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    Welcome to the privacy policy of Imperial London Hotels Limited. 

    Imperial London Hotels Limited 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) and tell you about your privacy rights and how the law protects you. 

    1. Important information and who we are

    Purpose of this privacy notice

    This privacy notice aims to give you information on how we collect and process your personal data through your use of this website (including our mobile site) and our mobile app, including any data you may provide through either when you sign up to our newsletter, purchase a product or service or take part in a competition organised by us. 

    Whilst this website and our app are not intended to be used by children, there may be situations whereby we collect the personal data of a child (i.e. where a child makes use of our digital key feature via our app). If this is the case, we will ensure that an appropriate lawful basis for processing their data applies and appropriate security measures are in place. 

    Controller

    Imperial London Hotels Limited is made up of different legal entities. This privacy notice is issued on behalf of Imperial London Hotels Limited’s group, therefore any mention of "Imperial", "we", "us" or "our" in this privacy notice is to include the relevant company in the Imperial group responsible for processing your data. Imperial London Hotels Limited is the controller and responsible for this website and our mobile app. 

    Third-party links

    This 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. 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, maiden name, last name, username or similar identifier, marital status, title, date of birth, gender, and CCTV images.

    · 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, media access control (MAC) address, your login data, browser type and version, browsing history,  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 and app. 

    · 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, app, [AW2] 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. 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.

    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;

    · subscribe to our service or publications; 

    · request marketing to be sent to you;

    · enter a competition, promotion or survey; 

    · make use of our mobile app; or

    · provide us with feedback of any kind. 

    · Automated technologies or interactions. As you interact with our website and app, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. A cookie is a small file that can be stored by your browser on your computers hard drive. Cookies may be used to compile anonymous statistics related to the use of services or patterns of browsing. When used in this manner you are not individually identified and data collected in this manner is only used in aggregate. You can usually change your browser's settings so that it will not accept cookies, although this may restrict some website functionality. We may also receive Technical Data about you if you visit other websites employing our cookies.

    · Third parties. We may from time to time receive Identity Data, Contact Data, Financial Data and Transaction Data about you from various third parties who introduce you to us for the purposes of us providing you with our products or services. Data received from third parties will enjoy the same security as data collected directly by us. 

    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 you have provided your express consent to our processing. 

    · 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.

    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 usif 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)

    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, this website and our app (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 and app 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, app, 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 and app 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)
    To allow you to make full use of our mobile app during the course of our relationship  (a) Identity

    (b) Contact

    (c) Technical

    (e) Profile

    (d) Usage

    (a) Performance of a contract with you

    (b) Necessary for our legitimate interests (for assisting in the operation of our business and showing how customers use our products/services)

    Marketing 

    We aim to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms for your attention:

    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 may receive marketing communications from us if you have requested information from us or purchased goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion 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 Imperial’s group of companies for marketing purposes. You can ask us to stop sending you marketing messages at any time by contacting usat 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, service or other transaction.

    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.

    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 in the table in paragraph 4 above.

    External Third Parties, including: 

    · Service providers acting as processors based within and outside the EEA who provide IT and system administration services;

    · Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based within and outside the EEA who provide consultancy, banking, legal, insurance and accounting services;

    · Logistics providers who we use to deliver our products or product samples;

    · HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances; and

    · 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.

    6. International transfers

    We do not transfer your personal data outside the European Economic Area.

    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. For example, your data is kept confidential through encryption (we use the 128-bit secure sockets layer, or SSL, standard). We also do not retain live records of your credit card information on our servers after the transaction has been completed. 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. 

    8. Data retention

    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. 

    Notwithstanding your legal rights (as set out below), we will apply the following data retention policy to your personal data, after which your personal data will be securely disposed of: 

    · Personal data obtained for the performance of a contract with you: for a period of 28 calendar months following either (i) the date we obtained your personal data or (ii) the date in which you provided your consent to us processing your personal data, whichever is later. 

    · Personal data obtained for the purposes of marketing (via consent): for a period of 19 months. 

    If you wish to find out more about our data retention policy please contact our DPM.   

    9. Your legal rights

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

    · Request access. 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. 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. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it or if you have exercised your right to object to processing. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you 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 there is something about your particular situation which 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. 

    · Request restriction of processing. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us 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. Note that 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. 

    You will not have to pay a fee to exercise these 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.

    If you wish to exercise any of the rights set out above, please contact privacy@imperialhotels.co.uk.  

    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.

    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. 

    Web Accessibility

    Imperial Hotels has developed this website to serve the largest possible audience by addressing the needs of people and systems with differing abilities. The site conforms to the Web Accessibility Initiative of the World Wide Web Consortium level 1.

    Data Protection Manager

    We have appointed a data privacy manager (DPM) 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 DPM using the following details:.

    Email address: privacy@imperialhotels.co.uk

    Postal address:  38-51 Bedford Way, London, WC1H 0DG

    Complaints

    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 and we will endeavour to address your concerns. 

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

    This version was last updated on 25 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.

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