Introduction

The Celtic Manor Resort Limited (“the Resort”) respects your privacy and is committed to protecting your personal data. We comply with all aspects of the UK General Data Protection Regulation and the Data Protection Act 2018 (collectively referred to in this privacy notice as ‘Data Protection Legislation’).

For the avoidance of doubt, this privacy notice applies to all of the Resort’s hotels and lodges that form part of The Celtic Collection (collectively referred to in this notice as “us”, “we” or “our”) including but not limited to:

• The Celtic Manor Resort Hotel;
• Coldra Court Hotel;
• Hunter Lodges;
• Newbridge on Usk;
• The Manor House Hotel;
• Tŷ Hotels;
• The Parkgate Hotel; and
• St Brides Spa Hotel.

In the course of running our business, we gather and use personal information about guests who stay with us, people who visit us and use our facilities or dine with us, members of our golf and health clubs, people who attend events that we host and people who are interested in finding out more information about us, whether in a personal or professional capacity.

We have developed this privacy notice in order to be as transparent as possible about the personal information we collect and use.

We ask that you read this privacy notice carefully as it contains important information about:

• the personal information that we collect and use;
• the lawful bases we rely on to collect and use it;
• why we collect and use personal information;
• where we get the personal information from;
• with whom we share personal information;
• when we transfer personal information outside the UK;
• how long we keep information and how we ensure it is secure; and
• your privacy rights.

It is important that you read this privacy notice together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data and what your rights are under Data Protection Legislation. This privacy notice supplements the other notices and is not intended to override them.

This privacy notice does not apply to our current or former employees, or to people who apply to work for us.

Data Controller

The Celtic Manor Resort Limited is the controller and responsible for your personal data. We are not required to appoint a Data Protection Officer under Data Protection Legislation. However, any queries or concerns relating to personal data should instead be directed online here.

Categories of Personal Information that we hold

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).

The personal information that we collect, store and use about you includes:

• identity data such as your name, username or similar identifier, marital status, title, date of birth and gender;
• contact data including your billing address, home address, employer’s address, email addresses and telephone numbers;
• professional information such as details of your employer and job title;
• family information such as details of members of your family that have enjoyed using our services with you and dates of special occasions that you have chosen to celebrate with us;
• financial data including bank account and payment card details;
• transaction data including details about payments to and from you and details of other products and services you have purchased from us;
• profile data such as the services you have used and enjoyed, your interests, preferences (such as your room preference), records of any complaints or requests that you make to us either during or after your stay; feedback and survey responses;
• vehicle information such as the vehicle’s registration number (number plate);
• usage data such as information about how you use our website, products and services;
• images or footage captured by CCTV located in and around our properties and other information obtained through electronic means such as swipe card records; and
• technical data such as internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website; and marketing data including your preferences in receiving marketing from us and your communication preferences.

We may also collect, store and use the following more sensitive types of personal information:

• information about your health including details of any accidents you may have had or health information relevant to your access needs;
• health and safety related information such as your dietary requirements;
• information about your trade union membership, religious, philosophical or political views or information about your sexuality as a result of your attendance at certain events at any part of the Celtic Collection or International Convention Centre Wales Limited (“ICC Wales”); and
• when using our health clubs and spa facilities, we may also ask you to advise us of any medical or health conditions from which you suffer where these are relevant to the activities you plan to participate in during your stay.

We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data but is not considered personal data under Data Protection Legislation as this data will 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.

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.

Sources of Personal Data

We collect information about you in the following ways:

• Directly when you stay with us or use our services, correspond with us by post, phone, email, via social media or otherwise (including prior to your stay with us or use of our services), create an account on our website, subscribe to our newsletters, enter a competition, or complete a survey or give us some feedback.
• When you send requests and messages via our customer text messaging system and mobile application.
• Directly from cameras (CCTV) located in and around our properties and swipe / key cards;
• When we acquire your details via a third party such as when you attend an event within the Celtic Collection, or you book using an agency.
• When you register to use our Wi-Fi service, you will have an option to provide us with your details. We may also collect information when you register for the Wi-Fi service at ICC Wales and agree to receiving news and offers from us.
• When you use our website, we collect your personal information using “cookies” and other tracking methods. There are more details on the cookies and tracking methods we use in our Cookie Policy, please see www.stbridesspahotel.com/home/cookie-policy.
• Depending on your settings or the privacy policies for social media and messaging services like Facebook, WhatsApp or Twitter, you might give us permission to access information from these services, for example when you publicly tag us in an event photo.
• We also generate person information about you when we record your engagement with us and we may supplement information about you with information from publicly available sources.

The lawful basis for processing personal information

We will only use your personal data when the law allows us to. Most commonly, we rely on the following legal bases to process your personal information:

Certain types of personal information are in a special category under Data Protection Legislation, as they are considered to be more sensitive. Examples of this type of data include information about health, race, religious beliefs, political views, trade union membership, sex life or sexuality and genetic/biometric information.

When we use special category personal information we require an additional legal basis to do so under Data Protection Legislation, so will either do so on the basis of your explicit consent or another route available to us by law, such as for example if you have made the information manifestly public or we need to process it for health and safety purposes or to ensure we can accommodate your access needs. We only collect this type of information about you where there is a clear reason for us to do so. Please see the ‘Categories of Personal Information that we hold’ section above for details about the types of special category data that we may collect from you.

Why do we collect and use personal information?

We collect and use personal information for the following purposes, relying on the specific lawful bases set out in the table below. We have also identified what our legitimate interests are where appropriate:

If you fail to provide personal data

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 (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

Marketing and Promotional Offers

We may use your personal information to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and promotional offers may be relevant for you.

You will receive marketing communications from us if you have requested information from us or purchased services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

You can ask us to stop sending you marketing messages at any time or adjust your marketing preferences by following the opt-out links on any marketing message sent to you or at any time.

We do not sell, rent or otherwise make personal information commercially available to any third party for marketing purposes.

Registering for Wi-Fi

We may collect your personal data when you register for complimentary Wi-Fi and data collected in this way may be used in the way described under the “Marketing and Promotional Offers” above. This may include some forms of electronic marketing. We will only use personal data collected in this way for marketing purposes if you are over the age of 13 and have agreed to this in the course of the Wi-Fi registration process. This is not compulsory and you can still get temporary access to our free Wi-Fi without agreeing to receive news and offers.

You can withdraw your agreement at any time and can adjust your marketing preferences or ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you.

We do not sell, rent or otherwise make personal information commercially available to any unconnected third party for marketing purposes. However, subject to you giving express consent, we may use a third-party provider (currently Wi-Fi SPARK Ltd) to collect your personal data during the course of Wi-Fi Registration. Such personal data is limited to your email address(es) and is collected for the limited purposes of sending you marketing communications as referred to above and the provision to you of guest access to entertainment services. If you agree to receiving news about ICC Wales we may also share your personal data with them but only for the purpose of them sending you information about ICC Wales.

Cookies

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 this website may become inaccessible or not function properly. For more information about the cookies we use, please see www.stbridesspahotel.com/home/cookie-policy.

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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

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.

Sharing your personal data

We use a number of third-party providers to help us run our businesses. Such suppliers may have access to your personal information, or we may share or send it to them for the purposes set out in the table above. This includes IT and system administration services, professional advisers including lawyers, bankers, auditors and insurers and regulators and other authorities.

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 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.

International transfers

Some of our third parties with whom we share your personal data are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK. Further information about such third parties and their location is available on request.

Whenever we transfer your personal data outside of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
• Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK. Requests for additional information should be directed as set out above under the heading Data Controller.

How long do we keep personal information?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect of our relationship with you.

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, regulatory, tax, accounting or other requirements.

Our key retention periods are as follows:

• We keep guest records for 7 years, although registration cards and details of your nationality are only kept for 12 months.
• If you have any accident whilst on our premises, we will keep any details of the accident for four years, unless the accident involves a child, in which case the records will be kept until the child’s 22nd birthday.
• As long as your email address remains in use, we will keep your contact and preferences of marketing communications indefinitely. As noted below, you have the right to opt-out of receiving marketing communications from us at any time.
• Additional data that we collect about you using our marketing tools, such as monitoring your level of engagement with the emails we send to you, is kept for two years.

At the expiry of the relevant retention period, your personal data is deleted or destroyed securely.

For further information about our retention periods in respect of specific data please send any requests as directed above under the heading Data Controller.

Security

We are strongly committed to information security and we take reasonable and appropriate steps to protect your personal information from unauthorised access, loss, misuse, alteration or corruption. 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 physical, electronic, and managerial procedures to safeguard and secure the information you provide to us including the use of encryption and pseudonymisation. We also have 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.

Individual Rights

You have a number of rights in relation to your personal data which we have. Not all of the rights apply in all circumstances. If you wish to exercise any of the rights, please contact us in the ways detailed below:

• You have a right of access to the personal information we hold about you (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.
• You have the right to ask us to correct any information 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.
• You have the right to object to any processing of your personal information where we are relying on a legitimate interest (or that of a third party) to do so and you think that your rights and interests outweigh our own and you wish us to stop. There may, however, be legal or other legitimate reasons why we need to keep or use your information. If this is the case, we will consider your request and explain why we cannot comply with it. You can ask us to restrict the use of your personal information while we are considering your request.
• You have the right to object if we process your personal data for the purposes of direct marketing. If you no longer want to receive communications from us, please contact us. We will stop sending you communications but will continue to keep a record of you and your request not to hear from us. If we deleted all of your information from our direct marketing databases, we would have no record of the fact that you have asked us not to communicate with you and it is possible that you may start receiving communications from us at some point in the future, if we obtain your details from a different source.
• You have the right to ask us to delete your information where there is no good reason for us continuing to process it. This is also known as the right to be forgotten or to erasure. We will not always agree to do this in every case as there may be legal or other legitimate reasons why we need to keep or use your information. If this is the case, we will consider your request and explain why we cannot comply with it. You can ask us to restrict the use of your personal information while we are considering your request.
• Where our processing of your personal information is based on your consent, you have the right to withdraw it at any time. Please contact us if you wish to do so. 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.
• You have the right to 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:
  • 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.
  • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• You may have a right to obtain the personal information that you have given us in a format that be easily re-used and to ask us to pass this personal information on in the same format to other organisations. Please contact us to find out if this right applies to you.

No fee usually required

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.

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 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.

How to Complain

Please let us know if you are unhappy with how we have used your personal information. You can contact us online here.

You also have the right to complain to the Information Commissioner’s Office. Find out on their website how to report a concern https://ico.org.uk/

Changes to this Privacy Notice

This privacy notice was last updated on 15 September 2021. We keep this privacy notice under regular review and may change it from time to time by updating this page in order to reflect changes in the law and/or our privacy practices. We would encourage you to check this privacy notice for any changes on a regular basis.