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Privacy Notice

Welcome to Hospitality Finder (“us”, “we”, or “our”). We respect the privacy of all the people we work with in the course of operating our business and have created this Privacy Notice to provide information about how we collect and use personal data. So, if you are one of our customers or are attending an event through one of our packages, are visiting our website, or otherwise interact with us in relation to the services that we provide, then this notice applies to you.

Please note that while we trade as Hospitality Finder, Hospitality Sports & Banqueting Club Ltd will be the data controller of any personal data that you provide or that we collect about you. As part of our commitment to protecting your data, we are registered with the Information Commissioner’s Office (ICO) (registration number: Z9749058), and if you have any questions regarding how we handle your data then you can always contact using the information provided below.

Important information about this Notice

While we always aim to provide complete and transparent information about how we handle your personal information, we reserve the right to update this Notice from time to time or to create additional policies in order to accurately reflect changed circumstances or new regulatory requirements.

As a result, 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 personal data. Please note that this Privacy Notice supplements the other notices and is not intended to override them.

Equally, to assist us in ensuring that we can provide the most accurate information possible, we ask that you check this Notice for updates. We also ask that, where we have an ongoing relationship with you and any of the data you have provided become are no longer accurate, that you keep us informed of this so that we can amend our records accordingly.

What information do we collect about you & how do we collect it?

Personal data means any information about you that can be used to contact or identify you. It does not however include data which has been permanently anonymised to prevent identification or aggregated statistical data which we may generate to monitor the performance of our business and to ensure that we are providing the best service possible.

When making a booking with us to attend an event or experience, communicating with us regarding our services, or otherwise interacting with us in the context of our business (for example as a partner or supplier), then we may collect, use, store and otherwise process the following categories of personal data about you:

Identity Data: your first name, last name, job title and your login information where you create an account with us
Contact Data: your email address and telephone numbers
Financial Data: bank account and payment card details
Transaction Data: details about payments to and from you and other information related to bookings and experiences
Technical Data: internet protocol (IP) address, login information, 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
Usage Data: information about how you use our website and services
Marketing and Communications Data: includes your preferences in relation to receiving marketing communications (such as news, offers and other updates)
Health Data: information about allergies and accessibility requirements

What if you fail to provide personal data?

There may be cases where we need certain information in order to enter into a contract with you or, where we already have such a relationship with you, to administer the terms of the contract. In such cases, where you fail to provide that data requested, then we may not be able to enter into that contract with you or may be prevented from performing aspects of it (including but not limited to providing our services to you). In those circumstances, we may have to cancel a product or service you have with us, but we will always notify you if this is the case at the time.

On what basis will 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 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 necessary to enter into or perform an existing a contract with you
Where we need to comply with a legal or regulatory obligation
Where you have provided your consent

Where we process limited amounts of special category data related to health, then we do this on the basis that:

We have obtained your explicit consent
It is necessary to protect your vital interests

In any case where we rely on your consent in order to process your personal data, we will only do so where your consent is clear, unambiguous and informed. In addition, you can withdraw your consent at any time, although please note that withdrawal of your consent would not affect the legality of any processing which has already occurred.

Why do we use your personal data?

Below is a table including 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. However, please 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.

Purpose/Activity	Type of data	Basis of processing
To enter into and subsequently to manage our relationship with you, including but not limited to in: · Responding to service related enquiries · Executing bookings, including processing any associated payments · Notifying you about changes to our terms of business or privacy Notice · Asking you to leave a review or take a survey · Sending you promotions or other marketing materials regarding our products and services	(a) Identity Data (b) Contact Data (c) Financial Data (d) Transaction Data (e) Marketing and Communications Data	· Necessary for our legitimate interests (promoting, advancing and operating our business) · Performance of a contract with you · Necessary to comply with a legal obligation
To manage your order or booking, including in relation to any special requirements of the venue or attendees	(a) Identity Data (b) Contact Data (c) Health Data	· Necessary for our legitimate interests (promoting, advancing and operating our business) · Performance of a contract with you · Necessary to comply with a legal obligation · Your explicit consent · To protect the vital interests of an individual
To administer, advance and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity Data (b) Contact Data (c) Technical Data	· Necessary for our legitimate interests (administering our IT and maintaining network security)
To make decisions about how best to deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising used	(a) Identity Data (b) Contact Data (c) Profile Data (d) Usage Data (e) Marketing and Communications Data (f) Technical	· Necessary for our legitimate interests (understanding how customers and website visitors engage with our website and our services)
To use data analytics to improve our website, services, marketing, customer relationships and experiences	(a) Technical Data (b) Usage Data	· Necessary for our legitimate interests (targeting our service and content delivery).
To make suggestions and recommendations to you about services or experiences that may be of interest to you based on previous services or experiences that you have booked through us	(a) Identity Data (b) Contact Data (c) Technical Data (d) Usage Data (e) Profile Data	· Necessary for our legitimate interests (promoting our business through advertising)
To allow you to interact with us online through our website or over the phone	(a) Identity Data (b) Contact Data (c) Technical Data (d) Usage Data (e) Profile Data	· Necessary for our legitimate interests (to understand our customers and to develop our products/services and grow our business)

Purpose/Activity

Type of data

Basis of processing

To enter into and subsequently to manage our relationship with you, including but not limited to in:

· Responding to service related enquiries

· Executing bookings, including processing any associated payments

· Notifying you about changes to our terms of business or privacy Notice

· Asking you to leave a review or take a survey

· Sending you promotions or other marketing materials regarding our products and services

(a) Identity Data

(b) Contact Data

(d) Transaction Data

(e) Marketing and Communications Data

· Necessary for our legitimate interests (promoting, advancing and operating our business)

· Performance of a contract with you

· Necessary to comply with a legal obligation

To manage your order or booking, including in relation to any special requirements of the venue or attendees

(a) Identity Data

(b) Contact Data

· Necessary for our legitimate interests (promoting, advancing and operating our business)

· Performance of a contract with you

· Necessary to comply with a legal obligation

· Your explicit consent

· To protect the vital interests of an individual

To administer, advance and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

(a) Identity Data
(b) Contact Data
(c) Technical Data

· Necessary for our legitimate interests (administering our IT and maintaining network security)

To make decisions about how best to deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising used

(a) Identity Data
(b) Contact Data
(c) Profile Data
(d) Usage Data
(e) Marketing and Communications Data
(f) Technical

· Necessary for our legitimate interests (understanding how customers and website visitors engage with our website and our services)

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

(a) Technical Data
(b) Usage Data

· Necessary for our legitimate interests (targeting our service and content delivery).

To make suggestions and recommendations to you about services or experiences that may be of interest to you based on previous services or experiences that you have booked through us

(a) Identity Data
(b) Contact Data
(c) Technical Data
(d) Usage Data
(e) Profile Data

· Necessary for our legitimate interests (promoting our business through advertising)

To allow you to interact with us online through our website or over the phone

(a) Identity Data
(b) Contact Data
(c) Technical Data
(d) Usage Data
(e) Profile Data

· Necessary for our legitimate interests (to understand our customers and to develop our products/services and grow our business)

How do we use your personal data for marketing?

We may use your Identity, Contact, Technical, Usage and Profile Data to inform you of any specific events, experiences, services or offers that we think you might be interested in. However, if you would like to stop receiving updates from us, then you can unsubscribe at any time by using the link at the bottom of the email you have received or by contacting us.

Who will we share your information with?

Sometimes it may be necessary to share your personal data with trusted third parties, including but not limited to:

Venues holding events that you have booked to attend.
Service providers we use to operate our business, such as our IT and system administration providers and payment institutions that we use to process payments.
Regulatory authorities (such as HM Revenue & Customs), law enforcement agencies and emergency services and courts, to the extent necessary to comply with our legal and regulatory obligations.
Our professional advisors
Other entities within our group of companies
In the event of a sale of our business or part of our business, the purchaser and its professional advisors

Will we transfer your personal data internationally?

In certain circumstances we will need to transfer your personal data outside the UK. However, we will only transfer your data internationally where a similar degree of protection is ensured in the recipient jurisdiction.

In particular, we will only transfer your personal data to countries that have either been deemed to provide an adequate level of protection for personal data, or where there are specific contractual clauses in place to protect the transfer of your data. For more information, the contracts that we use to achieve this, then please get in touch.

How do we ensure the security of your personal data?

We have implemented appropriate technical and organisational measures to protect 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 service providers who have a business need to know. They will only process your personal data on our instructions and are subject to a formal duty of confidentiality.

In the event that we experience any intrusion of our information systems or otherwise suffer a breach of our data security, we have in place specific procedures designed to deal with such a breach, including protecting the personal data within our control and, where we are legally obliged to do so, notifying you and any applicable regulatory authority in a timely fashion.

Please note however that despite our best efforts we cannot guarantee the security of information being exchanged over the internet and, where our website contains links to other sites plug-ins and applications that are not operated by us, clicking on those links, or enabling those connections may allow third parties to collect or share data about you. When you leave our website, we strongly advise you to review the privacy information published on every site you visit. We have no control over, and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

How long will we keep your personal data for?

We will only keep 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 other mandatory reporting requirements.

To determine the appropriate retention period, we consider a number of factors, including the amount, nature, and sensitivity of the data, the potential risk of harm from unauthorised use or disclosure, the purposes for which we need to keep it and whether we can achieve those purposes through other means.

What are your legal rights in connection with your personal data?

You have rights under data protection laws in relation to your data and we have provided a list of these below. However, please note that not all of these apply in all circumstances:

Right of access: subject to certain exceptions, you have the right of access to your personal data that we hold.
Right to rectify your personal information: if you discover that the information, we hold about you is inaccurate or incomplete, you have the right to have this information rectified (i.e. corrected).
Right to be forgotten: you may ask us to delete information we hold about you in certain circumstances. This right is not absolute, and it may not be possible for us to delete the information we hold about you, for example, if we have an ongoing contractual relationship or are required to retain information to comply with our legal obligations.
Right to restriction of processing: in some cases you may have the right to have the processing of your personal information restricted. For example, where you contest the accuracy of your personal information, its use may be restricted until the accuracy is verified.
Right to object to processing: you may object to the processing of your personal information (including profiling) when it is based upon our legitimate interests. You may also object to the processing of your personal information for the purposes of direct marketing and for the purposes of statistical analysis.
Right to data portability: you have the right to receive, move, copy or transfer your personal information to another controller when we are processing your personal information based on consent or on a contract and the processing is carried out by automated means.

Please note that if you are requesting access to your data then in order to protect the rights of others we may require you to validate your identity before we can release that information to you. In addition, while submitting an access request is typically free of charge, please note that we may charge a reasonable fee where we consider that the request is manifestly unfounded, excessive or repetitive in nature.

In the event that you wish to exercise any of the rights identified above, then please contact us.

Questions or complaints?

If you have any questions regarding the ways in which we process your personal data, then you can always contact us using the contact information provided below.

You also have the right to make a complaint at any time to the relevant supervisory authority in your jurisdiction, which in the UK is the ICO. We would always welcome the chance to deal with your concerns in the first instance, but if you would like to contact the ICO then you can do so by calling their helpline on 0303 123 1113.