At Distinct Group, we’re committed to protecting and respecting your privacy.
This Policy explains when and why we collect personal information about people who visit our website, how we use it, the conditions under which we may disclose it to others and how we keep it secure.
We may change this Policy from time to time so please check this page occasionally to ensure that you’re happy with any changes. By using our website, you’re agreeing to be bound by this Policy.
Any questions regarding this Policy and our privacy practices should be sent by email to the address firstname.lastname@example.org or by writing to Distinct Group Ltd, c/o The Bedford Swan Hotel, The Embankment, Bedford, Bedfordshire MK10 1RW. Alternatively, you can telephone +44 (0) 1234 346565.
Who are we?
Distinct Group Limited is a company registered in England and Wales with the company registration number 08659395 and having a registered business address at 2A Ferdinand Place, London NW1 8EE.
How do we collect information from you?
We obtain information about you in the following ways:
Information you give us directly
For example, we may obtain information about you stay at one of our hotels, contact us about our rooms or services or when you register to receive one of our monthly newsletters.
When you visit this website
We, like many companies, automatically collect the following information:
- technical information, including the type of device you’re using, the IP address, browser and operating system being used to connect your computer to the internet. This information may be used to improve the services we offer.
- information about your visit to this website, for example we collect information about pages you visit and how you navigate the website, i.e. length of visits to certain pages, products and services you viewed and searched for, referral sources (e.g. how you arrived at our website).
When you interact with us on social media platforms such as Facebook and Twitter we may obtain information about you (for example, when you publicly tag us in a photo). The information we receive will depend on the privacy preferences you have set on those types of platforms.
What type of information is collected from you?
The personal information we collect, store and use might include:
- your name and contact details (including postal address, email address and telephone number);
- your date of birth;
- information about your activities on our website and about the device used to access it, for instance your IP address and geographical location;
- your bank or credit card details. If you make a purchase, your card information is not held by us, it is collected by our third party payment processors, who specialise in the secure online capture and processing of credit/debit card transactions; and
- any other personal information shared with us.
Data protection laws recognise certain categories of personal information as sensitive and therefore requiring greater protection, for example information about your health, ethnicity and religion.
We do not usually collect sensitive data about you unless there is a clear and valid reason for doing so and data protection laws allow us to.
Where appropriate, we will make why we are collecting this type of information and what it will be used for clear.
How is your information used?
We may use your information to:
- process bookings and orders that you have submitted;
- carry out our obligations arising from any service contracts entered into by you and us;
- keeping a record of your relationship with us;
- conducting analysis and market research so we can understand how we can improve our services, products or information;
- dealing with entries into a promotional competition;
- seek your views or comments on the services we provide;
- notify you of changes to our services;
- send you communications which you have requested and that may be of interest to you, for example, new services, products and services offered by us that are similar to those that we have already provided to you, events and exhibitions, promotions and special offers.
How long is your information kept for?
We keep your information for no longer than is necessary for the purposes it was collected for, The length of time we retain your personal information for is determined by operational and legal considerations. For example, we are legally required to hold some types of information to fulfil our statutory and regulatory obligations (e.g. health/safety and tax/accounting purposes).
We review our retention periods on a regular basis.
Who has access to your information?
We will not sell or rent your information to third parties.
We will not share your information with third parties for marketing purposes.
Third Party Service Providers working on our behalf: We may pass your information to our third party service providers, subcontractors and other associated organisations for the purposes of completing tasks and providing services to you on our behalf (for example to send you mailings). However, when we use third party service providers, we disclose only the personal information that is necessary to deliver the service and we have a contract in place that requires them to keep your information secure and not to use it for their own direct marketing purposes. Please be reassured that we will not release your information to third parties for them to use for their own direct marketing purposes, unless you have requested us to do so, or we are required to do so by law, for example, by a court order or for the purposes of prevention of fraud or other crime.
When you are using our secure online payment pages, your payment is processed by a third party payment processor, who specialises in the secure online capture and processing of credit/debit card transactions. If you have any questions regarding secure transactions, please contact us.
Data protection law requires us to rely on one or more lawful grounds to process your personal information. We consider the following grounds to be relevant:
Where you have provided specific consent to us using your personal information in a certain way, such as to send you email, text and/or telephone marketing.
Performance of a contract
Where we are entering into a contract with you or performing our obligations under it like when you buy our named products and services.
Where necessary so that we can comply with a legal or regulatory obligation to which we are subject, for example where we are ordered by a court or regulatory authority.
Where it is necessary to protect life or health or a safeguarding issue which requires us to share you information with the emergency services.
Where it is reasonably necessary to achieve our or others’ legitimate interests (as long as what the information is used for is fair and does not duly impact your rights).
We consider our legitimate interests to be running Distinct Group as a company in pursuit of our aims and ideals. For example to:
- send postal communications which we think will be of interest to you;
- conduct research to better understand who our customers are to better target our marketing;
- monitor who we deal with to protect the company against fraud, money laundering and other risks;
- enhance, modify, personalise or otherwise improve our services/communications for the benefit of our customers; and
- understand better how people interact with our website.
When we legitimately process your personal information in this way, we consider and balance any potential impact on you (both positive and negative), and your rights under data protection laws. We will not use your personal information where our interests are overridden by the impact on you, for example, where use would be excessively intrusive (unless, for instance, we are otherwise required or permitted to by law).
When we use sensitive personal information, we require an additional legal basis to do so under data protection laws, so will either do so on the basis of your explicit consent or another route available to us at law (for example, if we need to process it for employment, social security or social protection purposes, your vital interests, or, in some cases, if it is in the public interest for us to do so).
We may use your contact details to provide you with information about our services if we think it may be of interest to you.
We will only send you marketing communications by email, text and telephone if you have explicitly provided your prior consent. You may opt out of our marketing communications at any time by clicking the unsubscribe link at the end of our marketing emails.
We may send you marketing communications by post unless you have told us that you would prefer not to hear from us.
You have a choice about whether or not you wish to receive information from us. If you do not want to receive direct marketing communications from us about our services, then you can change your marketing preferences (including to tell us that you don’t want to be contacted for marketing purposes) at any time by contacting us by email: email@example.com.
We will not use your personal information for marketing purposes if you have indicated that you do not wish to be contacted and will retain your details on a suppression list to help ensure that we do not continue to contact you. However, we may still need to contact you for administrative purposes.
Under UK data protection law, you have certain rights over the personal information that we hold about you. Here is a summary of the rights that we think apply:
Right of access
You have a right to request access to the personal data that we hold about you. You also have the right to request a copy of the information we hold about you, and we will provide you with this unless legal exceptions apply.
If you want to access your information, please send a description of the information you want to see and proof of your identity by post to the address provided below.
Right to have your inaccurate personal information corrected
You have the right to have inaccurate or incomplete information we hold about you corrected. The accuracy of your information is important to us. If you change email address, or if you believe any of the other information we hold is inaccurate or out of date, please contact us via email or post (see below).
Right to restrict use
You have a right to ask us to restrict the processing of some or all of your personal information if there is a disagreement about its accuracy or we’re not lawfully allowed to use it.
Right of erasure
You may ask us to delete some or all of your personal information and in certain cases, and subject to certain exceptions; we will do so as far as we are required to.
Right for your personal information to be portable
If we are processing your personal information (1) based on your consent, or in order to enter into or carry out a contract with you, and (2) the processing is being done by automated means, you may ask us to provide it to you or another service provider in a machine-readable format.
Right to object
You have the right to object to processing where we using your personal information (1) based on legitimate interests, (2) for direct marketing or (3) for statistical/research purposes.
If you want to exercise any of the above rights, please email us at firstname.lastname@example.org or write to Distinct Group Ltd, c/o The Bedford Swan Hotel, The Embankment, Bedford, Bedfordshire MK10 1RW. We may be required to ask for further information and/or evidence of identity. We will endeavour to respond fully to all requests within one month of receipt of your request, however if we are unable to do so we will contact you with reasons for the delay.
Please note that exceptions apply to a number of these rights, and not all rights will be applicable in all circumstances. For more details we recommend you consult the guidance published by the UK’s Information Commissioner’s Office, https://ico.org.uk/
Keeping your information safe
When you give us personal information, we take steps to ensure that appropriate technical and organisational controls are in place to protect it.
Any sensitive information (such as credit or debit card details) is encrypted and protected with the following software 128 Bit encryption on SSL. When you are on a secure page, a lock icon will appear on the bottom of web browsers such as Microsoft Internet Explorer.
Non-sensitive details (your email address etc.) are transmitted normally over the Internet, and this can never be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, we cannot guarantee the security of any information you transmit to us, and you do so at your own risk. Once we receive your information, we make our best effort to ensure its security on our systems. Where we have given (or where you have chosen) a password which enables you to access certain parts of our website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
Use of ‘cookies’
It is possible to switch off cookies by setting your browser preferences. For more information on how to switch off cookies on your computer, visit our full cookies policy https://distinctgroup.co.uk/cookies-policy/. Turning cookies off may result in a loss of functionality when using our website.
Links to other websites
In addition, if you linked to our website from a third party site, we cannot be responsible for the privacy policies and practices of the owners and operators of that third party site and recommend that you check the policy of that third party site.
Changes to this Policy
Any changes we may make to this policy in the future will be posted on this website so please check this page occasionally to ensure that you’re happy with any changes. If we make any significant changes we’ll make this clear on this website.
Review of this Policy
We keep this policy under regular review. This policy was last updated 1st July 2020.