Privacy Policy

This privacy policy is provided in a layered format so you can click through to the specific areas set out below.

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Introduction

• Important information and who we are
• The 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

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1. Important information and who we are

Purpose of this privacy policy

This privacy policy aims to give you information on how Stapleford Park Limited collects and processes your personal data when you stay at the hotel or use the services offered by it, and through your use of this website or the hotel. This will include any data that you may provide through this website or when you make a booking.

We do not knowingly collect data relating to children, other than in respect of children that use our Tree Cottage Nursery. Given the age of these children, we rely on the parents to assess the use of their personal data in accordance with this privacy policy.

Please do read this privacy policy (and any other processing information we may give you 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 data.
This privacy policy supplements these other notices and is not intended to override them.

Controller

Stapleford Park Limited is the controller and responsible for your personal data and is referred to as “we”, “us” or “our” in this privacy policy.

Our data privacy manager is responsible for overseeing questions in relation to this privacy policy. If you have any questions, including any requests to exercise any of your rights, please contact the data privacy manager using the details set out below.

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

This version was last updated on 13th August 2018. The data protection law in the UK changed in May 2018 with the implementation of the Data Protection Act 2018 and the General Data Protection Regulation. 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.

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Third-party links

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 notice of every website you visit.

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2. The data we collect about you

Hotel:
We will collect personal data from you when you make a booking for the hotel, or use our facilities or services. That data may be collected by our staff, either in person or over the telephone, and also when you book online via our website or complete any registration cards or enquiry forms.

Spa:
We will collect personal data (including both health and medical information) from you when you make a booking for a spa treatment, or use our Lifestyle Club facilities or services. That data may be collected by our staff, either in person or over the telephone, and also when you complete the Lifestyle Club Health Form.

Membership:
We will collect personal data from you (including your photograph) when you apply for membership of Stapleford Park. That data may be collected by our staff, either in person or over the telephone and also when you complete any registration cards.

CCTV Monitoring:
We will collect personal data from you in the form of video imagery. The data is collected across our estate via a closed-circuit television system (CCTV) and used and retained in accordance with our CCTV policy. As set out in that policy, this data is normally retained for 30 days, or for such longer period as is felt by SPL that it has a legitimate purpose in retaining the images due to events or other activities captured on the images.

Marketing Preferences:
We will use the personal data that we collect from you in the various ways outlined in this privacy policy to keep your marketing preferences up to date. This data may be collected by our staff, either in person or over the phone, and also when you complete any registration cards or digital/paper enquiry forms.

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

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, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.

Contact Data includes home address, email address and telephone numbers.

Financial Data includes payment card details.

Transaction Data includes details about payments from (and to) you and other details of your use of the hotel and the services that we provide.

Technical Data includes IP address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.

Profile Data includes your username and password, bookings made by you, your interests, preferences, and guest survey feedback and number plate.

Usage Data includes information about how you use our website and call record data.

Marketing Preferences Data includes your preferences in receiving marketing from us and your communication preferences.

CCTV Data includes images captured by CCTV across the estate.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity.

We may collect some Special Categories of Personal Data about you. This means 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. We do not collect any information about criminal convictions and offences.

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If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with accommodation at the hotel). In this case, we may have to cancel a booking or other service you have with us but we will notify you if this is the case at the time.

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3. How is your personal data collected?

We use different methods to collect data from and about you including:

From you. You may give us your personal data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

• book accommodation at the hotel or book or use any other of the services that we provide, including our Spa facilities;
• become a member of Stapleford Park;
• request marketing to be sent to you; or
• give us some feedback.

Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.

Third parties or publicly available sources. We do not currently collect personal data about you from third parties and public sources.

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4. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in one or more of the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.
• When we have your consent.

Click here to find out more about the types of lawful basis that we will rely on to process your personal data. Generally, we do not rely on consent as a legal basis for processing your personal data.

We will rely on your consent in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

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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 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.

Note that we may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one basis has been set out in the table below.

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Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest	Retention Period
We may process information relating to transactions, including purchases of goods and services, that you enter in to with us and/or through our website.	Transaction Data: The transaction data may include your contact details, your card details and the transaction details. Financial Data: This includes payments cards details.	The legal basis for this processing is the performance of a contract between you and our legitimate interest, namely in the interest of our business.	7 years from the end of the year in which the data is collected
We may process data about your use of our website and services	Usage data and Technical Data: The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is Google Analytics.	The legal basis for this processing is legitimate interest, namely monitoring and improving our website and services.	This data is held on Google Analytics for 26 months. For more information please visit: https://policies.google.com/privacy
We may process your personal data that is provided in the course of the use of our services. The service data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you.	Profile Data: Profile data may include your name, address, telephone number, email address, gender, date of birth, profile picture, arrival date, departure date, transactions and purchases of goods and services.	The legal basis for this processing is the performance of a contract between you and our legitimate interest, namely in the interest of our business.	7 years from the end of the year in which the data is collected
We may process information that you post for publication on our website or through our services. The publication data may be processed for the purposes of enabling such publication and administering our website and services	Publication Data Publication data may include your name, email address and any commentary which is associated with the post (i.e. a review)	The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.	3 years
We may process information contained in any enquiry you submit to us regarding goods and/or services. The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you.	Enquiry Data Enquiry data may include your name, address, telephone number, email address and any commentary associated with the enquiry about our goods and services.	The legal basis for this is the performance of a contract between you and our legitimate interest, namely in the interest of our business.	1 year
We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters	Notification data: Notification data may include your name, address, telephone number, email address, marketing preferences and opt-in status.	The legal basis for this processing Is consent.	1 year
We may process information contained in or relating to any communication that you send to us.	Correspondence Data: Correspondence data may include your name, address, telephone number, email address and any communication messages shared between the data subject and Stapleford Park.	The legal basis for this processing is the performance of a contract between you and our legitimate interest, namely in the interest of our business.	3 years
We may process CCTV imagery that is captured during the use of our services.	CCTV Data: This data includes images captured by CCTV across the estate.	The legal basis for this processing is our legitimate interests, namely the proper administration of our business.	30 days or for such longer period as is felt by SPL that it has a legitimate purpose in retaining the images due to events or other activities captured on the images.
We may process calls with Stapleford Park’s sales, reception, reservations, events and spa departments to improve our customer service. However, if you would prefer that your call was not recorded, you can opt out by stating this, or by hanging up	Usage data and Technical Data: The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is Google Analytics.	The legal basis for this processing is legitimate interest, namely monitoring and improving our website and services.	30 days following the date of a call.

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Marketing

We wish to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

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Promotional offers from us

We may use your personal data to form a view on what we think may be of interest to you. This is how we decide which marketing may be relevant for you.

You will receive marketing communications from us if you have opted in to receiving marketing communication from us.

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Sharing your personal data

We will not share your personal data with any other company for marketing purposes.

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Opting out

You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time. We will still be able to use your personal data for purposes other than marketing as we are allowed to do under this privacy policy.

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Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy.

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Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

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5. Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

• Third parties (acting as processors) providing services to us, including services such as IT and systems administration, and professional advisors
• 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 notice.

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.

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6. International transfers

Some of the processing done on our behalf is done by third parties based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, 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 by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
• Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

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7. Data security

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.

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.

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8. Data retention

How long will you use my personal data for? We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

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 requirements.

Details of retention periods for different aspects of your personal data are set out in the table in paragraph 4 above.

In some circumstances you can ask us to delete your data: see [Request erasure] below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.’

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9. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

• Request access to your personal data.
• Request correction of your personal data.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer of your personal data.
• Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us.

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No fee usually required

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 may refuse to comply with your request in these circumstances.

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What we may need from you

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.

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Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may 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.

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Your Legal Rights

You have the right to:

Request access to your personal data (commonly known as a “data 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. 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) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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 (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

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. 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.