Last updated 4th March 2020
When we use your personal data we are regulated under the General Data Protection Regulation (GDPR) which applies across the European Union (including in the United Kingdom) and we are responsible as ‘controller’ of that personal data for the purposes of the GDPR. Our use of your personal data is subject to your instructions, the GDPR, other relevant UK and EU legislation and our professional duty of confidentiality.
We, us, our
Corvus Leisure LLP.
Our data protection partner
Any information relating to an identified or identifiable individual.
Personal data we will collect
guests’ names, addresses, and telephone numbers;
significant dates, e.g. anniversaries, birthdays;
electronic contact details, e.g. your email address and mobile phone number;
information relating to your booking.
This personal data is required to enable us to provide our service to you. If you do not provide personal data we ask for, it may delay or prevent us from providing services to you.
How your personal data is collected
We collect this information:
via automated monitoring of our websites (such as Google Analytics) and other technical systems, such as our computer networks and connections, CCTV and access control systems, communications systems, email and instant messaging systems;
How and why we use your personal data
Under data protection law, we can only use your personal data if we have a proper reason for doing so, e.g.:
to comply with our legal and regulatory obligations;
for the performance of our contract with you or to take steps at your request before entering into a contract;
for our legitimate interests or those of a third party; or
where you have given consent.
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.
What we use your personal data for
to provide guest services to you;
to comply with our legal and regulatory obligations;
gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies;
for our legitimate interests or those of a third party, i.e. to prevent and detect criminal activity that could be damaging for us and for you;
updating and enhancing client records;
for our legitimate interests, e.g. making sure that we can keep in touch with our clients about existing and new services;
external audits and quality checks by auditors, regulators and providers of accreditation.
We may use your personal data to send you updates (electronically or by post) about developments that might be of interest to you and/or information about our services.
We have a legitimate interest in processing your personal data for promotional purposes (see above ‘How and why we use your personal data’). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.
We will always treat your personal data with the utmost respect and never sell it to or share it with other organisations to enable them to market to you:
You have the right to opt out of receiving promotional communications at any time by:
contacting us by email (email@example.com);
using the ‘unsubscribe’ link in emails.
Who we share your personal data with
external service suppliers, representatives and agents we may use to make our business more efficient, e.g. typing services, marketing agencies, website hosts, providers of client relation management systems, document collation or analysis suppliers;
IT hosting services.
We only allow our service providers to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on service providers relating to ensure they can only use your personal data to provide services to us and to you.
We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
We may also need to share some personal data with other parties, such as potential buyers of some or all of our business or during a re-structuring. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.
Where your personal data is held
Information may be held at our offices, third party agencies, service providers, representatives and agents as described above (see 'Who we share your personal data with’).
How long your personal data will be kept
We will keep your personal data after we have finished advising or acting for you. We will do so for one of these reasons:
to respond to any questions, complaints or claims made by you or on your behalf;
to show that we treated you fairly;
to market and promote the business.
When it is no longer necessary to retain your personal data, we will delete or anonymise it.
You have the following rights, which you can exercise free of charge:
The right to be provided with a copy of your personal data.
The right to require us to correct any mistakes in your personal data.
To be forgotten
The right to require us to delete your personal data - in certain situations.
Restriction of processing
The right to require us to restrict processing of your personal data - in certain circumstances, e.g. if you contest the accuracy of the data.
The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party - in certain situations.
You have the right to object at any time to your personal data being processed for direct marketing (including profiling).
If you would like to exercise any of those rights, please:
complete a data subject request form - available by emailing firstname.lastname@example.org; or
email, call or write to our data protection partner - see below: ‘How to contact us’; and
let us have enough information to identify you including full name, address
let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and
let us know what right you want to exercise and the information to which your request relates.
Keeping your personal data secure
We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
How to complain
We hope that our data protection partner can resolve any query or concern you may raise about our use of your information.
The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner.
How to contact us
Corvus Leisure LLP, Trenewydd, Cardigan, Pembrokeshire SA43 3BJ.
Our data protection partner's contact details: