PRIVACY POLICY

Last updated 24 May 2018

1. Privacy Policy

At The Courthouse Hotel London (referred to as “Property” in this Privacy Policy), we strive to deliver outstanding products, services, and experiences to our Guests and Clients (referred to as “you” / “your” in this Privacy Policy). We value your business and, more importantly, your loyalty. We recognize that privacy is an important issue. We have developed this Privacy Policy (this “Policy”) to explain our practices regarding the personal information we collect when you visit this site and via our other online services (including Social Media Pages).
This Privacy Statement describes the privacy practices of The Courthouse Hotel London for data that we collect:

• through websites operated by us from which you are accessing this Privacy Statement
• through our social media pages that we control from which you are accessing this Privacy Statement (collectively, our “Social Media Pages”)
• through Text and HTML-formatted email messages that we send you that link to this Privacy Statement and through your communications with us
• when you visit or stay as a guest at one of our properties, or through other offline interactions
• when you host or participate in events (including conferences and corporate events) at the Hotel

Collectively, we refer to the Websites, and our Social Media Pages, as the “Online Services” and, together with offline channels, the “Services.” By using the Services, you agree to the terms and conditions of this Privacy Statement.

Please read this Policy carefully before submitting personal information about you to us. By using any of our products or services and/or by agreeing to this Statement, e.g. in the context of booking rooms with us or for any other services, you understand and acknowledge that we will collect and use personal information as described in this Statement.

2. Data we collect

“Personal Data” are data that identify you as an individual or relate to an identifiable individual.

At every touch point or guest interaction, we may collect personal information. In addition to any other information you may choose to provide to us, this personal information may include:

• Name
• Gender
• Postal address
• Telephone number
• Email address
• Credit and debit card number or other payment data
• Financial information in limited circumstances
• Language preference
• Date and place of birth
• Nationality, passport, visa or other government-issued identification data
• Important dates, such as birthdays, anniversaries and special occasions
• Membership or loyalty program data (including co-branded payment cards, travel partner program affiliations)
• Employer details
• Travel itinerary, tour group or activity data
• Prior guest stays or interactions, goods and services purchased, special service and amenity requests
• Geolocation information
• Social media account ID, profile photo and other data publicly available, or data made available by linking your social media and loyalty accounts

If you submit any Personal Data about other people to us or our Service Providers (e.g., if you make a reservation for another individual), you represent that you have the authority to do so and you permit us to use the data in accordance with this Privacy Statement.

“Other Data” are data that generally do not reveal your specific identity or do not directly relate to an individual. To the extent Other Data reveal your specific identity or relate to an individual, we will treat Other Data as Personal Data. Other Data include:

• Browser and device data
• App usage data
• Data collected through cookies, pixel tags and other technologies
• Demographic data and other data provided by you
• Aggregated data

3. How we collect data

• Online Services – We collect Personal Data when you make a reservation, purchase goods and services from our Websites or partner websites, communicate with us, or otherwise connect with us or post to social media pages, or sign up for a newsletter or participate in a survey, contest or promotional offer.
• Property Visits and Offline Communications – We collect Personal Data when you visit our Property or use on-property services and outlets, such as restaurants, concierge services, gym and spas. We also collect Personal Data when you attend promotional events that we host or in which we participate, or when you provide your Personal Data to facilitate an event.
• Business Partners – We collect Personal Data from companies with whom we partner to provide you with goods, services or offers based upon your experiences at our properties or that we believe will be of interest to you. Examples of Business Partners include on-property outlets (like SPA Services and Products), travel and tour partners, rental car providers and travel booking platforms. Business Partners are independent from The Courthouse Hotel London.  
• Internet Connected Devices – We collect Personal Data from internet-connected devices available in our Property. For example, a smart phone or assistant device may be available for your use and to tailor your accommodations and experience.

4. Cookies and other data

We also collect Other Data in a variety of ways

• Your browser or device – We collect certain data through your browser or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system name and version, device manufacturer and model, language, internet browser type and version and the name and version of the Online Services you are using. We use this data to ensure that the Online Services function properly.
• Cookies – We collect certain data from cookies, which are pieces of data stored directly on the computer or mobile device that you are using. Cookies allow us to collect data such as browser type, time spent on the Online Services, pages visited, referring URL, language preferences, and other aggregated traffic data. We use the data for security purposes, to facilitate navigation, to display data more effectively, to collect statistical data, to personalize your experience while using the Online Services and to recognize your computer to assist your use of the Online Services. We also gather statistical data about use of the Online Services to continually improve design and functionality, understand how they are used and assist us with resolving questions. Cookies further allow us to select which advertisements or offers are most likely to appeal to you and display them while you are using the Online Services or to send marketing emails. We also use cookies to track responses to online advertisements and marketing emails.

If you do not want data collected with cookies, you can learn more about controlling cookies at:
http://www.allaboutcookies.org/manage-cookies/index.html
https://ico.org.uk/for-the-public/online/cookies/

You can choose whether to accept cookies by changing the settings on your browser. If, however, you do not accept cookies, you may experience some inconvenience in your use of the Online Services. For example, we will not be able to recognize your computer, and you may not be able to successfully book with us. You also will not receive advertising or other offers from us that are relevant to your interests and needs. At this time, we do not respond to browser “Do-Not-Track” signals.

• Links to 3rd Party Websites & Services – Our site may contain links to third parties’ websites. Please note that we are not responsible for the collection, use, maintenance, sharing, or disclosure of data and information by such third parties. If you provide information on and use third-party sites, the privacy policy and terms of service on those sites are applicable. We encourage you to read the privacy policies of websites that you visit before submitting personal information.
• High Speed Internet Access and Wi-Fi Services – We may also partner with strategically selected Internet providers to offer Internet access to our guests. Your use of on-property Internet service is subject to the third-party Internet provider’s terms of use and privacy policy. You can access those terms and policies using the links on the service sign-in page, or by visiting the Internet provider’s website. Because Other Information does not personally identify you, such information may be disclosed for any purpose where permitted by law.

5. Use of personal information collected about you

We use your personal information in a number of ways, including to provide and personalize the services you request and expect from The Courthouse Hotel London, to offer you the expected level of hospitality in-room and throughout our Property, conduct direct marketing and sales promotions and as set forth below in more detail:

Provide the Services you request – We use Personal Data and Other Data to provide Services you request, including:
– To facilitate reservations, payment, send administrative information, confirmations or pre-arrival messages, to assist you with meetings and events and to provide you with other information about the area and the Property.
– To complete your reservation and stay, for example, to process your payment, ensure that your room is available and provide you with related customer service
– To support our electronic receipt program. When you provide an email address in making a reservation, we use that email address to send you a copy of your bill. If you make a reservation for another person using your email address, that person’s bill will be emailed to you, as well. You can opt out of receiving your bill via email and instead receive a paper copy by contacting the front desk

Personalize the Services according to your Personal Preferences – We use Personal Data and Other Data to personalize the Services and improve your experiences, including when you call the Property, visit the Property or use the Online Services.

Present offers tailored to your Personal Preferences 
– We use Personal Data and Other Data to send you marketing communications and promotional offers, as well as periodic customer satisfaction, market research or quality assurance surveys. We will only send you promotional and marketing communication in accordance to your Personal Preferences with your consent.
– We use Personal Data and Other Data to allow you to participate in sweepstakes, contests and other promotions and to administer these activities. Some of these activities have additional rules and may contain additional information about how we use and disclose your Personal Data. We suggest that you read any such rules carefully.

Manage Contractual Relationship – We will use Personal Data and Other Data to manage our contractual relationship with you, because we have a legitimate interest to do so and/or to comply with a legal obligation

Business Purposes – We use Personal Data and Other Data for data analysis, audits, security and fraud monitoring and prevention (including with the use of closed circuit television, card keys, and other security systems), developing new goods and services, enhancing, improving or modifying our Services, identifying usage trends, determining the effectiveness of our promotional campaigns and operating and expanding our business activities.

We will collect your consent prior to processing your data where required by applicable law.

We are obligated to collect certain data, including your name, address, payment information, and by law, for guests from certain countries, travel document information, in order to process your reservation. Failure to provide this information will result in our inability to process your reservation.

6. Sensitive information

The term “sensitive information” refers to information related to your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, sex life, or sexual orientation, genetic information, criminal background, and any biometric data used for the purpose of unique identification.

We do not generally collect sensitive information unless it is volunteered by you or unless we are required to do so pursuant to applicable laws or regulations. We may use health data provided by you to serve you better and meet your particular needs (for example, the provision of disability access).

7. Personal information from children

We do not knowingly collect personal information from individuals under 18 years of age. As a Parent or legal guardian, please do not to allow your children to submit personal information without your permission.

8. Protecting data and information

We seek to use reasonable organizational, technical and administrative measures to protect Personal Data. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contact” section on our Website.

9. How long we keep your information

We will retain your Personal Data for the period necessary to fulfil the purposes outlined in this Privacy Statement unless a longer retention period is required or permitted by law.
The criteria used to determine our retention periods include:

– The length of time we have an ongoing relationship with you and provide the Services to you (for example, for as long as you have an account with us or keep using the Services)
– Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them)
– Whether retention is advisable considering our legal position (such as, for statutes of limitations, litigation or regulatory investigations)

10. Choices: marketing communications

If you have given us your contact information (mail address, fax number, email address or phone number), we may want to inform you in accordance with any preferences you have expressed, and with your consent where required, about our products and services or invite you to events via email, online advertising, social media, WhatsApp, telephone, text message (including SMS and MMS), postal mail, our customer relations, and other means (including on-property messaging, such as your in-room television or smart devices where available).
If you prefer not to receive email marketing materials from us, you may opt-out at any time by using the unsubscribe function in the email you receive from us or by contacting dpo@courthouse-hotel.com 

To opt out of text messages, please email dpo@courthouse-hotel.com or reply “STOP” to the message you received.

11.Your rights and consent

Even if we already hold your personal data, you still have various rights in relation to it. To get in touch about these, please contact us. We will seek to deal with your request without undue delay, and in any event in accordance with the requirements of any applicable laws. Please note that we may keep a record of your communications to help us resolve any issues which you raise.

11.1 Data Subject Access Requests (DSAR): You have the right to ask us to confirm what information we hold about you at any time, and you may ask us to modify, update or delete such information. At this point we may comply with your request or, additionally do one of the following:

– we may ask you to verify your identity, or ask for more information about your request; and

– where we are legally permitted to do so, we may decline your request, but we will explain why if we do so.

If you require additional copies, we may need to charge a reasonable fee.

11.2 Right to rectification: If your personal data is inaccurate or incomplete, you are entitled to ask that we correct or complete it.

11.3 Right to object: You may ask us at any time to stop processing your personal data, and we will do so:

– If we are relying on a legitimate interest to process your personal data — unless we demonstrate compelling legitimate grounds for the processing or

– If we are processing your personal data for direct marketing.

11.4 Right to withdraw consent: Where we have obtained your consent to process your personal data for certain activities (for example, credit allowances), or consent to market to you, you may withdraw your consent at any time.

11.5 Right to erasure: In certain situations (for example, where we have processed your data unlawfully), you have the right to request us to “erase” your personal data.

If you wish to exercise your rights please contact us as described in the “Contact” section below. We will respond to your request within 30 days however we may be allowed to extend this period in certain cases, and will only disagree with you if certain limited conditions apply.

12. Policy Modifications

We may modify this Policy from time to time. When we make material changes to this policy we will post the revised policy on the homepage of our site. You can tell when this Policy was last updated by looking at the date at the top of the Policy. Any changes to our Policy will become effective upon posting of the revised Policy on the site. Use of the site following such changes constitutes your acceptance of the revised Policy then in effect.

13. Contacts and complaints

If you have any questions about this Policy or how The Courthouse Hotel processes your personal information, please contact us by email to dpo@courthouse-hotel.com or by postal mail to

The Courthouse Hotel London, 19-21 Gt Marlborough St, London, W1F 7HL, United Kingdom