Introduction and purpose of this privacy and cookie policy

• The Cairn Hotel Group (Company registration number 03888360) (CN: The Group) (collectively referred to as “we“, “us” or “our” in this privacy and cookie policy) are committed to safeguarding the privacy of our website visitors.
• In this privacy and cookie policy we explain how we will collect and process your personal information through your use of this website (including any data you may provide when you purchase a product or service, or otherwise provide any data to us).
• We will ask you to consent to our use of cookies in accordance with the terms of this privacy and cookie policy when you first visit our website.
• It is important that you read this privacy and cookie policy, together with any other privacy policy or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you, so that you are fully aware of how and why we are using your data. This privacy and cookie policy supplements the other notices and is not intended to override them.
• This website is not intended for children and we do not knowingly collect data relating to children.

Controller and third party links

• We are the controller and processor responsible for your personal data.
• We have appointed a Data Protection Officer who is responsible for overseeing questions in relation to this privacy and cookie policy. If you have any questions about this privacy policy (including any requests to exercise your legal rights) please contact our Data Protection Officer, Richard Mark Warren by either: post to Zonebright Limited, 31-32 West Parade, Newcastle upon Tyne NE4 7LB; or email at gdpr@cairnhotelgroup.com
• You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.
• This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

Collecting personal data

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, last name, title, date of birth.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Financial Data includes bank sort code, account and payment card details.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
• Technical Data includes internet protocol (IP) address, your login data, 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.
• Profile Data includes purchases or orders made by you, your interests, preferences, and feedback and survey responses.
• Usage Data includes information about how you use our website, products and services, including traffic data.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We do not collect any Special Categories of Personal Data about you (this includes details 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). Nor do we collect any information about criminal convictions and offences.

Where we need to collect personal data by law, or under the terms of a contract (including booking, enquiry or purchase) we have with you and you fail to provide that data when requested, we may not be able to perform the contract (including booking, enquiry or purchase) 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 a product or service you have with us but we will notify you if this is the case at the time.

Personal data collection methods

We use different methods to collect data from and about you including through: Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email, on our website(s) or otherwise. This includes personal data you provide if you:

• Enquire about our products or services;
• create an account on our website;
• subscribe to our service or publications;
• request marketing to be sent to you;
• give us your business card;
• enter a competition, promotion or survey; or
• give us some feedback.

Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy at paragraphs 13 – 16 for further details.

Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:

• Technical Data from the following parties:
• analytics providers such as Google based outside the EU;
• Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside the EU];

Using personal data We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.

Using Personal Data

You will receive marketing communications from us if you have requested information from us, enquired on our website, purchased goods or services from us or if you provided us with your details when you registered for a promotion and, in each case, you have not opted out of receiving that marketing;

• Prospective clients – if you are not our existing customer or representing a corporate business and you have given us your business card because you are happy to hear from us, we may use your Identity and Contact Data to form a view on what we think you may want or need, or what may be of interest to you.
• Third-party marketing – we will get your express opt-in consent before we share your personal data with any other company for marketing purposes;
• Opting out – you can ask us or third parties to stop sending you marketing messages at any time by ‘Unsubscribing’ at any time. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience or other transactions.
• We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please email gdpr@cairnhotelgroup.com.
• If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
• Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Disclosing personal data

• We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 5 above:
• Service providers acting as processors in the United Kingdom, the EEA and the USA who provide database and other IT and system administration services.
• Marketing services providers based in the EEA and the USA who provide direct marketing services to us.
• Payment services providers based in the EEA and the USA who provide payment services to us.
• Specific third parties such as Hilton, IHG, Accor, Marriot and Best Western with whom we may need to share your personal data in order to provide certain requested products or services to you.
• Businesses who referred your business to us.
• Professional advisers acting as processors including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances.
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy and cookie policy.
• We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

Security of personal data

• We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
• We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
• You acknowledge that the transmission of information over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
• You are responsible for keeping the password you use for accessing our website confidential; we will not ask you for your password (except when you log in to our website).

Retaining personal information

• We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
• To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
• In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

About cookies

• Our website uses cookies to distinguish you from other users of our website. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. By continuing to browse the site, you are agreeing to our use of cookies.
• Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
• Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
• Cookies can be used by web servers to identify and track users as they navigate different pages on a website and identify users returning to a website.
• Our cookies: We use both session and persistent cookies on our website. You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.
• We use the following cookies:
• Strictly necessary cookies – these are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing service;
• Analytics/performance cookies – they allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily;
• Functionality cookies – these are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region);
• Targeting cookies – these cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
• Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.
• Analytics cookies: We use Google Analytics to analyse the use of our website. Our analytics service provider generates statistical and other information about website use by means of cookies. The analytics cookies used by our website have the following names: _ga, _gat, utma, utmt, utmb, utmc, utmz and utmv. The information generated relating to our website is used to create reports about the use of our website. Our analytics service provider’s privacy policy is available at: Google’s Privacy & Terms site.
• Third party cookies: Our website also uses third party cookies. A common example is an embedded YouTube video.

Amendments

• We may update this policy from time to time by publishing a new version on our website.
• This version was last updated in 2018.
• The data protection law in the UK will change on 25 May 2018. Although this privacy and cookie policy sets out most of your rights under the new laws, we may not yet be able to respond to some of your requests (for example, a request for the transfer of your personal data) until May 2018, as we are still working towards getting our systems ready for some of these changes.
• You should check this page occasionally to ensure you are happy with any changes to this policy.
• We may notify you of changes to this policy by email or through the private messaging system on our website.