PRIVACY POLICY
Who we are
We are Aviator Hotel (Farnborough) Limited, an independent hotel for elite travellers moving between London and the world’s leading destinations. We are a company registered in England and Wales under company registration number 05812669, with our registered office at 3 Bunhill Row, London, England, EC1Y 8YZ
We process individually identifiable information about you (“personal data”) when you contact us, supply services, use our services or interact with our website and are the data controller responsible for the processing of the personal data described in this Notice.
How to contact us
If you have any questions about this privacy notice or data protection generally or you want to exercise your rights, please contact us as follows:
Email: privacy@aviatorhampshire.com
Post: 3 Bunhill Row, London, England, EC1Y 8YZ
You can use our “Contact Us” section on our website.
We have appointed IT Governance Europe Limited to act as our EU representative. If you wish to exercise your rights under the EU General Data Protection Regulation (EU GDPR), or have any queries in relation to your rights or general privacy matters, please email our Representative at eurep@itgovernance.eu Please ensure to include our company name in any correspondence you send to our Representative.
Personal information we collect about you
We collect personal data about you when you use our website, hotels and services. Please see below for examples of the personal data we collect from you:
The Personal Data Category | Personal Data Details | How we collect the personal data |
Hotel, Meetings Wedding, Restaurant and Event Booking details
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Identity e.g. name of the guests and participants Address and email address Title and job title Date of birth Date of wedding or other special occasion Gender Payment details Telephone numbers Reservation number Dietary preferences Disability e.g. to provide wheel access Date of arrival and departure or date of event |
Directly from you through our online booking form, call centre Directly from you when you phone or email us From or alternative booking channel From your travel agent or hotel booking websites such as Expedia and Secret Escapes From the restaurant booking system |
Hotel check-in, stay and check-out Hotel details
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Identity e.g. name of the guests and participants Children’s first names Address and email address Title and job title Gender Payment details Telephone numbers Reservation number Dietary preferences Disability e.g. to provide wheel access Date of arrival and departure or date of event Stay details and Bookings (hotel, restaurant, event, theatre, etc.) Payment card type, number and expiration date Consumption habits |
Information you provide directly to us or that we gather from the specific services used during your hotel stay. We might ask you or your child’s name to personalise services such as a cookie with the child’s name or initials. |
Client surveys, online forms, service emails, complaints |
Name of guests Address and email address Title Gender Reservation number Date of arrival and departure Stay details Any other data you may decide to share with us |
Information you provide us when you complete a form, survey, or email or complain to us. |
User and Analytics Data |
IP address Login information, browser type and version Time zone setting, browser plugin types and versions, operating system and platform, traffic data, location data and the resources that you access Pages of our website that you view, Information about your visit including the URL clickstream to, though and from our site. |
When you visit our website or use our application, we may collect user and analytics data. |
Social Media |
Name Email address Feedback, comments, information and content you upload to our social media accounts including Facebook, Instagram and twitter |
When you visit our social media accounts you provide us with your information. Your username and any information you upload including personal data will be visible to other users. We recommend that you secure your anonymity and information so that you do not allow others to identify you. |
Candidate Data |
Name and contact details (ie address, home and mobile phone numbers, email address) Details of your qualifications, experience, employment history salary and interests; Details of your referees. Your curriculum vitae Nationality and immigration status passport and other identification and immigration information including copies of right to work documentation |
Personal data that you provide to us when you apply for a vacancy with us, or when you register your interest in a position with us, or if you send a speculative job application to us. |
Information received from third parties |
Personal information including identification and contact details. Time zone setting, browser plugin types and versions, operating system and platform, traffic data, location data and the resources that you access. Pages of our website that you view, Information about your visit including the URL clickstream to, though and from our site. |
We may collect or receive information about individuals from service providers, and other third parties, such as our advertising companies’ customers, professional advisers, content providers, government authorities and public sources and records. We may receive information information we such as Google booking sites/agents |
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.
Why Do We Collect This Information?
We collect and process personal information about you to enable us to administer our website, applications, products, and services and to provide you with other related services and manage our relationship with you. Under Data Protection Law, we can only use your personal information if we have a proper reason for doing so.
Use of your Personal Data | Processing your data | Lawful basis of processing |
To set up Customers’ accounts. Provide services to them and process their related billing information |
Providing services to you, administering your account, and taking payment. For e.g.: Registering your arrival and departure at the hotel, event, meeting or restaurant. Assigning you a key card to your room or allowing you to use your mobile device as a room key. Managing payment and obtaining a credit card guarantee or deposit to ensure payment. Creating or updating your profile in our management system. Assessing your eligibility for upgrades and managing this if applicable. Paying a commission e.g. To your travel agent or wedding planner. Cancelling your stay and any other reservation you may have made. Returning lost or forgotten items to you. Managing your and your guests’ preferences, such as dietary requirements and pillow preferences Managing guest special requirements e.g. Food allergy, wheelchair access, |
Contract Performance – We use your personal data on the basis that it is necessary for us to provide our services and products to you. Accordingly, if you are unable to provide such personal data this may make it difficult or prevent us from providing our services and products to you. We will use your Explicit consent when managing health data about you when providing our services. |
To support, improve and troubleshoot our Services and to respond to queries obtain Users’ feedback with regard to the Services |
Ensuring our Services are continually improving. and are tailored to you, our Customers. Should you have a particular query, feedback or complaint, including the exercise of one of your rights under the GDPR or UK Data Protection Act 2018, you may contact us through email or the contact forms available on our website. In such context, we may process your Personal Data for the purposes of handling and providing an answer to your query or request or to follow up on your feedback |
Contract Performance – We use your personal data on the basis that it is necessary for us to provide our services and products to you. You may unsubscribe from our guest satisfaction survey emails at any time by clicking on the unsubscribe link in the emails sent to you.
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Security |
To protect our websites and infrastructure from cyber-attack or other threats and to report and deal with any illegal acts. |
Legitimate Interests – Wherever we process your personal data for these purposes, we ensure that your interests, rights, and freedoms are carefully considered. |
Risk Management |
Managing risks, obtaining professional advice and managing legal disputes. |
Legitimate Interests – Wherever we process your personal data for these purposes, we ensure that your interests, rights, and freedoms are carefully considered. |
Legal Compliance |
In order to prevent and detect fraudulent or criminal activity we may share information with forces such as the Police. This is done in a safe and secure manner. You may not be notified of this. For accounting and taxation purposes. |
Legal obligation – We may use your personal data in order to comply with law. |
To communicate with you about any issue that you raise with us or which follows from an interaction between us. |
So, your rights can be exercised, and complaints managed. If you are booking online but for some reason are not able to finalise the booking process, we process your personal data for the purpose of enabling you to easily continue the online booking process by sending you an email with a link to the online booking form, which is pre-filled on the basis of the data you had already provided in the form. |
Legitimate Interests – Wherever we process your personal data for these purposes, we ensure that your interests, rights, and freedoms are carefully considered. |
Marketing our Products and Services generally |
To communicate with you as a potential client and to keep you informed of our services and send you third party direct marketing communications to you via email, letters or phone calls. When we collect and use sensitive information about you. |
Consent – sometimes we may have to get your consent to use your personal data. Where we process your personal data on this basis you have the right to withdraw consent at any time. If you are signed up to our mailing list, you will have the option to unsubscribe at the bottom of any marketing email you receive from us. Alternatively, you may contact us via privacy@aviatorhampshire.com and we will remove you from all relevant databases. |
Marketing our Products, Services, and any improvements to you. |
To communicate with you and to keep you informed of our latest updates and newsletters in an identified area of interest. |
Legitimate Interests – Wherever we process your personal data for these purposes, we ensure that your interests, rights, and freedoms are carefully considered. |
Ensuring the proper use of our Products and Services. |
To investigate violations and enforce our policies, and as required by law, regulation, or other governmental authority, or to comply with legal processes or respond to government requests |
Legitimate interests – Wherever we process your personal data for these purposes, we ensure that your interests, rights, and freedoms are carefully considered.
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Job Application |
To process the personal data that you provide to us when you apply for a vacancy, when you register your interest in a position with us, or if you send a speculative job application to us job employment. |
Legitimate Interests- Wherever we process your personal data for these purposes, we ensure that your interests, rights, and freedoms are carefully considered. Consent – where we collect special category data during this process. |
Do you use my personal data for Marketing?
We may use your information to provide you with details about our services, and services from our partners and other relevant third parties. We may send you marketing messages by email or through social media.
You can change your mind on how you receive marketing messages or choose to stop receiving them at any time and you can manage your contact preferences.
If you ask us not to send you marketing, it may take us a short period of time to update our systems and records to reflect your request, during which time you may continue to receive marketing messages.
If you have opted out from our marketing communications, it is possible that your details may be recaptured through public sources in an unconnected marketing campaign. We will try to make sure this does not happen, but if it does, we are sorry, and we would ask that you opt out again.
Please note that, even if you choose not to receive this information, we may still use your personal information to provide you with important services communications, including communications in relation to any applications or services you use.
Do you share my personal data with others?
We do not rent or sell any of your Personal Data. However, we may share your personal data with our subsidiaries and other affiliated companies as well as to other trusted third-party service providers or partners for the purposes listed below:
Sharing your Personal Data | Purpose of the Sharing |
Assisting us with our business operations |
We may share personal data to be able to provide our products and services to you, to help administering your account, and for taking payment. |
Manage and Support the Technology We Provide |
We may share personal data with third parties for the further processing and analysing of user data, or for research and analytics that will enable us to improve our services. |
Risk Management |
We may disclose your Personal Data to our professional advisers insofar as reasonably necessary. |
To comply with our legal obligations |
We may disclose your Personal Data to appropriate third parties where we have a good faith belief that disclosure of such information is helpful or reasonably necessary to: (i) comply with any applicable law, regulation, legal process or governmental request; (ii) enforce our policies (including our agreements), including investigations of potential violations of such policies and agreements; (iii) investigate, detect, prevent, or take action regarding illegal activities or other wrongdoing, suspected fraud or security issues; (iv) establish or exercise our rights to defend against legal claims; (v) prevent harm to the rights, property or safety of us, our users, yourself or any third party; or (vi) for the purpose of collaborating with law enforcement agencies or in case we find it necessary in order to enforce intellectual property or other legal rights. |
For the purposes of fraud/crime protection and investigation |
We may share information with organisations, Financial institutions, Payment card companies, credit agencies. |
Analytics Service Providers |
We may share information with third-party service providers to assist us with client insight analytics, such as Google Analytics |
Business transfers |
We may share information as part of any merger, sale and transfer of our assets, acquisition or restructuring of all or part of our business, bankruptcy, or similar event, including related to due diligence conducted prior to such event where permitted by law. |
Where we share your personal data with any third party, we will ensure this processing is protected by appropriate safeguards including a suitable data processing agreement with that third party and we require all third parties to respect the security of your personal data and to treat it in accordance with the law.
If we wish to pass your sensitive data onto a third party we will only do so once we have obtained your express consent, unless we are legally required to do otherwise.
Can I withdraw my consent to let you process my personal data?
We may ask for your agreement to process your information for specific purposes and you have the right to withdraw your consent at any time. Please contact us to withdraw your consent by emailing privacy@aviatorhampshire.com
Do you share my personal data overseas?
Your information may be transferred to and stored in locations outside the European Economic Area (EEA), including countries that may not have the same level of protection for personal information.
When we do this, we’ll ensure it has an appropriate level of protection and that the transfer is lawful. We may need to transfer your information in this way to carry out our contract with you, to fulfil a legal obligation, to protect the public interest and/or for our legitimate interests. You can obtain more details of the protection given to your information when it’s transferred outside the EEA by contacting us via email privacy@aviatorhampshire.com
What privacy rights do I have?
You have several rights under Data Protection Law, the rights available to you depend on our reason for processing your information and include:
Your Rights | |
Your right to be informed
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We have a legal obligation to provide you with concise, transparent, intelligible, and easily accessible information about your personal information and our use of it. We have written this notice to do just that, but if you have any questions or require more specific information, you can contact us by emailing privacy@aviatorhampshire.com |
Your right to access your data |
You have the right to ask us to confirm whether we process your personal data and, to have access to the personal data, and any additional information. that additional information includes the purposes for which we process your data, the categories of personal data we hold and the recipients of that Personal Data. You may request a copy of your personal data by emailing privacy@aviatorhampshire.com |
Your right to rectification |
You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete. This right always applies. |
Your right to erasure |
Where no overriding legal basis or legitimate reason continues to exist for processing personal data, you may request that we delete the personal data. This includes personal data that may have been unlawfully processed. We will take all reasonable steps to ensure erasure. |
Your right to restrict processing
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You may ask us to stop processing your personal data. We will still hold the data but will not process it any further. This right is an alternative to the right to erasure. If one of the following conditions applies you may exercise the right to restrict processing: -The accuracy of the personal data is contested. -Processing of the personal data is unlawful. -We no longer need the personal data for processing, but the personal data is required for part of a legal process. -The right to object has been exercised and processing is restricted pending a decision on the status of the processing. |
Your right to object to processing |
You may ask us to stop processing your personal data. We will still hold the data but will not process it any further. This right is an alternative to the right to erasure. |
Your right to data portability. |
You have a legal right to receive a copy of the personal data we hold about you in a structured, commonly used and machine-readable format. the right only applies if we are processing information based on your consent or for the performance of a contract and the processing is automated. |
For more information about your rights contact us or see privacy@aviatorhampshire.com first and title your complaint “Complaint”. All complaints will be treated in a confidential manner and we will try our best to deal with your concerns.
You have the right to lodge a complaint with a supervisory authority, in particular in the UK or EEA member state where you work or normally live, or where any alleged infringement of data protection law occurred. The supervisory authorities are listed here EDPB members
The supervisory authority in the UK is the Information Commissioner’s Office, which may be contacted at https://ico.org.uk/concerns or by telephone on 0303 123 1113.
How long do you keep my personal information?
We will keep your personal data in line with our data retention schedule for no longer than is 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 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.
How do you keep my data safe?
We take great care in implementing and maintaining the security of our services, and your information. We employ industry standard procedures to ensure the confidentiality, integrity, and availability and safety of your personal data, and to prevent unauthorised use of any such information.
We use a range of measures to keep your information safe and secure including, encryption, and other forms of security. We require our staff and any third parties who carry out any work on our behalf to comply with appropriate compliance standards including obligations to protect any information and applying appropriate measures for the use and transfer of information.
We have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
We do not, however, have any control over what happens between your device and the boundary of our information infrastructure. You should be aware of the many information security risks that exist and take appropriate steps to safeguard your own information.
If you feel that your privacy is not being treated in accordance with this Privacy Notice, please contact us directly at privacy@aviatorhampshire.com
Social media
Our website includes social media links, that link to our presence on that specific site (e.g., our page on Twitter). These features may collect your IP address and information on which page you are visiting on our site and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by another company or are hosted directly on our site. Your interactions with these features are governed by the privacy policy of the company providing it.
Links to other websites
Where we provide links to websites of other organisations, this Privacy Notice does not cover how that organisation processes personal information. We do not control such third-party websites and are not responsible for their content or privacy statements. We would encourage you to read the privacy notice or policy of every website you visit.
Do you use Cookies?
We collect certain information automatically and store it in log files. We sometimes collect information about our visitor’s behaviour during their visits to our websites to help us provide better customer service, to improve the quality of our website experiences or to tailor advertising. For more information on which cookies we use and how we use them, please see our Cookie Notice.
Do you use personal information about Children?
We do not knowingly collect or solicit personal information from anyone under the age of 16 without verifiable parent or guardian consent. In the event we learn that we collected personal information from anyone under the age of 16, and do not have a parent or guardian’s consent, we will delete that information as quickly as possible.
Changes to this document
We keep this document under regular review to make sure it is up to date and accurate. We encourage you to review this page regularly to identify any updates or changes to our Privacy Notice.
What if I need extra help?
If you would like this website privacy notice in another format (for example: audio, large print, braille) please contact us.