Introduction
This privacy policy tells you how Dorchester Collection and its hotels use your personal data when you visit our website, when we welcome you as our guest or when you otherwise interact with us. It also tells you your privacy rights and how the law protects you.

If you are a resident of California, you have rights under the California Consumer Privacy Act (“CCPA”). Pease refer instead to our California Consumer Privacy Policy which you can find here: https://www.dorchestercollection.com/en/ccpa/

It’s important that you read this privacy policy, together with any other privacy notices we may show you from time to time, so that you’re fully aware of how and why we are using your personal data.

This privacy policy was last updated on September 8, 2020.

If you have any questions, please see How to contact Dorchester Collection about privacy below.

Who we are
Dorchester Services Limited (“Dorchester Collection”) holds a portfolio of nine of the world’s finest luxury hotels in Europe and the US. Each hotel is an icon in its own right, with a worldwide reputation for offering the most sought-after experiences of good living, charm, elegance and service.

Dorchester Collection is the data controller responsible for this website and the handling of any personal data carried out by it on behalf of the group of companies which operate each hotel. Dorchester Collection and each hotel work collaboratively to provide services to guests and website visitors and may sometimes be acting as joint data controllers. When we mention Dorchester Collection, “we”, “us” or “our” in this privacy policy, we are referring to Dorchester Collection.

We have appointed a data privacy manager who is responsible for looking after questions about this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please see How to contact Dorchester Collection about privacy below.

How we collect data
We may collect or receive data in lots of different ways. Here is an explanation of the main ways we do this:

You may give us data in person when you are a guest at one of our hotels

You may give us data in person when you’re a guest at one of our hotels, for example when you:

check-in and check-out;
make use of our accommodation, facilities and services;
make use of our concierge services;
attend our events;
enter a competition, promotion or survey;
complete a contact details card; and/or
give us your business card.
You may give us data remotely when you interact with us

You may give us data remotely when you interact with us via this website, by post, phone or email, or through chat or social media. For example, when you:

sign up to receive our newsletter or other direct marketing;
make enquiries or request information, or correspond with us generally;
create an account on our website;
book accommodation, hospitality, spa treatments or services;
buy items from our gift shop;
engage with us on social media;
enter a competition, promotion or survey;
leave comments or reviews; and/or
register for some of our business services, including the Diamond Club.
We may get some data automatically

When you interact with us, we may get some data automatically, including via this website. For example, that could be data about your equipment, browsing or the way you use this website. We may also collect data when you click on one of our adverts (including the ones you see on third party websites or social media).

The systems we use for guest management may also collect data automatically to help create a guest profile, which in turn gives us a better understanding of how we can improve your experience with us.

We may get some data from third parties

We may get some data from third parties as part of the booking process for our accommodation, hospitality, spa treatments or services at our hotels. For example, when you:

use third party booking services for accommodation, restaurants, hospitality, spa treatments or other services; and/or
are our guest as part of a group or corporate booking.
We may receive data about you from various other types of third parties, including:

from technology partners who help us run our website and mailing list sign-ups;
from providers of payment and fraud prevention services;
from analytics providers, advertising networks and search information providers;
from data partners;
from feedback and review partners;
from publicly available sources;
from social media, where privacy settings are set to public;
from third parties to whom you have given permission to share your data with us; and/or
from any third parties who are permitted by law to share your personal data with us.

Types of personal data we collect
How we collect data above explained the different ways we might obtain or receive data. Some of that data may be personal data, so please read below to understand the different types we may collect about you. Of course, the types of personal data we collect will depend on how you interact with us.

Personal data, or personal information, means any information about an individual, which can be used to identify that person. It does not include data where the identity has been removed (anonymous data).

We collect a variety of personal information about our guests, customers and visitors to our website. As our website is not intended for children, we do not knowingly collect data relating to children.

This personal data falls into these categories:

Identity Data includes title, gender, first name, maiden name, last name, marital status, date of birth, username or similar identifier and an encrypted version of your login/password. If you interact with us through social media, this may include your social media user name.
Contact Data includes billing address, delivery address, email address and telephone numbers.
Financial Data includes payment card and direct debit/bank account details.
Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses, as well as any data which we have added (for example, using analytics and profiling).
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.
Usage Data includes information about how you use our website, products and services.
Tracking Data includes information we or others collect about you from cookies and similar tracking technologies, such as web beacons, pixels, and mobile identifiers.
Marketing and Communications Data includes your preferences in receiving direct 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 policy.

We do not ordinarily collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, 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.  The only exceptions to this are: (i) if you provide health data to us as part of a spa booking, we will use this to perform our contract with you, and we need your explicit consent to use your health data as part of that; or (ii) you have made the special category data obviously public.

Remember, if you choose not to share personal data with us, or refuse certain contact permissions, we might not be able to provide the products and services you’ve asked for.

Explaining the legal bases for using 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. For example, when you make a booking at one of our hotels, that’s a contract.
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. For example, when we carry out fraud screening as part of the check-out process or take steps to keep our website secure.
Where we need to comply with a legal or regulatory obligation. For example, keeping records of our sales for tax compliance.
When we are considering legitimate interests, we make sure we think about 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).

Generally, we do not rely on consent as a legal basis for processing your personal data other than where the law requires it, for example in relation to sending certain direct marketing communications. Where our legal basis is consent, you have the right to withdraw consent any time.

See How and why we use your personal data below for more detailed information.

How and why we use your personal data
Click here to see a table explaining how we use your personal data, the types of personal data that applies to and why it is we can do this. When we explain why, we will identify the relevant category from Explaining the legal bases for using personal data above, and, where it’s based on being able to do so for our legitimate interests, we will highlight what that legitimate interest is.

We may process your personal data for more than one legal basis depending on how we are using it.

Advertising, marketing and your communications preferences
You could see our adverts in lots of different places, but it doesn’t always mean they’re using your personal data, because we also buy advertising space in the real world, on websites and on social media. If you see one of our adverts on a website and in social media, it may not be directed specifically at you and may simply be there because we’ve bid for the space.

To understand what we think you want, need or would be interested in, we may use your Identity, Contact, Technical, Tracking, Usage and Profile Data to form a picture. This is how we tell you about the hotels, services and events, and any special offers or promotions, we think you might be interested in.

To share our news, offers and services, we may use direct marketing by email, phone, text and post. Your direct marketing preferences are made clear on our website, and you can ask us about these any time via our contact page.

You may choose to opt in to receive our newsletter on our website. We may also be able to send you relevant direct marketing about our hotels, services and events unless you choose to opt out when making a booking with us, visiting our hotels or making a purchase via the gift shop.

Here are some examples of our direct marketing activities which may be directed specifically at you:

our newsletter via email;
invitations and promotions by post, to tell you about special events at our hotels; and/or
phone calls, to tell you something that might be relevant to you or your business.
You can opt out of direct marketing at any time. The easiest way to do this is to click the unsubscribe link at the bottom of your email or contact privacy.DCL@dorchestercollection.com.

If a third party outside Dorchester Collection wants to use your personal data for their own direct marketing, we will always get your express opt-in consent first.

If you use a third party service to make a reservation at our hotels or restaurants, we may receive your marketing preferences from them. We may record these preferences, so when using these services please make sure you choose your marketing preferences correctly. As we have no control over the preferences which third party booking websites present to you, you should read their privacy policy.

We also work with partners to try and promote the reach of our adverts, using analytics and retargeting. To make sure the adverts you see on websites and social media are relevant, we use Tracking Data to see what you’ve looked at.

We want to give you the best Dorchester Collection experience online. Tracking Data, and in particular cookies, help us to do this by telling us which adverts will be most relevant to you and potential new guests on websites and social media. The cookies used for this purpose are often placed on our website by specialist organisations – and this is also why when you’ve been on the Dorchester Collection website, you might see content from our website again. This includes retargeting.

Cookies can also tell us if you’ve seen a specific advert, and how long it’s been since you have seen it. This is helpful, because it means we can control the effectiveness of our adverts and control the number of times people might be shown our adverts. Cookies also help us understand if you’ve opened a marketing email because we don’t want to send you things you won’t find interesting.

For more information about Tracking Data, in particular cookies, see Cookies below.

Almost all the cookies that relate to advertising are part of third party online advertising networks. If you’d like to read about how you can control which adverts you see online, see opt-out programs established by the Digital Advertising Alliance (United States), the Digital Advertising Alliance of Canada and the European Interactive Digital Advertising Alliance. We do not control cookies which are set by advertising networks.

© Dorchester Services Limited 2020