PRIVACY POLICY

Hodson Bay Group is committed to protecting and respecting your privacy in line with the principles set out in the General Data Protection Regulation (GDPR) and the Data Protection Act. We adhere to the Privacy Policy (the “Policy”) together with any disclaimers sets out the basis on which any personal data we collect from you or that you provide to us, or that is provided to us relating to you (“Data”) by any means will be processed. Please read the following carefully to understand our use of personal data. Please note that the Policy relates only to living individuals in relation to personal data relating directly to themselves, and not to persons in any other capacity.

Information we may collect from you

We collect personal data from you which you volunteer when you provide such personal data to us, or via our services with which you interact. We may also be given other personal data relating to you by other persons, or we may obtain such other personal data about you as may be provided to us in the course of our legitimate business activities.

We may collect and process Data. Including the following in the course of providing services to you, which could contain your personal data:

your full name; your address; your various email addresses; your various phone numbers including mobile phone numbers; your nationality; your address; financial information about you, including your bank account details, credit card details, or other payment details; details of contracts you have entered with third parties for us to provide services to you; details of your relationship to other parties; details of your membership of professional or other organisations; your date of birth; details of your children and other relations; medical details, including details of allergies; details of your car registration number; details of your driving license; details of your passport and all other Data which you ask us to process on your behalf, or which is necessary for us to process in order for us to fulfil our role as providing accommodation, gym, leisure. Retail or food related services to you. And CCTV data whilst on the premises of Hodson Bay Group Hotels.

We may also process other data, which is not personal data.

When you access our website or wi-fi facilities, your device’s browser provides us with information such as your IP address, browser type, access time and referring URL which is collected and used to compile statistical data. This information may be used to help us to improve our website and the services we offer, and to offer services to you.

Security and where we store your personal data

We are committed to protecting the security of your personal data. We use a variety of security technologies and procedures to help protect your personal data from unauthorised access and use. As effective as modern security practices are, no physical or electronic security system is entirely secure. We cannot guarantee the complete security of our databases, nor can we guarantee that information you supply will not be intercepted while being transmitted to us over the Internet. We will continue to revise policies and implement additional security features as new technologies become available.

The transmission of information via the internet is not completely secure and may involve the transfer of data to countries outside of the European Economic Area (EEA). This occurs typically through use of cloud solutions for web hosting, email hosting or proprietary software solutions delivered to us through the Cloud. We do not however authorise any third party to use your personal data for their own purposes. Non-EEA countries may not provide an adequate level of protection in relation to processing your personal data. By submitting your data, you agree to this transfer, storing and processing.

Although we will do our best to protect your personal data, we cannot guarantee the security of your personal data transmitted to us. Any transmission of data is at your own risk. Once we receive your personal data, we use appropriate security measures to seek to prevent unauthorised access.

Uses made of your personal data

The data collected by Hodson Bay Group is only used in the specific manner it was collected.
information collected is kept by Hodson Bay Hotel and the third parties contracted by Hodson Bay Group to facilitate the booking, such as but not limited to, the software booking engine provider, e-mailing provider, telephone / SMS text message provider.
Information submitted or sent through specific enquiry (eg. submission of an enquiry form or sent through an email) is only used for the exact query raised.

Technical information collected during website visits such as IP address, browser, operating system, device used or physical location etc. is only used for website operation and is not personally identifiable or persistent. For persistent information (cookies) please see the segment regarding cookies below.

– We use your personal data that we hold to:

– In our legitimate interest of advertising our services, provide you with information, products or services that you request from us or which we feel may interest you.

carry out our obligations arising from any contracts entered into between you and us;

in our legitimate interest of advertising our services, provide details of any loyalty scheme or promotion;

comply with legislation; and/or

notify you about changes to our.

List of services include

• Accommodation
• Meetings & Events (incl weddings and family occasions)
• Leisure Centre Membership
• Spa
• Retail (e.g. Vouchers; Spa gifts & products; Pool merchandise)
• Restaurant, bar service and other food related services.

How do we collect your personal data?

Currently there are a number of ways that customers can express a wish to either engage or continue to engage further with Hodson Bay Group

• Email – we send emails to those who have chosen not to excluded from email notifications. Each email sent from Hodson Bay Group or its Hotels provides an unsubscribe option which if enacted, will exclude the recipient from future email communications.
• Check in or reception – as part of the check in process, all guests are asked to sign a guest registration form. Included in that guest registration form, is the option to sign up (or opt in) for receipt of marketing information or special offers which may be of interested to the guest. Guests who do opt in, will receive communications from time to time including email, text or postal offers.
• By post – from time to time, Hodson Bay Group may send special offers of interest to you by post. With each mail received, we will remind you of the option to discontinue receiving such marketing materials at any time.
• Phone – as of May 25^th 2018, when a customer or potential customer calls a Hodson Bay Group Hotel, at their own discretion, customers will not be asked if they wish to subscribe to marketing communications and therefore will not receive marketing collateral as a result of the phone conversation. Callers to the Hotels who do book, will receive a confirmation email outlining details of their booking.

Reservations calls may be recorded from time to time for training purposes. All recordings will be held for no more than 14 days post recording.

• SMS/Text – please note that SMS pre-stay messages are also sent to customers as an extension to their confirmation email, between 3 and 7 days in advance of arrival. The purpose of the texts are to remind customers of their booking and key booking details.
• Social Media: including but not exclusive to Facebook/Twitter/Instagram/LinkedIn – from time to time, and in the case of campaigns, competitions, job vacancies, company announcements or other social posts/initiatives which result in participation/engagement and subsequently information volunteered by “social” participants, Hodson Bay Group may use and personal data shared to engage with the participant in a relevant and appropriate manner. Such data will not be used for any other purpose and will not be shared with any 3^rd
• CCTV: there are numerous locations across all hotels where we collect CCTV Personal Data. Notices are in place throughout the hotel to clearly highlight the presence of cameras in the nearby location.

Meeting, Events, Group Bookings Weddings

Weddings

With regards to Wedding enquiry into any hotel within Hodson Bay Group, the following takes place:

• All wedding enquiries are responded to by the Hotel Wedding team, which includes an email.
• Within the email, the wedding enquirer will be reminded of the other hotels within the group, and that the Wedding co-ordinator of those hotels will send an email introducing herself and in doing so, present the enquirer with the option to add other Hodson Bay Group hotels to their Hotel research.
• In the event that the enquirer does not express a wish to do so, then communications with the enquirer will cease.

Meetings & Events

Regarding communications with Meeting & Events bookers (or B2B customers), whether via direct inquiry incoming, or cold calling outgoing, the following takes place:

• All Meeting & Events enquiries received are responded to by the Hotel’s Sales team.
• All customer details are recorded in the Hodson Bay Group Database (or Group CRM Database) and ongoing/relevant communications with the customer are recorded in the CRM database.
• Under GDPR “legitimate interest”, each hotel may connect with all contacts in the Group CRM database as part of the Group Proactive sales approach. In other words, any Hotel may contact a B2B contact to explore their Meeting & Events activity and hence the potential for new business opportunities.

Group Bookings (“one off” family/friends gatherings, non-repeat residential enquiry with < 5 bedrooms)

Such bookings have little potential to be repeat, and do not warrant recording in the Group CRM.

• Such enquiries are responded to by the Hotel’s Reservations team.
• Details of the enquiry are recorded in a dedicated file accessible by the Reservations function only.
• All details will be stored in line with our GDPR data retention guidelines.

Note that there may be other instances not mentioned above where we have captured person data. Please be reminded that we may use your data to send you information relating to our services, events and products which may be of interest to you. If you do not want us to use your data in this way, at any time, please notify us to that effect by emailing privacy@hodonbaygroup.com

Links to other sites

Our website may, from time to time, contain links to and from other websites. If you follow a link to any of those websites, please note that those websites have their own privacy policies and that we do not accept any responsibility or liability for those policies. Please check those policies before you submit any data to those websites.

Your data protection rights

We will keep your personal data only for as long as is reasonably necessary for the purposes outlined in this Privacy Policy, or for the duration required by any legal, regulatory, accounting or reporting requirements, whichever is the longer. When you consent to receive marketing communications, we will keep your data until you unsubscribe.

To determine the appropriate retention period for your personal data, we consider the amount, nature, and sensitivity of the personal data, the purposes for which we process your personal data and applicable legal requirements or operational retention needs.
Upon expiry of the applicable retention period we will securely destroy your personal data in accordance with applicable laws and regulations.

You can write to us at any time to exercise the following rights available to you under data protection legislation:

• To get a copy of the personal information we hold about you
• To correct inaccurate information about you
• To delete the information we hold on you
• To exercise your right of data portability
• To opt-out of receiving messages relating to business events
• To object to the processing of your personal data
• To restrict the processing of your personal data

You can do this by emailing us at privacy@hodsonbaygroup.com

The controller for the purposes of GDPR is Hodson Bay Group.

Changes to this policy

We reserve the right to change this Policy from time to time in our sole discretion. If we make any changes, we will post those changes here so that you can see what information we gather, how we might use that information and in what circumstances we may disclose it. By continuing to use our site or our services or otherwise provide data after we post any such changes, you accept and agree to this Policy as modified.

Contact Us

Questions, comments, requests and complaints regarding this Policy and the information we hold are welcome and should be addressed to us at privacy@hodsonbaygroup.com. All requests will be dealt with promptly.

COOKIE STATEMENT

What are Cookies?

Cookies are small text files stored on your device by a web browser (e.g. Internet Explorer) that hold information about your previous visits to our site. On returning to our site this stored information is fed back to us allowing us to offer you a more personal browsing experience. By using our site, you consent to cookies being used in accordance with our policy. For more information on cookies, visitwww.dataprotection.ie

Why are we telling you this?

EU law requires website operators to ask for permission before using certain kinds of cookies. To ensure you are completely aware of the types of cookies we use and to enable us to continue to bring you the best possible browsing experience, we are giving you a detailed outline of the cookies we use and their unique role in your browsing experience.

What cookies do we use? 

Our website uses the following types of cookies:

Strictly necessary cookies– These technical cookies enable you to navigate our site and gain full access to its features and secure areas. Without these cookies essential services, you have asked for, cannot be provided.

Functionality cookies– These cookies remember choices you made on previous visits to our site such as your username, language or region so we can provide enhanced, more personal features. They can also be used to remember changes you’ve made to text size, fonts and other parts of web pages you can customise. Functionality cookies can also be used to provide services you have previously asked for such as watching videos or commenting on a blog. The information collected by these cookies may be anonymised and they cannot track your browsing activity on other sites.

Performance cookies(Google analytics cookies) – These cookies remember information about how you and other customers use our website. This gives us vital information such as which pages are visited most often and if customers are receiving error messages from certain pages. The role of these cookies is to allow us to analyse and improve the performance of our website ensuring you receive a consistent look, feel and shopping experience.Performance cookies don’t collect any information that identifies the customer and all information collected is aggregated and therefore anonymous.

Targeting or advertising cookies– These cookies are used to show you Hodson Bay Group Hotels and Partner Hotel advertisements on other websites. This is called ‘retargeting’ and these cookies remember that you have visited our website and the information is shared with other organisations such as third-party advertisers. Third-party advertisers, including Google, use first-party cookies (such as Google Analytics cookie) and third-party cookies (such as the DoubleClick cookie) together to inform, optimise, and serve advertisements based on someone’s past visits to our Website. When one of these adverts is presented to you on a site there will be a quick and easy way to click in and opt out of receiving further adverts.

We use tracking technologies for a variety of reasons

We use tracking tools on our websites and mobile applications. Cookies are common on our websites and are small files that download when you access certain websites. To learn more, visitwww.allaboutcookies.org/ or www.youronlinechoices.eu/. These pages also explain how you can manage and delete cookies. We use tracking tools, including (but not limited to) cookies:

• To recognize new or past customers.
• To store your password if you are registered to our site.
• To improve our website.
• To serve you with interest-based or targeted advertising (see below for more on interest-based advertising).
• To observe your behaviours and browsing activities over time.
• To better understand the interests of our customers and our website visitors.

We engage in interest-based advertising.

We and our partners display interest-based advertising using information gathered about you over time across multiple websites, mobile applications, or other platforms.

Interest-based advertising or “”online behavioural advertising”” includes ads served to you after you leave our website, encouraging you to return. They also include ads we think are relevant based on your shopping habits or online activities. These ads might be served on websites or on apps. They might also be served in emails. We might serve these ads, or third parties may serve ads. They might be about our products or other companies’ products.

How do we gather relevant information about you for interest-based advertising?

To decide what is relevant to you, we use information you make available to us when you interact with us, our affiliates, and other third parties. We gather this information using the tracking tools described above. For example, we or our partners might look at your purchases or browsing behaviours. We might look at these activities on our platforms or the platforms of others.

We work with third parties who help gather this information. These third parties might link your name or email address to other information they collect. That might include past purchases made offline or online. Or, it might include online usage information.

You can control tracking tools and can opt out of interest-based advertising.

In engaging in interest-based advertising, we adhere to the Digital Advertising Alliance’s Self-Regulatory Program for Online Behavioural Advertising, which you can review at www.aboutads.info/principles.

On websites, we typically use cookies to engage in interest-based advertising. Your browser may give you the ability to control cookies. How you do so depends on the type of cookie. Certain browsers can be set to reject browser cookies. To find out more about how to enable, disable, or delete cookies from your web browser, please visitwww.allaboutcookies.org/ and www.adobe.com/devnet/security.html.

To control flash cookies, which we may use on certain websites from time to time, you can go to

 www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html. Why? Because flash cookies cannot be controlled through your browser settings. If you block cookies, certain features on our sites may not work. If you block or reject cookies, not all of the tracking described here will stop. Options you select are browser and device specific.?

In addition, the Self-Regulatory Program for Online Behavioural Advertising program provides consumers with the ability to opt-out of having their online behaviour recorded and used for advertising purposes. To opt out of having participating entities collect your online behaviour for advertising purposes when browsing our websites, visit www.aboutads.info/choices/. To opt out of having participating entities collect your online behaviour for advertising purposes when using our mobile apps, download and use the Digital Advertising Alliance’s “”App Choices”” app. Choices you make are both browser and device-specific.