1.5 This website is not intended for children and we do not knowingly collect data relating to children.
2. Controller and third party links
2.1 We are the controller and processor responsible for your personal data.
(a) post to Zonebright Limited, 31-32 West Parade, Newcastle upon Tyne NE4 7LB; or
(b) email at email@example.com
2.3 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.
3. Collecting personal data
3.1 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).
3.2 We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
(a) Identity Data includes first name, last name, title, date of birth.
(b) Contact Data includes billing address, delivery address, email address and telephone numbers.
(c) Financial Data includes bank sort code, account and payment card details.
(d) Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
(e) 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.
(f) Profile Data includes purchases or orders made by you, your interests, preferences, and feedback and survey responses.
(g) Usage Data includes information about how you use our website, products and services, including traffic data.
(h) Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
3.3 We do not 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.
3.4 Where we need to collect personal data by law, or under the terms of a contract (including booking, enquiry or purchase) we have with you and you fail to provide that data when requested, we may not be able to perform the contract (including booking, enquiry or purchase) 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.
4. Personal data collection methods
4.1 We use different methods to collect data from and about you including through:
(a) Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email, on our website(s) or otherwise. This includes personal data you provide if you:
(i) Enquire about our products or services;
(ii) create an account on our website;
(iii) subscribe to our service or publications;
(iv) request marketing to be sent to you;
(v) give us your business card;
(vi) enter a competition, promotion or survey; or
(vii) give us some feedback.
(c) 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:
(i) analytics providers such as Google based outside the EU;
(i) Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside the EU];
5. Using personal data
5.1 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:
(a) Where we need to perform the contract we are about to enter into or have entered into with you.
(b) 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.
(c) Where we need to comply with a legal or regulatory obligation.
5.2 Generally we do not rely on consent as a legal basis for processing your personal data other than:
(a) if you are not our existing customer or represent a corporate business, and you have given us your business card; or
(b) 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 emailing firstname.lastname@example.org.
5.3 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.
5.4 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, administer your account and manage our relationship with you (a) Identity
(b) Contact (a) Performance of a contract with you
(b) Necessary for our legitimate interests (to administer your account and manage our relationship with you)
If you are a representative of a business, to manage our relationship with that business or to discharge our contractual obligations to the business that referred your business to us (a) Identity
(c) Transaction (a) Necessary for our legitimate interests (to manage our relationship with the business you represent, and to discharge our contractual obligations to the business who referred your business to us)
(b) Necessary for the legitimate interests of the business you represent (to manage their relationship with us)
To process and deliver your order including:
(a) Managing communications traffic
(b) Managing payments, fees and charges
(c) Preventing and detecting fraud
(d) Collecting and recovering money owed to us or otherwise enforcing our legal rights (a) Identity
(f) Marketing and Communications (a) Performance of a contract with you
(b) Legal obligation (providing accurate billing information)
(c) Necessary for our legitimate interests (traffic management; prevention and detection of fraud; recovering debts due to us or otherwise enforcing our legal rights)
To manage our relationship with you which will include:
(b) Asking you to leave a review or take a survey
(c) Dealing with enquiries and complaints (a) Identity
(d) Marketing and Communications
(g) Usage (a) Performance of a contract with you
(b) Necessary to comply with a legal obligation (providing accurate billing information and handling complaints)
(c) Necessary for our legitimate interests (keeping our records updated and to study how customers use our products/services)
To enable you to partake in a promotion or complete a survey (a) Identity
(e) Marketing and Communications (a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity
(c) 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
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you (a) Identity
(e) Marketing and Communications
(f) Technical Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences (a) Technical
(b) Usage Necessary for our legitimate interests (using diagnostic analytics to assess the number of visitors, posts, page views, reviews and followers in order to optimise future marketing campaigns)
To make suggestions and recommendations to you about goods or services that may be of interest to you (a) Identity
(e) Profile Necessary for our legitimate interests (to develop our products/services and grow our business)
5.5 If you submit personal information for publication on our website, we will publish and otherwise use that information in accordance with the licence you grant to us.
5.6 Marketing - we strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:
(a) 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 products, services 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, enquired on our website, purchased goods or services from us or if you provided us with your details when you registered for a promotion and, in each case, you have not opted out of receiving that marketing;
(b) Prospective clients – if you are not our existing customer or representing a corporate business and you have given us your business card because you are happy to hear from us, we may use your Identity and Contact Data to form a view on what we think you may want or need, or what may be of interest to you.
(c) Third-party marketing – we will get your express opt-in consent before we share your personal data with any other company for marketing purposes;
(d) Opting out – you can ask us or third parties to stop sending you marketing messages at any time by ‘Unsubscribing’ at any time. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience or other transactions.
5.7 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 email email@example.com.
5.8 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.
5.9 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.
6. Disclosing personal data
6.1 We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 5 above:
(a) Service providers acting as processors in the United Kingdom, the EEA and the USA who provide database and other IT and system administration services.
(b) Marketing services providers based in the EEA and the USA who provide direct marketing services to us.
(c) Payment services providers based in the EEA and the USA who provide payment services to us.
(d) Specific third parties such as Hilton, IHG, Accor, Marriot and Best Western with whom we may need to share your personal data in order to provide certain requested products or services to you.
(e) Businesses who referred your business to us.
(f) Professional advisers acting as processors including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
(g) HM Revenue & Customs, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances.
6.2 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.
7. International data transfers
7.2 Information that we collect may be transferred to the following countries which do not have data protection laws equivalent to those in force in the European Economic Area (EEA): the USA.
7.3 Some of our external third parties are also based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.
7.4 If 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:
(a) 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.
(b) 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.
7.5 You expressly agree to the transfers of personal information described in this paragraph 7.
7.6 Please email firstname.lastname@example.org if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
7.7 Personal information that you publish on our website or submit for publication on our website may be available, via the internet, around the world. We cannot prevent the use or misuse of such information by others.
8. Security of personal data
8.1 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.
8.2 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.
8.3 You acknowledge that the transmission of information over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
8.4 You are responsible for keeping the password you use for accessing our website confidential; we will not ask you for your password (except when you log in to our website).
9. Retaining personal information
9.1 We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
9.2 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.
9.3 In some circumstances we may 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.
10. Updating information
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.
11. Your legal rights
11.1 Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
(a) [Hyperlink to Glossary section “Request access to your personal data”].
(b) [Hyperlink to Glossary section “Request correction of your personal data”].
(c) [Hyperlink to Glossary section “Request erasure of your personal data”].
(d) [Hyperlink to Glossary section “Object to processing of your personal data”].
(e) [Hyperlink to Glossary section “Request restriction of processing your personal data”].
(f) [Hyperlink to Glossary section “Request transfer of your personal data”].
(g) [Hyperlink to Glossary section “Right to withdraw consent”].
12. About cookies
12.2 Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
12.3 Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
12.4 Cookies can be used by web servers to identify and track users as they navigate different pages on a website and identify users returning to a website.
12.5 Our cookies: We use both session and persistent cookies on our website. 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.
12.6 We use the following cookies:
(a) 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 service;
(b) Analytics/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;
(c) 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);
(d) 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.
12.9 Third party cookies: Our website also uses third party cookies. A common example is an embedded YouTube video.
13.1 We may update this policy from time to time by publishing a new version on our website.
13.2 This version was last updated in 2018.
13.4 You should check this page occasionally to ensure you are happy with any changes to this policy.
13.5 We may notify you of changes to this policy by email or through the private messaging system on our website.
14.1 Lawful Basis
(a) Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
(b) Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure 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 emailing email@example.com.
(c) 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.
14.2 Your Legal Rights
14.3 You have the right to:
(a) 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.
(b) 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.
(c) 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.
(d) 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.
(e) 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.
(f) 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.
(g) 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.