This Privacy Statement applies to the processing by Neptune of your (our guests) personal data. Neptune takes your privacy very seriously and treats all your personal data with great care. Neptune acts in accordance with the applicable data protection legislation.
When you visit our websites (or subdomains) (the “Website”), make a reservation, contact us, purchase products from us or visit one of our properties, we collect information from and about you. Some of the information we collect may be classed as personal data under data protection legislation, that is, “any information relating to an identified or identifiable natural person”. It may be collected any time you submit it to us, whatever the reason may be.
This Privacy Statement describes which personal data is collected and for which purposes this personal data is processed by Neptune. It also states which rights you have under applicable data protection legislation.
PARTICULARLY IMPORTANT INFORMATION
WHO WE ARE: For the purpose of applicable data protection legislation, the data controller of your personal data is Neptune, Cnr of Guilford Street and Russell Square, London, WC1B 5BE.
MUST READ SECTIONS: We draw your attention in particular to the sections entitled “International Data Transfers” and “Your Rights.”
2. COLLECTING YOUR PERSONAL DATA
Neptune collects information about you in the following ways.
Information you give to us. This includes personal data collected:
- Through our Website when you register, login, commence or complete an online transaction to use our products and services.
- When you contact our reservations team to make a booking or use the facilities at any of our properties. Facilities include, but are not limited to, meeting rooms, bar and/or restaurant, function rooms, and guest Wi-Fi.
- When you have provided your consent, in order to:
- subscribe to any of our marketing communications
- complete customer surveys, enter competitions or provide feedback.
- When we do business with you, which will usually include:
- Full or partial contact details including names and addresses (including business details if you are making a corporate booking), telephone and email details.
- If you have special requirements then it may also be necessary to collect details about diet or disability or any other preferences that you may have.
- Car parking arrangements at our properties may also make it necessary for us to collect your car registration number for your visit to us.
- We collect payment card information from you should you choose to use this form of payment for purchasing or guaranteeing use of our products and services.
- We may also collect your birthdate and other significant dates for making special offers to you around your birthday and other anniversaries.
Information Automatically Collected. This includes information and personal data collected:
- Through CCTV at our properties. We operate CCTV systems at our properties. These are in operation and video recordings may be made. This activity is carried out for security and service reasons for the better management of Neptune and security for all its clients and staff.
3. WHY DO WE PROCESS YOUR PERSONAL DATA?
Your personal data will be stored in a centralised system which is under the control of Neptune and accessible by authorised staff, and relevant suppliers.
We use the information we collect about you to process your bookings, answer your queries, process your gift card purchases, provide our restaurant facilities and services, enable you to manage your website user account and provide loyalty programmes. With your consent, we will contact you via our marketing and sales channels (email/phone/post) about other related products and services we, or our group business, provide which we think may be of interest to you. Our marketing communications are sent by email.
We mainly collect, store and process personal data at two different stages: (i) before you decide to visit and (ii) when you visit, or have visited.
i. Before you decide to visit Neptune
When you visit our Website (neptune.london), we collect information about your use of the Website. This includes both information we collect directly from you, and information we collect about your behaviour. This information may constitute ‘personal data’ under applicable law. We use this information to provide you with (personal) offers, both on our Website and via advertisements on other websites you visit.
Generally. We may use other companies to serve third-party advertisements when you visit and use the Website. These companies may collect and use click stream information, browser type, time and date, subject of advertisements clicked or scrolled over during your visits to the Website and other websites in order to provide advertisements about goods and services likely to be of interest to you. These companies typically use tracking technologies to collect this information. Other companies’ use of their tracking technologies is subject to their own privacy policies.
Targeted Advertising. We use Website information to provide you with (personal) offers, both on our Website and via advertisements on other websites you visit. [In order to serve offers and advertisements that may interest you, we may display targeted advertisements on the Website, or other digital properties or applications in conjunction with our content based on information provided to us by our users and information provided to us by third parties that they have independently collected. We do not provide personal data to advertisers when you interact with an advertisement.
ii. When you visit or have visited Neptune
When you make a reservation, you will have to provide us with your name, email address, phone number, the dates you are staying with us and a credit card token or other payment information as applicable. We use this personal data to process the reservation, for billing purposes, and to allow us to communicate with you about your reservation. When you stay in one of our properties, we will collect personal data about your preferences, use of our services, and location.
Overview of activities under stage (i) and (ii):
We may at each of the stages outlined above use your personal data but only when and to the extent the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
- Where you have provided your consent.
For your convenience, we have made an overview of activities that involve the processing of your personal data, and the corresponding legal basis/legal bases that allow us to process this data:
First of all, we store the personal data you provide to us in our systems for administrative purposes.
We store your personal data in our database(s), also after your transaction has been completed and after you have dined, to be able to contact you and welcome you again in the future.
For many of our business purposes we use cloud based services. Therefore, for technical and organizational reasons, it is necessary that your personal data is transferred to servers located in the US, or to servers located in countries outside of the European Economic Area (‘EEA’).
We process your booking, howsoever made directly via our website or via a third party (online) booking agent.
We offer and provide services and products you request from us or which we may think you are interested in, via email. These marketing communications contain commercial offers and news of Neptune and related third parties. We use the email address you provide to send the newsletter to. If you no longer wish to receive the newsletter, you can unsubscribe and we will no longer send you these marketing communications.
We use credit card data or other payment data for invoicing purposes.
If you would like to park in one of our parking areas we may collect your license plate number for security purposes.
We collect data on your use of our Wi-Fi services for security and anti-piracy purposes (such as: IP address, your device’s MAC address, connections made, location, etc.). We do not process the content of traffic.
We endeavour to provide a high level of security of both the information we store as well as our facilities, (IT) systems and premises, by means of encryption, physical security measures, passwords, company procedures and policies and professional IT support. Personal data may be processed in this context by Neptune and its vendors.
We endeavour to prevent our services and facilities (properties) from being used for illegal purposes, of any kind. Personal data may be processed in this context by Neptune and its vendors, such as through CCTV surveillance.
We engage in activities required for compliance with legal obligations, third party claims or requests from public authorities, such as (i) the mandatory storage/containment of certain information because of a criminal investigation, (ii) requests from third parties for access to information (iii) any further instructions from third parties, such as supervisory authorities, that involve data processing.
If you have special requirements then it may also be necessary to collect special categories of personal data in relation to diet or disability.
4. SHARING YOUR DATA
We may share your personal data as follows:
- Third Parties Designated by You. We may share your personal data with third parties where you have provided your consent to do so.
- OurThird Party Service Providers. We may share your personal data with our third party service providers who provide services such as payment processing, information technology and related infrastructure provision, business support (operational and administrative), customer service, the processing and delivery of marketing communications to you, email delivery, auditing and other similar services. These third parties are only permitted to use your personal data to the extent necessary to enable them to provide their services to us. They are required to follow our express instructions and to comply with appropriate security measures to protect your personal data. Third parties are subject to confidentiality obligations and may only use your personal data to perform the necessary functions and not for other purposes.
- Affiliates. We may share some or all of your personal data with our affiliates, in which case we will require our affiliates to comply with this Privacy Statement. In particular, you may let us share personal data with our affiliates where you wish to receive marketing communications from them.
- Corporate Restructuring. We may share personal data when we do a business deal, or negotiate a business deal, involving the sale or transfer of all or a part of our business or assets. These deals can include any merger, financing, acquisition, or bankruptcy transaction or proceeding.
- Other Disclosures. We may share personal data as we believe necessary or appropriate: (a) to comply with applicable laws; (b) to comply with lawful requests and legal process, including to respond to requests from public and government authorities to meet national security or law enforcement requirements; (c) to enforce our Privacy Statement; and (d) to protect our rights, privacy, safety or property, and/or that of you or others.
We do not share your data with any third parties outside of the above processing arrangements and we do not share your data with any business external to our group for their own marketing purposes. From the data we collect, you should only ever receive marketing communications from our own brands and hotels.
5. INTERNATIONAL DATA TRANSFERS
In some instances it is necessary to transfer your personal data overseas. Any transfers will be made in full compliance with all aspects of the applicable regulations.
For many of our business purposes we use cloud based services. Therefore, for technical and organizational reasons, it is necessary that your personal data is transferred to servers located in the US, or to servers located in countries outside of the EEA. When we transfer the data to a country outside of the EEA that does not offer an adequate level of data protection, we will ensure compliance with applicable law by way of EU Model Clauses, EU-US Privacy Shield-certification, or other legally accepted safeguards, as applicable.
6. YOUR RIGHTS
The GDPR provides the following rights for individuals:
Right to revoke consent
If we process personal data on the basis of your consent, you have the legal right to revoke such consent at any time. We will then cease the relevant processing activity going forward.
Right of access to your information
If you want to know what personal data we have collected or process about you, you may request us to provide a copy of your personal data by sending an email to email@example.com. We will ask you to identify yourself. We will not provide you with a copy of your personal data to the extent that the rights and freedoms of others are or may be adversely affected.
Right to rectification and erasure of data, and restriction of processing
If you believe that our processing of your personal data is incorrect, inaccurate, unlawful, excessive, incomplete, no longer relevant, or if you think that your data is stored longer than necessary, you may ask us to change or remove such personal data or restrict such processing activity, by sending an email to firstname.lastname@example.org.
Right to data portability
You have the right to receive your personal data, which you have provided to us, in a structured, commonly used and machine-readable format, in accordance with Article 20 of the General Data Protection Regulation.
Right to object
You have the legal right to object, on grounds relating to your particular personal situation, at any time to processing of your personal data. Furthermore, you have the right to object at any time to our processing of your personal data for direct marketing purposes or to profiling. You can do this by either (i) opting out by using the option we provide in the relevant direct marketing message (e.g. an email newsletter), or (ii) by sending an email to email@example.com or (iii) writing to:
Cnr of Guilford Street and Russell Square
For the sake of clarity: without prejudice to the foregoing we are at all times entitled to send you messages that do not constitute direct marketing, i.e. service messages.
General information relevant for all requests and queries
Nothing in this Privacy Statement is intended to provide you with rights beyond or in addition to your rights as a data subject under applicable mandatory data protection law.
We will use reasonable endeavours to respond to your request or query within one month. We are entitled to extend this term by another two months if the complexity of the situation so requires. If your request is manifestly unfounded or excessive we may either (i) charge you a fee, or (ii) refuse to process your request. With respect to access requests we may also charge you for extra copies. If we decide not to honour your request or answer your query, we will explain our reasons for doing so in our reply.
7. PROTECTION AND STORAGE OF YOUR DATA
We have used and will continue to use reasonable endeavours to protect your personal data against loss, alteration or any form of unlawful use. Where possible, your personal data will be encrypted and stored on a virtual private server that is secured by means of state of the art protection measures. A strictly limited amount of people have access to your personal data.
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.
9. RETENTION OF INFORMATION
We will only retain your personal data for the period necessary to fulfil the purposes outlined in this Privacy Statement. This may be up to 4 years, unless a longer retention period is required or permitted by law (which is typically the case in the context of our obligations under tax law).
Should you choose to unsubscribe from our mailing list, please note that your personal data may still be retained on our database to the extent permitted by law.
We are committed to resolve any complaints about our collection or use of your personal data. In case you have any questions in relation to this Privacy Statement or our practices in relation to your personal data you may send an email to firstname.lastname@example.org. We hope to resolve any complaint brought to our attention, however if you feel that your complaint has not been adequately resolved, you reserve the right to contact your local data protection supervisory authority, which for the UK, is the Information Commissioner’s Office.
We have done our best to make sure that this Privacy Statement explains the way in which we process your personal data, and rights you have in relation thereto. We may change this Privacy Statement from time to time to make sure it is still up to date and we will notify you if we make any material updates. We may also notify you in other ways from time to time about the processing of your personal information.