1. WHO ARE WE?
This Site is operated by Brownber Limited, a company registered in England and Wales under registration number 09983779 and our registered address is Fifteen Rosehill Montgomery Way, Rosehill Estate, Carlisle, Cumbria, United Kingdom, CA1 2RW (“we” “us” and “our” being interpreted accordingly).
By using our Site or submitting your personal data you are taken to accept the terms of this Policy, so please read it carefully.
3. HOW DO WE COLLECT DATA ABOUT YOU?
We collect or obtain your information:
· When you provide it to us (e.g. by contacting us when making a booking, by booking a room through our website or a third party booking channel, in person during your stay and or by signing up to our newsletter);
· From third parties who may contact us in order to make a booking on your behalf;
· From your use of our website, using cookies, Google Adwords and Facebook custom audience targeting and Facebook conversion tracking.
4. WHAT PERSONAL DATA MAY WE COLLECT?
We may collect the following personal data about you:
· Personal contact details (such as name, home address, email address; business address and phone number);
· Additional personal details you choose to provide us with when corresponding with us by phone, e-mail, through this Site or when you visit our premises, which relate directly to your booking;
· Information about your debit/credit card and or bank account information that we require for the purpose of recording and processing your booking. For further details please also refer to the section below headed PAYMENT INFORMATION.
· Data about your use of our website and services, such as: IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use.
5. HOW WE USE YOUR DATA
We may use your personal data in the following ways:
· For administrative and business purposes directly relating to a contractual agreement that we have with you.
· To administer our Site and ensure that our Site is presented in the most effective manner for you and for your computer/device. Data will be used in this way in so far as it is necessary for our legitimate interests.
· For internal business/technical operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes and as part of our efforts to keep our Site secure. Data will be used in this way in so far as it is necessary for our legitimate interests.
· For advertising on third party websites (including Google) to previous visitors to this Site. Data will be used in this way in so far as it is necessary for our legitimate interests.
· To send out newsletters to opted-in subscribers, using third party marketing platform MailChimp. We will only process your personal data in this way where your consent has been given enabling us to do so.
Contact information will be retained and used from opted-in subscribers who have given their consent, to enable us to provide updates, send out newsletters and other marketing material relating to Brownber Hall.
As part of this agreement, your personal data will be transferred to and processed by MailChimp, enabling us to distribute email marketing campaigns. You will be able to unsubscribe at any time via the unsubscribe option at the footer of our newsletter.
7. COOKIES, GOOGLE ADWORDS & FACEBOOK
· Our Site stores a number of different cookies on the computer or device that you use to access our website. Cookies are small text files used by browsers to store small bits of information about a device or computer, such as preferred settings or preferred languages.
· Cookies do not take up much space (unless you have thousands of them) and cannot contain viruses or other harmful code.
· The ICO has categorised all cookies into to four classes:
Category 1: strictly necessary cookies
These cookies are essential in order to enable you to move around the website and use its features, such as accessing secure areas of the website. Without these cookies services you have asked for, like shopping baskets or e-billing, cannot be provided.
Category 2: performance cookies
These cookies collect information about how visitors use a website, for instance which pages visitors go to most often, and if they get error messages from web pages. These cookies don't collect information that identifies a visitor. All information these cookies collect is aggregated and therefore anonymous. It is only used to improve how a website works.
Category 3: functionality cookies
These cookies allow the website to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features. For instance, a website may be able to provide you with local weather reports or traffic news by storing in a cookie the region in which you are currently located. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customise. They may also be used to provide services you have asked for such as watching a video or commenting on a blog. The information these cookies collect may be anonymised and they cannot track your browsing activity on other websites.
Category 4: targeting cookies or advertising cookies
These cookies are used to deliver adverts more relevant to you and your interests They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaign. They are usually placed by advertising networks with the website operator's permission. They remember that you have visited a website and this information is shared with other organisations such as advertisers. Quite often targeting or advertising cookies will be linked to site functionality provided by the other organisation.
· The majority of our cookies are category 2 cookies, although other websites/services that we use, such as Facebook, may store category 3 cookies on your computer when you visit our website or share content.
· You can set preferences for how Google advertises to you using the Google Ad Preferences page, and if you want to you can opt out of interest-based advertising entirely by cookie settings or permanently using a browser plugin.
8. DISCLOSURE OF YOUR INFORMATION TO THIRD PARTIES
We will only disclose your information to the extent necessary:
o To run our business;
o To fulfil any contract that we enter into with you;
o Where we are required to do so by law;
o To enforce our legal rights;
o To protect us, our contractors or our guests against loss or damage.
We will not sell your personal information to any third parties.
9. HOW LONG DO WE KEEP YOUR DATA FOR?
We will keep your data for no longer than necessary, taking into account any legal obligations we have (e.g. to maintain records for tax purposes) and any other legal basis we have for using your personal data.
10. PAYMENT INFORMATION
Any credit/debit card payments and other payments you make through this Site will be processed by our third party payment provider. The payment data you submit will be securely stored and encrypted by our payment service provider using up to date industry standards. Please note, we do not ourselves directly process or store the debit/credit card data that you submit.
We may arrange that the card or payment data you submit is stored for the purpose of processing your booking and collecting the payment. Please note, this data may be stored for future use.
We may also store and use this card or payment information for the purpose of processing any future payments that you make for additional goods and services. We will store this data in accordance with our legal obligations under applicable law and only for so long as legally permitted.
You may choose to opt-out of us holding your card or payment data although this means that you will need to re-supply us with card/payment details for any future bookings.
The personal data that we collect from you may be transferred to and stored at a destination outside the European Economic Area (“EEA”) such as by our subcontractors in the United States who process your payment details and/or provide IT support services. In accordance with applicable law, we will do everything we reasonably can to make sure that those subcontractors comply with appropriate security standards to protect the personal data that they handle.
Unfortunately, the transmission of information over the internet or public communications networks can never be completely secure. We will take appropriate technical and organisational security measures to protect the personal data that you submit to us against unauthorised/unlawful access or loss, destruction or damage, although we cannot 100% guarantee the security of data that you provide to us online.
12. YOUR DATA PROTECTION RIGHTS
You have a right to access a copy of the Data which we hold about you. If you would like to do this, please email us at firstname.lastname@example.org, putting the subject matter in the email header, or write to us at Brownber Hall, Newbiggin-on-Lune, Kirkby Stephen, Cumbria, CA17 4NX. Any subject access request may be subject to a small fee to meet our administrative costs. We may also need to ask you for further information to verify your identity before we can respond to any request. We will provide your Data within thirty (30) days of receipt of your written request and payment of any necessary processing fee.
You have a right to have any inaccurate personal data about yourself rectified and, taking into account the purposes of the processing, to have any incomplete personal data about yourself completed. You are able to request that amendments be made to your personal data, either by informing us in person, over the telephone, or contacting our Data Processor in writing or via email at email@example.com.
In some circumstances you have the right to have your personal data erased, without undue delay. These circumstances include:
o When your personal data is no longer necessary for the purposes of enabling us to conclude our contractual agreement with you;
o When you withdraw your consent to consent-based processing;
o When you object to the processing, under certain rules of applicable data protection law;
There are exceptions to the right to erasure. The general exclusions include where processing is necessary for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
If you have any questions or complaints regarding this Site or these Terms, contact us by emailing firstname.lastname@example.org.
Policy updated 21st May 2018