THE LEWIS PARTNERSHIP
In summary: -
· We will take reasonable steps to protect the security of the Personal Information we collect from you.
· We will not disclose your Personal Information to third parties except as described in this policy.
· We will allow you to view, correct or remove your Personal Information and other information that we have collected.
· We will not keep your personal data on file for any longer than is legally required or a term you agree to.
· We will not send you details of our exclusive offers, events, and news unless you "opt in" to our mailing list.
Who is the Data controller?
Chris Lewis, The Moat House, Lower Penkridge Road, Acton Trussell, Staffordshire, ST17 0RJ, firstname.lastname@example.org
The Lewis Partnership takes the privacy of customers and their information very seriously. This policy explains how we use any personal information we collect about you, your rights to access and correct the personal information we hold about you.
For the purpose of this document, “THE Lewis Partnership” will refer to LP and "you" the user of the LP website and services and facilities, that is 16 years old or older and capable of entering a contract.
1.0. What personal information does LP collect about you?
LP collect personal data from you when you make an enquiry, a reservation, purchase a gift voucher, either in person or over the phone, and also when you make a reservation online.
LP also collect data from you when you subscribe to LP marketing communications, connect using LP social media websites, enter LP competitions or provide feedback. These may be carried out online, by telephone or in person.
Without limitation, any of the following personal data may be collected: -
· Your full name
· Contact information such as email address, landline and/or mobile telephone numbers
· Home address and postcode
· Your credit or debit card details if you are making a payment
· Preferences and interests
· The month of your birthday
· Your special dietary requirements and allergies
· Passport details (only for guests who reside outside of the commonwealth)
· Your IP address
· Your web browser type and version
· Your operating system
· A list of URLS starting with your referring site, activity on our website, and the website you exit to
· Your cookie information
· Data from our EPOS system relating to your purchasing history and visits
If you provide LP with any personal Data relating to any third party (e.g. information about your spouse, companion, employees or colleagues) for particular purposes, by submitting such information, you do so at your own risk having obtained the consent of such third party to provide LP with their personal Data for the respective purposes.
We never knowingly collect data from anyone under the age of 16.
2.0 What do LP use your Data for?
LP use the information collected about you to:
- Reply to your questions and enquiries
- Respond to your feedback
- Process your bookings, reservations, and purchases (see 2.1.)
- Keep you updated on latest news, offers and events at LP properties (see 2.2)
- Monitor the LP website and email performance using Cookies (see 2.3)
2.1. Bookings, reservations, and purchases
LP operate a centralised reservation system. This means that any personal Data you have shared for booking purposes is available in that system and can be accessed at any LP property or central office.
Any or all of the aforementioned Data may be required by LP from time to time in order to provide you with the best possible service and experience. Specifically, Data may be used for the following reasons:
- Internal record keeping
- Providing you with confirmation of the services LP have provided to you and follow-up on your stay
- Connecting you with third-party agents that offer services you may require (including but not limited to making a table reservation during your stay)
- Connecting you with a third-party payment collection company for processing payments - To pass on to the police and government authorities as requested by them, for example in cases of fraud and theft
- To comply with any applicable rules, laws, regulations, codes of practice or guidelines issued by any legal or regulatory body which are binding on LP
- To notify you of any security or data breach alerts
LP will only contact you via marketing channels (email, phone or post) with news and offers relating to LP as a group, or individual properties, if you have given your consent by "opting in" to marketing communications. Consent can be given by, but not limited to, signing up to the newsletter on the website, ticking the box to give your permission whilst making a booking, purchase, enquiry, or checking in to the hotel/s. LP marketing communications are generally sent by email and include news, offers and events.
You can stop marketing communications at any time by clicking the "UNSUBSCRIBE" link at the bottom of each marketing email. Alternatively, you can email email@example.com to request manual deletion from the mailing list, typing “UNSUBSCRIBE” in the subject line.
Please note that as a result of operational requirements, LP may still be required to contact you from time to time regarding any past, present or future bookings that you have made (see 2.1. for details).
2.2.1 Social Media
Please note that by connecting with LP via social media websites you are bound by their own Terms and Conditions and Privacy Policies.
2.2.2 Google Adwords
You can set preferences for how Google advertises to you using the Google Ad Preferences page, and if you want to you can opt out of interest-based advertising entirely by cookie settings or permanently using a browser plugin.
LP may set and access cookies on your ‘computer’ (meaning any computer, laptop, tablet, mobile, or other device that the website can be viewed on.)
A ‘cookie’ is a small file of letters and numbers which asks permissions from your browser to be placed on your Computer’s hard drive. Cookies allow web applications to respond to you as an individual and allow us to distinguish you from other users on the website. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences and allows LP to continually improve the website.
Cookies do not take up much space (unless you have thousands of them) and cannot contain viruses or other harmful code.
- Google Analytics Cookies to identify which pages are being used. This helps us analyse data about web page traffic (the number of visitors and how visitors move around the LP Website when they are using it) and improve the Website in order to tailor it to your needs.
- Third party Cookies within LP email campaigns, predominantly sent using third party email marketing tools, as well as Google Analytics. Cookies are used to monitor open rates and improve your experience and also for the tracking of website activity initiated from hyperlinks within email marketing campaigns.
- Session Cookies. These are temporary Cookies on our website which only exist in the period you access the it (or more specifically, until you close the browser after accessing the Website). Session Cookies help the Website remember what you chose on the previous page, therefore avoiding having to re-enter information.
The length of time a Cookie will remain on your Computer will depend on the type of Cookie. On the LP Website, these Cookies do not contain personal information, and cannot be used to identify you. To find out more about how to manage cookies through your chosen browser go to: www.allaboutcookies.org/managecookies/
You may delete/disable your Cookies or manage your Cookies preferences but if you do decide to disable or delete the Cookies altogether please note that the LP Website may not work as well as it could.
You can choose to enable or disable Cookies in your web browser. By default, your browser will accept Cookies; however, this can be altered. For further details please consult the help menu in your browser on your Computer and search for “cookies”.
3.0 How do LP look after your Personal Data?
To ensure that your data is treated with the highest regard and compliant with legal requirements, it is LP company policy to:
- Ensure all relevant employees have received training in how to correctly handle Data. Training includes educating employees in the importance of the safe and secure handling of Data, and the procedures in place to ensure all Data is handled in this way.
- Anonymise all data collected for third-party clients save for payment details where LP use third party payment collecting company; Secure Trading Ltd.
- Evaluate the LP database every 36 months and securely delete any contacts that are either no longer engaged or no longer required to meet with the reasoning outlined in 2.1.
- Always adhere to the internal procedures and measures in place to keep any personal Data held safe and secure.
4.0 How do LP store your personal information?
To ensure your data is stored safe and legally LP use the following trusted third-party agents:
Property Management System (PMS) LP properties use the ‘Guestline’ third-party PMS to store all bedroom reservation history.
Internet Booking Engine LP properties use the ‘RezLynx’ third-party online Booking Engine (OBE) to take hotel reservations on the website (www.moathouse.co.uk).
Details of Guestline's policies can be found at https://www.guestline.com/about-us/aboutguestline/gdpr.html
Content Management System (CMS) LP use the Clockwork Marketing’s CMS to manage our website.
LP properties use the ‘Gift Voucher Brilliance’ third-party system to facilitate all gift voucher purchases. https://www.giftvoucherbrilliance.co.uk/privacy-policy The secure payment system used when purchasing a voucher is via Stripe https://stripe.com/gb/privacy
Guest Loyalty App
LP properties use a loyalty app provided by COMO.com http://app4mobilebiz.wpengine.com/como-uk-website-privacy-policy.html
Email Marketing Application
LP use the ‘Mail Chimp’ application for all email marketing activity.
Online Payments and Credit Card storage
LP use a centralised cloud-based function and events diary ass part of our hotel PMS
In addition to the Data collected via the website, there are some occasions where LP must collect data in person. This information is filed securely using a Microsoft cloud account with restricted access to passwords.
5.0 Data Sharing
LP will never sell your data to a third party for marketing purposes. Your data will be shared within the LP group on our password protected, centralised Property Management System (see 4.0). If required or deemed necessary, LP may on occasions share your data with other organisations in the following way/s:
5.1. To facilitate services and offers
Where contracted and trusted third parties are used to facilitate services and offers, LP will share your Data with those parties for that purpose, and that purpose only. This includes the processing and delivery of marketing communications, and any other third-party services engaged to perform payment, business support, operational or administrative function. Third parties are subject to confidentiality obligations. (See 4.0)
5.2 The sale of a property
LP may on occasion expand or reduce the collection of properties, and this may involve the sale of a property. Where the original remit for the Data remains the same and is relevant, Data provided by you will be transferred to the new owner or controlling party. Should this situation arise, your data will only be shared if the new owner or controlling party strictly adhere to this policy for the permitted use of the Data and the purposes for which it was supplied by you.
5.3. Legal requirement
LP may also disclose personal Data as permitted or required by law. For instance, if asked by the police, your personal Data may be shared with them for the purposes of prevention and detection of crime.
6.0 Transaction and Data Security LP are committed to protecting the confidentiality and security of the information that you provide to. To do this, technical, physical and organizational security measures are put in place to protect against any unauthorized access, disclosure, damage or loss of your information. The collection, transmission and storage of information can never be guaranteed to be completely secure, however, we take steps to ensure that appropriate security safeguards are in place to protect your information.
7.0 Accessing and amending your Data You have a right to access a copy of the Data LP hold about you. If you would like to do this, please write to LP at the address at the bottom of this document and enclose a stamped self-addressed envelope. The following details are also required in order to verify your identity before LP can release the data:
- Full name
- Email address
- Telephone number
- Details of your previous or forthcoming stay/ reservation with LP
Upon receipt of your written request and all the details above, LP will provide the Data within thirty (30) days. LP want to make sure that your personal Data is kept accurate and up-to-date so you may need to modify or update your Data if your circumstances change. Additional Data as to your marketing preferences may also be stored and changed. You are able to make amendments via a link in any email we send or by contacting LP via email at firstname.lastname@example.org with “UPDATE” in the subject line.
8.0 Retention of your Data
Your personal Data will be retained for as long as it is necessary to fulfil the purpose for which it is collected, for business or legal purposes, or in accordance with applicable laws.
Should you choose to unsubscribe from the LP marketing list (see 2.2) please note that your personal Data may still be retained on the LP database for a minimum of 12 months or to the extent permitted by law.
As part of LP Google Analytics tracking, user-level data and event-level data associated with cookies, user identifiers (e.g., User-ID) and advertising identifiers are collected for the purpose of monitoring the performance of the LP website. This data is retained within Google Analytics for 38 months before being automatically deleted.
9.0. Deleting your Data
You have a right to withdraw your consent of use. If you wish for your entire data records to be deleted, please email: email@example.com s.co.uk with “DELETION” in the subject line.
LP can only delete your data in accordance with applicable laws and once any contractual obligations have concluded, including payment for previous contractual obligations.
If you wish to withdraw your consent to any or all use of your personal Data, depending upon the nature of your request, LP may not be able to provide or continue providing our products and services to you, or administer any contractual relationship already in place.
You understand and agree that in such instances where LP require your personal Data to fulfil a contractual obligation to you and you withdraw your consent to collect, use or disclose the relevant personal Data for those purposes, LP cannot be held liable for breach of that agreement. LP legal rights and remedies in such event are expressly reserved.
LP have CCTV installed at all properties in public areas and particularly around entrances and exits. This is for the purposes of prevention and detection of crime and monitoring of staff. The images captured on the CCTV system are overwritten on a rolling 30-day basis. Only senior appointed staff within the organisation have access to replay the CCTV footage. LP may disclose CCTV footage as permitted or required by law. For example, footage may be shared with the Police if requested for the purposes of prevention and detection of crime.
If you choose to use the complimentary guest WiFi at LP properties you will require to log-on to the service. This service is provided to LP by Cisco Meraki Splash Access https://www.splashaccess.com/privacy-policy
Phishing is the practice of tricking someone into giving confidential information. Examples include falsely claiming to be a legitimate company when sending an e-mail to a user in an attempt to get the user to send private information that will be used for criminal activities such as identity theft and fraud.
LP will never ask you to confirm any account or credit card details via email. If you receive an email claiming to be from LP asking you to do so, please ignore it and do not respond. If you are unsure whether an email from LP is legitimate, please forward it to firstname.lastname@example.org with your message and the subject line “FRAUD”. LP will then reply to advise you on the situation.
LP will on occasion take bookings over the phone. On these occasions, LP employees will state their name and the company name. If you are anxious about the phone call, revealing your payment details or do not believe that the person on the other end of the phone is an employee of LP, please put the phone down and ring the hotel or office directly asking for the person you spoke to. Telephone numbers are available on the LP website.
13.0 Links to other websites
Address: The Moat House, Lower Penkridge Road, Acton Trussell, Staford, ST17 0RJ
Phone: 01785 712217