ROW Legal policy, Bbar and Restaurant, Victoria, London

Privacy Policy

1. ABOUT THIS DOCUMENT
2. YOUR CONSENT
3. COPYRIGHT NOTICE
4. ABOUT US
5. CONTACTING US
6. OUR COMMITMENT
7. WHO OUR PRIVACY POLICY COVERS
8. WHAT LAWS WE COMPLY WITH
9. WHAT TYPES OF PERSONAL INFORMATION WE PROCESS
10. HOW WE COLLECT OR GENERATE YOUR PERSONAL INFORMATION
11. WHAT DO WE USE YOUR PERSONAL INFORMATION FOR?
12. USE OF YOUR PERSONAL DATA FOR DIRECT MARKETING
13. DISCLOSURE OF YOUR PERSONAL DATA
14. HOW THIRD PARTIES WILL HANDLE YOUR PERSONAL DATA
15. LOCATION OF YOUR PERSONAL INFORMATION
16. KEEPING YOUR DATA SECURE
17. HOW LONG DO WE KEEP YOUR PERSONAL DATA FOR?
18. YOUR RIGHTS
19. CHANGES TO THIS PRIVACY POLICY

1. ABOUT THIS DOCUMENT

This document (our “privacy policy”) sets out information into how we use personal information relating to people we interact with including, for example, customers and website users. It serves as an expression of our commitment to protecting your personal data. It is important that you read this privacy policy together with any other privacy notices we may provide you on all occasions of personal data collection and processing, so you are fully aware of how and why we are using your data. This privacy notice supplements other notices and is not intended to override them.

2. YOUR CONSENT

This Privacy Policy is incorporated into and forms part of our Terms of Use, which outline the terms and conditions you agree to when accessing and using this website. By accessing and using this website and providing personal information to us, or by booking any travel services with us, you agree and consent to the collection, use and disclosure of your personal information as outlined in this Privacy Policy.

3. COPYRIGHT NOTICE

4. ABOUT US

This is the privacy policy of Red Carnation Hotels (referred to as “we”, “us” or “our”). We are incorporated under the laws of England and Wales. Our incorporation number is 3328595 our incorporation address or registered office is 35 Charles Street, London, W1J 5EBV.

5. CONTACTING US

If you have any questions about our privacy policy or about how we process your personal data, including any complaints, please contact us either by e-mail to emarketing@rchmail.com or by post to Red Carnation Hotels Marketing, 14 Grosvenor Place, London, SW1X 7HH.

6. OUR COMMITMENT

We respect your right to privacy and we aim to ensure you have a trustworthy experience with us, including when using our websites or shops and booking with or through us. We understand that you care about how your personal data is used by us, and we want to share with you the policies and practices we’ve adopted. This way you can feel confident about how we handle your personal data that you entrust to us.

7. WHO OUR PRIVACY POLICY COVERS

7.1 Our customers

Our privacy policy sets out how we process personal data (including information) relating to individuals who are booking or enquiring about booking travel services with or through us or who are the recipients of any travel services booked with or through us (e.g. you are the passenger for a booking or booking enquiry made by someone else for you), or who are customers or potential customers or recipients of travel services that can be booked with or through us.

7.2 Examples of who this policy covers

We include in this privacy policy personal data we process relating to: (1) individuals who are making any enquiry or booking with us or through us, and individuals in respect of whom any enquiry or booking is made (such as friends, family members, and tour group members, and officers and employees of businesses and organisations booking with or through us); (2) individuals in respect of whom any enquiry or booking is made with us by an agent; (3) where our customer is a business or organisation, employees or individuals who are acting as representatives of that business or other organisation, and individuals connected to that business or other organisation, such as owners, partners, shareholders, and directors; and (4) individuals whose personal data from other companies in our group (such as where you have consented to your personal data being disclosed to other group companies for marketing purposes).

7.3 When we are a data Intermediary only

7.4 Terms used in this policy

When we refer to "you" and "your" in this privacy policy, we refer to you, any such individual whose personal information we collect, use and disclose from time to time.   When we refer to "processing" of your personal information, this includes obtaining, recording, storing or holding your personal information, and anything we do with it, such as organizing, adapting or altering it, retrieving, consulting or using it, disclosing it or otherwise making it available to others, combining it with other data, and blocking, erasing or destroying it.   When we refer to "travel services" this covers all products and services which may be booked with or through us, such as bespoke holidays, package holidays, accommodation, tours, transport and transfers (whether by air, coach, bus, train, ferry, taxi or other means), car hire, cruises, and charters, and it includes both (1) all such products and services which we supply or operate ourselves (including where we sub-contract); and (2) any such products and services provide by a third party which we book for you (acting as agent for you or that third party). Travel services also includes any services we or a third party provide in association with travel, such as obtaining visas, foreign exchange, and providing local representatives and support.

8. WHAT LAWS WE COMPLY WITH

We process your personal data in accordance with the following data protection law(s): The Singapore Personal Data Protection Act 2012.
Our regulator is Personal Data Protection Commission Singapore, www.pdpc.gov.sg
We also comply generally with the laws of Singapore in relation to the processing of your personal data, and not any other laws.

9. WHAT TYPES OF PERSONAL INFORMATION WE PROCESS

This section summarizes the types of personal data about you that we process:-

9.1 Data concerning you as an individual

This includes name, age, photograph, gender, address, telephone, mobile, fax, e-mail, social networking contact details, proofs of identity and address, copies of passports, driving licences, and utility bills, card and other payment details, and financial information, health information relevant to your planned travel, and travel insurances held, results of searches carried out against you (such as to verify you identity, address, and credit status), your preferences, frequent flyer or travel partner program affiliation and member number, and any other information provided to us by or in relation to you which concern you as an individual.

9.2 Business Related Information

If you are an individual associated with a business or other organisation that is our customer, then your personal data may include the following information that we link to you: business or organisation details (such as name, address, telephone numbers, payment arrangements, financial information, etc.), your relationship with that business or organisation (such as owner, partner, director, shareholder, employee, or agent), and your contact details within that business (such as work address, work telephone and mobile numbers, work fax number, and work e-mail address).

9.3 Enquiry and Booking Information

Information concerning enquiries and bookings made with or through us for travel services, including where you are making the enquiry or booking or are the recipient of the travel services to which the enquiry or booking relates. This information may include: records of enquiries and searches for holiday and travel products made by or on your behalf, details of your personal interests, needs and other data relevant to your enquiry; details of results, quotes, proposals, estimates and other information given in response to enquiries; details of the holiday, accommodation, travel, car hire, and other travel services booked or enquired about; details of the passengers / holidaymakers travelling; details of the provider of the travel services (e.g. tour operator); dates and times of travel; price; payment details (including card details); passport information and visa information; foreign exchange requirements and arrangements; and sensitive information such as health, medical, dietary, mobility, disability, religious or other special conditions or requirements.
Information generated concerning the performance of any booking or other contract made with or through us, including information relating to anything arising during any holiday or other travel services, and information relating to payments to be made.

9.5 Survey Information

Information collected or generated out of any surveys we conduct.

9.6 Competition Information

Information collected or generated out of any competitions or promotions we run.

9.7 Account, Registration and Loyalty Information

Information concerning any accounts, registrations, or memberships with us, or participation in any loyalty program.

9.8 Correspondence

Correspondence, communications and messages, including between you and us, and between us and third parties, including relating to any booking or booking enquiry, or performance of any contract.

9.9 Website Usage Information

We may collect information about your visits to, browsing of, and use of our website, unless your web browser blocks this. The range of data we collect will depend on how you interact with our website.
This information may include: your IP address (a unique identifier allocated to your computer for your connection to the internet); your computer device details (PC, tablet, smartphone, watch etc.); the make and version of web browser (e.g. Internet Explorer, Firefox, Safari, Opera, Chrome) you are using; your operating system (e.g. Windows, Windows Phone, OSX, iOS, Android, Linux etc); your time-zone; your browser plug-ins; any web-page you came from, identified as the referrer web page address by your web browser; cookies; page response times; download error; pages and parts of pages you visit; usage you make of our website, including enquiries and searches undertaken, and registrations for accounts, forums etc.; services and products you viewed; length of visit to website and pages; page interaction information (such as scrolling, keys pressed, mouse clicks, touches, and mouse-overs). This will normally be collected and used anonymously, and aggregated for analysis, with your name and any characteristics identifying you remaining anonymous, but our privacy policy will apply, and it will be treated as your personal data, if this information is in any way linked to you personally.

This information may also include: data inputted into forms and field; registrations for any accounts, forum, feedback mechanism, social functionality, newsletters or other features of our site; usernames and passwords, log-in / out history, and settings; actions taken within any account or other registration, including view and update and changes to settings; and posts to any forum, feedback, review or other social functionality on our website.

10. HOW WE COLLECT OR GENERATE YOUR PERSONAL INFORMATION

This section sets out the ways in which we may collect or generate personal information concerning you.

10.1 Visiting our website

By visiting and using our website you or your computer may provide personal data. This includes: information which is automatically provided by your browser to our servers; information record on our web servers about your interaction with our website and pages viewed; information we capture or place on your computer or generate using cookies or other technologies on our website; and information you input into forms and fields on our website.

10.2 Data you provide

Your personal data will include data you provide (or later amend), whether: from correspondence with you; verbally to us over the phone or in person; by filing in any field or form on a website; by filling in any printed form we provide you with; by e-mail; from documents you provide use with; and from updates to any information to provide from time to time. This includes when you: register or subscribe for any service, account, members, or loyalty program, or make an enquiry or booking for a holiday or other travel services whether in person, by phone, through our website or otherwise; send us your comments or suggestions; subscribe to any newsletter or other publication; and request sales and advertising information, including brochures.

User Generated Content (UGC)
We may process, Information or content provided by you in relation to your feedback or experience on a past, current or future trip with us. We will only use such content and images you have submitted to our social media channels or websites, if you have given consent to let [Brand Name] and TTC subsidiary companies to process this information in various initiatives. These could include any marketing activities such as: * Print materials
on our website
email activities
social posts
mages on our trips
provide images to our trade partners to use on their websites, email marketing and other marketing initiatives
make available in our content feeds
We would share imagery in our content feeds, image repositories, via email and share with our trade partners via these methods
Any other information provided to us by or in relation to you which concerns you as an individual.

10.3 Data obtained from third parties

We may obtain personal data concerning you from third parties, including from: providers of any holidays, accommodation, other travel services which are enquired about or booked, and their intermediaries; credit, fraud, identity and other searches we may undertake, including searches with public records and regulatory and private organisations; from any business or organisation you are associated with; from telephone numbers identified by the telephone system when you telephone us.

10.4 Data generated by us

We and any suppliers or sub-contractors working for us may generate personal data relating to you, including in connection with responding to and dealing with any enquiry, booking or complaint; or in performing any booking or other contract with you; or through the analysis of your personal data or data gained from your use of our website. We may record telephone calls with you.

11. WHAT DO WE USE YOUR PERSONAL INFORMATION FOR?

This section sets out the uses which we make of your personal data:

11.1 Operate our website

To operate and provide the search, booking, accounts, review, forums and other services, facilities and functions of our websites, including all community functionality. This includes managing any accounts or registrations you have with our websites, apps, community functionality and services, and making changes to your settings and profile at your request.

11.2 Provide information and respond to enquiries

To provide information to you about our websites, apps, systems and services, including to respond to booking enquiries and searches for holidays and travel, and to keep you updated generally.

11.3 Bookings and other contracts

To enable you to make bookings, and to fulfill, provide, perform, administer, manage, and enforce all bookings, orders, and other contracts which relate to you (including if you are a passenger in a booking made by someone else), and to process any transactions authorised or made with us which relate to you.

11.4 Payments

To collect and make payments due and administer our accounts.

11.5 Communication with customers
To collect and make payments due and administer our accounts.

11.6 Record keeping

To keep internal records and maintain reasonable archives, including concerning enquiries, bookings, contracts, travel services, and complaints. and including for the purposes of disputes, legal proceedings and investigations.

11.7 Manage and improve our business

To analyse, audit, provide, operate, administer, maintain and improve our business, website, systems, and services; to carry out surveys and analyse the results; to run promotions and competitions; undertake product or customer research/development; to assist us in and help us to improve our sales, editorial, advertising and marketing processes; to carry out other business development and improvement activities; and to provide training to our staff, sub-contractors and suppliers. For example, we may use your personal data to help us profile how our customers generally are using our websites and booking travel services with (or through) us. We may also use this information to ascertain interests so that we can better tailor our business offerings.

11.8 Direct marketing

To carry out direct marketing to you. See next section below for further information.

11.9 Advertising

To report aggregate information concerning usage of our websites to our advertisers. We normally create anonymous statistical data about browsing actions and patterns, and do not identify any individual.

11.10 Anything you have specifically consented to

11.11 Maintenance of our website and apps

11.12 Change of Purpose

12. USE OF YOUR PERSONAL DATA FOR DIRECT MARKETING

We do not use or disclose your personal information for direct marketing purposes unless we have obtained your express consent to this, such as through an opt-in or opt-out tick box on any form or website of ours.

12.1 Direct marketing by us

Where you have consented to this, we may use your personal information to carry out direct marketing and send you marketing messages, materials, adverts and promotions relating to travel services we provide or which can be booked with third parties through us.

Where you have consented to this, we may also use your personal data to carry out direct marketing and send you marketing messages, materials, adverts and promotions relating to travel services which are offered by or which can be booked through any other company in the same group of companies as us (i.e. within the Travel Corporation group) or third parties selected by us.
You will be free to withdraw your consent to this at any time, by contacting us as detailed in this privacy policy or as detailed in any direct marketing that you receive or by clicking the ‘unsubscribe’ button at the bottom of any of our emails. In any e-mail you send we would ask you to insert “unsubscribe” as the subject heading.

12.2 Direct marketing by third parties

Where you have expressly consented to this, we may disclose your personal information which is contact data (such as name, e-mail, postal address, telephone, mobile or fax number) to any other company in the same group of companies as us (e.g. within the Travel Corporation group), or to third parties selected by us. They will use this to carry out direct marketing in their own right and will use it to send you marketing materials, advertisements and promotions relating to products and services they offer or which can be booked through them. You will be free to withdraw your consent to our disclosure of your personal information for this purpose at any time, by contacting us as detailed above as well as by unsubscribing from their email directly by clicking the ‘unsubscribe’ button at the bottom of any of their emails. If you withdraw your consent, this will not affect any disclosures we have already made (i.e. we will not be able to remove your personal information from anyone we have disclosed it to), but we will tell you who they are on request, and you should contact them directly concerning this.

13. DISCLOSURE OF YOUR PERSONAL DATA

We disclose your personal data to third parties in the following circumstances:-

13.1 Credit Checks etc.

We may disclose your personal information to third parties (including intermediaries) as necessary to carry out any checks concerning you or enforce any booking or contract with you (including credit, security, fraud and identity checks). This may include credit reference agencies and other companies for use in credit decisions, for fraud prevention and to pursue debtors.

13.2 Bookings and performance of contracts

We disclose your personal information to third parties (including intermediaries) as necessary to deal with any booking enquiry being made by or for you, to make any booking requested by or for you, to perform and administer any booking for you or other contract with or in respect of you. This may include; to apply for visas on your behalf, to collect payments to be made by you, to investigate and respond to complaints, and to enforce any booking or other contract with you. Such third parties may include any suppliers or sub-contractors and their agents (e.g. airlines, coach, ferry or train companies, hoteliers, hire companies, cruise companies, tour operators etc.).

13.3 Suppliers of travel and other services

We may disclose your personal data to any third party (e.g. supplier, contractor sub-contractor) we make any enquiries with concerning or engage or sub-contract to perform any booking or other contract, including to provide any travel, tour or other products or services we have agreed to provide to you. We may disclose your personal data to any supplier with whom we make any enquiry concerning or book any travel or other products and services for you as agent (whether as agent for you, someone representing you, or the supplier), such as a tour operator. Details of any third party tour operators or other third parties who will be responsible for or supply you with the travel services booked or enquired about, may be obtained from us on request, and may be stated in any tour or other brochure provided by us.

13.4 Insurance

If any application is made through us for any travel or other insurance to cover you, we will pass your personal data on to the insurer. Information provided by you may be put on to a register of claims and shared with other insurers to prevent fraudulent claims.

13.5 Business Function Outsourcing

Where we use third parties to host, provide, operate or supply any part of our websites, databases, systems, business, or services, or carry out on our behalf any of our business functions or actions (including sending mail, processing payments, providing marketing assistance, providing customer and advertising analysis, and providing customer services), then then we may provide your personal data to them as required for use for or processing as part of those purposes.

13.6 Public Forums etc.

Where any facility on our website is clearly designed to make certain of your personal data public (e.g. posts you make to any public forum or reviews facility) then any personal data you provide in relation to that forum or other facility, which is provided in circumstance where it is clear that it is intended to be published, will be disclosed to the public accordingly, subject to moderation by us.

13.7 Legal Requirements

We may supply personal data to a government authority or regulator where required to comply with a legal requirement, for the administration of justice, for the purposes of customs, visas and immigration, or where reasonably required to protect your vital interests or enforce any booking or other contract. We may disclose your personal data where otherwise required by or permitted by law.

13.8 Direct Marketing by third parties

We may disclose your personal data to third parties to carry out direct marketing to you, where you have given your prior consent, to third parties to carry out direct marketing. See the direct marketing section above.

13.9 Customer Representatives

If our customer is a business or organisation, and we are holding your personal data in your capacity as an associate of that business or organisation (including as agent, representative, contact, employee, officer, owner, partner, or director), then we may disclose to them that personal data. If our customer is making a booking or booking enquiry on your behalf, with your authority, then we may disclose to our customer your personal data as reasonably required in connection with such booking or enquiry, or the subsequent performance of or payment for any booking made.

13.10 Business Acquirers

If our business is ever transferred to a third party, then your personal data will be transferred to the acquirer to enable them to continue our business.

14. HOW THIRD PARTIES WILL HANDLE YOUR PERSONAL DATA

Where we provide your personal information to a third party one of the following two circumstances will apply:-

14.1 Processing on our behalf

In some cases, your personal information may be held and otherwise collected and used by them on our behalf, in which case we will remain responsible for what they do with your personal information, and your personal information will only be held and collected and used by them in accordance with our instructions and this privacy policy.

14.2 Processing on their own account

In other cases, your personal information may need to be provided to them to be held and collected, used or disclosed by them in their own right and on their own account. In such case, they will have their own responsibility for that personal information, subject to their own privacy policy, and we will not be responsible for what they do with it following disclosure.

15. LOCATION OF YOUR PERSONAL INFORMATION

We (and any affiliate, subcontractor or other person collecting, using and disclosing your personal information on our behalf) may transfer, store and otherwise collect, use and disclose your personal information anywhere in the world.
In each case, we will comply with any legal requirements concerning the transfer of your personal information by us to any third party outside the country where we are established, and where your personal information is still controlled by us or is being stored or otherwise collected, used or disclosed on our behalf, our security measures (as detailed below) will also apply.

16. KEEPING YOUR DATA SECURE

16.1 Our security measures

16.1.1 Our general commitment

We are committed to doing what we reasonably can to keep your personal information secure, and we are obliged by law to put in place appropriate technical and organisational measures against unauthorised or unlawful collection, use and disclosure of your personal information and against accidental loss or destruction of, or damage to, your personal information. We have accordingly implemented security policies, rules and technical measures with a view to achieving this.

16.1.2 Transmissions between your web browser and our servers

We use Secured Socket Layer (“SSL”) software in order to encrypt the personal information that you provide to us whilst it is in transit over the internet. This will work if your browser is SSL enabled (which most are). You can verify that this is working by looking for the symbol of a closed lock or solid key on the bottom bar of your browser window, and checking that the prefix for the web address in the browser address bar has changed from “http” to “https”.

16.1.3 Storage of your personal data

The personal information we collect from you online is stored by us and/or our service providers on databases protected through a combination of physical and electronic access controls, firewall technology and other reasonable security measures.

16.2 Your security measures

For your own privacy protection, we encourage you to maintain anti-virus and other malware protection software on your computers and other devices, and to maintain your own measures to protect your personal information. Please do not include sensitive personal information in any e-mails you may send to us, including payment card information.
We also encourage you to be careful about who you give personal information to. We never contact you to ask you for sensitive personal information, such as payment card information, or sensitive personal information such as passport numbers or log-in details, and we will only ask you for such information in person or through our website, or by telephone in connection with a booking you are making or have made. Please let us know if you someone purports to contact you in our name.

17. HOW LONG DO WE KEEP YOUR PERSONAL DATA FOR?

We keep your personal information for so long as is reasonably necessary for the purposes for which we use it, and if longer, for any duration required by law, and for statutory claims limitation periods where your personal information may be relevant to any possible liability we may have to you.

18. YOUR RIGHTS

18.1 Access to your personal data

You may request us to tell you whether we are processing personal data about you, to tell you what personal data we are processing and for what purposes, and to provide you with a copy of your personal data that we hold. Once we have sufficient information from you to deal with the request, we will seek to provide you with the relevant personal data within 30 calendar days. Where we are unable to respond to you within the said 30 calendar days, we will notify you of the soonest possible time within which we can provide you with the information requested. Note that there are certain types of personal data which are exempt under the applicable data protection laws from being subject to your access request.
We will also be charging you a reasonable fee for the handling and processing of your requests to access your personal data. We will provide you with a written estimate of the fee, Please note that we are not required to respond to or deal with your access request unless you have agreed to pay the fee. If we refuse to provide you with access to information we hold about you, we will provide reasons for such refusal and inform you of any exceptions relied upon under the Privacy Act, 1988.

18.2 Use causing substantial distress or damage

You have the right to ask us to stop using your personal information for any purpose in any manner that is causing you or is likely to cause you unwarranted and substantial damage or distress, subject to exceptions.

18.3 Use for direct marketing

You have the right to ask us to stop using your personal data to carry out direct marketing to you.

18.4 Correction of inaccuracies

For a request to correct personal data, once we have sufficient information from you to deal with the request, we will:
Correct your personal data within 30 calendar days. Where we are unable to do so within the said 30 calendar days, we will notify you of the soonest practicable time within which we can make the correction. Note that there are certain types of personal data which are exempt under the applicable data protection laws from being subject to your access request; and
We will send the corrected personal data to every other organisation to which the personal data was disclosed, within a year before the date the correction was made, unless that other organisation does not need the corrected personal data for any legal or business purpose.
We may, if you so consent send the corrected personal data only to specific organisations to which the personal data was disclosed by us within a year before the date the correction was made.

18.5 Request to withdraw consent

You may withdraw your consent for the collection, use and/or disclosure of your personal data in our possession or under our control at any time by submitting your request to the contact details provided in this policy.

We will process your request within a reasonable time from such a request for withdrawal of consent being made, and will thereafter refrain from collecting, using and/or disclosing your personal data in the manner stated in your request.

However, your withdrawal of consent could result in certain legal consequences arising from such withdrawal. In this regard, depending on the extent of your withdrawal of consent for us to process your personal data, it may mean that we will not be able to continue with your existing relationship with us.

18.6 Compensation

You have the right to claim compensation for damage and (in certain cases) distress you suffer if we do not comply with the laws referred to above.

18.7 Complaints to applicable authority

the laws we comply with are regulated by Personal Data Protection Commission (www.pdpc.gov.sg) in Singapore. In addition to your rights above, it is open to you, if you have a complaint or concern, to seek assistance from such government regulator, who has powers to compel us to comply with applicable laws and fine us for non-compliance. However, before you do so, we would hope that you will contact us first to discuss any complaint or concerns you have.
If you have any complaint or grievance regarding about how we are handling your personal data or about how we are complying with our Data Protection Policy, we welcome you to contact us with your complaint or grievance.

Please contact us through one of the following methods with your complaint or grievance:

E-mail: emarketing@rchmail.com
Office address: Our incorporation address/registered office is 35 Charles Street, London, W1J 5EBV

Where it is an email or a letter through which you are submitting a complaint, your indication at the subject header that it is a personal data protection complaint would assist us in attending to your complaint speedily by passing it on to the relevant staff in RCH to handle. For example, you could insert the subject header as “Personal Data Complaint”.

We will certainly strive to deal with any complaint or grievance that you may have speedily and fairly.

19. CHANGES TO THIS PRIVACY POLICY

We may change this privacy policy at any time and from time to time without notice to you, including by publishing a new version on our website. You should check this privacy policy for updates each time you visit our website to be sure that you are aware of any changes. You should check the top of the document to see the latest version in force. Any change will be prospective only, and we will not make any changes that have retroactive effect unless legally required to do so.