Privacy Notice

1. Who we are

Hotel Benchmark Limited, a private company limited by guarantee incorporated in Scotland with company number SC646183 and registered office at 2 South Charlotte Street, Edinburgh, EH2 4AW.

Hotel Benchmark are committed to protecting the privacy and security of your personal data. This privacy notice describes how we collect and use personal data about you, in accordance with the General Data Protection Regulation (“GDPR”). We are a “data controller”. This means that we are responsible for deciding how we hold and use personal data about you when you visit our website, contact us, or buy goods or services from us.

We are required under data protection legislation to notify you of the information contained in this privacy notice.

Contact details

If you have any questions about this privacy policy, please contact us in the following ways:

Email address: hello@hotelbenchmarking.com

Telephone number: 0131 225 5555

Postal address: Hotel Benchmark, Charlotte House, 2 Charlotte Street, Edinburgh, EH2 4AW

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 policy of every website you visit.

2. Data protection principles

We will comply with data protection law. This says that the personal data we hold about you must be:

  • Used lawfully, fairly and in a transparent way.
  • Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
  • Relevant to the purposes we have told you about and limited only to those purposes.
  • Accurate and kept up to date.
  • Kept only as long as necessary for the purposes we have told you about.
  • Kept securely.

3. The kind of information we hold 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, store and use the following categories of personal about you which we have grouped together as follows:

  • Identity Data includes first name, last name, username or similar identifier, title, and date of birth.
  • Contact Data includes billing address, email address and telephone numbers.
  • Financial Data includes bank account and payment card details.
  • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from 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 your username and password, 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.

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).

By logging in to Google Analytics on our platform some parts or the entirety of your Google Analytics data is downloaded into our database.

4. 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 or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
    • create an account on our website;
    • subscribe to our service or reports;
    • connect a Google Analytics account;
    • request marketing to be sent to you;
    • request our newsletter
    • interact with us at industry events or conferences; or
    • give us feedback or contact us.
  • Automated technologies or interactions. As you interact with our website, we will 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. By logging into Google Analytics on the Hotel Benchmark platform, some parts or the entirety of your Google Analytics data is downloaded into our database.
  • Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
    • LinkedIn
    • Facebook
    • Twitter
  • Technical Data from the following parties:
    • analytics providers such as Google based outside the EU;
  • Contact, Financial and Transaction Data from providers of technical, payment and delivery services
  • Identity and Contact Data from data brokers or aggregators
  • Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU

5. How we will use information about you

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.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before 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.

Marketing and promotional offers from us

We strive to provide you with choices regarding the way we process your data, particularly in relation to marketing and advertising. We may use your personal 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, purchased goods or services from us and you have not opted out of receiving that marketing.

As part of the registration for our newsletter, we collect your personal data. We use that information to: tell you about things you’ve asked us to tell you about; to contact you if we need to obtain or provide additional information and to check our records are right. We don’t rent or trade email lists with other organisations and businesses.

Opting Out

You can ask us to stop sending you marketing messages at any time by contacting us at any time.

6. Cookies

Our website uses cookies. A cookie is a small file of letters and numbers that is sent by a web server to a web browser and then stored by the browser, when you access certain websites. Cookies allow a website to recognise a user’s computer. We use cookies to understand how people use our website and to help us to make your experience of our website better.

Cookies do not typically contain any information that personally identifies a user, but personal data that we store about you may be linked to the information stored in and obtained from cookies.

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.

The names of the cookies that we use on our website, and the purposes for which they are used, are set out below. This list may be updated from time-to-time.

  • Cookies required for basic functionality
    • ‘sessionid’ – Used to keep you logged in into the website
    • ‘csrftoken’ – Helps prevent Cross-Site Request Forgery (CSRF) attacks
    • ‘django_language’ – Used to keep track of your preferred language
    • ‘ss‘ – Necessary for the functionality of the website's chat-box function

Please note that the following third parties may also use cookies, over which we have no control. These named third parties may include, for example, advertising networks and providers of external services like web traffic analysis services. These third party cookies are likely to be analytical cookies or performance cookies or targeting cookies:

  • Google Analytics statistics cookies – Used to understand how visitors interact with websites by collecting and reporting information anonymously
  • Google Analytics marketing cookies – Used to track visitors across websites to display ads that are relevant and engaging
  • Recaptcha cookies – Used to distinguish between humans and bots
  • Stripe cookies – Used to ensure that any payments performed on the website are genuine
  • Google Data Studio cookies – Used to allow for embedding of interactive reports

Should you wish to avoid this data being collected, 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.

7. If you fail to provide personal information

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.

8. 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 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.

9. Legal Basis for Processing your Data

We are legally obliged to have a lawful basis for collecting and using your personal data. This means that we are only allowed to collect and use your data if:

  • 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.

10. Data sharing

We may have to share your data with third parties, including third-party service providers. We require third parties to respect the security of your data and to treat it in accordance with the law. We do not envisage transferring your personal data outside the EU, however, if we do, you can expect a similar degree of protection in respect of your personal data.

Why might you share my personal data with third parties?

We might share your anonymised Google Analytics data with partners for a fee. The data might include the general location of your property together with other descriptive information about your property you provided us with. Furthermore, your non-anonymised data (hotel name, location, etc.) will be visible to other users of Hotel Benchmark. We will however never share your precise data (a combination of your hotel name and its analytics data) with anyone.

Which third party service providers process my personal data?

  • Hotel Benchmark Partner’s:
    • 80 DAYS
  • Services that Hotel Benchmark utilises to store and analyse your data:
    • Agile CRM
    • Google Cloud Services (SQL, App Engine)
    • Google Analytics

How secure is my information with third party service providers?

We require third party service providers to treat your data with the same high standards outlined in this document and 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.

What about other third parties?

We may share your personal information with other third parties, for example in the context of possible sale or restructuring of the business. We may also need to share your personal information with a regulator to otherwise comply with the law.

11. International transfers

We do not transfer your personal data outside of the European Economic Area (EEA).

12. Retaining Personal Data

This section sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

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 compliant 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.

13. 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.

14. Rights of access, correction, erasure and restriction

Your duty to inform us of changes

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 working relationship with us.

Your rights in connection with personal data

Under certain circumstances, by law you have the right to:

  • Right to be informed about the collection and use of your personal data
  • 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 information we hold about you corrected.
  • 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 exercised your right to object to processing (see below).
  • 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. You also have the right to object where we are processing your personal data for direct marketing purposes.
  • Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.
  • Request the transfer of your personal data to another party.

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.

If you want to review, verify, correct or request erasure of your personal data, object to the processing of your personal data, or request that we transfer a copy of your personal data to another party, please contact us.

15. Changes to this privacy notice

We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.

If you have any questions about this privacy notice or how we handle your personal information, please contact us: Hotel Benchmark, Charlotte House, 2 Charlotte Street, Edinburgh, EH2 4AW. 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. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.