In this policy “we”, “us” or “our” refers to The Cavendish Hotel (London) Limited. We are the data controller of the personal data you provide when you interact with us. We are a member of The Ascott Limited group.
You can contact us at any time about our processing of your personal data. Our contact details are set out in the “Contact Us” section at the end of the policy.
When do we collect your personal data?
- When you visit our website.
- When you stay at our hotel.
- When you make a reservation with us on our website, by email or by telephone.
- When you contact us with a question or request (e.g. to find out about our rates or conference facilities).
- When you fill out any forms or make a specific request during a stay with us (e.g. a dietary requirement or an accessibility request).
- When you visit our premises.
- When you have made a booking through a third party such as a travel agent, the travel agent will provide us with your personal data to for that reservation.
- When you enter one of our competitions or participate in a special offer.
- When you provide a review, or otherwise leave feedback on your visit.
- When you request to join our newsletter mailing list.
- When you engage with us on social media.
Our guests include the person who has made the reservation (and is responsible for settling the bill) and individuals accompanying them (e.g. family members or conference attendees). Please do not give us someone else’s personal data before you have checked that they are happy for you to do so.
What personal data we collect
Typically, we collect the following categories of personal data:
- Contact details: Details we may use to contact you about your stay, or another matter you’ve asked us about (e.g. your name, physical (postal) address, email address, phone number).
- Additional information: Information we collect to enhance your visit with us (e.g. dietary needs, onward travel requirements, access needs), or that we are required to collect by law (e.g. your passport details).
- Payment information: Your preferred payment method may contain some personal data about you (e.g. credit/debit card details, your billing address and any other financial information we require to complete a transaction).
- CCTV images: We operate CCTV on our premises for your safety and security.
- Technical information: When you land on our website, we collect some technical information such as your device type, browser, IP address, how you came to the website or how you interacted with the website. Where this information allows us to identify you, this may be your personal data.
How we use your personal data
Below we set out our uses of your personal data and the lawful basis under data protection law we rely on to process your personal data for these purposes.
- We need to collect contact details and payment information to allow you to make a reservation with us (e.g. for a hotel stay, or for one of our conference suites) and deal with any queries you may have that are associated with your reservation. Sometimes we also ask you for some additional information before or during your stay. When we collect and use this personal data, we do so to perform or take steps to perform the contract between you and us for the reservation and this is our lawful basis for processing your personal data. Depending on the circumstances, we may need to collect some of the personal data because it is our obligation under law (e.g. passport details).
- We also collect contact details and additional information from you if you accompany someone who made the reservation (e.g. family members). We collect this personal data either because it is a legal obligation that we do so (e.g. passport details), or because it is in our legitimate interests to do so. Our legitimate interests are in providing you with our services, and ensuring your stay is as comfortable as possible. For example, you may have a dietary requirement we need to log with the kitchens, or you may wish to ask questions about our services to which we respond. We are careful to balance our interests against those of your own, and you can always object to us processing your personal data in this way; see the “Your Rights” section below for more about how to do this.
- We want to ensure that you feel valued, and we want to give you the best experience every time you visit our hotel. Below we outline the processing we do to make sure this happens:
- Following your stay, we ask you for some feedback by way of a guest stay survey. This isn’t mandatory, so you don’t have to complete it. We keep any information you provide confidential and use it only to assess general trends, unless you have specific concerns and ask us to follow up. We ask that you do not give us any particularly sensitive information when completing a survey (e.g. medical information). The information in this survey helps us continually improve our services.
- We may monitor or record phone calls and customer-facing interactions for quality assurance, employee training and performance evaluation, identity verification purposes, feedback, to respond to your queries and requests and resolve complaints and other related purposes.
When we process your personal data for these purposes, we do so because it is in our legitimate interests. We are careful to balance our interests against your own, and you can always object to us processing your personal data in this way; see the “Your Rights” section below for more about how to do this.
- We ask you for your consent to send you our newsletter by email. For example, on our website you’ll need to enter your email and press “sign up”. Or, if you are at our hotel, you will have the option to sign up by ticking a box on our registration card. If you give us your consent, you’ll be able to withdraw this consent at any time by pressing the “unsubscribe” button in the newsletter email.
- We may use technical information to monitor or improve website performance. We do not process your personal data for this purpose. For example, where we collect an IP address, we aggregate this information so that it cannot reveal who you are.
- We sometimes process your personal data for other reasons where we have an obligation under law to do so. For example: to handle disputes and investigations; to protect and enforce our contractual and legal rights; and to prevent, detect and investigate crime, including fraud and money laundering.
How long do we keep your personal data and where is it stored?
We keep your personal data for as long as it is necessary for the purposes for which we collected it. After this period, we destroy, erase or anonymise (de-identify) your personal data. For example, we retain your registration details for one year from the date of your departure.
To provide our services and our website, we may transfer any personal data we collect and process to a third party located inside or outside the UK or the European Economic Area (EEA), including to a country where the law provides less protection for personal data. If we transfer personal data to a third party outside of the UK or EEA, we will, as required by applicable law, ensure that we continue to protect your data protection rights using appropriate safeguards. Examples of safeguards we may use include such as the standard contractual clauses for the transfer of personal data from the EEA to third countries or, where appropriate, the EU-US Privacy Shield. Please contact us if you would like more information about these safeguards.
Do we share your personal data with anyone?
Within the hotel, and our group of companies
With third parties
We may share your personal data with third parties, including:
- Payment processors for secure credit card payment transactions.
- Our web-hosting providers, WiFi providers and other IT companies who support our business systems.
- Operational companies such as taxi companies and travel agencies.
- Our marketing platform partners (for our newsletter, should you consent to receiving this) and market research partners (who assist us in generating reviews of products and services).
- Analytics and search engine providers who assist us in the improvement of our website.
- Government and regulatory authorities, for example to respond to a legal request or comply with a legal obligation.
- In the event that we sell, buy or merge any business or assets, we may share your personal data with the prospective seller or buyer of such business or assets and their respective professional advisers.
We do not share your data with third parties for their own marketing purposes.
These newsletters may contain some tracking technologies (similar to cookies) to help us analyse the effectiveness of our newsletter, such as open and click rates. When we collect this information, we do so in an aggregated format so that you cannot be individually identified.
What rights do I have?
You have certain rights in respect of the personal data that we hold about you. If you wish to:
- request a copy of the Personal Data that we hold about you (for yourself or to transfer to another organisation);
- request that we rectify, delete, or restrict the processing of your Personal Data; or
- where we rely on our legitimate interests to process your personal data, object to our processing of your personal data for reasons that are specific to your situation,
Please submit your written request via https://www.thecavendish-london.co.uk/contact-us We will always acknowledge your request but we are not always obliged to fulfil the request (e.g. where the request is manifestly unfounded or excessive). You may also raise any of your concerns with the Information Commissioner’s Office (the UK’s data protection regulator), but we hope that in the first instance you will contact us so that we can try to resolve your query.
Your use of third-party websites
It is your choice whether to give us any information via a social media platform (e.g. Instagram, Facebook, Twitter etc.). We cannot control the actions of other users of these platforms or the actions of the platforms themselves. The privacy policies of the companies that provide these platforms govern your interactions with them.
Our website includes links to other websites, whose privacy practices may be different from ours. If you visit those websites via one of these links and provide them with personal data, their privacy policies govern your personal data.
The Cavendish Hotel (London) Limited
[81 Jermyn St, St. James's, London SW1Y 6JF, United Kingdom]