Privacy and Cookie Policy

The Purpose of this Notice

In this privacy notice we explain how we will process your personal information obtained through your use of our website https://www.gardenshotelmanchester.com/ and through other interactions with you, for example, when you visit our social media pages, when we supply our goods and/or services to you, though our sales and marketing activities.

If you wish to learn how we process personal data of residents, employees, and leisure club members obtained, please contact GDPR@shnl.co.uk

It is important that you read this privacy notice, together with any other privacy notice we may provide on specific occasions, so that you are fully aware of how and why we are using your data, and what data protection rights you have.

About Gardens Hotel Manchester 

Gardens Hotel Manchester  is owned by The Cairn Hotel Group. Gardens Hotel Manchester is part of a family-run hotel group with over 60 years of experience in the hotel services industry. This Website and Marketing Privacy Notice is intended to cover the data collected when you sign up to marketing newsletters via our website, when you complete our online enquiry form, cookie tracking via our website, use of third-party bookings and other data capture via our website.

What Does This Notice Cover:

  1. Who We Are and How To Contact Us
  2. Data Protection Legislation
  3. Personal Data We Collect
  4. How We Collect Personal Data
  5. How and Why We Use Personal Data
  6. Marketing
  7. Who We Share Personal With
  8. International Data Transfer Outside The United Kingdom
  9. International Data Transfers if you are Based in the European Economic Area
  10. How Long we Keep Personal Data
  11. Your Rights
  12. Information Security
  13. Complaints
  14. Changes to this Privacy Notice

 

  1. Who We Are and How To Contact Us

When we say we, us or our in this privacy notice, we mean Gardens Hotel Manchester, a company incorporated and registered in England and Wales with company number 01958222 and whose registered office is at CHG House, 31-40 West Parade, Newcastle Upon Tyne, NE4 7LB.

For the purposes of the Data Protection Legislation, we are the controller of your personal data. This means that we are responsible for deciding how we hold and use personal information about you.

Our Data Protection Officer is Richard Warren. You can contact him at GDPR@shnl.co.uk.

  1. Data Protection Legislation 

We are committed to protecting your privacy and safeguarding your personal data. Our use of your personal data is subject to the UK General Data Protection Regulation, the UK Data Protection Act 2018 and other UK privacy laws (together UK Data Protection Legislation).

If you are based in the European Union, then our use of your personal data is also subject to the EU General Data Protection Regulation and other EU privacy laws (together EU Data Protection Legislation). (together Data Protection Legislation).

When we say Data Protection Legislation in this notice, we mean both the UK Data Protection Legislation and the EU Data Protection Legislation.

  1. Personal Data We Collect

Personal data means information which relates to an identified or an identifiable individual.

Identify Data:

first name; last name; user name

Contact Data:

address; email; telephone number;

Financial and Transactional Data:

payment card details; details of orders made and processed; details of payment received/made; details of invoices received/issued;

Contract Data:

details of your contracts with us

Usage Data:

products purchased and prices paid; how you use and navigate our website and our social media pages; services you signed up to; events you attended or expressed interest in;

Profile Data:

information about you that you provide in your profile/account on our; your interests and preferences; posts and materials you upload onto our website;

Advertising Profile Data:

interests; preferences; feedback and survey responses; assumptions about your predicted buying behaviour and interests based on the usage data collected by us, non-personal data and personal data held about you by our advertisers such as Facebook, Google;

Professional Data:

job title; name of business or organisation; professional credentials; professional contact details;

Communication Data:

details of enquiries submitted by you through our website, app or emailed to us; information obtained through networking;

IT Data:

logins and usernames to our portals; encrypted passwords;

Technical Data:

your IP address; your general geographic location based on your IP address; your time zone setting; the type of device you use and its operating system and version; your browser type; the platform you use and other technology on the devices you use to access our website; the pages you view on our website and how you interact with that content; advertising identifiers (such as those on mobile devices, tablets and streaming media devices that include such identifiers)

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Special Categories of Data

We do not routinely collect any special categories of personal data about you (meaning information about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, your health, and genetic and biometric data), nor do we collect any data relating to criminal convictions and offences.

Children's Data

We do not provide goods/services directly to children however we may collect their personal data as we do accept hotel bookings/ leisure club membership sign ups made by a parent or guardian on their child’s behalf. For further information on how we process data related to children, please contact GDPR@shnl.co.uk

Anonymised Data

We may also collect, use, and share anonymised, aggregated data such as statistical or demographic data for any purpose. Anonymised data may be derived from your personal data but is not considered personal information in law as this information does not directly or indirectly reveal your identity. For example, we may aggregate information on how you use our website and/or app to calculate the percentage of users accessing a specific website and/or app feature.

  1. How We Collect Personal Data

We collect most of this information from you direct. However, we may also collect information from other sources.

Your Use of Our Website and Services 

when you create an account on our website; when you use our website services; when you buy our products or services; when you submit an enquiry or feedback to us or complete our survey; when you sign up to our mailing list; when you submit any information or materials on our website

Your Use of our Social Media Pages

when you follow, post on, or interact with our post on our Facebook/Instagram/other social media page

Direct Interactions With You

when you contact us (e.g. by phone or email); when you participate in our user research activities (e.g. provide us with feedback or respond to our questionnaires); when you network with us (e.g. provide us with your business card or contact us via our social media); when you register interest in our products or services.

From Publicly Accessible Sources

your website; your profiles on social media platforms (e.g. LinkedIn, Facebook, Instagram); professional networking groups and databases.

Third Parties

from another organisation or professional who told us that you would like to hear from us; or if you visit our website by clicking on our advertisement on social media or another website or app.

Automated Technologies or Interactions

as you interact with our website and advertisements, we may automatically collect technical data (as described in section The personal data we collect above). We collect this personal data by using cookies, server logs and other similar technologies. For further details, please see our [insert link to Cookies Notice).

  1. How and Why We Use Personal Data 

Under the Data Protection Legislation, we can only use your personal data if we have a proper reason for doing so, for example: consent, contact, legitimate interests, or legal obligation.

Consent. Generally, we do not rely on consent as a legal basis for processing your personal data other than to:

  • place cookies and similar tracking technologies on your device including third-party cookies (for further details please see our [insert link to Cookies Notice];
  • send you our newsletters or other electronic marketing communication if you are our existing customer or if you request or expressly agree to receive such communication;
  • use your information for the purpose of profiling for marketing or other purposes (for example, all details and demographics captured in google analytics);
  • send you invites to our marketing events; and
  • share your details with a third party for marketing purposes.

Where your permission is required, we will clearly ask you for such consent separately from the body of this privacy notice.

You have the right to withdraw consent by:

  • emailing us at GDPR@shnl.co.uk;
  • in case of marketing emails, by using the ‘unsubscribe’ link in our marketing emails; or

Even if we are not required to obtain your consent for marketing purposes, you can still opt-out of receiving marketing communications at any time, so you are still in control.

From time to time, we may ask you to confirm or update your marketing preferences.

Contract. We will use your personal data if we need to do it to perform our obligations under a contract with you, or if it is necessary for a contract which we are about to enter with you. For example, if we need to:

  • register you as a new customer and administer your account (e.g. manage your orders, administer invoicing and payments);
  • provide our products and/or services to you;
  • manage our relationship with you (e.g. to respond to your enquiries or to notify you about changes to our products and/or services); and
  • provide after sale care services (e.g. technical support).

Legitimate interests. We may process your personal data when we (or a third party) have a legitimate reason to use it, so long as this is not overridden by your own rights and interests. For example:

  • to administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data);
  • to manage your account and our relationship with you;
  • to manage payments, fees, charges, and to collect debts which you may owe to us;
  • to interact with you professionally (e.g. if you represent our current or prospective customer, supplier or business partner) to manage our relationship with the organisation you represent;
  • to deal with your enquiry;
  • to ask you to leave a review or complete a survey;
  • to send you our email updates or other electronic marketing communications if you are our existing client;
  • to increase our business or promote our brand through delivering relevant website content, advertisements, and marketing communications to you;
  • to measure or understand the effectiveness of the advertising we provide to you;
  • to improve our website products, services, marketing, and customer relationships;
  • for the prevention and detection of fraud and spam; and
  • for the establishment, exercise or defence of our rights under our contract with you and/or legal claims.

Legal obligation. We may process your personal data to comply with our legal obligation. For example, to:

  • notify you about changes to our terms or privacy notice;
  • address your complaint; and
  • comply with a request from a competent authority.

  1. Marketing 

Our marketing emails

We may send you emails about our products if you are our existing customer (on the basis of our legitimate interests) or, if you are our prospective customer, when you expressly agree to that (for example, by signing up to our newsletter).

Profiling

If you are our existing customer, we may use the information we have about you (such as what product you previously bought from us, where you live, how old you are, how you use our website) to make predictions on what other products may be of interest to you. We will use that information to make our marketing emails and offers relevant to you. This type of personal data use is called ‘profiling’. We will do that on the basis of your consent.

Cookies and similar technologies

We may also use cookies and similar tracking technologies (for example tracking pixels in our marketing emails and website/app advertisements) and analytics services (such as Google Analytics) to collect information about your use of our website, app, services and your interactions with our marketing emails and advertisements.

In addition, third party advertising platforms (for example, Facebook and Google) may also use their advertising pixels and other cookies on our website and in our emails with our permission. Their cookies are used to track visitors across websites in order to deliver adverts more relevant to them and their interests. The advertisers may use information about your visit to our website to target advertising to you on other websites.

We will ask for your consent to the use of non-essential cookies, including third party cookies.

  1. Who We Share Personal Data With 

We may share your information with third parties for the purposes set out in this notice.

Service provision

We use service providers to provide goods/services to you:

  • Payment gateways such as Stripe (based in the US), to process payments through our website. If you pay for our products through our website, or if you receive payments from us through our website you will be providing your personal data (for example, details of your payment card and billing address) to that gateway. Please see Stripe’s privacy policy.
  • Booking software platforms such as OpenTable (in various locations including the US, see OpenTable’s privacy policy) and P3 (based in Ireland however uses processors such as Google Analytics which is based in the US, see P3’s privacy policy), so that users can self-book and pay for our services online.
  • WiFi providers such as Purple Wifi (based in the UK however uses third party providers that may be based outside of the EEA, see Purple’s privacy notice), a cloud-based captive portal solution that we use so that users can authenticate to their Wi-Fi services.

We impose contractual obligations on providers to ensure that your personal data is protected.

Social media

We may share your information with social media providers such as Facebook and Instagram when you have specifically opted into marketing for the purposes of advertising. Please also see the ‘Marketing’ section of this notice for further details of sharing information with social media platforms.

IT and technology

We also share data with providers of IT, digital, and technology products and services, which we use to operate our business:

  • Google, who provide Google Analytics web and app analytics services to us.

Other sharing

We may also:

  • share your personal data with members of our staff;
  • disclose your personal data to professional advisers (e.g. lawyers, accountants, auditors or insurers) who provide professional services to us;
  • disclose your personal data to certain third parties if specifically requested or agreed with you (e.g. if you ask us to introduce you to a third party);
  • disclose and exchange certain information with law enforcement agencies and regulatory bodies to comply with our legal obligations; and
  • share some personal data with other parties, such as potential buyers of some or all of our business, potential investors, or group companies if our business undergoes a corporate re-structure.

Such data recipients will be bound by confidentiality obligations.

  1. International Data Transfers Outside the United Kingdom 

Transfers of personal data outside the United Kingdom are subject to special rules under the UK Data Protection Legislation.

If you are based outside the United Kingdom, we may receive and transfer your personal data directly to you to the country where you are based.

We may also transfer your personal data to providers based in the European Economic Area (EEA) or receive your personal data from third parties in the EEA. The UK Government has recognised the EEA as providing an appropriate level of protection to the data protection rights of individuals.

We may also transfer your personal data to providers based in Canada. The UK Government has recognised Canada as providing an appropriate level of protection to the data protection rights of individuals where personal information is collected by private sector organisations in the course of commercial activities.

We may also transfer your personal data to the USA, due to our use of providers such as Google, Stripe and OpenTable (Please see the section ‘Who we share your personal data with’ in this privacy notice for more information about these providers.)

Where we transfer your personal data to the USA, in order to protect your information, we have entered into transfer agreements with the third parties in the USA with whom we share your data. Transfers of your personal data to the USA operate under an International Data Transfer Agreement (IDTA) or under the standard contractual data protection provisions (Standard Contractual Clauses) and/or the UK’s IDTA Addendum (IDTA Addendum). These mechanisms of transfer are recognised as being appropriate safeguards under the UK GDPR.

Please email gdpr@cairnhotelgroup.com if you would like further information in relation to international data transfers.

  1. How Long We Keep Personal Data

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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, regulatory, tax, accounting or other requirements.

For example:

  • we are required to keep accounting records for seven years for tax audit purposes;
  • if you have a contract with us, we will keep your data until you close you account on our website; and
  • if you subscribe to our updates, we will hold your data for that purpose until you unsubscribe or otherwise tell us that you no longer wish to receive such communications.

We may also anonymise your personal data (so that it can no longer be associated with you) for analytics, research, or statistical purposes, in which case we may use this information indefinitely without further notice to you.

  1. Your Rights

You have a number of rights in relation to your personal data, which allow you to access and control your information in certain circumstances. You can exercise these rights free of charge, unless your request is manifestly unfounded or excessive (in which case we may charge a reasonable administrative fee or refuse to respond to such request).

Access

This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Rectification 

The right to require us to correct any inaccuracies in your personal data.

Erasure (to be forgotten)

The right to require us to delete your personal data in certain situations.

Restriction of Processing 

The right to require us to restrict processing of your personal data in certain circumstances (e.g. if you contest the accuracy of the data we hold).

Data Portability

The right to receive, in certain situations, the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party.

To Withdraw Consent 

The right to withdraw your consent, if we rely on your consent to use your information.

To Object

The right to object at any time to your personal data being processed for direct marketing (including profiling) or, in certain other situations, to our continued processing of your personal data (e.g. processing carried out for the purpose of our legitimate interests).

If you would like to exercise any of those rights, please contact us either directly or at GDPR@shnl.co.uk. Please let us know what right you want to exercise and the information to which your request relates.

  1. Information Security

We have appropriate security measures to prevent personal data from being accidentally lost or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

  1. Complaints 

We hope that our Data Protection Officer can resolve any query or concern you may raise about our use of your information. You may contact our Data Protection Officer by using the contact methods set out in the How to contact us section of this privacy notice.

The Data Protection Legislation also gives you a right to lodge a complaint with the Information Commissioner, who may be contacted at https://ico.org.uk/make-a-complaint/, telephone on 0303 123 1113, or by post to: Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.

We would, however, appreciate the chance to deal with your concerns before you approach the supervisory authority, so please contact us in the first instance.

  1. Changes to This Privacy Notice 

This privacy notice was last updated on 02/11/2023.

We may change this privacy notice from time to time; when we do, we will publish the new version of the privacy notice on our website. If you are our customer, we may also inform you via email or post.

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To register you as a new customer, administer your account and manage our relationship with you (a) Identity(b) Contact (a) Performance of a contract with you(b) Necessary for our legitimate interests (to administer your account and manage our relationship with you)
If you are a representative of a business, to manage our relationship with that business or to discharge our contractual obligations to the business that referred your business to us (a) Identity(b) Contact

(c) Transaction

(a) Necessary for our legitimate interests (to manage our relationship with the business you represent, and to discharge our contractual obligations to the business who referred your business to us)(b) Necessary for the legitimate interests of the business you represent (to manage their relationship with us)
To process and deliver your order including:(a) Managing communications traffic

(b) Managing payments, fees and charges

(c) Preventing and detecting fraud

(d) Collecting and recovering money owed to us or otherwise enforcing our legal rights

(a) Identity(b) Contact

(c) Financial

(d) Transaction

(e) Usage

(f) Marketing and Communications

(a) Performance of a contract with you(b) Legal obligation (providing accurate billing information)

(c) Necessary for our legitimate interests (traffic management; prevention and detection of fraud; recovering debts due to us or otherwise enforcing our legal rights)

To manage our relationship with you which will include:(a) Notifying you about changes to our terms or privacy and cookie policy

(b) Asking you to leave a review or take a survey

(c) Dealing with enquiries and complaints

(a) Identity(b) Contact

(c) Profile

(d) Marketing and Communications

(e) Financial

(f) Transaction

(g) Usage

(a) Performance of a contract with you(b) Necessary to comply with a legal obligation (providing accurate billing information and handling complaints)

(c) Necessary for our legitimate interests (keeping our records updated and to study how customers use our products/services)

To enable you to partake in a promotion or complete a survey (a) Identity(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(a) Performance of a contract with you(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity(b) Contact

(c) Technical

(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)(b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you (a) Identity(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(f) Technical

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 (a) Technical(b) Usage Necessary for our legitimate interests (using diagnostic analytics to assess the number of visitors, posts, page views, reviews and followers in order to optimise future marketing campaigns)
To make suggestions and recommendations to you about goods or services that may be of interest to you (a) Identity(b) Contact

(c) Technical

(d) Usage

(e) Profile

Necessary for our legitimate interests (to develop our products/services and grow our business)

If you submit personal information for publication on our website, we will publish and otherwise use that information in accordance with the licence you grant to us.

Marketing - 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, enquired on our website, purchased goods or services from us or if you provided us with your details when you registered for a promotion and, in each case, you have not opted out of receiving that marketing;

Prospective clients  if you are not our existing customer or representing a corporate business and you have given us your business card because you are happy to hear from us, we may use your Identity and Contact Data to form a view on what we think you may want or need, or what may be of interest to you.

Third-party marketing  we will get your express opt-in consent before we share your personal data with any other company for marketing purposes;

Opting out  you can ask us or third parties to stop sending you marketing messages at any time by unsubscribing at any time. 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.

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 email gdpr@cairnhotelgroup.com.

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.

Disclosing 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 5 above:
Service providers acting as processors in the United Kingdom, the EEA and the USA who provide database and other IT and system administration services.

  • Marketing services providers based in the EEA and the USA who provide direct marketing services to us.
  • Payment services providers based in the EEA and the USA who provide payment services to us.
  • Specific third parties such as Hilton, IHG, Accor, Marriot and Best Western with whom we may need to share your personal data in order to provide certain requested products or services to you.
  • Businesses who referred your business to us.
  • Professional advisers acting as processors including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
  • HM Revenue & Customs, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances.
  • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. 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 and cookie policy. 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.

International data transfers
Information that we collect may be stored and processed in and transferred between any of the countries in which we operate in order to enable us to use the information in accordance with this privacy and cookie policy.

Information that we collect may be transferred to the following countries which do not have data protection laws equivalent to those in force in the European Economic Area (EEA): the USA.

Some of our external third parties are also based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.

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

Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.

Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

You expressly agree to the transfers of personal information described. 

Please email gdpr@cairnhotelgroup.com if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

Personal information that you publish on our website or submit for publication on our website may be available, via the internet, around the world. We cannot prevent the use or misuse of such information by others.

Security of personal data
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.

You acknowledge that the transmission of information over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.

You are responsible for keeping the password you use for accessing our website confidential; we will not ask you for your password (except when you log in to our website).

Retaining personal information
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.

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.

Updating information
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.

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

About cookies
Our website uses cookies to distinguish you from other users of our website. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. By continuing to browse the site, you are agreeing to our use of cookies.

Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

Cookies may be either persistent cookies or session cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

Cookies can be used by web servers to identify and track users as they navigate different pages on a website and identify users returning to a website.

Our cookies:

We use both session and persistent cookies on our website.  You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.

We use the following cookies:

  • Strictly necessary cookies  these are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing service;
  • Analytics/performance cookies  they allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily;
  • Functionality cookies  these are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region);
  • Targeting cookies these cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

Analytics cookies: We use Google Analytics to analyse the use of our website. Our analytics service provider generates statistical and other information about website use by means of cookies. The analytics cookies used by our website have the following names:

[_ga, _gat, __utma, __utmt, __utmb, __utmc, __utmz and __utmv].

The information generated relating to our website is used to create reports about the use of our website.

Our analytics service provider's privacy policy is available here.

Third party cookies: Our website also uses third party cookies.  A common example is an embedded YouTube video.

Amendments
We may update this policy from time to time by publishing a new version on our website.
This version was last updated in 2018.
The data protection law in the UK will change on 25 May 2018. Although this privacy and cookie policy sets out most of your rights under the new laws, we may not yet be able to respond to some of your requests (for example, a request for the transfer of your personal data) until May 2018, as we are still working towards getting our systems ready for some of these changes.
You should check this page occasionally to ensure you are happy with any changes to this policy.
We may notify you of changes to this policy by email or through the private messaging system on our website.

Glossary

Lawful Basis
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.

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 emailing gdpr@cairnhotelgroup.com.

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.

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.