EH management limited TA “ The Hadley Hotel” . its subsidiaries and holding companies (“EH”) is a hotel operator, owner, and operator of hotel accommodations and a range of associated amenities (including bar, restaurant, pub, salon, offices  and thus we understand and respect our customers, guests and users’ privacy.

 

This Privacy Notice (“Notice”) describes how we collect, use, store, share and protect personal information collected from or about visitors to our online sites, mobile applications, and facilities or properties located in the United Kingdom.

1. Practices Covered by this Notice

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This Notice describes our privacy practices in relation to the personal information we collect:

• Through our websites "www.thehadleyhotel.com”” and any other websites owned or operated by EH management and its affiliates (collectively the “Site” or “Sites”).

• When you visit and stay as a guest at The Hadley Hotel or our on-property services such as restaurants, entertainment, bar, spas, salons, , concierge and customer services.

• Through our mobile applications, such as “www.thehadleyhotel.com”

• Through our social media pages that we control.

• Through HTML-formatted email messages that we send to you.

Together we refer to these services as “The Hadley Hotel.” The Notice does not apply to the following The Hadley Hotel entities or services, which are governed by separate Privacy Notices:

• The Hadley Hotel Jobs – Including any employment and job applicant personal information collected

• The Hadley Hotel Gift Cards

• Hotel Wi-Fi Services

• Sweepstakes and other on-property Promotions – We will use personal information to allow you to participate in these activities. Some of these activities have additional rules and privacy terms attached to them. Please refer to each activity’s terms and conditions for more information.

Although this Notice broadly describes The Hadley Hotel’s general privacy practices, some jurisdictions may place restrictions on our personal information processing activities. Due to variances in local laws, our practices in such jurisdictions may be more restrictive than those described in this Notice, which enables us to comply with local requirements. Customers from California are directed to Appendix A which sets out additional information about information practices pursuant to the California Consumer Privacy Act (“CCPA”). Please note that if you are based in the European Economic Area (EEA) or UK, the additional information set out in Appendix B applies.

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Please read this Notice carefully to understand how we collect, use and process your personal information. By visiting, accessing, or using, or providing information to us in connection with, the The Hadley Hotel, you understand and acknowledge our collection, storage, use and sharing of your information as described in this Privacy Notice. Please note that if you disagree with anything in this Privacy Policy, you should not visit, access, or use, or provide information to us in connection with, the The Hadley Hotel. You can contact us with questions about our information practices or policies at info@thehadleyhotel.com.

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2. What (and How) Information is Collected from or About You

We collect information from or about you at many, diverse points of interaction with The Hadley Hotel, such as when you make inquiries, book accommodations or other services, purchase tickets, sign up for The Hadley Hotel membership, and visit our hotel. We maintain integrated profiles of our customers, in keeping with the highest industry standards for an exceptional customer service experience at our luxury hotel, restaurant, spa and other properties.

Information You Provide to Us

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• Bookings, visits, and other interactions with The Hadley Hotel .  We collect personal information about you when you make an online or offline (e.g. via phone) booking for our hotels or entertainment venues, and in the course of any stay or visit to our facilities, such as when your ID is scanned upon check-in at a The Hadley Hotel property, or reserve spa, restaurant, or entertainment activities and services. This information may include your name, email and/or physical address, legal identification such as driver’s license or passport, vehicle information, date of birth, phone number, other guest names, business contact information (where relevant) and payment information. We may also use closed circuit television and other security measures at our properties that may capture or record images of guests and visitors in public areas, as well as information related to your location while on our properties (via keycards and other technologies). We may also use closed-circuit television and other technologies that record sound or video for the protection of our personnel, guests and visitors to our properties where permitted by law.

• The Hadley Hotel website form submission – We collect contact information through online forms when you sign up to join our loyalty programs such as your name and email address. We will ask you to create a password to manage your account.

• Marketing – We collect name and contact information directly for marketing purposes, for example when you sign up for promotional messages online, at one of our properties, or via one of our The Hadley Hotel mobile applications.

• The Hadley Hotel Concierge and Customer Service – We collect personal information from you such as your name and contact information when you:

o Contact us for any reason and/or request or receive services or information;

o Submit a guest claim, report any problems, contact lost and found, and/or are in dispute with us;

o Contact us through our call centre; and

o Contact us through social media channels.

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Please note that telephone calls to our concierge, customer service and call centre are recorded and actively monitored for the purposes of compliance, security and customer service.

• Travel – We collect personal information about you when you use our travel services such as your name, contact details, passport information, travel dates and other passenger details. This information may be shared with our affiliates and travel partners for purposes of providing our travel services only.

• Surveys – We collect personal information when you complete surveys about your stay at our hotels if you provided us with your email address. Information we collect through surveys include your name, email address, hotel stay location, quality of stay experience and amenities used during your stay.

• Social Media – When you interact with us through social media (including Facebook, Instagram, Twitter, WhatsApp, and Snapchat) we collect personal information, such as your social media profile information and online behaviour through this interaction consistent with your settings within the social media service. If you have provided us with your telephone number or email address, we may use this information to send targeted advertisements to you on these social media properties.

• The Hadley Hotel Mobile Applications – If you download or use one of the The Hadley Hotel mobile applications, we may collect and use information regarding your mobile device, including (if you activate / allow this functionality) your location. The privacy practices related to the Apps are available through the respective Apps.

Information We Collect Automatically

When you visit our Sites, we automatically collect the following information:

• Technical information, including your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;

• IP address, this is identified and logged automatically in our server log files when you access our Sites. We use IP addresses to calculate usage levels, diagnose server problems and administer our Sites. We also may derive your approximate location from your IP address; and

• Website visit information, including the full Uniform Resource Locators (“URL”) clickstream to, through and from the Sites (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.

Information Received from Third Parties

We also collect information about you (as relevant and appropriate to the The Hadley Hotel Service you have requested) from third parties, including:

• Online travel agencies and other third party hotel booking partners;

• Consumer reporting agencies, in connection with a credit application or financial account with The Hadley Hotel, as further disclosed and described to you at the time of your application;

• Social media channels, such as Facebook or Instagram, consistent with your settings on such services;

• Marketing and analytics providers; and

• Third party analytics services and content from third party businesses, including as described in our Cookie Notice.

This information includes contact information such as your name, email address and phone number. It also includes, where applicable, your travel details, such as booking confirmation numbers, number of rooms, arrival and departure dates, payment information, online browsing and usage behaviour and social media profile information. We will also obtain email addresses and limited demographic information for our US customer accounts where we do not hold a current email address or demographic information for such customer and append this to the customer account.

 

3. How We Use Your Personal Information

The Hadley Hotel uses your information for various purposes, including:

• To send you personalized messages, publications, news, and information about events, special offers, promotions and benefits, as well as measure and understand the effectiveness of the content we serve to you and others.

• As described in our Cookie Notice.

• To improve The Hadley Hotel and the content of the Sites to enhance users' experiences when visiting the Sites or using The Hadley Hotel and to customize the content and layout of the Sites to each individual user.

• To administer the Sites, keep the Sites safe and secure, monitor and analyse our Sites usage and activity trends, to operate and improve our Sites, and for internal operations, to conduct troubleshooting and data analysis, including testing, research, statistical and survey analysis.

• To enforce our Sites’ terms and conditions.

• To facilitate the processing of online reservations such as facilitating payment, sending of confirmation or pre-arrival messages including information about the resort you are visiting and the amenities available to you, sending administrative messages about events or meetings you have reserved and provide you with related customer service, such as sending your receipt by email.

• To respond to your queries, and to communicate with you about your reservations, requests or transactions.

• For analytics purposes, to optimize your experience at The Hadley Hotel, enhance our marketing, create customer or audience segments, enhance our business and operational efficiency and tailor promotions and offers to your preferences and habits when interacting with us.

• To offer, manage and administer The Hadley Hotel Insider loyalty program, assess your benefits, administer offers and manage your choices regarding how you wish to use your offers.

• To maintain the accuracy of your account or profile information and to provide you with a better and more personalized service, including by pairing information collected under this privacy notice with your Red Card profile, if you have enrolled in that program. For further information about our privacy practices relating to The Hadley Hotel Red Card, please see here.

• To facilitate our hotel operations, including guest account management, hotel room reservations and requests.

• To organize events or meetings in connection with your use of our meeting and convention space and processing payments.

• To facilitate the provision of airline services to you, if these services have been made available to you, upon your request.

• To carry out appropriate compliance, security and/or financial checks, such as when we need to:

o Confirm your identity;

o Make a payment to you or receive payment from you; and

o Comply with law enforcement, court, and regulatory obligations.

 

4. Marketing Preferences

 

• You may withdraw your consent for direct marketing communications at any time by contacting us at info@thehadleyhotel.com, or by following the unsubscribe instructions in the marketing message.

• When you receive a commercial (promotional) electronic communication, we provide the choice to opt-out of receiving future messages by following the instructions provided in the message.

• You may choose whether to provide your phone number to receive text messages or advertising phone calls from us or our call centre agents using an automatic telephone dialling system or an artificial or pre-recorded voice. By providing your phone number and express consent, you are choosing to receive such messages until you withdraw your consent.

Your consent to receive text messages or pre-recorded calls using an automatic telephone dialling system is not required to make a purchase with The Hadley Hotel. You may revoke your consent at any time by contacting us at info@thehadleyhotel.com.

 

5. How We Share Your Information

 

We share your personal information only with selected recipients which include the following:

• EH Management - We share personal information with any corporate affiliate of the The Hadley Hotel for the purposes described in this Notice such as providing the The Hadley Hotel (e.g. when you book travel with us, we will share your personal information with our affiliated companies, ).

• Marketing Partners - We share aggregated or de-identified information with our marketing partners to provide certain services, offers and enhance your experience at The Hadley Hotel. This information cannot reasonably be used to identify you.

• Service Providers - We disclose your personal information to vendors, consultants and other service providers such as credit or background check companies, payment processors, marketing companies, email service providers, advertising networks and advertisers, information technology services and those who need access to such information to provide services on our behalf. These companies are prohibited from retaining, using, or disclosing your personal information except as necessary to provide the services on our behalf.

• Analytics and Search Engine Providers - We share personal information with these providers to assist us in the improvement and optimization of our guest records, Sites and The Hadley Hotel. For more information please see our Cookie Notice.

• Compliance and regulatory purposes - We share your personal information with law enforcement agencies, public authorities or other third parties if legally required to do so, or if we have a good faith belief that such use is reasonably necessary to:

o Comply with a legal obligation, process or request, such as a subpoena, court order, search warrant or other valid legal process, or to comply with legal, administrative, or administrative requirements of any governmental authorities, including gaming regulators, tax authorities, and law enforcement authorities;

o Enforce our terms and conditions and other agreements, including investigation of any potential violation thereof;

o Detect, prevent or otherwise address security, fraud or technical issues; or

o protect the rights, property or safety of the The Hadley Hotel Group, or any of its corporate affiliates or workforce members, our users and guests, a third party or the public as required or permitted by law (including without limitation, exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction such as requesting and sharing your information with credit bureaus), which may be exercised in our sole discretion.

• Sale or Merger - We will also disclose your information to third parties in connection with business transfers or bankruptcy proceedings, as permitted by law:

o In the event we sell any business or assets, in which case we will disclose your data to the buyer of such business or assets; or

o If The Hadley Hotel or substantially all The Hadley Hotel assets are acquired by a third party, in which case information held by us about our users will be one of the transferred assets.

o Other than to the extent ordered by a court of competent jurisdiction, the use and disclosure of all transferred user information will be subject to this Notice. However, any information you submit or that is collected after this type of transfer may be subject to a new privacy notice adopted by the successor entity.

 

6. Cookies and Tracking Technologies

 

We use cookies, tags and other similar technologies to collect information about your browsing activities over time and across different websites or online services following your use of The Hadley Hotel or Sites, including our mobile applications. We use the information we collect to enhance your visit to our various Sites and to provide you with information tailored to your needs. For more information about how we use cookies and to learn how to manage cookies and other tracking technologies related to interest-based advertising, please see our Cookie Notice.

 

7. How We Protect Your Information

 

We take appropriate technical and organizational measures to safeguard your personal information against loss, theft and unauthorized use, access or modification. We maintain information security policies, routinely test our security controls through internal and external audits, and maintain compliance. We also require third party service providers acting on our behalf or with whom we share your information to provide security measures in accordance with industry standards.

 

Although we do our best to protect your personal information, we cannot guarantee the security of the information stored or handled by The Hadley Hotel or its authorized service providers. The transmission of information via the internet or email is not completely secure and any transmission is at your own risk.

 

For your own online security, please do not send payment card numbers or any other confidential personal information to us via email.

 

8. Minimum Age Requirements

 

We do not knowingly or intentionally collect any personally identifiable information from, or market to, individuals under the age of 13.  Our online services are not intended for persons under the age of 13. Persons under the age of 13 are not allowed to use our online services in any fashion, so the provisions of the Children’s Online Privacy Protection Act do not apply to The Hadley Hotel online services. If you learn that a child under the age of 13 has provided us with personal information contrary to these rules, please contact us at the address listed in the “Contact Us” section below.

 

9. Use of Third-Party Internet Sites

 

Certain third party services, websites, or applications you use, or navigate to and from our Sites may have separate user terms and privacy policies that are independent of this Notice. This includes, for example, websites owned and operated by our customers or partners. We are not responsible for the privacy practices of these third party services or applications. We recommend carefully reviewing the user terms and privacy statement of each third party service, website, and/or application prior to use.

 

10. Changes to this Notice

 

We may change this Privacy Notice from time to time to reflect updates to the information that we collect from you, how we use that information and how we share that information with third parties. You can determine when this Privacy Notice was last revised by referring to the “Effective Date” at the bottom of this Notice. In some cases, we may provide you with additional notice of our privacy practices (such as adding a statement to the homepages of our Site or sending you an email notification). We encourage you to review the Privacy Notice whenever you interact with us to stay informed about our information practices and the ways you can help protect your privacy.

 

11. Contact Us

 

To submit questions regarding this Privacy Notice or updating or requesting changes to your information, please contact our Privacy Team (see details below).. The Hadley Hotel does not share personal information with third parties for their direct marketing purposes, as these activities are defined in state law. However, if you feel you have such rights, you may send a request to the email address below and The Hadley Hotel will respond promptly to your request.

 

Email us at: info@thehadleyhotel.com or

 

Write to us at:

 

Privacy Team

The Hadley Hotel

113 Hadley Road EN5 5QN

 

Effective Date: 05/06/2020