Clermont Hotel Management Limited (“we”, “our”, “us”) is the data controller when you provide information to any of our brands, including: Thistle, Thistle Express, The Clermont Hotel and Guoman Hotels.

When you interact with our products and services, for example when browsing our website or booking a hotel room, we collect information about you and that particular interaction. Generally, this may include your personal data which means personal details from which you can be identified or are identifiable, for example:

• Contact information, and preferences;
• Information about your use of our hotels, and other services when you stay with us;
• Images of you in areas of our hotels covered by CCTV;
• Conversations you have when you call our reservations or sales teams;
• Information about anyone you’re travelling with or meeting, if that information is provided to us; and Information about the devices you use to interact with us.
• More sensitive information, for example when you tell us about dietary requirements, disabilities, and religious beliefs;

Where you provide us with sensitive details, for example in relation to requirements you may have regarding accessibility to our hotels, we will only hold this information with your express permission. This information is stored securely with restricted access and handled the greatest respect for your privacy.

Where you provide information to us about other people, you need to make sure you have their permission to do so or that you can speak on their behalf, for example, in the case of children.

We collect information you provide to us directly and indirectly when interacting with our products and services, including when you stay with us. This may include when you:

• Book a room online, over email or on the phone;
• Create, use or manage an online account;
• Sign up to our loyalty programmes
• Visit our website or use our apps;
• Fill out our online forms or registration cards;
• Visit our hotels or use our hotel services, like room service or gym and spa facilities;
• Access hotel internet;
• Use our restaurants;
• Use social media login functionality;
• Interact with us in online forums, by email, text, telephone, or on social media;
• Post reviews of your stay or interaction with us;
• Complete our market research/customer surveys; and
• Enter competitions or promotions.

All organisations need a legal reason to use your personal information, if they don’t have one, they can’t use it. There are a number of legal grounds that enable data processing. It’s quite complicated but below are the most relevant grounds you should be aware of.

There are some activities where we process personal information with your consent, for example, where we want to send you marketing messages by email, we would ask your permission first and you could opt-out at any time by clicking on the unsubscribe link on the email or updating your account preferences. We will indicate in the Policy where we rely on consent.

We also process your personal information in order to fulfil a contract we have with you. For example, when you book a stay with us, we will process your information to administer that stay.

Sometimes we may use your information to help achieve our business objectives but only where that activity doesn’t negatively affect your rights. For example, we might use your information to analyse occupancy rates of our hotels and adjust room rates or to send you details of special offers or other information about our hotels. You can object to us relying on our legitimate interest to use your personal data in these ways at any time through your account preferences or by getting in touch with us using the contact details below.

There may be situations where we need to use your information to comply with legal obligations. For example, we are required by law to keep records of who is in our hotels in case there is an emergency, so we can make sure you’re safe.

The reason we use your information will often be obvious from the way you interact with us. For example, if you book a room at one of our hotels, we would use that information to administer your stay with us. However, our uses of your information may not always be so obvious. You can find out more below. When you provide your information to us, we may use it to:

Technical and organisational measures

We have secure systems and processes in place to ensure the personal information you provide us is kept safe. We store personal information on our secure electronic systems. Your information may be transferred to one of our reputable cloud-based service providers who may store and process this information outside the UK or European Economic Area (EEA). We can assure you that we take all reasonable steps to ensure your data is handled securely under appropriate agreements with our suppliers.

How we store your personal information and how long we keep it for

We will retain your information for as long as necessary for the uses set out in this Policy or while there is a legitimate business reason for doing so. If you ask us to delete your information before this time, we may not be able to do so for technical, legal, regulatory or contractual constraints. For example, where you wish to be suppressed from direct marketing, we would need to retain your information for this purpose. Where you ask for your account to be closed, we will do this as soon as possible subject to any terms and conditions relating to the account. Your information will be retained in order to comply with legal and regulatory obligations as well as for analysis, to prevent fraud, collect any monies owed, and to resolve disputes.

Our processors

There may be situations where we use data processors – companies who act on our behalf – to collect your information for us or to use the personal data we pass to them to provide your service. These processors can only use your information in accordance with our instructions and for the purposes in this Policy.

Identity verification

If we provide a service that is dependent on age or residency we have an obligation to verify relevant information. Where relevant we may pass your information to a third party for this purpose.

We also receive information about you indirectly when you interact with us. For example, when you visit our websites or use our apps the devices you use may provide us with your general location (like which country or region you’re in). They also tell us if you are using ad-blockers and your IP address. We may also receive information from cookies and other technologies that are on your device or browser. For more information on our use of cookies, please see our cookie policy.

We collect information about you when it is provided to us by third parties. This might include online travel agents, travel websites, and other partners. This could be when you make bookings, review your stay online, or where you interact with anyone who promotes our brands. You should always read the privacy policies of travel companies or other third parties you use, as they will use your information in accordance with their own privacy policies. When you, or someone on your behalf, make a booking using travel agent, booking platform or other third party to use our services, they may pass us information about your booking, including information about anyone else on that booking. The same would be true where you use a third party to make enquiries about our products or services. Where you interact with third parties who promote our services for us, these third parties may pass us your information. When you post comments, reviews, or engage in discussions and polls about our products and services, we may receive this information from the platform you interacted with or from our partners who monitor how our brands are performing. We may also obtain information about you from our partners and other companies that have your permission to share your information both online and offline, like insight providers. Sometimes we may want to improve our products and services by getting a better understanding about our customers and their preferences. In these situations we may ask reputable insight providers to provide us information that may identify you. However, this would only be where you have specifically consented to that third party providing your information to us. Where we do receive information about you from other sources, we may combine it with information we already hold about you and use it in accordance with this Policy. We may receive updated information about you from organisations that provide services to you. For example, we might be updated if you move home so that we can keep our records up to date or receive updated bank details to ensure that you can continue to use our products and services. Alternatively, we may be updated if your flight is late, so that we can anticipate your arrival more accurately. Where we engage with credit reference agencies (for example if you were using our hotel facilities for a business event) we would only do this with your explicit consent.

We sometimes use your information for reasons that we think you might want a bit more detail on, so to help we have added more information to these below.

Profiling and preferences

We sometimes make decisions about what your interests are based on the way that you interact with us and the information we hold about you, this is called profiling. For example, if you regularly stay at a particular hotel or frequently choose a specific room or pillow type, then we might use this information improve your experience by pre-selecting certain features of your stay for you, so you don’t need to. Understanding your preferences and personalising your experience in this way allows us to deliver the very best service possible.

Do not track signals or browser/device settings Our websites are not designed to respond to “do not track” signals or browser/device settings.

Direct marketing

In addition to sending you information about the products and services you use (product communications) and in-life communications while you stay with us, where we have your permission or where we are relying on our legitimate interest, we may send you direct marketing communications about our products, services, events and offers.

Direct marketing communications may be sent by post, email, telephone, SMS and MMS, through social media (such as Whatsapp, Instagram, Twitter, and Facebook), messages including push notifications to your mobile devices, and via other electronic means such as when you visit our websites or use our apps. This may also include any websites and apps of our partners who are in our advertising networks.

We may send you direct marketing while you have an ongoing relationship with us and for a reasonable time after you have used one of our products or services where we feel we have a legitimate interest.

You will be able to opt-out of direct marketing by following the instructions in the communications you receive or changing your device settings. Alternatively, where you have an account with us, you will be able to log-in and change your marketing preferences.

Product related communications and “in-life” updates

We may use your information to send you newsletters, bulletins, and other “in-life” communications (about your stay), and triggered communications where you make changes to your account or other information about products and services you have signed up for.

For example, we may send you email or text messages about an upcoming stay with us in order to help you plan your visit and give you the best experience possible. You’ll be able to opt-out of these.

Service communications will be sent to you regarding products and services you interact with. These are important messages relating to the products and services we provide to you.

Data matching and audience insights

Sometimes we may compare our customer database with our commercial customers or partners databases either directly with each other or by using an independent third party. This helps us understand if customers are on both databases, and allows us to plan joint marketing activities, and promotions. Additionally, we may match databases for business planning/continuity purposes.

We may use marketing permissions we hold to contact those customers for promotions that relate to data matching exercises.

We will only share personal information for data matching purposes where we have an agreement in place with the commercial customer or partner. This ensures that they comply with their data protection obligations, protect the information we share and limit the use of any shared information.

We may provide commercial customers and partners with information about the effectiveness of campaigns they run and well as the potential reach of future campaigns by providing aggregated reports of customer segments. This is called audience insights and helps us plan promotions and other marketing campaigns. Your personal information is not shared for this activity. You have the right to object to us processing your information this way, known as profiling. If you would like to opt-out of profiling, you can do this in your account preferences or by contacting us using the details below, where this feature is available.

Analysis and product development

We may use your information to improve the products and services we offer. For example, we may look at the preferences our guests have when they stay with us to offer more relevant personalisation to customers.

Detecting ad blockers

When you visit our websites we may check (by using script, code, cookies or other technical means) if you are using ad-blocker or other privacy tools. If we do detect one of these tools, we may ask you or ask your browser to ask you, if you would give us permission to ignore those settings and continue to serve adverts and/or collect your information using cookies and similar technologies.

Information about your device and use of ad blockers may be stored or associated with your device and used to reinsert adverts and to understand how ad blockers and other privacy tools are being used by our visitors.

Our website may, from time to time, contain links to other websites which are outside of our control and are not covered by this Policy. We do not accept any responsibility or liability for other sites’ privacy policies. If you access other websites using the links provided, please check their policies before submitting any personal information.

Your information may be used to take payment for products and services and may be used to verify credit details related to payments.

Your information will be disclosed where we are obliged by law to do so. We may also disclose your information where we are allowed by law to protect or enforce our rights or the rights of others and for the detection and prevention of crimes, such as fraud.

If you post or send offensive or inappropriate content anywhere on or to any of our websites or apps, or otherwise engage in disruptive behaviour on any of our websites or apps, we may use the information that is available to us about you to stop such behaviour. This may involve responding to or informing relevant third parties and law enforcement agencies about the content and your behaviour.

When you complete our registration forms or use our services, we may transfer your information to our processors - companies that carry out activities on our behalf, only on our instructions - outside the UK or European Economic Area (EEA) to countries that may not have data protection rules that provide the same level of protection to your personal information as the UK or countries in the EEA. However, we will only transfer your information if we have appropriate measures in place to ensure the protection of your information in accordance with applicable data protection legislation. (For example, model contract clauses or UK-US Data bridge in the case of the USA).

When you give us information about other individuals, you confirm that you have authority to act for them and have made them aware of the potential transfer of their information outside the UK or EEA.

If you call contact us by phone or on chat the conversation may be recorded and listened to for training and quality purposes.

Our websites and apps provide plug-ins to social media websites, including Facebook, Twitter, Google, Yahoo and LinkedIn.

If you make use of, or log-in to, the social media features on our websites or apps, we may (depending on your privacy settings) access, use and store information about you, including, but not limited to: your name, e-mail address, gender, location, profile, picture, contacts, and any other information you have chosen to make available.

To find out more about the reasons and extent to which social media sites collect and process your data, or to change your privacy settings, please refer to your social media provider’s privacy policy.

Where you provide your information to us we may share it with our group companies and affiliates, advertising networks and partners, commercial partners (including but not limited to owners of hotel businesses we manage or to whom we have licensed a brand and/or hotel system), and sharing with our suppliers.

What sharing takes place will depend on the activity that your information is being used for. Your information will only be shared and used in accordance with this Policy and where an agreement is in place to ensure that your information is protected. We won’t sell your personal information without your consent or share it with other organisations for their own marketing purposes, unless you have consented to such sharing.

With your consent, we will share your email address with Trip Advisor, in order for them to send you a post stay survey. You will be sent an initial email and one reminder. If you do not respond, Trip Advisor will not continue to use your email address for this purpose. If you wish to complete the survey, you will be asked to create a Trip Advisor member profile which is covered by Trip Advisor’s own terms and conditions and privacy policy rather than those of Clermont Hotel Group. Trip Advisor’s Privacy Policy can be found here.

We will share your information within our group of hotels (as named above) for administrative purposes such as managing bookings and guest stays, as well as making sure information is accurate, up to date and to enable business planning and continuity.

Sharing with advertising partners

When you visit our websites or apps we may pass information about you and any devices you are using to our advertising network partners to enable them to deliver relevant adverts and tell advertisers that adverts have been delivered and seen.

Sale of our business

If we restructure or sell all or part of our business or business operations, we may transfer your information as part of that activity, including, but not limited to, where we transfer or cease to manage (or license the use of a brand at) a hotel. Where this is the case your information will be used in accordance with this Policy unless you are notified otherwise.

Please ensure you keep your information up to date by logging into your account and modifying it. Alternatively, you can tell us when you check-in that your information has changed and we will update it for you.

Controlling direct marketing

You can change your mind about receiving direct marketing from us or change your preferences by logging into your account, if you have one, opting-out in any marketing or product communication you have received from us or emailing us using the contact details below.

Requesting copies of your information

You may request a copy of your personal information which we may hold about you by getting in touch with us using the contact details below. You may also ask us to correct any inaccuracies in your personal information. This right may be restricted by law where disclosing information may result in the personal information of other individuals being disclosed and it would be unreasonable to do so.

Withdrawing consent

Where we may rely on consent to use your information, you have the right to withdraw that consent for that processing activity at any time by logging into your account, if you have one, opting-out in any marketing or product communication you have received from us or emailing us using the contact details below. However, we may have the right to rely on an alternative legal basis for the processing activity so that we are able to provide you with the product or service you have requested and, in that case, will inform you of that.

Other rights

You may have the right to object, erase, or restrict our processing of your information - for example, where we process your personal information because this is in our legitimate interests, you may object to this. We will carefully consider your request as there may be circumstances which require us to, or allow us to, continue processing your data.

Complaining to the regulator

If you have any comments, concerns or complaints about our uses of your information we would ask that you contact us first, so that we can try and resolve any matter. However, where we are unable to help, you are able to complain to the Information Commissioner’s Office in the United Kingdom or the data protection regulator in your country of residence, who will be able to liaise with the UK Information Commissioner in the UK. Details for the UK Information Commissioner can be found at https://ico.org.uk/

Changes to our Privacy Policy

From time to time we may make changes to this Policy. This might be in relation to changes in the law, best practice, changes to the services we provide or collection and use of your personal information. We will always display clearly when the Policy was last updated and where appropriate, notify you of any relevant changes.

Contact

If you would like to get in touch with us, please contact

By Email: data.protection@clermonthotel.group

By Post: The Data Protection Officer, Clermont Hotel Management Limited, 110 Central Street, London EC1V 8AJ

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Performance Cookies - Performance cookies also allow us to see if there are any technical issues on our websites and if you are experiencing any issues using our websites. They also allow us to look at usage statistics and performance. We use Google Analytics to help us understand how you use our services. For more information on Google Analytics, please visit Google’s website.

Functional cookies - These cookies collect information about the language you have requested the site display content in, remembering your username so you can log-in more quickly, text size, location you are in and generally allow us to customise your experience. Nobody likes having to repeat themselves and these cookies help with that.

Tracking and advertising cookies and similar technologies - We use these types of cookies and similar technologies to provide adverts that we think may be more relevant to your interests. This can be based on your browsing activity and is known as Online Behavioural Advertising or OBA. Cookies are placed on your browser, which remembers what websites you’ve been to. Advertising based on what you have been viewing is then displayed.

Web beacons and tracking pixels - These technologies help us to count users on a web page, and see if a cookie has been activated. They allow us to see how popular content is and if an email has been delivered to a recipient, opened and links clicked on. We use this information to track how successful campaigns have been.

Flash cookies - Sometimes we may use flash players to deliver special content, such as video clips. This uses Local Shared Objects or flash cookies to remember settings. Device Fingerprinting - Sometimes we may use a device’s browser information to identify that device, conduct analysis, help detect and prevent fraud and present content correctly. We also use cookies and similar technologies to:

• Allow you access to our websites;
• Permit your internet connection to our websites;
• Allow our servers to record information about your device (such as IP address, browser type, location, hardware and software information;
• Collect unique device identifier (UDID), geo-location and other transactional data to validate free trials when you use a mobile device;
• Assess content usage;
• Provide relevant content;
• Sell third party advertising and enable frequency capping;

ContentSquare Cookies

ContentSquare is a solution which aggregates usage and frequency data to improve user experience. Statistics created are anonymous and do not contain any personal data.

To opt-out of ContentSquare Cookies, please click here.

You can change your cookie settings very easily in your browser settings. However, you need to be careful about restricting the use of cookies, as they may prevent the websites you visit from working as they were intended.

You can also control which companies set cookies on your devices by visiting the following pages. Please note that you will need to turn off any ad blockers or privacy tools to see what cookies are being set:

Internet Advertising Bureau (IAB) Your Online Choices is an industry programme that allows you to control which companies can set cookies and show you advertising. It provides you an easy way of opting out several advertising networks.

The Network Advertising Initiative control page also allows you to control OBA from the advertising networks they represent.

The Digital Advertising Alliance’s control page also allows you to control cookies too.

It is important to remember that these services use cookies to remember that you have opted-out of cookies being placed on your browsers. If you clear your cache, the opt-outs will be forgotten and you will have to opt-out again.

You can stop web beacons being set, although you cannot decline receiving them in emails. For information about managing these, please visit https://www.allaboutcookies.org/