PRIVACY POLICY;

1. IMPORTANT INFORMATION AND WHO WE ARE
The Hotel York Limited (trading as the Columbia Hotel) is a company incorporated and registered in England & Wales, company number 89315 with its registered office address at 4th Floor, 50 Mark Lane, London EC3R 7QZ.
The Columbia Hotel 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 and tell you about your privacy rights and how the law protects you when you visit our website (regardless of where you visit it from) or attend the Columbia Hotel.

Purpose of this privacy notice:
This privacy notice aims to give you information on how The Columbia Hotel collects and processes your personal data through your use of our website or visit us, including any data you may provide when you visit our website, set up an account with us, purchase products or services and use our services.
We do not knowingly collect data relating to children.

Controller:
The Columbia Hotel is the controller of and is responsible for your personal data (collectively referred to as “The Columbia Hotel”, “we”, “us” or “our” in this privacy notice).
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:
Data Privacy Manager: Luanne Fresco
The Columbia Hotel
Email address: administration@columbiahotel.co.uk
Postal address: The Columbia Hotel, 95-99 Lancaster Gate, London W2 3NS
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 privacy notice was produced 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.
Third-party links
Our 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.

2. THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include anonymous data.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
• Identity Data includes first name, last name, username or similar identifier, marital status, title, date of birth and gender.
• Contact Data includes billing 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 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 purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Visiting Data includes details of when you last visited us, your car registration details, and any preferences expressed by you about your visit.
• 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 may 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.

Special Categories of Personal Data (SCPD) – this may include details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data.
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 services). In this case, we may have to cancel any contract made with you, 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, Visiting and Financial Data and SCPD, by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

• book a bedroom, conference room, dine in our restaurant or drink in our bar;
• request marketing material to be sent to you;
• enter a competition, promotion or survey; or
• make an enquiry via our website;
• give us feedback.

Automated technologies or interactions. As you interact with our website or in house WIFI 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.
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;
• Contact, Financial and Transaction Data from providers of technical, payment and delivery services
• Booking information from booking websites such as:
• Booking.com;
• Expedia;
• other third-party websites who provide booking services.

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:
• For our legitimate Interest: which means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider 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).
• For the performance of a Contract with you: which means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps, at your request, before entering into such a contract.
• To comply with a legal or regulatory obligation: which means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
• Consent: 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.

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.

Promotional offers from us:
We may use your Identity, Contact, Technical, Usage, Profile Data and Visiting 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 products or services from us or and, in each case, you have not opted out of receiving that marketing.

Third-party marketing:
We will get your express opt-in consent before we share your personal data with any company outside the Columbia Hotel.

Opting out:
You can ask us to stop sending you marketing messages at any time by contacting us by emailing administration@columbiahotel.co.uk 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 any product/service purchase, product/service experience or other transactions.

Cookies:
• This Website may place and access certain Cookies on your computer. We use Cookies to improve your experience of using the Website. We have carefully chosen these Cookies and has taken steps to ensure that your privacy is protected and respected at all times.
• All Cookies used by our Website are used in accordance with current UK and EU Cookie Law.
• Before the Website places Cookies on your computer, you will be presented with a message bar requesting your consent to set those Cookies. By giving your consent to the placing of Cookies, you are enabling us to provide a better experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of the Website may not function fully or as intended.
This Website may place the following Cookies:
• Analytical/performance cookies: They 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.
• Functionality cookies: These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
• Targeting cookies: These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
• You can choose to enable or disable Cookies in your Internet browser. By default, most Internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your Internet browser.

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.

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.

5. DISCLOSURES OF YOUR PERSONAL DATA:
We may have to share your personal data with the parties set out below for the purposes set out above.
• External Third Parties:
• Service providers acting as processors based in the EU who provide IT and system administration services.
• Professional advisers including lawyers, bankers, auditors and insurers based in the EU who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, Emergency Services, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances.
• 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. 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.

 6. INTERNATIONAL TRANSFERS:
If we transfer your personal data out of the EEA, we will ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
• 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.

7. 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. 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.

8. 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. We intend to retain your data for 7 years after you last stayed with us, used our services or purchased products from us.
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.

 9. YOUR LEGAL RIGHTS:
 Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). 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 the personal data that we hold about you. 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, we may not always be able to comply with your request for 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 where we are relying on a legitimate interest (or those of a third party) and your particular situation 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 of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) 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 the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. 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.
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 contact administration@columbiahotel.co.uk

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 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.