Updated on 24/05/2018
Your personal information allows us to provide the products and services you have asked for, as well as enabling us to improve those products and services by understanding your interests and preferences. By understanding what you like (and what you don’t) we are able to personalise your experience and improve your stay.
Who we are
Estee Group (“we”, “our”, “us”) is the data controller when you provide information to us.
What information do we collect?
When you interact with our products and services, for example when browsing our website or booking a hotel room, we collect information about you and that particular interaction. Generally, this may include your personal data which means personal details from which you can be identified or are identifiable, for example:
Contact information, and preferences;
Information about your use of our hotels, and other services when you stay with us;
Images of you in areas of our hotels covered by CCTV;
Conversations you have when you call our reservations or sales teams;
Information about anyone you’re travelling with or meeting, if that information is provided to us; and
Information about the devices you use to interact with us.
More sensitive information, for example when you tell us about dietary requirements, disabilities, and religious beliefs;
Where you provide us with sensitive details, for example in relation to requirements you may have regarding accessibility to our hotels, we will only hold this information with your express permission. This information is stored securely with restricted access and handled the greatest respect for your privacy.
Where you provide information to us about other people, you need to make sure you have their permission to do so or that you can speak on their behalf, for example, in the case of children.
When and how we collect your information
We collect information you provide to us directly and indirectly when interacting with our products and services, including when you stay with us. This may include when you:
Book a room online, over email, on the phone or in person;
Create, use or manage an online account;
Sign up to our loyalty programmes;
Visit our website or use our apps;
Fill out our online forms or registration cards;
Visit our hotels or use our hotel services, like room service or gym and spa facilities;
Access hotel internet;
Use our restaurants;
Use social media login functionality;
Interact with us in online forums, by email, text, telephone, or on social media;
Post reviews of your stay or interaction with us;
Complete our market research/customer surveys; and
Enter competitions or promotions.
Travel agents and partners
We collect information about you when it is provided to us by third parties. This might include online travel agents, travel websites, and other partners. This could be when you make bookings, review your stay online, or where you interact with anyone who promotes our brands. You should always read the privacy policies of travel companies or other third parties you use, as they will use your information in accordance with their own privacy policies.
When you, or someone on your behalf, make a booking using travel agent, booking platform or other third party to use our services, they may pass us information about your booking, including information about anyone else on that booking. The same would be true where you use a third party to make enquiries about our products or services.
Where you interact with third parties who promote our services for us, these third parties may pass us your information.
When you post comments, reviews, or engage in discussions and polls about our products and services, we may receive this information from the platform you interacted with or from our partners who monitor how our brand is performing.
We may also obtain information about you from our partners and other companies that have your permission to share your information both online and offline.
How we use your personal information
The reason we use your information will often be obvious from the way you interact with us. For example, if you book a room at our hotel, we would use that information to administer your stay with us. However, our uses of your information may not always be so obvious. You can find out more below. When you provide your information to us, we may use it to:
confirm your hotel reservations;
send you emails that relate to your hotel stay;
respond to your customer-service inquiries or requests;
to confirm, update and improve customer records;
identify and inform you of services that may be of interest;
banks and payment providers, to authorize and complete payments;
service providers who work with us to help provide our services i.e. Chauffeur services
other agencies such as police of government organisations where we are required to by applicable law.
Personal information you supply us with and the information about your use of services will only be used by us, to tell you by letter, telephone or email about services that may be of interest to you. Your personal information will not be disclosed to any third party for marketing purposes.
Further Information on how we use your information
We sometimes use your information for reasons that we think you might want a bit more detail on, so to help we have added more information to these below.
Profiling and preferences
We sometimes make decisions about what your interests are based on the way that you interact with us and the information we hold about you, this is called profiling. For example, if you regularly stay at a particular hotel or frequently choose a specific room or pillow type, then we might use this information improve your experience by pre-selecting certain features of your stay for you, so you don’t need to. Understanding your preferences and personalising your experience in this way allows us to deliver the very best service possible.
If you post or send offensive or inappropriate content anywhere on or to any of our websites or apps, or otherwise engage in disruptive behaviour on any of our websites or apps, we may use the information that is available to us about you to stop such behaviour. This may involve responding to or informing relevant third parties and law enforcement agencies about the content and your behaviour.
In addition to sending you information about the products and services you use (product communications) and in-life communications while you stay with us, where we have your permission or where we are relying on our legitimate interest, we may send you direct marketing communications about our products, services, events and offers.
Direct marketing communications may be sent by post, email, telephone, SMS and MMS, through social media (such as Whatsapp, Instagram, Twitter, and Facebook), messages including push notifications to your mobile devices, and via other electronic means such as when you visit our websites or use our apps. This may also include any websites and apps of our partners who are in our advertising networks. We may send you direct marketing while you have an ongoing relationship with us and for a reasonable time after you have used one of our products or services where we feel we have a legitimate interest. You will be able to opt-out of direct marketing by following the instructions in the communications you receive or changing your device settings. Alternatively, where you have an account with us, you will be able to log-in and change your marketing preferences.
Product related communications and “in-life” updates
We may use your information to send you newsletters, bulletins, and other “in-life” communications (about your stay), and triggered communications where you make changes to your account or other information about products and services you have signed up for. For example, we may send you email or text messages about an upcoming stay with us in order to help you plan your visit and give you the best experience possible. You’ll be able to opt-out of these.
Service communications will be sent to you regarding products and services you interact with. These are important messages relating to the products and services we provide to you.
Sale of our business
If we restructure or sell all or part of our business or business operations, we may transfer your information as part of that activity, including, but not limited to, where we transfer or cease to manage (or license the use of a brand at) a hotel. Where this is the case your information will be used in accordance with this Policy unless you are notified otherwise.
How we keep your personal data secure
Technical and organisational measures
We have secure systems and processes in place to ensure the personal information you provide us is kept safe. We store personal information on our secure electronic systems. We can assure you that we take all reasonable steps to ensure your data is safe and secure with us.
How we store your personal information and how long we keep it for
We will retain your information for as long as necessary for the uses set out in this Policy or while there is a legitimate business reason for doing so. If you ask us to delete your information before this time, we may not be able to do so for technical, legal, regulatory or contractual constraints. For example, where you wish to be suppressed from direct marketing, we would need to retain your information for this purpose.
Where you ask for your account to be closed, we will do this as soon as possible subject to any terms and conditions relating to the account. Your information will be retained in order to comply with legal and regulatory obligations as well as for analysis, to prevent fraud, collect any monies owed, and to resolve disputes.
Do not track signals or browser/device settings Our websites are not designed to respond to “do not track” signals or browser/device settings.
Access and Control
Updating your information
Please ensure you keep your information up to date by logging into your account and modifying it. Alternatively, you can tell us when you check-in that your information has changed and we will update it for you.
Controlling direct marketing
You can change your mind about receiving direct marketing from us or change your preferences by logging into your account, if you have one, opting-out in any marketing or product communication you have received from us or emailing us using the contact details below.
Requesting copies of your information
You may request a copy of your personal information which we may hold about you by getting in touch with us using the contact details below. You may also ask us to correct any inaccuracies in your personal information. This right may be restricted by law where disclosing information may result in the personal information of other individuals being disclosed and it would be unreasonable to do so.
Where we may rely on consent to use your information, you have the right to withdraw that consent for that processing activity at any time by logging into your account, if you have one, opting-out in any marketing or product communication you have received from us or emailing us using the contact details below. However, we may have the right to rely on an alternative legal basis for the processing activity so that we are able to provide you with the product or service you have requested and, in that case, will inform you of that.
You may have the right to object, erase, or restrict our processing of your information - for example, where we process your personal information because this is in our legitimate interests, you may object to this. We will carefully consider your request as there may be circumstances which require us to, or allow us to, continue processing your data.
Complaining to the regulator
If you have any comments, concerns or complaints about our uses of your information we would ask that you contact us first, so that we can try and resolve any matter. However, where we are unable to help, you are able to complain to the Information Commissioner’s Office in the United Kingdom or the data protection regulator in your country of residence, who will be able to liaise with the UK Information Commissioner in the UK. Details for the UK Information Commissioner can be found at https://ico.org.uk/
From time to time we may make changes to this Policy. This might be in relation to changes in the law, best practice, changes to the services we provide or collection and use of your personal information. We will always display clearly when the Policy was last updated and where appropriate, notify you of any relevant changes.
If you would like to get in touch with us, please contact
By Email: firstname.lastname@example.org
By Post: The Data Protection Officer,
2 Forum House, Empire Way, Wembley, HA90AB