Dorchester Collection

Privacy Policy

 
 

Welcome to Dorchester Collection’s privacy policy.
Your privacy is important to us, and we are committed to protecting your personal data.

1. Introduction

This privacy policy tells you how the Dorchester Collection group of hotels use your personal data when you visit our website, when we welcome you as our guest or you otherwise interact with us. It also tells you your privacy rights and how the law protects you.

It is important that you read this privacy policy, together with any other privacy notices we may show you from time to time, so that you are fully aware of how and why we are using your personal data. Thank you.

This website is not intended for children and we do not knowingly collect data relating to children.

This privacy policy was last updated on 24 May, 2018.

If you have any questions, please see How to contact Dorchester Collection about privacy below.

2. Who we are

Dorchester Services Limited (“Dorchester Collection”) holds a portfolio of nine of the world’s finest luxury hotels in Europe and the US. Each hotel is an icon in its own right, with a worldwide reputation for offering the most sought-after experiences of good living, charm, elegance and service.

Dorchester Collection is the data controller responsible for this website and the handling of any personal data carried out by it on behalf of the group of companies which operate each hotel. Dorchester Collection and each hotel work collaboratively to provide services to guests and website visitors and may sometimes be acting as joint data controllers. When we mention Dorchester Collection, “we”, “us” or “our” in this privacy policy, we are referring to Dorchester Collection.

We have appointed a data privacy manager who is responsible for looking after questions about this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please see How to contact Dorchester Collection about privacy below.

3. How we collect data

We may collect or receive data in lots of different ways. Here is an explanation of the main ways we do this:

You may give us data in person when you are a guest at one of our hotels

You may give us data in person when you’re a guest at one of our hotels, for example when you:

  • check-in and check-out;
  • make use of our accommodation, facilities and services;
  • make use of our concierge services;
  • attend our events;
  • enter a competition, promotion or survey;
  • complete a contact details card; and/or
  • give us your business card.

You may give us data remotely when you interact with us

You may give us data remotely when you interact with us via this website, by post, phone or email, or through chat or social media. For example, when you:

  • sign up to receive our newsletter or other direct marketing;
  • make enquiries or request information, or correspond with us generally;
  • create an account on our website;
  • book accommodation, hospitality, spa treatments or services;
  • buy items from our gift shop;
  • engage with us on social media;
  • enter a competition, promotion or survey;
  • leave comments or reviews; and/or
  • register for some of our business services, including the Diamond Club.

We may get some data automatically

When you interact with us, we may get some data automatically, including via this website. For example, that could be data about your equipment, browsing or the way you use this website. We may also collect data when you click on one of our adverts (including the ones you see on third party websites or social media).

The systems we use for guest management may also collect data automatically to help create a guest profile, which in turn gives us a better understanding of how we can improve your experience with us.

We may get some data from third parties

We may get some data from third parties as part of the booking process for our accommodation, hospitality, spa treatments or services at our hotels. For example, when you:

  • use third party booking services for accommodation, restaurants, hospitality, spa treatments or other services; and/or
  • are our guest as part of a group or corporate booking.

We may receive data about you from various other types of third parties, including:

  • from technology partners who help us run our website and mailing list sign-ups;
  • from providers of payment and fraud prevention services;
  • from analytics providers, advertising networks and search information providers;
  • from data partners;
  • from feedback and review partners;
  • from publicly available sources;
  • from social media, where privacy settings are set to public;
  • from third parties to whom you have given permission to share your data with us; and/or
  • from any third parties who are permitted by law to share your personal data with us.

4. Types of personal data we collect

How we collect data above explained the different ways we might obtain or receive data. Some of that data may be personal data, so please read below to understand the different types we may collect about you. Of course, the types of personal data we collect will depend on how you interact with us.

Personal data, or personal information, means any information about an individual, which can be used to identify that person. It does not include data where the identity has been removed (anonymous data).

We collect a variety of personal information about our guests, customers and visitors to our website. As our website is not intended for children, we do not knowingly collect data relating to children.

This personal data falls into these categories:

  • Identity Data includes title, gender, first name, maiden name, last name, marital status, date of birth, username or similar identifier and an encrypted version of your login/password. If you interact with us through social media, this may include your social media user name.
  • Contact Data includes billing address, delivery address, email address and telephone numbers.
  • Financial Data includes payment card and direct debit/bank account details.
  • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
  • Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses, as well as any data which we have added (for example, using analytics and profiling).
  • 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.
  • Usage Data includes information about how you use our website, products and services.
  • Tracking Data includes information we or others collect about you from cookies and similar tracking technologies, such as web beacons, pixels, and mobile identifiers.
  • Marketing and Communications Data includes your preferences in receiving direct marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature.

However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not ordinarily collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, 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.  The only exceptions to this are: (i) if you provide health data to us as part of a spa booking, we will use this to perform our contract with you, and we need your explicit consent to use your health data as part of that; or (ii) you have made the special category data obviously public.

Remember, if you choose not to share personal data with us, or refuse certain contact permissions, we might not be able to provide the products and services you’ve asked for.

5. Explaining the legal bases for 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. For example, when you make a booking at one of our hotels, that’s a contract.
  • 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. For example, when we carry out fraud screening as part of the check-out process or take steps to keep our website secure.
  • Where we need to comply with a legal or regulatory obligation. For example, keeping records of our sales for tax compliance.

When we are considering legitimate interests, we make sure we think about and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

Generally, we do not rely on consent as a legal basis for processing your personal data other than where the law requires it, for example in relation to sending certain direct marketing communications. Where our legal basis is consent, you have the right to withdraw consent any time.

See How and why we use your personal data below for more detailed information.

6. How and why we use your personal data

Click here to see a table explaining how we use your personal data, the types of personal data that applies to and why it is we can do this. When we explain why, we will identify the relevant category from Explaining the legal bases for using personal data above, and, where it’s based on being able to do so for our legitimate interests, we will highlight what that legitimate interest is.

We may process your personal data for more than one legal basis depending on how we are using it.

7. Advertising, marketing and your communications preferences

You could see our adverts in lots of different places, but it doesn’t always mean they’re using your personal data, because we also buy advertising space in the real world, on websites and on social media. If you see one of our adverts on a website and in social media, it may not be directed specifically at you and may simply be there because we’ve bid for the space.

To understand what we think you want, need or would be interested in, we may use your Identity, Contact, Technical, Tracking, Usage and Profile Data to form a picture. This is how we tell you about the hotels, services and events, and any special offers or promotions, we think you might be interested in.

To share our news, offers and services, we may use direct marketing by email, phone, text and post. Your direct marketing preferences are made clear on our website, and you can ask us about these any time via our contact page.

You may choose to opt in to receive our newsletter on our website. We may also be able to send you relevant direct marketing about our hotels, services and events unless you choose to opt out when making a booking with us, visiting our hotels or making a purchase via the gift shop.

Here are some examples of our direct marketing activities which may be directed specifically at you:

  • our newsletter via email;
  • invitations and promotions by post, to tell you about special events at our hotels; and/or
  • phone calls, to tell you something that might be relevant to you or your business.

You can opt out of direct marketing at any time. The easiest way to do this is to click the unsubscribe link at the bottom of your email or contact [email protected]

If a third party outside Dorchester Collection wants to use your personal data for their own direct marketing, we will always get your express opt-in consent first.

If you use a third party service to make a reservation at our hotels or restaurants, we may receive your marketing preferences from them. We may record these preferences, so when using these services please make sure you choose your marketing preferences correctly. As we have no control over the preferences which third party booking websites present to you, you should read their privacy policy.

We also work with partners to try and promote the reach of our adverts, using analytics and retargeting. To make sure the adverts you see on websites and social media are relevant, we use Tracking Data to see what you’ve looked at.

We want to give you the best Dorchester Collection experience online. Tracking Data, and in particular cookies, help us to do this by telling us which adverts will be most relevant to you and potential new guests on websites and social media. The cookies used for this purpose are often placed on our website by specialist organisations – and this is also why when you’ve been on the Dorchester Collection website, you might see content from our website again. This includes retargeting.

Cookies can also tell us if you’ve seen a specific advert, and how long it’s been since you have seen it. This is helpful, because it means we can control the effectiveness of our adverts and control the number of times people might be shown our adverts. Cookies also help us understand if you’ve opened a marketing email because we don’t want to send you things you won’t find interesting.

For more information about Tracking Data, in particular cookies, see Cookies below.

Almost all the cookies that relate to advertising are part of third party online advertising networks. If you’d like to read about how you can control which adverts you see online, see opt-out programs established by the Digital Advertising Alliance (United States), the Digital Advertising Alliance of Canada and the European Interactive Digital Advertising Alliance. We do not control cookies which are set by advertising networks.

8. 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 via your device. We explain below how we use cookies and how you can use controls on your device (e.g. your browser settings) to set your cookie preferences.

Cookies help us to provide you with a good experience when you use our website and also allows us to improve our website and services. We use the following categories of cookies:

  • Strictly necessary cookies. These are cookies which are needed to make the website work properly. For example, cookies enable you to log in, make a booking or buy a gift, and make secure payments.
  • Functionality cookies. These are used to recognise you when you return to our website. This helps us to personalise our content for you and remember your preferences.
  • Analytical/performance cookies. These 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.
  • Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. This forms part of Tacking Data and we may also share this information with third parties for this purpose.

You can find more information about the individual cookies we use and the purposes for which we use them in this list.

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, and we have no control over this. These cookies are likely to be analytical/performance cookies or targeting cookies.

We can use strictly necessary and functional cookies without consent. We gain your consent for other cookies via the banner that you see the first time you visit our website. You can choose not to consent. You can also block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies.

However, if you do not consent, or use your browser settings to block all cookies (including essential cookies), you may not be able to access all or parts of our site.

Please be aware that if you delete your cookies we will no longer know that you’ve opted out of online behavioural advertising, so our adverts can still appear to you on other websites.

9. Sharing your personal data

We may share your personal data with the third parties set out below for the purposes set out in this privacy policy. We may also share your personal data if the law otherwise permits or requires it.

We may share personal data with the following categories of third parties:

  • suppliers and service providers (such as outsourced service providers for administration and hotel management (e.g. booking and reservation systems, customer relationship management systems), technology and media services providers, payment processing and fraud prevention providers, fulfilment partners for the gift shop);
  • Dorchester Collection group and affiliates;
  • auditors and professional advisers like bankers, lawyers, accountants and insurers; and
  • government, regulators and law enforcement.

We share personal data with the following specific third parties:

  • Sabre: to enable reservations at our hotels using their SynXis booking system;
  • Ryatta: to enable spa bookings at our hotels using their spa direct booking system;
  • Adobe Campaign: to send our direct marketing campaigns to prospective and current customers; and
  • Gallup: to send out guest surveys on our behalf.

We also share data with third parties connected to advertising, retargeting and analytics. Please see the sections on Advertising, marketing and your communications preferences and Cookies above for more information about who those third parties are.

If we choose to sell, transfer or merge parts of our business or assets with a third party, we may share your data with them. 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 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.

10. International transfers

We share your personal data within Dorchester Collection, which involves transferring your data outside Europe

Many of our external third parties are based outside Europe, so your data will be transferred outside Europe when they process it.

Whenever we transfer your personal data outside Europe, we make sure it receives a similar degree of protection. To do this, we may implement one of the following safeguards:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
  • Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.

Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.

11. Data security

We want to keep your personal data safe, which is why we’ve put in place appropriate security measures to prevent it being accidentally lost, used or accessed in an unauthorised way, altered or shared. We also make sure that only people with a business need to know are able to access your data, including employees, agents, contractors and other third parties. 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.

Unfortunately, sending information over the internet is not completely secure.  Although we will do our best to protect your personal data, we cannot completely guarantee the security of your data transmitted to our site. It’s also important that you keep your password to our website secure. Please do not share it with anyone.

12. How long we keep your personal data for

We will only keep your personal data for as long as we need to fulfil the purposes we collected it for, including for satisfying any legal, accounting, or reporting requirements.

To decide how long we should keep your personal data for, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or sharing 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.

By law we have to keep basic information about our guests and customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances we may remove your identity from your personal data (so that it can no longer be associated with you) for statistical purposes, in which case we may use this information indefinitely without further notice to you.

13. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

Request access to your personal data

This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of your personal data

This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data

This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data

This enables you to object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing your personal data

This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request transfer of your personal data

We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Right to withdraw consent

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please see How to contact Dorchester Collection about privacy below.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not shared with anyone who doesn’t have the right to receive it. We may also contact you to ask you for more information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you’ve made a number of requests. In this case, we will let you know and keep you updated.

14. How to contact us about privacy

If you have any questions about this privacy policy, or would like to exercise any of your rights, please don’t hesitate to email us at [email protected] or send a letter addressed to: Privacy Manager, Dorchester Collection, Sixth Floor East, Lansdowne House, Berkeley Square, London W1J 6ER.

For any other general questions about our hotels, services or website, please contact us here.

If you have any complaints, we will always do our best to help with your concerns, so please do not hesitate to contact us first of all. Alternatively, 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 (www.ico.org.uk).

15. Third-party links

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 notice of every website you visit.

16. If you choose not to give us your personal data

When you make a booking with us for accommodation, hospitality, spa treatments or other services, we may need to collect some of your personal data by law, or under the terms of a contract we have with you. This means that if you decide not to give us your data, we might not be able to provide the service, and may have to cancel your booking or gift shop purchase. We will let you know if this is the case at the time, so you can decide what you’d like to do.

17. Change of purpose

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 we need to use your personal data for an unrelated purpose, we will let you know and explain how the law allows us to do this.

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.

18. Changes to this privacy policy

If anything changes in this privacy policy in future, we will post the details on the page or send you an email if appropriate.

19. Finally, a small request

To help you get the most from your Dorchester Collection experience, it’s important that your personal data is accurate and up to date. If anything changes during your relationship with us, please let us know. Thank you.

© Dorchester Services Limited 2018

1. Introduction

This privacy policy tells you how the Dorchester Collection group of hotels use your personal data when you visit our website, when we welcome you as our guest or you otherwise interact with us. It also tells you your privacy rights and how the law protects you.

It is important that you read this privacy policy, together with any other privacy notices we may show you from time to time, so that you are fully aware of how and why we are using your personal data. Thank you.

This website is not intended for children and we do not knowingly collect data relating to children.

This privacy policy was last updated on 24 May, 2018.

If you have any questions, please see How to contact Dorchester Collection about privacy below.

2. Who we are

Dorchester Services Limited (“Dorchester Collection”) holds a portfolio of nine of the world’s finest luxury hotels in Europe and the US. Each hotel is an icon in its own right, with a worldwide reputation for offering the most sought-after experiences of good living, charm, elegance and service.

Dorchester Collection is the data controller responsible for this website and the handling of any personal data carried out by it on behalf of the group of companies which operate each hotel. Dorchester Collection and each hotel work collaboratively to provide services to guests and website visitors and may sometimes be acting as joint data controllers. When we mention Dorchester Collection, “we”, “us” or “our” in this privacy policy, we are referring to Dorchester Collection.

We have appointed a data privacy manager who is responsible for looking after questions about this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please see How to contact Dorchester Collection about privacy below.

3. How we collect data

We may collect or receive data in lots of different ways. Here is an explanation of the main ways we do this:

You may give us data in person when you are a guest at one of our hotels

You may give us data in person when you’re a guest at one of our hotels, for example when you:

  • check-in and check-out;
  • make use of our accommodation, facilities and services;
  • make use of our concierge services;
  • attend our events;
  • enter a competition, promotion or survey;
  • complete a contact details card; and/or
  • give us your business card.

You may give us data remotely when you interact with us

You may give us data remotely when you interact with us via this website, by post, phone or email, or through chat or social media. For example, when you:

  • sign up to receive our newsletter or other direct marketing;
  • make enquiries or request information, or correspond with us generally;
  • create an account on our website;
  • book accommodation, hospitality, spa treatments or services;
  • buy items from our gift shop;
  • engage with us on social media;
  • enter a competition, promotion or survey;
  • leave comments or reviews; and/or
  • register for some of our business services, including the Diamond Club.

We may get some data automatically

When you interact with us, we may get some data automatically, including via this website. For example, that could be data about your equipment, browsing or the way you use this website. We may also collect data when you click on one of our adverts (including the ones you see on third party websites or social media).

The systems we use for guest management may also collect data automatically to help create a guest profile, which in turn gives us a better understanding of how we can improve your experience with us.

We may get some data from third parties

We may get some data from third parties as part of the booking process for our accommodation, hospitality, spa treatments or services at our hotels. For example, when you:

  • use third party booking services for accommodation, restaurants, hospitality, spa treatments or other services; and/or
  • are our guest as part of a group or corporate booking.

We may receive data about you from various other types of third parties, including:

  • from technology partners who help us run our website and mailing list sign-ups;
  • from providers of payment and fraud prevention services;
  • from analytics providers, advertising networks and search information providers;
  • from data partners;
  • from feedback and review partners;
  • from publicly available sources;
  • from social media, where privacy settings are set to public;
  • from third parties to whom you have given permission to share your data with us; and/or
  • from any third parties who are permitted by law to share your personal data with us.

4. Types of personal data we collect

How we collect data above explained the different ways we might obtain or receive data. Some of that data may be personal data, so please read below to understand the different types we may collect about you. Of course, the types of personal data we collect will depend on how you interact with us.

Personal data, or personal information, means any information about an individual, which can be used to identify that person. It does not include data where the identity has been removed (anonymous data).

We collect a variety of personal information about our guests, customers and visitors to our website. As our website is not intended for children, we do not knowingly collect data relating to children.

This personal data falls into these categories:

  • Identity Data includes title, gender, first name, maiden name, last name, marital status, date of birth, username or similar identifier and an encrypted version of your login/password. If you interact with us through social media, this may include your social media user name.
  • Contact Data includes billing address, delivery address, email address and telephone numbers.
  • Financial Data includes payment card and direct debit/bank account details.
  • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
  • Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses, as well as any data which we have added (for example, using analytics and profiling).
  • 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.
  • Usage Data includes information about how you use our website, products and services.
  • Tracking Data includes information we or others collect about you from cookies and similar tracking technologies, such as web beacons, pixels, and mobile identifiers.
  • Marketing and Communications Data includes your preferences in receiving direct marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature.

However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not ordinarily collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, 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.  The only exceptions to this are: (i) if you provide health data to us as part of a spa booking, we will use this to perform our contract with you, and we need your explicit consent to use your health data as part of that; or (ii) you have made the special category data obviously public.

Remember, if you choose not to share personal data with us, or refuse certain contact permissions, we might not be able to provide the products and services you’ve asked for.

5. Explaining the legal bases for 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. For example, when you make a booking at one of our hotels, that’s a contract.
  • 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. For example, when we carry out fraud screening as part of the check-out process or take steps to keep our website secure.
  • Where we need to comply with a legal or regulatory obligation. For example, keeping records of our sales for tax compliance.

When we are considering legitimate interests, we make sure we think about and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

Generally, we do not rely on consent as a legal basis for processing your personal data other than where the law requires it, for example in relation to sending certain direct marketing communications. Where our legal basis is consent, you have the right to withdraw consent any time.

See How and why we use your personal data below for more detailed information.

6. How and why we use your personal data

Click here to see a table explaining how we use your personal data, the types of personal data that applies to and why it is we can do this. When we explain why, we will identify the relevant category from Explaining the legal bases for using personal data above, and, where it’s based on being able to do so for our legitimate interests, we will highlight what that legitimate interest is.

We may process your personal data for more than one legal basis depending on how we are using it.

7. Advertising, marketing and your communications preferences

You could see our adverts in lots of different places, but it doesn’t always mean they’re using your personal data, because we also buy advertising space in the real world, on websites and on social media. If you see one of our adverts on a website and in social media, it may not be directed specifically at you and may simply be there because we’ve bid for the space.

To understand what we think you want, need or would be interested in, we may use your Identity, Contact, Technical, Tracking, Usage and Profile Data to form a picture. This is how we tell you about the hotels, services and events, and any special offers or promotions, we think you might be interested in.

To share our news, offers and services, we may use direct marketing by email, phone, text and post. Your direct marketing preferences are made clear on our website, and you can ask us about these any time via our contact page.

You may choose to opt in to receive our newsletter on our website. We may also be able to send you relevant direct marketing about our hotels, services and events unless you choose to opt out when making a booking with us, visiting our hotels or making a purchase via the gift shop.

Here are some examples of our direct marketing activities which may be directed specifically at you:

  • our newsletter via email;
  • invitations and promotions by post, to tell you about special events at our hotels; and/or
  • phone calls, to tell you something that might be relevant to you or your business.

You can opt out of direct marketing at any time. The easiest way to do this is to click the unsubscribe link at the bottom of your email or contact [email protected]

If a third party outside Dorchester Collection wants to use your personal data for their own direct marketing, we will always get your express opt-in consent first.

If you use a third party service to make a reservation at our hotels or restaurants, we may receive your marketing preferences from them. We may record these preferences, so when using these services please make sure you choose your marketing preferences correctly. As we have no control over the preferences which third party booking websites present to you, you should read their privacy policy.

We also work with partners to try and promote the reach of our adverts, using analytics and retargeting. To make sure the adverts you see on websites and social media are relevant, we use Tracking Data to see what you’ve looked at.

We want to give you the best Dorchester Collection experience online. Tracking Data, and in particular cookies, help us to do this by telling us which adverts will be most relevant to you and potential new guests on websites and social media. The cookies used for this purpose are often placed on our website by specialist organisations – and this is also why when you’ve been on the Dorchester Collection website, you might see content from our website again. This includes retargeting.

Cookies can also tell us if you’ve seen a specific advert, and how long it’s been since you have seen it. This is helpful, because it means we can control the effectiveness of our adverts and control the number of times people might be shown our adverts. Cookies also help us understand if you’ve opened a marketing email because we don’t want to send you things you won’t find interesting.

For more information about Tracking Data, in particular cookies, see Cookies below.

Almost all the cookies that relate to advertising are part of third party online advertising networks. If you’d like to read about how you can control which adverts you see online, see opt-out programs established by the Digital Advertising Alliance (United States), the Digital Advertising Alliance of Canada and the European Interactive Digital Advertising Alliance. We do not control cookies which are set by advertising networks.

8. 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 via your device. We explain below how we use cookies and how you can use controls on your device (e.g. your browser settings) to set your cookie preferences.

Cookies help us to provide you with a good experience when you use our website and also allows us to improve our website and services. We use the following categories of cookies:

  • Strictly necessary cookies. These are cookies which are needed to make the website work properly. For example, cookies enable you to log in, make a booking or buy a gift, and make secure payments.
  • Functionality cookies. These are used to recognise you when you return to our website. This helps us to personalise our content for you and remember your preferences.
  • Analytical/performance cookies. These 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.
  • Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. This forms part of Tacking Data and we may also share this information with third parties for this purpose.

You can find more information about the individual cookies we use and the purposes for which we use them in this list.

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, and we have no control over this. These cookies are likely to be analytical/performance cookies or targeting cookies.

We can use strictly necessary and functional cookies without consent. We gain your consent for other cookies via the banner that you see the first time you visit our website. You can choose not to consent. You can also block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies.

However, if you do not consent, or use your browser settings to block all cookies (including essential cookies), you may not be able to access all or parts of our site.

Please be aware that if you delete your cookies we will no longer know that you’ve opted out of online behavioural advertising, so our adverts can still appear to you on other websites.

9. Sharing your personal data

We may share your personal data with the third parties set out below for the purposes set out in this privacy policy. We may also share your personal data if the law otherwise permits or requires it.

We may share personal data with the following categories of third parties:

  • suppliers and service providers (such as outsourced service providers for administration and hotel management (e.g. booking and reservation systems, customer relationship management systems), technology and media services providers, payment processing and fraud prevention providers, fulfilment partners for the gift shop);
  • Dorchester Collection group and affiliates;
  • auditors and professional advisers like bankers, lawyers, accountants and insurers; and
  • government, regulators and law enforcement.

We share personal data with the following specific third parties:

  • Sabre: to enable reservations at our hotels using their SynXis booking system;
  • Ryatta: to enable spa bookings at our hotels using their spa direct booking system;
  • Adobe Campaign: to send our direct marketing campaigns to prospective and current customers; and
  • Gallup: to send out guest surveys on our behalf.

We also share data with third parties connected to advertising, retargeting and analytics. Please see the sections on Advertising, marketing and your communications preferences and Cookies above for more information about who those third parties are.

If we choose to sell, transfer or merge parts of our business or assets with a third party, we may share your data with them. 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 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.

10. International transfers

We share your personal data within Dorchester Collection, which involves transferring your data outside Europe

Many of our external third parties are based outside Europe, so your data will be transferred outside Europe when they process it.

Whenever we transfer your personal data outside Europe, we make sure it receives a similar degree of protection. To do this, we may implement one of the following safeguards:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
  • Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.

Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.

11. Data security

We want to keep your personal data safe, which is why we’ve put in place appropriate security measures to prevent it being accidentally lost, used or accessed in an unauthorised way, altered or shared. We also make sure that only people with a business need to know are able to access your data, including employees, agents, contractors and other third parties. 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.

Unfortunately, sending information over the internet is not completely secure.  Although we will do our best to protect your personal data, we cannot completely guarantee the security of your data transmitted to our site. It’s also important that you keep your password to our website secure. Please do not share it with anyone.

12. How long we keep your personal data for

We will only keep your personal data for as long as we need to fulfil the purposes we collected it for, including for satisfying any legal, accounting, or reporting requirements.

To decide how long we should keep your personal data for, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or sharing 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.

By law we have to keep basic information about our guests and customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances we may remove your identity from your personal data (so that it can no longer be associated with you) for statistical purposes, in which case we may use this information indefinitely without further notice to you.

13. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

Request access to your personal data

This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of your personal data

This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data

This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data

This enables you to object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing your personal data

This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request transfer of your personal data

We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Right to withdraw consent

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please see How to contact Dorchester Collection about privacy below.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not shared with anyone who doesn’t have the right to receive it. We may also contact you to ask you for more information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you’ve made a number of requests. In this case, we will let you know and keep you updated.

14. How to contact us about privacy

If you have any questions about this privacy policy, or would like to exercise any of your rights, please don’t hesitate to email us at [email protected] or send a letter addressed to: Privacy Manager, Dorchester Collection, Sixth Floor East, Lansdowne House, Berkeley Square, London W1J 6ER.

For any other general questions about our hotels, services or website, please contact us here.

If you have any complaints, we will always do our best to help with your concerns, so please do not hesitate to contact us first of all. Alternatively, 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 (www.ico.org.uk).

15. Third-party links

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 notice of every website you visit.

16. If you choose not to give us your personal data

When you make a booking with us for accommodation, hospitality, spa treatments or other services, we may need to collect some of your personal data by law, or under the terms of a contract we have with you. This means that if you decide not to give us your data, we might not be able to provide the service, and may have to cancel your booking or gift shop purchase. We will let you know if this is the case at the time, so you can decide what you’d like to do.

17. Change of purpose

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 we need to use your personal data for an unrelated purpose, we will let you know and explain how the law allows us to do this.

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.

18. Changes to this privacy policy

If anything changes in this privacy policy in future, we will post the details on the page or send you an email if appropriate.

19. Finally, a small request

To help you get the most from your Dorchester Collection experience, it’s important that your personal data is accurate and up to date. If anything changes during your relationship with us, please let us know. Thank you.

© Dorchester Services Limited 2018