Privacy Policy

BACKGROUND:

Hempstead House Hotel and Aquamanda Spa understands that your privacy is important to you and that you care about how your personal data is used and shared. We respect and value the privacy of everyone who provides their personal data and will only collect and use personal data in ways that are described here, and in a manner that is consistent with Our obligations and your rights under the law.

This policy outlines the types of personal data we may collect about you when you contact and interact with us.  It also explains how we store, handle and protect your data, and to ensure you are fully informed of your rights.

1. Definitions and Interpretation

In this Policy, the following terms shall have the following meanings: 

“Account”

means an account created when booking/making a reservation with us and/or required to access and/or use certain areas and features of Our website

“Cookie”

means a small text file placed on your computer or device by Our website when you visit certain parts of Our website and/or when you use certain features of Our website. Details of the Cookies used by Our website are set out in section 16, below

“Cookie Law”

means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003

“personal data”

means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. This definition shall, where applicable, incorporate the definitions provided in the Data Protection Act 1998 and EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”)

“We/Us/Our”

means Hempstead House Restaurant Limited, a limited company registered in England under company number 3493654, whose registered and trading address is Hempstead House, London Road, Bapchild, Sittingbourne, Kent, ME9 9PP

2. Information About Us

2.1 Hempstead House is a limited company which includes Aquamanda registered in England under company number 3493654, whose registered and trading address is Hempstead House, London Road, Bapchild, Sittingbourne, Kent, ME9 9PP.

2.2 Our VAT number is 624792325.

2.3 Our Data Protection Officer can be contacted by email at info@hempsteadhouse.co.uk, by telephone on 01795428020, or by post at Hempstead House Hotel, London Road, Bapchild, Sittingbourne, Kent, ME9 9PP.

3. What Does This Policy Cover?

3.1 This Privacy Policy outlines the types of personal data we may collect about you when you contact us.  It also explains how we store, handle and protect your data.

3.2 Our website may contain links to other websites. Please note that we have no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.

4. Your Rights

4.1 As a data subject, you have the following rights under the GDPR, which this Policy and Our use of personal data have been designed to uphold:

4.1.1 The right to be informed about Our collection and use of personal data;

4.1.2 The right of access to the personal data We hold about you (see section 15);

4.1.3 The right to rectification if any personal data We hold about you is inaccurate or incomplete (please contact Us using the details in section 17);

4.1.4 The right to be forgotten – i.e. the right to ask Us to delete any personal data We hold about you (We only hold your personal data for a limited time, as explained in section 6 but if you would like Us to     delete it sooner, please contact Us using the details in section 17);

4.1.5 The right to restrict (i.e. prevent) the processing of your personal data;

4.1.6 The right to data portability (obtaining a copy of your personal data to    re-use with another service or organisation);

4.1.7 The right to object to Us using your personal data for particular purposes; and

4.1.8 Rights with respect to automated decision making and profiling.

4.2 If you have any cause for complaint about Our use of your personal data, please contact Us using the details provided in section 17 and We will do Our best to solve the problem for you. If We are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.

4.3 For further information about your rights, please contact the Information     Commissioner’s Office or your local Citizens Advice Bureau.

5. What Data Do We Collect?

5.1 We process personal data for a number of different purposes, which are explained below, We may collect some or all of the following personal and non-personal data:

5.2 Brasserie reservation

The following personal information is required in order for Us to make a reservation in Our Brasserie:

  • Booking name
  • Contact telephone number
  • In order to provide you with the best possible experience, we may also collect and process additional personal information, including the following:
  • Any special occasions i.e. birthdays (excluding year of birth), anniversaries and that of the guest(s)
  • Allergies and food intolerances
  • Any personal connections to a member of staff
  • Any previous booking history
  • Where a booking is made on behalf of a company, the company name and contact details
  • The age of any children

5.3 Private Dining

The following personal information is required in order for Us to make a reservation for private use of our Brasserie:

  • Reservation name
  • E-mail address
  • Telephone number
  • Credit/debit card details

In order to provide you with the best possible experience, we may also collect and process additional personal information, including the following:

  • Any special occasions i.e. birthdays (excluding year of birth), anniversaries and that of the guest(s)
  • Allergies and food intolerances
  • Any personal connections to a member of staff
  • Any previous booking history
  • Where a booking is made on behalf of a company, the company name and contact detail
  • The age of any children

5.4 Spa treatment

The following personal information is required in order for Us to make a reservation for a spa treatment:

  • Guest name
  • Contact telephone number and/or email address
  • Previous treatment history
  • Previous purchasing history

Prior to the appointment the Health Assessment Form and the health information on it, and the emergency contact information you provide, will be used by the hotel in order to ensure the safety of our guests when using the spa services, and in the event of an emergency. The health information includes Special Categories of Personal Data, which will not be provided to any third parties or used for any other purpose.

5.5 Aquamanda membership

The following personal information is required in order for you to become a member of Aquamanda Spa:

  • Member name
  • Contact telephone number or email address
  • Address
  • Guest pass name(s) (if applicable)
  • Credit/debit card payment detail

Upon joining, the Health Assessment Form and the health information on it, and the emergency contact information you provide, will be used by the hotel in order to ensure the safety of our guests when using the spa services, and in the event of an emergency. The health information includes Special Categories of Personal Data, which will not be provided to any third parties or used for any other purpose.

5.6 Aquamanda voucher

The following personal information is required in order for you to purchase an Aquamanda voucher

  • Name of recipient
  • Contact telephone number or email address of purchaser
  • Purchaser name
  • Credit/debit card payment details

5.7 Online bookings or enquiries made via our website

The following personal information is required when making a booking or enquiry via our website:

5.7.1   Name;

5.7.2   Business/company name

5.7.4   Contact information such as email addresses and telephone         numbers

5.7.6   Financial information is collected via third party;

5.7.7   IP address;

5.7.8   Web browser type and version;

5.7.9   Operating system;

5..10   A list of URLs starting with a referring site, your activity on Our Site, and the site you exit to.

(please also see section 16 on Our use of Cookies and similar technologies)

6. How Do We Collect Your Personal Data?

6.1 Your personal data is collected from you in the following ways:

6.1 Phone

6.1.2 E-mail

6.1.3 Our website www.aquamanda.co.uk

6.1.4 In person

6.1.5 Social media

6.1.6 Via a third party, which may include:

  • Travel agents, booking agents, other agents and tour operators
  • Corporate customers
  • Comparison and review websites
  • Social networks
  • Government and law enforcement agencies
  • Other hotel providers and other organisations as part of their contingency plans
  •  

Why Do We Collect and Process Your Personal Data and How Do We Use it?

7.1 All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under the Data Protection Act 1998 and GDPR at all times. For more details on security see section 9, below.

7.2 Our use of your personal data will always have a lawful basis, either because      it is necessary for Our performance of a contract with you, because you have        consented to Our use of your personal data (e.g. by subscribing to emails), or        because it is in Our legitimate interests. Specifically, We may use your data          for the following purposes:

7.2.1 To deal with an enquiry

7.2.2  Providing and managing your Account and/or booking, including processing and storing your payment details;

7.2.3  Supplying Our products and services to you (please note that We require your personal data in order to enter into a contract with you);

7.2.4  Replying to contact you have made with us;

7.2.5  Supplying you with marketing emails that you have opted into (you may unsubscribe or opt-out at any time by using the unsubscribe link found in all our marketing emails)

7.2.6  To fulfil the requirements of the booking made

7.2.7  To collect guest/customer feedback to improve our guest experience

7.2.8  To respond to any complaints or comments posted on social media about our business

7.2.9 To prevent and detect crime as well as protect our guests, employees, business and premises,

7.3  With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email, telephone and text message with information, news and offers on Our products and services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the Data Protection Act 1998 and GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003.

7.4 Third parties whose content appears on Our Site may use third party Cookies, as detailed below in section 16. Please refer to section 16 for more information on controlling Cookies. Please note that We do not control the activities of such third parties, nor the data they collect and use and advise you to check the privacy policies of any such third parties.

7.5 Where you have given consent, you have the right to withdraw it at any time, and to request that we delete it.

7.6 We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Data will therefore be retained for no longer than necessary.

8. What is The Legal Basis Gor The Use of Personal Data?

8.1 To fulfil a contact. 

This applies when you want to make a booking/becoming a member with us and includes:

8.1.1 Making, amending or administering your booking

8.1.2 Providing additional services at your request

8.1.3 To verify your identity

8.1.4 To process payments

8.1.5 To communicate with you

8.1.6 To provide customer services, including managing complaints

If the information we request to complete your booking/membership is not provided, we may not be able to enter into a contract with you.

8.2 In our legitimate interests this includes:

8.2.1 To protect our business and prevent fraud

8.2.2 Ensuring customer satisfaction and dispute resolution

8.2.3 The safety and security of our guests, employees, business and      premises, including the use of CCTV

8.2.4 Marketing services and events

8.2.5 Legal and regulatory purposes

8.3 Where you have given your consent 

8.3.1    Marketing

8.3.2   Where information is provided regarding dietary, accessibility and allergy   information you or a member of your party on your behalf provides to us (we may also be able to do this where it is in your vital interests).

8.3.3 You have the right to withdraw your consent at any time.

8.5  Where there is a legal requirement 

8.5.1 To record details of guests not resident in the UK

8.5.2 In response to requests by government, law enforcement authorities or      intelligence services and court orders

8.5.3 To comply with health and safety legislation

8.6  To protect your vital interests or those of another person

8.6.1    Disclose your personal data to the emergency services where we believe it is necessary to protect your vital interests or the vital interests of another person

8.6.2    Where you (or someone acting on your behalf) provide us with dietary, allergy, accessibility information/data

9. How and Where Do We Store Your Data?

9.1 We only keep your personal data for as long as We need to in order to use it as described above in section 6, and/or for as long as We have your permission to keep it.

9.2 Data security is very important to Us, and to protect your data We have taken suitable measures to safeguard and secure data collected through Our Site.

9.3 Steps We take to secure and protect your data include:

9.3.1 Up-to-date and secure IT systems;

9.3.2 An SSL Certificate on Our website;

9.3.3 Internal policies and procedures.

‚Äč10. Do We Share Your Data?

10.1  We work with a number of trusted and contracted third parties in order to be able to provide our goods and services to you.  These third parties include (but are not limited to) those who provide services to us for the delivery of goods, restaurant and hotel bookings and business systems providers. 

10.2  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 provides to use your personal data for their own purposes and only permit them to process your data for specified purposes and in accordance with our instructions.

10.3  Some of our external service providers are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.  Whenever we transfer your personal data out of the EEA we ensure a similar degree of protection is afforded to it by ensuring at lease one of the following safeguards is implemented:

10.3.1 Use specific contracts approved by the European Commission which                     gives personal data the same protection it has in the EEA.

10.3.2 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 EEA and US.

10.4  We do not share or sell your data to third parties for marketing purposes or for any purposes other than those explained in this privacy policy, without your consent.

10.5  We do not purchase personal data from third parties.

10.6  We may sometimes contract with third parties to supply products and services to you on Our behalf. These may include payment processing, delivery of goods, search engine facilities, advertising, and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law.

10.7  We may compile statistics about the use of Our Website including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymised and will not include any personally identifying data, or any anonymised data that can be combined with other data and used to identify you. We may from time to time share such data with third parties such as prospective investors, affiliates, partners, and advertisers. Data will only be shared and used within the bounds of the law.

10.8  In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal requirements, a court order, or a governmental authority.

11. How Long Do We Retain Your Data

11.1  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.

11.2  The period for which we will retain your personal data depends on the purposes for which we are processing it.

12. What Happens If Our Business Changes Hands?

12.1 We may, from time to time, expand or reduce Our business and this may involve the sale and/or the transfer of control of all or part of Our business. Any personal data that you have provided will, where it is relevant to any part of Our business that is being transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use that data only for the same purposes for which it was originally collected by Us.

12.2 In the event that any of your data is to be transferred in such a manner, you will not be contacted in advance and informed of the changes. When contacted you will not, however, be given the choice to have your data deleted or withheld from the new owner or controller.

13. How Can You Control Your Data?

13.1 When you submit personal data you may be given options to restrict Our use of your data. In particular, We aim to give you strong controls on Our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails and at the point of providing your details).

13.2 You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.

14. Your Right to Withhold Information

14.1 You may access certain areas of Our website without providing any data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.

14.2 YOu may restrict Our use of Cookies. For more information, see section 16.

15. How Can You Access Your Data?

15.1 You have the right to ask for a copy of any of your personal data held by Us (where such data is held).  Under the GDPR, no fee is payable and We will provide any and all information in response to your request free of charge.  However, we may impose a ‘reasonable fee’ to comply with requests for further copies of the same information and when a request is manifestly unfounded, excessive or repetitive.  Please contact Us for more details at info@hempstadhouse.co.uk, or using the contact details below in section 17.

16. Our Use of Cookies

16.1 Our Site may place and access certain first party Cookies on your computer or device. First party Cookies are those placed directly by Us and are used only by Us. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve Our products and services. We have carefully chosen these Cookies and have taken steps to ensure that your privacy and personal data is protected and respected at all times.

16.2 By using Our Site you may also receive certain third party Cookies on your computer or device. Third party Cookies are those placed by websites, services, and/or parties other than Us. For more details, please refer to section 6, above, and to section 16.6 below. These Cookies are not integral to the functioning of Our Site and your use and experience of Our Site will not be impaired by refusing consent to them.

16.3 All Cookies used by and on Our Site are used in accordance with current Cookie Law.

16.4 Before Cookies are placed on your computer or device, you will be shown a pop-up requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling Us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Site may not function fully or as intended.

16.5 Certain features of Our Site depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are shown below in section 16.6. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings as detailed below in section 16.10, but please be aware that Our Site may not work properly if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.

16.6 The following first party Cookies may be placed on your computer or device:

Name of Cookie

Purpose

Strictly Necessary

PHPSESSID

A general-purpose identifier used to maintain user session variables, such as logged-in status for a user.

YES

CookieConsent

Used to store your cookie consent state.

YES

JSESSIONID

Used for session management.

YES

and the following third party cookies may be placed on your computer or device:

Name of Cookie

Provider

Purpose

ai_session

uk2.roomlynx.net

Used to preserve user states across page requests.

16.7 Our Site uses analytics services provided by Google Analytics. Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling Us to better understand how Our Site is used. This, in turn, enables Us to improve Our Site and the products and services offered through it. You do not have to allow Us to use these Cookies, however whilst Our use of them does not pose any risk to your privacy or your safe use of Our Site, it does enable Us to continually improve Our Site, making it a better and more useful experience for you.

16.8 The analytics service(s) used by Our Site use(s) Cookies to gather the required information.

16.9 The analytics service(s) used by Our Site use(s) the following Cookies:

Name of Cookie

First / Third Party

Provider

Purpose

_ga

First

Google Analytics

Used to register a unique ID that is used to generate statistical data on how a visitor uses the website.

_gid

First

Google Analytics

Used to register a unique ID that is used to generate statistical data on how a visitor uses the website.

_gat

First

Google Analytics

Used by Google Analytics to throttle request rate.

collect

First

Google Analytics

Used to send data to Google Analytics about the visitor's device and behaviour.

16.10 In addition to the controls that We provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third party Cookies. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.

16.11 You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.

16.12 It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.

17. Contacting Us

17.1 If you have any questions about Our Site or this Privacy Policy, please contact Us by email at info@hempsteadhouse.co.uk, by telephone on 01795 428020, or by post at Hempstead House Hotel, London Road, Bapchild, Sittingbourne, Kent, ME9 9PP. Please ensure that your query is clear, particularly if it is a request for information about the data We hold about you (as under section 15, above).

18. Changes to Our Privacy Policy

18.1 We may change this Privacy Policy from time to time (for example, if the law changes). Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date.

 

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