Privacy Policy

Tower Hotel Management and the Peel Group Privacy Notice

Tower Hotel Management is part of the Peel Group of companies.  Peel respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) or after we have received it in any email correspondence. It will tell you about your privacy rights and how the law protects you.

1. Purpose of this privacy notice

This privacy notice aims to give you information on how Peel collects and processes your personal data through your use of our website, email or our other interactions with you.

Our websites are not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

Controller

Peel Group is made up of different legal entities. This privacy notice is issued on behalf of the Peel Group so when we mention "Peel", "we", "us" or "our" in this privacy notice, we are referring to the relevant company in the Peel Group responsible for processing your data.

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

Contact details

Peel Group
Group Company Secretary
Companysecretarial@peel.co.uk
Peel Dome, intu Trafford Centre, Trafford City, Manchester, M17 8PL
0161 629 8200

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). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy notice and your duty to inform us of changes

This version was last updated in May 2018.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

2. What data do we collect and how do we use it?

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

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.

Contact Data includes billing address, delivery address, email address and telephone numbers.

Financial Data includes bank account and payment card details.

Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.

Technical Data includes internet protocol (IP) address, your email 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.

Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses

Usage Data includes information about how you use our website, products and services

Marketing and Communications Data includes your preferences in receiving 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 notice.

HOTEL GUESTS & GENERAL PUBLIC

The main reasons that we collect data regarding hotel guests users and the general public are:

i) Hotel booking – we receive Identity Data relating to our guests from multiple booking partners or online travel agents, through our franchisors global distributions systems or mobile apps.  When you book your accommodation through one of these channels you will be providing your data to them and they will be a data controller.  You should familiarise yourself with their data privacy controls as we have no control over how they process your data until they provide it to us in the course of reserving your accommodation.

Once we receive your booking, whether from a booking partner or directly from yourself we will process your data on our Property Management System (PMS) and this data will be stored securely on our own servers. 

ii) Loyalty Schemes - Where we operate under a franchised brand, your personal data will be shared with our franchisor, for purposes such as managing the loyalty points scheme. 
 

iii) Food and Beverages –As part of your stay with us you may choose to enjoy our restaurant, or room service.  As a result, we will use your personal information in managing your booking or order.  In some of our hotels we restaurant franchises where our franchisors operate a booking process.  If you use one of these booking services, your identity data will be shared with the booking system operator and our franchisor.

iv) Other guest services – We pride ourselves in providing a personalised service wherever possible and we encourage all of our staff to address you by name wherever possible.  This means that we also share your name with staff and housekeeping services.

In providing this personalisation we also process your personal name on our telephone system and our television information system for the duration of your stay.

v) Providing a safe environment – we need to ensure the safe operation of the hotel and its supporting services and in doing so we will collect personal information in the management of health and safety incidents.  In addition we utilise CCTV within the hotel reception, corridors and service areas and this data is retained for 30 days when it is over written

In providing these services, your data may be shared with official agencies such as the Police if requested through the official procedures.

vi) Logging of day to day accounts – we will collect personal information in the process of managing the hotel and as a result this will produce a paper trail of items, such as registration cards etc.  These are archived securely on a daily basis and retained for up to 18 months to provide an audit trail for our accounts.
 

vii) Marketing and promotions – we may from time to time collect personal information from you to provide you with details of additional services provided by us or by our partners, we only do this with your consent and you are able to withdraw this at any time. 

We also use some of your personal data in our legitimate interests, we do not think that any of the following activities prejudice individuals in any way – in fact, they help us to offer you a more tailored, efficient service. However, you do have the right to object to us processing your personal data on this basis.
 

i) Guest support services – we might collect and hold personal information in providing supporting services, for example:

a.     Managing customer service enquiries

b.     Managing complaints

c.     Managing lost property

d.     Providing you with services if you have reduced mobility

e.     Recording CCTV images

 

SUPPLIERS & COMMERCIAL PARTNERS

The main reasons that we collect data regarding suppliers and commercial partners are:

       i. Managing contractual relationships – We will collect the details for our contacts within your organisation, such as names, telephone numbers and email addresses.  We may also hold extra information that someone in your organisation has chosen to tell us.
 

      ii. Managing finances – We will collect personal information in relation to our Finance processes such as bank details, so that we can pay you. In certain circumstances, such as when you engage with our Finance and Debt Recovery teams, our calls with you may be recorded, depending on the applicable local laws and requirements.
 

     iii. Providing a safe environment – we need to ensure the safe operation of the hotel and in doing so we will collect personal information in the management of health and safety incidents or in managing public order issues.  In addition, we utilise hotel reception, corridors and service areas and this data is retained for 30 days when it is over written.

In providing these services, your data may be shared with official agencies such as the Police if requested through the official procedures.

We also use some of your personal data in our legitimate interests, we do not think that any of the following activities prejudice individuals in any way – in fact, they help us to offer you a more tailored, efficient service. However, you do have the right to object to us processing your personal data on this basis.

       i. Marketing and developing our business – we may from time to time collect personal information from you or other sources to help us to grow our business, such as when you provide us with a business card or we obtain your information from another source. 

      ii. Hotel support services – we might collect and hold personal information in providing supporting services, for example:

a.     Collating and managing business proposals

b.     Recording CCTV images

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

·       apply for our products or services;

·       interact with us via electronic systems (such as email)

·       create an account on our website;

·       subscribe to our service or publications;

·       request marketing to be sent to you;

·       enter a competition, promotion or survey; or

·       give us some feedback.

Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, [server logs] and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.

Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:

·       Technical Data from the following parties:

·       analytics providers such as Google based outside the EU;

·       advertising networks based inside or outside the EU; and

·       search information providers based inside or outside the EU.

Contact, Financial and Transaction Data from providers of technical, payment and delivery services based inside or outside the EU.

Identity and Contact Data from data brokers, aggregators or other referrers based inside or outside the EU.

Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside the EU.

4.      How we use your 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.

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.

Where we need to comply with a legal or regulatory obligation.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us at the address above.

5.      Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

To register you as a new customer

(a) Identity

(b) Contact

Performance of a contract with you

To process and deliver your order including:

(a) Manage payments, fees and charges

(b) Collect and recover money owed to us

(a) Identity

(b) Contact

(c) Financial

(d) Transaction

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to recover debts due to us)

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy

(b) Asking you to leave a review or take a survey

(a) Identity

(b) Contact

(c) Profile

(d) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) (d) Necessary for our legitimate interests (to keep our records updated and to manage our relationships with our suppliers and business contacts)

To enable you to partake in a prize draw, competition or complete a survey

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) 

(a) Identity

(b) Contact

(c) Technical

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(f) Technical

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

(a) Technical

(b) Usage

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

To make suggestions and recommendations to you about goods or services that may be of interest to you

(a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

Necessary for our legitimate interests (to develop our products/services and grow our business)

 

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not already opted out of marketing. This will be restricted to similar products or services and is necessary for our legitimate interests (to develop our products and services and grow our business).

If you provided us with your details when you entered a competition, used our free wi-fi services or registered for a promotion and in the process, have requested marketing information, then you will continue to receive marketing communications until you choose to opt-out.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any company outside the Peel group of companies for marketing purposes and we will explicitly tell you who these companies are at the time.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

6. 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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

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.

7. Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

·       Internal Third Parties

·       External Third Parties

Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. 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 notice.

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.

8. International transfers

There may be occasions where we need to process your data internationally, if we do this regularly it will be noted in this privacy statement.  If we are to do this more occasionally then this may be:

·      to third parties (such as advisers or other Suppliers to our business);

·      to overseas clients

·      to clients within your country who may, in turn, transfer your data internationally;

·      to a cloud-based storage provider; and

·      to other third parties, as referred to here.

We want to make sure that your data are stored and transferred in a secure way. We will therefore only transfer data outside of the European Economic Area or EEA where it is compliant with data protection legislation and the means of transfer provides adequate safeguards in relation to your data, for example:

·       by way of data transfer agreement, incorporating the current standard contractual clauses adopted by the European Commission for the transfer of personal data by data controllers in the EEA to data controllers and processors in jurisdictions without adequate data protection laws; or

·       by signing up to the EU-U.S. Privacy Shield Framework for the transfer of personal data from entities in the EU to entities in the United States of America or any equivalent agreement in respect of other jurisdictions; or

·       transferring your data to a country where there has been a finding of adequacy by the European Commission in respect of that country's levels of data protection via its legislation; or

·       where it is necessary for the conclusion or performance of a contract between ourselves and a third party and the transfer is in your interests for the purposes of that contract (for example, if we need to transfer data outside the EEA in order to meet our obligations under that contract if you are a Client of ours); or

·       where you have consented to the data transfer.

9. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. 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.

10. Data retention

How long will you use my personal data for?

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

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure 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 customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see Request erasure below for further information.

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

11. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data:

·       Request access to your personal data.

·       Request correction of your personal data.

·       Request erasure of your personal data.

·       Object to processing of your personal data.

·       Request restriction of processing your personal data.

·       Request transfer of your personal data.

·       Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us.

No fee usually required

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.

What we may need from you

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 disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

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 have made a number of requests. In this case, we will notify you and keep you updated.