Your full satisfaction and confidence in JJW Hotels &
Resorts are absolutely essential to us.
That's why, as part of our commitment to meeting your
expectations, we have set up a customer privacy protection policy.
This Charter formalizes our commitments to you and describes how
JJW Hotels & Resorts uses your personal data.
This Statement is designed to provide you with appropriate
information, assurance and confidence that we are handling your
data in a secure, professional manner, with the respect it
deserves. This statement therefore addresses what personal
information we collect and how we handle the personal information
shared with us. Please read the following carefully to understand
our views and internal practices.
For the purposes of the General Data Protection Regulations
(GDPR), the data controller is San Lorenzo Golf Course with the
Data Protection contact being Clifford Goldhill.
Who is JJW Hotels & Resorts Limited?
This Privacy Statement is issued by JJW Hotels & Resorts
Limited (collectively referred to as "JJW H&R", "we", "us" or
"our" in this Privacy Statement), which includes the direct and
indirect subsidiaries of JJW Hotels & Resorts Limited and
covers information collected and used by us in the course of our
business. When we mention "JJW H&R", "we", "us", or "our" we
are referring to the company that processes your personal
information.
Your information may also be collected and used by JJW H&R
branded hotels. In most cases, these hotels are independently owned
and their use of your information is only covered in this Privacy
Statement where specifically noted.
Information We Collect and How We Use and Share
It
We collect and use personal information if you make a booking
through our reservation system, stay at a JJW H&R branded hotel
or interact with us through our corporate site. We generally
collect this information directly from you, but in some cases we
may collect your information from other sources. For example, we
occasionally run offer campaigns on the hotel websites. In these
cases, we always ask if you are happy for JJW H&R to retain the
personal data of the respondents to the offer. We also collect
information through our third party service providers' use of
technologies such as pixels, web beacons, and similar
technologies.
You do not have to provide us with your information although in
some cases, if you do not, it may mean that you are unable to use
our services. For example, we may be unable to complete any booking
you may wish to make.
There are other times when we collect and use personal
information, for example if you choose to sign up to receive our
newsletters or other special offers and promotions or participate
in one of our other services. In these instances, we will collect
information from you for running and administering the respective
special offer, promotion or service that you have elected to
participate in. The information collected may include personal
details such as your name and address as well as certain
demographic information. In each case, we will collect, use and
secure your information in a manner consistent with the general
principles set out in this Privacy Statement unless we tell you
otherwise.
We also collect information from you when you browse our
website, or participate in certain services at a JJW H&R
branded hotel. In these instances, information such as your country
information, internet protocol ("IP") address, media access control
address and other characteristics about your system or device may
be automatically collected. This information is collected for
functional purposes as well as to improve your experience when
using these services. This information may also be used for
aggregated trend and statistical analysis, and for showing you more
relevant advertisements and messages.
The Legal Basis for Processing Your Personal
Data
We are committed to collecting and using your information in
accordance with applicable data protection laws.
We will only collect, use and share your information where we
are satisfied that we have an appropriate legal basis to do this.
This may be because:
- You have provided your consent to us using the personal
information;
- Our use of your information is necessary to perform our
contract with you, for example, making and managing your
booking;
- Our use of your information is necessary to meet
responsibilities we have to our regulators, tax officials, law
enforcement, or otherwise meet our legal responsibilities;
- Our use of your information is in our legitimate interest as a
commercial organisation, for example to operate and improve our
services and to keep our clients informed about our products and
services (including for targeted advertising) - in these cases, we
will look after your information at all times in a way that is
proportionate and respects your privacy rights and you do have a
right to object to processing.
If you have provided your consent to our processing of your
information you can withdraw this consent at any time by contacting
the Data Control Office on [email protected].
Data Transfer
As we operate via a network of corporate offices, reservation
and service centres, data centres and hotels, it may be necessary
to transfer your information to another EU country outside of the
country where it was originally collected or outside of your
country of residence or nationality. The information that you
provide us during the course of a reservation or through the
provision of any other services may be transferred to any of our
JJW H&R or affiliated entities and hotels for the purposes of
carrying out or facilitating these services. It will also be
necessary to transfer this information to third parties, including,
without limitation, third-party service providers.
Using our Websites and Other Technology
We and our third-party service providers use cookies, pixels,
web beacons, and other similar technologies on our websites, and in
other areas of our business to collect information and provide you
with the services that you have requested or participate in and to
provide targeted advertising. Subject to local consent
requirements, we may use this and other information we collect,
such as a hashed email address, to help us and our third-party
service providers identify other devices that you use (e.g., a
mobile phone, tablet, other computer, etc.). We, and our third
party service providers, also may use the cross-device tracking and
other information we learn about you to serve targeted advertising
on your devices. We also use the information that we collect to
improve our products and services as well as your experience when
visiting our websites.
Cookies and other Tracking Technologies
What is a cookie: A "cookie" is a small text file that is placed
onto an Internet user's web browser or device and is used to
remember as well as obtain information about that party. You might
be assigned a cookie when visiting our websites. In some instances,
where permitted under the applicable law, cookies may also be used
for the purposes of certain email campaigns.
What types of cookies we use and how we use them: We use three
primary types of cookies, which include:
- Functional Cookies - these cookies support the
use of the website and applications and enable certain features to
enhance your experience. For example, we use functional cookies to
facilitate your reservation and to remember your selections as you
move from page to page. We also use functional cookies for
remembering things like your sign-in information and hotel
preferences to avoid you having to re-enter it.
- Performance Cookies - these cookies collect
information needed to support the website and our applications and
allow us to improve our website and identify any problems that you
faced while visiting us. For example, performance cookies may
provide us with information about how you came to our website and
how you navigated around our website during your visit. We also use
these cookies to provide us with certain statistical and analytics
information, such as how many visitors came to our website or how
effective our advertising is.
To learn more about cookies and how they are used, please visit:
http://www.allaboutcookies.org/.
Third-party cookies: As described above, we use a
number of third-party service providers to help us manage, carry
out and improve our advertising. These parties set cookies at our
direction to help us collect information and provide you with
advertisements that we believe would be relevant for you. In some
instances these third parties may also assist us by providing
certain statistical and analytics information in relation to our
marketing practices.
Managing cookies and opting out: You can choose
to visit our web sites without cookies, but in some cases certain
services, features and functionality may not be available. To visit
without cookies, you can configure your browser to reject all
cookies or notify you when a cookie is set.
Other technologies: Other technologies such as
pixels and web beacons may also be used on our websites, in email
messages and in other areas of our business. These technologies are
used to improve our products and services as well as our marketing
efforts.
Location Information
We may receive information about your location during the course
of and for the purpose of providing you the services described
above through your use of our websites. For example, if you are
using our mobile applications and have consented to sharing your
location information with us, this information might be collected
through GPS or Bluetooth technologies to enable us to provide
certain services to you such as customised offers and promotions.
In addition to your use of our websites and mobile applications, we
may also receive location information from wireless networks or
cellular towers in proximity to your mobile device, through your
Internet protocol ("IP") address or through your use of other
services we provide at our hotels. We may also have access to
location information that you provide to us through your use of
social media, such as when you "tweet" your location. Your location
preferences can be set or modified at the device level or through
modifying your settings with the relevant social media
platform.
Use of WI-FI Services
When you use JJW H&R Hotels WI-FI service, we may collect
and process certain additional information.
What information we collect
- Registration and User-Provided Information:
When you register to use JJW H&R Hotels WI-FI service, we may
collect personal information about you. You may also provide us
with personal information about you in various ways when you use
JJW H&R Hotels WI-FI service, for example, when you send us
customer service-related requests.
- Device Identifiers: In the course of providing
the JJW H&R Hotels WI-FI service, we may automatically collect
a device identifier (such as your IP address, MAC Address or other
unique identifier) for the computer, mobile device, technology or
other device you use to access JJW H&R Hotels WI-FI service. A
device identifier is a number that is automatically assigned to
your device when you access JJW H&R Hotels WI-FI service, and
we may identify your device by its device identifier. When you use
JJW H&R Hotels WI-FI service, we may view your device
identifier and use this information to enhance our service.
- Other device information: We may also
automatically record certain information from your device
including, device type, the web pages, apps or sites that you
visit, and the dates and times that you visit, access, or use JJW
H&R Hotels WI-FI service. While generally this information is
pseudonymous and/or aggregated, this information may be associated
with your JJW H&R Hotels service account information or
persistent identifiers. This data helps us to manage our networks
and provides us with information about the use of JJW H&R
Hotels WI-FI service. We do not, however, collect and process the
contents of email communications or other electronic communications
you send or receive when using JJW H&R Hotels WI-FI
service.
How We Use the Information We Collect
We use personal information only for the purposes described in
this Policy, except if otherwise disclosed to you at the time the
data is collected or further authorised by law or by you.
- We use the personal information that we collect through JJW
H&R Hotels WI-FI service to operate, maintain, enhance and
provide all features of the service, to provide services and
information that you request, to respond to comments and questions
and to provide support to users.
How We Secure Your Information
We are committed to protecting the confidentiality and security
of the information that you provide to us. To do this, technical,
physical and organisational security measures are put in place to
protect against any unauthorised access, disclosure, damage or loss
of your information. The collection, transmission and storage of
information can never be guaranteed to be completely secure,
however, we take steps to ensure that appropriate security
safeguards are in place to protect your information.
Managing Your Preferences and Information
We want to ensure that you have the necessary tools at your
disposal to control the information that you provide to us,
including how we communicate with you. It is also important that
you contact us to update your information if any of it is
inaccurate or changes.
Managing Your Information
In the event any information that you provide to us is
inaccurate, changes or you would like this information deleted,
your information can be updated by contacting [email protected]. In some instances, you
can update certain aspects of your personal information by going to
your account, signing in and clicking on the "Personal Information"
section to update and amend your personal information. For all
other cases, please contact [email protected]. We will respond to your
request within a reasonable timeframe.
Please note that in some instances it may not be possible to
delete certain pieces of your information and a portion of the
information may be needed for suppression purposes. In other
instances, we may not have the ability to delete certain pieces of
information that are stored on our systems or that have been
provided to third parties in connection with the services discussed
in this Privacy Statement.
Children
Our websites are not intended for children and we do not
intentionally solicit or collect personal information from
individuals under the age of 18. If we are notified or otherwise
discover that a minor's personal information has been improperly
collected, we will take all commercially reasonable steps to delete
that information. In limited instances, we may have a campaign or
programme targeted toward children. In these instances, details on
the information practices will be presented within the terms and
conditions of the programme or campaign.
Retaining Your Information in Our Systems
We generally only keep your information for as long as is
reasonably required for the reasons explained in this privacy
policy. In some cases we keep transactional records (which may
include your information) for longer periods if necessary to meet
legal, regulatory, tax or accounting needs. We will also retain
information if we reasonably believe there is a prospect of
litigation.
We maintain a data retention policy which we apply to the
records we hold.
How do You Contact us Regarding Your Personal Data and
how it is Handled?
If you wish to contact us regarding;
- The manner in which your personal data is handled
- Updating your personal preferences
- Utilising your personal rights
- Wishing to complain
- 1) Email us at [email protected]
- 2) Post your enquiry to The Data Protection Officer, JJW Hotels
& Resorts Limited, 78 - 80 Wigmore Street, London W1U 2SJ.
Please note, we may require proof of identity in order to
complete some requests. A copy of your driving licence is the most
suitable, however other forms of photographic identity are also
acceptable.
If you remain unhappy with the manner that your data is being
handled and/or you feel that the response is not sufficient, please
contact the Information Commissioners Officer (ICO) using their
website www.ico.org.uk who are the supervisory
authority for data protection within the UK. If the situation
pertains to France the French authority is the CNIL and can be
contacted at www.cnil.fr If the situation pertains to
Portugal the Portuguese authority is the CNPD and can be contacted
at www.cnpd.pt
Where EU data protection laws apply, you have a right to lodge a
complaint with your local data protection supervisory authority at
any time. However, we ask that you please try to resolve any issues
with us first before referring your complaint to the supervisory
authority.
Changes to this Privacy Statement
In some instances, we may have to change, modify or amend this
Privacy Statement in order to comply with the evolving regulatory
environment or the needs of our business. Subject to any applicable
legal requirements to provide additional notice, any changes to
this Privacy Statement will be communicated through our websites
and mobile applications. However, if there will be changes made to
the use of your personal information in a manner different from
that stated at the time of collection we will take appropriate
steps to notify you, such as by posting a notice on our website for
30 days prior to the changes taking effect or by emailing
you.
What Rights do You Have Over Your Personal
Information?
Under GDPR, individuals have by far greater ownership of the way
in which they are able to manage their own personal information.
There are now eight areas in which you have rights to, known as the
Data Subject Rights and they are broken down as follows;
Right to Access/Subject Access Requests - The
Right to Access provides you with the opportunity to obtain all the
information JJW Hotels & Resorts Limited hold against you as an
individual (also known as Subject Access Requests). The GDPR allows
JJW Hotels & Resorts Limited one month to provide you with all
the information we hold against you and your address. This will
solely be in relation to the person making the request. We will
review all our manual and electronic data and provide you with
everything accordingly. If your request specifies what
documentation you require, this will assist us in responding to
your request quicker.
Right of Rectification - If you believe that
the information that JJW Hotels & Resorts Limited hold about
yourself is incorrect, inaccurate or incomplete, the right of
rectification ensures that you can contact us and we will update it
accordingly. We will provide you with confirmation once the update
has taken place.
Right to Erasure - Under GDPR, you have the
option for all records of your personal information held by JJW
Hotels & Resorts Limited to be erased. There are however a
number of exemptions to this right, given that we may have legal or
contractual rights to retain your person information. If, however
it is felt that JJW Hotels & Resorts Limited hold information
about you which is no longer necessary for the initial purpose it
was collected, your right to erasure will be granted.
Right to Data Portability - GDPR provides you
with the opportunity for your personal information to be provided
back to you in a portable format. This means that you can transfer
your data to a different provider without the need for you to
provide it again to them.
Right to Withdraw Consent - JJW Hotels &
Resorts Limited like to give you the opportunity to manage the way
in which we communicate with you. Under GDPR, this is known as the
Right to Withdraw Consent. If for any reason, you would no longer
wish for us to contact you, either entirely, or via certain
methods, this right can be used. This simply means that JJW Hotels
& Resorts Limited will update your contact preferences within
our systems, as well as advising third parties with whom we have
supplied your information, of your updated preferences also.
Right to be Informed - This right encompasses
the need for transparency over how we use your data and is the
intention for this entire document. It ensures that JJW Hotels
& Resorts Limited supply appropriate notification about our
processing activities and ensure that they are concise,
transparent, easily accessible, written in clear, plain language
and free of charge.
Right to Restrict Processing - This allows you
the opportunity to let you hold your data but not processes it for
marketing purposes. If you request this right to be actioned, JJW
Hotels & Resorts Limited will place you on a suppression list
where it is no longer processed.
Right to Object - Under GDPR you can object to
processing based on legitimate interest or a task classified as
being in public interest, direct marketing and processing for
purposes of scientific/historical research and statistics.
