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Imperial London Hotels Limited respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and our mobile application ("app") and tell you about your privacy rights and how the law protects you.
1. Important information and who we are
Purpose of this privacy notice
This privacy notice aims to give you information on how we collect and process your personal data through your use of our website (including our mobile site) and our mobile app, including any data you may provide through either when you sign up to our newsletter, purchase a product or service or take part in a competition organised by us.
Whilst our website and our app are not intended to be used by children, there may be situations whereby we collect the personal data of a child (i.e. where a child makes use of our digital key feature via our app). If this is the case, we will ensure that an appropriate lawful basis for processing their data applies and appropriate security measures are in place.
Imperial London Hotels Limited is made up of different legal entities. This privacy notice is issued on behalf of Imperial London Hotels Limited’s group, therefore any mention of "Imperial", "we", "us" or "our" in this privacy notice is to include the relevant company in the Imperial group responsible for processing your data. Imperial London Hotels Limited is the controller and responsible for our website and our mobile app.
Our website and our app 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 or our app, we encourage you to read the privacy notice of every website you visit.
2. The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
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. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
3. How is your personal data collected?
We use different methods to collect data from and about you including through:
4. How we use your personal data
Purposes for which we will 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 the following circumstances:
Note that we may process your personal data for more than one lawful ground 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 ground has been set out above.
We aim to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms for your attention:
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You may receive marketing communications from us if you have requested information from us or purchased goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any company outside Imperial’s group of companies for marketing purposes. You can ask us to stop sending you marketing messages at any time by contacting us at any time. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, service or other transaction.
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.
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 paragraph 4 above.
External Third Parties, including:
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.
6. Internal transfers
We do not transfer your personal data outside the European Economic Area.
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. For example, your data is kept confidential through encryption (we use the 128-bit secure sockets layer, or SSL, standard). We also do not retain live records of your credit card information on our servers after the transaction has been completed. 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.
8. Data retention
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.
Notwithstanding your legal rights (as set out below), we will apply the following data retention policy to your personal data, after which your personal data will be securely disposed of:
If you wish to find out more about our data retention policy please contact our DPM.
9. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These rights include:
You will not have to pay a fee to exercise these 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.
If you wish to exercise any of the rights set out above, please contact firstname.lastname@example.org.
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.
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.
Imperial Hotels has developed our website to serve the largest possible audience by addressing the needs of people and systems with differing abilities. The site conforms to the Web Accessibility Initiative of the World Wide Web Consortium level 1.
Data Protection Manager
We have appointed a data privacy manager (DPM) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPM using the following details:.
Email address: email@example.com
Postal address: 38-51 Bedford Way, London, WC1H 0DG
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance and we will endeavour to address your concerns.
Changes to the privacy notice and your duty to inform us of changes
This version was last updated on [ ] March 2019.
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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