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