HARBOUR HOTELS Privacy policy Welcome to www.harbourhotels.co.uk (the “Site”). Introduction We understand that privacy online is important to users of our Site, especially when conducting business. This statement governs our privacy policies with respect to those users of the Site who visit without transacting business and Visitors who register to transact business on the Site and make use of the various services offered by Harbour Hotels. Who we are Your personal information is collected by Harbour Hotels Group Limited trading as Harbour Hotels. Registered address: Harbour Hotels 60 Purewell Christchurch Dorset BH23 1ES We are a hospitality group providing accommodation, restaurant and spa services. This privacy policy explains how we use any personal information we collect about you when you use this website or stay at our hotel. Harbour Hotels Group Limited is registered as a data controller with the Information Commissioner’s Office. Our brand hotels are also covered by their own ICO registrations. The current data controller registration details are: Data Controller Name: Harbour Hotels Group Limited Registration Number: ZA209486 Date Registered: 5 October 2016 Data Controller Name: Bond Street (Estates) Brighton Limited Registration Number: ZA209448 Date Registered: 5 October 2016 Data Controller Name: Bristol Harbour Hotel Limited Registration Number: ZA209462 Date Registered: 5 October 2016 Data Controller Name: Chichester Harbour Hotel Limited Registration Number: ZA209465 Date Registered: 5 October 2016 Data Controller Name: Christchurch Hotels Limited Registration Number: ZA209312 Date Registered: 4 October 2016 Data Controller Name: Christchurch Restaurants Limited Registration Number: ZA209443 Date Registered: 5 October 2016 Data Controller Name: Fowey Harbour Hotel Limited Registration Number: ZA460078 Date Registered: 18 September 2018 Data Controller Name: Froyle Harbour Hotel Limited Registration Number: ZA209466 Date Registered: 5 October 2016 Data Controller Name: RMH (Guildford) LLP Registration Number: ZA209475 Date Registered: 5 October 2016 Data Controller Name: Kings Harbour Hotel Limited Registration Number: ZA209468 Date Registered: 5 October 2016 Data Controller Name: Padstow Harbour Hotel Limited Registration Number: ZA460087 Date Registered: 18 September 2018 Data Controller Name: Porthminster Hotel Company Limited Registration Number: ZA209471 Date Registered: 5 October 2016 Data Controller Name: Richmond Harbour Hotel Management Limited Registration Number: ZA298236 Date Registered: 28 November 2017 Data Controller Name: Salcombe Harbour Hotel Limited Registration Number: ZA209476 Date Registered: 5 October 2016 Data Controller Name: Southampton Harbour Hotel Limited Registration Number: ZA284413 Date Registered: 5 October 2016 Data Controller Name: Westcliff Hall (Sidmouth) Limited Registration Number: ZA209478 Date Registered: 5 October 2016 What information do we collect about you? At various times, we will be obliged to ask you, as a Harbour Hotels customer, for information about you and/or members of your family, such as: Contact details (for example, last name, first name, telephone number, email) Personal information (for example, date of birth, nationality) Information relating to your children (for example, first name, date of birth, age) Your credit card details (for transaction and reservation purposes) Your arrival and departure dates. Your preferences and interests (for example, smoking or non-smoking room, preferred floor, type of bedding, type of newspapers/magazines, sports, cultural interests) Your questions/comments, during or following a stay in one of our hotel The information collected in relation to persons under 18 years of age is limited to their name, nationality and date of birth, which can only be supplied to us by an adult. We also collect web statistics automatically about your visit to our site. This information is used to help us follow browsing preferences on our site so that we can regularly improve our website. These statistics do not contain personal data and cannot be traced back to an individual. We do not use cookies to store personal data or link non-personal information stored in cookies with personal data about specific individuals. We will only disclose your information if it is lawful to do so in accordance with the principles of the Data Protection Act 2018 or the General Data Protection Regulation (GDPR) (EU) 2016/679. How will we use the information about you? We use your information in a number of different ways, primarily to fulfil a contract and also provide excellent service to our customers — what we do depends on the information. The tables below set this out in detail, showing what we use the information we collect for, and the lawful basis we rely on to process it. Your Rights You have rights relating to your personal information: The right to be informed about how your personal information is being used The right to access the personal information we hold about you The right to request the correction of inaccurate personal information we hold about you The right to request that we delete your data, or stop processing it or collecting it, in some circumstances The right to restrict direct marketing messages, and to withdraw consent for other consent-based processing at any time The right to request that we transfer or port elements of your data either to you or another service provider The right to complain to your data protection regulator — in the UK, the Information Commissioner’s Office If you want to exercise your rights, have a complaint, or just have questions, please contact us, details in the contact us section at the end of this document. The Data Protection Act 2018 also gives you the right to lodge a complaint with the supervisory authority in the UK. This is Information Commissioner who may be contacted at https://ico.org.uk/concerns or telephone: 0303 123 1113. Keeping Your Information We’ll hold on to your information for as long as you have a booking with us, and for as long as is necessary to provide support-related reporting. We’ll also hold on to your information, if reasonably necessary or required, to meet legal or regulatory requirements, resolve disputes, prevent fraud and abuse, or enforce our terms and conditions. We may also keep hold of some of your information as required, even if it is no longer needed to provide the services to you. We may share information. When it is necessary for us in delivering our products and services to you and for the purposes set out in this Privacy Policy, we may share your personal information with the below parties: Other hotels operated by us Business partners and third parties involved in the delivery of services Our marketing and advertisement partners Our agents, advisors, consultants and other third parties in order to enable us to operate effectively and provide the best service to our guests Third parties when we have your consent or if it is legally required How we secure your information Harbour Hotels takes data security seriously, and we use appropriate technologies and procedures to protect personal information. Our information security policies and procedures are aligned with widely accepted international standards, we apply the controls detailed in the Payment Card Industry Data Security Standard to all environments storing personal data. These standards are applied and are reviewed regularly and updated as necessary to meet our business needs, changes in technology, and regulatory requirements. For example: Policies and procedures We have measures in place to protect against accidental loss and unauthorized access, use, destruction, or disclosure of data We have a Business Continuity and Disaster Recovery strategy that is designed to safeguard the continuity of our service to our clients and to protect our people and assets We place appropriate restrictions on access to personal information We implement appropriate measures and controls, including monitoring and physical measures, to store and transfer data securely We conduct Privacy Impact Assessments in accordance with legal requirements and our business policies Training for employees and contractors We require privacy, information security, and other applicable training on a regular basis for our employees and contractors who have access to personal information and other sensitive data We take steps to ensure that our employees and contractors operate in accordance with our information security policies and procedures and any applicable contractual conditions Vendor risk management We require, through the use of contracts and security reviews, our third-party vendors and providers to protect any personal information with which they are entrusted in accordance with our security policies and procedures Marketing We would like to send you information about products and services of ours and other companies in our group which may be of interest to you. If you have consented to receive marketing, you may opt-out at any time. You have a right at any time to stop us from contacting you for marketing purposes. If you no longer wish to be contacted for marketing purposes, you may unsubscribe from any marketing email, or adjust your marketing preferences on your preferences page on our website. You may also contact our marketing team on marketing@harbourhotels.co.uk. Cookies We use cookies when you visit our site. There are four main types of cookies – here’s how and why we use them: Site functionality cookies. These cookies allow you to navigate the site and use our features Site analytics cookies. These cookies allow us to measure and analyse how our customers use the site, to improve both its functionality and your user experience. We use Google Analytics to collect information about visitor behaviour on our website. Google Analytics stores information about what pages you visit, how long you are on the site, how you got here and what you click on. This Analytics data is collected via a JavaScript tag in the pages of our site and is not tied to personally identifiable information. We therefore do not collect or store your personal information (e.g. your name or address) so this information cannot be used to identify who you are. The Google Analytics tracking cookie also allows us to access aggregates demographic and audience data from online behavioural advertising services. This information is only available to us at a group level, with no personal or identifiable information contained within it. It is used only for us to evaluate the effectiveness of the website and see how different groups of users use and respond to the site, and in no way allow us to track people individually. You may opt out of this tracking by disabling cookies within your browser. We use Hotjar in order to better understand our users’ needs and to optimize this service and experience. Hotjar is a technology service that helps us better understand our users’ experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables us to build and maintain our service with user feedback. Hotjar uses cookies and other technologies to collect data on our users’ behaviour and their devices. This includes a device's IP address (processed during your session and stored in a de-identified form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), and the preferred language used to display our website. Hotjar stores this information on our behalf in a pseudonymized user profile. Hotjar is contractually forbidden to sell any of the data collected on our behalf. For further details, please see the ‘about Hotjar’ section of Hotjar’s support site. Customer preference cookies. When you are browsing, these cookies will remember your preferences (like your language or location), so we can make your experience as seamless as possible, more personalised to you, and save you time specifying them again Targeting or advertising cookies. These cookies are used to deliver ads relevant to you. They also limit the number of times that you see an ad and help us measure the effectiveness of our marketing campaigns. By using our site, you agree to us placing these sorts of cookies on your device and accessing them when you visit the site in the future. If you want to delete any cookies that are already on your computer, the “help” section in your browser should provide instructions on how to locate the file or directory that stores cookies. Further information about cookies can be found at https://ico.org.uk/for-organisations/guide-to-pecr/cookies-and-similar-technologies. Please note that by deleting or disabling future cookies, your user experience may be affected, and you might not be able to take advantage of certain functions of our site. Your name, address, telephone number or email address may also be used to find you on Facebook [and Instagram], for the purposes of targeting you with advertising of our products and services on Facebook [and Instagram]. This site uses the Lucky Orange and Hotjar analytics systems to help improve usability and customer experience. These systems anonymously record mouse clicks, mouse movements and scrolling activity, and keystroke information that you voluntarily enter on this website. Changes to how we protect your Privacy We may change this page from time to time, to reflect how we are processing your data. If we make significant changes, we will make that clear on our website, or by some other means of contact such as email, so that you are able to review the changes before you continue to use our services. How to contact us If you: Have any questions or feedback about this notice Would like us to stop using your information Want to exercise any of your rights as set out above, or have a complaint You can contact our privacy team by emailing us at: dataprotection@harbourhotels.co.uk. Or if you’d like to, you can write to us at: Harbour House, 60 Purewell, Christchurch, Dorset, United Kingdom, BH23 1ES This policy was last updated 21st January 2019.