Privacy Policy

Introduction

The Pilgrm respects your privacy and is committed to protecting your personal information. This privacy notice will let you know how we look after your personal information generally as well as when you visit our website and tell you about your privacy rights and how the law protects you.

This privacy notice aims to give you information on how The Pilgrm collects and processes your personal information. It is intended to cover all of your rights and information required under applicable data protection laws including with effect from 25th May 2018 the General Data Protection Regulation (GDPR) and, once in force, the UK Data Protection Bill. We are continually aiming to improve our systems and processes so there may be some updates to this privacy notice from time to time.

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.

Who are we?

The Pilgrm is a trading name of New World Hospitality UK Limited which is the data controller and responsible for your personal information.

New World Hospitality UK Limited is an English company registered with company number 114573 and its registered address at Second Floor, The Quadrant, Manglier Street, P.O. Box 1312 Victoria, Mahé Seychelles.

When we refer to "The Pilgrm" "we", "us" or "our" in this privacy notice we are referring to the above. References to “website” or our “site” are to the sites or site operated by the above hotel and brand.

What personal information do we collect about you?

We collect and process a range of personal information.

We collect certain information from you. This may be via our website (e.g. information that you provide by filling in forms on our website including information provided at the time of registering to use our site, subscribing to our site, posting material on our site or requesting further services), when you enter a competition, when you make a request or query whether by e-mail, via our website or on the telephone. You may provide some of this information directly to us whilst at our hotel.

This type of information is likely to fall into one of the following categories:

• contact details (for example, last name, first name, telephone number, email)
• personal information (for example, date of birth, nationality)
• information relating to your spouse or other family members (for example, first name, date of birth, age) and other members of your party and/or participants at any event
• your credit or debit card number (for transaction and reservation purposes)
• your arrival and departure dates
• your preferences and interests (e.g, in relation to dietary requirements, rooms etc.)
• your views, opinions, questions and comments, during or following a stay in, visit to or event at one of our hotels including via any survey to which may choose to respond or via social media channels (see below for further information about this)
• your transaction history including any discounts to which you may be entitled and rates that you have paid
• details of any membership you may have to our loyalty scheme
• records of your correspondence with us
• details of your visit to our website and the resources you access
• data entered on our website including non-submitted (or abandoned) data
• your image when you visit or stay at our hotel where we frequently operate CCTV for your security and that of our staff and other guests

Some of the above may be provided to us via third party sources (i.e. from someone who is not part of The Pilgrm). For example:

• you may choose to make a reservation via an online booking service (e.g. booking.com) or via an agent and they will need to pass certain information to us so that we can fulfill your request;
• you may post reviews or other content via third party social media platforms and channels such as Twitter, Facebook, Tripadvisor, Instagram etc;
• you may interact with us via social media channels.

We recommend that that you check the privacy notices and statements of any third parties that you provide information to as we are not responsible for the way in which they use, share or make available your personal information.

Sometimes we may collate information you have provided to us via multiple direct interactions with The Pilgrm and/or third party sources and/or the technical data referred to below so that we can use this to try to improve the services and information we provide to you.

We collect contact details from our suppliers in order to enable us to place orders with them, pay them, manage our relationships with them and fulfill our contracts with them.

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 services). In this case, we may have to cancel a service you have requested from us but we will notify you if this is the case at the time.

What technical personal information do we collect about you?

As you interact with our website, we may automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive technical data about you if you visit other websites employing our cookies. Please see our cookie policy below for further details.

Technical data may include:

• 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 our website
• the previous website from you reached us.

Some technical data about you may be collected from third parties including those below:

• analytics providers such as Google based outside the EU;
• advertising networks; and
• search information providers.

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 our websites may become inaccessible or not function properly.

How do we use your information?

The law requires us to ensure we have a lawful basis for processing your personal information. We only use your personal information when we believe it is lawful to do so. This is usually because it is necessary for:

• the performance of a contract that you enter in to with us; and/or
  - For example, once we have accepted a booking from you, we will need some of your personal information to fulfill our obligations with regard to that booking.
• our legitimate interests or those of a third party; and/or
  - For example, The Pilgrm has a legitimate interest in keeping in touch with its guests, customers and others who have shown an interest in our services.
• Where we have collected your contact details in the process of a booking or similar, The Pilgrm is permitted to send you our email marketing messages under the Privacy and Electronic Communications Regulations (PECR) provided you have not said that you do not want us to do this. You will also be told how to say if you prefer not to receive these emails in every subsequent communication from us.
• compliance with a legal obligation.
  - For example, sometimes we may be legally obliged to provide information to law enforcement agencies if we suspect fraudulent or criminal activity.

Sometimes, we may ask you to consent to our collection and use of certain of your personal information for certain purposes. Where this is the case, you can change your mind and withdraw your consent at any time by e-mailing us at dataprotection@thepilgrm.com.

In relation to direct marketing, you can always opt out of receiving this as described below.

Why do we use your details?

We use your personal information for the purposes listed below.

• delivering our services to our guests and customers in relation to any hotel booking, visit or event including processing bookings and payments
• managing activities related to any stay, visit or event at our hotels e.g. use of hotel services, access to rooms, guest conduct
• fulfilling and responding to requests from you or made on your behalf
• tailoring, developing, improving our hotel and related services
• communications with you including:
• marketing and promotional messages
• sending and receiving surveys and analysis of the feedback received
• providing information relating to offers, events and new services, new openings by The Pilgrm etc.
• dealing with competition entries
• reviewing feedback, comments and other posts on restaurant review sites and other social media platforms
• operating our loyalty database and scheme
• for our internal business management and operational purposes
• ensuring content from our website is presented to you in the most effective manner for you and for your computer
• protecting you, our other guests and visitors and our staff from crime
• preventing or detecting unlawful acts.

Who do we share your personal information with?

Some third party service providers are engaged by The Pilgrm to assist in the provision of our services, the operation of our business and the running and maintenance of our systems. For example, when you make a payment to us this is frequently processed via a secure third party payment process provider.

When we use third party service providers, we disclose only the personal information that is necessary to deliver the service. We aim to ensure we have a contract in place that requires them to keep your information secure and not to use it for their own direct marketing purposes. If you would like a full list of the relevant service providers that we use please contact us dataprotection@thepilgrm.com.

If you request certain services at our hotels then again we may sometimes need to share certain of your personal details with anyone we engage to assist us in fulfilling your request.

We may release your information to third parties beyond the above only if we are required to do so by law (e.g. by a court order) or in connection with the prevention of fraud or other crime.

How can you opt out of receiving our marketing messages?

You can ask us to stop sending you marketing messages at any time by:

• following the opt-out or manage your preferences links on any marketing message sent to you
• contacting us at any time at dataprotection@thepilgrm.com.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a booking or other transaction.

How do we protect the personal information you provide to us?

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.

We regularly review 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.

How long will you keep my information?

We will not to keep your personal information in for any longer than is reasonably necessary for achieving the permitted purposes.

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.

By law we have to keep certain basic information about our guests, customers and their transactions with us for certain specified periods of time.

Will you transfer my information overseas?

Personal information may sometimes be transferred outside of the European Economic Area (“EEA”) to other third party service providers and we will take steps to ensure that adequate protection is provided for that data as required under data protection laws.

What happens to your personal information on a change of control of our business?

In the event of a business change in control resulting from, for example, a sale to, or merger with, another entity, we may transfer your personal information to the new party in control.

What rights do I have in relation to my personal information?

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.
• If you wish to make a formal request for information we hold about you or to make changes to the data we hold about you or to opt-out of being contacted for sales or marketing purposes then you can contact us at dataprotection@thepilgrm.com. You may also use these contact details to ask questions or raise concerns about the privacy policy

Our Cookie policy

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. By continuing to browse the site, you are agreeing to our use of cookies.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.

We use the following cookies:

• Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
• Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
• Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
• Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.

Except for essential cookies, all cookies will expire after two years.

Changes to this privacy statement

This privacy policy was last updated in May 2018.

We may change or update this notice from time to time so please check this page occasionally to ensure that you’re happy with any changes. If we make material changes we will endeavour to notify clients and contacts.

How can you contact us and/or complain?

Our full details are:

Full name of legal entity: New World Hospitality UK Limited
Name of data privacy manager: Jason Catifeoglou
Email address: dataprotection@thepilgrm.com
Postal address: The Pilgrm, 25 London Street, London, W2 1HH

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority 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 first.