PRIVACY POLICY

TERMINOLOGY USED IN THIS POLICY

A "customer" is someone who makes a booking, or stays, or uses any of the services, at one of our hotels, resorts, spas, health clubs, golf clubs, golf courses or other facilities, or is a member of one of our health clubs or golf clubs or of our loyalty programme.

A "contact" is someone who makes an enquiry, or contacts us, on our website or in person or by letter, phone, email or text, enters into a competition run by us or use wi-fi services offered at one of our properties or facilities but is not a customer of ours.

CUSTOMERS

What personal information do we collect from our customers?

The personal information we collect may include:

name, email address, home and/or business address, phone number;
where you become a member of our health or golf clubs or use their facilities, date of birth;
bank account and payment card information;
booking history;
transactional data including details about payments to and from you and other details of products and services you have purchased from us;
information relating to your use of our services, such as room preferences, special requests, feedback and survey responses; and
marketing preferences.

How is our customers' personal data collected?

We will collect this data from you when you provide it to us by phone, email, post, through our website or in person.

Website (hereinafter: "Website") Booking Factory. Booking engine used for Nineteen Brighton, legal company name Isenhurst Limited .
Party responsible for processing personal data (hereinafter: "the controller"): Booking Factory, established at ADDRESS: Borgartún 37, 105 Reykjavík, Iceland.

Responsibilities

The controller is not liable for any failure, disturbances, difficulties or interruptions in the functioning of the website, causing the (temporary) inaccessibility of the website or of any of its functionalities. You, yourself, are responsible for the way you seek connection to our website. You need to take all appropriate steps to protect your equipment and data against hazards such as virus attacks on the Internet. Furthermore, you are responsible for which websites you visit and what information you seek.
The controller is not liable for any legal proceedings taken against you:

because of the use of the website or services accessible via the Internet
for violating the terms of this privacy policy

The controller is not liable for any damages that incur to you or third parties or your equipment, as a result of your connection to or use of the website and you will refrain from any subsequent (legal) action against the controller.
If the controller is involved in a dispute because of your (ab)use of this website, he is entitled to (re)claim all subsequent damages from you.

Collection of data

Your personal data will be collected by Booking Factory and (an) external processor(s) .
Personal data means any information relating to an identified or identifiable natural person (‘data subject’).
An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
The personal data that are collected on the website are used mainly by the controller in order to maintain a (commercial) relationship with you and if applicable in order to process your orders. They are recorded in an (electronic) register.

Your rights regarding information

Pursuant to Article 13 paragraph 2 sub b GDPR each data subject has the right to information on and access to, and rectification, erasure and restriction of processing of his personal data, as well as the right to object to the processing and the right to data portability.
You can exercise these rights by contacting us at info@booking factory.com.
Each request must be accompanied by a copy of a valid ID, on which you put your signature and state the address where we can contact you.
Within one month of the submitted request, you will receive an answer from us.
Depending on the complexity and the number of the requests this period may be extended to two months.

Legal basis for processing our customers' information

We will only use your personal information as the law permits. By law we are required to tell you the legal bases upon which we rely in processing your personal information. The legal bases we principally rely upon are these:

it is necessary for the performance of a contract between us for the provision of services or in order to take steps at your request prior to entering into such a contract; and/or
it is necessary for the purposes of the legitimate interests of pursuing and developing our business, where such interests are not overridden by your rights or interests.

Occasionally we may also rely upon the following legal bases for processing:

you have given your consent to the processing; and/or
it is necessary for us to comply with a legal obligation on us; and/or
it is necessary to protect your vital interests or those of another individual.

Where we rely on consent to process your personal information, you may withdraw that consent at any time by contacting us using the contact details set out under "HOW TO CONTACT US" below or by emailing us.

What do we use our customers' personal information for?

We intend to use your personal information for the following purposes:

to fulfil your bookings and/or to provide services or facilities you request from us;
to collect payment from you;
to administer and manage our relationship with you, which may include asking you to complete surveys or feedback forms;
where you have made a reservation with us, to send you information before your visit to confirm the reservation and to provide you with other information relating to your reservation which we think you may find of interest;
where required by law; and
where necessary to protect your health or well being or that of another individual.

CONTACTS

What personal information do we collect from our contacts?

The personal information we collect may include:

name, email address, home and/or business address, date of birth, phone number; and
marketing preferences

How is our contacts' personal data collected?

We will collect this data from you when you provide it to us by phone, email, post, through our website or in person.

Legal basis for processing our contacts' information

you have given your consent to the processing; and/or
it is necessary for the purposes of our legitimate interests of pursuing and developing our business, where such interests are not overridden by your rights or interests.

Occasionally we may also rely upon the following legal bases for processing:

it is necessary for us to comply with a legal obligation on us; and/or
it is necessary to protect your vital interests or those of another individual.

Where we rely on consent to process your personal information, you may withdraw that consent at any time by contacting us using the contact details set out under "HOW TO CONTACT US" below.

What do we use our contacts' personal information for?

We intend to use your personal information for the following purposes:

to fulfil your requests for information;
where it is required by law; and
where necessary to protect your health or well being or that of another individual.

IF YOU FAIL TO PROVIDE PERSONAL INFORMATION REQUESTED

Where we need to collect personal data by law or under the terms of a contract we have with you and you fail to provide that data when requested, 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 services). In this case, we may have to cancel a service you have booked with us but we will notify you if this is the case at the time.

DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION FOR?

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances you can ask us to delete your data: see under YOUR RIGHT TO ACCESS YOUR PERSONAL INFORMATION AND YOUR OTHER RIGHTS/to request erasure below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

We will take all reasonable steps to destroy, or erase from our systems, all the personal information we hold about you when it is no longer required.

MANAGING YOUR PERSONAL INFORMATION

If at any time you believe that any personal data we are holding about you is inaccurate, out-of-date or incomplete, please tell us by emailing us and we will rectify this.

CHANGES TO THIS POLICY

We may need to make changes to this Privacy Policy from time to time to take account of changes in law or the needs of our business. Please refer back to this page regularly to see any changes or updates to this Policy.