A. Background
This privacy policy informs you what happens to any personal data given to us, or any that we may obtain from or about you. It applies to all products and services, and occasions where we collect your personal data.
Use the links below to find out more about how we use your personal information:
- Who are we and how do you contact us and our Data Protection Officer?
- What kinds of personal information about you do we process?
- What is the source of your personal information?
- What are the legal grounds for our processing of your personal information (including when we share it with others)?
- What should you do if your personal information changes?
- For how long is your personal information retained by us?
- What are your rights under data protection laws?
Changes to this privacy policy
We may change this privacy policy from time to time by updating this page in order to reflect changes in the law and/or our privacy practices. We encourage you to check this privacy policy for changes whenever you visit our website - www.downshotel.co.uk.
The Downs, Babbacombe and our Data Protection Officer
We're The Downs, Babbacombe, 41-43 Babbacombe Downs Road, Babbacombe, Torquay, TQ1 3LN. We are a data controller of your personal data. The Downs, Babbacombe who provide your product of service are named at the start of these terms and conditions.
We have a dedicated data protection officer ("DPO"). You can contact the DPO using the details below or by writing to the above address, marking it for the attention of the DPO or going to Contact Us section of our website.
B. What kinds of personal information about you do we process
Personal information that we'll process in connection with all of our products and services, if relevant, includes:
- Personal and contact details, such as title, full name, contact details and contract details history
- Your date of birth, gender and/or age
- Your nationality, if needed for the product or service
- Family members (if relevant to the product or service)
- Records of your contact with us such as via the phone number
- Products and services you have obtained from us as well as have been interested in and have held and the associated payment methods used
- The usage of our products and services
- Marketing to you and analysing data, including history of those communications, whether you open them or click on links, and information about products or services we think you may be interested in, and analysing data to help target offers to you that we think are of interest or relevance to you. Offers may include reduced price theatre tickets or free golf and any of our other products and services
- Information about your use of products or services
- Information about your employment status, if relevant, so we can tailor our services to your circumstances
- Your marital status, family, lifestyle or social circumstances, if relevant to the product
- Insights about you and our customers gained from analysis or profiling of customers
C. What is the source of your personal information?
We'll collect personal information from the following general sources:
- From you directly, and any information from family members
- Information generated about you when you use our products and services
D. What do we use your personal data for?
We use your personal data, including any of the personal data listed in section A above, for the following purposes:
- Managing products and services relating to the product or service
- Updating your records
- To make automated decisions on whether to offer you a product or service, or the price
- To perform and/or test the performance of our products, services and internal processes
- To improve the operation of our business
- To follow guidance and best practice under the change to rules of governmental and regulatory bodies
- For management and auditing of our business operations including accounting
- To monitor and to keep records of our communications with you and our staff (see below)
- To administer our good governance requirements
- For market research and analysis and developing statistics
- For direct marketing communications and related profiling to help us to offer you relevant products and services, including whether or not to offer you certain products and services. We may send marketing to you by SMS, email, phone, post, social media and digital channels (for example, using Facebook Custom Audiences and Google Custom Match). Offers may relate to any of our products and services such as reduced rate theatre, tickets or wine/prosecco in the room upon arrival, as well as to any other offers and advise we think may be of interest
- To provide personalised content and services to you, such as tailoring our products and services, our digital customer experience and offerings, and deciding which offers or promotions to show you on our digital channels
- To develop new products and services and to review and improve current products and services
- To comply with legal and regulatory obligations, requirements and guidance
- To provide insight and analysis of our customers for ourselves, helping us improve products or services, or to assess or improve the operating of our businesses
- To facilitate the sale of one or more parts of our business
E. What are the legal grounds for our processing of your personal information (including when we share it with others)?
We rely on the following legal bases to use your personal data:
1. Where it is needed to provide you with products or services, such as:
- All stages and activities relevant to managing the product or service including enquiry, application, administration and management of accounts, illustrations, requests for transfers of equity, setting up/changing/removing guarantors
- For some of our profiling and other automated decision making to decide whether to offer you a product and/or service, particular payment method and the price of terms of this
2. Where it is in our legitimate interests to do so, such as:
- Managing your products and services relating to that, updating your records, tracing your whereabouts to contact you about your account and doing this for recovering debt (where appropriate)
- To perform and/or test the performance of our products, services and internal processes
- To follow guidance and recommended best practice of government and regulatory bodies
- For management and audit of our business operations including accounting
- To carry out monitoring and to keep records of our communications with you and our staff (see below)
- For market research and analysis and developing statistics
- For direct marketing communications and related profiling to help us to offer you relevant products and services, including deciding whether or not to offer you certain products and services. We may send marketing to you by SMS, email, phone, post and social media and digital channels (for example, using Facebook Custom Audiences and Google Custom Match
- Subject to the appropriate controls, to provide insight and analysis of our customers to business partners either as part of providing products or services, helping us improve products or services, or to assess or to improve the operating of our business
- For some of our profiling and other automated decision making
- Where we need to share your personal information with people or organisations in order to run our business or comply with any legal and/or regulatory obligations
3. To comply with our legal obligations
4. With your consent for explicit consent:
a) For some direct marketing communications
b) For some of our profiling and other automated decision making
5. For a public interest
F. When do we share your personal information with other organisations?
We do not share your information with other companies however as a hotel we have a legal requirement to keep guest details for at least 12 months and must have the register available for inspection by police or other authorised persons at all times.
G. How and when can you withdraw your consent?
Where we're relying upon your consent to process personal data, you can withdraw this at any time by contacting us using the details below
H. What should you do if your personal information changes?
You should tell us so that we can update our records using the details in the Contact Us section of our website. We'll then update your records if we can
I. Do you have to provide your personal information to us?
We're unable to provide you with our products or services if you do not provide certain information to us. In cases where providing some personal information is optional, we'll make this clear
J. Do we do any monitoring involving processing of your personal information?
In this section monitoring means any: listening to, recording of, viewing of, intercepting of, or taking and keeping records (as the case may be) of calls, email., text messages, social media messages, in person (face to face) meeting and other communications.
We may monitor where permitted by law and we'll do this where the law requires it, or to comply with regulatory rules, to prevent or detect crime, in the interests of protecting the security of our communications systems and procedures and for quality control and staff training purposes. This information may be shared for the purposes described above.
K. What about other automated decision making?
We sometimes make decisions about you using only technology, where none of our employees or any other individuals have been involved. For instance, we may do this to decide: whether to offer you a product of service, to determine the risk of doing so, the price we will offer, whether to offer you credit, what terms and conditions to offer you or to assess what payment methods we can offer you.
L. For how long is your personal information retained by us?
Unless we explain otherwise to you, we'll hold your personal information based on the following criteria:
- For as long as we have reasonable business needs, such as managing our relationship with you and managing our operations
- For as long as we provide goods and/or services to you
- Retention periods in line with legal and regulatory requirements or guidance. As a hotel we have a legal requirement to keep guest details for at least 12 months and must have the register available for inspection by police or other authorised persons at all times
M. What are your rights under data protection laws?
Here is a list of the rights that all individuals have under data protection laws. They don't apply in all circumstances. If you wish to use any of them, we'll explain at that time if they are engaged or not. The right of data portability is only relevant from May 2018.
- The right to be informed about the processing of your personal information
- The right to have your personal information corrected if it is inaccurate and to have incomplete personal information completed
- The right to object to processing of your personal information
- The right to restrict processing of your personal information
- The right to have your personal information erased (the "right to be forgotten)
- The right to request access to your personal information and to obtain information about how we process it
- The right to move, copy or transfer your personal information ("data portability")
- Rights in relation to automated decision making which has a legal effect or otherwise significantly affects you
You have the right to complain to the Information Commissioner's Office which enforces data protection laws: https://ico.org.uk. You can contact us using the details below.
N. Your right to object
You have the right to object to certain purposes for processing, in particular to data processed for direct marketing purposes and to data processed for certain reasons based on our legitimate interests. You can contact us by going to the Contact us section of our website to exercise these rights.
O. What are your marketing preferences and what do they mean?
We may use your home address, phone numbers, email address and social media or digital channels (for example Facebook, Google and message facilities in other platforms) to contact you according to your marketing preferences. You can stop our marketing at any time by contacting us using the details below or by following the instructions in the communication.
Contact us
If you have any questions about this privacy policy, or if you wish to exercise your rights or contact the DPO, you can contact us by going to the Contact us section of our website. Alternatively, you can write to Edward Wood, The Downs Babbacombe, 41-43 Babbacombe Downs Road, Babbacombe, Torquay, TQ1 3LN.
