We take your privacy and security very seriously and take steps to ensure that your personal information is only collected and processed as required by law and to the extent required to provide the service you have asked us to while ensuring your health and safety.
We want to ensure that you are in control of the information we hold about you and the way in which it is used, where such use is not controlled by law. Our basic measures in this regard are to never purchase personal data lists, collect only the information that we need, store it for only as long as it helps us to deliver a service to you, never share (other than when this directly relates to the service we deliver) or sell your information under any circumstances. We also ensure that we tell you how we will use your information and seek your authorisation to use it in any further way, for example if we intend to contact you with marketing messages.
Who We Are
Seamill Hydro (‘we’ or ‘us’ or ‘our’) gather and process your personal information in accordance with this privacy notice and in compliance with the relevant data protection Regulation and laws. This notice provides you with the necessary information regarding your rights and our obligations, and explains how, why and when we process your personal data.
Seamill Hydro’s registered office is at Ardrossan Road, Seamill, West Kilbride, Ayrshire, Scotland, KA23 9ND. We are registered on the Information Commissioner’s Office Register; registration number ZA322746, and act as the data controller and data processor when processing your data. Our designated Appointed Person is Mr Steven Sweeney, who can be contacted at firstname.lastname@example.org.
Information That We Collect
Seamill Hydro processes your personal information to meet our legal, statutory and contractual obligations and to provide you with our products and services. We will never collect any unnecessary personal data from you and do not process your information in any way, other than as specified in this notice.
The personal data that we collect from is: –
- Date of Birth – if provided
- Home Address
- Personal Email – if provided
- Business Email – if provided
- Home Telephone Number – if provided
- Mobile Telephone Number – if provided
- National Insurance Number – of employees only
- Passport Number – if you are not from Britain, Ireland or the Commonwealth
- Your next destination – if you are not from Britain, Ireland or the Commonwealth
- Details of disability that may impact upon our emergency evacuation procedures
- Details of food intolerances and other dietary requirements
We collect information in the below ways: –
- Over the phone when you make a reservation
- In person when you make a reservation
- From our booking engine when you make a reservation online
- From an agent working on your behalf when they make a reservation for you, this includes OTAs (Online Travel Agents such as booking.com)
- On our website when you complete a contact form
- On our website when you subscribe to marketing
- On our website and social media when you engage with our content by, for example, entering competitions
- On our website and third party websites when you complete surveys concerning your experiences with us
- On our website and third party sites when you make purchases, for example gift vouchers or event tickets
- In writing when you complete a form or enter a competition in person at an event, exhibition or at the hotel
- Over the phone when you make a reservation
- Application forms in writing and online
- From third parties such as employment agencies and websites
- Submitted CVs
- Forms you complete at Induction
- Application forms in writing and online
How We Use Your Personal Data (Legal Basis for Processing)
Seamill Hydro takes your privacy very seriously and will never disclose, share or sell your data without your consent; unless required to do so by law. We only retain your data for as long as is necessary and for the purpose(s) specified in this notice. Where you have consented to us providing you with promotional offers and marketing, you are free to withdraw this consent at any time.
The purposes and reasons for processing your personal data are detailed below: –
- We collect your personal data to provide a service (A room or restaurant reservation, wedding, event or business booking for example), to ensure that the service meets your requirements and so that we can keep in contact with your regarding that service
- We collect and store your personal data as part of our legal obligation for business accounting and tax purposes
- We collect and store your personal data as part of our legal obligation under the Immigration (Hotel Records) Order 1972
- We retain your data for your ease in making repeat bookings
- We retain your data for business and service quality monitoring and statistical analysis
- From time to time we will use your data, where we have your permission to send you marketing we believe to be interesting and relevant to you.
You have the right to access any personal information that Seamill Hydro processes about you and to request information about: –
- What personal data we hold about you
- The purposes of the processing
- The categories of personal data concerned
- The recipients to whom the personal data has/will be disclosed
- How long we intend to store your personal data for
- If we did not collect the data directly from you, information about the source
If you believe that we hold any incomplete or inaccurate data about you, you have the right to ask us to correct and/or complete the information and we will strive to do so as quickly as possible; unless there is a valid reason for not doing so, at which point you will be notified.
You also have the right to request erasure of your personal data, where this does not contravene legislation or to restrict processing (where applicable) in accordance with the data protection laws; as well as to object to any direct marketing from us. Where applicable, you have the right to data portability of your information and the right to be informed about any automated decision-making we may use.
Some automated marketing decisions are based on your personal information or behaviour, the distance from the hotel you live or the length of time since your last stay for example.
If we receive a request from you to exercise any of the above rights, we may ask you to verify your identity before acting on the request; this is to ensure that your data is protected and kept secure.
Sharing and Disclosing Your Personal Information
We do not share or disclose any of your personal information without your consent, other than for the purposes specified in this notice or where there is a legal requirement. Seamill Hydro uses third parties to provide the below services and business functions; however, all processors acting on our behalf only process your data in accordance with instructions from us and comply fully with this privacy notice, the data protection laws and any other appropriate confidentiality and security measures.
Amilight Limited are our marketing and business development consultants and responsible for managing our social media accounts, website content and marketing campaigns. Amilight are afforded access to client data only to the extent required for their role as above described, for example no method of payment information is ever provided to Amilight Limited. Amilight Limited do not copy or store our customer data on any systems not controlled by Seamill Hydro.
Seamill Hydro takes your privacy seriously and takes every reasonable measure and precaution to protect and secure your personal data. We work hard to protect you and your information from unauthorised access, alteration, disclosure or destruction and have several layers of security measures in place, including: –
- Our website uses SSL encryption
- Our booking engine uses SSL encryption and is PCI compliant
- Our property management system is password protected with a full audit trail and is PCI compliant
- Our cloud data processing and storage applications use SSL encryption and are password protected and information is strictly limited to that which is critical to the particular application
- Our internal servers are housed in secured and camera monitored rooms, protected by firewalls from remote breach and by password from local breach
- Any printed information which is stored for statutory compliance is done so in secured rooms and is destroyed as soon as allowed under applicable regulation
Transfers Outside the EU
Seamill Hydro utilise some products or services (or parts of them) that may be hosted/stored in non-EU countries such as the United States of America, which means that we may transfer any information which is submitted by you through the website outside the European Economic Area (“EEA”) for the below purposes: –
We utilise a number of services which do not disclose the location of all of their data centres and so cannot state that all of your data will only ever be stored within the EEA and subject to the GDPR. These services are provided by market leading, highly regarded and well established companies with extensive data protection and privacy policies and safeguarding measures. Please contact us for more information.
Consequences of Not Providing Your Data
When staying at a hotel in the UK you are required to provide a basic level of personal information under the Immigration (Hotel Records) Order 1972, where this law is not in affect you are not obligated to provide your personal information to Seamill Hydro, however, as this information is required for services, we will not be able to offer some our services without it.
As noted in the ‘How We Use Your Personal Data’ section of this notice, we occasionally process your personal information under the legitimate interests’ legal basis. Where this is the case, we have carried out a thorough Legitimate Interests’ Assessment (LIA) to ensure that we have weighed your interests and any risk posed to you against our own interests; ensuring that they are proportionate and appropriate.
We use the legitimate interests’ legal basis when contacting you concerning your reservation and this may extend to sending you information about your reservation, information before you arrive to let you know how to make the most of your stay, give you the opportunity to extend or enhance your stay or collect your feedback following your stay to help us provide a better level of service in the future.
How Long We Keep Your Data
Seamill Hydro only ever retains personal information for as long as is necessary and we have strict review and retention policies in place to meet these obligations. We are required under UK tax law to keep your basic personal data (name, address, contact details) for a minimum of 6 years after which time it will be destroyed.
Where you have consented to us using your details for direct marketing, we will keep such data until you notify us otherwise and/or withdraw your consent.
Special Categories Data
Owing to the products and services Seamill Hydro sometimes needs to process sensitive personal information (known as special category data) about you, to ensure your health and safety during your visit. Where we collect such information, we will only request and process the minimum necessary for the specified purpose and identify a compliant legal basis for doing so.
This information will be collected, stored and processed under Section 9 (2) paragraph (h). This is for the “management of health” and will be limited to food allergies and intolerances and disability which directly impact upon emergency evacuation procedures. This information can only be collected directly from the subject or their agent and as such consent to process is implied.
Occasionally, Seamill Hydro would like to contact you with the services and promotions that we provide. If you consent to us using your contact details for this purpose, you have the right to modify or withdraw your consent at any time by using the opt-out/unsubscribe options or by contacting Seamill Hydro directly.
LEGITIMATE INTERESTS EXAMPLE
Seamill Hydro will occasionally send you services and promotions by email that have been identified as being beneficial to our customers and in our interests. Such information will be relevant and specific to you as a customer is non-intrusive and you will always have the option to opt-out/unsubscribe at any time. You have the right to opt-out of legitimate interests contact.
Lodging A Complaint
Seamill Hydro only processes your personal information in compliance with this privacy notice and in accordance with the relevant data protection laws. If, however you wish to raise a complaint regarding the processing of your personal data or are unsatisfied with how we have handled your information, you have the right to lodge a complaint with the supervisory authority.
Mr Steven Sweeney
Ardrossan Road, Seamill, West Kilbride, Ayrshire, KA23 9ND
01294 822 217 | email@example.com
Information Commissioner’s Office