Your privacy is very important to us.
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, show relevant adverts and improve your stay.
This Policy applies to RTL customers or prospective customers such as an enquirer, booker, guest or user of any of RTL’s facilities or services. Including anyone contacting, visiting or using our Hotels, website, Apps, Reservations team or Guest relations.
Ralph Trustees Limited operates a group of hotels comprising The Grove, The Runnymede on Thames and The Athenaeum.
In order to provide our services, we will collect and use personal information about individuals. We are the Controller of all personal information we process pursuant to this Policy and we are responsible for complying with data protection laws.
If you have any questions about how we collect, store or use your personal information, you may contact us using the details set out in the “Contact Us” section 8.
This Policy sets out the legal grounds enabling us to process your personal information.
Where you provide personal information to us about other individuals (for example, members of your family or your employees) we will also be data controller of and responsible for their personal information. You should refer them to this Policy before supplying us data on behalf of others.
When you engage with us, such as make a booking or view our website, we will collect information about you and that engagement. This may include information such as:
Sometimes we need to collect personal information by law, or under the terms of the contract we have with you. If you fail to provide that information when we request it, we may not be able to perform the contract we have or are trying to enter into with you (for example to provide you with goods or services). In this case, we may have to cancel the product or service, but we will notify you if this is the case.
We will collect information directly from you when you engage with us:
We will also collect information indirectly when you engage with us via:
We will combine any personal information about you that we receive from you, from other hotels in our group, and from third parties.
Sometimes we will request or receive your “sensitive personal information” in order to fulfil services you have requested. This may include information such as:
From time to time, we may share your personal information, as follows:
We may share your personal information internally between our departments or RTL hotels. We will do this via access to internal reports and centralised IT and marketing systems.
We may share your personal information with our third-party service providers, agents, sub-contractors and other associated organisations for the purposes of completing tasks and providing services to you on our behalf (for example, to process payments and send you emails). However, when we use third-party service providers, we disclose only the personal information that is necessary to deliver the service and we have a contract in place that requires them to keep your information secure and not to use it for their own direct marketing purposes.
When you are using our secure online booking system, your purchase is processed by a third-party payment processor, who specialises in the secure online capture and processing of credit/debit card transactions.
Save as expressly detailed above in this section, we will never share, sell or rent any of your personal information to any third party without notifying you and/or obtaining your consent.
If you would like further information regarding the disclosures of your personal information, please see the “Contact us” section below for our contact details.
We have a legitimate interest to market to you. We use your personal information to provide you with information about RTL’s hotels, services or events which may be of interest to you as one of our past or prospective customers. These may include information about stays, events, promotions, offers, information about the hotel and the surrounding area
If you wish to opt out of marketing, you may do so by clicking on the “unsubscribe” link that appears in all emails or telling us when we talk to you.
Please note that, even if you opt out of receiving marketing messages, we may still send you service related communications where necessary.
We are also required to keep certain information in order to comply with our legal and regulatory obligations.
The exact time period will depend on your relationship with us and the type of personal information we hold. We may be required to retain the personal information for longer periods e.g. to establish, exercise or defend legal rights, such as responding to customer personal injury complaints.
If you would like further information regarding the periods for which your personal information will be stored, please contact us using the details set out in section 8.
RTL carries out automated processing.
We will combine any personal information about you that we receive from you, from other hotels in our group, and from third-parties in order to create marketing profiles.
Marketing profiles include personal information such as information about services you have used, information about when you have visited our hotels in the past, demographic data and, where you have agreed, data from your social media profiles.
For example, we may analyse the personal information of people who have used our services in the past and then compare them with other people in our database. If we identify people in our database who have similar personal information, we may then target marketing to those people, for example by sending direct marketing emails. We may conduct the profiling and marketing automatically.
We conduct these automated decision-making and profiling activities for our legitimate interests in providing the services and ensuring they operate in a commercially suitable way which is tailored to your use and interests.
Under data protection law you have certain rights in relation to the personal information that we hold about you. You may exercise these rights at any time by contacting us using the details set out in section 8.
In some cases we may not be able to comply with your request (for example, where there is a conflict with our own obligations to comply with other legal or regulatory requirements). However, we will always respond to any request you make and if we can’t comply with your request, we will tell you why.
You have the right to:
Request access to your personal information
This enables you to receive a copy of the personal information we hold about you and to check that we are processing it lawfully.
Request correction of the personal information we hold about you
This enables you to have any incomplete or inaccurate data we hold about you corrected, although we may need to verify the accuracy of the new information you provide us with.
Request erasure of your personal information.
This enables you to ask us to delete or remove your personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal information to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons. We will notify you of these, if applicable, at the time of your request.
Object to the processing of your personal information
Where we are relying on a legitimate interest (or those of a third party) and you feel it impacts on your fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information, which override your rights and freedoms, e.g. a requirement imposed on us by law.
Request restriction of the processing of your personal information
In some cases, e.g. questions over accuracy, lawfulness, the requirement to hold data or your objection to data usage, you may ask us to suspend the processing of your personal information.
Request the transfer of your personal information to you or to a third party.
If required, we will provide you or a third party of your choice with your personal information in a structured, commonly used, machine-readable format. Note, this right only applies to automated information that you initially provided consent for us to use or information that was used to perform a contract with you.
Withdraw consent at any time
Where we are relying on consent to process your personal information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent we may not be able to provide certain products or services to you. We will advise you if this is the case at the time.
Please note that for some purposes, we need your consent in order to provide you with a service. If you withdraw your consent, we may need to cancel your reservation, booking or service. We will advise you of this at the point you seek to withdraw your consent.
Lodge a complaint with the ICO
You have a right to complain to the Information Commissioner’s Office (ICO) if you believe that any use of your personal information by us is in breach of applicable data protection laws and regulations. More information can be found on the Information Commissioner’s Office website: https://ico.org.uk/
Making a complaint will not affect any other legal rights or remedies that you have.
We use a range of organisational and technical security measures to protect your information, including firewalls and access controls, which we review periodically. We also ensure that our employees receive appropriate data security training.
Data Protection Enquiries
Ralph Trustees Limited