BDL Management Guest Privacy Policy

OUR COMMITMENT

As our valued guest (hereinafter “You”), we value your commitment to BDL Management hotels

Our first priority is to offer you exceptional stays at our hotels and we recognise that your privacy forms part of our commitment to our guests.  Our Guest Privacy Policy is outlined below which describes how BDL Management operated hotels use your personal information in accordance with the Data Protection Act (1998).

CONSENT TO THIS HOTEL GUEST PRIVACY POLICY

Please read our Guest Privacy Policy carefully before providing us with any of your “Personal Information” (hereinafter referred to as “PI”), i.e. any information collected and recorded in any format that identifies you personally, whether directly (e.g. name) or indirectly (e.g. phone number).

This Hotel Guest Privacy Policy is part of BDL Management’s terms and conditions governing our hotel services. By accepting said terms and conditions, you expressly consent to this Guest Privacy Policy.

BDL Management operated hotels may use Your PI for marketing purposes. If required by applicable law, you will be requested to give your prior express consent to receive such marketing materials.

BDL MANAGEMENT PRIVACY PRINCIPLES

The following constitute BDL Management’s Privacy Principles.

At BDL Management we will ensure

• Your PI is Fairly and lawfully processed
• Your PI is processed for limited purpose. When collecting and processing Your PI, we will provide You with relevant information and notice, for what purposes and who are the recipients.
• Your PI is adequate, relevant and not excessive. We will only collect PI which is necessary for the purposes of data processing as set out in this Guest Privacy Policy.
• We will take all reasonable measures to ensure that the PI that we have stored is accurate and up to date.
• Your PI is not kept longer than necessary - we will keep Your PI for the period necessary for the purposes of the data processing as set out in this Hotel Guest Privacy Policy and in accordance with local law requirements.
• Your PI is processed in accordance with the individual's rights and we will collect and process your PI only for the purposes mentioned in this Guest Privacy Policy.
• Your PI is secure; and not transferred to countries outside European Economic area unless country has adequate protection for the individual.
• Confidentiality & Security: we will implement reasonable technical and organisational measures to protect Your PI against accidental or unlawful alteration or loss, or from unauthorized use, disclosure or access
• Sharing & International Transfer: we may share Your PI within the BDL Management estate or with third parties (such as commercial partners and service providers) for the purposes described in this Hotel Guest Privacy Policy. We will take appropriate measures to secure such sharing and transfer.

THIS HOTEL GUEST PRIVACY POLICY IS APPLICABLE TO:

Any data processing implemented by BDL Management owned and managed hotels, i.e. hotels which are part of the BDL Management group, including managed hotels, e.g. hotels operating under the following brands Crowne Plaza Hotels & Resorts, Holiday Inn, Holiday Inn Express, Ramada, Ramada Encore, BEST WESTERN, BDL Select and other independent properties.

Any BDL Management web site, i.e. e.g. www.bdlhotels.co.uk and independent hotel websites e.g. www.cpcolchester.co.uk

WHAT PERSONAL INFORMATION IS COLLECTED BY BDL MANAGEMENT?

As a guest at a BDL Management owned and/or managed hotel, You may be asked, at various times, to provide PI about Yourself and Your family members, such as:

• Contact information, e.g. name, telephone numbers, e-mail addresses, postal address etc)
• Other personal details: date of birth & nationality
• Children Information: name, birth date and age;
• Credit card details (only in transactional related system)
• Membership card numbers of any loyalty program or any membership number of frequent flyer or any BDL Management Partner. This may include but is not limited to, IHG Priority Club & Wyndham Rewards or a BDL specific loyalty programme.
• Your dates of arrival and departure/visit from our hotels; type of room booked, length of your stay, cost of your stay, promotional off used, information regarding any agent used to book your stay  with us and your company name (if applicable)
• Your preferences and interests, e.g. smoking or non-smoking room, preferred location of Your room (low floor, high floor, etc.), type of bed, preferred newspaper, sports and cultural interests;
• Any questions/comments you may have during or after your stay in one of our hotels.

We do not knowingly collect PI from children under the age of 18, except name, date of birth and nationality as provided directly by an adult on their behalf or with adult’s permission.  Please make sure that Your children do not provide us with any PI without Your permission, e.g. online. If you believe your child has submitted PI to us, please contact us so that we can delete such PI.

Generally, we do not knowingly collect sensitive information such as racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health or sex life details.

In addition, depending on the applicable law, other data than those listed above may also be considered as sensitive data: credit card number, leisure habits, personal activities and hobbies, cultural habits, smoker/ non-smoker status, etc. However, we may need to collect such data which may be considered as sensitive, to satisfy Your request or provide You with specific services such as specific diet or any disability access facilities. In such case, if required by applicable law, we will ask You to expressly consent that we collect and process such sensitive information.

WHEN IS MY PERSONAL INFORMATION COLLECTED?

PI may be collected in certain circumstances including without limitation as follows:

Hospitality activities such as:

• Booking of an hotel room;
• Check in and check out;
• Consumption during a stay in an hotel as tracked through room charges;
• Claims, requests and/or disputes.
• Participation in marketing programs:
• Registering with loyalty programs;
• Contribution to guests surveys and/or comments (e.g. “Guest Satisfaction Survey”, “Contact us”; “Guests comments”; “
• Contests;
• Subscription to newsletters, to receive e-mail offers or promotions.
• Provision of information by third party service providers:
• Tour operators, travel agencies, GDS reservation systems, others,
• Internet activities:
• Connection to any BDL Management websites (IP address, session cookies);
• Fill in of an online collection form (e.g. online bookings, questionnaire, etc.).

WHAT ARE THE PURPOSES?

We use Your PI for the following purposes:

• To manage Your reservation and booking:
• To book and reserve hotel rooms and requested accommodation;
• To establish and maintain business records and comply with accounting requirements;
• For back office processing; including managing a list of undesirable guests, further to a non-payment, or to improper behaviour, etc.
• To manage Your stay at the hotel:
• To track consumption (telephone, bar, Internet, pay TV…);
• To access rooms.
• To improve our hospitality services, including:
• To process Your PI in the BDL Management Clients Relationship Management (CRM) program;
• To better understand Your needs and requests;
• To tailor our products and services to better suit your desires.
• To send you newsletters, promotions and marketing material or contact you about tourism, hospitality or services, hotel promotions, or about BDL Management partners.
• You can choose to unsubscribe from our Email Newsletters service by clicking a link in one of our email newsletters.

To improve our services, including:

• To conduct surveys and analyze guests’ questionnaires and comments and activity patterns
• To manage guests’ complaints.
• To let you benefit from our loyalty program
• To secure and improve Your use of Internet websites, including:
• To improve website navigation and;
• To implement security and fraud prevention means.
• To comply with local regulations (e.g. retention of business or accounting documents).

SHARING OF YOUR PERSONAL INFORMATION

At BDL Management, we wish to offer you the same level of service and hospitality across all our owned and managed properties across the UK.

To this end, subject to your rights set forth below, we may have to share Your PI with internal or external recipients in the following ways:

The BDL Management estate: we may share Your PI with any BDL Management owned or managed entity or authorized individuals who need to access Your PI to provide You with the requested services or in the context of an action as a consequence of You providing such PI.

This may include (but is not limited to)

• Hotel Staff
• Reservation Staff using BDL Management reservation tools
• Information Technology, commercial partnership and marketing departments
• Medical services, if any
• Legal Department, if necessary
• Any relevant individuals of the BDL Management entities for specific categories of data.
• External service providers and partners: we may share Your PI with third parties for providing you with the requested services and improving Your stay with us
• Local authorities – internal investigations: we may also share information with local authorities if required by local law or as part of internal investigations within the BDL Management estate in compliance with local regulations.

INTERNATIONAL TRANSFERS

We may transfer Your PI to recipients, internal or external, which may be located in countries with different levels of PI protection.

Therefore, in addition to the implementation of the present Hotel Guest Privacy Policy, BDL Management implements appropriate measures, including contractual clauses, to secure transfer of Your PI to any BDL Management entity or external recipient located in a country with a level of protection different from the one existing in the country in which the PI is collected.

DATA SECURITY

BDL Management takes appropriate technical and organisational measures, in accordance with local law requirements, to protect Your PI against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure or access. To this end, we have implemented technical measures such as firewalls and organisational measures such as a login/efficient password system, physical protection, etc.

You may have to enter your credit card details to complete your reservations; in such event, BDL Management uses Secure Socket Layer (SSL) technology to encrypt such PI.

SESSION COOKIES/EXTERNAL LINKS

BDL Management uses persistent cookies to manage your session on BDL Management owned and managed websites and to personalize your online experience (automatic recognition, list of your favourite hotels, etc.)

We also collect technical information on your computer each time you open a page during your visit to our sites. This information includes Your IP (Internet Protocol) address, the operating system used, the type of browser, the screen resolution and the origin website address, as needed. We collect this information to improve the quality of your visit to our site and do not sell or transfer this information to third parties. These temporary cookies are a built-in feature of the technology used. Most browsers automatically accept these cookies, but you can delete them or have them automatically refused. As each browser is different, you should refer to the “Help” section on your browser toolbar to find out how to set your preferences regarding cookies. However, you may not be able to use certain features on our site if you choose not to accept cookies.

BDL Management takes no responsibility for any privacy policies or practices of any third-parties’ web sites accessible from BDL Management’s websites.

DATA STORAGE

We will store Your PI only for the time necessary for the purposes stated in this Hotel Guest Privacy Policy, or as permitted by the applicable law.

ACCESS AND MODIFICATION

You have the right to access, modify or delete Your PI.

You can also object to the processing of Your PI as described in this Hotel Guest Privacy Policy provided that you have legitimate reasons.

However, please note that if you object, we may in certain circumstances be unable to provide you with the service requested.

If you wish to exercise your rights on Your PI held by a specific hotel, then you must contact the hotel directly.

To object to the processing of Your PI for marketing purposes or if You encounter any problem when exercising Your rights, You can contact the dedicated Guest Data Services department of the BDL Management Group, contactable on 00 44 (0) 141 419 4567 or at Guest Data Services, Central Marketing Team, BDL Management, 40 Brand Street, Glasgow, Scotland, United Kingdom, G51 1DG.

In the interests of protecting the privacy of all the BDL Management Group’s guests, we will need to identify you properly prior to responding to your request. To this end, we may request a copy of a valid identification paper such as a current driver's licence, identity card or passport.

If your PI is not accurate, complete or up to date, please provide the BDL Management Dpt. Data Privacy with Your request for correction. Any requests for correction will be dealt with as soon as practicable or in compliance with applicable law at the contact details outlined above.

UPDATES

We may amend this Hotel Guest Privacy Policy from time to time as indicated below. Therefore, we invite you to read this Hotel Guest Privacy Policy regularly and in any event when making a reservation in one of our Hotels. This Hotel Guest Privacy Policy was last updated on August 2012.

QUESTIONS / CONTACT

If You have any questions about this Hotel Guest Privacy Policy or how BDL Management processes Your PI in general, please contact us at the dedicated Guest Data Services department of the BDL Management Group, contactable on 00 44 (0) 141 419 4567 or at Guest Data Services, Central Marketing Team, BDL Management, 40 Brand Street, Glasgow, Scotland, United Kingdom, G51 1DG.