Our Privacy Policy | Crerar Hotels

This privacy policy sets out how Crerar Hotel Group Limited (Crerar Hotels) uses and protects your personal data. It will also tell you about your privacy rights and how the law protects you.

IMPORTANT INFORMATION AND WHO WE ARE
TYPES OF PERSONAL DATA WE COLLECT ABOUT YOU
HOW IS YOUR PERSONAL DATA COLLECTED?
HOW WE USE YOUR PERSONAL DATA
DISCLOSURES OF YOUR PERSONAL DATA
INTERNATIONAL TRANSFERS
DATA SECURITY
DATA RETENTION
YOUR LEGAL RIGHTS
CONTACT DETAILS
COMPLAINTS
CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES
THIRD PARTY LINKS

Important information and who we are
1. Crerar Hotel Group Limited is a company registered in England and Wales with registered company number 00075625 and is the trading company for the following hotels (for the purposes of this privacy policy, the Hotels):
  - Loch Fyne Hotel and Spa
  - Golf View
  - Thainstone House
  - Oban Bay Hotel
  - Isle of Mull Hotel & Spa
  - Balmoral Arms
  - The Glencoe Inn
2. Crerar Hotel Group Limited is part of a corporate group of companies (our Group)
  
  Purpose and application of this privacy policy
3. This privacy policy addresses how Crerar Hotels (including each of the Hotels) collects and processes your personal data as a controller. In respect of each Hotel, Crerar Hotels is the company responsible for processing your personal data.
4. For the avoidance of doubt, this privacy policy does not apply to any personal data collected and used by the Dunkeld House Hotel, Daffodil Hotel or Fonab Castle Hotel which managed by Crerar Hotels; such collection and use shall be subject to the following privacy policies respectively: [LINK TO DUNKELD PAGE], [LINK TO DAFFODIL PAGE] and [LINK TO FONAB PAGE].
5. This privacy policy applies regardless of the method through which Crerar Hotels collects and uses your personal data - whether this be personal data collected from you through your use of this website (www.crerarhotels.com), through your use of the Crerar Hotels mobile app, during a Hotel visit or when you otherwise contact us (including telephone and email enquiries).
6. It is important that you read this privacy policy (together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you) so that you are fully aware of how and why we are using your personal data. This privacy policy supplements other notices and privacy policies and is not intended to override them.
  
  Controller
7. Crerar Hotel Group Limited is the controller and responsible for your personal data (collectively referred to as Crerar Hotels, we, us or our in this privacy policy).
8. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the us using the information set out in the contact details section (paragraph 10).
The types of personal data we collect about you
1. Personal data means any information about an individual from which that person can be identified.
2. 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, any previous names, marital status, title, date of birth, gender, car registration details, social media handles / identifiers and photographic (CCTV) data, and, as part of our recruitment processes, details of your qualifications, skills, experience, employment history, salary information, information about entitlement to work in the UK and equal opportunities monitoring information.
  - Contact Data includes postal address, billing address, email address and telephone numbers.
  - Financial Data includes bank account and payment card details.
  - Transaction Data includes details about payments to and from you and details of other bookings and any extra products or services you have purchased from us.
  - Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID and other technology on the devices you use to access this website.
  - Profile Data includes your purchases or bookings made by you, your interests, preferences, feedback and survey responses.
  - Usage Data includes information about how you interact with and 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.
3. We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals' Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our website to help improve the website and our service offering.
4. When you visit us one of our Hotels, we may collect, use and process Identity Data which may include dietary, health and medical and/or disability information. In addition, as part of Crerar Hotels' recruitment process, we will collect, use and process Identity Data which may include disability information and other equal opportunities monitoring information. Outside of these contexts, we do not collect any 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). Nor do we collect any information about criminal convictions and offences.
How is your personal data collected?
1. We use different methods to collect data from and about you including through:
  - Your interactions with us. You may give us your personal data by filling in online or paper forms or by corresponding with us in person, by post, phone, email or otherwise. This includes personal data you provide when you:
    - submit an enquiry to us (whether online, by telephone, by email or via social media);
    - make a reservation with us (including room, spa, restaurant and leisure bookings);
    - correspond with our on-site teams (for example, our reception teams may make a record of any dietary or special requirements which you tell them about);
    - fill in a questionnaire or form (including a spa consultation form);
    - subscribe to our newsletter;
    - request marketing to be sent to you;
    - enter a competition, promotion or survey;
    - enquire about or apply to work with us; or
    - give us feedback or contact us.
  - Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy Cookies Policy | Crerar Hotels for further details.
  - Third parties. We will receive personal data about you from various third parties as set out below:
    - Technical Data is collected from the following parties:
      - analytics providers such as Google based outside the UK; and
      - advertising networks based inside OR outside the UK.
    - Identity, Contact, Financial and Transaction Data is collected from third party booking agents, providers of payment services such as Stripe based outside the UK.
  - Information we receive from other sources (as part of our recruitment processes). We may receive information about you from third parties who we have asked to conduct pre-employment checks about you and/or former employers when they provide references.

How we use your personal data

Legal basis

The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:
- Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.
- Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure user / guest experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) 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).
- Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
- Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter.
  
  Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use the various categories of 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.

Purpose/Use	Type of data	Legal Basis
To respond to an enquiry submitted to us by you	Identity Contact	(a) Necessary for our legitimate interests (to manage our relationship with you)
To process and deliver your reservation including: Manage payments, fees and charges Collect and recover money owed to us Record and meet any special requirements or preferences you tell us about (including any accessibility, dietary and health/medical requirements you have)	Identity Contact Financial Transaction Marketing and Communications	Performance of a contract with you Necessary to comply with a legal obligation Necessary for our legitimate interests (to recover debts due to us) In relation to any special category personal data, as necessary to comply with a legal obligation and, otherwise, with your explicit consent
To manage our relationship with you which will include: Notifying you about changes to our terms or privacy policy Dealing with your requests, complaints and queries	Identity Contact Profile Marketing and Communications	Performance of a contract with you Necessary to comply with a legal obligation Necessary for our legitimate interests (to keep our records updated and manage our relationship with you) In relation to any special category personal data, as necessary to comply with a legal obligation and, otherwise, with your explicit consent
To protect the safety and security of our business, staff, guests and visitors. This includes protecting the physical security of our Hotels and monitoring activity in our Hotels through CCTV recordings (to the extent that these are used and available)	Identity Contact Technical Usage Profile	Processing is necessary for compliance with a legal obligation. Our legitimate interests (to ensure the safety and wellbeing of individuals and the physical security of our Hotels and business).
To conduct a recruitment process	Identity Data Contact Data Marketing and Communications Data	Necessary for our legitimate interests (of running a recruitment process and keeping records of such process) Necessary to comply with a legal obligation (for example, in some cases it is necessary to check a successful applicant's eligibility to work in the UK) To take steps prior to entering a contract of employment with you In relation to any special category personal data, as necessary to comply with a legal obligation and, otherwise, with your explicit consent
To enable you to partake in a prize draw, competition or complete a survey	Identity Contact Profile Usage Marketing and Communications	Performance of a contract with you Necessary for our legitimate interests (to study how guests and other visitors use our Hotels and Hotel facilities and 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)	Identity Contact Technical	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) Necessary to comply with a legal obligation
To improve our Hotels and the services we (and our Group) provide to guests and other hotel visitors	Technical Usage Profile	Necessary for our legitimate interests (to develop our business and our services)
To deliver relevant website content and online advertisements to you and measure or understand the effectiveness of the advertising we serve to you	Identity Contact Profile Usage Marketing and Communications Technical	Necessary for our legitimate interests (to study how users use our website and services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, user relationships and experiences and to measure the effectiveness of our communications and marketing	Technical Usage	Necessary for our legitimate interests (to define types of users to our website, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To send you relevant marketing communications and make personalised suggestions and recommendations to you about our Hotels and special offers that may be of interest to you based on your Profile Data, including offers and services offered by other members of our Group	Identity Contact Technical Usage Profile Marketing and Communications	Consent; and/or Necessary for our legitimate interests (to carry out direct marketing and grow our business)
To carry out market research through your voluntary participation in surveys	Identity Contact Usage Profile	Necessary for our legitimate interests (to study how guests and other visitors use our Hotels and to help us improve our guest experiences).
To capture images of events we host at our Hotels for inclusion within our marketing literature	Identiy	Consent

Direct marketing

You will receive marketing communications from us if you have requested information from us or placed reservation with us and you have not opted out of receiving the marketing. We may also contact you about other Hotels, products or services provided by companies within our Group. In each case we rely on our respective legitimate interests to do so.
We may also analyse your Identity, Contact, Technical, Usage and Profile Data to form a view on which services and offers may be of interest to you so that we can then send you relevant marketing communications.

Third-party marketing
We will get your express consent before we share your personal data with any third party for their own direct marketing purposes.

Opting out of marketing
You can ask to stop sending you marketing communications at any time by following the opt-out links within any marketing communication sent to you or by contacting us using the details set out in the contact details section (paragraph 10).
If you opt out of receiving marketing communications, you will still receive reservation or service-related communications that are essential for administrative or customer service purposes, for example relating to booking confirmations or updates to our Terms and Conditions.

Cookies
For more information about the cookies we use and how to change your cookie preferences, please see Cookies Policy | Crerar Hotels.

Disclosures of your personal data
1. Your personal data may be shared with other companies within our Group (who are based in the United Kingdom).
2. For the purposes set out in the table above (Purposes for which we will use your personal data), we may have to share personal data with external third parties who provide support integral to the provision of our services and enable us to operate, such as:
  - Service providers acting as processors based in the UK and/or Europe who provide IT, cloud, software and system administration services (including CRM and other reservation booking software providers), customer, property and/or reservation management services, marketing services and accounting services.
  - Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors, insurers and employment and recruitment agencies based in the UK (or other relevant jurisdictions) who provide consultancy, banking, legal, insurance, accounting and recruitment services.
  - HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the UK (or other relevant jurisdictions) who require reporting of processing activities in certain circumstances.
  - Other third party companies where we have an agreement in place and only where an individual has agreed that we may share their personal data with them.
  - 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 policy.
3. 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.[MM4]
International transfers
1. Some of our suppliers are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.
2. Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented
  - We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
  - Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.
3. Please contact us if you would like further information on the specific mechanism used by us when transferring your personal data out of the UK.
Data security
1. 1. 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.
  2. 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.
Data retention
How long will you use my personal data for?
1. 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.
2. 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.
3. You can request further details of retention periods for different aspects of your personal data by contacting us directly (please see section 10). [MM5]
Your legal rights
1. You have a number of rights under data protection laws in relation to your personal data.
2. You have the right to:
  - Request access to your personal data (commonly known as a "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 in certain circumstances. 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) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
  - You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes (see "Opting out of marketing" in paragraph 4 for details of how to object to receiving direct marketing communications).
  - 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 (see the table in section 4 for details of when we rely on your consent as the legal basis for using your 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.
  - Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:
    - If you want us to establish the data's accuracy;
    - Where our use of the data is unlawful but you do not want us to erase it;
    - 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
    - You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
3. If you wish to exercise any of the rights set out above, please contact us using the information set out in the contact details section (paragraph 10).
  
  No fee usually requried
4. 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 could refuse to comply with your request in these circumstances.
  
  What we may need from you
5. 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
6. We try to respond to all legitimate requests within one month. Occasionally it could 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.
Contact details
1. If you have any questions about this privacy policy or about the use of your personal data or you want to exercise your privacy rights, please contact us in the following ways:
  - Email address: marketing@crerarhotels.com
  - Postal address: FAO Data Officer, Crerar Hotels Group, Great Michael House, Links Place, Leith, Edinburgh EH6 7EZ.
Complaints
1. You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator 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.
Changes to the privacy policy and your duty to inform us of changes
1. We keep our privacy policy under regular review. This version was last updated on 1 November 2024.
2. 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, for example a new address or email address.
Third-party links
1. 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 policy of every website you visit.

At Dunkeld Opco Ltd t/a Dunkeld House Hotel, accessible from https://www.dunkeldhousehotel.co.uk/, one of our main priorities is the privacy of our visitors. This Privacy Policy document contains types of information that is collected and recorded by dunkeldhousehotel.co.uk and how we use it.

If you have additional questions or require more information about our Privacy Policy, do not hesitate to contact us.

This Privacy Policy applies only to our online activities and is valid for visitors to our website with regards to the information that they shared and/or collect in dunkeldhousehotel.co.uk. This policy is not applicable to any information collected offline or via channels other than this website.

Consent

By using our website, you hereby consent to our Privacy Policy and agree to its terms.

Information we collect

The personal information that you are asked to provide, and the reasons why you are asked to provide it, will be made clear to you at the point we ask you to provide your personal information.

If you contact us directly, we may receive additional information about you such as your name, email address, phone number, the contents of the message and/or attachments you may send us, and any other information you may choose to provide.

When you register for an Account, we may ask for your contact information, including items such as name, company name, address, email address, and telephone number.

How we use your information

We use the information we collect in various ways, including to:

Provide, operate, and maintain our website
Improve, personalize, and expand our website
Understand and analyse how you use our website
Develop new products, services, features, and functionality
Communicate with you, either directly or through one of our partners, including for customer service, to provide you with updates and other information relating to the website, and for marketing and promotional purposes
Send you emails
Find and prevent fraud

Log Files

dunkeldhousehotel.co.uk follows a standard procedure of using log files. These files log visitors when they visit websites. All hosting companies do this and a part of hosting services’ analytics. The information collected by log files include internet protocol (IP) addresses, browser type, Internet Service Provider (ISP), date and time stamp, referring/exit pages, and possibly the number of clicks. These are not linked to any information that is personally identifiable. The purpose of the information is for analyzing trends, administering the site, tracking users’ movement on the website, and gathering demographic information.

Cookies and Web Beacons

Like any other website, dunkeldhousehotel.co.uk uses ‘cookies’. These cookies are used to store information including visitors’ preferences, and the pages on the website that the visitor accessed or visited. The information is used to optimize the users’ experience by customizing our web page content based on visitors’ browser type and/or other information.

For more general information on cookies, please read “What Are Cookies” from Cookie Consent.

Google DoubleClick DART Cookie

Advertising Partners Privacy Policies

You may consult this list to find the Privacy Policy for each of the advertising partners of dunkeldhousehotel.co.uk.

Third-party ad servers or ad networks uses technologies like cookies, JavaScript, or Web Beacons that are used in their respective advertisements and links that appear on dunkeldhousehotel.co.uk, which are sent directly to users’ browser. They automatically receive your IP address when this occurs. These technologies are used to measure the effectiveness of their advertising campaigns and/or to personalize the advertising content that you see on websites that you visit.

Note that dunkeldhousehotel.co.uk has no access to or control over these cookies that are used by third-party advertisers.

Third Party Privacy Policies

dunkeldhousehotel.co.uk’s Privacy Policy does not apply to other advertisers or websites. Thus, we are advising you to consult the respective Privacy Policies of these third-party ad servers for more detailed information. It may include their practices and instructions about how to opt-out of certain options.

You can choose to disable cookies through your individual browser options. To know more detailed information about cookie management with specific web browsers, it can be found at the browsers’ respective websites.

CCPA Privacy Rights (Do Not Sell My Personal Information)

Under the CCPA, among other rights, California consumers have the right to:

Request that a business that collects a consumer’s personal data disclose the categories and specific pieces of personal data that a business has collected about consumers.

Request that a business delete any personal data about the consumer that a business has collected.

Request that a business that sells a consumer’s personal data, not sell the consumer’s personal data.

If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us.

GDPR Data Protection Rights

We would like to make sure you are fully aware of all of your data protection rights. Every user is entitled to the following:

The right to access — You have the right to request copies of your personal data. We may charge you a small fee for this service.

The right to rectification — You have the right to request that we correct any information you believe is inaccurate. You also have the right to request that we complete the information you believe is incomplete.

The right to erasure — You have the right to request that we erase your personal data, under certain conditions.

The right to restrict processing — You have the right to request that we restrict the processing of your personal data, under certain conditions.

The right to object to processing — You have the right to object to our processing of your personal data, under certain conditions.

The right to data portability — You have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions.

If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us.

Children’s Information

fAnother part of our priority is adding protection for children while using the internet. We encourage parents and guardians to observe, participate in, and/or monitor and guide their online activity.

dunkeldhousehotel.co.uk does not knowingly collect any Personal Identifiable Information from children under the age of 13. If you think that your child provided this kind of information on our website, we strongly encourage you to contact us immediately and we will do our best efforts to promptly remove such information from our records.

Fonab Castle Hotel Privacy Policy

Fonab Castle Hotel Limited trading as Fonab Castle Hotel takes the privacy and security of your data very seriously. We’d like to assure you that we are committed to protecting the privacy of all our users. We will ensure that the information you provide us with is kept private and confidential, and we will only use it to provide the services you request.

Data Protection

Your personal information refers to the data obtained from you in connection with the service provided. Your privacy is important to us and we promise to respect your personal information.

Information is collected lawfully and we will do our best to ensure that your details are accurate and up-to-date.

We will use your personal information for the following reasons so that we can provide you with a first class service:

To confirm, update and improve customer records
Identify and inform you of services that may be of interest.
Analyse and develop a relationship with you. Personal information you supply us with and the information about your use of services will only be used by Fonab Castle Hotel Ltd, to tell you by letter, telephone or email about services that may be of interest to you.

Information Voluntarily Provide

When you complete a booking, sign up to our newsletter, consult with our service team, send us an email, or communicate with us in any way, you are voluntarily giving us information that we collect. That information may include either your name, physical address, email address, IP address, phone number, credit card information, as well as details including gender, location, purchase history, and other demographic information.

By giving us this information, you consent to this information being collected, used, disclosed, transferred or stored by the hotel or our third-party providers as described in this privacy policy. In the interest of your privacy, we only collect, use and retain information reasonably required for our legitimate business interests, such as processing bookings and queries or providing you with marketing materials.

Information Automatically Collect

When you browse the website or make a purchase, we may automatically collect information about your visit by using cookies. This information may include your device type, browser, IP address, how you came to the website or how you interacted with the website. This information may be used to monitor or improve website performance or deliver targeted advertising. Information from the cookie alone generally will not identify you personally and we will not use this information in connection with any personally identifiable information you have provided.

Cookie Usage

Cookies are small amounts of information that are sent to and are stored on your computer. They are used by Fonab Castle Hotel to identify you when you visit the site, and to make your use of the site more convenient for you. If you do not wish to have Cookies placed on your computer you can disable Cookies on your Internet browser.

Information We Share with Third Party Providers

We may share your personally identifiable information with service providers including:

Payment processors for secure credit card payment transaction.
Hosting services.
Email service providers to send you emails pertaining to your booking. Such providers may send emails of a marketing nature if you have agreed to receive such newsletters and will track some performance indicators, such as open and click rates.
Advertising partners who may use email address, cookies and other tracking technologies, such as pixels and web beacons, to gather information about your activities on our website and other sites to provide you with targeted advertising based on your browsing activities and interests.
Our business partners, suppliers, and sub-contractors, for the performance of any contract we enter into with them. We may also share your data with analytics and search engine providers that assist us in the improvement of our website.
Legal authorities when we believe in good faith that we are lawfully authorised or required to do so or when necessary to do so to protect the rights and safety of Fonab Castle, employees and users from fraudulent, abusive, inappropriate or unlawful use of our services.
In connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition, or in any other situation where personally identifiable information may be disclosed or transferred as one of the business assets of Fonab Castle Hotel.
Information that is aggregated or anonymised that does not directly identify you.

How we safe guard your information

We take reasonable and appropriate measures to protect Personal Information from loss, misuse and unauthorized access, disclosure, alteration and destruction, considering the risks involved in the processing and the nature of the personal information.

Our website is hosted on a secure https server and is scanned on a regular basis for security holes and known vulnerabilities to make your visit to our site as safe as possible. We implement a variety of security measures when a user makes a booking, enters, submits, or accesses their information to maintain the safety of your personal information.

Your personal information is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the information confidential. In addition, all sensitive/credit card information you supply is encrypted via SSL Secure Socket Layer technology. If a security breach causes an unauthorized intrusion into our system that materially affects you, then The Fonab Castle Hotel will notify you as soon as possible and later report the action we took in response.

Access to Personally Identifiable Information

If your personally identifiable information changes or you wish your information to be removed from our records, you may update or delete it by emailing Fonab Castle Hotel. We will give you access to your personally identifiable information that we hold within 30 days of a request to access. You may send a request to this email address reservations@fonabcastlehotel.com If you wish to stop receiving email newsletters, click on the unsubscribe link on any of the newsletters.

How long your personal data is kept

We will retain your information for as long as required to deliver your service, agreement or resolve any issues, or until advised not to. Please note that we cannot always delete records of all historical data. For example, we are required to retain certain records for financial reporting and compliance reasons.

Links to other websites

Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website.

Therefore, we cannot be responsible for the protection and privacy of any information you provide whilst visiting such sites and such sites are not governed by this privacy policy. You should exercise caution and look at the privacy policy applicable to the website(s) in question.

Security

Fonab Castle Hotel uses reasonable measures to safeguard sensitive personally identifiable information, with measures that are appropriate to the type of information maintained and follows applicable laws regarding safeguarding any such information under our control.

Changes to Privacy Policy

From time to time, we may need to update or modify this Privacy Policy, which come into effect upon updating this page. We recommend reviewing this privacy policy so you are aware of any changes that affect what you are consenting to by interacting with the website, submitting a query, making a booking or otherwise interacting with Fonab Castle Hotel.

Your privacy is extremely important to us. We want to make sure our website is accessible to everyone. Use of the Fonab Castle website is subject to undernoted terms of use. Users who do not accept these terms of use are not authorised to continue using this website.

Our Promise

Here at Daffodil Hotel 2 Limited trading as The Daffodil Hotel and Spa we place a huge importance on respecting and protecting your privacy.

We hope that the policy below is clear in outlining when, how and why we collect your personal information and the way in which we use it and of course, keep it secure.

We are committed to respecting and protecting your privacy and any changes we may make to refresh the policy in the future will be published on this page. Any personal data you give to us for the purposes set out in this Policy will be processed in accordance with this Policy unless stated otherwise at the time of collection.

We would welcome you to contact us with any questions regarding this policy by emailing privacy@daffodilhotel.com, or by contacting our Privacy Manager via post at The Daffodil Hotel & Spa, Keswick Road, Grasmere, LA22 9PR. Alternatively, please do feel to contact us by phone on 015394 63550.

WHO WE ARE

We are The Daffodil Hotel & Spa, a family owned hotel and limited company with a registered address as above on Keswick Road, Grasmere, LA22 9PR.

HOW DO WE COLLECT INFORMATION ABOUT YOU?

When you visit our website (or subdomains), make a reservation, contact us, purchase products from us or visit our hotel, we collect personal data from and about you. This Policy describes what personal data is collected and for which purposes this personal data is processed by The Daffodil Hotel & Spa. It also states which rights you have under applicable data protection law.

WHAT TYPE OF INFORMATION IS COLLECTED FROM YOU?

The personal information we collect might include your name, address, email address, booking details, IP address, and information regarding pages that you viewed on our website. If you make a booking online or purchase a gift voucher from us, your card information is not held by us, it is collected by our third-party payment processors, who specialise in secure online capture.

HOW IS YOUR INFORMATION USED?

When you stay at The Daffodil Hotel & Spa, your personal data will be stored in (i) centralised systems which are under the control of The Daffodil Hotel & Spa and accessible by authorised staff only of The Daffodil Hotel & Spa, and (ii) local systems controlled solely by The Daffodil Hotel & Spa accessible by authorised staff only. We want to get to know you, because that enables us to make your stay even better, so you may one day decide to return and stay with us. We collect, store and process personal data at two different stages: (i) before you decide to stay at or visit our hotel and (ii) when you stay or have stayed or visited in our hotel.

Before you decide to stay with or visit us

When you visit our website, we collect information about your use of the website. This includes both information we collect directly from you, and information we collect about your behaviour. This information may constitute ‘personal data’ under applicable law. We use this information to provide you with (personal) offers, both on our website and via advertisements on other websites you visit. The information about your use of the website comprises http header information which your browser transmits to our webserver and information collected through the use of cookies.

When you stay or have stayed with or visited us

When you make a reservation, you will have to provide us with your name, your (email) address, phone number, the dates you are staying with or visiting us and a credit card token or other payment information as applicable. We use this personal data to process the reservation, for billing purposes, and to allow us to communicate with you about your reservation. When you stay at or visit The Daffodil Hotel & Spa, we will collect personal data about your preferences, use of our services, and location.

Overview of activities under stage (i) and (ii)

We may at each of the stages outlined above use your personal data. For your convenience, we have made an overview of activities that involve the processing of your personal data, and the corresponding legal basis/legal bases that allow/s us to process this data:

No.	Purpose/Activity	Legal Basis
1	First of all, we store the personal data you provide to us in our systems for administrative purposes.	consent (if required) enter into or perform a contract to which you are a party
2.	We are legally obliged to ask you to provide us with certain information when you arrive at the Daffodil Hotel & Spa. This may include information such as: birth date, nationality, place of residence and date of arrival.	compliance with legal obligation
3.	We will have to verify your identity when you arrive at the Daffodil Hotel & Spa. We will use your passport or other identification document. We will not store a copy of your passport, unless to the extent permitted by law.	enter into or perform a contract to which you are a party for the purposes of our, or a third party’s, legitimate interests
4.	We store information of your use of the systems in the guest room to ensure that they work correctly. This information is used by our 24/7 support team for preventative and reactive support purposes.	for the purposes of our, or a third party’s, legitimate interests
5.	We store your personal data in our database(s) until your visit is complete and our contract with you is complete, also after your transaction has been completed and after you have stayed in our hotel, in order to comply with data retention obligations and to be able to contact you about our offers, products and services and welcome you again in the future.	enter into or perform a contract to which you are a party for the purposes of our, or a third party’s, legitimate interests
6.	For many of our business purposes we use cloud-based services. Therefore, for technical and organisational reasons, it may be necessary that your personal data is transferred to servers located in the US, or to servers located in countries outside of the European Economic Area (‘EEA’).	When we transfer the data to a country outside of the EEA, we will ensure compliance with applicable law by way of: EU Model Clauses; or EU-US Privacy Shield-certification; or other legally accepted safeguards, as applicable to ensure an adequate level of data protection for your personal data and your rights and freedoms.
7.	We process your booking, howsoever made (directly via our website or via a third party (online) travel agent).	enter into or perform a contract to which you are a party
8.	We create a general and simple profile of you on the basis of information disclosed by you via public sources on the internet. We will not use any sensitive personal data that we may collect or derive from your stay or from public sources on the internet.	enter into or perform a contract to which you are a party for the purposes of our, or a third party’s, legitimate interests
9.	We offer and provide services and products you request from us or which we may think you are interested in, via email, telephone or other media. You can subscribe to our newsletter, which contains commercial offers and news of the Daffodil Hotel & Spa only. We use the email address you provide to send the newsletter to. If you no longer wish to receive the newsletter, you can use the link provided in every newsletter to unsubscribe.	consent (if required) enter into or perform a contract to which you are a party for the purposes of our, or a third party’s, legitimate interests
10.	We use credit card data or other payment data for invoicing purposes.	enter into or perform a contract to which you are a party
11.	If you would like to park in our car park we may collect your license plate number in order to provide you access to the car park.	enter into or perform a contract to which you are a party
12.	We collect (meta) data on your use of our Wi-Fi services for security and anti-piracy purposes (such as: IP address, your device’s MAC address, connections made, location, etc.). We do not process the content of traffic.	consent (if required) for the purposes of our, or a third party’s, legitimate interests
13.	We collect automatically generated information for statistical (research) purposes. This information tells us how well our services are functioning. This information may be provided to third parties, but only if permitted by law or if this information cannot be traced back to you.	for the purposes of our, or a third party’s, legitimate interests
14.	We track information on your purchases for future use in case you return to the Daffodil Hotel & Spa.	for the purposes of our, or a third party’s, legitimate interests
15.	We track and record your use of our, or our affiliates’, (online) services, either through cookies or via other means. Cookies enable us and others to monitor your browsing behaviour. Please read our Cookies Policy for further information on cookies.	consent (if required) enter into or perform a contract to which you are a party for the purposes of our, or a third party’s, legitimate interests
16.	We engage in the advertising and marketing of our brand, company, affiliates, services and/or products both online and offline, possibly via third party service providers. For this, we use your contact details, information on your stay at the Daffodil Hotel & Spa and information collected through cookies.	for the purposes of our, or a third party’s, legitimate interests
17.	We endeavour to provide a high level of security of both the information we store as well as our facilities, (IT) systems and premises, by means of encryption, physical security measures, passwords, company procedures and policies and professional IT support. Personal data may be processed in this context by the Daffodil Hotel & Spa and its vendors.	for the purposes of our, or a third party’s, legitimate interests
18.	We endeavour to prevent our services and facilities (hotels) from being used for illegal purposes, of any kind. Personal data may be processed in this context by the Daffodil Hotel & Spa and its vendors, such as through CCTV surveillance.	for the purposes of our, or a third party’s, legitimate interests
19.	We engage in activities required for compliance with legal obligations, third party claims or requests from public authorities, such as (i) the mandatory storage/containment of certain information because of a criminal investigation, (ii) requests from third parties for access to information (iii) any further instructions from third parties, such as supervisory authorities, that involve data processing.	consent (if required) enter into or perform a contract to which you are a party for the purposes of our, or a third party’s, legitimate interests

Whenever we process data for any of the purposes above we will ensure that we always keep your Personal Data rights in high regard and take account of these rights. You have the right to object to processing if you wish, and if you would like to do so please email us at privacy@daffodilhotel.com.

Please bear in mind that if you object this may affect our ability to carry out some of the tasks above for your benefit or provide you with a particular service or product such as not providing health information to the Spa may mean that you will not be able to have some of the treatments.

Click here to learn more about what we mean by legitimate interests, and when we process your data for our legitimate interests.

WHO ELSE HAS ACCESS TO YOUR INFORMATION?

Third Party Service Providers working on behalf of The Daffodil Hotel & Spa include — Siteminder for online bookings, Opera as our PMS system, Gift Pro for online gift voucher sales and Guestfolio or Adestra for CRM and the creation of marketing e-newsletters.

We may pass your information to our third party service providers, their agents, subcontractors and other associated organisations for the purposes of completing tasks and providing services to you on our behalf (for example to process bookings, purchases or to send you e-newsletters). However, when we use third party service providers, we disclose only the personal information that is necessary to deliver the service and we have a contract in place with them that complies with our and their legal obligations under the General Data Protection Regulation (GDPR).

Please be reassured that we will not release your information to third parties beyond The Daffodil Hotel & Spa for them to use for their own direct marketing purposes, unless you have requested us to do so, or we are required to do so by law, for example, by a court order or for the purposes of prevention of fraud or other crime.

When you are using our secure online booking pages, your booking is processed by Siteminder and Sage World Pay, who specialise in the secure online capture and processing of credit/debit card transactions. If you have any questions regarding secure transactions, please contact us.

We may transfer your personal information to a third party as part of a sale of some or all of our business and assets to any third party or as part of any business restructuring or reorganisation, or if we’re under a duty to disclose or share your personal data in order to comply with any legal obligation or to enforce or apply our terms of use or to protect the rights, property or safety of our customers. However, we will take steps with the aim of ensuring that your privacy rights continue to be protected.

HOW LONG IS YOUR DATA STORED?

We store the data you provide to us on an ongoing basis relevant to the average length between stays and visits to The Daffodil Hotel & Spa. On an annual basis, we cleanse our marketing databases and remove data from our lists for the purposes of direct marketing that have not engaged with our marketing communication in any way during the previous two years. We will continue to keep any personal data to do with your purchases from us for a period of 6 years after the purchase or stay.

YOUR RIGHTS

RIGHT TO REVOKE CONSENT
If we process personal data on the basis of your consent, you have the legal right to revoke such consent at any time. We will then cease the relevant processing activity going forward.

RIGHT OF ACCESS TO YOUR INFORMATION
If you would like to know what personal data we have collected or process about you, you may request us to provide a copy of your personal data by sending an email to privacy@daffodilhotel.com. We will ask you to identify yourself. We will not provide you with a copy of such data to the extent that the rights and freedoms of others are or may be adversely affected by such disclosure to you such as the data containing personal data about others.

RIGHT TO RECTIFICATION AND ERASURE OF DATA, AND RESTRICTION OF PROCESSING
If you believe that our processing of your personal data is incorrect, inaccurate, unlawful, excessive, incomplete, no longer relevant, or if you think that your data is stored longer than necessary, you may ask us to change or remove such personal data or restrict such processing activity, by sending an email to privacy@daffodilhotel.com.

RIGHT TO DATA PORTABILITY
You have the right to receive your personal data, which you have provided to us, in a structured, commonly used and machine-readable format, in accordance with section 20 of the General Data Protection Regulation.

RIGHT TO OBJECT
You have the legal right to object, on grounds relating to your particular personal situation, at any time to processing of your personal data which is based on the legal basis of either point (e) or (f) of section 6(1) of the General Data Protection Regulation (i.e. the performance of a task carried out in the public interest; the purposes of our, or a third party’s, legitimate interests) including profiling based on those provisions. We will only cease the processing if so required under section 21(1) of the General Data Protection Regulation. Furthermore, you have the right to object at any time to our processing of your personal data for direct marketing purposes by either (i) opting out by using the option we provide in the relevant direct marketing message (e.g. an email newsletter), or (ii) by sending an email to privacy@daffodilhotel.com.

GENERAL INFORMATION RELEVANT FOR ALL REQUESTS AND QUERIES
You must exercise your rights, as explained in this clause, in accordance with applicable law, in particular section 15, 16, 17, 18, 20 and 21 of the General Data Protection Regulation, if and when it applies. We will solely review your request or query in light of our obligations under applicable mandatory data protection law. Nothing in this Policy is intended to provide you with rights beyond or in addition to your rights as a data subject under applicable mandatory data protection law.

We will use reasonable endeavours to respond to your request or query within one month. We are entitled to extend this term by another two months if the complexity of the situation so requires. If your request is manifestly unfounded or excessive we may either (i) charge you a fee, or (ii) refuse to process your request. With respect to access requests we may also charge you for extra copies. If we decide not to honour your request or answer your query, we will explain our reasons for doing so in our reply.

HOW YOU CAN ACCESS AND UPDATE YOUR INFORMATION
The accuracy of your information is important to us. If you change email address, or any of the other information we hold is inaccurate or out of date, please email privacy@daffodilhotel.com, or contact our Privacy Manager via post at The Daffodil Hotel & Spa, Keswick Road, Grasmere, LA22 9PR. Alternatively, please do feel to contact us by phone on 015394 63550.

You have the right to ask for a copy of the information The Daffodil Hotel & Spa hold about you at any time.

SECURITY PRECAUTIONS IN PLACE TO PROTECT THE LOSS, MISUSE OR ALTERATION OF YOUR INFORMATION
When you give us personal information, we take steps to ensure that it is treated securely. Any sensitive information (such as credit or debit card details) is encrypted and protected with appropriate software. When you are on a secure page, a lock icon will appear on the bottom of web browsers such as Microsoft Internet Explorer, Safari or Firefox.

Non-sensitive details (your email address etc.) are transmitted normally over the Internet, and this can never be guaranteed to be 100% secure. As a result, whilst we strive to protect your personal information, we cannot guarantee the security of any information you transmit to us, and you do so at your own risk. Once we receive your information, we make our best effort to ensure its security on our systems.

PROFILING
For the purpose of customer relationship management and campaign effectiveness, we may analyse your personal information to create a profile of your interests and preferences so that we can contact you with information relevant to you. We may make use of additional information about you when it is available from external sources to help us do this effectively. We may also use your personal information to detect and reduce fraud and credit risk.

USE OF COOKIES
Like many other websites, The Daffodil Hotel & Spa website uses cookies. ‘Cookies’ are small pieces of information sent by an organisation to your computer and stored on your hard drive to allow that website to recognise you when you visit. They collect statistical data about your browsing actions and patterns and do not identify you as an individual. For example, we use cookies to store your country preference. This helps us to improve our website and deliver a better more personalised service.

It is possible to switch off cookies by setting your browser preferences. For more information on how to switch off cookies on your computer, visit our Cookies Policy. Turning cookies off may result in a loss of functionality when using our website.

LINKS TO OTHER WEBSITES
Our website may contain links to other websites run by other organisations. This Policy applies only to our website, so we encourage you to read the privacy statements on the other websites you visit. We cannot be responsible for the privacy policies and practices of other sites even if you access those using links from our website.

In addition, if you linked to our website from a third party site, we cannot be responsible for the privacy policies and practices of the owners and operators of that third party site and recommend that you check the policy of that third party site.

WEBSITE RECORDING
Our web site may also use Lucky Orange web site recording service. Lucky Orange is a product that has been developed by Lucky Orange Ltd. Lucky Orange may record mouse clicks, mouse movements, page scrolling and any text keyed into website forms. The information collected does not include bank details or any sensitive personal data. Data collected by Lucky Orange is for The Daffodil Hotel & Spa’s internal use only. The information collected is used to improve our website usability and is stored and used for aggregated and statistical reporting.

16 AND UNDER
We are concerned to protect the privacy of children aged 16 or under. If you are aged 16 or under, you will be required to provide parent/guardian’s consent beforehand whenever you provide us with personal information.

TRANSFERRING YOUR INFORMATION OUTSIDE EUROPE
As part of the services offered to you through this website, the information which you provide to us may be transferred to countries outside the European Union (“EU”). By way of example, this may happen if any of our servers are from time to time located in a country outside of the EU. These countries may not have similar data protection laws to the UK. When you submit your personal data, you either agree to this transfer, storing or processing or it will be undertaken to enter into or perform a contract to which you are a party or for the purposes of our legitimate interests. If we transfer your information outside of the EU in this way, we will take steps to ensure that appropriate security measures are taken with the aim of ensuring that your privacy rights continue to be protected as outlined in this Policy.

If you use our services while you are outside the EU, your information may be transferred outside the EU in order to provide you with those services.

CHANGES TO OUR PRIVACY POLICY

We are committed to keeping our policy under regular review, this policy was last updated in April 2018.

HOW TO CONTACT US

Please contact us if you have any questions or feedback about our Privacy Policy or the information we hold about you by emailing privacy@daffodilhotel.com, or contacting our Privacy Manager via post at The Daffodil Hotel & Spa, Keswick Road, Grasmere, LA22 9PR. Alternatively, please do feel to contact us by phone on 015394 63550.

COMPLAINTS

If you have a complaint to do with your personal data or our use of it please send an email to privacy@daffodilhotel.com and we will investigate it for you. If you wish you can complain to the Information Commissioner’s Office on ico.org.uk.

Crerar Hotel Group Privacy Policy

Dunkeld House Hotel Group Privacy Policy