Privacy Policy

Welcome to the St Giles Hotels’ privacy policy which applies to our group.

St Giles Hotel group is made up of different legal entities and hotels, details of which can be found on our website. This privacy policy is issued on behalf of the St Giles Group so when we mention "St Giles", "we", "us" or "our" in this privacy policy, we are referring to the relevant company in the St Giles Group responsible for processing your data, including St Giles Hotel Limited in the UK. We will endeavour to let you know which entity will be the controller for your data when you purchase a guest stay or guest experience with us.

St Giles respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website StGilesHotels.com (regardless of where you visit it from) and our mobile app, St Giles App, and tell you about your privacy rights and how the law protects you. Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.

1. IMPORTANT INFORMATION AND WHO WE ARE

2. THE DATA WE COLLECT ABOUT YOU

3. HOW IS YOUR PERSONAL DATA COLLECTED?

4. HOW WE USE YOUR PERSONAL DATA

5. DISCLOSURES OF YOUR PERSONAL DATA

6. INTERNATIONAL TRANSFERS

7. DATA SECURITY

8. DATA RETENTION

9. YOUR LEGAL RIGHTS

10. GLOSSARY

Important information and who we are

Purpose of this privacy policy

This privacy policy aims to give you information on how St Giles collects and processes your personal data through your use of this website and the St Giles App, including any data you may provide through this website and our app, or any third-party person or platform, when you purchase a guest stay or guest experience, engage with us online or you visit any of our hotels for any reason.

This website and the St Giles App are not intended for children and we do not knowingly collect data relating to children unless you choose to provide information relating to your children such as age data when booking (although this is not a requirement to use our services) and their dietary requirements or allergen information when making a food related booking, and our processing of such data will be in accordance with this policy. As we have CCTV systems at our premises in order to protect the interests and security of our customers, staff and other visitors, data relating to children might be captured on those systems and so we set out in more detail below how and why we collect data using CCTV. For your reassurance, our CCTV footage is generally only monitored/reviewed when there has been an incident.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy 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. This privacy policy supplements other notices and privacy policies and is not intended to override them.

Controller and contact details

For personal data processed in respect of our UK operations, St Giles Hotel Limited is the controller. We have appointed a data protection team which is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact our team at GDPRenquiries@stgiles.com or at The GDPR Team, St Giles Hotel Limited, Bedford Avenue, WC1B 3GH.

For data protection queries in respect of our Malaysian operations, please use the following contact details:

Email: admin@chm-hotels.com & Tel No: 603 2081 1188.
Mailing Address: Privacy Team, Cititel Hotel Management Sdn Bhd, Unit A-8-1 & 2, Northpoint Offices, Mid Valley City. No 1, Medan Syed Putra Utara, 59200, Kuala Lumpur, Malaysia

For data protection queries in respect of our Australian operations, please use the following contact details:

Email: gm@tankstreamhotel.com
Mailing Address: St Giles Tank Stream, Sydney, Privacy Team, 97 Pitt Street Sydney NSW 2000

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.

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

We keep our privacy policy under regular review. This version was last updated on 26 May 2022.

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.

Third-party links

This website (and our app) may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

The data we collect about you

In conducting all aspects of our business and interaction with you, our guests, we collect Personal Data in accordance with the law, and in our effort to always deliver outstanding service, products, and experiences to you at our hotels.

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 different kinds of personal data about you which we have grouped together as follows:

Identity Data includes first name, last name, username or similar identifier, marital status, title, date of birth, gender, nationality, passport details, and any other data contained on a form of government-issued identification, such as a driving licence, and details about your vehicle and image data on identification and captured by CCTV.
Contact Data includes billing address, email address and telephone numbers and social media handles.
Financial Data includes bank account and payment card or similar details.
Transaction Data includes details about payments to and from you and other details of guest stays and guest experiences you have purchased from us, including information about your stay, including room number, dates of your stay and services, facilities and amenities used during your stay (such as shuttle buses, concierge, chauffeur, taxis, room service, dry cleaning etc) and tour group and trip activity data.
Technical Data includes 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 or our app.
Profile Data includes your username and password, your interests, preferences/dietary and health requirements and related information, feedback and survey responses, your company or employer details (for corporate travel related reservations and membership programme), your social media handles, any customer number or hotel club account numbers assigned to you and special dates such as birthdays, anniversaries, and other celebratory life moments.
Usage Data includes information about how you use our website, app, guest stays and experiences and services.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We may also from time to time 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 in law 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 or app 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 policy.

We do not collect any Special Categories of Personal Data about you that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, and genetic and biometric data, with exception of any applicable health related data (for example allergens and dietary requirements or any disability related requirements (for example in order to access and use our facilities)) which you may decide is relevant to provide us during the booking process or in comments posted on our site or via our social media feeds or covid-19 or other public health related information which we may require where the processing is necessary for reasons of public interest in the area of public health or where we process health data in relation to sickness, injuries and emergencies at our premises for protecting the vital health of data subjects, or for public health or legal claim reasons. We do not collect any information about criminal convictions and offences about users to this site or our customers (save in the highly unlikely event it relates to a matter with which we are involved directly).

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 guest stays or guest experiences). In this case, you may not be able to book with us or we may have to cancel your reservation but we will notify you if this is the case at the time.

How is your personal data collected?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity, Contact, Financial and Profile Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
book or purchase guest stays or guest experiences or sign in at or use any of our premises, facilities or amenities (including hotels, shops, restaurants, gyms and conference and event facilities);
- create an account on our website or app;
- request our marketing/newsletter to be sent to you;
- enter a competition, promotion or survey;
- engage with us via social media; or
- give us feedback or contact us using any medium (including phone, email or online chat services).
Automated technologies or interactions. As you interact with our website and app and our WIFI network on our premises, we will automatically collect Technical Data about your device, browsing actions and patterns. We collect this 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 for further details.
Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources (where relevant) as set out below:

Identity, Contact, Financial, Profile, Transaction and Marketing and Communications Data by third party promotional partners, travel agencies (online and offline), tour operators, group tours, travel planners, wholesalers, joint marketing partners and online third-party platforms you use to find and book/purchase guest stays and experiences from us.

Technical Data potentially from the following parties from time to time:

analytics providers such as Google;
affiliate service providers; and

Contact, Financial and Transaction Data from providers of technical, payment and delivery services.

Identity and Contact Data from potentially publicly available sources such as Companies House from time to time.

We collect data in respect of your image and activities at our premises via our CCTV system.

If you submit any Personal Data about other people to us (e.g., if you make a reservation for another individual), you must only do so where you have the other data subject’s authority to do so. We will use the data in accordance with this privacy notice.

How we use your personal data

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 obligation.

Please see the glossary below to find out more about the types of lawful basis that we will rely on to process your personal data.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use 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.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

To register you as a new customer of our guest stays and experiences/book you into our hotels and other services, facilities and amenities (including hotels, shops, restaurants, gyms and conference and event facilities)

(a) Identity

(b) Contact

Performance of a contract with you and where special category data (such as health/disability related data) you will have provided that with your explicit consent or if it is covid-19 related or similar data then we will process that only where we need to for reasons of public interest in the area of public health

To process and deliver your guest stay or experience including:

(a) Manage our service to you online and at our premises and to ensure that our service conforms to your order, and manage payments, fees and charges and manage emergencies or incidents at our premises

(b) Collect and recover money owed to us

(a) Identity

(b) Contact

(d) Transaction

(e) Profile

(f) Marketing and Communications

(a) Performance of a contract with you and where special category data (such as health/disability related data) you will have provided that with your explicit consent or if it is covid-19 related or similar data then we will process that only where we need to for reasons of public interest in the area of public health or if it relates to an incident at our premises, we may need to process special category data for the establishment of a legal position on the matter

(b) Necessary for our legitimate interests (to recover debts due to us)

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy

(b) Asking you to leave a review or take a survey

(c) Dealing appropriately with your rights under relevant data protection legislation to provide to you, rectify, delete and transfer your data

(a) Identity

(b) Contact

(d) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

To enable you to partake in a prize draw, competition or complete a survey

(a) Identity

(b) Contact

(d) Usage

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to study how customers use our services, to develop them and grow our business)

To administer and protect our business and this website and our app (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) and security measures at our physical premises such as CCTV systems monitoring appropriate public areas at our hotels

(a) Identity

(b) Contact

(d) Technical

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation (including to employ adequate security measure in respect of personal data)

(c) Necessary to protect the vital interests of you or other guests attending our premises or our staff and other visitors (by employing accepted and usual security systems such as CCTV monitoring of appropriate public areas of our hotels)

To deliver relevant website and app content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

(a) Identity

(b) Contact

(d) Usage

(e) Marketing and Communications

(f) Technical

(a) Consent where given and where you enjoyed similar guest stays and experiences with us

(b) Necessary for our legitimate interests (to study how customers use our services, to develop them, to grow our business and to inform our marketing strategy)

To use data analytics to improve our website, app services, marketing, customer relationships and guest stays and experiences

(a) Technical

(b) Usage

Necessary for our legitimate interests (to define types of customers for our services and guest stays and experiences, to keep our website and app updated and relevant, to develop our business and to inform our marketing strategy)

To make suggestions and recommendations to you about guest stays or experiences that may be of interest to you

(a) Identity

(b) Contact

(d) Usage

(e) Profile

(f) Marketing and Communications

(a) Consent where given and where you enjoyed similar guest stays and experiences with us recently

(b) Necessary for our legitimate interests (to develop our guest stays and experiences offerings and grow our business)

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data 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 guest stays and experiences and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased guest stays and experiences from us and you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes, although please note that we do not at present provide your data to third parties for them to market their own services to you. We may share personal data with our marketing suppliers though.

Opting out

You can ask us to stop sending you marketing messages at any time by clicking on the unsubscribe links on any marketing message sent to you or by contacting us by email to: faqs@stgiles.com with subject line: Please Unsubscribe Me from Marketing Communications. In the body of your email, please communicate the contact information that should be removed and from which hotel’s communication. Requests must be sent from the email address and the name we have on file.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us for other reasons set out in this privacy policy.

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 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.

Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in the table above.

Internal Third Parties as set out in the Glossary below.
External Third Parties as set out in the Glossary below.
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 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.

International transfers

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. We have also employed technical measures such as firewalls and Secure Socket Layer (SSL) technology which encrypts the information you input, as an additional security measure to protect the information that you transmit via our website. Unfortunately, however, no online data transmission can be guaranteed to be entirely secure.

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.

Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, 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 to 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.

Details of retention periods for different aspects of your personal data are available in our retention policy, which you can request from us by contacting us.

For legal and tax reasons, we may have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers.

In some circumstances you can ask us to delete your data: see your legal rights below for further information.

In some circumstances we might 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.

Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please see the bottom section of this notice for details of those rights.

If you wish to exercise any of the rights set out above, please contact us at GDPRenquiries@stgiles.com

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.

Glossary

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 and the best and most secure guest stay and 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). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

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 obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

THIRD PARTIES

Internal Third Parties

Other companies in the St Giles Group acting as joint controllers or processors.

External Third Parties

Service providers acting as processors or joint controllers or controllers in common based who provide IT and system administration services, maintenance, facilities, catering and security and CCTV related services at our hotels, marketing and CRM (client relationship management) related services and platforms and fraud prevention services.
Professional advisers acting as processors or joint controllers or controllers in common including hotel health and safety and food safety related advisers, and lawyers and compliance advisers (such as in respect of advising on alcohol licences), bankers, auditors and insurers who provide consultancy, banking, legal, compliance, insurance and accounting related services.
Other hotel industry related organisations acting as processors or joint controllers or controllers in common including travel agencies (online and offline), tour operators, group tours, travel planners, wholesalers, booking and discount platforms and price comparison websites and companies who are based in our hotels (including hotels, shops, restaurants, gyms and conference and event facilities).
HM Revenue & Customs (or similar in other jurisdictions), courts and tribunals, regulators and industry regulatory or advisory boards, local and national authorities and emergency services acting as processors or joint controllers or controllers in common based in the United Kingdom or elsewhere who require reporting of processing activities in certain circumstances, including the Information Commissioner’s Office, the Food Standards Agency and the Health and Safety Executive.

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:

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.

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 services to you or bookings for you. We will advise you if this is the case at the time you withdraw your consent.