Privacy Policy
1. Summary
EPH Property Investments Limited (“EPH”) (ICO registration: ZA663064) is the data controller in relation to Personal Information of the Guests of the Hotel and is committed to ensuring it is protected and processed lawfully. Personal Information is only held and used for specified purposes in connection with a Guest’s Booking (or services and products in connection therewith) or to market the services and products of the Hotel where a Guest has provided positive consent to do so.
Guests’ Personal Information will never be sold to anyone but it is accessed by certain third parties for processing for the specified purposes. Online travel agents, such as Booking.com, may process Personal Information as agreed directly between them and the Guest. Guests have important rights in relation to their Personal Information: They may request at any time for a copy of their Personal Information, or for it to be erased, corrected, or processed differently, or to withdraw their consent for their Personal Information to be used for marketing purposes, by contacting the Hotel Operator, using the details below. In the event of any conflict in meaning between this summary and the full text of the Notice, the full text will apply. Capitalised terms have the meanings given to them as outlined throughout this Policy.
2. Personal Information Held
It is necessary to hold and process certain Personal Information about anyone who stays or wishes to stay in the Hayward Hotel (the “Hotel”) as a permitted guest (a “Guest”). This may include (but is not limited to) the following information:
a. Name and Title
b. Email address
c. Home address
d. Telephone number
e. Payment information
f. CCTV images and audio
It may also be necessary to hold and process such additional sensitive Personal Information about Guests as is necessary in order to enable the Hotel to provide its products and services. This may include a Guest’s medical information (to assist in managing accessibility requirements), the Personal Information of minors who are Guests, food allergy or ethical or religious requirements, events Guests have told us they attend which may reveal their political or religious beliefs (solely in order to target Hotel availability to them, where they have consented).
3. Purposes and Uses of Personal Information
Personal Information is used for the following purposes / activities and in accordance with the following lawful grounds pursuant to a legitimate interest:
a. Processing a booking or potential booking for a stay at the Hotel and associated products and services (“Booking”);
b. Managing the Hotel’s relationship with Guests and to enable it to provide Guests with its products or services, including but not limited to, responding to queries, complaints, or requests;
c. Managing and collecting all applicable payments, fees and/or charges, including recovering all sums due to the Hotel;
d. Administering and protecting the Hotel’s business, its website and its online booking system;
e. Any purpose connected with the performance of the Hotel Operator’s contract with Guests;
f. Providing of administration and IT services, maintaining network security and preventing fraud;
g. Security and safety within the Hotel’s premises;
h. Seeking and responding to reviews of services or goods supplied by the Hotel;
i. Financial accounting and reporting.
4. Marketing
If a Guest provides positive consent (which may be withdrawn at any time), Personal Information may be used for marketing purposes relating to goods, services and/or promotional offers in relation to the Hotel. This will be limited to email or SMS communications.
Personal Information will only be shared with third parties for marketing purposes where they process Personal Information to market services or goods supplied by the Hotel. Personal Information will never be sold to anyone.
5. Retention of Personal Information
Personal Information is only retained for as long as necessary for the purpose for which it is held and in any event no longer than seven (7) years from the date of its creation.
6. How Personal Information is Processed
EPH will permit access to Personal Information to third parties solely for processing in accordance with the specified purposes. EPH requires all such third parties to process Personal Information securely and in accordance with applicable law or regulation. Such third parties are not permitted to use Personal Information for their own purposes, unless otherwise agreed by a Guest separately (e.g. with Booking.com).
In particular, EPH will permit access to Personal Information to The Hayward Hotel Blackpool Limited (the “Hotel Operator”), which operates the Hotel and the Queensborough Group, who provide hotel and channel management services.
The Hotel Operator may also need to disclose Personal Information to the following categories of recipients: (i) other group companies; (ii) our third party service providers; (iii) our professional advisers, including but not limited to legal advisers and accountants; (iv) payment providers and other financial organisations; (iv) our suppliers or those of the Hotel; (v) central and local government and regulatory authorities, where required to do so; (vi) other hoteliers in the Blackpool area, in the event of Guest Misconduct.
Personal Information will not be transferred outside the European Economic Area.
Personal Information is collected directly from Guests. Personal Information will also be obtained from the Queensborough Group and other third parties providing services in connection with the operation of the Hotel’s online booking system. Personal Information will also be collected from such travel agency intermediaries, such as Booking.com and Expedia.com.
7. Guests’ Rights in relation to Personal Information
Guests have a number of important rights in relation to their Personal Information. This includes, but it is not limited to, the right to:
a. ask for a copy of the Personal Information held and a description of how it is used (i.e. subject access request);
b. request the correction of inaccurate Personal Information;
c. require deletion of Personal Information in certain circumstances (i.e. the right to be forgotten);
d. require restrictions in the use of Personal Information or object to how it is used in certain circumstances;
object to the processing Personal Information on the basis of legitimate interests, in certain circumstances; and
e. withdraw consent to the processing of Personal Information for marketing purposes.
f. Notwithstanding these rights, EPH reserves the right to retain Personal Information where it is required to do so for legal, regulatory or taxation purposes or otherwise where it is necessary to do so for the administration of the business of the Hotel or the Hotel Operator or where there has been Guest Misconduct.
8. Contact Information
Guests should raise questions or complaints in writing to: reservations@haywardnewbury.co.uk
Please note that Guests have the right to complain to the Information Commissioner's Office where they feel their complaint has not been resolved.
Please note that this Privacy Notice may be updated by from time to time. Updates become effective on publication on the Hotel Operator’s website.