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This Privacy Policy sets out how we, Greenwoods Hotel Management Limited,
collect, store and use information about you when you use or interact with
our website, https://www.greenwoodshotel.com/ (our website
) and where we otherwise obtain or collect information about you. This
Privacy Policy is effective from 5 June 2018.

Contents

  1. Summary
  2. Our Details
  3. Information we collect when you visit our website
  4. Information we collect when you contact us
  5. Information we collect when you interact with our website
  6. 6. Information we collect when you place an order on our website

  7. Our use of profiling
  8. 8. How we collect or obtain information about you from third parties

  9. Disclosure and additional uses of your information
  10. How long we retain your information
  11. How we secure your information
  12. Transfers of your information outside the European Economic Area

  13. Your rights in relation to your information
  14. Your right to object to the processing of your information for
    certain purposes
  15. Sensitive Personal Information
  16. Changes to our Privacy Policy
  17. Children’s Privacy
  18. California Do Not Track Disclosures
  19. Copyright

1. Summary

This section summarises how we obtain, store and use information about you.
It is intended to provide a very general overview only.

It is not complete in and of itself and it must be read in conjunction
with the corresponding full sections of this Privacy Policy.

2. Our details

The data controller in respect of our website is Greenwoods Hotel
Management Limited (company registration number 08869717) of 4 Woodbrook
Crescent, Lake View, Billericay, Essex, CM12 0EQ. You can contact the data
controller by writing to the address above or sending an email to
info@greenwoodshotel.co.uk.

If you have any questions about this Privacy Policy, please contact the
data controller.

3. Information we collect when you visit our website

We collect and use information from website visitors in accordance with
this section and the section entitled Disclosure and additional uses of
your information.

Web server log information

We use a third party server to host our website called Up Hotel Agency, the
privacy policy of which is available here:
http://www.hotel-internet-marketing.com/policies/privacy-policy/. Our
website server automatically logs the IP address you use to access our
website as well as other information about your visit such as the pages
accessed, information requested, the date and time of the request, the
source of your access to our website (e.g. the website or URL (link) which
referred you to our website), and your browser version and operating
system.

Our servers are located in the United Kingdom.

Use of website server log information for IT security purposes

Our third party hosting provider collects and stores server logs to ensure
network and IT security and so that the server and website remain
uncompromised. This includes analysing log files to help identify and
prevent unauthorised access to our network, the distribution of malicious
code, denial of service attacks and other cyber attacks, by detecting
unusual or suspicious activity.

Unless we are investigating suspicious or potential criminal activity, we
do not make, nor do we allow our hosting provider to make, any attempt to
identify you from the information collected via server logs.

Legal basis for processing:
compliance with a legal obligation to which we are
subject (Article 6(1)(c) of the General Data Protection Regulation).

Legal obligation:
we have a legal obligation to implement appropriate technical and
organisational measures to ensure a level of security appropriate to the
risk of our processing of information about individuals. Recording access
to our website using server log files is such a measure.

Legal basis for processing:
our legitimate interests (Article 6(1)(f) of the General
Data Protection Regulation).

Legitimate interests:
we have a legitimate interest in using your information for the purposes
of ensuring network and information security.

Cookies

Cookies are data files which are sent from a website to a browser to record
information about users for various purposes.

We use cookies on our website, including, functional, analytical and
targeting cookies. For further information on how we use cookies, please
see our cookies policy which is available here:

Cookie Policy

You can reject some or all of the cookies we use on or via our website by
changing your browser settings by using our cookie control tool, but doing
so can impair your ability to use our website or some or all of its
features. For further information about cookies, including how to change
your browser settings, please visit www.allaboutcookies.org or see our
cookies policy.

4. Information we collect when you contact us

We collect and use information from individuals who contact us in
accordance with this section and the section entitled Disclosure and
additional uses of your information.

Email

When you send an email to the email address displayed on our website we
collect your email address and any other information you provide in that
email (such as your name, telephone number and the information contained in
any signature block in your email).

Legal basis for processing:
our legitimate interests (Article
6(1)(f) of the General Data Protection Regulation).

Legitimate interest(s):
responding to enquiries and messages we receive and keeping records of
correspondence.

Legal basis for processing:
necessary to perform a contract or to take steps at your request to enter
into a contract (Article 6(1)(b) of the General Data Protection
Regulation).

Reason why necessary to perform a contract:
where your message relates to us providing you with goods or services or
taking steps at your request prior to providing you with our goods and
services (for example, providing you with information about such goods and
services), we will process your information in order to do so).

Transfer and storage of your information

We use a third party email provider to store emails you send us. Our third
party email provider is Microsoft which is located in the United States of
America. Their privacy policy is available here:
https://privacy.microsoft.com/en-us/privacystatement

Microsoft transfers and stores emails you send us outside the European
Economic Area. Where they do so, they will put appropriate safeguards in
place.

For further information about the safeguards used when your information is
transferred outside the European Economic Area, see the section of this
privacy policy below entitled Transfers of your information outside the
European Economic Area.

Contact form

When you contact us using our contact form, we collect name, email address , and any information you include in the message field. We also
collect any other information you provide to us when you complete the
contact form, including any optional information, such as the nature of
your enquiry.

If you do not provide the mandatory information required by our contact
form, you will not be able to submit the contact form and we will not
receive your enquiry.

Legal basis for processing:
our legitimate interests (Article
6(1)(f) of the General Data Protection Regulation).

Legitimate interest(s):
responding to enquiries and messages we receive and keeping records of
correspondence.

Legal basis for processing:
necessary to perform a contract or to take steps at your request to enter
into a contract (Article 6(1)(b) of the General Data Protection
Regulation).

Reason why necessary to perform a contract:
where your message relates to us providing you with goods or services or
taking steps at your request prior to providing you with our goods and
services (for example, providing you with information about such goods and
services), we will process your information in order to do so).

Transfer and storage of your information

Information you send us via our contact form, your information is stored on
our email provider’s servers. For further information, please see ‘Email’
above.

Phone

When you contact us by phone, we collect your phone number and any
information provide to us during your conversation with us.

We do not record phone calls.

Legal basis for processing:
our legitimate interests (Article
6(1)(f) of the General Data Protection Regulation).

Legitimate interest(s):
responding to enquiries and messages we receive and keeping records of
correspondence.

Legal basis for processing:
necessary to perform a contract or to take steps at your request to enter
into a contract (Article 6(1)(b) of the General Data Protection
Regulation).

Reason why necessary to perform a contract:
where your message relates to us providing you with goods or services or
taking steps at your request prior to providing you with our goods and
services (for example, providing you with information about such goods and
services), we will process your information in order to do so).

Transfer and storage of your information

Information about your call, such as your phone number and the date and
time of your call, is processed by our third party telephone service
provider, BT Group Plc. which is located in the United Kingdom. Their
privacy policy is available here:
https://www.productsandservices.bt.com/privacy-policy/

Post

If you contact us by post, we will collect any information you provide to
us in any postal communications you send us.

Legal basis for processing:
our legitimate interests (Article
6(1)(f) of the General Data Protection Regulation).

Legitimate interest(s):
responding to enquiries and messages we receive and keeping records of
correspondence.

Legal basis for processing:
necessary to perform a contract or to take steps at your request to enter
into a contract (Article 6(1)(b) of the General Data Protection
Regulation).

Reason why necessary to perform a contract:
where your message relates to us providing you with goods or services or
taking steps at your request prior to providing you with our goods and
services (for example, providing you with information about such goods and
services), we will process your information in order to do so).

5. Information we collect when you interact with our website

We collect and use information from individuals who interact with
particular features of our website in accordance with this section and the
section entitled Disclosure and additional uses of your information.

E-Newsletter

When you sign up to join our e-newsletter we collect your name and email
address.

Legal basis for processing:
your consent (Article 6(1)(a) of the
General Data Protection Regulation).

Consent:
you give your consent to us sending you our e-newsletter by signing up to
receive it using the steps described above.

Transfer and storage of your information

We use a third party service to send out our e-newsletter and administer
our mailing list, Mail Chimp. Their privacy policy is available here:
https://mailchimp.com/legal/privacy/

Information you submit to subscribe for our e-newsletter will be stored outside the European Economic Area on our third party
mailing list provider’s servers in the United States of America. For
further information about the safeguards used when your information is
transferred outside the European Economic Area, see the section of this
privacy policy below entitled Transfers of your information outside the
European Economic Area.

Registering on our website

When you register and create an account on our website when you place an
order, we collect the following information: name, address, email address,
phone number and security question answer.

If you do not provide the mandatory information required by the
registration form, you will not be able to register or create an account on
our website.

Legal basis for processing:
necessary to perform a contract or to take steps at your
request prior to entering into a contract (Article 6(1)(b)
of the General Data Protection Regulation).

Reason why necessary to perform a contract:
creating an account on our website is necessary to allow you to access
our services.

Legal basis for processing:
our legitimate interests (Article 6(1)(f) of the General
Data Protection Regulation).

Legitimate interest:
registering and administering accounts on our website to provide
access to content and facilitate the running and operation of our business.

Transfer and storage of your information

Information you submit via our registration form will be stored both within
and outside the European Economic Area on our third party
hosting and email providers’ servers in the United Kingdom
and the United States of America respectively. For further information,
please see the sections entitled ‘Email’ and ‘Web server log information’
above.

Information we collect when you place a booking on our website

We collect and use information from individuals who place an order on our
website in accordance with this section and the section entitled Disclosure
and additional uses of your information.

Information collected when you place an order

Mandatory information

When you place an order for goods or services on our website, we collect
your name, email address, billing address, company name (if applicable),
VAT number (if applicable), and phone number.

If you do not provide this information, you will not be able to purchase
goods or services from us on our website or enter into a contract with us.

Legal basis for processing:
necessary to perform a contract (Article 6(1)(b) of the
General Data Protection Regulation).

Reason why necessary to perform a contract:
we need the mandatory information collected by our checkout form to
establish who the contract is with and to contact you to fulfil our
obligations under the contract, including sending you receipts and order
confirmations.

Legal basis for processing:
compliance with a legal obligation (Article 6(1)(c) of the General Data
Protection Regulation).

Legal obligation:
we have a legal obligation to issue you with an invoice for the goods and
services you purchase from us where you are VAT registered and we require
the mandatory information collected by our checkout form for this purpose.
We also have a legal obligation to keep accounting records, including
records of transactions.

Optional information

If you do not supply the optional information requested at checkout, such
as your phone number we will not be able to contact you by phone.

Legal basis for processing:
your consent (Article 6(1)(a) of the
General Data Protection Regulation).

Legitimate interests:
you consent to us processing any optional information
you provide by submitting that information to us.

Processing your payment

After you place an order on our website you will need to make payment for
the booking you have placed. In order to process your payment we use a
third party payment processor, Worldpay UK Limited. Your payment will be
processed by SK Chase Incorporated or Oracle UK Corporation to process your
payment.

SK Chase Incorporated and Oracle UK Corporation collect, use and process
your information, including payment information, in accordance with their
privacy policies. You can access their privacy policies via the following
link(s):

Transfer and storage of your information

Information relating to the processing of your payment is stored within and
outside the European Economic Area on our third party payment processor’s
servers in the United Kingdom and the United States of America.

For further information about the safeguards used when your information is
transferred outside the European Economic Area, see the section of this
privacy policy below entitled Transfers of your information outside the
European Economic Area.

Legal basis for processing:
necessary to perform a contract (Article 6(1)(b) of the
General Data Protection Regulation).

Reason why necessary to perform a contract:
to fulfil your contractual obligation to pay for the goods or services
you have ordered from us.

Information collected or obtained from third parties

This section sets out how we obtain or collect information about you from
third parties.

Information received from third parties

Generally, we do receive information about you from third parties. The
third parties from which we receive information about you will generally
include Treatwell Limited and SK Chase Incorporated.

It is also possible that third parties with whom we have had no prior
contact may provide us with information about you.

Information we obtain from third parties will generally be your name and
contact details, but will include any additional information about you
which they provide to us.

Legal basis for processing:
necessary to perform a contract or to take steps at your
request to enter into a contract (Article 6(1)(b) of the General Data
Protection Regulation).

Reason why necessary to perform a contract:
where a third party has passed on information about you to us (such as
your name and email address) in order for us to provide services to you, we
will process your information in order to take steps at your request to
enter into a contract with you and perform a contract with you (as the case
may be).

Legal basis for processing:
consent (Article 6(1)(a) of the General Data Protection
Regulation).

Consent:
where you have asked that a third party to share information about you
with us and the purpose of sharing that information is not related to the
performance of a contract or services by us to you, we will process your
information on the basis of your consent, which you give by asking the
third party in question to pass on your information to us.

Legal basis for processing:
our legitimate interests (Article 6(1)(f) of the General
Data Protection Regulation).

Legitimate interests:
where a third party has shared information about you with us and you have
not consented to the sharing of that information, we will have a legitimate
interest in processing that information in certain circumstances.

For example, we would have a legitimate interest in processing your
information to perform our obligations under a sub-contract with the third
party, where the third party has the main contract with you. Our legitimate
interest is the performance of our obligations under our sub-contract.

Similarly, third parties may pass on information about you to us if you
have infringed or potentially infringed any of our legal rights. In this
case, we will have a legitimate interest in processing that information to
investigate and pursue any such potential infringement.

Where we receive information about you in error

If we receive information about you from a third party in error and/or we
do not have a legal basis for processing that information, we will delete
your information.

Information obtained by us from third parties

In certain circumstances (for example, to verify the information we hold
about you or obtain missing information we require to provide you with a
service) we will obtain information about you from certain publicly
accessible sources, both EU and non-EU, such as the electoral register,
Companies House, online customer databases, business directories, media
publications, social media, and websites (including your own website if you
have one).

In certain circumstances we will also obtain information about you from
private sources, both EU and non-EU.

Legal basis for processing:
necessary to perform a contract or to take steps at your
request to enter into a contract (Article 6(1)(b) of the General Data
Protection Regulation).

Reason why necessary to perform a contract:
where you have entered into a contract or requested that we enter into a
contract with you, in certain circumstances, we will obtain information
about you from public sources in order to enable us to understand your
business and provide services to you or services to a sufficient standard.

For example, we would obtain and/or verify your email address from your
website or from a directory where you ask us to send you information by
email but we do not possess the information or we need to confirm that we
have recorded your email address correctly.

Legal basis for processing:
our legitimate interests (Article 6(1)(f) of the General
Data Protection Regulation).

Legitimate interests:
in certain circumstances, we will have a legitimate interest in obtaining
information about you from public and private sources. For example, if you
have infringed or we suspect that you have infringed any of our legal
rights, we will have a legitimate interest in obtaining and processing
information about you from such sources in order to investigate and pursue
any suspected or potential infringement.

7. Our use of profiling

We use profiling on our website. We do not consider that this has any legal
effect on you or similarly significantly affects you.

You have the right to object to our use of profiling described in this
section. You can do that by opting-out of cookies and similar technologies
in accordance with the method described in the relevant section below. If
you do not want us to process your actual IP address (usually the IP
address assigned to you by your Internet Service Provider) when you visit
our website, you can use a Virtual Private Network (VPN) or a free service
such as Tor.

You can find out more about our use of cookies and similar technologies
(including the legal basis on which we use them) and how to opt out from
them in our cookies policy, which is available here:

Cookie Policy

Profiling

Profiling is any form of automated processing of your information to
evaluate personal aspects about you, in particular to analyse or predict
things like your performance at work, economic situation, health, personal
preferences, interests, reliability, behaviour, location or movements.

Use of profiling for web analytics

Our web analytics service, Google Analytics, uses collects information such
as your location (based on your IP address) and your behaviour (based on
cookies) when you access our website (such as the pages you visit and what
you click on). We will only process information from cookies if you have
consented to us setting cookies on your computer in accordance with our
cookies policy (https://www.greenwoodshotel.com/cookie-policy/).

Logic involved
by automatically analysing and categorising information such as the
location (based on IP address) as well as the behaviour and devices of
visitors to our website (using cookies), we are able to gain a better
understanding of what our website visitors want (in terms of the content of
our website and our products), how to improve our website and how to
advertise and market our services to them.

Significance and envisaged consequences:
cookies will be used to track and store information about your behaviour
and device on our website (unless you have opted out from receiving such
cookies by using our cookie control tool) and your location will be
analysed based on your IP address.

Legal basis for processing:
our legitimate interests (Article 6(1)(f) of
the General Data Protection Regulation).

Legitimate interest:
we have a legitimate interest in understanding how individuals use our
website to and to improve our website in general.

9. Disclosure and additional uses of your information

This section sets out the circumstances in which will disclose information
about you to third parties and any additional purposes for which we use
your information.

Disclosure of your information to service providers

We use a number of third parties to provide us with services which are
necessary to run our business or to assist us with running our business and
who process your information for us on our behalf. These include the
following:

Apart from our email provider and our mailing list provider, which are
located in the United States of America, our service providers are located
in the United Kingdom.

Your information will be shared with these service providers where
necessary to provide you with the service you have requested, whether that
is accessing our website or ordering goods and services from us.

We do not display the identities of all of our service providers publicly
by name for security and competitive reasons. If you would like further
information about the identities of our service providers, however, please
contact us directly by email and we will provide you with such information
where you have a legitimate reason for requesting it (where we have shared
your information with such service providers, for example).

Legal basis for processing:
legitimate interests (Article 6(1)(f) of the General
Data Protection Regulation).

Legitimate interest relied on:
where we share your information with these third parties in a context
other than where is necessary to perform a contract (or take steps at your
request to do so), we will share your information with such third parties
in order to allow us to run and manage our business efficiently.

Legal basis for processing:
necessary to perform a contract and/or to take steps at
your request prior to entering into a contract (Article 6(1)(b) of the
General Data Protection Regulation).

Reason why necessary to perform a contract:
we may need to share information with our service providers to enable us
to perform our obligations under that contract or to take the steps you
have requested before we enter into a contract with you.

Disclosure of your information to other third parties

Providing information to Google, Twitter and TripAdvisor

Google collects information through our use of Google Analytics on our
website. Google uses this information, including IP addresses and
information from cookies, for a number of purposes, such as improving its
Google Analytics service. Information is shared with Google on an
aggregated and anonymised basis. To find out more about what information
Google collects, how it uses this information and how to control the
information sent to Google, please see the following page:
https://www.google.com/policies/privacy/partners/

We share information with Twitter to track conversions to our site (i.e. to
measure which people visit our website and who contacts us in relation to
our products and services). You can find out more about conversion tracking
here:
https://business.twitter.com/en/help/campaign-measurement-and-analytics/conversion-tracking-for-websites.html
and about the information Twitter collects here:
https://twitter.com/en/privacy

You can find out more about how TripAdvisor uses your information in
accordance with their privacy policy here:
https://www.tripadvisor.co.uk/pages/privacy_pre_060407.html

Legal basis for processing:
our legitimate interests (Article
6(1)(f) of the General Data Protection Regulation).

Legitimate interest(s):
meeting our contractual obligations to Google under our Google Analytics
Terms of Service (https://www.google.com/analytics/terms/us.html).

You can opt out of Google Analytics by installing the browser plugin here:
https://tools.google.com/dlpage/gaoptout

If you would not like to receive ads on Twitter, you can opt out using the
Digital Advertising Alliance’s consumer choice tool available here:
optout.aboutads.info

Transfer and storage of your information

Information collected by Google Analytics, Twitter is stored outside the
European Economic Area on their servers in the United States of America.
TripAdvisor may transfer you information outside the European Economic Area
from time to time.

For further information about the safeguards used when your information is
transferred outside the European Economic Area, see the section of this
privacy policy below entitled Transfers of your information outside the
European Economic Area.

Sharing your information with third parties, which are either related to or
associated with the running of our business, where it is necessary for us
to do so. These third parties include our accountants, advisors, business
partners, independent contractors, and insurers. Further information on
each of these third parties is set out below.

Legal basis for processing:
our legitimate interests (Article
6(1)(f) of the General Data Protection Regulation).

Legitimate interest:
running and managing our business efficiently.

Accountants

We share information with our accountants for tax purposes. For example, we
share invoices we issue and receive with our accountants for the purpose of
completing tax returns and our end of year accounts.

Our accountants are located in the United Kingdom.

Advisors

Occasionally, we obtain advice from advisors, such as accountants,
financial advisors, lawyers and public relations professionals. We will
share your information with these third parties only where it is necessary
to enable these third parties to be able to provide us with the relevant
advice.

Our advisors are located in United Kingdom.

Business partners

Business partners are businesses we work with which provide goods and
services which are complementary to our own or which allow us to provide
goods or services which we could not provide on our own. We share
information with our business partners where you have requested services
which they provide whether independently from, or in connection with or own
services.

Our business partners are located in the United Kingdom.

Independent contractors

Occasionally, we use independent contractors in our business. Your
information will be shared with independent contractors only where it is
necessary for them to perform the function we have hired them perform in
relation to our business.

Our independent contractors are located in the United Kingdom.

Insurers

We will share your information with our insurers where it is necessary to
do so, for example in relation to a claim or potential claim we receive or
make or under our general disclosure obligations under our insurance
contract with them.

Our insurers are located in the United Kingdom.

Sharing your information with a prospective or actual purchaser or seller
in the context of a business or asset sale or acquisition by us, a merger
or similar business combination event, whether actual or potential.

Legal basis for processing:
legitimate interests (Article 6(1)(f) of the General
Data Protection Regulation).

Legitimate interest(s):

sharing your information with a prospective purchaser,
seller or similar person in order to allow such a transaction to take
place.

Disclosure and use of your information for legal reasons

Indicating possible criminal acts or threats to public security to a
competent authority

If we suspect that criminal or potential criminal conduct has been
occurred, we will in certain circumstances need to contact an appropriate
authority, such as the police. This could be the case, for instance, if we
suspect that a fraud or a cyber crime has been committed or if we receive
threats or malicious communications towards us or third parties.

We will generally only need to process your information for this purpose if
you were involved or affected by such an incident in some way.

Legal basis for processing:
our legitimate interests (Article
6(1)(f) of the General Data Protection Regulation).

Legitimate interests:
preventing crime or suspected criminal activity (such as fraud).

In connection with the enforcement or potential enforcement our legal
rights

We will use your information in connection with the enforcement or
potential enforcement of our legal rights, including, for example, sharing
information with debt collection agencies if you do not pay amounts owed to
us when you are contractually obliged to do so. Our legal rights may be
contractual (where we have entered into a contract with you) or
non-contractual (such as legal rights that we have under copyright law or
tort law).

Legal basis for processing:
our legitimate interests (Article 6(1)(f) of the General Data Protection
Regulation).

Legitimate interest:
enforcing our legal rights and taking steps to enforce our legal rights.

In connection with a legal or potential legal dispute or proceedings

We may need to use your information if we are involved in a dispute with
you or a third party for example, either to resolve the dispute or as part
of any mediation, arbitration or court resolution or similar process.

Legal basis for processing:
our legitimate interests (Article 6(1)(f) of the General Data Protection
Regulation).

Legitimate interest(s):
resolving disputes and potential disputes.

For ongoing compliance with laws, regulations and other legal requirements

We will use and process your information in order to comply with legal
obligations to which we are subject. For example, we may need to disclose
your information pursuant to a court order or subpoena if we receive one or
to the National Crime Agency.

Legal basis for processing:
compliance with a legal obligation (Article 6(1)(c) of
the General Data Protection Regulation).

Legal obligation(s):
legal obligations to disclose information which are part
of the laws of England and Wales or if they have been integrated into the
United Kingdom’s legal framework (for example in the form of an
international agreement which the United Kingdom has signed).

Legal basis for processing:
our legitimate interests (Article
6(1)(f) of the General Data Protection Regulation).

Legitimate interest:
where the legal obligations are part of the laws of another country and
have not been integrated into the United Kingdom’s legal framework, we have
a legitimate interest in complying with these obligations.

10. How long we retain your information

This section sets out how long we retain your information. We have set out
specific retention periods where possible. Where that has not been
possible, we have set out the criteria we use to determine the retention
period.

Retention periods

Order information: when you place an order for goods and services, we
retain that information for seven years following the end of the financial
year in which you placed your order, in accordance with our legal
obligation to keep records for tax purposes and to defend against legal
claims.

Correspondence and enquiries: when you make an enquiry or correspond with
us for any reason, whether, we will retain your information for as long as
it takes to respond to and resolve your enquiry, and for 1 further year,
after which point we will delete your information.

E-Newsletter: we retain the information you used to sign up for our
e-newsletter for as long as you remain subscribed (i.e. you do not
unsubscribe) or if we decide to cancel our e-newsletter service, whichever
comes earlier.

Criteria for determining retention periods

In any other circumstances, we will retain your information for no longer
than necessary, taking into account the following:

11. How we secure your information

We take appropriate technical and organisational measures to secure your
information and to protect it against unauthorised or unlawful use and
accidental loss or destruction, including:

Transmission of information to us by email

Transmission of information over the internet is not entirely secure, and
if you submit any information to us over the internet (whether by email,
via our website or any other means), you do so entirely at your own risk.

We cannot be responsible for any costs, expenses, loss of profits, harm to
reputation, damages, liabilities or any other form of loss or damage
suffered by you as a result of your decision to transmit information to us
by such means.

12. Transfers of your information outside the European Economic Area

Your information will be transferred and stored outside the European
Economic Area (EEA) in the circumstances set out below.

We will also transfer your information outside the EEA or to an
international organisation in order to comply with legal obligations to
which we are subject (compliance with a court order, for example). Where we
are required to do so, we will ensure appropriate safeguards and
protections are in place.

Email

Information you submit to us by email is transferred outside the EEA and
stored on our third-party email provider’s servers. Our third-party email
provider is Microsoft. You can access their privacy policy here:
https://privacy.microsoft.com/en-gb/privacystatement

Country of storage: the United States of America. This country is not
subject to an adequacy decision by the European Commission.

Safeguard(s) used: Microsoft has self-certified its compliance with the
EU-U.S. Privacy Shield which is available here:
https://www.privacyshield.gov/welcome. The EU-U.S. Privacy Shield is an
approved certification mechanism under Article 42 of the General Data
Protection Regulation, which is permitted under Article 46(2)(f) of the
General Data Protection Regulation. You can access the European Commission
decision on the adequacy of the EU-U.S. Privacy Shield here:
http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm

Contact form

Information you submit to us via our contact form is transferred outside
the EEA and stored on our third party email provider’s servers. For further
information, please see ‘Email’ above.

E-Newsletter

Information you submit to us when you sign up for our e-newsletter is
transferred outside the EEA and stored on our third party mailing list
provider’s servers. Our third party mailing list provider is Mail Chimp.
You can access their privacy policy here:
https://mailchimp.com/legal/privacy/

Country of storage: the United States of America. This country is not
subject to an adequacy decision by the European Commission.

Safeguard(s) used: our third party contact form provider has self-certified
its compliance with the EU-U.S. Privacy Shield which is available here:
https://www.privacyshield.gov/welcome. The EU-U.S. Privacy Shield is an
approved certification mechanism under Article 42 of the General Data
Protection Regulation, which is permitted under Article 46(2)(f) of the
General Data Protection Regulation. You can access the European Commission
decision on the adequacy of the EU-U.S. Privacy Shield here:
http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm

Google Analytics

Information collected by Google Analytics (your IP address and actions you
take in relation to our website) is transferred outside the EEA and stored
on Google’s servers. You can access Google’s privacy policy here:
https://www.google.com/policies/privacy/

Country of storage: United States of America. This country is not subject
to an adequacy decision by the European Commission.

Safeguard(s) used: Google has self-certified its compliance with the
EU-U.S. Privacy Shield which is available here:
https://www.privacyshield.gov/welcome. The EU-U.S. Privacy Shield is an
approved certification mechanism under Article 42 of the General Data
Protection Regulation, which is permitted under Article 46(2)(f) of the
General Data Protection Regulation. You can access the European Commission
decision on the adequacy of the EU-U.S. Privacy Shield here:
http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm

Twitter

Information collected by Twitter, Inc. is transferred and stored outside
the EEA on their servers in the United States of America. Twitter, Inc.’s
privacy policy is available here: https://twitter.com/en/privacy

Country of storage: United States of America. This country is not subject
to an adequacy decision by the European Commission.

Safeguard(s) used: Twitter, Inc. has self-certified its compliance with the
EU-U.S. Privacy Shield which is available here:
https://www.privacyshield.gov/welcome. The EU-U.S. Privacy
Shield is an approved certification mechanism under Article 42 of the
General Data Protection Regulation, which is permitted under Article
46(2)(f) of the General Data Protection Regulation. You can access the
European Commission decision on the adequacy of the EU-U.S. Privacy Shield
here: https://ec.europa.eu/info/law/law-topic/data-protection_en

Payment processing

We use third party payment processors and bookings via external websites,
including Worldpay UK Limited, SK Chase Incorporated, and Oracle
Corporation. These third parties may transfer information they process
about your order outside the EEA. Where they do so, they will ensure
appropriate safeguards are in place. You can access their privacy policies
via the following links:

13. Your rights in relation to your information

Subject to certain limitations on certain rights, you have the following
rights in relation to your information, which you can exercise by writing
to Greenwoods Hotel & Spa, 4 Woodbrook Crescent, Lake View, Billericay,
Essex, CM12 0EQ or sending an email to info@greenwoodshotel.co.uk:

In accordance with Article 77 of the General Data Protection Regulation,
you also have the right to lodge a complaint with a supervisory authority,
in particular in the Member State of your habitual residence, place of work
or of an alleged infringement of the General Data Protection Regulation.

For the purposes of the UK, the supervisory authority is the Information
Commissioner’s Office (ICO), the contact details of which are available
here: https://ico.org.uk/global/contact-us/

Further information on your rights in relation to your personal data as an
individual

The above rights are provided in summary form only and certain limitations
apply to many of these rights. For further information about your rights in
relation to your information, including any limitations which apply, please
visit the following pages on the ICO’s website:

You can also find out further information about your rights, as well as
information on any limitations which apply to those rights, by reading the
underlying legislation contained in Articles 12 to 22 and 34 of the General
Data Protection Regulation, which is available here:
http://ec.europa.eu/justice/data-protection/reform/files/regulation_oj_en.pdf

Verifying your identity where you request access to your information

Where you request access to your information, we are required by law to use
all reasonable measures to verify your identity before doing so.

These measures are designed to protect your information and to reduce the
risk of identity fraud, identity theft or general unauthorised access to
your information.

How we verify your identity

Where we possess appropriate information about you on file, we will attempt
to verify your identity using that information.

If it is not possible to identity you from such information, or if we have
insufficient information about you, we may require original or certified
copies of certain documentation in order to be able to verify your identity
before we are able to provide you with access to your information.

We will be able to confirm the precise information we require to verify
your identity in your specific circumstances if and when you make such a
request.

14.Your right to object to the processing of your information for certain purposes

You have the following rights in relation to your information, which you
may exercise in the same way as you may exercise by writing to Greenwoods
Hotel & Spa, 4 Woodbrook Crescent, Lake View, Billericay, Essex, CM12
0EQ or sending an email to info@greenwoodshotel.co.uk:

You may also exercise your right to object to us using or processing your
information for direct marketing purposes by:

For more information on how to object to our use of information collected
from cookies and similar technologies, please see the section entitled How
to accept or reject cookies in our cookies policy, which is available here:

Cookie Policy

15. Sensitive Personal Information

‘Sensitive personal information’ is information about an individual that
reveals their racial or ethnic origin, political opinions, religious or
philosophical beliefs, or trade union membership, genetic information,
biometric information for the purpose of uniquely identifying an
individual, information concerning health or information concerning a
natural person’s sex life or sexual orientation.

We do not knowingly or intentionally collect sensitive personal information
from individuals, and you must not submit sensitive personal information to
us.

If, however, you inadvertently or intentionally transmit sensitive personal
information to us, you will be considered to have explicitly consented to
us processing that sensitive personal information under Article 9(2)(a) of
the General Data Protection Regulation. We will use and process your
sensitive personal information for the purposes of deleting it.

16. Changes to our Privacy Policy

We update and amend our Privacy Policy from time to time.

Minor changes to our Privacy Policy

Where we make minor changes to our Privacy Policy, we will update our
Privacy Policy with a new effective date stated at the beginning of it. Our
processing of your information will be governed by the practices set out in
that new version of the Privacy Policy from its effective date onwards.

Major changes to our Privacy Policy or the purposes for which we process
your information

Where we make major changes to our Privacy Policy or intend to use your
information for a new purpose or a different purpose than the purposes for
which we originally collected it, we will notify you by email (where
possible) or by posting a notice on our website.

We will provide you with the information about the change in question and
the purpose and any other relevant information before we use your
information for that new purpose.

Wherever required, we will obtain your prior consent before using your
information for a purpose that is different from the purposes for which we
originally collected it.

17. Children’s Privacy

Because we care about the safety and privacy of children online, we comply
with the Children’s Online Privacy Protection Act of 1998 (COPPA). COPPA
and its accompanying regulations protect the privacy of children using the
internet. We do not knowingly contact or collect information from persons
under the age of 18. The website is not intended to solicit information of
any kind from persons under the age of 18.

It is possible that we could receive information pertaining to persons
under the age of 18 by the fraud or deception of a third party. If we are
notified of this, as soon as we verify the information, we will, where
required by law to do so, immediately obtain the appropriate parental
consent to use that information or, if we are unable to obtain such
parental consent, we will delete the information from our servers. If you
would like to notify us of our receipt of information about persons under
the age of 18, please do so by sending an email to
info@greenwoodshotel.co.uk

18. California Do Not Track Disclosures

“Do Not Track” is a privacy preference that users can set in their web
browsers. When a user turns on a Do Not Track signal in their browser, the
browser sends a message to websites requesting that they do not track the
user. For information about Do Not Track, please visit www.allaboutdnt.org

19. Copyright

The copyright in this Privacy Policy is either owned by, or licensed to, us
and is protected by copyright laws around the world and copyright
protection software. All intellectual property rights in this document are
reserved.

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