The data we collect and how we collect it
We may collect, store and use the following kinds of personal information including, without limitation:
- your first and last name, telephone number, postal and e-mail address, fax number;
- information about your computer and about your visits to and use of our website including your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation;
- if you make a reservation or purchase any items using a credit or debit card then we need the card number, cardholder name, expiry date and CVV number;
- your membership details, hotel preferences and travel experiences;
- any survey responses or feedback.
We may ask you for personal information in a variety of circumstances, for instance:
- when you make a hotel reservation or purchase something from our website or on the telephone or by e-mail, letter or fax;
- when you register with us, subscribe to our newsletter, enter competitions or register for promotions; or
- when you join the SLH loyalty programme, INVITED; or
- when you take part in surveys or provide us with feedback.
Our use of "cookies"
To make SLH work even better for you, we also use 'cookies' to collect information about your use of the website. Cookies are a feature of web browser software that allows web servers to temporarily store information within your browser, which in turn allows us to recognise the computer used to access SLH.
Using your personal information
SLH may use your personal information to:
(a) administer the website;
(b) improve your browsing experience by personalising the website;
(c) enable your use of the services available on the website;
(d) send you goods purchased via the website and/or supply you with services purchased via the website;
(e) send statements and invoices to you and process payments;
(f) track your use of the reservation process and contact you once via email regarding your experience;
(g) send you general (non-marketing) commercial communications;
(h) send you e-mail notifications which you have specifically requested;
(i) send you marketing communications relating to our business or the businesses of carefully selected third parties which we think may be of interest to you by post or, where you have specifically agreed to this, by e-mail or similar technology (you can inform us at any time if you no longer require marketing communications);
(j) provide third parties with statistical information about our users but this information will not be used to identify any individual user;
(k) deal with enquiries and complaints made by or about you relating to the website.
Where you submit personal information for publication on the website, SLH will publish and otherwise use that information in accordance with the license you grant to us.
SLH will not, without your express consent, provide your personal information to any third parties for the purpose of direct marketing.
Disclosures of information
In addition, SLH may disclose your personal information:
(a) to the extent that it is required to do so by law;
(b) in connection with any legal proceedings or prospective legal proceedings;
(c) in order to establish, exercise or defend its legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk);
(d) to the purchaser (or prospective purchaser) of any business or asset which it is (or are contemplating) selling; and
(e) to any person whom SLH reasonably believes may apply to a court or other competent authority for disclosure of that personal information where, in its reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information.
International data transfers
Information that SLH collects will be transferred to, and stored at a destination outside of the European Economic Area (“EEA”). It will also be processed by staff operating outside the EEA who work for SLH or for one of our suppliers. This includes staff engaged in, among other things, the fulfilment of any reservation, the processing of your payment details and the provision of support services.
Information which you provide may be transferred to countries (including the United States of America) which do not have data protection laws equivalent to those in force in the EEA.
In addition, personal information that you submit for publication on the website will be published on the Internet and may be available, via the Internet, around the world. SLH cannot prevent the use or misuse of such information by others.
By submitting your personal data, you expressly agree to these transfers, storing, processing and publishing.
Data processing on behalf of an SLH hotel
SLH will process any personal data that you may submit through the SLH website, on the telephone or by e-mail, letter or fax when making your reservation at an SLH hotel or making any permitted cancellations or changes (such as your name, address or payment details) on behalf of and as the contractual data processor of the particular SLH hotel with which you have chosen to book.
SLH does not have any discretionary authority regarding the processing of your personal data and the processing of your personal data is fully controlled by the relevant SLH hotel and is processed by SLH in accordance with the SLH hotel’s instructions.
Where information is processed by SLH on behalf of an SLH hotel, SLH will not store your personal data for any other purpose than for its processing according to the instructions of the relevant SLH hotel and will not share your personal data with any third party other than any members of our group.
Credit Card CVV number
In the course of processing or transmitting your credit card CVV number SLH will observe and fully comply with the current Data Security Standard of the PCI Security Standards Council.
Security of your personal information
SLH will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information.
SLH will store all the personal information you provide on its secure (password and firewall protected) servers. Reservations you make with SLH will be encrypted using SSL technology.
You accept that data transmission over the Internet is inherently insecure and SLH cannot guarantee the security of data sent over the Internet.
If you are a member of INVITED, you are responsible for keeping your password and user details confidential. SLH will not ask you for your password (except when you log in to the website).
Your privacy rights
You may instruct SLH to provide you with any personal information it holds about you. Provision of such information will be subject to:
(a) the payment of a fee (currently fixed at £10.00); and
(b) the supply of appropriate evidence of your identity (for this purpose, we will usually accept a photocopy of your passport certified by a solicitor or bank plus an original copy of a utility bill showing your current address).
SLH may withhold such personal information to the extent permitted by law.
You may instruct SLH not to process your personal information for marketing purposes by e-mail at any time. In practice, you will usually either expressly agree in advance to SLH’s use of your personal information for marketing purposes or we will provide you with an opportunity to opt-out of the use of your personal information for marketing purposes via the ‘unsubscribe’ link on any SLH e-mail.
Third party websites
The SLH website contains links to other websites. SLH is not responsible for the privacy policies or practices of third party websites.
If you are a member of INVITED, please let SLH know if the personal information which we hold about you needs to be corrected or updated. Please e-mail email@example.com.
The data controller responsible in respect of the information collected on the SLH website or otherwise in the course of your dealings with us is Small Luxury Hotels of the World Limited whose registered office is at 3rd Floor, Portland House, Bressenden Place, London SW1E 5BH.
SLH’s Data Protection Registration Number is Z2850240
19th March 2018