Privacy Policy

Rose Application

Last modified 1st July 2024

This privacy policy gives you information about how Rose Hospitality Limited (“RH”) collects and uses the personal data which we collect through the use of our Rose Application which includes our Rose Questions platform used by hospitality venues to help them make your visit more comfortable, and ideally exceptional. 

Please note that we do not use cookies to gather any personal information in our preference engine and Rose Questions services. We only utilise cookies solely for essential website site functionality when cookies are strictly necessary for the proper functioning of the website eg keeping state in a sequential process, like a booking engine. See our Website Privacy Policy (which is different to this Rose Application Privacy Policy) for website details.

 

Controller

Rose Hospitality Limited (collectively referred to as “Rose Hospitality”, “we”, “us” or “our” in this privacy policy) is the controller and is responsible for the personal data submitted to Rose Hospitality via the questions platform which is saved at your request, for re-use by you.

Our aim is to help you manage and curate your personal data, to help:
•    Auto-fill answers to questions you have already answered before - to help reduce the friction and time taken by you to inform each venue of your regular personal preferences. 
•    Give you a tool to help you update your preferences centrally – to help you ensure the accuracy of your preferences, as your circumstances change.
•    Let you know each date and name of hospitality venue to which your personal data was processed by RH.
•    Assist you in making your preferences known ahead of your next visit to any hospitality venue you choose, by giving you a Letter Of Introduction to send any venue for which you have your own forward booking details to hand.

Note that Rose Hospitality is collecting your answers to questions asked by each venue via questionnaires. We can help you save, manage and conveniently share your preferences easily with the next hospitality venue you are booked to visit. 

To avoid repetitive answering of preference questions across multiple occasions, Rose Hospitality will store your answers and auto-fill your preferences for future hospitality visits, as a service to you. 

If you have any questions about this privacy policy, including any requests to exercise your legal rights (Section 9), please contact us using the information set out in the contact details Section (Section 10).

 

1    The types of personal data we collect about you

Personal data means any information about an individual from which that person can be identified.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
a)    Identity Data may include one or more of first name, last name, any previous names, marital status, title, date of birth and gender.
b)    Contact Data may include one or more of billing address, delivery address, email address and telephone numbers.
c)    Transaction Data may include one or more details about payments to and from you and other details of products and services you have purchased from hospitality venues.
d)    Technical Data includes your login data.
e)    Profile Data includes your purchases or orders made by you, your interests, preferences (including allergy and accessibility requirements), complaints and queries.
f)    Usage Data includes information about how you interact with and use our services.
We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals’ Usage Data to analyse general trends in how users are interacting with our services to help improve our service offering.

 

2    How is your personal data collected?

We use different methods to collect data from and about you including through:
· Your interactions with us. You may give us your personal data by saving your answers to one or more sets of questions and other information submitted by you to us and agreeing that we may use it when you log-in and/or use your account. 

 

3    How we use your personal data

We have set out below, in a table format, a description of all the ways we plan to use the various categories of your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. 

Where we process special category data in relation to you (which may include one or more details about your race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data) we will only do so where we have your consent. In some cases, where your information is provided on your behalf by someone else, we will ask for confirmation from them that you have provided your consent.  

 

4    Disclosures of your personal data

We may share your personal data where necessary with the parties set out below for the purposes set out in the table above.
·    Hospitality providers (where your data is used to pre-fill hospitality questionnaires).
·    Service providers who provide services to us in: IT/software, media and analytics and system administration.
·    Our professional advisers including lawyers and insurers.
·    HM Revenue & Customs, regulators and government and other public authorities who require reporting of processing activities in certain circumstances under applicable law or regulation.
·    Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy. We will notify you of any material change in our business circumstances to keep you informed of this matter.

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 and only permit them to process your personal data for specified purposes and in accordance with our instructions.

 

5    International transfers

We may transfer your personal data to service providers that carry out certain functions on our behalf. This may involve transferring personal data outside the UK to countries which have laws that do not provide the same level of data protection as the UK law. We will notify you of any country in which we know our data storage systems and web services are being physically sited, as well as the countries in which hospitality venues have asked questions from you using the Rose Hospitality questions platform.

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring that the following safeguards are in place:
·    The country to which we are sending your personal data to has been deemed by the UK to provide an essentially equivalent level of protection for your personal data to the protection it would receive in the UK. At the time of this privacy notice being issued the countries deemed adequate are the countries who are members of the EU, Iceland, Norway, Liechtenstein, Gibraltar, the Republic of Korea, Andorra, Argentina, Faroe Islands, Guernsey, Isle of Man, Israel, Jersey, New Zealand, Switzerland, Uruguay plus Canada, Japan and the USA (for certain transfers).
·    We have implemented standard contractual terms with the receiving organisation, approved under UK law, which impose obligations on the receiving organisation and give you rights in respect of your data. We will also undertake a risk assessment to ensure that these clauses enable ‘essentially equivalent’ protection to the protections applied to your data in the UK. 

To obtain a copy of these contractual safeguards, please contact us on the Contact details (Section 10). 

 

6    Data security

We have put in place appropriate security measures to 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.

 

7    Data retention

We will keep your data as follows :
1.    Answers to questions and Technical Data will be kept for 12 months from the last time the pre-fill functionality was used. At that point it will be stored for a further 7 years (to deal with complaints and claims). After that it will be deleted or anonymised.
2.    Usage Data is kept for 12 months, at which point it will be anonymised. 
Complaints and queries will be kept for 7 years from the date the complaint or query is made to deal with any claims or questions which may arise regarding the complaint or query. After this they will be deleted. In some circumstances you can ask us to delete your data: see Section 9 below for further information.

In some circumstances we will 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.

 

8    Anonymisation

We will anonymise your data, as noted in section 7. 
An anonymisation process starts with the deletion of all special category data prior to anonymising other personal data which is performed by removing key identifiers such as your name, email address and phone number, so that the information can no longer be linked to you.

We regularly review our anonymisation process to ensure that you cannot be re-identified from the information we have anonymised. As we do not anonymise special category data and we remove any identifiers from the rest of your data, the risks of anonymising your data is low.

Once anonymised, anonymised information is not personal data and so you no longer have any rights in respect of this information, as it cannot be linked back to you.

We use anonymised information for analytics and statistical purposes. We will never make it public. 

 

9    Your legal rights

You have a number of rights under data protection law in relation to your personal data.
You have the right to:
·    Request access to your personal data (commonly known as a “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 in certain circumstances. 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) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
·    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 provided to us and which you provided consent for us to use or which we process on the basis of a contract we have with you.
·    Withdraw consent at any time where we are relying on consent to process your personal data (see the table in Section 3 for details of when we rely on your consent as the legal basis for using your 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.
·    Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:
•    If you want us to establish the data’s accuracy;
•    Where our use of the data is unlawful but you do not want us to erase it;
•    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
•    You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

If you wish to exercise any of the rights set out above, see Contact details (Section 10) below.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

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.

We try to respond to all legitimate requests within one month. Occasionally it could 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.

 

10    Contact details

If you have any questions about this privacy policy or about the use of your personal data or you want to exercise your privacy rights, please contact us in the following ways:
·    privacy@rose-hospitality.com
·    Postal address: Rose Hospitality Limited, Random Stones, Bassenthwaite, Cumbria, CA12 4RG, UK

 

11    Complaints

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

 

12    Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review.