PRIVACY policy

1. About us

This website is operated by Bluebelt Hospitality Limited (‘we’, ‘us’ or ‘Bluebelt). For the purposes of this Privacy Policy, we are the Data Controller, which means that we determine why and how we process the personal information you give us when using this website.

This notice provides you with information about your rights and our obligations, and explains:

• the personal information we collect and why;
• how and when we process it;
• and how you can access, amend and erase the information we hold about you. 

By using venues operated by us under our Original Collection brand, our websites, our social media pages, our telephone reservations lines, our customer services and any other Original Collection service, you acknowledge that we are processing your personal information and – where necessary – consenting to such practices, as outlined in this statement.

2. Personal information that we collect

The personal information that we collect may include the following about you (and others if you provide us with their personal information):

Name

Date of birth

Home address

Personal email

Business email

Home telephone number

Mobile telephone number

Business telephone number

Card payment details 

ID information such as passport number and driving licence number

Car registration number

Disability and health information

Additional information (dietary and other preferences and special requirements)

Website behavioural data (such as through tags and cookies – see our separate Cookie Policy)

Partner’s birthday

Anniversary date

3. How we collect your personal data

We may collect personal information about you (and others if you provide us with their personal information) when you:

1. make or manage a booking or purchase directly with us via our website, email, phone, in person or by post;
2. make or manage a bookingor purchase via a third party service provider or partner;
3. subscribe online to our newsletter and other marketing emails (in line with 4b, Marketing emails);
4. make an enquiry via a website form, email, phone or post;
5. follow, engage with or post material to our social media pages;
6. complete customer feedback or surveys as part of your stay at one of our venues;
7. register at reception in one of our venues;
8. make a complaint against us or are involved in a legally recordable incident at our premises;
9. speak to a member of one our customer services teams;
10. take part in competitions or promotions; and/or
11. use our website in any other way.

4. How we use your personal data

Bluebelt takes your privacy very seriously. We will never disclose, share or sell your data without your consent, unless required to do so by law. We retain your data only for as long as necessary and for the purpose(s) specified in this notice. Where you have consented to us providing you with promotional offers and marketing, you are free to withdraw this consent at any time. The purposes and reasons for processing your personal data are detailed below.

We collect personal information:

a) To take the necessary steps to fulfil our obligations under a booking contract

• Bookings and payments – communicate with you about bookings, products and services we are providing you with (and with others if you provided us with their personal information).
• Bookings updates – send you details of new, amended or cancelled bookings.
• Update you about things that affect your booking – contact you (and others if you provided their personal information) if there is a change that affects your booking or any information or personal data you have given us, such as changes to this privacy policy or booking terms and conditions.
• Communication with customer services – provide you with the information you have asked for in response to an enquiry made by you.

b) With your consent

• Marketing emails – create a profile about you for use by marketing so we can send you information that’s tailored to your needs.
• Offers and promotions – tell you about offers, promotions and other products and services that we think may interest you (see previous point, marketing emails).
• Keep records showing your consent status – we use these to ensure we reflect your wishes when we communicate with you.
• To meet our legal obligations.
• Accounting and taxation: ensure we meet our legal obligation for business accounting and tax purposes.

c) When we have a legitimate interest to do so

• Where this is the case, we have carried out a thorough Legitimate Interests’ Assessment to ensure we have weighed up your interests and the risks posed to you against our own interests, ensuring that they are proportionate and appropriate.

5. Your rights

You have the right to access any of your personal information that we process and to request information about:

• What personal data we hold about you.
• The purpose of processing. 
• The categories of personal data concerned.
• The recipients to whom the personal data has/will be disclosed. 
• For how long we intend to store your personal data.
• If we did not collect the data directly from you, information about the source.

If you believe that we hold any incomplete or inaccurate data about you, you have the right to ask us to correct and/or complete the information. We will strive to do so as quickly as possible; unless there is a valid reason for not doing so, at which point you will be notified. You also have the right to request erasure of your personal data or to restrict processing (where applicable) in accordance with the data protection laws, as well as object to any direct marketing from us. Where applicable, you have the right to data portability of your information and the right to be informed about any automated decision making we may use.

If we receive a request from you to exercise any of the above rights, we may ask you to verify your identity before acting on it; this is to ensure that your data is protected and kept secure.

To make a request, please contact our Data Protection Officer by post or email:

Caroline Bestwick
Data Protection Officer
Bluebelt Hospitality Ltd
Unit 5 The Chandlery 
Bradford on Avon Marina
Trowbridge Road
Bradford on Avon 
BA15 1UD
cbestwick@original.co.uk

6. Sharing and disclosing your personal information 

We do not share or disclose any of your personal information without your consent, other than the purpose specified in this notice or where there is a legal requirement. We use third parties to provide some services and business functions. However, all processors acting on our behalf only process your data in accordance with instructions from us and comply fully with this privacy notice, the data protection laws and any other appropriate confidentiality and security measures.

7. Consequences of Not Providing Your Data

You are not obligated to provide your personal information to Bluebelt. however, as this information is required to process your booking we will not be able to do this without the information provided.

8. How long we keep your data

We retain personal information only for as long as it is necessary and we have strict review and retention policies in place to meet these obligations. We are required under UK tax law to keep your basic personal data (name, address, contact details) for a minimum of 6 (six) years, after which time it will be destroyed. Where you have consented to us using your details for direct marketing, we will keep such data until you notify us otherwise and/or withdraw your consent.

9. Special category data

Because of the products, services or treatments that we offer, we sometimes need to process sensitive personal information (known as special category data) about you, to ensure we can cater for dietary or other requirements for medical or religious reasons. Where we collect such information we will process the minimum necessary for the specified purpose.

10. Making a complaint 

We only process your personal information in compliance with this privacy notice and in accordance with the relevant Data Protection laws. If you wish to raise a complaint about the processing of your personal data you have the right to lodge a complaint with the supervisory authority, the Information Commissioner’s Office (ICO).

Information Commissioner’s Office (ICO) 
Wycliffe House Water Lane 
Wilmslow 
Cheshire 
SK9 5AF 
Tel: 0303 123 1113
https://ico.org.uk

11. Contact details

If you have any questions about this policy, need more information or want to make a complaint, use the following details to contact us.

Caroline Bestwick
Data Protection Office
Bluebelt Hospitality Ltd
Unit 5 The Chandlery 
Bradford on Avon Marina
Trowbridge Road
Bradford on Avon 
BA15 1UD
cbestwick@original.co.uk