Privacy Policy

INTRODUCTION

This document refers to personal data, which is defined as information concerning any living person (a natural person who hereafter will be called the Data Subject) that is not already in the public domain.

The General Data Protection Regulation (GDPR) seeks to protect and enhance the rights of data subjects. These rights cover the safeguarding of personal data, protection against the unlawful processing of personal data and the unrestricted movement of personal data within the EU. It should be noted that GDPR does not apply to information already in the public domain.

Newton Lodge is pleased to provide the following Privacy Notice, which applies to the Newton Lodge website.

PERSONAL DATA

Newton Lodge uses the information collected from you to secure a booking for restaurant, accommodation or partner experience and to email marketing information from time to time, which Newton Lodge believes may be of interest to you and your business. In making initial contact you consent to Newton Lodge maintaining a marketing dialogue with you until you either opt out (which you can do at any stage) or we decide to stop promoting our services. Newton Lodge also acts on behalf of its guests/suppliers in the capacity of a data processor. When working exclusively as a data processor, Newton Lodge will ensure that all data is held and processed in accordance with GDPR requirements.

Some personal data may be collected about you from the forms and contracts/orders completed, from records of our correspondence and phone calls and details of your visits to our website, including but not limited to personally identifying information like Internet Protocol (IP) addresses. Newton Lodge may from time to time use such information to identify its visitors. Newton Lodge may also collect statistics about the behaviour of visitors to its websites.

The Newton Lodge website uses cookies, which is a string of information that a website stores on a visitor’s computer, and that the visitor’s browser provides to the website each time the visitor returns. Google Analytics (Google Analytics privacy policy), installed on the Newton Lodge website, uses cookies to help Newton Lodge identify and track visitors and their website access preferences. The Newton Lodge website visitors who do not wish to have cookies placed on their computers should set their browsers to refuse cookies before using the website. Cookies may also track your behaviour via external media embedded in the website, including but not limited to Instagram, Vimeo and YouTube.

Any information that Newton Lodge holds about you, your business and all transactions relating to the service/contract have been passed on from travel agents or we have gathered them directly from you.

Newton Lodge will only collect the information needed so that it can provide you with the service required and for marketing purposes and we do not sell or broker your data.

Legal basis for processing any personal data

To meet Newton Lodge’s contractual obligations to guests/suppliers and to also respond to marketing enquiries.

LEGITIMATE INTERESTS PURSUED BY NEWTON LODGE

To promote the services offered, market events and special offers by Newton Lodge to guests who have provided explicit consent.

CONSENT

Through agreeing to this privacy notice you are consenting to Newton Lodge processing your personal data for the purposes outlined. You can withdraw consent at any time by emailing marketing@highlandcoasthotels.com

DISCLOSURE

Newton Lodge may on occasions pass your personal information to third parties exclusively to process work on its behalf. Newton Lodge requires these parties to agree to process this information based on our instructions and requirements consistent with this Privacy Notice and GDPR.

Newton Lodge does not broker or pass on information gained from your engagement without your consent. However, Newton Lodge may disclose your personal information to meet legal obligations, regulations or valid governmental request. We may also enforce its Terms and Conditions, including investigating potential violations of its Terms and Conditions to detect, prevent or mitigate fraud or security or technical issues; or to protect against imminent harm to the rights, property or safety of Newton Lodge, its guests/suppliers and/or the wider community.

RETENTION POLICY

Newton Lodge will process personal data during the duration of any visit/stay or contract and will continue to store only the personal data needed for five years after the contract has expired to meet any legal obligations. After five years any personal data not needed will be deleted.

DATA STORAGE

Data is held in Scotland using local PCs that are networked through a Local Area Network. If you join our mailing list your data will be stored using software provided by For-Sight. Our booking system is provided by SHR Global. Please visit their links to view their privacy notices.

YOUR RIGHT AS A DATA SUBJECT

At any point while Newton Lodge is in possession of or processing your personal data, all data subjects have the following rights:

  • Right of access – you have the right to request a copy of the information that we hold about you.
  • Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
  • Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
  • Right to restriction of processing – where certain conditions apply you have a right to restrict the processing.
  • Right of portability – you have the right to have the data we hold about you transferred to another organisation.
  • Right to object – you have the right to object to certain types of processing such as direct marketing.
  • Right to object to automated processing, including profiling – you also have the right not to be subject to the legal effects of automated processing or profiling.

In the event that Newton Lodge refuses your request under rights of access, we will provide you with a reason why, which you have the right to legally challenge.

Newton Lodge can at your request confirm what information it holds about you and how it is processed.

YOU CAN REQUEST THE FOLLOWING INFORMATION

  • Identity and the contact details of the person or organisation (Newton Lodge) that has determined how and why to process your data.
  • Contact details of the data protection officer, where applicable.
  • The purpose of the processing as well as the legal basis for processing.
  • If the processing is based on the legitimate interests of Newton Lodge or a third party such as one of its clients, information about those interests.
  • The categories of personal data collected, stored and processed.
  • Recipient(s) or categories of recipients that the data is/will be disclosed to.
  • How long the data will be stored.
  • Details of your rights to correct, erase, restrict or object to such processing.
  • Information about your right to withdraw consent at any time.
  • How to lodge a complaint with the supervisory authority (Data Protection Regulator).
  • Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
  • The source of personal data if it wasn’t collected directly from you.
  • Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.

TO ACCESS WHAT DATA IS HELD IDENTIFICATION WILL BE REQUIRED

Newton Lodge will accept the following forms of ID when information on your personal data is requested: a copy of your national ID card, driving license, passport, birth certificate and a utility bill not older than three months. A minimum of one piece of photographic ID listed above and a supporting document is required. If Newton Lodge is dissatisfied with the quality, further information may be sought before personal data can be released.

All requests should be made to marketing@highlandcoasthotels.com

COMPLAINTS

In the event that you wish to make a complaint about how your personal data is being processed by Newton Lodge, you have the right to complain to the Highland Coast Hotels Limited Marketing Department. If you do not get a response within 30 days you can complain to the Data Protection Regulator.

The complaint should be directed to:

marketing@highlandcoasthotels.com

or

Highland Coast Hotels Limited

1-4 Atholl Crescent

Edinburgh

EH3 8HA