Privacy Policy – Navarino Services Ltd. and Hotels

Navarino Services Limited (“we”/”us”) are committed to protecting and respecting any personal information you share with us.

This statement describes what types of information we collect from you, how it is used by us, how we share it with others, how you can manage the information we hold and how you can contact us.

We will always give you the option not to receive marketing communications from us. We will never send you unsolicited ‘junk’ email or communications or share your data with anyone else who might. We do not sell your information to third parties, but we do work closely with selected partners who help us to provide you with the information, products and services that you request from us. For example, Sabre Hospitality Solutions for the provision of CRS services.

The contents of this statement may change from time to time so you may wish to check this page occasionally to ensure you are still happy to share your information with us. Where possible, we will also contact you directly to notify you of these changes.

This version of our Privacy Policy is live from 16th May 2018.

What information do we collect?

We collect information about you, your Hotel and Hotel guests when you engage with our website or systems provided under contract or directly with a member of our Operations teams. We only collect information which is necessary, relevant and adequate for the purpose you are providing it for.

Further Detail

We collect information about you, your Hotel and Hotel guests when you engage with our website or systems provided under contract or directly with a member of our Operations teams. We also obtain information about you or your Hotel or Hotel guests from our technology and service partners when required to fulfil the services provided under contract. Some of this information does not identify you personally but provides us with information about how you use our services and engage with us (we use this information to improve our services and make them more useful to you). The information we collect includes some or all of the following:

  1. Your Name (including title)
  2. Your Hotel guests name (including title)
  3. Address
  4. Phone number
  5. Date of birth
  6. Email address
  7. Reservation number
  8. Date of reservation made
  9. Start and end date of reservation
  10. The date and time you used our services
  11. The pages you visited on our website and how long you visited us for
  12. Your IP address
  13. The internet browser and devices you are using
  14. The website address from which you accessed our website
  15. Where you engage with us in a business context, we may collect your job title, company contact details (including email addresses)
  16. Voice recordings of calls you make to our customer service centre;
  17. “Live chat” records; and
  18. Any information within correspondence you send to us.

 

How do we use this information?

Navarino Services Ltd will only process information that is necessary for the purpose for which it has been collected. You will always have the option not to receive marketing communications from us (and you can withdraw your consent or object at any time). We will never send you unsolicited ‘junk’ email or communications or share your personal information with anyone else who might.

Further Detail

There are various ways in which we may use or process your personal information, that of your Hotel or that of your Hotel guests.  We list these below:

Consent

Where you have provided your consent, we may use and process your information to:

  1. Contact you from time to time about promotions, events, products, services or information which we think may be of interest to you (don’t worry, we won’t bombard you);
  1. Share your personal information, that of your Hotel or that of your Hotel guests with our third party partners (such as Sabre Hospitality Solutions), so that they can assist in the provision of the products and services provided under our contract with your Hotel.

Contractual performance

We may use and process your personal information where this is necessary to perform a contract with you and to fulfil and complete your orders, purchases and other transactions entered into with us (or one of our third-party partners, such as Sabre Hospitality Solutions).

Legitimate interests

We may use and process your personal information, that of your Hotel or that of your Hotel Guest as set out below where it is necessary for us to carry out activities for which it is in our legitimate interests as a business to do so.

Processing necessary for us to support your, your Hotel or your Hotel guests with reservation information and other enquiries

  1. To respond to correspondence you send to us and fulfil the requests you make to us (for example: enquiries regarding reservation confirmations, dates of stay or value of reservations);
  2. To provide product support and services (for example Booking Engine modifications);

Processing necessary for us to respond to understanding Hotel and Hotel guest needs

  1. To analyse, evaluate and improve our products and services so that your visit and use of our website or systems provided under contract or directly with a member of our Operations teams are more useful and enjoyable (we will generally use data amalgamated from many people so that it doesn’t identify you personally);
  2. To undertake market analysis and research (including contacting you with customer surveys) so that we can better understand you as a Hotel customer and provide tailored offers, products and services that we think you will be interested in. We will only send marketing communications to you if you have provided your consent for us to do so.
  3. In some cases we may use automated methods to analyse, combine and evaluate information that you have provided to us. We may collect and analyse this information in this way so that we can deliver the most appropriate customer experience to you by tailoring and making relevant all our service and communications.

Processing necessary for us to promote our business, services and products and measure the reach and effectiveness of any marketing campaigns

  1. To send you marketing information from time to time after you have contracted a product or service from us or made a purchasing enquiry or requested a brochure or other information of interest. We will only contact you with information about our own products and services (and in ways the law allows), which we hope you will like. You have the right to object to us sending you this information at any time;
  2. To identify and record when you have received, opened or engaged with our website or electronic communications.
  3. To administer competitions and promotions that you enter with us from time to time and to distribute prizes

Processing necessary for us to operate the administrative and technical aspects of our business efficiently and effectively

  1. To verify the accuracy of information that we hold about you, your Hotel or Hotel guest and create a better understanding of you as a customer
  2. For network and information security purposes i.e. in order for us to take steps to protect your information, that of your Hotel or Hotel guest against loss, damage, theft or unauthorised access
  3. To comply with a request from you in connection with the exercise of your rights (for example where you have asked us not to contact you for marketing purposes, we will keep a record of this on our suppression lists in order to be able to comply with your request)
  4. To inform you of updates to our terms and conditions and policies.

 

Legal obligation

We may process your personal information, that of your Hotel or your Hotel guest to comply with any legal requirements (for example PCI compliance).

Vital interest

Sometimes we will need to process your personal information, that of your Hotel or your Hotel guest to contact you if there is an urgent notice that we need to tell you about .

 

How do we share this information?

We do not sell your information to third parties, but we do work closely with third party suppliers who fulfil business activities for us (like CRS transactions, Booking Engine design, Corporate rate negotiation.)

Further Detail

We do not sell your, your Hotel or Hotel guest information to third parties. However, we may from time to time disclose your, your Hotel or Hotel guest information to the following categories of companies or organisations to which we pass the responsibility to handle services on our behalf: CRS providers, GDS services, web design agencies, Hotel service contractors or consultants, direct marketing communications agencies and consultants, market research and market analytics service providers, our legal and other professional advisors.

We will also share your information with our third-party partners in situations where we need to pass your information to them in order to manage any request or complaint you have made to us. For example, where you have requested a review of reservation details, we will need to share information of you, your Hotel or your Hotel guest with the CRS provider to ensure the correct reservation retrieval is made for analysis.

We take steps to ensure that any third-party partners who handle your, your Hotel or your Hotel guest information comply with data protection legislation and protect the information just as we do. We only disclose personal information that is necessary for them to provide the service that they are undertaking on our behalf. We will aim to anonymise your information or use aggregated none specific data sets where ever possible.

Due to the international nature of our business, there may be some instances where your, your Hotel or your Hotel guest information is processed or stored outside of the EU.  In those instances, we will ensure that appropriate safeguards are in place for that transfer and storage as required by applicable law.

  

 

How long do we keep this information for?

We will not hold your, your Hotel or Hotel guest information in an identifiable format for any longer than is necessary. If you are a customer or otherwise have a relationship with us we will hold personal information about you for a longer period than if we have obtained your details in connection with a prospective relationship.

Further Detail

We do not retain personal information in an identifiable format for longer than is necessary.

If we have a relationship with you (e.g. you are a customer), we hold your, your Hotel or Hotel guest information for up to 6 years from the date our relationship ends. We hold this information for this period to establish, bring or defend legal claims.  Our relationship may end for a number of reasons including where the contract expires.

Where we have obtained your personal information following a request for information, brochure, quotation or any other information on any of our products or services, we hold your personal information for up to 1 year and 6 months from the date we collect that information, unless during that period we form a relationship with you e.g. you enter a contract with us.  We hold your personal information for this period to give us an opportunity to form a relationship with you.

The only exceptions to the periods mentioned above are where:

  • The law requires us to hold your, your Hotel or Hotel guest information for a longer period, or delete it sooner;
  • Where you have raised a complaint or concern regarding a product or service offered by us, in which case we will retain your information for a period of 6 years following the date of that complaint or query; or
  • You exercise your right to have the information erased (where it applies) and we do not need to hold it in connection with any of the reasons permitted or required under the law (see further How can I manage the information we hold about you);

 

How can the information we hold about you be managed? 

You have the right as an individual to access your personal information we hold about you and make corrections if necessary. You also have the right to withdraw any consent you have previously given us and ask us to erase information we hold about you.

Further Detail

You have a number of rights in relation to your, your Hotel or Hotel guest information under data protection law. In relation to most rights, we will ask you for information to confirm your identity and, where applicable, to help us search for your personal information. Except in rare cases, we will respond to you within 30 days after we have received any request (including any identification documents requested).

You have the right to:

  1. Ask for a copy of the information that we hold about you or your Hotel
  2. Correct and update your information;
  3. Withdraw your consent (where we rely on it).
  4. Object to our use of your information (where we rely on our legitimate interests to use your personal information) provided we do not have any continuing lawful reason to continue to use and process the information.  When we do rely on our legitimate interests to use your personal information for direct marketing, we will always comply with your right to object;
  5. Erase your information (or restrict the use of it), provided we do not have any continuing lawful reason to continue to use and process that information;
  6. Transfer your information in a structured data file (in a commonly used and machine readable format), where we rely on your consent to use and process your personal information or need to process it in connection with your contract.

You can exercise the above rights and/or manage your information by contacting us using the details below:

Post: Navarino House, Network Point, Range Road, Witney, Oxfordshire, OX29 0YN, England

Email:  support@navarinoservices.com

Phone:  +44 (0) 1993 773 597

If you have any specific data protection concerns or a complaint, you can address it to our Data Protection Team, Email:  dataprotection@navarinoservices.com

If you are unhappy, you have the right to lodge a complaint with a data protection regulator in Europe, in particular in a country you work or live or where your legal rights have been infringed.  The contact details for the Information Commissioner’s Office, the data protection regulator in the UK, are below:

Post:   Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Call:     +44 (0)303 123 1113

Email:   casework@ico.org.uk

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