York Pavilion Hotel Privacy Policy  

Introduction

This policy describes how Pavilion Hotel Ltd t/a Best Western York Pavilion Hotel and, collect, use, and share personal information. Please note that Best Western® branded hotels and properties (“Licensed Hotels”) are independently owned and operated and are not owned, managed, or controlled by BWI. We may collect personal identification information from customers and prospective customers in a variety of ways, including, but not limited to, when users visit our website, subscribe to marketing information, fill out a form, become a customer and in connection with other activities, services, features or resources we make available in our business. 

You have to opt-in to enable us to contact you. Customers and prospective customers may visit our website anonymously. We will only collect personal identification information from customers and prospective customers if they voluntarily submit such information to us. Customers and prospective customers can refuse to supply personally identification information.

Use and Processing of the Information we Collect

The following chart provides examples of the type of information that we collect from you and how we use that information. 

Context 
Room Reservations
Types of Information 
We collect your contact information, payment information, reservation information, and accommodation preferences. That information is collected directly from you when you make a room reservation. In a small number of cases we collect information about a guest’s health. For example, a guest may voluntarily choose to provide information about a disability as part of a request for an accommodation preference.
Primary Purpose for Collection and Use of Information
We use your information in order to perform our contractual obligations, fulfil your requests for a reservation, and to take steps in anticipation of those obligations. In some jurisdictions we also need your information to comply with legal obligations to collect and maintain information about guests. We also have a legitimate interest in analysing trends and patterns among guests. In the rare circumstances in which we collect information about a guest’s health, that information is collected only for the purpose of accommodating a guest’s needs and is used for no other purpose.


Best Western Rewards® (“BWR”)
Types of Information 
BWR is Best Western’s loyalty rewards program. We collect your contact information, communication preferences, reservation history, redemption details, and partner loyalty program elections. Information is collected when you register for BWR, redeem reward points, make a hotel reservation, update your BWR account, or link your BWR account to a partner loyalty program.
Primary Purpose for Collection and Use of Information
We use your information in order to perform our contractual obligations to you. For example, we use the information to allow you to earn and redeem rewards, points, or credits in connection with loyalty programs. We also have a legitimate interest in marketing to you and analysing trends and patterns among our rewards members. For complete BWR program terms see www.bestwesternrewards.com.


Cookies and First Party Tracking
Types of Information 
We use cookies and clear GIFs. “Cookies” are small pieces of information that a website sends to a computer’s hard drive while a web site is viewed.
Primary Purpose for Collection and Use of Information
We have a legitimate interest in making our website operate efficiently and analysing trends and patterns among our website visitors.


Cookies and Third Party Tracking
Types of Information 
We participate in behaviour-based advertising. This means that a third party uses technology (e.g., a cookie) to collect information about your use of our website so that it can provide advertising about products and services tailored to your interests on our website or on other websites.
Primary Purpose for Collection and Use of Information
We have a legitimate interest in engaging in behaviour-based advertising.


Email Inter connectivity
Types of Information 
 If you receive email from us, we use certain tools to capture data related to when you open our message, click on any links or banners it contains, or make reservations.
Primary Purpose for Collection and Use of Information
We have a legitimate interest in understanding how you interact with our communications to you.


Customer Service via Reception
Types of Information 
If you contact us with an issue we will collect your name and e-mail address, as well as any other content that you send to us in order to reply.
Primary Purpose for Collection and Use of Information
We have a legitimate interest in receiving and acting upon the information that you provide to us concerning issues that you raise.


Mailing List
Types of Information 
When you opt-in or sign up for one of our mailing lists we collect your email address or postal address.
Primary Purpose for Collection and Use of Information
We share information about our products and services or the products and services of other companies, if you consent to receive that information. We also have a legitimate interest in sharing information with you about our services and those of our partners.


Mobile Devices
Types of Information 
We collect information from your mobile device such as unique identifying information broadcast from your device when visiting our websites or applications.
Primary Purpose for Collection and Use of Information
We have a legitimate interest in identifying unique visitors and in understanding how users interact with us on their mobile devices.


Surveys
Types of Information 
When you participate in a survey we collect information that you provide through the survey.
Primary Purpose for Collection and Use of Information
We have a legitimate interest in understanding your opinions and collecting information relevant to our organisation to improve our services.


Website Interactions
Types of Information 
We use technology to monitor how you interact with our website. This may include the links you click on or information that you type into our online forms.
Primary Purpose for Collection and Use of Information
We have a legitimate interest in understanding how you interact with our website to better improve it and to understand your preferences and interests in order to select offerings that you might find most useful.


Web Logs
Types of Information 
We collect information, including your browser type, operating system, Internet Protocol (IP) address (a number that is automatically assigned to a computer when the Internet is used), domain name, click-activity, referring website, and/or a date/time stamp for visitors.
Primary Purpose for Collection and Use of Information
We have a legitimate interest in monitoring our networks and the visitors to our websites. Among other things, it helps us understand which of our services is the most popular.


WiFi Access
Types of Information 
We collect information about individuals that access those WiFi networks.
Primary Purpose for Collection and Use of Information
We have a legitimate interest in providing WiFi networks and in collecting information for fraud and security purposes.


Employment Candidates
Types of Information 
If you apply to work for us, we collect information necessary to evaluate your application.
Primary Purpose for Collection and Use of Information
We use information about prospective employees in connection with our legal obligations and our legitimate interest in evaluating candidates.


Employees
Types of Information 
If you are or were an employee, we collect information necessary to your employment.
Primary Purpose for Collection and Use of Information
We use information about current employees in connection with our employment obligations. In some contexts, we are also required by law to collect information about our employees and we have a legitimate interest in complying with those laws. We also have a legitimate interest in using employment information to have efficient staffing and work force operations.


Suppliers/Partners
Types of Information 
From time to time we may use additional suppliers/partners who provide additional services to our staff and guests.
Lists of partners can be requested from the Hotel direct via our contact details within this policy.
Primary Purpose for Collection and Use of Information
We share and use information about our products and services or the products and services of other suppliers & partners, if you consent to receive that information. We also have a legitimate interest in sharing information with you about our services and those of our partners.
 


In addition to the information that we collect from you directly, we may also receive information about you from other sources, including business partners, Affiliates, or publicly available sources. For example, if you make a reservation at our Hotel, we may transmit information to Best Western as part of our legitimate interest in, among other things, maintaining a global reservation system and providing for customer service and support.

In addition to the purposes and uses described above, we use information in the following ways:

• For internal administrative purposes as well as to manage our relationships.
• To conduct analytics.
• To identify you when you visit our website or Hotel.
• To provide service to you and to improve our services and product offerings.
• To respond to inquiries related to support, employment opportunities, or other requests.
• To send marketing and promotional materials, including information relating to our products, services, sales, or promotions.
• To streamline the reservation or checkout process.
• For the safety and security of guests, staff, and other visitors.

Although the sections above describe our primary purpose in collecting your information, in many situations we have more than one purpose. For example, if you make a room reservation we collect your information so that we, can perform a contract with you, but we also collect your information as we have a legitimate interest in maintaining your information after your transaction is complete so that we can quickly and easily respond to any questions about your stay. As a result, our collection and processing of your information may be based upon our need to perform a contract, our obligations under law, our legitimate interest in conducting our business, and/or your consent.

Sharing Of Information

In addition to the specific situations discussed elsewhere in this policy, we disclose information in the following situations:
We do not sell, trade, or rent customers and prospective customers personal identification information to others. We use third party service providers to help us operate our business and or administer activities on our behalf, such as sending out emails, newsletters or surveys. We may share your information with these third parties for those limited purposes provided that you have given us your permission.

We may share your data with Best Western International, Best Western Great Britain and Best Western suppliers working on our behalf. For further details on how your data is used and stored by Best Western Hotels, please see Best Western Hotels’ privacy policy.

1. Best Western & Hotel Partners. We share information with independent companies that we have partnered with or that are participants in our BWR program to allow you to earn and redeem rewards, points, or credits in connection with your BWR membership and in accordance with your chosen earning and spending preferences. For example, you may decide to select a particular airline partner through which you can earn BWR points. We also share information with independent companies if you have selected that you would like to receive promotions and marketing material from Best Western’s third party-business partners.

2. Partner Marketing and Promotions. We share information with independent companies if you have selected that you would like to receive promotions or marketing material from Best Western’s third party-business partners. We also offer promotions with third party partners. If you decide to enter a promotion that is sponsored by a third-party partner, the information that you provide will be shared with us and with them. Their use of your information is not governed by this privacy policy.

3. Travel Agents and Online Travel Websites. We share your information with travel agents, and/or online travel websites that you use in order to process your reservation request and to comply with any requirements or needs of those entities.

4. Service Providers. We share your information with service providers. Among other things, service providers help us to administer our databases, websites, marketing, communications, and surveys; service providers provide us with technical and logistical support; service provider’s process payments on our behalf; and service providers assist in the fulfilment of reservations and orders. If a service provider receives information from us about an EU data subject or a Swiss data subject and takes an action that is contrary to the principles of the EU-US Privacy Shield, we shall be liable for those actions unless we prove that we are not responsible for causing them.

5. Public. Some of our social media platforms or website may provide the opportunity to post comments or reviews in a public forum. If you decide to submit information on these pages, that information may be publicly available.

6. Other Disclosures without Your Consent. We may disclose information in response to, warrants, or court orders, or in connection with any legal process, or to comply with relevant laws or the other jurisdictions in which we operate. We may also share your information in order to establish or exercise our rights, to defend against a legal claim, to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of our policies, or to comply with your request for the shipment of products to or the provision of services by a third party intermediary. We also may share information with our corporate affiliates (e.g., subsidiaries, joint ventures, or other companies under common ownership or control). In addition, if another company acquires or plans to acquire our company, business, or our assets, we will also share information with that company, including at the negotiation stage.

7. Other Disclosures with Your Consent. We may ask if you would like us to share your information with other unaffiliated third parties who are not described elsewhere in this policy.


    Your Choices

    You can make the following choices regarding your personal information:

    1. Promotional Emails. You can stop receiving promotional emails by following the unsubscribe instructions in emails that you receive. If you decide not to receive promotional emails, we may still send you service related communications.

    2. Promotional Mailings. If at any time you do not want to receive offers and/or circulars from us you can remove yourself from our mailing lists by emailing us (our contact information is below) with "REMOVE FROM MAILING LIST” in the subject line along with your name, address and postal code in the content of the email. Please note that our mailings are prepared in advance of their being sent. Although we will remove your name from our mailing list after receiving your request, you may still receive mailings from us that had been initiated prior to your name being removed.

    3. Promotional Text Messages. If you receive a text message from us that contains promotional information you can opt-out of receiving future text messages by replying “STOP.”

    4. Access to Your Personal Information. You can request access to your personal information by completing and submitting a Request Form which can be obtained from reception. If required by law, upon request, we will grant you reasonable access to the personal information that we have about you.

    5. Changes to Your Personal Information. We rely on you to update and correct your personal information. Note that we may keep historical information in our backup files as permitted by law. If our website does not permit you to update or correct certain information you can request that your information be changed by completing and submitting a Request Form which can be obtained from reception. Although our hotel will attempt in good faith to respond to your request, we may not be able to change your information in all circumstances. For example we may not be able to change your information if doing so would impose an undue burden or expense, or if it would require us to change information relating to another person.

    6. Deletion of Your Personal Information. You can request information about how long we keep a specific type of information by contacting us at the address described below. You can request that your information be deleted by completing and submitting a Request Form which can be obtained from reception. If required by law we will delete your personal information after such a request is made. You should note that there are some situations in which we may decline to delete your information. For example, we may keep your personal information as needed to comply with our legal obligations, resolve disputes, and/or enforce any of our agreements.
    7. Revoking Consent or Objecting to Processing. You can revoke consent to processing (where such processing is based upon consent) or object to our processing by completing and submitting a Request Form which can be obtained from reception. If you revoke consent or object to further processing we may no longer be able to provide you services. In some cases, we may limit or deny your request if the law permits or requires us to do so, or if we are unable to adequately verify your identity.

      How We Protect Personal Information

      No method of transmission over the Internet or of electronic storage is fully secure. While we use reasonable efforts to protect your personal information from unauthorised access, use, or disclosure, we cannot guarantee the security of your personal information. In the event that we are required by law to inform you of any breach to your personal information we may notify you electronically, in writing, or by telephone, if permitted to do so by law.

      Some of our websites permit you to create an account. When you do you will be prompted to create a password. You are responsible for maintaining the confidentiality of your password, and you are responsible for any access to or use of your account by someone else that has obtained your password, whether or not such access or use has been authorised by you. You should notify us of any unauthorised use of your password or account.

      How Long We Retain Information

      We retain your personal information for the period necessary to fulfil the purposes outlined in this policy, unless a longer retention period is required or permitted by law. For example, we retain Best Western Rewards information for as long as an individual remains a BWR member because BWR points do not expire and the information is needed in order to allow the individual to redeem their rewards. We retain information in our reservation system, in full or in summary form, for six years following a guest’s departure in order to process your reservation, provide post-reservation customer support, and provide invoicing and record keeping. We typically retain information in our customer care complaint system for six years after receipt, unless the information is needed for an ongoing purpose such as to address an open issue. 

      Miscellaneous

      The following additional information relates to our privacy practices:

      • Third Party Applications, Websites, and Social Media. We have no control over the privacy practices of websites or applications that we do not own. Our website or our communications may also contain plug-ins and other features that integrate third party social media platforms. If you interact with these, the third parties who operate these platforms may be able to identify you, determine how you use our website, and link and store this information with your social media profile.

      • Changes to This Privacy Policy. We may change our privacy policy and practices over time. To the extent that our policy changes in a material way, the policy that was in place at the time that you submitted personal information to us will generally govern that information unless we receive your consent to the new privacy policy.

      Changes to this privacy policy

      We have the discretion to update this privacy policy at any time. We encourage customers and prospective customers to frequently check our website for any changes or to stay informed about how we are helping to protect the personal information we collect. You acknowledge and agree that it is your responsibility to review this privacy policy periodically and become aware of modifications.

      Third party collection of information

      Our policy only addresses the use and disclosure of information we collect from you. To the extent you disclose your information to other parties or sites throughout the internet, different rules may apply to their use or disclosure of the information you disclose to them. Accordingly, we encourage you to read the terms and conditions and privacy policy of each third party that you choose to disclose information to. 

      This Privacy Policy does not apply to the practices of companies that we do not own or control, or to individuals whom we do not employ or manage, including any of the third parties which we may disclose information as set forth in this Privacy Policy. 

      Your acceptance of these terms

      By using this website, you signify your acceptance of this policy. If you do not agree to this policy, please do not use our website. Your continued use of the website following the posting of changes to this policy will be deemed your acceptance of those changes.

      Your legal rights

      Under data protection laws you have rights in relation to your personal data that include the right to request access, correction, erasure, restriction, transfer, to object to processing, to portability of data and (where the lawful ground of processing is consent) to withdraw consent.

      You can see more about these rights at:

      https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/

      If you wish to exercise any of the rights set out above, please email Reception.

      Contact Information 

      We will attempt to respond to any questions, comments, or complaints concerning our privacy practices. Please feel free to contact us using the following information:

      If you would like to update your information or modify your communication preferences, please contact us by e-mail at reception@yorkpavilionhotel.com, by phone on 01904 622099 or write to us at the following address:

      Best Western York Pavilion Hotel, 45 Main Street, York, YO10 4PJ

      Should you have any questions about this privacy statement or your personal data, please contact our Data Protection Officer at reception@yorkpavilionhotel.com or by phoning 01904 622099.

      Please note that e-mail communications will not necessarily be secure; accordingly you should not include Payment Information or Sensitive Information in e-mail correspondence to us.

      If you are not satisfied with our response, and are in the European Union, you may have a right to lodge a complaint with your local supervisory authority.

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      Updates or amendments to this Privacy Policy

      We reserve the right to periodically amend or revise the Privacy Policy; material changes will be effective immediately upon the display of the revised Privacy policy. The last revision will be reflected in the "Last modified" section. Your continued use of the Platform, following the notification of such amendments on our website, constitutes your acknowledgment and consent of such amendments to the Privacy Policy and your agreement to be bound by the terms of such amendments.


      If you have any general questions about the Site or the information we collect about you and how we use it, you can contact us at [add applicable email address] .

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      Last Modified 22/07/2019
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