based on your interests. This is known as online behavioural advertising, or “OBA”. Our advertising network partners that engage in OBA are to identify themselves to you and let you know about how they are using your personal information, so that you can decide whether to opt out of OBA (see the “Opt Out of Online Behavioural Advertising” section below).

Opt Out of Online Behavioural Advertising

When a Seven Hotel Southend online behavioural advertisement is delivered to you, you will see an “Ad Choices” icon. Clicking on the icon or link will take you to a website where you can manage or opt out of the use of data about your browsing history that is used for the delivery of online behavioural advertising.

On your mobile device, you may also have a “Limit Ad Tracking” setting (in iOS devices) or a setting to “Opt out of Interest-Based Ads” (on Android), which allows you to limit the use of information about your use of apps for purposes of serving ads targeted to your interests.

If you opt out, you may still see advertisements online, including advertisements from Seven Hotel Southend that are based on other information (e.g., based on the content of the page being viewed rather than your prior web-browsing activity).

In some cases, data may still be collected about your browsing activity by third-party advertisers after you have opted out, but they will not use this data to deliver advertisements that are based on your past online browsing behaviour.

To learn more about the choices that advertisers provide generally for individuals to influence how information about their online activities over time and across third-party websites or online services is collected and used, visit:

• the Network Advertising Initiative at http://www.networkadvertising.org/managing/opt_out.asp;

• the Digital Advertising Alliance at http://www.aboutads.info/; or

• the European Digital Advertising Alliance at http://youronlinechoices.eu/