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Your privacy is very important to us. We promise to respect and protect your personal information and try to make sure that your details are accurate and kept up to date. This Privacy Notice sets out details of the information that we may collect from you and how we may use that information. Please take your time to read this Privacy Notice carefully. When using our website, this Privacy Notice should be read alongside the website terms and conditions.
In this Privacy Notice references to “we” or “us” or “Athenaeum” are to Genesta Athenaeum LLP.
Ralph Trustees Limited operates a group of hotels comprising The Grove, The Runnymede-on-Thames and The Athenaeum.
In order to provide our services, we will collect and use personal information about individuals. We are the Controller of all personal information we process pursuant to this Policy and we are responsible for complying with data protection laws.
If you have any questions about how we collect, store or use your personal information, you may contact us using the details set out in the “Contact Us” section 8.
This Policy sets out the legal grounds enabling us to process your personal information.
Where you provide personal information to us about other individuals (for example, members of your family or your employees) we will also be data controller of and responsible for their personal information. You should refer them to this Policy before supplying us data on behalf of others.
When you engage with us, such as make a booking or view our website, we will collect information about you and that engagement. This may include information such as:
Sometimes we need to collect personal information by law, or under the terms of the contract we have with you. If you fail to provide that information when we request it, we may not be able to perform the contract we have or are trying to enter into with you (for example to provide you with goods or services). In this case, we may have to cancel the product or service, but we will notify you if this is the case.
We will collect information directly from you when you engage with us:
We will also collect information indirectly when you engage with us via:
We will combine any personal information about you that we receive from you, from other hotels in our group, and from third parties.
Sometimes we will request or receive your “sensitive personal information” in order to fulfil services you have requested. This may include information such as:
We will only collect, process and/or use the personal information where we are satisfied that we have an appropriate legal basis to do so. All personal information that we obtain about you will be used in accordance with current data protection law and this Privacy Policy. We, or third party data processors acting on our behalf, will process your personal information as follows:
We will collect information directly from you:
As well as obtaining information directly from you, we will collect information from:
There are a number of reasons we use your personal information and for each use we need to have a “legal ground” to do so.
We will rely on the following “legal grounds” when we process your “personal information”:
In each case we assess our need to use this personal information for these purposes against your rights to privacy to ensure we are protecting your rights.
When we use your “special categories of personal information”, we must have an additional “legal ground” and we will rely on the following legal grounds in these circumstances:
From time to time, we may share your personal information between our internal departments of the Athenaeum hotel as follows:
or with the following third parties for the purposes set out above:
If you would like further information regarding the disclosures of your personal information, please see the “Contact us” section below for our contact details.
This section will apply if you are a third party supplier to Genesta Athenaeum LLP.
We do not collect any special categories information from 3rd parties.
We will collect information directly from you:
As well as obtaining information directly from you, we will collect information from:
Other business companies and representatives
Publically available sources such as internet search engines and company check websites.
Third party providers including (e.g. credit checks service providers.)
Financial crime detection agencies (such as for fraud prevention and checking against international sanctions)
There are a number of reasons we use your personal information and for each use we need to have a “legal ground” to do so.
We will rely on the following “legal grounds” when we process your “personal information”:
In each case we assess our need to use this personal information for these purposes against your rights to privacy to ensure we are protecting your rights.
When we use your “special categories of personal information”, we must have an additional “legal ground” and we will rely on the following legal grounds in these circumstances:
From time to time, we may share your personal information, as follows:
Within Genesta Athenaeum LLP
We may share your personal information internally between our departments. We will do this via access to internal reports and centralised IT and marketing systems.
With third parties and service providers working on our behalf
We may share your personal information with our third-party service providers, agents, sub-contractors and other associated organisations for the purposes of completing tasks and providing services to you on our behalf (for example, to process payments and send you emails). However, when we use third-party service providers, we disclose only the personal information that is necessary to deliver the service and we have a contract in place that requires them to keep your information secure and not to use it for their own direct marketing purposes.
Third-party product providers we work in association with:
We work with carefully selected Online Travel Agents (OTAs, e.g. Booking.com). When you enquire about us or book with these third parties, the relevant third-party will use your details to provide you with information and carry out their obligations arising from any contracts you have entered into with them. They will be acting as a data controller of your information and we therefore advise you to read their Privacy Policy. These third-party product providers will share required information about you with us (e.g. room type purchased and dates of stay) that we will use in accordance with this Privacy Policy.
When you are using our secure online booking system, your purchase is processed by a third-party payment processor, who specialises in the secure online capture and processing of credit/debit card transactions.
We will also disclose your personal information to third parties in the following circumstances:
Save as expressly detailed above in this section, we will never share, sell or rent any of your personal information to any third party without notifying you and/or obtaining your consent.
If you would like further information regarding the disclosures of your personal information, please see the “Contact us” section below for our contact details.
We have a legitimate interest to market to you. We use your personal information to provide you with information about The Athenaeum hotel’s, services or events which may be of interest to you as one of our past or prospective customers. These may include information about stays, events, promotions, offers, information about the hotel and the surrounding area
If you wish to opt out of marketing, you may do so by clicking on the “unsubscribe” link that appears in all emails or telling us when we talk to you.
Please note that, even if you opt out of receiving marketing messages, we may still send you service related communications where necessary.
We will only keep your personal information for the minimum periods required in order to fulfil the relevant purposes set out in this Privacy Policy.
We are also required to keep certain information in order to comply with our legal and regulatory obligations.
The exact time period will depend on your relationship with us and the type of personal information we hold. We may be required to retain the personal information for longer periods e.g. to establish, exercise or defend legal rights, such as responding to customer personal injury complaints.
If you would like further information regarding the periods for which your personal information will be stored, please contact us using the details set out in section 8.
Genesta Athenaeum LLP carries out automated processing.
We will combine any personal information about you that we receive from you, from other hotels in our group, and from third-parties in order to create marketing profiles.
Marketing profiles include personal information such as information about services you have used, information about when you have visited our hotels in the past, demographic data and, where you have agreed, data from your social media profiles.
For example, we may analyse the personal information of people who have used our services in the past and then compare them with other people in our database. If we identify people in our database who have similar personal information, we may then target marketing to those people, for example by sending direct marketing emails. We may conduct the profiling and marketing automatically.
We conduct these automated decision-making and profiling activities for our legitimate interests in providing the services and ensuring they operate in a commercially suitable way which is tailored to your use and interests.
Under data protection law you have certain rights in relation to the personal information that we hold about you. You may exercise these rights at any time by contacting us using the details set out in section 8.
In some cases we may not be able to comply with your request (for example, where there is a conflict with our own obligations to comply with other legal or regulatory requirements). However, we will always respond to any request you make and if we can’t comply with your request, we will tell you why.
You have the right to:
· The right to access your personal information ► |
This enables you to receive a copy of the personal information we hold about you and to check that we are processing it lawfully. |
· Request correction of the personal information we hold about you ► |
This enables you to have any incomplete or inaccurate data we hold about you corrected, although we may need to verify the accuracy of the new information you provide us with. |
· Request erasure of your personal information ► |
This enables you to ask us to delete or remove your personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal information to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons. We will notify you of these, if applicable, at the time of your request |
· Object to the processing of your personal information ► |
Where we are relying on a legitimate interest (or those of a third party) and you feel it impacts on your fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information, which override your rights and freedoms, e.g. a requirement imposed on us by law. |
· Request restriction of the processing of your personal information ► |
In some cases, e.g. questions over accuracy, lawfulness, the requirement to hold data or your objection to data usage, you may ask us to suspend the processing of your personal information. |
· Request the transfer of your personal information to you or to a third party ► |
If required, we will provide you or a third party of your choice with your personal information in a structured, commonly used, machine-readable format. Note, this right only applies to automated information that you initially provided consent for us to use or information that was used to perform a contract with you. |
· Withdraw consent at any time ► |
Where we are relying on consent to process your personal information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent we may not be able to provide certain products or services to you. We will advise you if this is the case at the time.
Please note that for some purposes, we need your consent in order to provide you with a service. If you withdraw your consent, we may need to cancel your reservation, booking or service. We will advise you of this at the point you seek to withdraw your consent. |
· The right to lodge a complaint with the ICO ► |
You have a right to complain to the Information Commissioner’s Office (ICO) if you believe that any use of your personal information by us is in breach of applicable data protection laws and regulations. More information can be found on the Information Commissioner’s Office website: https://ico.org.uk/
Making a complaint will not affect any other legal rights or remedies that you have. |
We use a range of organisational and technical security measures to protect your information, including firewalls and access controls, which we review periodically. We also ensure that our employees receive appropriate data security training.
If you would like further information about any of the matters in this Privacy Policy or have any other questions about how we collect, store or use your personal information, you may contact our data protection adviser by using the contact details provided below:
Data Protection Enquiries
Genesta Athenaeum LLP
116 Piccadilly
London
W1J 7BJ
info@athenaeumhotel.com
We may need to make changes to this Privacy Policy periodically, for example, as the result of government regulation, new technologies, or other developments in data protection laws or privacy generally.
This Privacy Notice was last updated on: 1 December 2022.
If you cannot find the answer you are looking for, feel free to call 020 7640 3557, contact us via our form, or email info@athenaeumhotel.com.
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