TABLE OF CONTENTS
· What information about you do we collect, and why?
· What do we do with your information?
· Lawful grounds for processing personal information
· Cookies and online tracking
· Who might we share your information with?
· How secure is your information?
· How long do we keep how of your information?
· How can I access, verify or change the information your hold about me?
WHAT INFORMATION ABOUT YOU DO WE COLLECT AND WHY
We may collect and process personal data relating to you, your friends and family members or any other individual where you have provided their information to us. Before providing us with any information you are responsible for ensuring that such individuals are aware of this policy and the provisions of this are clearly communicated to them:
· Contact information (such as name, email address, mailing address, and phone number);
· Payment information (including payment card numbers, billing address, and bank account information);
· Passport information;
· Travel itinerary;
· Details about birthdays, special events and friends and family where we are hosting an event for you;
· Demographic data (such as age, gender, country, and preferred language);
· Special categories of data (such as food allergies, health information we collect from your use of the Spa or if you have any health conditions);
· Information related to your reservation, stay, or visit to our property (including the date of arrival and departure, and goods and services purchased);
· Information necessary to fulfil your special requests and/or specific accommodations;
· Loyalty program member information, online account details, profile or password details;
· Copies of your correspondence if you contact us;
· Your interests and preferences;
· Information collected through the use of closed circuit television systems, card key and other security systems; and
· Information related to your use and interaction with our website (see section Cookies and online tracking below).
WHAT DO WE DO WITH YOUR INFORMATION?
The Landmark London collects your information to operate effectively and provide you with the best experiences with our services. The Landmark London may collect, use, and disclose the information it collects for a variety of reasons, including for the following purposes:
· Fulfillment of reservation and other purchases: we may process information relating to transactions that you enter into with us and/or through our website (“transaction data”). The transaction data may be processed for the purpose of completing your room reservation, supplying the purchased goods and services, customizing our services to your preferences, seeking your feedback on your stay at our properties, and keeping proper records of those transactions.
· Membership Programs: to administer and operate membership programs, including the Friends of Landmark program. The data may be processed for the purposes of recording stay and transactional data, earning and redeeming rewards, points, or credits in connection with the programs.
· Response to inquiries: we may process information contained in or relating to any communication that you send to us (“correspondence data”). The correspondence data may include the communication content and metadata associated with the communication. The correspondence data may be processed for the purposes of communicating with you and record-keeping.
· Internal business purposes: for our internal business purposes, such as data analysis, audits, developing new products, enhancing the website, improving our services, identifying usage trends and visiting patterns, determining the effectiveness of our promotions, and meeting contractual obligations.
· Administrative and other communications: to send you important information regarding our website, changes to our terms, conditions, and policies, or other administrative information (e.g., information about your travel reservations, such as reservation confirmations).
· Marketing and promotions: to communicate news and promotions relating to The Landmark London products and services and other products and services we think may be of interest to you, and to operate sweepstakes, contests, or other marketing or promotional activities.
· Safety and security: to maintain your safety and security as well as that of other guests and personnel, while you visit our managed hotels and residences.
· Our legal duties: to comply with legal and regulatory requirements or demands in accordance with applicable law, a court order, subpoena, or other legal process.
· Additional uses: We may also use your data in other ways as described to you when you provide such information to us.
LAWFUL GROUNDS FOR PROCESSING PERSONAL INFORMATION
The legal basis for processing your personal information is made up of one or more of the following reasons:
· Consent to the processing of such information for a specific reason;
· The processing is necessary to perform the agreement or to take steps to enter into an agreement;
· The processing is necessary for compliance with a legal obligation we have; or
· The processing is necessary for the purposes of a legitimate interest pursued by us, which might be:
(i) to provide our services;
(ii) to improve our website;
(iii) to keep our website safe and secure;
(iv) to prevent fraud;
(v) to protect our business interests;
(vi) to ensure that complaints are investigated;
(vii) to evaluate, develop or improve our services; or
(viii) to keep you informed about relevant services.
In relation to any processing of special categories of personal data, we will generally rely on obtaining specific consent from you at the time unless there is otherwise a legal requirement for us to process such information. Where you have consented to our processing of such special categories of personal data you may withdraw such consent at any time, by contacting us at firstname.lastname@example.org, however please be aware if you withdraw such consent we may be unable to provide you with our services.
COOKIES AND ONLINE TRACKING
We use tracking tools like browser cookies and web beacons to collect information from you. We collect information about users over time when you use this website or any apps that we may make available on our website.
Users of our website are able to verify and grant their consent to the use of tracking cookies during their visit. We use a privacy dashboard to permit users of our website to review and control their privacy settings during the time on our website.
We make the following distinctions between the cookie types in use on our website, and each cookie type is explained below:
· System: these cookies are necessary to ensure the website loads correctly. If these cookies were not set the website would not function. These are permanently enabled.
· Preference: these cookies ensure that choices you make while navigating the website are remembered for when you return to the website. These are permanently enabled.
· Anonymized: these cookies allow us to record information about your visit, the time you spend on the website and other points of interaction. The Internet Protocol (IP) information collected via these cookies are anonymized, and no personal information is shared. These are enabled by default but may be optionally disabled using the privacy dashboard.
· Marketing: these cookies allow us to collect IP information from you, this information is shared with third party data processors and allow us to provide relevant offers and promotions after you leave the website. An example of this might be a relevant hotel offer appearing on your personal news feed or timeline of a social media network you use. For example, we use The Facebook tracking pixel which is enabled once you have granted your consent to its use via our cookie popup. The use of such tracking pixels for marketing purposes can be changed at any time via your privacy dashboard which is accessible from this page. You should simply untick the checkbox for “marketing” and these cookies will not be active during your visit.
For your information we would like to highlight that each advertising network may provide additional mechanisms to anonymize your visit when connecting to a website. This stops any data about your visit being shared back to the social media network. For your ease of reference we provide the following link to the popular Facebook social network, where you may review the tracking preferences you have currently set and change them [click here]. If you use Google products the following page [click here] provides similar information for controlling your advertising settings.
WHO MIGHT WE SHARE YOUR INFORMATION WITH?
We keep all information confidential. However, in order to provide our services to the best of our ability, we may share any information with our agents, advisers, contractors, and support service or data providers, wherever located. The specific kind of information we share will depend on the context of your interactions with The Landmark London, and the services you use. Accordingly, your personal information may be shared with the following parties insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy:
· The Lancaster Landmark Hotel Company Ltd network of companies;
· To the representative or travel advisor that has supplied us with your personal information (for example, your travel agent, personal assistant, employer or spouse who has provided us with your details);
· To our trusted business partners and suppliers to process it for us, based on our instructions and any other appropriate confidentiality and security measures;
· To our marketing and advertisement partners to provide you with more-relevant ads on our site and to encourage you to return to our site;
· To our advisers;
· To third parties not affiliated with The Landmark London if we have a good-faith belief that it is reasonably necessary to: (1) meet any applicable law, regulation, legal process or enforceable governmental request; (2) enforce applicable terms of service, including investigation of potential breaches; (3) detect, prevent, or otherwise address fraud, security or technical issues; and (4) protect against harm to the rights, property or safety of The Landmark London, our users or the public as required or permitted by law; and
· To any third parties to the extent necessary with respect to a sale of all or part of our business operations or assets.
TRANSFERRING INFORMATION OUTSIDE THE UK
Information in our possession may be transferred to other countries (particularly to our agents, service providers and contractors in different countries which may include countries outside the European Economic Area) for any of the purposes described in this Notice.
These countries may have differing (and potentially less stringent) laws relating to the degree of confidentiality afforded to the information they hold and that such information can become subject to the laws and disclosure requirements of such countries, including disclosure to governmental bodies, courts regulatory agencies and private persons, as a result of applicable governmental or regulatory inquiry, court order or other similar process. In addition, a number of countries have agreements with other countries providing for exchange of information for law enforcement, tax and other purposes.
When we, or our permitted third parties, transfer information outside the European Economic Area, we or they will impose contractual obligations on the recipients of that data to protect such information to the standard required in the European Economic Area. We or they may require the recipient to subscribe to international frameworks intended to enable secure data sharing. In the case of transfers by us, we may also transfer information where:
· The transfer is to a country deemed by the European Commission to provide adequate protection of information;
· We have received consent to such transfer, or
· Such transfer is otherwise permissible under data protection legislation (for example if we are required to provide such information by law).
HOW SECURE IS YOUR INFORMATION?
We implement appropriate administrative, organisational and technical safeguards and security measures to protect personal information within our control from unauthorized access, acquisition, disclosure, destruction or alteration, accidental loss, misuse or damage. We regularly review and monitor such safeguards and security measures.
HOW LONG DO WE KEEP HOLD OF YOUR INFORMATION?
To the extent permissible by applicable law, we will retain your personal information for such period as necessary to satisfy or to fulfil the following:
· The purposes for which that personal information was provided;
· An identifiable and ongoing business need, including record keeping;
· A specific legal or regulatory requirement; and/or
· A requirement to retain records that may be relevant to any notified regulatory investigations or active legal proceedings.
Where there is no sufficient justification to retain such personal information, such personal information will be safely and securely deleted, disposed of, anonymised and/or blocked.
WHAT ARE MY RIGHTS IN RELATION TO PERSONAL INFORMATION?
At any time, you have the right:
· To request access to or a copy of any personal data which we hold about you;
· To rectification of your personal data, if you consider that it is inaccurate;
· To ask us to delete your personal data, if you consider that we do not have the right to hold it;
· To withdraw consent to our processing of your personal data (to the extent such processing is based on previously obtained consent);
· To ask us to stop or start sending you marketing messages as described below in the marketing section;
· To restrict processing of your personal data;
· To data portability (moving some of your personal data elsewhere) in certain circumstances;
· To object to your personal data being processed in certain circumstances; and
Any request for access to or a copy of your personal data must be in writing and we will endeavour to respond within a reasonable period and in any event within one month in compliance with data protection legislation. We will comply with our legal obligations as regards your rights as a data subject.
We aim to ensure that the information we hold about you is accurate at all times. To assist us in ensuring that your information is up to date, do let us know if any of your personal details change.
Questions, comments and requests regarding this policy are welcomed and should be addressed to email@example.com.
If also have the right to make a complaint to the ICO, you can contact them on their helpline 0303 123 1113.
INFORMATION ABOUT RELATED PERSONS
The collection of personal data relating to persons under the age of 16 years is not within our interests. Should it come to our attention that such data has been passed to us without the approval of the parents or legal guardian, this data will be deleted immediately.
Thereby we are reliant on the parents or legal guardians providing us with the appropriate information.
GENERAL TERMS & CONDITIONS
LINKS TO OTHER WEBSITES
The information contained in this website is for general information purposes only. The information is provided by The Landmark London and while we do endeavour to keep the information up to date and correct, we make no representations or warranties of any kind, express or implied, about the completeness, accuracy, reliability, suitability or availability with respect to the website or the information, products, services, or related graphics contained on the website for any purpose. Any reliance you place on such information is therefore strictly at your own risk.
In no event will we be liable for any loss or damage including without limitation, indirect or consequential loss or damage, or any loss or damage whatsoever arising from loss of data or profits arising out of, or in connection with, the use of this website.
Through this website you are able to visit to other websites which are not under the control of The Landmark London. We have no control over the nature, content and availability of those sites. The inclusion of any links does not necessarily imply a recommendation or endorse the views expressed within them.
Every effort is made to keep the website up and running smoothly. However, The Landmark London takes no responsibility for, and will not be liable for, the website being temporarily unavailable due to technical issues beyond our control.
For more information, please contact firstname.lastname@example.org.
This website and its content is copyright of The Landmark London, registered in England No. 6618138. All rights reserved. Any redistribution or reproduction of part or all of the contents in any form is prohibited other than the following:
You may print or download to a local hard disk extracts for personal and non-commercial use only. You may copy the content to individual third parties for their personal use, but only if you acknowledge the website as the source of the material. For example, source: The Landmark London.
You may not, except with express written permission, distribute or commercially exploit the content. Nor may you transmit it or store it in any other website or other form of electronic retrieval system.