PRIVACY NOTICE

Platinum Pillows understands that data privacy is important and that you care about how your personal data is processed. We respect and value the privacy of any person who visits our website as well as any client or guest who makes a booking with us.

In collecting your information, we are acting as a data controller and, by law, we are required to provide you with information about us, about why and how we use your data and about the rights you have over your data.

This Privacy Notice applies only to your use of Our Site and to any client or guests who make a booking with us and submit their personal data when completing our check-in and on-boarding process.

Please read this Privacy Notice carefully and ensure that you understand it. Your acceptance of this Privacy Notice is deemed to occur when booking with us.

1. DEFINITIONS

In this Notice the following terms shall have the following meanings:

“We”, “Us”, “Our”- refers to Platinum Pillows Management Services Ltd

“Our Site”- means our website https://www.platinumpillows.co.uk

“Booking”- means a request to secure the accommodation as offered on our site. In placing a booking, you will be granted additional access and/or use certain areas and features of Our Site.

2. PERSONAL DATA

Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

3. YOUR DATA PROTECTION RIGHTS

Under the GDPR, you have the following rights, which We will always work to uphold:

A) The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 18.

B) The right to access the personal data we hold about you. Part 12 will tell you how to do this.

C) The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 18 to find out more.

D) The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that We have. Please contact us using the details in Part 18 to find out more.

E) The right to restrict (i.e. prevent) the processing of your personal data.

F) The right to object to us using your personal data for a particular purpose or purposes.

G) The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.

H) Rights relating to automated decision-making and profiling. We do not use your personal data in this way.

For more information about Our Site, use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 18.

4. FURTHER CONTROL OF YOUR DATA

In addition to your rights under the GDPR, set out above, when you submit personal data via Our Site, subscribe to be marketed to, or book with Us you may be given options to restrict our use of your personal data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails and at the point of providing your details).

You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you from receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you

have consented to receive.

5. WITHHOLDING YOUR INFORMATION

You may access certain areas of our site without providing any personal data at all. However, to use all features and functions available on Our Site or to make a booking with us you will be required to submit or allow for the collection of certain data as described below.

6. WHEN MAKING A BOOKING

When you are looking to make a booking with Us, it is likely to be through an agent. When this is the case, the agent will act as a Data Controller in their own right for the personal data they process on your behalf.

We are passed very limited information from the agents when a booking is made and undertake our own additional data recording and validation steps before a booking can be approved.

We will ask you to confirm your standard Contact Data, provide a copy of your ID a well as proof that you are in possession of the payment card used to make the booking. We use this information to facilitate your purchase, prevent fraud and keep in touch with you throughout the process.

7. THE DATA WE COLLECT ABOUT YOU

We may collect, use, store and process different kinds of personal data about you which we have grouped as follows:

Contact Data   Title, name, address, email address, telephone number

ID Data   Government Issued ID (Passport, Driving License, etc.)

Payment Data  Payment card information (Name, Last four digits and Expiry only)

Communications Data  Emails, notes of conversations, etc.

Other Identifier Data  Information about your preferences and interests

8. HOW WE USE YOUR INFORMATION

Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it.

Before you make a booking, we collect and use your data based on legitimate interest. This will persist until such point that a booking has been agreed, after which we will keep and use your data based on our contractual obligation to process it to best service the contract between us.

Your personal data may be used for the following purposes:

• Providing and managing your Booking;
• Validating your identity and preventing fraud;
• Providing and managing your access to our site when making a booking;
• Supplying the accommodation to you. Your personal details are required for us to enter into a contract with you;
• Personalising and tailoring our services for you;
• Communicating with you. This may include responding to emails or calls from you;
• Supplying you with information by email that you have opted-in to (you may unsubscribe or opt-out at any time by contacting us);
• Analysing your use of our services and gathering feedback to enable us to continually improve Our Site and Services.
  

9. HOW LONG WE WILL KEEP YOUR PERSONAL DATA

We do not keep your personal data for any longer than is necessary for the reason(s) for which it was first collected, as summarised below:

*or until such point that you request that we stop marketing to you

10. OUR THIRD-PARTY DATA PROCESSORS

We use several third parties to process personal data on our behalf to deliver the highest level of service to our customers. These third parties have been carefully chosen; all of them comply with the GDPR legislation and have extensive and mature data protection controls in place.

• Google
• Tokeet
• Stripe
• Formsite
• MailerLite

All of these third parties are EU-US Privacy Shield compliant.

11. SHARING YOUR PERSONAL DATA

We will not share any of your personal data with any third parties for any purposes, outside of those parties as required to fulfil our contractual obligation with you, subject to one important exception.

In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

12. ACCESSING YOUR PERSONAL DATA

If you want to know what personal data We hold about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 18.

There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests), a fee may be charged to cover our administrative costs in responding.

We will respond to your subject access request within one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date We receive your request. You will be kept fully informed of our progress.

13. AUTOMATED DECISION MAKING

We do not use the information you provide to make any automated decisions that might affect you.

14. DATA SECURITY

We apply the highest standards of security when it comes to hosting and protecting information. We have put in place appropriate technical and organisational measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.

All activities which require the use of your personal information will be formally assessed for risk(s) relating to the protection of your rights and freedoms to privacy, and the requirements of Us as a data controller.

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.

If at any point you suspect or become aware of a security incident (i.e. your password is stolen, or you receive suspicious communication from someone holding themselves out to be a Platinum Pillows employee or from a website claiming to be affiliated with Us), please let us know using the contact information provided below.

15. WHEN YOU USE OUR SITE

Our Site and booking processes may contain links to other websites. Please note that We have no control over how your data is collected, stored, or used by other websites and We advise you to check the privacy notices of any such websites before providing any data to them.

Please see Our separate Cookies Policy which can be found on Our Site.

16. CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES

This version of our Privacy Notice was last updated in March 2019.

We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if We change Our business in a way that affects personal data protection.

Any changes will be immediately posted on Our Site, and you will be deemed to have accepted the terms of the Privacy Notice on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date.

17. INFORMATION ABOUT US

Our Site is owned and operated by Platinum Pillows Management Services Ltd, a limited company registered in England under company number 11306230.

Registered Office: 40 Broadway Lane, Bournemouth, BH8 0AA

Correspondence Office: Kemp House, 152-160 City Road, London, EC1V 2NX

ICO Registration: ZA203531

18. CONTACTING US

To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details:

Email Address: info@platinumpillows.co.uk

Telephone Number: +44 (0)845 299 7887

Postal Address: Kemp House, 152-160 City Road, London, EC1V 2NX

19. YOUR RIGHT TO COMPLAIN

If you have a complaint about our use of your information, we would prefer you to raise it with us in the first instance to allow us to put it right, but you can also contact the Information Commissioner’s Office as below:

Address: Wycliffe House

    Water Lane

               Wilmslow

               Cheshire

    SK9 5AF

Website: www.ico.org.uk/concerns