Privacy Policy
Tinakilly Country House Hotel is committed to protecting and respecting your privacy. We appreciate how important your privacy is and recognise that we are being trusted with protecting it, so the purpose of this privacy notice is to give you a clear explanation about how we collect and use your personal Data.
We adhere to the Privacy Policy (the “Policy”) together with any disclaimers that sets out the basis on which any personal Data we collect from you, or that you provide to us, or that is provided to us relating to you, by any means, will be processed.
We think it’s important that you read this privacy notice in full, so that you understand what data we collect about you, how we collect, use and look after that data, what privacy rights you have and how the law protects you.
Please note that the Policy relates only to living individuals in relation to personal data relating to themselves, and not to persons in any other capacity.
For all our services, the Data Controller, the company that is responsible for personal data, is Tinakilly Country House Hotel.
Information we may collect from you
We collect, use, store and transfer different kinds of personal data about you to enable us to provide you with the service that you wish to avail of; to give you information about that service; to help us monitor and improve the services we provide and, where we are permitted to, to tell you about upcoming promotions and/or events that we think you might like.
We collect personal data from you which you volunteer when you provide such personal data to us, or via our services, or third party services with which you interact. We may also be given, or obtain other personal data relating to you, as may be provided to us in the course of our legitimate business activities.
Personal Data, or personal information, means any information about an individual from which that person can be identified. It does not include Data where the identity has been removed (anonymous data).
We may collect, use, store and transfer (process) different kinds of personal Data about you which we have grouped together as follows:
- Name and contact details
This includes your name, title, billing address, delivery address, email addresses and any telephone numbers you provide, including mobile phone numbers. - Date of birth
- Nationality
- Details of your children provided at time of booking if under the age of 18
- Medical details
This includes any information relating to disabilities to allow us to provide you with the correct service on arrival at our hotel. - Information relating to any allergies to ensure that the food provided is in line with your medical needs.
- Information relating to any medical conditions that may have an impact on our ability to deliver a service to you – for example: a massage, room requirements etc.
- Financial information
This includes your bank account and/or payment card details or any other payment details provided.
- Details of contracts you have entered with third parties for us to provide services to you
- Details of your vehicle registration number
- Details of your driving license
- Details of your passport
- Booking history
This includes details of any services you may have purchased from us. - Profile information if provided
This includes information relating to your interests and preferences. - Linked account information
This includes your Facebook ID and Twitter handle, if you link your account to us in any manner. - Marketing preferences
This includes your preferences in receiving any marketing information from us and your communication preferences. - Survey response and competition entries
This includes interactions with us over the phone, via the website, via forms you may complete at wedding fairs/open days, or on social media. - Customer service history
This includes interactions with us over the phone, via the website, via forms you may complete at wedding fairs/open days, or on social media. - Information about your device and how you use our website
This includes information you give us when you browse our websites, including your internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, as well as how you use your websites and apps.
All other Data which you ask us to process on your behalf, or which is necessary for us to process in order for us to fulfil our role as providing accommodation, conference / corporate or food related services to you.
We may also process other Data, which is not personal data.
How we collect your personal Data:
We collect personal data from and about you when you do things like purchase products and services from us, create an account, use our Wi-Fi, sign up to our newsletters and mailing lists or enter our competitions. We also use cookies to understand your browsing behaviour on our website to enable us to improve your experience on this and future visits.
We use different methods to collect data from and about you including through:
- Direct interactions.
You may give us your name and contact details and payment information by filling in forms, or by corresponding with us by post, phone, email, or otherwise. This includes personal data you provide when you: - Book a room, table in the restaurant, or other products or services from us;
- subscribe to our mailing lists or newsletters;
- request marketing to be sent to you;
- take part in a competition, promotion or survey; or
- give us some feedback.
Automated technologies, or interactions. As you interact with our website, we may automatically collect information about your device and how you use our websites and apps. We collect this personal data by using cookies, server logs and other similar technologies. For more information on cookies, please see our Cookie Policy here.
Name and contact details, payment information and purchase history from providers of technical payment and delivery services.
When you access our Wi-Fi facilities, your device’s browser provides us with information such as your IP address, browser type, access time and referring URL which may be collected and used to compile statistical data. This information may be used to help us improve our website and the services we offer to you.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
Unless we have told you otherwise in a specific privacy notice, we do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). The only exception to this is where you have specific disability needs which we need to be aware of in order to make reasonable adjustments and be able to perform our contract with you and comply with our obligations pursuant to social protection and equality laws.
If you don’t provide personal Data
You don’t have to give us any of your personal data but, if you don’t, you are unlikely to receive our optimal customer service experience. Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you.
Keeping your personal Data up-to-date
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
How we use your personal Data
We use your personal Data that we hold as follows:
- In our legitimate interest of advertising our services, provide you with information, products, or services, that you request from us, or which we feel may interest you, where you have consented to be contacted for such purposes.
- carry out our obligations arising from any contracts entered into between you and us;
- comply with legislation; and / or
- notify you about changes to our services.
We keep your data for varying periods according to our Retention Schedule here.
You will only receive marketing communications from us, if you have requested information from us, purchased products, or services from us, or told us that we can send them to you. You can tell us that you want to stop receiving marketing communications from us at any time.
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Where we need to perform the contract we are about to enter into, or have entered into, with you.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal, or regulatory obligation.
For certain processing purposes, we may request your consent to authorise the processing. For example, if you are not a customer of Tinakilly Country House Hotel and have not enquired about our products, or services, we would need clear consent from you in order to send any communications to you about our products or services.
Marketing Messages and Promotional Offers
We strive to provide you with choices regarding certain personal Data uses, particularly around marketing and advertising.
You may receive marketing communications from us if you have requested information from us, or purchased products, or services from us. You’ll receive these communications if you have said that we can send them to you when you provided us with your details when booking one of our services, when you entered a competition, signed up for a newsletter, or used our Wi-Fi services in our Hotel.
You can tell us that you want to stop receiving marketing communications from us at any time. You can do this when completing your Check-in sheet at the Hotel, when signing your contract if booking a wedding, or by contacting us directly by email, post, or over the phone.
We’ll process any such request as quickly as we can, but it might take a few days for all of our systems to be updated. Don’t worry about not getting communications about the service we are
providing to you – stopping marketing communications won’t stop service communications, so you’ll continue to get all the information you need.
Cookies
We use cookies on our websites. You can set your browser to refuse all, or some, browser cookies, or to alert you when websites set, or access, cookies. If you disable, or refuse cookies, please note that some parts of the website may become inaccessible, or not function properly. For more information about the cookies we use, please see our Cookie Policy here.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal Data without your knowledge, or consent, in compliance with the above rules, where this is required, or permitted, by law.
We keep your data for varying periods according to our Retention Schedule here.
Sharing your Personal Data
We are serious when we say that we are committed to protecting your privacy – we want to earn and maintain your trust, so we do not sell any of your personal data to any third party.
We do however, share your personal data with certain companies who play an essential part in enabling us to provide our products and services to you, such as payment providers, IT and system administration providers and others who help us run our business.
You can rest assured however, that we require all third parties to respect the security of your personal Data and to treat it in accordance with the law; we do not allow our third party service providers to use your personal data for their own purposes.
We may also disclose your Data in the event that we sell, or buy, any business, or assets, in which case we may disclose your Data to the prospective seller, or buyer, of such business, or assets of, if we are under a duty to disclose, or share your Data in order to comply with any legal obligation, or to protect our rights, property, or safety of staff, or customers.
Links to other sites
Our website may, from time to time, contain links to and from other websites. If you follow a link to any of those websites, please note that those websites have their own privacy policies and that we do not accept any responsibility, or liability, for those policies. Please check those polices before you submit any data to those websites.
Sending your personal data to countries outside Europe
Sometimes we might need to transfer your personal Data to third party processors outside the European Economic Area. For example this might be required to process your payment details, or provide support services. We will only do this if appropriate safeguards are in place to make sure your
personal Data receives the same protection as when it is being processed inside the European Economic Area.
Keeping your personal data secure
We are committed to protecting the security of your personal Data.
We use a variety of security technologies and procedures to help prevent your personal Data from being accidentally lost, used, or accessed, in an unauthorised way, altered, or disclosed.
In addition, we limit access to your personal Data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal Data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach, where we are legally required to do so.
As effective as modern security practices are, no physical, or electronic security system is entirely secure. We cannot guarantee the complete security of our databases, nor can we guarantee that information you supply will not be intercepted while being transmitted to us over the internet. We will continue to revise policies and implement additional security features as new technologies become available.
The transmission of information via the internet is not completely secure and may involve the transfer of data to countries outside of the European Economic Area (EEA). This occurs typically through use of Cloud solutions for web hosting, e-mail hosting, or proprietary software solutions delivered to us through the Cloud. We do not however authorise any third party to use your personal Data for their own purposes. Non EEA countries may not provide an adequate level of protection in relation to processing your personal Data. By submitting your data, you agree to this transfer, storing and processing.
Although we will do our best to protect your personal Data, we cannot guarantee the security of your personal Data transmitted to us. Any transmission of data is at your own risk. Once we receive your personal Data, we use appropriate security measures to seek to prevent unauthorised access.
How long will we keep your personal data for?
We will only retain your personal Data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal Data, we consider the amount, nature, and sensitivity of the personal Data, the potential risk of harm from unauthorised use, or disclosure of your personal Data, the purposes for which we process your personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements. Details of retention periods for different aspects of your personal Data are available in our retention schedule which you can review here.
In some circumstances, you can ask us to delete your data: see the section detailing your legal rights below for further information.
In some circumstances, we may anonymise your personal Data (so that it can no longer be associated with you) for research, or statistical purposes, in which case we may use this information indefinitely without further notice to you.
No fee required
You will not have to pay a fee to access your personal Data (or to exercise any of your other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal Data (or to exercise any of your other rights). This is a security measure to ensure that personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex, or you have made a number of requests. In this case, we will notify you and keep you updated.
Changes to this policy
We reserve the right to change this Policy from time to time and / or in line with legislative requirements. If we make any changes, we will post those changes here, so that you can see what information we gather, how we might use that information and in what circumstances we may disclose it. By continuing to use our site, or our services, or otherwise, provide data after we post any such changes, you accept and agree to this Policy as modified.
Glossary
We recognise that some of the privacy law terminology can be a bit complicated so we have included a glossary at the end to provide a bit more detail on the meaning of some of the terms used in this privacy notice.
Lawful Basis
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Your Legal Rights:
You have the right to:
Request access to your personal Data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal Data we hold about you and to check that we are lawfully processing it.
Request correction of the personal Data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal Data. This enables you to ask us to delete, or remove, personal Data where there is no good reason for us continuing to process it. You also have the right to ask us to delete, or remove, your personal Data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully, or where we are required to erase your personal Data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal Data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal Data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal Data. This enables you to ask us to suspend the processing of your personal Data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal Data to you, or to a third party. We will provide to you, or a third party you have chosen, your personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal Data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products, or services, to you. We will advise you if this is the case at the time you withdraw your consent.
Contact us
Questions, comments, requests and complaints regarding this Policy and information we hold are welcome and should be addressed to us by email at info@tinakilly.ie, or in writing to:
Tinakilly Country House Hotel
Rathnew
County Wicklow
A67 EE09
Ireland
All requests will be dealt with promptly and efficiently.