Red Brighton Blue Privacy Notice
This notice describes how Red Brighton Blue Boutique Guest House processes your personal data, in accordance with GDPR regulations.
‘Red Brighton Blue’ is the controller of data for all hotel bookings made at the property. The address and contact details of the company are:-
7 Charlotte Street
Telephone +44 1273 256300.
You have the right to object to some of the processing which Red Brighton Blue carries out. More information about your rights and how to exercise these is set out in the section headed “Your rights” below.
This notice applies to:
- Callers; and
- Other customers.
And anyone contacting, visiting or using our:
- Facebook Page;
- Telephone; and
- Guest House.
Summary of the purposes for processing your personal data and the legal basis for doing so:
We process personal data to make, amend and administer room bookings, provide hotel services process and store payment details and provide other products and services (such as meals and car parking). We also deal with enquires, gather customer feedback, undertake market research and direct marketing (including analysis to create profiles), in our legitimate interests to promote our business and improve our service and delivery.
When booking with us, we don’t ask for accessibility, dietary, health or other sensitive personal data. If you (or someone on your behalf) do provide such information to us, please be aware we may need to ask for your explicit consent. In some cases, it may be permissible for us to have such data as it is in your vital interests that we do so.
On our websites we use third party marketing and analytical cookies plus similar technologies are included in our marketing emails. You can reject and block cookies in your browser settings.
We monitor social media to understand comments or complaints about our business and with the permission of the platform owner we may reproduce your comments on our website, on the lawful basis of our legitimate interests.
In our legitimate interests, we also seek to prevent and detect crime as well as protect our business and premises.
In order to fulfil the above purposes:
- we disclose your personal data to payment providers, technology providers, insurers, and other specialist professional and technical service providers and advisers, to manage your bookings, arrange payments, and provide services.
- we may transfer your personal data outside the European Economic Area (the EU Member States plus Iceland, Lichtenstein and Norway) and, where we do this, we will use safeguards to protect your data.
- we keep your data to enable us to fulfil our contract with you or to provide services, where required by law, to respond to a question or complaint, to obey rules about keeping records, to uphold or protect contractual or legal rights or where it is in your or another party’s vital interests or our legitimate interests. Where we process personal data on the basis of your consent, we will retain it for as long as required for the specified purpose. We also keep your data in line with any statutory limitation periods and for tax, legal or regulatory purposes.
Any consent(s) you give us may be withdrawn at any time.
You have an absolute right to object to direct marketing (and any profiling for the purposes of direct marketing) at any time.
You also have the qualified right to:
- request access, rectify, and erase your personal data;
- object to processing for any purpose where we rely on our legitimate interests as the legal basis;
- restrict processing; and
- supply or transfer your personal data in a portable format.
Where you exercise any of your rights, we will process your personal data to comply with your request in accordance with our legal obligations.
Where we use automated decision-making, you have the right to human intervention, to add a statement, and to have the decision reviewed. You have the right to lodge a complaint with the data protection supervisory authority of the country in which you are resident, work or in which your complaint arises. For the contact details of the Information Commissioner in the UK see www.ico.org.uk, for Information Commissioner in the Isle of Man see www.inforights.im and for the Office of Information Commissioner in Jersey see https://oicjersey.org . Details of all EU supervisory authorities can be found at http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080
We may provide additional information during the booking and check-in process and at other points at which we collect your personal data.
If you wish to exercise your rights, please email us on firstname.lastname@example.org.
PERSONAL INFORMATION WE COLLECT
We collect personal information when you book with us or request or use our services. This includes hotel, using our websites or apps, or corresponding with us. We may also receive personal data about you from another source. This includes:
- Personal Identifiers - title, name, marital status, postal and email addresses, postcode, IP addresses and contact telephone numbers. We may also collect the names of those who are part of a group booking where necessary, and the age of children to meet your needs (e.g. to provide a cot) and enable us to confirm any restrictions that may apply to a room booking;
- Business-to-Business Information - for corporate customers and corporate business leads and contacts: job title, business address and business email address;
- Transaction Information - payment, reservation and booking details, including meals, beverages & car parking;
- Facebook Page Insights Data - In relation to our Facebook Pages, we may receive Insights Data from Facebook, i.e. aggregated data that can help us to understand how visitors are engaging with our Page, which may be based on personal data collected during your visit to our Page or its contents. In relation to the processing of this personal data only, we are joint controllers with Facebook Ireland Limited. Facebook Ireland Ltd has agreed to take primary responsibility under the GDPR for the processing of Insights Data and to comply with all applicable obligations under the GDPR with respect to the processing of Insights Data, so all requests and queries should be addressed to Facebook Ireland Limited. This is subject to the jurisdiction of the Irish Courts and the laws of Ireland. The Irish Data Protection Commissioner is the lead supervisory authority; and
- Customer special requests and feedback including complaints - via call centres, emails and online free text fields.
Third parties, including where we are joint controllers, that we receive personal data from may include:
- Travel agents, booking agents, other agents, tour operators and schools;
- Corporate customers and public information sources such as Companies House;
- Comparison and review websites;
- Social networks;
- Market researchers;
- Marketing service providers and advertising technology providers;
- Government and law enforcement agencies;
- Other hotel providers and other organisations as part of their contingency plans; and
HOW DO WE USE YOUR INFORMATION AND WHAT IS THE LEGAL BASIS FOR THIS USE?
To fulfil a contract, or take steps linked to a contract. This is relevant when you want to make a reservation with us; or receive other products and services from us such as meals and includes:
- making, amending or administering your room booking and meal orders;
- providing products and services requested by you;
- verifying your identity;
- processing payments;
- to administer your account on our website;
- to administer your Red Brighton Blue Business Account;
- communicating with you;
- providing customer services, including managing complaints; and
- alerting you by text, email or phone in the event of an unplanned incident, as a result of which we have to make alternative arrangements under our contract (or where we believe it is in your vital interests).
If the information we request is not provided, we may not be able to enter into or comply with a contract or our legal obligations.
In our legitimate interests regarding the conduct of our business, in particular:
Ensuring customer satisfaction, maintaining goodwill and dispute resolution
- we provide technical support and investigate and process any complaints about our website or our products or services, and to maintain appropriate records for internal administrative purposes. We reserve the right to request evidence to support any claims or complaints.
To protect our business and prevent fraud
- monitor, test and control the performance and security of our systems, networks, processes and premises to prevent and detect fraud and protect our business;
- if you provide a credit or debit card as payment, we use third parties to check the validity of your bank account or card details in order to prevent fraud.
For business performance and improvement
- monitor and record CCTV, call centre communications, including incoming and outgoing calls and emails for staff training, quality improvement purposes and establishing facts; and
- analyse transactions to enable us to improve our services and products and plan for our business.
Safety & Security of our Guests and Employees
- to protect premises and for security purposes including information recorded from CCTV;
- to monitor food safety and hygiene;
- to obtain statements from witnesses to accidents and other incidents; and
- for the detection and prevention of crime.
Developing and Marketing Products and Services
- for raising brand awareness;
- to understand you better as a customer by analysing your transactions and other information you provide to us or which we learn through your interactions with us;
- for marketing (including creating profiles), competitions and promotions by post, email, text and push notification where permitted to do so by law (for an alternative lawful basis, see consent below);
- we may use your data to provide personalised promotional offers to you;
- we may also use your data to provide you with personalised promotional offers on selected partner websites (for example, you might see an advertisement for our products on a partner site such as Facebook and Google);
- we also share some of your information with marketing service and ad technology providers and digital marketing networks, such as Facebook, Google, Adobe and Rocket Fuel, to present advertisements that might interest you.
- For example we may transfer information about you to such providers so that they may recognize your devices and deliver interest-based content and advertisements to you.
- The information may include your name, email, device ID, or other identifier in encrypted form. The providers may process the information in hashed form. These providers may collect additional information from you, such as your IP address and information about your browser or operating system; may combine information about you with information from other companies in data sharing cooperatives in which we participate; and may place or recognize their own unique cookie on your browser. These cookies may contain demographic or other data in de-identified form;
- for monitoring the use of our websites, apps and Facebook Pages in order to improve their performance, understand how people are engaging with them and optimise our media spend;
- we use personal data of some individuals to invite them to provide feedback or take part in market research; and
- for developing corporate business and applying rates.
Legal and Regulatory purposes
- in connection with legal claims, compliance, regulatory and investigative purposes as necessary (including disclosure of such information in connection with claims, legal process or litigation);
- to comply with health and safety legislation, including accounting for the number of individuals on our premises and logging accidents;
- to prevent, investigate and/or report suspected fraud, terrorism, security incidents or other crime, in accordance with applicable law; and
- to anonymise personal data when we no longer need to process it.
Where you give us consent:
- we will send you emails, texts and push notifications (including newsletters) in relation to products and services provided by us (for an alternative lawful basis see “legitimate interests” above), or by our named affiliates and carefully selected partners;
- when you use our websites or apps, we place cookies and use similar technologies on your computer, mobile or other device and we use such technologies such as pixel tags and web beacons in marketing emails and communications (also see our Cookie Notice);
- we may use credit checks if you apply for a Business Account;
- to participate in competitions we run and, if you win, to use your information for promotional purposes;
- we will process health information, such as dietary, accessibility, and allergy information you or a party on your behalf provides to us (we may also be able to do this where it is in your vital interests);
- when you make a donation to a charity, we will process your payment for this purpose; and
- on other occasions where we ask you for consent, we will use the personal data for the purpose which we explain at that time.
- You have the right to withdraw consent at any time.
For purposes which are required by law:
- to record the identity and nationality of overseas guests (excluding the Republic of Ireland and Commonwealth citizens) on check-in. These guests will be asked to complete a registration form and provide their identity card/passport details, to comply with the Immigration (Hotel Records) Order 1972, as amended. Acceptable forms of identification are: a passport, driving licence, ID card or police warrant card.
- And in the UK;
- in response to requests by government, law enforcement authorities, or intelligence services and court orders;
- if required to comply with health and safety legislation to which we are subject;
- we may be required to share information with other licensees in accordance with local licensing requirements; and
- responding to a rights request under data protection legislation.
To protect your vital interests or those of another person:
- disclosing your personal data to the emergency services where we believe it is necessary to protect your vital interests or the vital interest of another person; and
- where you (or a person acting on your behalf) provide us with dietary or other personal health data such as allergies.
OTHER RECIPIENTS THAT WE DISCLOSE, TRANSFER OR SHARE YOUR PERSONAL DATA WITH
For some activities Red Brighton Blue uses third party service providers including where we are joint controllers. Your personal data will be disclosed to such organisations where this is necessary to provide a service to you, or where it is in our legitimate interests. For example, we use third parties to:
- administer bookings;
- provide Wi-Fi;
- provide parking facilities;
- undertake customer feedback surveys;
- provide analytics;
- send promotional offers;
- provide personalised advertisements;
- provide insurance;
- provide IT development, support, maintenance and hosting, including the provision of applications
- and website hosting;
- process payments to enable you to pay by credit or debit card;
- provide credit checks and fraud checks; and
- provide CCTV systems and maintenance.
Personal data may be shared with regulators, government authorities and/or law enforcement officials for the prevention or detection of crime, if required by law or if required for a legal or contractual claim or regulatory purposes.
We disclose your personal data to payment providers, technology providers, insurers, and other specialist professional and technical advisers, to manage your bookings, arrange payments, and provide services.
With your consent, we will also disclose your personal data to Ombudsman services and Citizens’ Advice.
Restructure and sale
We may in the future restructure our company to run our hotel under a different corporate structure. If this happens we will let you know and your data may be shared with such company and processed as set out in this notice.
In the event that the business is sold or integrated with another business, your details may be disclosed to our advisers and any prospective purchaser’s adviser and will be passed to the new owners of the business.
Sometimes we may need to send or store your data outside of the European Economic Area (the EU plus Iceland, Lichtenstein and Norway) (‘EEA’). For example, to follow your instructions, comply with a legal duty or to work with or receive services from our service providers who we use to help run your accounts and our services.
If we do transfer information outside of the EEA, we will make sure that it is protected by using one of these safeguards:
- Transfer it to a non-EEA country with privacy laws that give the same protection as the EEA. Some countries have been deemed adequate by the EU.
- Put in place a contract with the recipient that means they must protect it to the same standards as the EEA or use other mechanisms and measures to achieve adequate protection. We also may use the Standard Contractual Clauses published by the EU.
- Transfer it to organisations that are part of Privacy Shield. This is a framework that sets privacy standards for data sent between EU countries and the US. It makes sure those standards are similar to what is used within the EEA.
- Binding corporate rules. These are internal rules adopted by group companies to allow international transfers of personal data to entities within the same corporate group located in countries which do not provide an adequate level of protection.
WHAT RIGHTS TO I HAVE?
Withdrawing consent or otherwise objecting to direct marketing
Wherever we rely on your consent, you will always be able to withdraw that consent. We will continue to process your personal data for other purposes on a different lawful basis (other than consent) where that applies.
In some cases, we are able to send you direct marketing without your consent, where we rely on our legitimate interests. You have an absolute right to opt-out of direct marketing, and any profiling we carry out for direct marketing, at any time. You can do this by clicking on the 'unsubscribe' link located in the footer of every marketing email or text.
Where you have a relationship with another organisation, such as a social media platform like Facebook, we may ask them to send marketing to you. If you object to receiving marketing from us we will stop marketing to you. However, please contact the organisation directly if you want to object or withdraw your consent to such organisation marketing to you.
Other qualified rights
- You have the right to know whether or not we process information about you and to access that information.
- You have the right to update, correct and complete any information we hold about you which is inaccurate or incomplete.
- You have the right to obtain the personal data you provide to us for a contract or with your consent in a commonly used, structured, and machine-readable format, and to ask us to share (port) this personal data to another controller.
- You have the right to ask that we erase or restrict (stop active) processing of your personal data.
- In addition, you can object to the processing where the lawful basis is our legitimate interests.
These rights may be limited, for example if fulfilling your request would reveal personal data about another person or you ask us to erase information which we are required by law to keep. Where you object to us processing personal information we may have a compelling justification for processing it. Relevant exemptions are also included within the data protection laws that apply in the UK. We will inform you of relevant exemptions we rely upon when responding to any request you make.
To exercise any of these rights, you can get in touch with us using the details set out below. If you have concerns, you have the right to complain to the data protection supervisory authority of the EU Member State in which you are resident, work or in which your complaint arises. In the UK, the supervisory authority is the Information Commissioner. Details of all EU supervisory authorities can be found at:
HOW LONG WILL YOU RETAIN MY PERSONAL DATA?
We keep your data to enable us to fulfil our contract with you or to provide services, where required by law, to respond to a question or complaint, to obey rules about keeping records, to uphold or protect contractual or legal rights or where it is in your or another party’s vital interests or our legitimate interests. Where we process personal data on the basis of your consent, we will retain it only for as long as required for the specified purpose. We also keep your data in line with any statutory limitation periods and for tax, legal or regulatory purposes.
The period for which we will retain your personal data depends on the purposes for which we are processing it and where the same personal data is processed for two or more purposes, we will retain it for the longest period. For example, we retain:
- CCTV recording for up to 31 days;
- for up to 1 year incoming and outgoing voice recordings (although we will keep a record of any consent you give us during a call for as long as we rely on it as the lawful basis for processing);
- for up to 25 months from your last stay, any personal data we process for managing your hotel or restaurant bookings;
- for up to 36 months after it is resolved, any personal data we process in relation to queries, complaints or feedback (other than market research surveys) relating to your hotel or restaurant booking;
- until a period of 3 years has elapsed since your last interaction with us, personal data we process for marketing (including profiling) purposes, unless you ask us to stop sending electronic direct marketing, in which case we will act on your request, and then keep a record of your request indefinitely;
- for 3 years in the case of accident report forms (or for accidents relating to a child, for 3 years after the child’s 18th birthday);
- for up to 6 years from your last stay or access to your account, any personal data in an account you have set up with us, for example a My Red Brighton Blue Account or Business Booker Account;
- for up to 6 years, financial and transactional data for the purposes of insights and analytics; and
- for up to 7 years, financial information for accounting, business reporting, analysis and audit purposes.
In any of the cases mentioned above, we may retain the personal data for longer, if it is required for the purposes of any internal or external investigation or litigation. In these cases, it may be retained until the matter is resolved. We may keep your data for longer in line with any limitation periods, or if we cannot delete it, e.g. for tax, legal or regulatory reasons.
You have the qualified right to request deletion of your personal data at any time, or we may choose or be obliged to erase your personal data earlier, for example, if we no longer need to process it.
HOW DO I GET IN TOUCH WITH YOU?
Queries and exercise of rights
If you have any queries or want to exercise any of your rights, please get in touch with us using the “Contact” page on our website.
General data protection queries
If you have any queries about the way we process your personal data, you can get in touch at email@example.com.
Any changes to this Privacy Notice will be communicated on our website.