Privacy Policy

Welcome to Cala Hotels’ privacy notice

Cala Hotels respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you: visit our website (regardless of where you visit it from); engage with us as a customer (on your own or on your company’s behalf); or communicate with us directly in any other way (for example, by telephone, e-mail or in person); 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 notice.

  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

Purpose of this privacy notice

This privacy notice aims to give you information on how Cala Hotels collects and processes your personal data through:

  • your use of this website, including any data you may provide through this website when you make an enquiry or make a booking;
  • your engagement with us as a customer; and
  • your communication with us (directly in any other way for example, by telephone, e-mail or in person).

This website is not intended for children and we do not knowingly collect data relating to children.

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

Controller

Cala Hotels Ltd (Company Number SC1245609) of James Street, Stornoway, Isle of Lewis HS1 2QN, is the data controller and responsible for your personal data (referred to as “Cala Hotels”, “we”, “us” or “our” in this privacy notice).

If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us using the details set out below.

Contact details

Our full details are:

Full name of legal entity: Cala Hotels Limited

Contact: Kenneth Mackenzie CA

E-mail: privacycala@calahotels.com

Postal address: Cala Hotels Limited, 11 James Street, Stornoway, Isle of Lewis HS1 2QN

Telephone number: 01851 706600

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 in the first instance.

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

We keep this privacy notice under regular review and, if we make any changes to this notice, we will place an updated version on our website and, where appropriate, notify you by e-mail. Regularly reviewing this page ensures you are always aware of what personal information we collect, how we use it and under what circumstances, if any, we will share it with other parties.

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 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 notice of every website you visit.

The data we collect about you

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, title, date of birth and geographic location.
  • Contact Data includes billing address, residential and / or business address, email address and telephone numbers (business and / or personal).
  • Financial Data includes bank account and payment card details.
  • Transaction Data includes details about payments to and from you and other details of bookings you have made with us.
  • 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.
  • Profile Data includes purchases or orders made by you, your interests, preferences, feedback and survey responses.
  • Usage Data includes information about how you use our website, products and services.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does 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.

We do not generally collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences. However, from time to time we may need to collect limited health data about you in order to enable us to make arrangements for you in connection with your booking (for example, we may need to know about accessibility or mobility requirements that you have; dietary requirements; or other health matters which could affect your use of our services or the way we need to provide our services) and will only do so to the extent that processing relates to personal data which are manifestly made public by you or otherwise with your consent.

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.

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 and Financial Data by filling in forms (either in person, on our website or electronically through our systems, including on our Holiday Planner page) or by corresponding with us in person, by post, phone, e-mail or otherwise. This includes personal data you provide when you:

  • make an enquiry on our website;
  • make a booking on our website;
  • make an enquiry about our hotels and associated products and / or services in person, by post, phone, e-mail or otherwise;
  • enter into negotiations with us to book a room, dining experience or other product and / or service (in person, by post, phone, e-mail or otherwise);
  • enter into an agreement with us for: the booking of a room or dining; or provision of another of our products and / or services (in person, by post, phone, e-mail or otherwise);
  • request marketing to be sent to you; or
  • give us some feedback or survey response, e.g. mailerlite.com.

Automated technologies or interactions. 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 for further details.

Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:

  • Technical Data from the following parties: o analytics providers such as Google based outside the EU; and o search information providers such as Google based outside the EU.
  • Contact, Financial and Transaction Data from providers of technical, payment and delivery services based inside and outside the EU, such as Elavon Financial Services DAC, trading as Elavon Merchant Services.
  • Identity, Contact and Transaction Data from any agents you instruct to make a booking with us. Some of these agents are based worldwide e.g. Capita group • Internet booking sites, such as – booking.com, expedia.com, triparvisor.com, laterooms.com

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 or regulatory obligation.

More information about the types of lawful basis that we will rely on to process your personal data is contained in the Glossary at the end of this Policy.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party 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.

Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

  • Service providers acting as processors based within the UK who provide payment, IT and system administration services, including Elavon Financial Services DAC, trading as Elavon Merchant Services (our payment provider) Sabre Hospitality Solutions (our channel manager) and Calico UK (our internet services provider). • Agents acting on your behalf to make a booking with us and who are usually based outside the UK.
  • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based within the UK who provide consultancy, banking, legal, insurance and accounting services.
  • HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the UK who require reporting of processing activities in certain circumstances.
  • 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 notice.

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

Some of our external third party service providers have operations outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

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

Whenever we transfer your personal data out of the EEA, 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 by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
  • Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
  • Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

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 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.

 

Your legal rights

Under certain circumstances, you have the following rights under data protection laws in relation to your personal data:

  • Request access to your personal data.
  • Request correction of your personal data.
  • Request erasure of your personal data.
  • Object to processing of your personal data.
  • Request restriction of processing your personal data.
  • Request transfer of your personal data.
  • Right to withdraw consent.

More detail about these rights is provided below in the Glossary. If you wish to exercise any of the rights set out above, please contact us.