1.0 Introduction and Terms
2.0 WHO WE ARE AND How to contact us
FAO: Privacy Officer
Watergate Bay Hotel Limited
Watergate Bay Hotel
Telephone: 01637 860543 and ask to speak to the Privacy Officer
3.0 Your rightsUnder the Data Protection Laws your rights are:
3.1 To be informed – We must make available this privacy notice with the emphasis on transparency over how we process your data.
3.2 Access – You are entitled to find out what details we may hold about you and why.
3.3 Rectification – We are obliged to correct or update your details.
3.4 Erasure – This is also known as the request to be forgotten.
3.5 Restrict processing – You have the right to ‘block’ or suppress the processing by us of your personal data.
3.6 Data portability – You have the right to obtain and reuse your personal data that you have provided to us.
3.7 Object – You have the right to object to us processing your data in relation to direct marketing and or profiling.
3.8 Rights in relation to automated decision making and profiling – We do not use automatic decision making or processing.
4.0 The data we collect about you
4.1 We collect and process Personal Data. Typically the Personal Data we collect and process will include name, billing address, shipping address and email address but we may collect and/or process other Personal Data from time to time. It also may include your IP address and cookies of your visit to websites.
4.2 We only collect data from you directly or via third parties (see Third Parties below).
5.0 How your data will be used
5.1 We use information held about you to:
5.1.1 ensure that content from our site is presented in the most effective manner for you and for your devices;
5.1.2 provide you with information, products or services that you request from us or which we feel may interest you (where you have consented to be contacted for such purposes or by Legitimate Interest);
5.1.3 carry out our obligations arising from any contracts entered into between you and us;
5.1.4 allow you to participate in interactive features of our service when you choose to do so, e.g. asking a question through our website.
5.1.5 carry out necessary maintenance to our infrastructure; and
5.1.6 notify you about changes to our services
5.2 We also embrace the use of social media and may wish to process any comments made public by you.
5.3 We never sell your data to third parties or allow third parties to contact you without your permission.
5.4 We share your data with third parties where there is a legal obligation for us to do so or we have identified a valid lawful basis or a legitimate interest for us to do so.
5.5 Where we rely on legitimate interest to process or share data, we have carried out a legitimate interest assessments to identify our legitimate interests in processing the data on this basis. Copies of our legitimate interest assessments are available on request, using the contact details at 2.1 above.
5.6 Note that we may also 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(s) we are relying on to process your personal data.
5.7 We may process your personal data without your knowledge or consent where this is required or permitted by law.
5.8 You can ask us to stop sending you marketing messages at any time by following the opt-out links or contact details on any marketing message/materials sent to you.
6.0 THIRD PARTIES
6.1 We will keep your information within the organisation except where disclosure is required or permitted by law or when we use third party service providers (data processors) to supply and support our services to you. We have contracts in place with our data processors. This means that they cannot do anything with your personal data unless we have instructed them to do so. They will not share your personal data with any organisation apart from us. They will hold it securely and retain it for the period we instruct.
6.2 Please see below the list which sets out the categories of recipients of personal data.
- Courier provider
- IT support services
- Email provider
- Secure document disposal service
- Internal HR systems provider
- Email marketing platforms
6.3 In addition, third parties may provide us with Personal Data and they should only do so where the law allows them to.
6.4 Our store is hosted on Shopify Inc. They provide us with the online e-commerce platform that allows us to sell our products and services to you. Your data is stored through Shopify’s data storage, databases and the general Shopify application. They store your data on a secure server behind a firewall.
- If you choose a direct payment gateway to complete your purchase, then Shopify stores your credit card data. It is encrypted through the Payment Card Industry Data Security Standard (PCI-DSS). Your purchase transaction data is stored only as long as is necessary to complete your purchase transaction. After that is complete, your purchase transaction information is deleted.
- All direct payment gateways adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard and American Express.
- PCI-DSS requirements help ensure the secure handling of credit card information by our store and its service providers.
- For more insight, you may also want to read Shopify’s Terms of Service (https://www.shopify.com/legal/terms) or Privacy Statement https://www.shopify.com/legal/privacy).
7.0 WHERE YOUR DATA IS HELD
Any digital data that contains your personal data is stored within the European Economic Area, or with Privacy Shield (or equivalent) registered organisations who have confirmed their compliance with the GDPR regulations.
8.0 LEGITIMATE INTEREST & MARKETING
8.1 Where we use Legitimate Interests we will record our decision and our method on making this decision.
8.2 If you are new or existing contact or customer we will only contact you by postal and electronic means (e-mail) with information about services or goods which you have previously purchased from us or enquired about, where you have given consent or where we have identified the valid lawful basis of legitimate interest to contact you.
9.0 APPLICATIONS TO WORK FOR US
If you apply to work for us (directly or indirectly) in any role (including volunteers) we may receive data about you from third parties. In addition, we will keep the details of your application and any additional information provided to us by you or others during your application so that we can keep you informed of future opportunities that you may be interested in. If you do not wish for us to keep your details for this reason, please let us know by contacting us using the details provided in this policy.
10.0 DATA RETENTION
Our data retention policy is dictated by the Data Protection Laws and is available for inspection by submitting a written request using the contact details provided in this policy.
11.0 DATA DELETION
Under Data Protection Laws you have the right to erasure under specific circumstances. A request for your personal data to be deleted will be decided on a case by case basis and must be submitted in writing to the contact details provided in this policy.
12.0 DATA CORRECTION
We will correct or update your data without delay provided you make the request in writing to the contact details provided in this policy, clearly specifying which data is incorrect or out of date.
13.0 DATA INSPECTION
13.1 We strive to be as open as we can be in terms of giving people access to their personal data. Individuals can find out if we hold any of their personal data by making a formal request under the Data Protection Laws. Such requests must be in writing to the contact details provided in this policy. If we do hold your personal data we will respond in writing within one calendar month of your request (where that request was submitted in accordance with this policy).
13.2 The information we supply will:
13.2.1 confirm that your data is being processed;
13.2.2. verify the lawfulness and the purpose of the processing;
13.2.3 confirm the categories of personal data being processed;
13.2.4 confirm the categories of personal data being processed;
13.2.5 confirm the type of recipient to whom the personal data has been or will be disclosed; and
13.2.5 let you have a copy of the data in an intelligible form.
13.3 Please note that you may need to provide identification in order to prove who you are to access your data.
13.4 If you agree, we will try to deal with your request informally, for example by providing you with the specific information you need over the telephone.
13.5 In the instance that we do not hold information about you we will also confirm this in writing at the earliest opportunity.
You have the right to complain about the processing of your personal data. Please contact us using the details provided above. If you are still unsatisfied you have the right to complain to the Information Commissioners Office.