This policy statement sets out the data processing practices carried out through the use of the Internet and World Wide Web by The Belfry.

Effective Date: December, 2017

This privacy statement applies to www.thebelfry.com owned and operated by The Belfry. This privacy statement describes how we collect and use the personal information you provide on our web site: www.thebelfry.com It also describes the choices available to you regarding our use of your personal information and how you can access and update this information. We may amend this privacy statement from time to time, so visit this page regularly to keep abreast of the updates. For the purpose of the Data Protection Act 1998, up to and including 24 May 2018, and the EU General Data Protection Regulation 2016/679 thereafter (the Data Protection Legislation), we are the data controller (i.e. the company who is responsible for, and controls the processing of, your personal data).

The types of personal information that we collect include:

• Your first name, last name, email address, phone number and home address;
• Credit card details (type of card, credit card number, name on card, expiration date and security code);
• Guest stay information, including date of arrival and departure, special requests made, observations about your service preferences (including room preferences, facilities or any other services used);
• Information you provide regarding your marketing preferences or in the course of participating in surveys, contests or promotional offers;

When you visit our website, even if you do not make a reservation, we may collect certain information, such as your IP address, which browser you’re using, and information about your computer’s operating system, application version, language settings and pages that have been shown to you. If you are using a mobile device, we might also collect data that identifies your mobile device, device-specific settings and characteristics and latitude/longitude details. When you make a reservation, our system registers through which means and from which websites you have made your reservation. If this data can identify you as a natural person, this data is considered personal information which is subject to this privacy statement.

You may always choose what personal information (if any) you wish to provide to us. If you choose not to provide certain details, however, some of your transactions with us may be impacted.

We may receive information about you if you use any of the other websites we operate or the other services we provide. In this case we will have informed you when we collected that data that it may be shared internally and combined with data collected on this website. We are also working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them which we will add to the information which we already hold about you in order to help us provide goods and services and improve and personalise our service to you.

Why do we collect, use and share your personal information?

Reservations: we use your personal information to complete and administer your online reservation. Customer service: we use your personal information to provide customer service. Guest reviews: we may use your contact information to invite you by email to write a guest review after your stay. This can help other travellers to choose the accommodation that suits them best. Marketing activities: we also use your information for marketing activities, as permitted by law. Other communications: there may be other times when we get in touch by email, by post, by phone or by texting you, depending on the contact information you share with us. There could be a number of reasons for this:

We may need to respond to and handle requests you have made.

If you have not finalised a reservation online, we may email you a reminder to continue with your reservation. We believe that this additional service is useful to you because it allows you to carry on with a reservation without having to search for the accommodation again or fill in all the reservation details from scratch. When you use our services, we may send you a questionnaire or invite you to provide a review about your experience with our website. Legal purposes: In certain cases, we may need to use your information to handle and resolve legal disputes, for regulatory investigations and compliance. Fraud detection and prevention: we may use your personal information for the detection and prevention of fraud and other illegal or unwanted activities. Improving our services: finally, we use your personal information for analytical purposes, to improve our services, to enhance the user experience, and to improve the functionality and quality of our online travel services.

Disclosure of your information

We may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the Companies Act 2006.

We may share your information with selected third parties including:

business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you; analytics and search engine providers that assist us in the improvement and optimisation of our website; and credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you. We may disclose your personal information to third parties:

in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets; if all, or substantially all, of our assets are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets; and if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements; or to protect the rights, property, or safety of our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction. To process your information as described above, we rely on the following legal basis:

Performance of a Contract: The use of your information may be necessary to perform the contract that you have with us. For example, if you use our services to make an online reservation, we'll use your information to carry out our obligation to complete and administer that reservation under the contract that we have with you. Legitimate Interests: We may use your information for our legitimate interests, such as providing you with the best appropriate content for the website, emails and newsletters, to improve and promote our products and services and the content on our website, and for administrative, fraud detection and legal purposes. Consent: We may rely on your consent to use your personal information for certain direct marketing purposes. You can withdraw your consent anytime by contacting us at any of the addresses at the end of this

Privacy Statement.

We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data.

Retention of Personal Information

We will retain your personal information for as long as we deem it necessary to provide services to you, comply with applicable laws (including those regarding document retention), resolve disputes with any parties and otherwise as necessary to allow us to conduct our business. All personal information we retain will be subject to this privacy statement.

Cookies

A cookie is a small text file that is placed onto your computer (or other electronic devices) when you access our website.

We use cookies to better the user's experience while visiting our website. Where applicable, our website uses a cookie control system allowing the user on their first visit to our website to allow or disallow the use of cookies on their computer and/or device. This complies with recent legislation requirements for websites to obtain explicit consent from users before leaving behind or reading files such as cookies on a user’s computer and/or device.

Cookies are small files saved to your computer’s hard drive that track, save and store information about your interactions and usage of our website. This allows our website, through its server to provide the users with a tailored experience.

Our website uses tracking software to monitor its visitors to better understand how they use it. This software is provided by Google Analytics which uses cookies to track visitor usage. The software will save a cookie to your computer’s hard drive in order to track and monitor your engagement and usage of the website, but will not store, save or collect personal information.

You can read Google’s privacy policy here for further information http://www.google.com/privacy.html.

Consent

There is a notice on the home page of our website which describes how we use cookies and which also provides a link to our Privacy Policy. If you use this website after this notification has been displayed to you we will assume that you consent to our use of cookies for the purposes described in this Privacy Policy.

Third-party cookies

We work with third-party suppliers who may also set cookies on our website, for example Twitter, Facebook and LinkedIn. These third-party suppliers are responsible for the cookies they set on our Site. If you want further information please go to the website for the relevant third party.

Where we store your personal data

The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff maybe engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

How to turn off cookies

If you do not want to accept cookies, you can change your browser settings so that cookies are not accepted. If you do this, please be aware that you may lose some of the functionality of this website. For further information about cookies and how to disable them please go to: www.aboutcookies.org or www.allaboutcookies.org

What security procedures are put in place to safeguard your personal data?

In accordance with applicable data protection laws, we observe reasonable procedures to prevent unauthorised access to, and the misuse of, personal data. We use appropriate business systems and procedures to protect and safeguard the personal data you give us. We also use security procedures and technical and physical restrictions for accessing and using the personal data on our servers. Only authorised personnel are permitted to access personal data in the course of their work.

How can you control your personal information?

You always have the right to review the personal information we keep about you. You can request an overview of your personal data by emailing us to the email address stated below. Please write 'Request personal information' in the subject line of your email to speed things along a bit.

You can also contact us if you believe that the personal information we have for you is incorrect, if you believe that we are no longer entitled to use your personal data, or if you have any other questions about how your personal information is used or about this Privacy Statement. Please email or write to us using the contact details below. We will handle your request in accordance with the applicable data protection law.

Right to be forgotten

In certain circumstances, you can request us to delete all information we hold which identifies you. You can make this request at any time by contacting enquiries@thebelfry.com but please note we may be compelled to maintain your information due to specific legislative or regulatory requirements, for example we keep copy invoices in case of an HMRC investigation.

Transfer You can request us to transfer information we hold which identifies you to another person. You can make this request at any time by contacting enquiries@thebelfry.com.

Complaints

You have the right to complain to us about the way we use your information, please contact us by emailing enquiries@thebelfry.com if you would like to talk to us. If we cannot resolve your complaint, you have the right to complaint to the Information Commissioner’s Office. Their contact information can be found at: https://ico.org.uk/global/contact-us/.

Third Party Links

Our Site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

Who is responsible for the processing of your personal data?

The Belfry, Lichfield Road, Wishaw, Sutton Coldfield, B76 9PR, United Kingdom. If you have any suggestions or comments about this privacy statement, please send an email to enquiries@thebelfry.com.