PRIVACY POLICY OF EDWARDIAN HOTELS LONDON

PLEASE READ THESE TERMS AND CONDITIONS OF USE CAREFULLY BEFORE USING THIS WEBSITE. By using this website, you signify your assent to these terms and conditions of use. If you do not agree to these terms and conditions, please do not use this website. We reserve the right, at our discretion, to change, modify, add, or remove portions of these terms and conditions at any time. Please check these terms and conditions periodically for changes. Your continued use of edwardian.com following the posting of changes to these terms and conditions (including edwardian.com Privacy Policy and Trademark Notice) will mean you accept those changes.


1. RESTRICTIONS ON USE OF MATERIALS
 

This site is owned by Edwardian London Management Services Limited* a member company of Edwardian Hotels London. Edwardian Hotels London is  the parent company of other subsidiaries which own and operate other hotels, in London and elsewhere in the UK each of which trades as a Radisson Blu Edwardian Hotel, The May Fair Hotel, The Edwardian Manchester and The Londoner Hotel. References to "we," "us," or "our" herein are to London Edwardian Management Services Limited. No material from this website may be copied, reproduced, republished, uploaded, posted, transmitted, or distributed in any way, except that a person may download one copy of the materials on any single computer for his or her personal, noncommercial home use only, provided all copyright and other proprietary notices are kept intact on such a copy.

All trademarks, logos, service marks, trade names and trade dress are proprietary to Edwardian London Management Services Limited or other companies owned by Edwardian Hotels London or by third party licensors. Nobody may frame or utilise framing techniques to enclose any of our trademarks, logos, or other proprietary information (including images, text, page layout, or form) without the prior express written consent of the proprietor. Nobody may use any meta tags or any other "hidden text" utilising Edwardian Hotels London companies' names, trademarks or other proprietary information without prior express written consent of the proprietor.
To obtain permission to reuse or republish electronically any of the proprietary material on this website, please contact privacy@edwardian.com.
 

2. USE OF WEBSITE AND RESERVATIONS
 

Nobody may use the website unless they are at least 18 years of age and can enter into binding contracts (our website is not available for use by minors). Please note that the minimum check-in age may vary from property to property. For questions on the minimum check-in age for a specific property, please contact the property directly prior to making the reservation. A valid credit card is required at check in for payment authorisation. Each user of the website is responsible for maintaining the secrecy of their passwords, login and account information and will be financially accountable for all uses of the website by the user and anyone using the user's password and login information. The website may be used only to make legitimate reservations or purchases. The website may not be used to make any false, fraudulent or speculative reservation or any reservation in anticipation of demand; nor to post or transmit any unlawful, threatening, libellous, defamatory, obscene, indecent, inflammatory, pornographic or profane material or any material that could constitute or encourage conduct that would be considered a criminal offence, give rise to civil liability, or otherwise violate any law; nor for any other purpose that is unlawful or prohibited by these terms and conditions. At any time and without advance notice or liability, a person's access to all or any component of the website may be terminated or restricted.
 

3. DISCLAIMER
 

The material in this website could include technical inaccuracies or typographical errors and changes or improvements may be made to it at any time. The material on this site are provided "as is" and without warranties or any kind, either express or implied. To the fullest extent permissable pursuant to applicable law. London Edwardian Management Services Ltd (LEMSL) disclaims all warranties of merchant ability and fitness for a particular purpose. LEMSL does not warrant that the functions contained in the material will be uninterrupted or error-free, that defects will be corrected, or that this website or the services that makes it available are free of viruses or other harmful components. LEMSL does not warrant or make any representations regarding the use of or the result of the use of the material in this website in terms of their correctness, accuracy, reliability, or otherwise. Each user assumes the entire cost of all servicing, repair or correction. The above exclusion applies save to the extent that any applicable law does not allow it.
 

4. SUBMISSIONS
 

LEMSL is pleased to hear from users and welcomes comments and feedback regarding the website and the products and services offered on it. It is company policy not to accept or consider unsolicited submissions of creative ideas, suggestions, or materials relating to the website or the products and services offered on it. Company staff and consultants may be working on the same or similar ideas, so the policy is intended to avoid the possibility of future misunderstandings when projects developed by company professional staff and/or consultants might seem to others to be similar to their own creative work.

Any submission of a creative suggestion, idea, notes, drawing, concept, or other information (the "Submission") sent to any member of Edwardian Hotels London shall be deemed, and shall remain, the property of the recipient. No submission shall be subject to any obligation of confidence on the recipient's part and the recipient shall not be liable for any use or disclosure of any Submission. Without limitation of the foregoing, the recipient shall exclusively own all now known or hereafter existing rights to the Submission of every kind and nature and shall be entitled to unrestricted use of the Submission for any purpose whatsoever, commercial or otherwise, without compensation to the provider of the Submission.

5. LINKS

No link of another's website shall be made to the website without express prior written consent from LEMSL. LEMSL reserves the right to disable links from any third party website to the website. LEMSL does not review or monitor any other websites linked to the website and is not responsible for the content of any such linked websites. The inclusion of any link to another website does not imply endorsement by any member of Edwardian Hotels London of the other website. A person who links another's website to this website does so at that person's own risk.

6. ACCESS AND INTERFERENCE

Nobody may use any robot, spider, other automatic device, or manual process to monitor or copy the website or the contents or information contained therein without the prior express written consent of LEMSL. Nobody may use any device, software or routine to interfere or attempt to interfere with the proper working of the website or any transaction being conducted through the website. Nobody may copy, reproduce, alter, modify, create derivative works, or publicly display any content (except for any information in which that person has an ownership interest) from the website without prior express written consent from LEMSL or the appropriate third party.

Every user is required to ensure that information submitted via the website or by any other means (i) shall not contain any virus, trojan, worm, time bomb, cancelbot or other computer programming routine that is intended to damage, detrimentally interfere with, surreptitiously intercept or expropriate any system, data or information; and (ii) shall not create liability for or cause any member of Edwardian Hotels Limited to lose (in whole or in part) the services of any ISP or other suppliers.

7. RESTRICTION OF LIABILITY

Neither LEMSL nor any other member of Edwardian Hotels London accepts any liability for any damages or injury caused by, including but not limited to, any failure of performance, error, omission, interruption, defect, delay in operation of transmission, computer virus, or line failure; nor for any damages or injury, including but not limited to, special or consequential damages that result from the use of, or the inability to use, the materials in the website, even if there is negligence or an authorised LEMSL representative has been advised of the possibility of such damages. The above limitation or exclusion shall apply save to the extent that applicable law does not allow it. Total liability to a user for all losses, damages, and causes of action (in contract, tort including without limitation, negligence), or otherwise will not be greater than the amount paid by the user to access the website.

8. TERMINATION

Save for continuing respect for proprietary rights to names, trade marks and other proprietary information a user of the website may terminate its obligation to observe these terms and conditions if he or she ceases to use the website and destroys (a) all materials obtained from the website, and (b) all related documentation and all copies and installations (together "Materials"). LEMSL may terminate a user's right to use the website immediately without notice if, in its sole judgment, the user has breached any of the terms and conditions, and upon termination, the user must destroy all materials.

9. JURISDICTION

Elmsl makes no promises that materials on edwardian.com website are appropriate or available for use in locations outside the United Kingdom, and accessing edwardian.com website from territories where its contents are illegal or unlawful is prohibited. If a user chooses to access the website from any location outside the United Kingdom, the user does so on the user's own initiative and the user shall be solely responsible for compliance with local laws. These terms and conditions are to be governed by and interpreted in accordance with English law.

10. DIGITAL SIGNATURE PROVISIONS

Each user represents and warrants that they have the legal right, power and authority to agree to the terms of this agreement on behalf of the user and any other person represented by the user as a member, buyer, supplier or other participating user of the website. Use of the website by a user shall constitute an electronic signature as defined by the Electronic Signatures in Global and National Commerce Act ("E-Sign") and the Uniform Electronic Transactions Act ("UETA") and a representation that you have formed, executed, entered into, accepted the terms of and otherwise authenticated an agreement constituted by these terms and conditions and have acknowledged and agreed that this agreement is an electronic record for purposes of E-Sign, UETA and the Uniform Computer Information Transactions Act and as such is completely valid, has legal effect, is enforceable, and is binding on, and non-refutable by the user and any other person represented by the user as a member, buyer or supplier or other person on whose behalf the user is acting.

11. PRIVACY POLICY

Scope of This Policy This Privacy Policy describes how the Edwardian London Management Services Limited and its Affiliates and Subsidiaries (“we” or “us”) collects, uses, consults or otherwise processes an individual’s Personal Data. This Privacy Policy applies globally, but depending on where you live some specific provisions of this Privacy Policy may not apply to you. In some of the situations described in this Privacy Policy, the hotel where you made a booking and/or stay will also process your data as a (joint or sole) Controller. The hotel will be solely responsible for the processing activities for which it is the sole Controller. *Edwardian London Management Services Limited is the administration company of Edwardian Hotels London. Registered Office: 173 Cleveland Street, London, W1T 6QR, United Kingdom. Registered in England No: [02800972] We are committed to protecting the privacy of our users and customers. This Privacy Policy is intended to inform you how we gather, define, and use Personal Data that you provide to us when using our websites and mobile applications or when relying on our hospitality services. Please take a moment to read this Privacy Policy carefully. Please note that if you plan to submit someone else’s Personal Data to us, for instance when making a booking on their behalf, you may only provide us with that person’s details with their consent and after they have been given access to information about how we will use their details, including the purposes set out in this Privacy Policy.

THIS POLICY INCLUDES A DESCRIPTION OF YOUR DATA PROTECTION RIGHTS, INCLUDING A RIGHT TO OBJECT TO SOME OF THE PROCESSING ACTIVITIES WE CARRY OUT. PLEASE NOTE THAT YOUR RIGHTS AS A DATA SUBJECT MAY VARY DEPENDING UPON WHERE YOU LIVE. EU PRIVACY LAW REQUIRES US TO BE SPECIFIC ABOUT OUR REASONS AND LEGAL GROUNDS FOR USING YOUR PERSONAL DATA. ACCORDINGLY, FOR THE PURPOSES OF EU PRIVACY LAW ONLY, THE INFORMATION BELOW DESCRIBES THE TYPES OF DATA WE PROCESS, WHERE WE GET YOUR DATA FROM, THE GROUNDS WE RELY ON TO CARRY OUT THE PROCESSING, AND WHO WE MAY SHARE YOUR DATA WITH. EXCEPT FOR THE “PROCESSED DATA CATEGORIES” SECTIONS SET OUT IN THE INFORMATION BELOW, NOTHING IS INTENDED TO BIND US IN RESPECT OF OUR NON-EU USERS.


COUNTRY-SPECIFIC PROVISIONS

Please note that there may be local variations to this Privacy Policy in order to comply with local legislation. In particular, there may be local deviations within the European Union in which case, please talk to your hotel’s front desk manager for more information or contact us at privacy@edwardian.com If you have questions about an individual hotel’s practices or the information provided by it, please contact the hotel directly.

Definitions

Affiliates and Subsidiaries: Any corporation, firm, partnership or other entity which directly or indirectly controls, is controlled by, or is under common control with Edwardian London Management Services Limited. Controller: The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data. EU Privacy Law: Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of Personal Data and on the free movement of such data (the “GDPR”), as well as any legislation and/or regulation implementing or created pursuant to the GDPR and the e-Privacy legislation, or which amends, replaces, re-enacts or consolidates any of them, and all other national applicable laws relating to the processing of Personal Data and privacy.

Processor: A natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the controller.

Recipient: A natural or legal person, public authority, agency or another body, to which the Personal Data are disclosed, whether a Third Party or not.

Third Party: A natural or legal person, public authority, agency or body other than the data subject, controller, Processor and persons who, under the direct authority of the controller or processor, are authorized to process Personal Data.

Supervisory Authority: An independent public authority which is established by a Member State pursuant to Article 51 of the GDPR.

Personal Data: Any information relating to an identified or identifiable natural person (“Data Subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Processing: Any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Privacy Shield: The EU-U.S. and Swiss-U.S. Privacy Shield legal framework, designed by the U.S. Department of Commerce and the European Commission and Swiss Administration to provide companies on both sides of the Atlantic with a mechanism to comply with data protection requirements when transferring Personal Data from the European Union and Switzerland to the United States in support of transatlantic commerce. Standard Contractual Clauses: Sets of standard contractual clauses for transfers as adopted by the European Commission for the international transfer of Personal Data.

Personal Data Breach: A breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, Personal Data transmitted, stored or otherwise processed.

Hotel Booking Process 1. Hotel booking process In the context of the hotel booking process – whether this takes place online on one of our brand websites, through an online booking channel, via a travel agent, through our call center or directly at the hotel – we process your Personal Data for the purpose of (i) enabling you to reserve a room in the hotel of your choice; (ii) verifying the availability of the hotel and to administer the booking; (iii) sending you a booking confirmation; and (iv) sending you non-commercial pre-arrival emails.

You may unsubscribe from pre-arrival emails at any time by clicking on the unsubscribe link in the emails sent to you. Processed data categories Address, Date of arrival and departure, Email address, First name / Last name, First name / Last name of adult co-guest(s), Payment card type, number and expiration date, Radisson Rewards membership number or I Prefer loyalty number, Telephone number, Title Source of data Depending on the booking mechanism used: • Directly from you through the online booking form • Through the online booking channel you used to make the booking • From your travel agent • From our call centre • From Edwardian Hotels London you made a direct booking with Ground for processing Processing is necessary to take steps to enter into and perform a contract. Recipients of data • Edwardian Hotels London • Other Edwardian Hotels London entities involved • IT service providers involved in the (online) booking process • IT service providers • Email communications service provider.

2. Interrupted or incomplete online booking process (abandoned cart).

When you are booking online but for some reason are not able to finalize the booking process, we process your Personal Data for the purpose of enabling you to easily continue the online booking process by sending you an email with a link to the online booking form, which is pre-filled on the basis of the data you had already provided in the form. Processed data categories Address, Date of arrival and departure, Email address, First name / Last name, First name / Last name of adult co-guest(s), Payment card type, number and expiration date, Radisson Rewards membership number or I Prefer Loyalty membership number, Telephone number, Title Source of data Directly from you through the online booking form Ground for processing It is in Edwardian Hotels’ London legitimate interest as a business to re-market an interrupted or incomplete booking process. In this context, Edwardian Hotels’ London business interests prevail over yours. Recipients of data • Email communications service provider • Provider of targeted advertisements

3. Guest satisfaction surveys We may send you guest satisfaction surveys by email during or after your stay to enable us to measure the performance of our hotels. You may unsubscribe from our guest satisfaction survey emails at any time by clicking on the unsubscribe link in the emails sent to you. Processed data categories Country of residence, Date of arrival and departure, Email address, First name / Last name, Nationality, Radisson Rewards membership number I Prefer Loyalty membership number, Stay details Source of data Depending on the booking mechanism used: • Directly from you through the booking form • Through the online booking channel you used to make the booking • From your travel agent • From our call center • From Edwardian Hotels London you made a direct booking with Ground for processing Processing is necessary to ensure and follow up on the good performance of the contract you have with us. Recipients of data • Other Edwardian Hotels London entities involved • Guest satisfaction survey provider

4. Service emails analytics In the context of service emails, which includes guest satisfaction survey emails and any non-commercial pre-arrival emails concerning your booking, we may process and collect your Personal Data, and notably whether you have opened and actioned a service email, for analytical purposes in order to measure the click-through rate and improve the content of our service emails. You may unsubscribe from our service emails at any time by clicking on the unsubscribe link in the service emails sent to you. The information below describes the types of data we process for this purpose, where we get your data from, the ground we rely on to carry out the processing, and who we may share your data with.

Processed data categories Email address, Email clicking behavior, Email opening behaviour, First name / Last name, Radisson Rewards membership number or I Prefer Loyalty membership number. Source of data From our email analytics service provider Ground for processing. It is in Edwardian Hotels’ London legitimate interest as a business to understand the email clicking behavior of its guests in order to determine whether improvements are needed. In this context, Edwardian Hotels’ London business interests prevail over yours. Recipients of data • Other Edwardian Hotels’ London entities involved • IT service providers • Email analytics service provider


HOTEL GUESTS

1. Hotel check-in and check-out When staying at the hotel of your choice, we will collect and process your Personal Data for the purposes of (i) registering your arrival and departure at the hotel; (ii) assigning you a key card to your room or allowing you to use your mobile device as a room key; (iii) obtaining a credit card guarantee or hotel deposit to ensure payment of your stay; (iv) managing (and archiving) your hotel registration card; (v) creating or updating your profile in our hotel management system; (vi) assessing your eligibility for a room upgrade and managing this if applicable; (vii) managing payment of your stay; (viii) establishing, printing or sending an invoice for your stay; and (ix) paying a commission to your travel agent (if applicable). In the event you have booked a room in one of our hotels but do not show up – without cancelling – on the date of arrival communicated, we will process your Personal Data for the purposes of (i) cancelling your stay and any other reservation you may have made; and (ii) managing, processing and settling any outstanding payment that may be due. Processed data categories Address, Bookings (hotel, restaurant, event, theatre, etc.), Date of arrival and departure, Email address, First name / Last name, First name / Last name of adult co-guest(s), Payment card type, number and expiration date, Radisson Rewards membership number or I Prefer Loyalty membership number, Telephone number, Title Source of data Depending on the booking mechanism used: • Directly from you through the booking form • Through the online booking channel you used to make the booking • From your travel agent • From our call center • From Edwardian Hotels London you made a direct booking with • Directly from you through the hotel registration card Ground for processing Processing is necessary to perform the contract you have with us. Recipients of data • Other Edwardian Hotels London entities involved • IT service providers • Your travel agent, if applicable.

2. Credit limit reports

To ensure payment for all guests staying in a hotel room, each hotel guest is asked for a credit card or deposit upon arrival. In order to ensure that you do not exceed your credit limit during your stay, we produce a credit limit report multiple times a day for the purposes of verifying whether your credit limit has been exceeded. These credit limit reports may contain your Personal Data. Please note that in limited circumstances these credit limit reports may be subject to one of our internal financial audits, and may therefore be accessed by members of our internal audit department, in order to ensure that our hotels follow the Edwardian Hotels’ London internal guidelines and policies. Processed data categories Date of arrival and departure, First name / Last name, Payment card type, number and expiration date Source of data Depending on the booking mechanism used: • Directly from you through the booking form • Through the online booking channel you used to make the booking • From your travel agent • From our call center • From Edwardian Hotels London you made a direct booking with • Directly from you through the hotel registration card Ground for processing Processing is necessary to ensure the performance of the contract you have with us. Recipients of data • Other Edwardian Hotels London entities involved • IT service providers

3. Hotel stay

When you stay in one of our hotels, we endeavor to make your stay as pleasant as possible. This requires processing your Personal Data for the purposes of providing specific services during your hotel stay. These services include (i) housekeeping and maintenance; (ii) returning lost or forgotten items to you; and/or (iii) managing your and your co-guests’ preferences, such as dietary requirements and pillow preferences, in order to provide you with a better service during your stay with us. Processed data categories Address, Consumption habits, Date of arrival and departure, Dietary requirements, Email address, First name / Last name, First name / Last name of adult co-guest(s), Other preferences, Telephone number Source of data Depending on the booking mechanism used: • Directly from you through the booking form • Through the online booking channel you used to make the booking • From your travel agent • From our call center • From Edwardian Hotels London you made a direct booking with • Directly from you during your stay at the hotel Ground for processing It is in Edwardian Hotels’ London legitimate interest as a business to organize its day-to-day hotel maintenance activities, to personalize the services it provides, and/or to be able to identify the owner of a lost or forgotten item. Taking into account the limited Personal Data processed and shared for such purpose(s), Edwardian Hotels’ London business interests prevail over yours. Recipients of data • Hotel personnel, including housekeeping, maintenance, front desk, and/or other hotel personnel concerned • Other Edwardian Hotels London entities involved • IT service providers


4. Hotel guest additional services and facilities
 

In many of our hotels you can benefit from additional services and facilities, such as breakfast, room service, minibar, pool, restaurants and bars, spa treatments, laundry services, parking, taxi requests, free Wi-Fi, etc. In the event you make use of additional services or facilities at one of our hotels, your Personal Data may be processed to (i) manage the booking and use of such additional hotel services and/or facilities; (ii) administer any advance bookings of additional services and/or facilities to your file; (iii) personalize returning guests’ arrival to the hotel and the choice of room amenities and room features; and (iv) manage the expenses incurred for such additional services and/or facilities. Processed data categories Consumption habits, Date of arrival and departure, Dietary requirements, Email address, First name / Last name, First name / Last name of adult co-guest(s), Payment card type, number and expiration date, Radisson Rewards membership number or I Prefer Loyalty membership number, Title Source of data • Directly from you through the online booking form • Through the online booking channel you used to make the booking • From your travel agent • From our call center • Directly from you through the hotel registration card • Directly from you when making your additional service/facility request with the hotel front desk or the concierge Ground for processing Processing is necessary to take steps with a view to entering into a contract and/or to perform the contract. Recipients of data • Hotel personnel, including front desk, room service, and/or other hotel personnel concerned • Other Edwardian Hotels London entities involved • IT service providers


LOYALTY PROGRAMMES

1. Radisson Rewards

Radisson Rewards is a global hotel rewards program applicable throughout the hotels of the Radisson Hotel Group that is available to guests staying in our hotels, and to professional partners irrespective of whether the professional partners stay as guests or book on behalf of others. The Radisson Rewards 
program is managed by Radisson Hospitality, Inc. The Radisson Rewards program provides you with a number of benefits during your stay at our hotel, and enables you to collect Radisson Rewards points during your stay in our hotels and when purchasing from our selected partners. In such context, we may process your Personal Data in order to be able to i) create your online Radisson Rewards profile, including sending you an activation link by email; ii) provide you with information on your Radisson Rewards points; iii) register your bookings and award points to your membership card; iv) inform you about your rewards once you reach a certain points level; and v) inform you about any changes to the Radisson Rewards program. Processed data categories First name / Last name, Hotel stay details, Radisson Rewards Membership number, Booking details, email address, Title, Address, Telephone number, Country of residence, Language preference Source of data Directly from you when signing up to Radisson Rewards or claiming or redeeming Radisson Rewards points Ground for processing Processing is necessary to take steps at your request with a view to perform the contract you have with us. Recipients of data • Other Edwardian Hotels London entities involved • IT service providers • Relevant partner company


2. Other loyalty programs
 

Apart from Radisson Rewards, we also offer our guests the possibility to earn miles or points in loyalty programs of our partners, such as frequent flyer programs, car rental programs and railway programs. In such context, we may process your Personal Data in order to be able to (i) award miles or points to your membership account with one of our recognized partners following your stay at our hotel; and (ii) assess and fulfil your request to redeem your miles or points of our recognized partners’ loyalty programs at our hotel. Processed data categories First name / Last name, Hotel stay details, Membership number of loyalty program of relevant partner company Source of data Directly from you when claiming or redeeming miles or points Ground for processing Processing is necessary to take steps at your request with a view to perform the contract you have with us as well as to perform the contract you have with our recognized partner(s). Recipients of data • Other Edwardian Hotels London entities involved • IT service providers • Relevant partner company

3. Redemption We provide you with the opportunity to redeem your loyalty points for items such as gift cards, partner offers or charities. When you make a redemption, we process your and, if applicable, the gift card recipient’s Personal Data for the purpose of managing and successfully completing your redemption. In cases where you purchase a gift card for another person, we will process additional Personal Data for the purpose of delivering the gift card to the recipient by email or by post. Processed data categories First name / Last name, Payment card type, number and expiration date, your Address, Telephone number, Connection logs, Email address, and IP address If you purchase a gift card for someone else and depending on the mode of delivery, we will also process the Address of the recipient, Email address of the recipient, First name / Last name of the recipient, Telephone number of the recipient Source of data Directly from you when redeeming your points at the hotel or online Ground for processing Processing is necessary for the performance of the contract you have with us. Recipients of data • Other Edwardian Hotels London entities involved • IT service providers • Gift card platform provider • Payment service provider • IT service providers involved in the (online) booking process


4. I PREFER HOTEL REWARDS PROGRAM FOR THE LONDONER HOTEL
 

The I Prefer Program ("Program") is a customer loyalty program offered by Preferred Hotel Group ("PHG") that rewards I Prefer Members (as defined below) who stay at Participating Hotels (as defined below). After you enroll in the Program and become an I Prefer Member, you will be eligible to earn points ("I Prefer Points") on eligible stays or eligible activities at Participating Hotels.


Gift Cards

We provide the opportunity to purchase physical or e-gift cards that can be redeemed at our hotel to pay hotel charges, restaurants and spa treatments.


1. Purchasing a gift card

When you purchase a gift card at one of our hotels or online, we process your and, if applicable, the gift card recipient’s Personal Data for the purposes of managing and successfully completing your purchase of the gift card. If you are purchasing the gift card for another person, we will process additional Personal Data for the purpose of delivering the gift card to the recipient by email or by post. Processed data categories First name / Last name, Payment card type, number and expiration date If a gift card is purchased online, in addition to the above, we will process your Address, Connection logs, Email address, and IP address If you purchase the gift card for someone else and depending on the mode of delivery, we will also process the Address of the recipient, Email address of the recipient, First name / Last name of the recipient, Telephone number of the recipient Source of data Directly from you when purchasing the gift card at the hotel or online Ground for processing Processing is necessary to take steps at your request with a view to enter into and perform a contract. Recipients of data • Other Edwardian Hotels London entities involved • IT service providers • Gift card platform provider • Gift card manufacturer • Payment service provider


2. Registering your gift card

As a recipient of one of our gift cards, you may choose to register your gift card online in order to protect the remaining value on the card in case it is lost or stolen. Should you decide to register your gift card, we will process your Personal Data for the purpose of processing such registration. Processed data categories Address, Date of birth, Email address, First name / Last name, Telephone number, Title Source of data Directly from you during the online registration of the gift card Ground for processing Ad hoc consent obtained during the registration of the gift card Recipients of data • Other Edwardian Hotels London entities involved • IT service providers • Gift card platform provider


Subscription to Our Newsletters

1. Newsletters and marketing communications

If you have explicitly consented to receive our newsletters or marketing communications, including in relation to Radisson Rewards or I Prefer Loyalty membership number, we may, from time to time, contact you with information about our services and latest offers and process your Personal Data for this purpose. If you no longer want to receive our newsletters or marketing communications, please let us know by sending us an email at privacy@edwardian.com.

You can also unsubscribe from our marketing emails by clicking on the unsubscribe link in the emails sent to you. For Radisson Rewards or I Prefer Loyalty membership number, you may also unsubscribe by updating your profile.
Processed data categories: Address, Date of birth, Email address, First name / Last name, Gender, Hobbies and interests, Telephone number, Hotel stay history, Country of residence
Source of data: Directly from you when subscribing to our newsletter or later when completing your account Ground for processing Ad hoc consent obtained during the subscription to our newsletter
Recipients of data: • Other Edwardian Hotels London entities involved • IT service providers • Email communications service provider • Providers of targeted advertisements 


2. Newsletters and marketing communications analytics

In the context of our newsletters and marketing communications, we may also process and collect your Personal Data, and notably whether you have opened and interacted with one of our communications, for analytical purposes in order to measure the click-through rate and improve the content of our newsletters and marketing communications. We may use any data you provide to us for analytical purposes to optimize your experience, enhance our marketing, business and operational efficiency, create segments of our customers based on their Personal Data and tailor our offers and promotions to your preferences and consumption habits. 
Processed data categories: mail address, Email clicking behavior, Email opening behavior, First name / Last name, Radisson Rewards membership number or I Prefer Loyalty membership number.
Source of data: From our email analytics service provider Ground for processing It is in Edwardian Hotels’ London legitimate interest as a business to understand the click-through rate of its emails in order to determine whether improvements are needed. In this context, Radisson Hotel Group’s and Edwardian Hotels London's  business interests prevail over yours.

Recipients of data: • Other Edwardian Hotels London and Radisson Hotels Group entities involved • IT service providers • Email analytics service provider • Providers of targeted advertisements 


Mobile Applications

The information below describes the types of data we process in the context of our mobile applications, where we get your data from, the ground we rely on to carry out the processing, and who we may share your data with. For the Radisson Rewards mobile application, please consult the dedicated section on Radisson Rewards or I Prefer. Processed data categories Email address, First name / Last name, Location data, Stay details, Telephone number Source of data Directly from you when downloading our application(s) or when interacting with the application(s) Ground for processing Ad hoc consent obtained during the installation of the application or in the context of your use of the application Recipients of data • Edwardian Hotels London • Other Edwardian Hotels London involved • Mobile applications provider • Cloud and hosting service providers


Website Forms

Should you have a particular query or feedback, including the exercise of one of your rights under the GDPR, you may contact us through the contact forms available on our website(s). In such context, we may process your Personal Data for the purposes of handling and providing an answer to your query or request or to follow up on your feedback. We also provide other forms on our websites which may assist you in requesting a particular service from us, such as the best online rate guarantee form. The information below describes the types of data we process for these purposes, where we get your data from, the ground we rely on to carry out the processing, and who we may share your data with. Processed data categories Address, Email address, First name / Last name, Radisson Rewards membership number or I Prefer Loyalty program membership number, Stay details, Telephone number, and any other data you may decide to share with us in open comment boxes. Source of data Directly from you through the form Ground for processing Ad hoc consent obtained through the contact form Recipients of data • Other Edwardian Hotels London entities involved • IT service providers


Meetings and Events

1. Meetings and events organization and feedback

If you wish to organize a meeting or event in one of our hotels or if you would like more information on this possibility, you can reach out to us by filling in the Request a Proposal form or dedicated contact form on our website(s), by directly contacting the hotel of your choice or by contacting us by other means. The Personal Data collected will be processed for the purposes of fulfilling your request to organize a meeting or event. We may also send you meeting satisfaction surveys after your meeting or event to enable us to measure the performance of our hotels as meeting venues. Processed data categories Address, Date of meeting or event, Email address, First name / Last name, Profession and employment, Radisson Rewards membership number or I Prefer Loyalty membership number, Telephone number Source of data Directly from you through • the online Request a Proposal form • the online contact form • a request communicated by other means Ground for processing Depending on whether you contract directly with us or on behalf of your company: • Processing is necessary to take steps at your request with a view to entering into and to perform a contract. • It is in Edwardian Hotels London legitimate interest as a business to have a lead contact person at the company organizing a meeting or event and providing feedback on that meeting or event. In this context, Edwardian Hotels’ London business interests prevail over yours. Recipients of data • The hotel of your choice • Other Edwardian Hotels London entities involved • IT service providers • Meeting satisfaction survey provider

2. Meetings and events marketing communications
If you have opted in to receive commercial communications in the context of the organization of a meeting or event, we will also process your data to contact you with information about our services and latest offers.
Processed data categories:
Address, Email address, First name / Last name, Profession and employment, Telephone number
Source of data
Directly from you through • the online Request a Proposal form • the online contact form • a request communicated by other means Ground for processing Ad hoc consent obtained through • the Request a Proposal form online • the contact form
Recipients of data:
• Other Edwardian Hotels London entities involved • IT service providers • Email communications service provider  • Providers of targeted advertisements 


3. Meetings and events marketing communications analytics

In the context of our marketing communications concerning meetings and events, we may also process and collect your Personal Data, and notably whether you have opened and interacted with one of our communications, for analytical purposes in order to measure the click-through rate and improve the content of our marketing communications. Processed data categories Email address, Email clicking behavior, Email opening behavior, First name / Last name, Profession and employment, Radisson Rewards membership number or I Prefer Loyalty membership number. Source of data From our email analytics service provider Ground for processing It is in Edwardian Hotels’ London legitimate interest as a business to understand the click-through rate of its emails in order to determine whether improvements are needed. In this context, Edwardian Hotels’ London business interests prevail over yours. Recipients of data • Other Edwardian Hotels London entities involved • IT service providers • Email analytics service provider Analytics We may use any data you provide to us for analytical purposes to optimize your experience, enhance our marketing, business and operational efficiency, create segments of our customers based on their Personal Data and tailor our offers and promotions to your preferences and consumption habits. In the context of such analytics, we analyze and may combine different data we hold about our guests, including (i) responses to guest satisfaction surveys; (ii) communications guests have with us; (iii) click-through rates for our marketing communications; (iv)our guests’ behavior on our websites; (v) bookings; and (vi) any information we receive via our Radisson Rewards program or I Prefer Loyalty program. Please see also our dedicated sections on Meeting and Events Marketing Communications Analytics and Newsletter and Marketing Communications Analytics. Processed data categories Hotel stay details, Address, Bookings (hotel, restaurant, event, theatre, etc.), Date of arrival and departure, Title, First name / Last name, First name / Last name of adult co-guest(s), Email address, Telephone number, Payment card type, number and expiration date, Radisson Rewards membership number or I Prefer Loyalty membership number, redemption history Source of data • Directly from you when signing up to Radisson Rewards/I Prefer Loyalty or claiming or redeeming Radisson Rewards or I Prefer points • Directly from you through the online booking form • Through the online booking channel you used to make the booking • From your travel agent • From our call center • From our email analytics provider • Directly from you when making your additional service/facility request with the hotel front desk or the concierge Ground for processing It is in Edwardian Hotels’ London legitimate interest as a business to understand its guests’ preferences and consumption habits. In this context, Edwardian Hotels’ London business interests prevail over yours. Recipients of data
• Other Edwardian Hotels London and Radisson Hotels Group entities involved
• IT service providers
• Analytics service provider
• Providers of targeted advertisements 

Analytics 
We may use any data you provide to us for analytical purposes to optimize your experience, enhance our marketing, business and operational efficiency, create segments of our customers based on their Personal Data and tailor our offers and promotions to your preferences and consumption habits. In the context of such analytics, we analyze and may combine different data we hold about our guests, including (i) responses to guest satisfaction surveys; (ii) communications guests have with us; (iii) click-through rates for our marketing communications; (iv) our guests’ behavior on our websites; (v) bookings; and (vi) any information we receive via our Radisson Rewards program. Please see also our dedicated sections on Meeting and Events Marketing Communications Analytics and Newsletter and Marketing Communications Analytics.

Processed data categories
• Hotel stay details, Address, Bookings (hotel, restaurant, event, theatre, etc.), Date of arrival and departure, Title, First name / Last name, First name / Last name of adult co-guest(s), Email address, Telephone number, Payment card type, number and expiration date, Radisson Rewards membership number, redemption history

Source of Data
• Directly from you when signing up to Radisson Rewards or claiming or redeeming Radisson Rewards points
• Directly from you through the online booking form
• Through the online booking channel you used to make the booking
• From your travel agent
• From our call center
• From our email analytics provider
• Directly from you when making your additional service/facility request with the hotel front desk or the concierge

Ground for processing
• It is in Radisson Hotel Group’s and Edwardian Hotels London's legitimate interest as a business to understand its guests’ preferences and consumption habits. In this context, Radisson Hotel Group’s and Edwardian Hotels London's business interests prevail over yours.

Recipients of data
• Other Radisson Hotel Group and Edwardian Hotels London  entities involved
• IT service providers
• Analytics service provider
• Providers of targeted advertisements

Social Media and Online Reviews

We may process your Personal Data obtained through social media platforms (including Facebook, Instagram, LinkedIn and Twitter) or online reviews (including TripAdvisor) concerning our Edwardian Hotels London brands for the purposes of (i) addressing your questions or complaints; (ii) monitoring our online reputation; and (iii) improving our services and identifying opportunities on which we can focus. Some of our social media pages allow users to submit their own content. Please remember that any content submitted to one of our social media pages can be viewed by the public, and you should be cautious about providing certain personal information (e.g., financial information or address details) via these platforms. We are not responsible for any actions taken by other individuals if you post personal information on one of our social media platforms (e.g., Facebook or Instagram). Please also refer to the respective privacy and cookie policies of the social media platforms you are using. Processed data categories Any Personal Data you may decide to share with us or published on social media or in other online reviews about us Source of data • Directly from you through publicly accessible social media pages, online booking channels or other (review) websites • From our online reputation monitoring service provider Ground for processing It is in Edwardian Hotels’ London legitimate interest as a business to understand its guests’ preferences and consumption habits. In this context, Edwardian Hotels’ London business interests prevail over yours. Recipients of data • Other Edwardian Hotels London entities involved • Online reputation monitoring service provider


Social media contests

From time to time, we may organize a contest on one of our social media pages. If you choose to participate in such contest, we will process your Personal Data for the purpose of organizing and managing the social media contest and picking the winner(s). Processed data categories This depends on the data fields in the contest concerned, but almost always includes the following categories of data: Address, Email address, First name / Last name, Telephone number Source of data Directly from you through our social media pages Ground for processing Processing is necessary to take steps to enter into and perform a contract as you accept the terms and conditions of the contest. Recipients of data • Other Edwardian Hotels London entities involved • IT service provider


Your Rights – Under EU Privacy Law

If you are in the EU, EU Privacy Law grants specific rights, summarized below, which you can in principle exercise free of charge, subject to statutory exceptions. These rights may be limited, for example if fulfilling your request would reveal Personal Data about another person, or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping. To exercise any of your rights, you can file a request via email at privacy@edwardian.com . Should you have unresolved concerns, you have the right to lodge a complaint with a Supervisory Authority where you live or where you believe a breach may have occurred. We encourage you to come to us in the first instance but, to the extent that this right applies to you, you are entitled to complain directly to the relevant Supervisory Authority.

1. Right to withdraw consent Wherever we rely on your consent, you will be able to withdraw that consent at any time you choose and at your own initiative by logging in to your account on our website (if you have one) or by contacting us at privacy@edwardian.com. The withdrawal of your consent will not affect the lawfulness of the collection and processing of your data based on your consent up until the moment where you withdraw your consent. Please note that we may have other legal grounds for processing your data for other purposes, such as those set out in this Privacy Policy.

2. Right to access and rectify your data You have the right to access, review, and rectify your Personal Data. You may be entitled to ask us for a copy of your information, to review or correct it if you wish to rectify any information like your name, email address, passwords and/or any other preferences, you can easily do so by logging in to your account on our website (if you have one) or by contacting us at privacy@edwardian.com. You may also request a copy of the Personal Data processed as described in this Privacy Policy.

3. Right to erasure In accordance with EU Privacy Law, you have the right to erasure of your Personal Data processed by us as described in this Privacy Policy in case it is no longer needed for the purposes for which the Personal Data was initially collected or processed or in the event you have withdrawn your consent or objected to processing as described in this Privacy Policy and no other legal ground for processing applies. Should you wish to have your Personal Data erased, please file a request via email at privacy@edwardian.com.

4. Right to restriction of processing Under certain circumstances described in EU Privacy Law, you may ask us to restrict the processing of your Personal Data. This is for example the case when you contest the accuracy of your Personal Data. In such event, we will restrict the processing until we can verify the accuracy of your data.

5. Right to object to processing Under certain circumstances described in EU Privacy Law, you may object to the processing of your Personal Data, including where your Personal Data is processed for direct marketing purposes.

6. Right to data portability Where you have provided your data directly to us and where the processing is carried out by automated means and based on your consent or the performance of a contract between you and us, you have the right to receive the Personal Data processed about you in a structured, commonly used and machine-readable format, and to transmit this data to another service provider.


YOUR RIGHTS - NON EU USERS

Depending on where you are located you will have different rights in respect of your Personal Data and we will comply with the relevant requirements of applicable laws and this Privacy Policy. California Privacy Rights If you reside in California, you have the right to ask us one time each year if we have shared Personal Data with third parties for their direct marketing purposes. To make a request, please send us an email at privacy@edwardian.com or write to us at the address listed below.

Indicate in your letter that you are a California resident making a “Shine the Light” inquiry. Russian Citizens In accordance with Russian Federal Law “On Personal Data” No. 152-FZ we collect, record, systematize, accumulate, store, update (renew and modify), and extract Personal Data about Russian citizens using databases located in the territory of the Russian Federation. If you indicate that you are a Russian citizen of the Russian Federation, we will process your Personal Data in compliance with this requirement and your profile will be maintained on databases in the Russian Federation. If you do not indicate that you are a citizen of the Russian Federation, we are not able to process and maintain your Personal Data under these requirements and will not be liable for that. You are solely responsible for indicating the country of your citizenship.

Information containing Personal Data of Russian citizens may be transmitted from the Russian Federation to countries that ensure an adequate level of protection for Personal Data, including member states of the European Union and other countries which Russian law recognizes as ensuring adequate to protection, and also to other countries that may not ensure adequate level of protection for Personal Data. By submitting information to us on our sites and apps, submitting forms to us, or registering on our sites, programs and apps, or making reservations, you grant us consent to process your Personal Data. Security Measures Appropriate technical and organizational measures are implemented in order to ensure an appropriate level of security of your Personal Data, including but not limited to encryption techniques, physical and IT system access controls, obligations of confidentiality, etc. In the event Personal Data is compromised as a result of a Personal Data Breach we will make the necessary notifications, as required under applicable laws.


WHAT RULES APPLY TO CHILDREN?

We do not knowingly collect or solicit Personal Data from anyone under the age of 18 or knowingly allow such persons to book a room in one of our hotels. In the event we learn that we have collected Personal Data from a child under the age of 18 without verification of parental consent, steps will be taken promptly to remove that information. If you believe that we have or may have information from or about a child under 18 years of age, please contact us at privacy@edwardian.com .

 

HOW IS YOUR PERSONAL DATA SHARED WITH THIRD PARTIES?

We only share or disclose information as described herein, including with Third Parties. Your Personal Data will also be shared with government authorities and/or law enforcement officials if required for the purposes above, if mandated by law or if required for the legal protection of the Controller(s) legitimate interests in compliance with applicable laws. In addition, we may share your Personal Data and other information with a successor to all or part of our business, where this is in our legitimate interests in facilitating a business sale and in this context our business interests prevail over yours. For example, if parts of our business or assets are sold, we may disclose user information as part of that transaction, subject to applicable law. International Data Transfers If you are in the European Economic Area (EEA), the data that we collect from you as described in this Privacy Policy may be transferred to and stored at a destination outside the EEA, including for the purposes of processing that data by selected Processors, in order to facilitate the Radisson Hotel Group’s and The Londoner Hotel’s business. Countries outside the EEA may not have laws which provide the same level of protection to your Personal Data as laws within the EEA. Where this is the case we will put in place appropriate safeguards to ensure that such transfers comply with EU Privacy Law, either by putting in place Standard Contractual Clauses approved by the European Commission as ensuring an adequate protection or by ensuring that the transfer is done to an organization that complies with Privacy Shield in case the transfer is made to the United States of America.

In this respect, please note that Radisson Hospitality, Inc. adheres to the E.U.-U.S. and Swiss-U.S. Privacy Shield Framework. In compliance with the E.U.-U.S. and Swiss-U.S. Privacy Shield Principles, Radisson Hospitality, Inc. commits to resolve complaints about your privacy and our collection or use of your Personal Data. Radisson Hospitality, Inc. has further committed to refer unresolved privacy complaints under the E.U.-U.S. and Swiss-U.S. Privacy Shields to the American Arbitration Association, http://go.adr.org/privacyshield.html. Finally, in certain limited circumstances and as a last resort, it may be possible for individuals to invoke binding arbitration before the Privacy Shield Panel to be created by the U.S. Department of Commerce and the European Commission.

Please note that if you are not a European Union or Switzerland resident, then Privacy Shield requirements regarding the handling of complaints may not apply to you and Privacy Shield enforcement mechanisms may not be available to you. In case you wish to obtain more details about our data transfer safeguards and the mechanisms in place, you may contact us at privacy@edwardian.com .


HOW LONG WILL WE KEEP YOUR PERSONAL DATA?
We retain your Personal Data for as long as is required to fulfil the activities set out in this Privacy Policy, for as long as otherwise communicated to you or for as long as is permitted by applicable law. For example, we may retain your Personal Data if it is reasonably necessary to comply with any legal obligations, meet any regulatory requirements, resolve any disputes or litigation, or as otherwise needed to enforce this Privacy Policy and prevent fraud and abuse. To determine the appropriate retention period for the information we collect from you, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of the data, the purposes for which we process the Personal Data, and whether we can achieve those purposes through other means, and the applicable legal requirements.


DOES THIS PRIVACY POLICY APPLY TO THIRD PARTY WEBSITES?
If you click on a link to a Third Party website, you will be taken to a website we do not control and our Privacy Policy will no longer be in effect. Your browsing and interaction on any other website is subject to the terms of use and privacy and other policies of such Third Party website. Read the privacy policies of other websites carefully. We are not responsible or liable for the information or content on such Third Party websites. What Happens If We Make Modifications to This Policy? We reserve the right to modify and update this Privacy Policy from time to time. We will bring these changes to your attention should they be indicative of a fundamental change to the processing or be relevant to the nature of the processing or be relevant to you and impact your data protection rights.


HOW TO CONTACT US
Questions, comments, remarks, requests or complaints regarding this Privacy Policy are welcome and should be addressed to privacy@edwardian.com . If you have questions about an individual hotel’s practices or the information it has, please contact the hotel directly. You can also write us at: Edwardian London Management Services Limited is the administration company of Edwardian Hotels London. Registered Office: 140 Bath Road Hayes Middlesex UB3 5AW Registered in England No: [02800972].