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.

Dunkeld House Hotel Privacy Policy

This privacy policy sets out how Dunkeld Opco Ltd t/a Dunkeld House Hotel (Dunkeld House) uses and protects your personal data. It will also tell you about your privacy rights and how the law protects you.

1. IMPORTANT INFORMATION AND WHO WE ARE

2. TYPES OF PERSONAL DATA WE COLLECT ABOUT YOU

3. HOW IS YOUR PERSONAL DATA COLLECTED?

4. HOW WE USE YOUR PERSONAL DATA

5. DISCLOSURES OF YOUR PERSONAL DATA

6. INTERNATIONAL TRANSFERS

7. DATA SECURITY

8. DATA RETENTION

9. YOUR LEGAL RIGHTS

10. CONTACT DETAILS

11. COMPLAINTS

12. CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES

13. THIRD PARTY LINKS]

1 Important information and who we are

1.1 Dunkeld House Hotel is a company registered in England and Wales with registered company number 13789389. Dunkeld House is part of a corporate group of companies (our Group), which includes Crerar Hotel Group Limited (a company registered in England and Wales with registered company number 00075625) and Fairtree Hotels Limited (a company registered in England and Wales with registered company number 13697442).

Purpose and application of this privacy policy

1.2 This privacy policy addresses how Dunkeld House collects and processes your personal data as a controller. Dunkeld House is the company responsible for processing your personal data.

1.3 For the avoidance of doubt, our sister company, Crerar Hotel Group Limited (Crerar Hotels) provides certain hotel management services to us from time to time. Where Crerar Hotels collect and process your personal data on our behalf, this privacy policy applies to such collection and use of your personal data. If you contact Crerar Hotels directly (including via www.crerarhotels.com) regarding another hotel listed on their website or in respect of any matter not connected to Dunkeld House, this privacy policy will not apply and instead such collection and use shall be subject to their own privacy policy

1.4 This privacy policy applies regardless of the method through which Dunkeld House collects and uses your personal data - whether this be personal data collected from you through your use of this website through your use of our mobile app, during a hotel visit or when you otherwise contact us (including telephone and email enquiries). This privacy policy also applies where you contact Crerar Hotels (including via www.crerarhotels.com or www.careers.crerarhotels.com) specifically about any matter connected to Dunkeld House (including any enquiry about staying or visiting Dunkeld House or any response to a vacancy advertised at Dunkeld House).

1.5 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

1.6 Dunkeld House Hotel is the controller and responsible for your personal data (collectively referred to as Dunkeld House , we, us or our in this privacy policy).

1.7 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).

2 The types of personal data we collect about you

2.1 Personal data means any information about an individual from which that person can be identified.

2.2 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.

2.3 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.

2.4 When you visit Dunkeld House, we may collect, use and process Identity Data which may include dietary, health and medical and/or disability information. In addition, as part of Dunkeld House's 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.

3 How is your personal data collected?

3.1 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:

o submit an enquiry to us (whether online, by telephone, by email or via social media);

o make a reservation with us (including room, spa, restaurant and leisure bookings);

o 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);

o fill in a questionnaire or form (including a spa consultation form);

o subscribe to our newsletter;

o request marketing to be sent to you;

o enter a competition, promotion or survey;

o enquire about or apply to work with us; or

o 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:

o Technical Data is collected from the following parties:

§ analytics providers such as Google based outside the UK; and

§ marketing or advertising partners,

o 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.

4 How we use your personal data

Legal basis

4.1 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

4.2 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

(a) Identity

(b) Contact

(a) Necessary for our legitimate interests (to manage our relationship with you)

To process and deliver your reservation including:

(a) Manage payments, fees and charges

(b) Collect and recover money owed to us

(c) Record and meet any special requirements or preferences you tell us about (including any accessibility, dietary and health/medical requirements you have)

(a) Identity

(b) Contact

(d) Transaction

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(d) 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:

(a) Notifying you about changes to our terms or privacy policy

(b) Dealing with your requests, complaints and queries

(a) Identity

(b) Contact

(d) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(d) 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 hotel and monitoring activity in our hotel through CCTV recordings (to the extent that these are used and available)

(a) Identity

(b) Contact

(d) Usage

(e) Profile

(a) Processing is necessary for compliance with a legal obligation.

(b) Our legitimate interests (to ensure the safety and wellbeing of individuals and the physical security of our hotel and business).

To conduct a recruitment process

(a) Identity Data

(b) Contact Data

(a) Necessary for our legitimate interests (of running a recruitment process and keeping records of such process)

(b) 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)

(d) 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

(a) Identity

(b) Contact

(d) Usage

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to study how guests and other visitors use our hotel 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)

(a) Identity

(b) Contact

(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 improve our hotel and the services we (and our Group) provide to guests and other hotel visitors

(a) Technical

(b) Usage

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

(a) Identity

(b) Contact

(d) Usage

(e) Marketing and Communications

(f) 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

(a) Technical

(b) 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 Dunkeld House 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

(a) Identity

(b) Contact

(d) Usage

(e) Profile

(f) Marketing and Communications

(a) Consent; and/or

(b) 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

(a) Identity

(b) Contact

(d) Profile

Necessary for our legitimate interests (to study how guests and other visitors use our hotel and to help us improve our guest experiences).

To capture images of events we host at Dunkeld House for inclusion within our marketing literature

(a) Identity

Consent

Direct marketing

4.3 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.

4.4 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

4.5 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

4.6 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).

4.7 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.

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

5 Disclosures of your personal data

5.1 Your personal data may be shared with other companies within our Group (who are based in the United Kingdom).

5.2 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.

5.3 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.

6 International transfers

6.1 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.

6.2 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.

6.3 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.

7 Data security

7.1 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.

7.2 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.

8 Data retention

How long will you use my personal data for?

8.1 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.

8.2 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.

8.3 You can request further details of retention periods for different aspects of your personal data by contacting us directly (please see section 10).

9 Your legal rights

9.1 You have a number of rights under data protection laws in relation to your personal data.

9.2 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:

o If you want us to establish the data's accuracy;

o Where our use of the data is unlawful but you do not want us to erase it;

o 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

o You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

9.3 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 required

9.4 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

9.5 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

9.6 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.

10 Contact details

10.1 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: ℅ Data Officer, Dunkeld House, Blairgowrie Road, Dunkeld, PH8 0HX

· Telephone number: 01350 727771

11 Complaints

11.1 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.

12 Changes to the privacy policy and your duty to inform us of changes

12.1 We keep our privacy policy under regular review. This version was last updated on 1st November 2024.

12.2 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.

13 Third-party links

13.1 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.

Fonab Castle Hotel Ltd Privacy Policy

This privacy policy sets out how Fonab Castle Hotel Ltd (Fonab Castle) uses and protects your personal data. It will also tell you about your privacy rights and how the law protects you.

1. IMPORTANT INFORMATION AND WHO WE ARE

2. TYPES OF PERSONAL DATA WE COLLECT ABOUT YOU

3. HOW IS YOUR PERSONAL DATA COLLECTED?

4. HOW WE USE YOUR PERSONAL DATA

5. DISCLOSURES OF YOUR PERSONAL DATA

6. INTERNATIONAL TRANSFERS

7. DATA SECURITY

8. DATA RETENTION

9. YOUR LEGAL RIGHTS

10. CONTACT DETAILS

11. COMPLAINTS

12. CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES

13. THIRD PARTY LINKS]

1 Important information and who we are

1.1 Fonab Castle Hotel Ltd is a company registered in England and Wales with registered company number 08275224. Fonab Castle is part of a corporate group of companies (our Group), which includes Crerar Hotel Group Limited (a company registered in England and Wales with registered company number 00075625) and Fairtree Hotels Limited (a company registered in England and Wales with registered company number 13697442).

Purpose and application of this privacy policy

1.2 This privacy policy addresses how Fonab Castle collects and processes your personal data as a controller. Fonab Castle is the company responsible for processing your personal data.

1.3 For the avoidance of doubt, our sister company, Crerar Hotel Group Limited (Crerar Hotels) provides certain hotel management services to us from time to time. Where Crerar Hotels collect and process your personal data on our behalf, this privacy policy applies to such collection and use of your personal data. If you contact Crerar Hotels directly (including via www.crerarhotels.com) regarding another hotel listed on their website or in respect of any matter not connected to Fonab Castle, this privacy policy will not apply and instead such collection and use shall be subject to their own privacy policy

1.4 This privacy policy applies regardless of the method through which Fonab Castle collects and uses your personal data - whether this be personal data collected from you through your use of this website (www.fonabcastlehotel.com), through your use of our mobile app, during a hotel visit or when you otherwise contact us (including telephone and email enquiries). This privacy policy also applies where you contact Crerar Hotels (including via www.crerarhotels.com or www.careers.crerarhotels.com) specifically about any matter connected to Fonab Castle (including any enquiry about staying or visiting Fonab Castle or any response to a vacancy advertised at Fonab Castle).

Controller

1.6 Fonab Castle is the controller and responsible for your personal data (collectively referred to as Fonab Castle, we, us or our in this privacy policy).