As part of our commitment to meeting your expectations, we have set up a customer privacy protection policy. This formalises our commitments to you and describes how we use your personal data. The main rules applicable are founded on the following principles:

1. CONSENT

“Personal data” means any information collected and logged in a format that allows you to be identified personally, either directly (e.g. name) or indirectly (e.g. telephone number) as a natural person.

2. WHAT PERSONAL DATA IS COLLECTED?

At various times, we will be obliged to ask you, as our customer, for information about you and/or members of your family, such as:

• Contact details (for example, last name, first name, telephone number, email)
• Personal information (for example, date of birth, nationality)
• Information relating to your children (for example, first name, date of birth, age)
• Your credit card number (for transaction and reservation purposes)
• Your arrival and departure dates
• Your preferences and interests (for example, smoking or non-smoking room, preferred floor, type of bedding, type of newspapers/magazines, sports, cultural interests)
• Your questions/comments, during or following a stay in one of our establishments.

The information collected in relation to persons under 18 years of age is limited to their name, nationality and date of birth, which can only be supplied to us by an adult. We would be grateful if you could ensure that your children do not send us any personal data without your consent (particularly via the Internet). If such data is sent, you can contact the Data Privacy department to arrange for this information to be deleted.

We do not deliberately collect sensitive information, such as information concerning race, ethnicity, political opinions, religious and philosophical beliefs, union membership, or details of health or sexual orientation.

Moreover, depending on applicable local laws, other information could be considered sensitive, such as your credit card number, your leisure activities, personal activities and hobbies, and whether or not you are a smoker. We may be obliged to collect such information in order to meet your requirements or provide you with an appropriate service, such as a specific diet.

In this case, depending on the laws in force in certain countries, your prior consent may be required with regard to the collection of sensitive information.

Personal data may be collected on a variety of occasions, including:

1. Hotel activities:

• Booking a room
• Checking-in and paying
• Eating/drinking at the hotel bar or restaurant during a stay
• Requests, complaints and/or disputes.

2. Participation in marketing programmes or events:

• Signing up for loyalty programmes
• Participation in customer surveys (for example, the Guest Satisfaction Survey)
• Online games or competitions
• Subscription to newsletters, in order to receive offers and promotions via email.

3. Transmission of information from third parties:

• Tour operators, travel agencies, GDS reservation systems, and others

4. Internet activities:

• Connection to The Royal Hotel (Bath) Ltd websites (IP address, cookies)
• Online forms (online reservation, questionnaires, The Royal Hotel or The Barn pages on social networks, network login devices such as Facebook login etc.).

3. FOR WHAT PURPOSES?

We collect your personal data for the purposes of:

1. Meeting our obligations to our customers.

2. Managing the reservation of rooms and accommodation requests:

• Creation and storage of legal documents in compliance with accounting standards.

3. Managing your stay:

• Monitoring your use of services (telephone, bar, etc)
• Managing access to rooms
• Internal management of lists of customers having behaved inappropriately during their stay at the hotel (aggressive and anti-social behaviour, non-compliance with the hotel contract, non-compliance with safety regulations, theft, damage and vandalism, or payment incidents).

4. Improving our service, especially:

• Processing your personal data in our customer marketing programme in order to carry out marketing operations, promote brands and gain a better understanding of your requirements and wishes.
• Adapting our products and services to better meet your requirements
• Customising commercial offers and the promotional messages we send to you
• Informing you of special offers and any new services created by us.

5. Managing our relationship with customers before, during and after your visit:

• Managing the loyalty program
• Providing details for the customer database
• Segmentation operations based on reservation history and customer travel preferences with a view to sending targeted communications
• Predicting and anticipating future behaviours
• Developing statistics and commercial scores, and carrying out reporting
• Providing context data for the offer push tool when a customer visits our website or makes a reservation
• Knowing and managing the preferences of new or repeat customers
• Sending you newsletters, promotions and tourist, hotel or service offers, or offers from us.
• Managing requests to unsubscribe from newsletters, promotions, tourist offers and satisfaction surveys
• Taking into account the right to object

6. Use a trusted third party to cross-check, analyse and apply certain devices to your collected data at the time of booking or at the time of your stay, in order to determine your interests and your customer profile, and to allow us to send you personalised offers.

7. Improving our services, especially:

• Carrying out surveys and analyses of questionnaires and customer comments
• Managing claims/complaints
• Offering you the benefits of our loyalty program.

8. Securing and enhancing your use of our websites, especially:

• Improving navigation
• Implementing security and fraud prevention.

9. Conforming to local legislation (for example, storing of accounting documents).

4. CONDITIONS OF THIRD-PARTY ACCESS TO YOUR PERSONAL DATA

Within The Royal Hotel (Bath) Ltd, in order to offer you the best service, we can share your personal data and give access to authorised personnel from the Company, including:

• Restaurant and bar staff
• Reservation staff using our reservation tools
• IT department (if applicable)
• Commercial partners
• Medical services (if applicable)
• Legal services (if applicable)
• Generally, any appropriate person within The Royal Hotel (Bath) Ltd entities for certain specific categories of personal data.

With service providers and partners: your personal data may be sent to a third party for the purposes of supplying you with services and improving your stay, for example

1. External service providers: IT sub-contractors, international call centres, banks, credit card issuers, external lawyers, dispatchers, and printers.

2. Commercial partners: The Royal Hotel (Bath) Ltd, unless you specify otherwise to the Data Privacy department, may enhance your profile by sharing certain personal information with its preferred commercial partners. In this case, a trusted third party may cross-check, analyse and apply certain devices to your data. This data processing will allow The Royal Hotel (Bath) Ltd and its privileged contractual partners to determine your interests and your customer profile, and will allow us to send you personalised offers.

3. Local authorities: We may also be obliged to send your information to local authorities if this is required by law or as part of an inquiry and in accordance with local regulations.

5. DATA SECURITY

The Royal Hotel (Bath) Ltd takes appropriate technical and organisational measures, in accordance with applicable legal provisions, to protect your personal data against illicit or accidental destruction, accidental alteration or loss, and unauthorised access or disclosure. To this end, we have taken technical measures (such as firewalls) and organisational measures (such as a user ID/password system, means of physical protection etc.). When you submit credit card data when making a reservation, direct with us on our website platforms SSL (Secure Socket Layer) encryption technology is used to guarantee a secure transaction.

6. COOKIES

Cookies and local storage may be set and accessed on your computer. Upon your first visit, a cookie or local storage may be sent to your computer that uniquely identifies your browser. “Cookies” and local storage are small files containing a string of characters that is sent to your computer’s browser and stored on your device when you visit a website. Many major Web services use cookies to provide useful features for their users. Each Web site can send its own cookie to your browser. Most browsers are initially set up to accept cookies. You can reset your browser to refuse all cookies or to indicate when a cookie is being sent; however, if you reject cookies, you will not be able to sign in to the Services or take full advantage of our Services. Additionally, if you clear all cookies on your browser at any point after setting your browser to refuse all cookies or indicate when a cookie is being sent, you will have to again reset your browser to refuse all cookies or indicate when a cookie is being sent.

You are advised that the company The Royal Hotel (Bath) Ltd uses cookies or other tracers on its online booking sites.

1. Why have a cookies policy?

With a view to provide information and ensure transparency, The Royal Hotel (Bath) Ltd established this policy so that you can learn more about:

• The origin and purpose of the information processed when you browse The Royal Hotel (Bath) Ltd websites
• Your rights with regard to cookies and other tracers used by The Royal Hotel (Bath) Ltd

2. What is a cookie?

Cookies and other similar tracers are packets of data used by servers to send status information to a user’s browser and return status information to the original server through this same browser.

The status information can be a session identifier, a language, an expiration date, a response field or other types of information.

During their validity period, cookies are used to store status information when a browser accesses various pages of a website or when the browser returns to this website at a later point.

We define Cookies and their purposes with different groups:

Essential cookies
We use essential cookies for the duration of each session (“session cookies”). Session cookies are essential to enable you to securely access the functionalities. Session cookies are deleted when you close your web browser. We strongly recommend that you leave these cookies active, because they enable you to take advantage of the features and functionality of our website.

Performance
These cookies allow us to improve the site’s functionality by tracking usage on the website. In some cases these cookies improve the speed with which we can process your request, allow us to remember site preferences you have selected. Blocking these cookies may result in poorly-tailored recommendations and slow site performance.

Marketing
Marketing cookies (of third parties) collect information to help better tailor marketing to your interests, both within and beyond our websites. Blocking these cookies may result in seeing marketing and or content that is not as relevant to you and require you to refill your information in forms to access resources.

3. Consent

• The installation of certain cookies is subject to your consent. Also, when you first visit the The Royal Hotel (Bath) Ltd websites, you are asked whether you agree to the installation of this type of cookie, which is only activated after your acceptance.
• This process is supported by means of an information banner on the home page of the The Royal Hotel (Bath) Ltd websites, which informs you that by continuing to browse, you are agreeing to the installation of cookies that require consent on your device.
• You can change your mind at any time using the various methods described in section below.

You may reject or disable session cookies by altering the cookie function of your browser. The “help” portion of the toolbar on most browsers will tell you how to stop accepting new cookies, how to be notified when you receive a new cookie, and how to disable existing cookies.

7. STORAGE OF DATA

We retain your personal data only for the period necessary for the purposes set out in this Charter or in accordance with the provisions of applicable law. This includes complying with the current Government guidelines relating to Covid-19 which requires us to retain your name and contact details for 21 days.

8. ACCESS AND MODIFICATION

You have the right to access your personal data collected by The Royal Hotel (Bath) Ltd and to modify it subject to applicable legal provisions.

You may also exercise your right to object by writing to the address below.

In the event of difficulty exercising your rights, please contact The Royal Hotel (Bath) Ltd directly by sending an email to zanres@ntlworld.com or by writing to the address below:

The Royal Hotel (Bath) Ltd
Lyndale
Beechcroft
Chislehurst
Kent
BR7 5BD

Company No. 12805578