Privacy Policy CENTRE ISLAND HOTELS LIMITED SUBSIDIARIES & ASSOCIATED COMPANIES Contents of privacy policy 1. Introduction 2. What is the Centre Island Hotels Limited subsidiaries & associated companies? 3. Explaining the legal bases we rely on 4. When do we collect your personal data? 5. What sort of personal data do we collect? 6. How and why do we use your personal data? 7. Combining your data for personalised direct marketing 8. How we protect your personal data 9. How long will we keep your personal data? 10. Who do we share your personal data with? 11. Where your personal data may be processed 12. What are your rights over your personal data? 13. How can you stop the use of your personal data for direct marketing? 14. Centre Island Hotels Limited 14.1. How we use your personal data 14.2. How our providers use your personal data 14.3. Joint use of your personal data 15. Contacting the Regulator 16. Any questions? 17. Appendixes 1. Introduction This Privacy Notice explains in detail the types of personal data we may collect about you when you interact with us. It also explains how we’ll store and handle that data, and keep it safe. We know that there’s a lot of information here, but we want you to be fully informed about your rights, and how the Centre Island Hotels Limited subsidiaries & associated companies uses your data; for example we will explain things such as our credit checking procedure, and how we combine data across the Centre Island to build a picture of you. We hope the following sections will answer any questions you have but if not, please do get in touch with us. It’s likely that we’ll need to update this Privacy Notice from time to time. We’ll notify you of any significant changes, but you’re welcome to come back and check it whenever you wish. 2. Who are the Centre Island Hotels Limited subsidiaries & associated companies? The Centre Island Hotels Limited subsidiaries & associated companies – which we’ll refer to as ‘Centre Island’ in this document – is made up of a number of related businesses: • Please reference – Appendix 1 at the end of this policy For simplicity throughout this notice, ‘we’ and ‘us’ means Centre Island and its brands. 3. Explaining the legal bases we rely on The law on data protection sets out a number of different reasons for which a company may collect and process your personal data, including: Consent In specific situations, we can collect and process your data with your consent. For example, when you tick a box to receive email newsletters. When collecting your personal data, we’ll always make clear to you which data is necessary in connection with a particular service. Contractual obligations In certain circumstances, we need your personal data to comply with our contractual obligations. For example, if you ask for invoices/billing details, we’ll collect your address details to deliver these to you as requested. Legal compliance If the law requires us to, we may need to collect and process your data. For example, we can pass on details of people involved in fraud or other criminal activity affecting Centre Island to law enforcement. Legitimate interest In specific situations, we require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom or interests. For example, we may use your stay history to send you or make available personalised offers to you. We may also combine the history of many customers to identify trends and ensure we can keep up with demand, or develop new offers/services i.e. wedding packages or offers. We may also use your address details to send you direct marketing information by post, telling you about offers and services that we think might interest you. 4. When do we collect your personal data? • When you visit any of our websites, and use your account to buy products and services, or redeem vouchers from Centre Island on the phone, or online booking and third party booking agents. • When you make an online purchase and check out as a guest (in which case we just collect transaction-based data). • When you create an account with us. • When you book a room or stay with us directly or by phone but don’t have (or don’t use) an account. • When you engage with us on social media. • When you download or install the IHG app. • When you join the IHG loyalty programme. • When you contact us by any means with queries, complaints etc. • When you ask one of our Partners to email you information about a service we offer. • When or if you redeem a competition prize for a complimentary stay. • When you book any kind of appointment with us or book to attend an event, for example a black tie event or function etc. • When you choose to complete any surveys we send you. • When you comment on or review our products and services. • Any individual may access personal data related to them, including opinions. So if your comment or review includes information about any of our hotels who provided that service, it may be passed on to them if requested. • When you fill in any forms. For example, if an accident happens any of the hotel areas, we will collect your personal data. • When you’ve given a third party permission to share with us the information they hold about you. • When any of our booking agents and partners – such as IHG central reservations – share information with us about the details of your stay or requirements. • We collect data from publicly-available sources (such as Land Registry) when you have given your consent to share information or where the information is made public as a matter of law. • When you use our car parks and hotels which have CCTV systems operated for the security of both customers and Partners. These systems may record your image during your visit. 5. What sort of personal data do we collect? • If you have an account with us: your name, gender, date of birth, billing/delivery address, orders and receipts, email and telephone number. For your security, we’ll also keep an encrypted record of your login password if needed. • Details of your interactions with us through third party booking agents, central reservations, online or by using the IHG app. For example, we collect notes from our conversations with you, details of any complaints or comments you make, details of bookings/reservations you made, personal guest profiles may include preference on room type, brands you show interest in i.e. Crowne Plaza/Holiday Inn etc., and when you contact us. • Copies of documents you provide to prove your age or identity where the law requires this, (including your passport and driver's licence). This will include details of your full name, address, date of birth and facial image. If you provide a passport, the data will also include your place of birth, gender and nationality. For example, which of our hotels you prefer to visit and where you redeem your vouchers. • Details of your visits to our websites or app, and which site or booking agent you came from to use our hotel/s. • Information gathered by the use of cookies in your web browser. Learn more about how we use cookies and similar technologies. • Personal details which help us to recommend room types which may be of interest. For example, you might tell us that you prefer a quiet room away from the elevators and on a high floor, which we’ll use to guide our suggested rooms. Or you might share information on your dietary needs which allows us to recommend appropriate meals in one of our hotel restaurants. We’ll only ask for and use your personal data collected for recommending items of interest and to tailor your stay/time and your experience with us. Of course, it’s always your choice whether you share such details with us. • Payment card information. • Your comments and hotel/restaurant reviews. • Your image may be recorded on CCTV when you visit any of our hotels or car parks. • Your car number plate may be recorded at some of our car parks to manage parking restrictions. • To deliver the best possible web experience, we collect technical information about your internet connection and browser as well as the country and telephone code where your computer is located, the particular web pages viewed during your visit, and any search terms you entered. Learn more about this. • Your social media username, if you interact with us through those channels, to help us respond to your comments, questions or feedback. 6. How and why do we use your personal data? We want to give you the best possible customer experience. One way to achieve that is to get the richest picture we can of who you are by combining the data we have about you. We then use this to offer you promotions, products and services that are most likely to interest you. In the case of loyalty scheme IHG members, we’ll also offer you relevant rewards. The data privacy law allows this as part of our legitimate interest in understanding our customers and providing the highest levels of service. Of course, if you wish to change how we use your data, you’ll find details in the ‘What are my rights?’ section below. Remember, if you choose not to share your personal data with us, or refuse certain contact permissions, we might not be able to provide some services you’ve asked for. For example, if you’ve asked us to let you know whether a particular room type is available, we can’t do that if you’ve withdrawn your general consent to hear from us. Here’s how we’ll use your personal data and why: • To process any orders that you make by using our websites, apps or in person. If we don’t collect your personal data during checkout, we won’t be able to process your order and comply with our legal obligations. For example, your details may need to be passed to a third party regarding your stay with us or booking with us, and we may keep your details for a reasonable period afterwards in order to fulfil any contractual obligations such as refunds, guarantees and so on. • To respond to your queries, refund requests and complaints. Handling the information you sent enables us to respond. We may also keep a record of these to inform any future communication with us and to demonstrate how we communicated with you throughout. We do this on the basis of our contractual obligations to you, our legal obligations and our legitimate interests in providing you with the best service and understanding how we can improve our service based on your experience. • To protect our business and your account from fraud and other illegal activities. This includes using your personal data to maintain, update and safeguard your account. • To protect our customers, premises, assets and Partners from crime, we operate CCTV systems in our hotels and car parks which record images for security. We do this on the basis of our legitimate business interests. • We manage our car parks in conjunction with Parking Eye (however; please note we can't be responsible for the content of external websites) • To process payments and to prevent fraudulent transactions. We do this on the basis of our legitimate business interests. This also helps to protect our customers from fraud. • If we discover any criminal activity or alleged criminal activity through our use of CCTV, fraud monitoring and suspicious transaction monitoring, we will process this data for the purposes of preventing or detecting unlawful acts. Our aim is to protect the individuals we interact with from criminal activities. • With your consent, we may use your personal data, preferences and details of your transactions to keep you informed by email, telephone and through our sales managers about relevant services including tailored special offers, discounts, promotions, events, competitions and so on. Of course, you are free to opt out of hearing from us by any of these channels at any time. • To send you relevant, personalised communications by post in relation to updates, offers, services and products. We’ll do this on the basis of our legitimate business interest. You are free to opt out of hearing from us by post at any time. • To send you communications required by law or which are necessary to inform you about our changes to the services we provide you. For example, updates to this Privacy Notice. These service messages will not include any promotional content and do not require prior consent when sent by email or through the post. If we do not use your personal data for these purposes, we would be unable to comply with our legal obligations. • To display the most interesting content to you on our websites or social media apps, we’ll use data we hold about your favourite room types or restaurants. We do so on the basis of your consent to receive app notifications and/or for our website to place cookies or similar technology on your device. For example, we might offer upgrade offers on room types that you may have recently looked at, or offer you recommendations based on your previous stay history and any other data you’ve shared with us. • To administer any of our prize draws or competitions which you enter, based on your consent given at the time of entering. • To comply with our contractual or legal obligations to share data with law enforcement. For example, when a court order is submitted to share data with law enforcement agencies or a court of law • To send you survey and feedback requests to help improve our services. These messages will not include any promotional content and do not require prior consent when sent by email or through the post. We have a legitimate interest to do so as this helps make our products or services more relevant to you and to enhance your guest experience with us. Of course, you are free to opt out of receiving these requests from us at any time by updating your preferences in your online account. • To build a rich picture of who our Guests are and what our Guests like, and to inform our business decisions, we’ll combine data captured from across Centre Island, third parties and data from publicly-available lists as we have described in the section 'What Sort of Personal Data do we collect?' We’ll do this on the basis of our legitimate business interest. For example, by combining this data, this will help us personalise your experience and decide which inspiration or content to share with you. This may then guide which services we offer in particular hotels. • For any IHG Rewards Club members, to decide which information to show you, with the help of computer algorithms. We do so on the basis of your consent when you become an IHG Rewards Club member. If you don’t want to continue receiving my IHG Rewards Club offers, you may be unable to continue your IHG Rewards Club membership. For example, if you consent through the IHG Rewards Club app, we may use your personal preferences to offer you tailored rewards. • To process your booking requests (for example through a booking agent). Sometimes, we may need to share your details with a third party who is providing a service (a courier delivering lost/left property for example). We do so to maintain our relationship with our Guests. Without sharing your personal data, we’d be unable to fulfil your request or to ensure the relationship with our Guests is as good as it needs to be. 7. Combining your data for personalised direct marketing We want to bring you offers and promotions that are most relevant to your interests at particular times. To help us form a better, overall understanding of you as a customer, we combine your personal data gathered across Centre Island as described above, for example your stay/reservation history at both our hotels and also any IHG branded hotels. For this purpose we also combine the data that we collect directly from you with data that we obtain from third parties to whom you have given your consent to pass that data onto us – such as the Land Registry mentioned above. 8. How we protect your personal data We know how much data security matters to all our customers. With this in mind we will treat your data with the utmost care and take all appropriate steps to protect it. We secure access to all transactional areas of our websites and apps using ‘https’ technology. We regularly monitor our system for possible vulnerabilities and attacks, and we carry out penetration testing to identify ways to further strengthen security. 9. How long will we keep your personal data? Whenever we collect or process your personal data, we’ll only keep it for as long as is necessary for the purpose for which it was collected. At the end of that retention period, your data will either be deleted completely or anonymised, for example by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning. Some examples of customer data retention periods: Guest Information - 3 years Credit card - 90 days Advance deposit reservation - Until checked out Advance deposit transfer - Until checked out Guest registration cards - 3 years CCTV - Maximum 31 days 10. Who do we share your personal data with? We sometimes share your personal data with trusted third parties. For example, IHG Central Reservations, the police authorities, for fraud management, to handle fraudulent activities, to help us to offer the very best protection for all of our Guests. Here’s the policy we apply to those organisations to keep your data safe and protect your privacy: • We provide only the information they need to perform their specific services. • They may only use your data for the exact purposes we specify in our contract with them. • We work closely with them to ensure that your privacy is respected and protected at all times. • If we stop using their services, any of your data held by them will either be deleted or rendered anonymous. Examples of the kind of third parties we work with are: • IT companies who support our website and other business systems. • Operational companies such as IHG Central Reservations. • Direct marketing companies who help us manage our electronic communications with you. • Google/Facebook to show you room types/offers that might interest you while you’re browsing the internet. This is based on either your marketing consent or your acceptance of cookies on our websites, to see our cookies policies please refer to the individual hotels website. Sharing your data with third parties for their own purposes: We will only do this in very specific circumstances, for example: • With your consent, given at the time you supply your personal data, we may pass that data to a third party for their direct marketing purposes. • For fraud management, we may share information about fraudulent or potentially fraudulent activity in our premises or systems. This may include sharing data about individuals with law enforcement bodies. • We may also be required to disclose your personal data to the police or other enforcement, regulatory or Government body, in your country of origin or elsewhere, upon a valid request to do so. These requests are assessed on a case-by-case basis and take the privacy of our customers into consideration. • We may, from time to time, expand, reduce Centre Island and this may involve the transfer of divisions or the whole business to new hotels. If this happens, your personal data will, where relevant, be transferred to the new hotel, under the terms of this Privacy Notice. • For further information please contact our Data Protection Officer. To help personalise your journey through any of our Centre Island Hotels websites we currently use the following companies, who will process your personal data as part of their contracts with us: • IHG IHG operates its own policy statements and its own cookies policy to refer to this please see this link: https://www.ihg.com/content/gb/en/cutomer-care/privacystatement • Facebook • Twitter 11. Where your personal data may be processed Sometimes we will need to share your personal data with third parties and suppliers outside the European Economic Area (EEA), such as the USA. International bookings If you are based outside the UK and make a booking or reservation with us, we will transfer the personal data that we collect from you to Centre Island in the UK. Protecting your data outside the EEA The EEA includes all EU Member countries as well as Iceland, Liechtenstein and Norway. We may transfer personal data that we collect from you to third-party data processors in countries that are outside the EEA. For example, this might be required in order to fulfil your order, process your payment details or provide support services. If we do this, we have procedures in place to ensure your data receives the same protection as if it were being processed inside the EEA. For example, our contracts with third parties stipulate the standards they must follow at all times. If you wish for more information about these contracts please contact our Data Protection Officer. Any transfer of your personal data will follow applicable laws and we will treat the information under the guiding principles of this Privacy Notice. 12. What are your rights over your personal data? An overview of your different rights You have the right to request: • Access to the personal data we hold about you, free of charge in most cases. • The correction of your personal data when incorrect, out of date or incomplete. • For example, when you withdraw consent, or object and we have no legitimate overriding interest, or once the purpose for which we hold the data has come to an end (such as the end of a warranty). • That we stop using your personal data for direct marketing (either through specific channels, or all channels). • That we stop any consent-based processing of your personal data after you withdraw that consent. • Review by a Partner of any decision made based solely on automatic processing of your data (i.e. where no human has yet reviewed the outcome and criteria for the decision). You have the right to request a copy of any information about you that Centre Island holds at any time, and also to have that information corrected if it is inaccurate. To ask for your information, please contact Data Protection Officer, Centre Island Hotels Ltd, 2 St. Nicholas Place, Princes Dock, Liverpool L3 1QW, or send an email with subject as: Access Request to data.protection@centreisland.co.uk and ask for your information to be amended. If we choose not to action your request we will explain to you the reasons for our refusal. Your right to withdraw consent. Whenever you have given us your consent to use your personal data, you have the right to change your mind at any time and withdraw that consent. Where we rely on our legitimate interest In cases where we are processing your personal data on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation. We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal data. Direct marketing You have the right to stop the use of your personal data for direct marketing activity through all channels, or selected channels. We must always comply with your request. Checking your identity To protect the confidentiality of your information, we will ask you to verify your identity before proceeding with any request you make under this Privacy Notice. If you have authorised a third party to submit a request on your behalf, we will ask them to prove they have your permission to act. 13. How can you stop the use of your personal data for direct marketing? There are ways you can stop direct marketing communications from us: • Click the ‘unsubscribe’ link in any marketing email communication that we send you. We will then stop any further emails from that particular hotel. • In the IHG app, you can refer to the IHG privacy statement • Write to Data Protection Officer, Centre Island Hotels Ltd, 2 St. Nicholas Place, Princes Dock, L3 1QW informing us that you want to stop direct communications from us. Please note that you may continue to receive communications for a short period after changing your preferences while our systems are fully updated. 14. Centre Island Hotels Ltd. 14.1 How we use your personal data When you make a reservation or book any of our hotels’ services, we might receive a copy of the information you supplied. If you agree to receive marketing communications from us, we will use your data to personalise what we send you. You are free to opt out of receiving marketing communications from us at any time. Find out more about the use of your data for marketing in section 7. 14.2 How our providers use your personal data When you then look to book a product or service from one of our chosen providers i.e. a registrar for your wedding or DJ for a function, your data will be collected and used by them under the terms of their own separate privacy policies. For any individual privacy policies on the companies we use please be aware that these are available upon request. 14.3 Joint use of your personal data We will share data with our providers to bring you relevant offers and services, and discounts that reward your loyalty to our brands. 15. Contacting the Regulator If you feel that your data has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. You can contact them by calling 0303 123 1113. Or go online to www.ico.org.uk/concerns (opens in a new window; please note we can't be responsible for the content of external websites) If you are based outside the UK, you have the right to lodge your complaint with the relevant data protection regulator in your country of residence. Details can be found in Section 16. 16. Any questions? We hope this Privacy Notice has been helpful in setting out the way we handle your personal data and your rights to control it. If you have any questions that haven’t been covered, please contact our Data Protection Officer who will be pleased to help you: • Email us at data.protection@centreisland.co.uk • Or write to us at Data Protection Officer, Centre Island Hotels Limited, 2 St. Nicholas Place, Princes Dock, L3 1QW Nothing in this Privacy Notice restricts, excludes or modifies or purports to restrict, exclude or modify any statutory consumer rights under any applicable law including the Competition and Consumer Act 2010 (Cth). 17. Appendixes Centre Island Hotels Limited subsidiaries & associated companies: Centre Island Hotels Limited Company # 03636029 2 St. Nicholas Place, Princes Dock Liverpool L3 1QW Crowne Plaza Birmingham Company # 05546306 Holliday St Operated in junction with Birmingham Centre Island Birmingham Ltd B1 1HH Crowne Plaza Liverpool Company # 03301561 St Nicholas Place Centre Island Development Company Pier Head (1997) Limited Liverpool L3 1QW Crowne Plaza Manchester Company # 05387813 70 Shudehill Operated in junction with Manchester M4 Shudehill Hotel Company Limited 4AF Holiday Inn Express Birmingham Company # 06789882 19 Holliday Street Operated in junction with Birmingham B1 DRPT Birmingham Ltd 1HH Holiday Inn Express Liverpool Albert Dock Company # 02724522 Britannia Pavilion Centre Island Development Company Albert Dock Ltd Liverpool L3 4AD Holiday Inn Express Manchester Company # 06835230 Goadsby St Operated in junction with Off Swan St DRPT Properties Limited Manchester M4 5AR Holiday Inn Ellesmere Port Company # 02724522 Lower Mersey St Centre Island Development Company Ellesmere Port Ltd Cheshire CH65 2AL Holiday Inn Liverpool Company # 03848990 Lime St Liverpool H I Lime Street Limited L1 1NQ Holiday Inn Preston Company # 03848213 The Ringway Operated in junction with Preston PR1 3AU Centre Island Preston Ltd Centre Island Hotels Ltd 2 St. Nicholas Place,Princes Dock, Liverpool, L3 1QW 0151 705 2680 yourhotel@centreisland.co.uk PORTFOLIO CAREERS BLOG CONTACT TERMS & CONDITIONS | PRIVACY POLICY | COOKIE POLICY