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 personalize your experience, show relevant advertisements, and improve your stay.
Who is covered
Who we are
Capital Hotel (“Capital,” “we,” “our,” or “us”) is the data controller when you provide information via www.capitalhotel.com.
Legal basis for using your information
All organizations need a legal reason to use your personal information. We are conscious of our legal responsibilities as a “data controller” and we strive to ensure that the personal information we obtain and use will always be held, used, transferred and otherwise processed in accordance with our legal obligations. There are a number of legal grounds that enable data processing. It’s quite complicated, but here are the most relevant grounds you should be aware of: your consent, to fulfill a contract, for a legitimate interest, and to comply with legal obligations.
What information do we collect?
When you interact with our products and services, we collect information about you and that particular interaction. Generally this may include:
- Your personal details, including contact information and preferences
- Sensitive information (i.e., dietary requirements, disabilities, and religious beliefs)
- Information about your use of our hotel and other services when you stay with us
- Conversations you have when you call our reservations or sales teams
- Information about anyone you’re travelling with or meeting, if that information is provided to us
- Information about the devices you use to interact with us
- Where you provide information to us about other people, you need to make sure you have their permission to do so.
When and how we collect your information?
We collect information you provide to us directly and indirectly when interacting with our products and services, including when you stay with us.
1. You provide information directly to us
This may include when you:
- Book a room online, over email or on the phone
- Visit our website
- Fill out our online forms or registration cards
- Visit our hotel or use our hotel services
- Access hotel internet
- Use our restaurants/bars
- Use social media login functionality
- Interact with us in online forums, by email, text, or on social media
- Post reviews of your stay or interaction with us
- Requests, complaints and/or disputes
2. You provide information via our processors
There may be situations where we use data processors – companies who act on our behalf – to collect your information for us. These processors can only use your information in accordance with our instructions and for the purposes in this Policy.
3. You provide information via our website and partner websites
4. You provide information via Travel agents and partners
We collect information about you when it is provided to us by third parties. This might include online travel agents, travel websites, and other partners. This could be when you make bookings, review your stay online, or where you interact with anyone who promote our hotel. You should always read the privacy policies of travel companies or other third parties you use, as they will use your information in accordance with their own privacy policies.
When you, or someone on your behalf, make a booking using travel agent, booking platform or other third party to use our services, they may pass us information about your booking, including information about anyone else on that booking. The same would be true where you use a third party to make enquiries about our products or services.
Where you interact with third parties who promote our services for us, these third parties may pass us your information.
When you post comments, reviews, or engage in discussions and polls about our products and services, we may receive this information from the platform you interacted with or from our partners who monitor how our brands are performing.
We may also obtain information about you from our partners and other companies that have your permission to share your information both online and offline, like insight providers.
Where we do receive information about you from other sources, we may combine it with information we already hold about you and use it in accordance with this Policy.
We may receive updated information about you from organizations that provide services to you. For example, we might be updated if you move home so that we can keep our records up to date or receive updated bank details to ensure that you can continue to use our products and services. Alternatively, we may be updated if your flight is late, so that we can anticipate your arrival more accurately.
How we use your personal information
The reason we use your information will often be obvious from the way you interact with us; however, our uses of your information may not always be so obvious. When you provide your information to us, we may use it to (see below for code descriptions):
- Provide you with the products and services you have requested, including administering your booking, responding to any inquiries, complaints or requests you may have C, LI, A
- To manage our relationship with you C, LI, A
- Tailor our service to your preferences, where you tell us about them C, LI, A
- Make decisions about what direct marketing to show you based on how you have interacted with us LI
- Improve our products and services online and offline, including our website LI
- Allow you to interact with us online, offline, in forums, on social media and elsewhere C, LI, A
- Monitor the use of our products and services and content LI, LO
- Verify your identity LI, A
- Conduct analysis, system testing and statistical research LI, LO
- Manage our hotel’s efficiency LI
- Send you product or service-related communications, service messages C, LI, A, LO
- Send you direct marketing, where you have consented C, LI
- Allow social sharing functionality C, LI, A
- Facilitate payments and credit checks C, LI, A, LO
- Provide you with help and support where it may be required. For example, we contact you to provide assistance if you do not complete the booking process or experience technical difficulties, where we have your contact details LI, A
(A) To fulfil a contract – We also process your personal information in order to fulfil a contract we have with you. For example, when you book a stay with us, we will process your information to administer that stay.
(LI) For a legitimate interest – Sometimes we may use your information to help achieve our business objectives but only where that activity doesn’t negatively affect your rights.
(LO) To comply with legal obligations – We may need to use your information to comply with legal obligations.
Profiling and preferences
We sometimes make decisions about what your interests are based on the way that you interact with us and the information we hold about you, this is called profiling. For example, if you frequently choose a specific room or regularly request certain amenities, then we might use this information to improve your experience by pre-selecting certain features of your stay for you.
In addition to sending you information about the products and services you use (product communications), where we have your permission we may send you direct marketing communications about our products, services, events and offers. You will be able to opt-out of direct marketing by following the instructions in the communications you receive or changing your device settings.
Analysis and product development
We may use your information to improve the products and services we offer. For example, we may look at the preferences our guests have when they stay with us to offer more relevant personalization to customers.
Linked services, third party sites and content
Our website may, from time to time, contain links to other websites which are outside of our control and are not covered by this Policy. Please note that we are not responsible for the collection, use, maintenance, sharing or disclosure of data and information by such parties. We do not accept any responsibility or liability for other sites’ privacy policies.
Protection of personal data
We strive to protect the privacy of the information that you share with us. We have undertaken reasonable efforts to implement security measures designed to protect all data we collect against unauthorized access. We utilize the industry standard security measures available through your browser, so that it is unlikely that your information can be read as it travels over the Internet. That said, we cannot ensure or warrant the security of the information that you submit to us via capitahotel.com and you do so at your own risk. We also implement measures to protect your personal information off-line.
Payments and credit checks
Your information may be used to take payment for products and services and may be used to verify credit details, related to payments.
Disclosures required by law
Your information will be disclosed where we are obliged by law to do so. We may also disclose your information where we are allowed by law to protect or enforce our rights or the rights of others and for the detection and prevention of crimes, such as fraud.
If you post or send offensive or inappropriate content anywhere on or to our website, or otherwise engage in disruptive behavior on our website, we may use the information that is available to us about you to stop such behavior. This may involve responding to or informing relevant third parties and law enforcement agencies.
When you complete our registration forms or use our services, we may transfer your information to our processors. When you give us information about other individuals, you confirm that you have authority to act for them and have made them aware of the potential transfer of their information outside the EEA.
How we share your personal information
Where you provide your information to us we may share it with our service providers in order to facilitate your stay at the Capital. Your information will only be shared and used in accordance with this Policy and where an agreement is in place to ensure that your information is protected. We won’t sell your personal information without your consent
1. Sharing with our processors
There may be situations where we use data processor companies who act on our behalf to process your information for us. These processors can only use your information in accordance with our instructions and for the purposes in this Policy.
2. Sharing with commercial partners
We may share your information with third parties for their own purposes, including direct marketing, where we have told you about this and you have given permission. As above, this may include sharing information with local businesses, restaurants, and golf resorts.
Rights in relation to your information
1. Your rights
Under GDPR, you may have the right to object, erase, or restrict our processing of your information. We will carefully consider your request as there may be circumstances which require us to, or allow us to, continue processing your data.
The request must be in writing (including email) and should contain your name, address, and the details of your request.
2. Personal information from Children
We do not provide services to children, nor do we market to children. We do not knowingly collect personally identifiable information from children under 18 without permission from a parent or guardian.
3. GDPR – The fees to access the personal data
We must provide a copy of the requested information free of charge. However, we can charge the requestor a ‘reasonable fee’ when a request is manifestly unfounded, mischievous, vexatious, specious or excessive, particularly if it is repetitive. We may also charge a reasonable fee to comply with requests for further copies of the same information. This does not mean that we can charge for all subsequent access requests. The fee will be based on the administrative cost of providing the information.
4. Complaining to the regulator
If you have any comments, concerns or complaints about our usage of your information we would ask that you contact us first, so that we can try and resolve any matter. However, where we are unable to assist, you are able to complain to the Information Commissioner’s Office in the United Kingdom or the data protection regulator in your country of residence.
5. Retention of your information
We will retain your information for as long as necessary for the uses set out in this Policy or while there is a legitimate business reason for doing so. We will destroy your personal information as early as practicable and in a way that the information may not be restored or reconstructed. If you ask us to delete your information before this time, we may not be able to do so for technical, legal, regulatory or contractual constraints. For example, where you wish to be suppressed from direct marketing, we would need to retain your information for this purpose.
Where you ask for your account to be closed, we will do this as soon as possible subject to any terms and conditions relating to the account. Your information will be retained in order to comply with legal and regulatory obligations as well as for analysis, to prevent fraud, collect any monies owed, and to resolve disputes.
Cookies and similar technologies
What are cookies?
What cookies do we use?
1. Essential cookies
These make our website work. They remember what dates you want to stay with us, what sort of room you want and that you are logged in to your account. They also allow us to collect information about your use of our website, enabling us to improve the way it works. Analytics cookies also allow us to see if there are any technical issues on our website and if you are experiencing any issues. They also allow us to look at usage statistics and performance.
We use Google Analytics to help us understand how you use our services. For more information on Google Analytics, please visit Google’s website.
2. Functional cookies
These cookies collect information about the language you have requested the site display content in, remembering your username so you can log-in more quickly, text size, location you are in and generally allow us to customize your experience.
What other purposes do cookies and similar technologies are used for:
- Allow you access to our website and permit your internet connection to our website;
- Allow our servers to record information about your device (such as IP address, browser type, location, hardware and software information);
- Assess content usage;
- Provide relevant content;
How to delete cookies?
Deleting your cookie settings is also relatively easy but the process does differ between browsers. Here’s how to delete cookies in the most popular browsers.
You can find this and further information about cookies at http://www.aboutcookies.org.
You can also control which companies set cookies on your devices by visiting the following pages. Please note that you will need to turn off any ad blockers or privacy tools to see what cookies are being set.
From time to time we may make changes to this Policy. This might be in relation to changes in the law, best practice, changes to the services we provide or collection and use of your personal information. We will always display clearly when the Policy was last updated and where appropriate, notify you of any relevant changes.
This policy was last updated on 25 May 2018