This privacy policy applies to the Red Carnation Hotel Group, encompassing all establishments within the Red Carnation Hotel Group Ltd (hereafter referred to as "we," "us," or "our"). The Red Carnation Hotel Group includes, Milestone Hotel & Residences,  Rubens at the Palace, Hotel 41, Egerton House Hotel, Chesterfield Mayfair,  Montague on the Gardens, Summer Lodge Country House Hotel & Restaurant, Acorn Inn, Ashford Castle, Lodge at Ashford Castle,  Old Government House Hotel & Spa,  Hotel D'Angleterre,100 Princes Street, Bushmans Kloof Wilderness Reserve & Wellness Retreat, Twelve Apostles Hotel and Spa, Oyster Box and Xigera Safari Lodge.

 

We are registered under the laws of the State of Guernsey, with incorporation number CMP 62944. Our registered office is located at Travel House, Rue Du Manoir, St Peter Port, Guernsey, GY1 2JH. This privacy policy outlines our commitment to protecting your personal data.

 

This Privacy policy has been adopted by all the legal entities that manage and operate Red Carnation Hotel Group around the world. A complete list of the entities, and additional information relevant to Red Carnation Hotel Group processing of personal information can be accessed here.

This privacy policy provides insight into how we handle personal information pertaining to individuals we engage with, such as customers and website users. It's essential that you review this policy alongside any other privacy notices we may issue during personal data collection and processing instances. By doing so, you gain a comprehensive understanding of how and why we utilise your data. Please note that this privacy notice complements other notices and is not intended to supersede them.

Examples of who this policy covers:

 

We include in this privacy policy personal data we process relating to:

 

• Individuals who are making any enquiry or booking with us or through us, and individuals in respect of whom any enquiry or booking is made (such as friends, family members, tour group members, officers and employees of businesses and organisations booking with or through us);
• Individuals in respect of whom any enquiry or booking is made with us by an agent.
• Where our customer is a business or organisation, employees or individuals who are acting as representatives of that business or other organisation, and individuals connected to that business or other organisation, such as owners, partners, shareholders, and directors.
• Individuals whose personal data is obtained from other companies in our group (such as where YOU have consented to your personal data being disclosed to other group companies for marketing purposes).

 

When we are data processors

 

Please note that this privacy policy does not apply where we are processing personal data strictly as a sub-contractor or data processor on behalf of a third party, and not on our own account. In this case, YOU should look to that third party and its privacy policy, who will be answerable for how we process that personal data on When we refer to "processing" of your personal data, this includes obtaining, recording, storing or holding your personal data, and anything we do with it, such as organising, adapting or altering it, retrieving, consulting or using it, disclosing it or otherwise making it available to others, combining it with other data, and blocking, erasing or destroying it.

 

• When we refer to the “Hotel Group" this covers all products and services which may be booked with or through us, including accommodation, dining, tours, weddings, and events.  It also includes the following:
• All such products and services which we supply or operate ourselves (including where we sub-contract); and
• Any such products and services provide by a third party which we book for you (acting as agent for you or that third party). Travel services also includes any services we or a third party provide in association with travel, such as obtaining visas, foreign exchange, and providing local representatives and support.

We will only use your personal information for the original purpose we collected it for. If we need to use it differently, we will make sure the new use is still related to the original one. If you have questions about how the new use relates to the original one, feel free to ask us for clarification.

 

Sometimes, we may need to use your personal information for additional purposes. In these cases, we will try to let you know in advance and seek your consent if necessary. For example, if you provided us with information for a booking, we might also use it for things like analysing customer trends or improving our services.

 

We will use aggregated data analysis to gain insights from your personal information without directly identifying you. This type of data isn't considered personal under the law because it doesn't identify individuals.

 

However, if we combine this aggregated data with your personal information in a way that does identify you, we'll treat it as personal information and handle it in accordance with UK and other relevant global data privacy laws.

Personal Identifying Information

This includes details like your full name, mailing address, email address, phone number, social media account identifiers, profile pictures, and any publicly available data or information provided by linking your social media and loyalty accounts.

 

Demographic Information and Significant Dates

This category covers data such as gender, language preferences, nationality, birthdays, anniversaries, and any other special occasions.

 

Government-Issued Identification

This pertains to documents like passports, visas, or any other form of government-issued identification, including the personal data contained within these documents.

 

Financial Information

This includes credit card, debit card, or other payment details provided during transactions.

 

Loyalty Program Details

Information related to membership or participation in loyalty programs, co-branded payment card details, and affiliations with travel partner programs.

 

Travel Details

Information about previous stays, interactions, purchases, special requests, travel itineraries, tour group data, activities, and employer details for business-related bookings.

 

Claims Data

This covers details such as insurance information, emergency contacts, complaints, and employment information for worker's compensation claims.

 

In certain circumstances, we may also collect:

Information about Family Members and Companions this includes the names and ages of children or companions.

Biometric Data Any data related to biometrics, such as fingerprints or facial recognition.

 

Images, Videos, and Audio Data

This involves recordings of your voice (e.g., for quality assurance during customer service calls), footage from security cameras in public areas of our properties, and recordings from body-worn cameras used by our security personnel.  

 

Preferences

We may also gather details about your "Stay Preferences" to enhance your current and future experiences with us. This includes information about your interests, likes and dislikes about our services, dietary requirements, and other personal needs. Additionally, we may collect "Personal Preferences," which encompass details like significant anniversaries, preferred activities during your stay, hobbies, and details about your travel companions. If you provide Personal Data about others to us or our Service Providers (e.g., when making a reservation for someone else), you confirm that you have the necessary authority to do so, and you allow us to use the data in accordance with this Privacy Statement.

 

We collect personal information from you only under the following lawful bases:

 

Consent: We process your personal information only with your explicit consent, such as when you opt in to receive marketing communications.

 

Legal Obligation: We process your personal information when we have a legal obligation to do so, such as fulfilling financial and tax obligations based on your transaction history.

 

Performance of a Contract: We process your personal information when it is necessary to fulfil a contract with you, such as managing bookings, processing payments, or creating an account as requested by you.

If we request personal information to comply with a legal requirement or to perform a contract, we will clearly indicate this at the relevant time and inform you whether providing the information is mandatory, along with the potential consequences of not doing so.

 

Legitimate Interest: We process your personal information when it is in our legitimate interests and does not override your rights. In certain countries and regions, we may rely on legitimate interests to operate or improve our platform, communicate with you, verify security when you contact us, respond to queries, undertake marketing activities, or potentially detect or prevent illegal activities. We carefully balance our use of your personal information against your rights on a global scale.

We also collect other data that does not identify you:

 

 

Cookies

Cookies are small data files that allow a website to collect and store a range of data on your desktop computer, laptop or mobile device. Cookies help us to provide important features and functionality on our websites and we use them to improve your customer experience. Please see our separate Cookie Notice here.

 

How we collect data from you:

 

We gather personal information and other data from other companies for various reasons outlined in this Privacy Statement. This includes tailoring services, communication, loyalty programs, and meeting business objectives.

 

On-Property and/or Travel Providers:

 

Your personal information and other data may be collected from various outlets at our properties, such as spas, restaurants, and concierge services. Online Services login to access third-party services, we collect personal information and other data. This includes partners in airlines, car rentals, and social media platforms.

 

Promotional Activity:

 

We collect personal information and other data from third parties offering promotions such as sweepstakes, contests, or special offers.

 

Other Sources & Service Providers

 

Personal information and other data are gathered from various third-party sources including public databases, joint marketing partners, financial service providers, and online travel agencies.

 

Online Services:

 

Interaction with our Online Services, including browsing, reservations, purchases, communications, social media engagement, and participation in surveys or promotions, leads to the collection of personal or other data.

 

Customer Support Centres

 

Personal information is collected when making reservations via phone, email, fax, or online chat services, and these interactions may be recorded for quality assurance and training purposes.

 

Internet-Connected Devices

 

Personal and other data may be obtained from internet-connected devices in our properties, such as smart home assistants, to tailor accommodations and enhance guest experiences.

 

Minors

Red Carnation Hotel respects the privacy of individuals under the age of majority in their respective jurisdiction. We do not knowingly collect, disclose, or sell personal information of minors without permission from a parent or guardian.

 

Closed Circuit Television (CCTV)

 

At Red Carnation Hotel properties, we employ closed circuit television (CCTV) and other security measures to safeguard our staff, guests, and visitors. These measures may capture or record images in public areas, as well as information related to your location while on our properties (via keycards and other technologies). This is done in accordance with applicable laws aimed at protecting the safety and security of everyone on our premises. We retain CCTV footage in alignment with our data retention policies, ensuring it is kept for the duration necessary to fulfil its intended purpose or as mandated by law. You may have the option to request access to CCTV images within the timeframe specified by applicable law and as permitted by law.

We may contact you directly to inform you about our products, services, and promotions that we think might interest you. This involves recognising you as a customer, understanding your preferences, and customising content and ads just for you. We use various methods for direct marketing, including text messages, phone calls, social media targeting, direct mail, web ads, and in-app messages.

 

We do not use or reveal your personal data for direct marketing unless:

 

• You have given us consent, like through an opt-in box on our website or form, or
• You've made a booking with us and there's a legitimate business reason to do so for similar products or services.

 

If you no longer wish to receive direct marketing, you can manage your communication preferences on your online account or unsubscribe using the link provided at the end of each electronic communication.

 

In addition to data protection laws, we may also need to follow additional rules governing direct marketing, such as the EU Privacy and Electronic Communications Directive 2009/136/EC. "Direct marketing" refers to marketing material or advertising directed at a specific individual.

 

We'll use your personal data to send you marketing information (including ads and promotions) about travel services:

 

• Offered by us,
• Available through third parties partnered with us,
• Provided by other companies within our group (i.e., the Travel Corporation Group), and
• Offered by third parties selected by us. However, we won't share your details with third parties without your explicit consent.

 

We'll only send you marketing information about the categories of travel services you've chosen. We'll also only contact you in the manner you've agreed to (e.g., email or SMS).

 

Sometimes, we may share your contact details (like name, email address, postal address, telephone number, mobile number, fax number, and preferences) with:

• Other companies within our The Travel Corporation group, subject to the same privacy policy requirements, and
• Other companies offering services that could enhance your travel experience or assist with your travel plans ("third parties"). These third parties may then reach out to you directly with marketing information about their services and products. They are not part of The Travel Corporation and aren't bound by this privacy policy. However, we ensure that our partners will only contact you in the manner you agreed to (e.g., email, text) when you provided consent.

 

Advertising

We may provide advertisers with general information about how our websites are used. This information is usually anonymous and does not identify individual users.

 

Marketing with Your Consent

We will only use your personal information for marketing purposes if you have given us your consent. You can withdraw your consent at any time. We'll make sure you have clear options for opting in or out of marketing communications.

 

Withdrawing from Direct Marketing

You are free to stop receiving marketing information from us at any time by contacting us as detailed in this privacy notice or by following the instructions set out in our marketing communications. If you email us to withdraw your consent, it would be helpful if you could insert the word “Unsubscribe” as the subject heading.”

When you elect to stop receiving marketing information we will, from that point onwards, not share your information further with any other third parties.

You are also free, at any time, to notify any third party to whom we have previously passed your contact details to, that you no longer wish to receive marketing communications from them.

We transfer your personal data to third parties in the following circumstances:

 

We may disclose your personal data to third parties (including intermediaries) as necessary to carry out any checks regarding your financial standing. The identities of these parties may change from time to time. They may include credit reference agencies and other companies for use in credit decisions, for fraud prevention and to pursue debtors.

 

We disclose your personal data to third parties (including intermediaries) as necessary to deal with any booking enquiry being made by or for you, to make any booking requested by or for you, to perform and administer any booking for you or other contract with or in respect of you. This may include;

 

• To collect payments to be made by you
• To investigate and respond to complaints
• To enforce any booking or other contract with you

 

Such third parties may include any suppliers or sub-contractors and their agents (e.g. airlines, coach, ferry or train companies, hoteliers, hire companies, cruise companies, tour operators etc.). The identities of these parties may change from time to time and are engaged so we can provide our services to you. We ensure that these third parties carry their tasks with the same level of protection on your personal data that you will expect from us.

 

Suppliers Of Travel And Other Services

We may disclose your personal data to any third party (e.g. supplier, contractor sub-contractor) we make any enquiries with concerning or engage or sub-contract to perform any booking or other contract, including to provide any travel, tour or other products or services we have agreed to provide to you in order to perform our contract with you. We may disclose your personal data to any supplier with whom we make any enquiry concerning or book any travel or other products and services for you as agent (whether as agent for you, someone representing you, or the supplier), such as a tour operator.  Details of any third party tour operators or other third parties who will be responsible for or supply you with the travel services booked or enquired about, may be obtained from us on request, and may be stated in any tour or other brochure provided by us.

 

Business Function Outsourcing

Where we use third parties to host, provide, operate or supply any part of our websites, databases, systems, business, or services, or carry out on our behalf any of our business functions or actions (including sending mail, processing payments, providing marketing assistance, providing customer and advertising analysis through third-party ad-tech vendors, and providing customer services), then we may provide your personal data to them as required for use for or processing as part of those purposes. We ensure that these third parties treat your personal data with the same level of care and duty as us.

 

Public Forums Etc.

Where any facility on our website is clearly designed to make certain of your personal data public (e.g. posts you make to any public forum or reviews facility), then any personal data you provide in relation to that forum or other facility, which is provided in circumstance where it is clear that it is intended to be published, will be disclosed to the public accordingly, subject to moderation by us and to the terms of this privacy policy.

 

Legal Requirements

We may supply personal data to a government authority or regulator where required to:

 

• Comply with a legal requirement
• For the administration of justice or when required by a public enforcement body
• For the purposes of customs, visas and immigration.

 

We may disclose your personal data where otherwise required by or permitted by law.  

 

Business Customers who are Businesses (Not Individuals)

If you are a business or organisation (“Business Customer”), and we are holding personal data of any authorised representative (such as an employee agent, employee, officer, owner, partner, or director), then we may disclose to them that personal data. If a Business Customer is making a booking or booking enquiry on behalf of an individual, with that person’s authority, then we may disclose to our Business Customer that individual’s personal data as reasonably required in connection with such booking or enquiry, or the subsequent performance of or payment for any booking made.

 

Business Acquirers

If our business is ever transferred to a third party, then your personal data will be transferred to the acquirer to enable them to continue our business. We will ensure that the acquirer is bound by terms similar to this privacy policy to protect your personal data.

 

How Third Parties Will Handle Your Personal Data

Where we provide your personal data to a third party one of the following two circumstances will apply:

 

Processing on Our Behalf

In some cases, your personal data may be held and otherwise processed by others on our behalf.  We have not included the names of our service partners as these will change over time. We will remain responsible for what they do with your personal data, and your personal data will only be held and processed by them in accordance with our instructions and this privacy policy.  The sharing of your data is necessary for the performance of any contract with you and for the efficient provision of our services.

 

Processing on Their Own Account

In other cases, your personal data may need to be provided to them to be held and processed by them in their own right and on their own account.  In such case, they will have their own responsibility for your personal data, subject to their own privacy policy, and we will not be responsible for what they do with it following disclosure. This will only be done to perform the contract. When this happens, you will be informed by the third party, and they will provide their privacy policy to you.

We (and any affiliate, subcontractor or other person processing your personal data on our behalf) may transfer, store and otherwise process your personal data anywhere within the European Economic Area ('EEA') and the United Kingdom. 

 

We will only send your personal data outside the EEA and the United Kingdom to companies either within our group or to parties with whom we have a contract based on the Standard Contractual Clauses as published by the European Commission. We ensure your personal data is protected by requiring all our group companies to follow the same rules when processing your personal data. This means within our group and for those other organisations with whom we have contracts we ensure that we have in place adequate safeguards in respect of such transfers outside the EEA and the United Kingdom. You can find out about what adequate safeguards these are by contacting us using the details provided compliance@rchmail.com of this privacy notice.

We take appropriate technical and organisational measures to secure your information and to protect it against unauthorised or unlawful use and accidental loss or destruction, including:

 

• only sharing and providing access to your information to the minimum extent necessary, subject to confidentiality restrictions where appropriate, and on an anonymised basis wherever possible.
• using secured servers to store your information.
• verifying the identity of any individual who requests access to information prior to granting them access to the information.
• using Secure Sockets Layer (SSL) and Transport Layer Security (TLS) software or other similar encryption technologies to encrypt your personal and payment transactions.

 

Unfortunately, transmission of information over email is not secure, and if you submit any information to us over the internet by email, we will do our best to protect your personal data and have contractual processes in place with our service providers to do this. Once we have received your information, we will use relevant procedures and adequate security measures to prevent unauthorised access.

 

For your own privacy protection, we encourage you to maintain anti-virus and other malware protection software on your computers and other devices, and to maintain your own measures to protect your personal data. Please do not include sensitive personal data in any e-mails you may send to us, including payment card information.

 

We also encourage you to be careful about who you give personal data to. We never contact you to ask you for your payment card information, or sensitive personal data such as passport numbers or log-in details, and we will only ask you for such information in person or through our website, or by telephone in connection with a booking you are making or have made.  Please let us know if you someone purports to contact you in our name.

You have certain rights under data protection laws, which we summarise below. If you contact us about these rights, we may ask for proof of your identity before we act on any request, and we may refuse to act if you do not provide this, or your identity is not established by you. This is to ensure that your data is protected and kept secure. More information about your rights and our obligations can be found on the Information Commissioner Office website here.

 

To exercise any of your rights below, please send your request via email to compliance@rchmail.com. 

 

You may request the following information be provided to you:

 

• Whether we are processing personal data about you
• What personal data we are processing, including a request for a copy of your data
• What purposes we are processing data for
• From which sources we have collected the data
• Who we disclose the data to

 

We will act within one month after receiving a valid request (i.e. when we will have been able to identify you as the data subject). If your request is complex, or if we have a high volume of requests, we may extend this period for two additional months. We will advise you if this is the case.

 

The law does allow us, in certain cases, to refuse to act upon your request or to charge a reasonable administration fee, if we estimate that the request is manifestly unfounded or excessive. We will advise you at the time if this is the case along with your possibility of lodging a complaint with a supervisory authority and seeking a judicial remedy.

 

Rectification

You have the right to have your personal data amended if it is inaccurate or incomplete.

 

Right to Object

You have the right to object to the use of your personal information for direct marketing or where we use it on the basis that we say we have a legitimate interest in using it.

 

Right to Request Access

You have the right to request access to the information we hold about you.

 

Erasure

You have the right to have your personal information deleted or removed in the following circumstances:

 

• The data is no longer necessary for the purpose for which it was originally collected or otherwise processed.
• Where you withdraw your consent, where consent was used as the legal basis for processing.
• Personal data has been unlawfully processed.
• When you object to the processing, and we have no overriding legitimate interest for continuing the processing.
• Erasure is required for compliance with a legal requirement; or
• Data has been collected in relation to the offering of online services to a child.

When a request for erasure is valid, we will take reasonable steps to inform third parties which are processing the personal data that you have requested us to delete.

 

We have the right to refuse to act on a request of erasure if the data is necessary for:

 

• Exercising the right of freedom of expression and information.
• Compliance with a legal obligation.
• The establishment, exercise, or defence of legal claims.

 

Right to Receive a Copy

You have the right to receive your personal data which you have provided to us, in a structured, commonly used, and machine-readable format and to transmit those data to another controller, when:

 

• the processing is based on consent or on a contract; and
• the processing is carried out by automated means

 

Restrict Processing

You have the right to obtain from us the restriction of processing of your personal data where one of the following applies:

 

• You contest the accuracy of the personal data, for a period enabling us to verify the accuracy of the personal data.
• The processing is unlawful, and you oppose the erasure of the personal data and request the restriction of their use instead.
• We no longer need the personal data for the purposes of the processing, but the data is necessary for you for the establishment, exercise, or defence of legal claims.
• You have objected to processing pending the verification whether our legitimate grounds override yours.

Where the processing of your personal data is restricted, at the exception of storage, we will only process your personal data with your consent, for the establishment, exercise, or defence of legal claims, for the protection of the rights of another individual or organisation, or because we are legally required to do so. We will inform you before the restriction of processing is lifted.

 

Right to Withdraw Your Consent

You are free to withdraw your consent at any time, where we rely on your consent as a legal basis for processing. Please contact us using the details outlined in Section 16 of this policy. See also section 10.3 for details as to how to object to our direct marketing communications.

 

Right to Lodge a Complaint with a Supervisory Authority

Right to Lodge a Complaint with a Supervisory Authority

We adhere to data protection laws regulated by various supervisory authorities worldwide. For specific regions, these include:

 

Geneva, Switzerland: Office of the Geneva Data Protection Authority (GDPA)

 

• Address: Rue de Lausanne 45, 1202 Geneva, Switzerland
• Phone: +44 22 388 9900 
• Website: GDPA website

 

Guernsey: Office of the Data Protection Authority (ODPA)

 

• Address: St Martin’s House, Le Bordage, St Peter Port, Guernsey, GY1 1BR
• Phone: +44 1481 742074
• Website: ODPA website

 

Ireland: Data Protection Commission (DPC)

 

• Address: 21 Fitzwilliam Square South, Dublin 2, D02 RD28, Ireland
• Phone: +353 57 868 4800
• Website: DPC website

 

South Africa: Information Regulator (South Africa)

 

• Address: 33 Hoofd Street, Forum III, 3rd Floor Braampark, Braamfontein, Johannesburg, 2001, South Africa
• Phone: +27 10 023 5200
• Website: Information Regulator website

 

United Kingdom: Information Commissioner's Office (ICO)

 

• Address: Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, United Kingdom
• Phone: +44 303 123 1113
• Website: ICO website

 

Each supervisory authority has the authority to compel compliance with data protection laws and impose fines for non-compliance. We encourage you to contact us first with any complaints or concerns. You can find our contact details in Section 16 of our privacy notice. If you reside in the European Economic Area and are dissatisfied with our handling of your request or believe we have violated applicable data protection laws, you may also lodge a complaint with the competent supervisory authority in your country or market of residence.

 

Period for Retaining your Personal Data

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. 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. If you would like to know more about our data retention policy, please ask us.

 

Changes to this privacy policy

We keep our privacy notice under regular review to make sure it is up to date and accurate. When we make any change, we will notify you by email of such change. You can check the top of the document to see the latest version in force.

 

Contacting Us

If you have any questions about our privacy policy or about how we process your personal data, including any complaints, please contact us either by e-mail to compliance@rchmail.com or by post to Red Carnation Hotels Marketing, 14 Grosvenor Place, London, SW1X 7HH.