This is the privacy notice of Spaniel, Spaniel, Lombard & Rowntree Ltd t/a The Albion Rooms. In this document, “we”, “our”, or “us” refer to Spaniel, Spaniel, Lombard & Rowntree Ltd t/a The Albion Rooms. Company number 10822975 registered in the United Kingdom. Our registered office is at 88/90 Baker Street, London W1U 6TQ.
We request you to read this policy document carefully before sharing personal information with us. By visiting our website, we assume, your acceptance to the practices described in this policy document.
This privacy notice aims to inform you about how we collect and process any information that we collect from you, or that you provide to us. It covers information that could identify you (“personal information”) and information that could not. In the context of the law and this notice, “process” means collect, store, transfer, use or otherwise act on information. It tells you about your privacy rights and how the law protects you.
We are committed to protecting your privacy and the confidentiality of your personal information. Our policy is not just an exercise in complying with the law, but a continuation of our respect for you and your personal information.
We undertake to preserve the confidentiality of all information you provide to us, and hope that you reciprocate.
Our policy complies with the Data Protection Act 2018 (Act) accordingly incorporating the EU General Data Protection Regulation (GDPR).
The law requires us to tell you about your rights and our obligations to you in regard to the processing and control of your personal data. We do this now, by requesting that you read the information provided at 5. http://www.knowyourprivacyrights.org
Except as set out below, we do not share, or sell, or disclose to a third party, any information collected through our website or property.
The Data we process
We may collect, use, store and transfer different kinds of personal data about you, grouped as follows:
- Identity information such as first name, last name, title, date of birth, and other identifiers that you may have provided at some time, such as your job designation and business contact details.
- Contact information includes information such as billing address, delivery address, email address, telephone numbers and any other information you have given to us for the purpose of communication or meeting.
- Financial data includes information such as your bank account and payment card details.
- Transaction data includes details about payments or communications to and from you and information about products and services you have purchased from us. Such as: your dates of arrival and departure from our hotel/restaurant/other outlets, your preferences when you stay with us, your transaction history with us; offers you have availed of from third party marketers in response to communication from us.
- Technical data includes your internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
- Marketing data includes your preferences in receiving marketing from us; communication preferences; responses and actions in relation to your use of our services.
We may aggregate anonymous data such as statistical or demographic data for any purpose e.g. to assess interest in a product or service. Anonymous data is data that does not identify you as an individual. Aggregated data may be derived from your personal data but is not considered personal information in law because it does not reveal your identity. However, if we combine or connect aggregated data with your personal information so that it can identify you in any way, we treat the combined data as personal information and it will be used in accordance with this privacy notice.
Special personal information is data about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data.
We do not collect any special personal information about you. We may use any health-related information provided by you only to serve you better and meet your specific needs when you stay or dine with us.
The legal bases on which we process information about you
It is necessary for the purposes of our legitimate interests of pursuing and developing our business, where such interests are not overridden by your rights or interests. When you create an account on our website, buy a product or service from us, or otherwise agree to our terms and conditions, a contract is formed between you and us. In order to carry out our obligations under that contract we must process the information you give us. Some of this information may be personal information. We may process information on the basis there is a legitimate interest, either to you or to us, of doing so. We may process your data on this basis for the purposes of, for example: record-keeping for the proper and necessary administration of our business; responding to unsolicited communication from you to which we believe you would expect a response; protecting and asserting the legal rights of any party; insuring against or obtaining professional advice that is required to manage business risk; protecting your interests where we believe we have a duty to do so.
We have a legal obligation to process your information in order to comply with a statutory obligation. For example, we may be required to give information to legal authorities if they so request or if they have the proper authorisation such as a search warrant or court order. This may include your personal information.
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform that contract. In that case, we may have to stop providing a service to you. If so, we will notify you of this at the time.
Specific uses of information you provide to us
We may use your personal information for the following purposes:
- to fulfil your bookings and/or to provide services, products or facilities you request from us;
- to collect payment from you;
- to administer and manage our relationship with you, which may include asking you to complete surveys or feedback forms;
- where you have made a reservation with us, to send you information before your visit to confirm the reservation and to provide you with other information relating to your reservation which we think you may find of interest;
- to send you marketing and promotional material where we think this may be of interest to you (unless you have objected to receiving this);
- where required by law; and
- where necessary to protect your health or wellbeing or that of another individual.
MAILING LIST SUBSCRIBERS
When you subscribe to our mailing list/newsletter, we use the so-called double opt-in procedure, i.e. we will only send you communications by e-mail if you confirm in our notification e-mail by clicking on a link that you are the owner of the e-mail address provided. If you confirm your e-mail address, we will store your e-mail address, the time of registration and the IP address used for registration until you unsubscribe from the newsletter. The sole purpose of the storage is to send you the newsletters/mailshot and to be able to prove your registration. You can unsubscribe from the newsletter/mailing list at any time. A corresponding unsubscribe link can be found in every newsletter. A message (e.g. by e-mail or letter) to the contact data given below or as provided in the footer of every communication we send, is of course also sufficient. The legal basis of the processing is your consent pursuant to Art. 6 sec. 1 lit. f GDPR.
In our newsletters/mailshots we use commercially established technologies, enabling us to measure interactions (e.g. opening of the e-mail, clicked links). We use this data in pseudonymous form for general statistical evaluations as well as for the optimisation and further development of our content and customer communication. This data is collected using small graphics embedded in the newsletter/mailshot (so-called pixels), which can also collect Technical Data regarding the device you use. The data is collected exclusively pseudonymised and is not linked to your other personal data. The legal basis for this is our aforementioned legitimate interest, Art. 6 sec. 1 lit. f GDPR [The legal basis of the processing is your consent pursuant to Art. 6 sec. 1 lit. a GDPR]. Through our newsletter/mailshots we want to share content that is as relevant as possible for our customers and better understand what readers are actually interested in. If you do not wish the analysis of usage behaviour, you can unsubscribe from our newsletter/mailing list or deactivate graphics in your e-mail program by default. The data on the interaction with our newsletters/mailshots are stored pseudonymously for 30 days and subsequently made completely anonymous.
Online payment information is never taken by us or transferred to us either through our website or otherwise. Our employees and contractors never have access to it. At the point of payment, you are transferred to a secure page on the website of PayPal or Stripe or other reputable payment service provider. That page may be branded to look like a page on our website, but it is not controlled by us.
THIRD PARTY SERVICE PROVIDERS
Third party providers of services such as hosting, data analysis (including webtracking services), search engines, payment processing, order fulfilment, IT services, email delivery, auditing and other similar services) to enable them to provide such services and/or to assist us in improving and optimising our website or services. All third-party service providers are bound by a Data Processing Agreement where applicable to ensure compliance with applicable privacy legislation and maintain their own privacy policies.
Any third party that sponsors or provides (in whole or in part) a contest or similar promotion through the Site for all purposes in connection with such contest or promotion, provided you have consented separately when taking part in the promotion.
As far as transfer to above mentioned recipients is required for any of the purposes mentioned, the transfer of data is based on our legitimate interests or on your consent.
When you contact us, whether by telephone, through our website or by e-mail, we collect the data you have given to us in order to reply with the information you need. We record your request and our reply in order to increase the efficiency of our business. We keep personally identifiable information associated with your message, such as your name and email address so as to be able to track our communications with you to provide a high quality service.
If you send us information in connection with a job application, we may keep it for up to three years in case we decide to contact you at a later date. If we employ you, we collect information about you and your work from time to time throughout the period of your employment. This information will be used only for purposes directly relevant to your employment. After your employment has ended, we will keep your file for six years before destroying or deleting it.
When we receive a complaint, we record all the information you have given to us. We use that information to resolve your complaint. If your complaint reasonably requires us to contact some other person, we may decide to give to that other person some of the information contained in your complaint. We do this as infrequently as possible, but it is a matter for our sole discretion as to whether we do give information, and if we do, what that information is. We may also compile statistics showing information obtained from this source to assess the level of service we provide, but not in a way that could identify you or any other person.
SOCIAL MEDIA PLATFORMS
Communication, engagement and actions taken through external social media platforms that this website and its owners participate on are custom to the terms and conditions as well as the privacy policies held with each social media platform respectively.
Users are advised to use social media platforms wisely and communicate / engage upon them with due care and caution in regard to their own privacy and personal details. This website nor its owners will ever ask for personal or sensitive information through social media platforms and encourage users wishing to discuss sensitive details to contact them through primary communication channels such as by telephone or email.
This website may use social sharing buttons which help share web content directly from web pages to the social media platform in question. Users are advised before using such social sharing buttons that they do so at their own discretion and note that the social media platform may track and save your request to share a web page respectively through your social media platform account.
When posting personal information, it is up to you to satisfy yourself about the privacy level of every person who might use it. On our website or associated social media channels, we do not specifically use this information except to allow it to be displayed or shared. Once your information enters the public domain, we have no control over what any individual third party may do with it. We accept no responsibility for their actions at any time. We do attempt to moderate user generated content, but we are not always able to do so as soon as that content is published. If you complain about any of the content, we shall investigate your complaint. If we feel it is justified or if we believe the law requires us to do so, we shall remove the content while we investigate.
Use of information we collect through automated systems when you visit our website:
Cookies are small text files that are placed on your computer’s hard drive by your web browser when you visit any website. They allow information gathered on one web page to be stored until it is needed for use on another, allowing a website to provide you with a personalised experience and the website owner with statistics about how you use the website so that it can be improved. Some cookies may last for a defined period of time, such as one day or until you close your browser. Others last indefinitely. Your web browser should allow you to delete any you choose. It also should allow you to prevent or limit their use.
Requests by your web browser to our servers for web pages and other content on our website are recorded. We record information such as your geographical location, your Internet service provider and your IP address. We also record information about the software you are using to browse our website, such as the type of computer or device and the screen resolution.
We use this information in aggregate to assess the popularity of the webpages on our website and how we perform in providing content to you. If combined with other information we know about you from previous visits, the data possibly could be used to identify you personally, even if you are not signed in to our website.
Disclosure and sharing of your information
INFORMATION OBTAINED FROM THIRD PARTIES
Although we do not disclose your personal information to any third party (except as set out in this notice), we sometimes receive data that is indirectly made up from your personal information from third parties whose services we use. No such information is personally identifiable to you.
CREDIT REFERENCE AGENCIES
To assist in combating fraud, we share information with credit reference agencies, so far as it relates to clients or customers who instruct their credit card issuer to cancel payment to us without having first provided an acceptable reason to us and given us the opportunity to refund their money.
DATA PROCESSED OUTSIDE THE EU
Our websites are hosted in the United Kingdom. We may also use outsourced services in countries outside the European Union from time to time in other aspects of our business. Accordingly data obtained within the UK or any other country could be processed outside the European Union. For example, some of the software our website uses may have been developed in the United States of America or in Australia.
With respect to data transferred outside the European Union, the Recipients either: comply with a code of conduct approved by a supervisory authority in the European Union; are bound by Standard Contractual Clauses of the EU Commission for the protection of personal data; or they are located in countries in regard to which the EU Commission issued an adequacy decision according to Art. 45. GDPR.
Control over your own information
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes.
At any time you may review or update personally identifiable information that we hold about you, by signing in to your account on our website.
To obtain a copy of any information that is not provided on our website you should contact us to make that request.
After receiving the request, we will tell you when we expect to provide you with the information, and whether we require any fee for providing it to you.
If you wish us to remove personally identifiable information from our website, you should contact us to make your request.
This may limit the service we can provide to you.
When we receive any request to access, edit or delete personal identifiable information we shall first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information.
USE OF THE SITE BY CHILDREN
We do not sell products or provide services for purchase by children, nor do we market to children. If you are under 18, you may use our website only with consent from a parent or guardian.
We do not knowingly collect personal information from individuals under 18 years of age. As a parent or legal guardian, please do not to allow your children to submit personal information without your permission.
Unfortunately, the transmission of information via online or mobile networks is not completely secure. You acknowledge and accept that others may intercept personal information you provide to us, and that any such transmission is at your own risk. Once we have received your information, we use set procedures and security features to try to prevent unauthorised access.
ENCRYPTION OF DATA
We use Secure Sockets Layer (SSL) certificates to verify our identity to your browser and to encrypt any data you give us.
Whenever information is transferred between us, you can check that it is done so using SSL by looking for a closed padlock symbol or other trust mark in your browser’s URL bar or toolbar.
RETENTION PERIOD FOR PERSONAL DATA
Except as otherwise mentioned in this privacy notice, we keep your personal information only for as long as required by us:
⦁ to provide you with the services you have requested;
⦁ to comply with other law, including for the period demanded by our tax authorities;
⦁ to support a claim or defence in court.
COMPLIANCE WITH THE LAW
However, ultimately it is your choice as to whether you wish to use our website.
We may update this privacy notice from time to time as necessary. The terms that apply to you are those posted here on our website on the day you use our website. We advise you to print a copy for your records.
HOW YOU CAN COMPLAIN
If a dispute is not settled then we hope you will agree to attempt to resolve it by engaging in good faith with us in a process of mediation or arbitration.
If you are in any way dissatisfied about how we process your personal information, you have a right to lodge a complaint with the Information Commissioner’s Office (ICO). This can be done at https://ico.org.uk/make-a-complaint/. We would, however, appreciate the opportunity to talk to you about your concern before you approach the ICO.