privacy Policy

Estee Hotels LLP t/a Mercure Newbury West Grange Hotel (referred to herein as "MNWG," "we," and "us") is committed to protecting your privacy and wants you to be familiar with how we collect, use, and disclose Personal Data (as defined below). This Privacy Policy (this "Policy") describes our practices in connection with information that we collect through our websites and mobile applications (collectively, the "Site") and by other means as described in this Policy. This Policy also applies to the collection, use, and disclosure of such information by our group (collectively known as “Estee Group Companies”). References to “MNWG,” “we” and “us” throughout this Policy, depending upon the context, collectively refer to MNWG and Estee Group Companies.

By using this Site or by providing Personal Data (as defined below) to MNWG, you consent to all actions taken by us with respect to your Personal Data as set forth in this Policy. If you do not agree to the terms and conditions of this Policy, please do not use the Site or provide any Personal Data to MNWG through our Site or otherwise.

This Policy does not address the collection, use, or disclosure of information by third parties, including entities authorized by MNWG or by an authorized licensee of MNWG to operate Mercure Newbury West Grange hotel and properties ("Licensed Hotels"), and third-party affiliated organizations permitted to sublicense Licensed Hotels outside the United Kingdom in various countries and territories throughout the world ("Affiliates"). Please be aware that Licensed Hotels and Affiliates are independent entities neither owned nor controlled by MNWG or Estee Group Companies. Licensed Hotels and Affiliates might have their own privacy policies, which might be different from this Policy. To learn about the privacy practices of any of the Licensed Hotels or Affiliates, please review their respective privacy policies, not this Policy.

While this Policy is intended to describe the broadest range of our information processing activities globally, those activities may be more limited in some jurisdictions based on the restrictions of their laws.

PERSONAL INFORMATION WE COLLECT

MNWG may collect "Personal Data" from you, meaning information that identifies you as an individual or from which you may be identified.  For example, we may collect:

• contact information, such as your name, mailing address, e-mail address, and telephone number;
• credit card number or other payment account number, billing address, and other payment and billing information (“Payment Information”);
• ALL loyalty program member information, online user account details, profile or password details and any frequent flyer or travel partner program affiliation;
• records and copies of your correspondence if you contact us;
• information necessary to fulfill special requests (e.g., health conditions that require specific accommodation);
• guest stay information, including the hotels where you have stayed, date of arrival and departure, and goods and services purchased;
• information collected through the use of closed circuit television systems, card key and other security systems; and
• in limited cases, information relating to the credit of customers.

We may collect Personal Information:

• through the Site;
• through reservation and call centers;
• through social media and brand channels (e.g. Facebook, Twitter);
• from Licensed Hotels, Affiliates, or other third parties; or
• when you otherwise voluntarily provide it to us, including in connection with our loyalty program.

We may also combine Personal Data we collect with publicly available Personal Data and Personal Data we receive from others or cross-reference with others. The collection and use of Personal Data, whether separately or combined, is done in accordance with and for the purposes described in this Policy.

If you voluntarily share "Sensitive Personal Data" (e.g., Personal Data related to your health, racial or ethnic origins, political opinions, religious or similar beliefs, membership of a trade union or professional association, physical or mental health or condition, genetic data, sexual life or judicial data) with us, that information may be used to provide a better experience and meet your particular needs.  For example, if you voluntarily convey a health-related need to us, we may store and use that information in order for a Licensed Hotel to provide a room with appropriate amenities. We do not collect or store Sensitive Personal Data unless it is voluntarily provided by you.  By providing such Sensitive Personal Data, you expressly consent to our collection, processing and storage of that information in accordance with the terms of this Privacy Policy.

HOW WE USE THE PERSONAL INFORMATION WE COLLECT

MNWG collects Personal Data about guests, visitors to the Site, and others, so that we can provide an experience that is responsive to the needs of such individuals. MNWG may collect, use, and disclose Personal Data for one or more of the following purposes:

• Fulfillment of Reservation or Information Requests: To fulfill your requests such as completing a credit card transaction or booking a reservation at any Licensed Hotel worldwide through our central reservation system (who could be located outside the UK/EEA), or responding to your requests that we send marketing, informational or other newsletters to you (and to personalize such newsletters and the Site to your preferences). For example, when you make a reservation through MNWG's central reservation system, we may collect Payment Information from you, and may use and disclose such Payment Information to fulfill your reservation. MNWG maintains a worldwide accessible website, call centers, and database computers in the United Kingdom and other locations around the world, which are intended to help MNWG conduct business and to facilitate the operation and maintenance of its central reservation system.
• Membership Programs: To administer and operate voluntary membership programs, including loyalty programs such as ALL, which allows members to earn and redeem rewards, points, or credits in connection with the programs. For complete Loyalty program terms and conditions, visit https://all.accor.com/loyalty-program/reasonstojoin/index.en.shtml
• Administrative and Other Communications: To send you important information regarding the Site, changes to our terms, conditions and policies, or other administrative information (e.g., information about your travel reservations, such as reservation confirmations).
• Marketing Communications: We may use your Personal Data to determine whether you are eligible for and/or inform you, if you have provided your consent, of products, programs, enhancements, events, special offers, and services of MNWG and third parties (including Licensed Hotels and Affiliates) that might be of interest to you. We promise to only send you relevant and timely marketing communications and we will give you the opportunity to decline to receive some or all of these communications every time we send them. For more information, see the “Your Choices” section of this Policy below and if you wish you can Opt-out here to receiving further communications. Please allow us up to one month to process all data regarding your opt out.
• Promotions. To operate sweepstakes, contests, or other marketing or promotional activities (collectively, "Promotions"). We typically ask you for certain Personal Data when you enter or participate in such Promotion and, if applicable, win a prize, and we use such Personal Data to administer the Promotion. Participation in these Promotions is completely voluntary, and you have a choice whether to disclose your Personal Data. You should carefully review the rules, if any, of each Promotion in which you participate, as it may contain additional important information about MNWG's use of your Personal Data. To the extent that the Promotion’s rules concerning the treatment of your Personal Data conflict with this Policy, the Promotion’s rules shall control.
• Surveys: To conduct or facilitate surveys and to ask for your responses to questionnaires in order to provide better products and services to guests and Site visitors. Completion of any surveys or questionnaires is strictly voluntary.
• Customer Care: To track, process, and respond to customer care enquiries and to enhance and improve the customers experience. We may also transmit your Personal Data to third party service providers, Affiliates, and Licensed Hotels to allow those third parties to track, process, and respond to customer care inquiries.
• Internal Business Purposes: For our internal business purposes, such as data analysis, audits, developing new products, enhancing the Site, improving our services, identifying usage trends and visiting patterns, determining the effectiveness of our Promotions, and meeting contractual obligations (e.g., a contractual obligation with regard to earning or redeeming points or miles through our airline partners).
• Our Rights and Legal Obligations: To: (i) comply with legal and regulatory requirements or demands in accordance with applicable law, a court order, subpoena or other legal process, (ii) detect, prevent, or take action against illegal activities, suspected fraud, or situations involving potential threats to the rights, privacy, safety, or property of MNWG, Licensed Hotels, Affiliates, you, or others; or (iii) enforce or apply our Terms of Use and/or other agreements and policies.
• E-mails to Friends: To permit you to forward information about our products, services, and Licensed Hotels to another individual, such as a friend or co-worker. If you wish to use this feature, you may be required to provide to us, and we may use, the applicable individual's name and e-mail address to facilitate your sending of such messages to such individual (and any Personal Data—such as your name and your email address—provided in connection with sending such information, will be disclosed to such individual). By using this functionality, you affirm that you are entitled to use and to provide to us the recipient's name and e-mail address for this purpose. We will not seek to use the applicable individual's Personal Data for any purpose other than to allow the e-mail to be sent, unless we disclose such other purpose to you at the time that you provide such Personal Data to us or unless we have separately collected such Personal Data through other means.
• Co-brand credit card:  To promote and asses eligibility for Accor hotels ’s co-brand credit cards.
• We may also use your Personal Data in other ways as described when you provide such information to us or for other purposes with your consent.

HOW WE SHARE AND DISCLOSE PERSONAL INFORMATION

• Estee Group Companies: We may share your Personal Data with Estee Group Companies so that they may use such Personal Data for the purposes described in this Policy. Estee Group Companies are required to protect your Personal Data consistent with this Policy. MNWG is the entity that is responsible for the management of such jointly used Personal Data.

• Licensed Hotels, Affiliates, and Third Parties: We may also share your Personal Data with Licensed Hotels, Affiliates, Estee Group Companies and other third parties located around the world for the purposes described in this Policy (e.g., to send your reservation information to the applicable Licensed Hotel or Affiliate, to provide Licensed Hotels, Affiliates, or other third parties with information on the rewards, points, or credits earned by you in connection with Estee Group, and to allow Licensed Hotels, Affiliates, and third parties to determine whether you are eligible for and/or inform you, if you have provided your consent, of products, programs, services, and promotions that they believe might be of interest to you).

• Third-Party Service Providers: MNWG relies on numerous third-party service providers to provide certain products and services on our behalf, including reservation services, credit card/payment processing and billing, IT services, customer care, e-mail delivery services, communication and delivery of promotional and marketing materials via e-mail and direct mail, administering guest surveys and Promotions, administration, data analysis, and other similar services. We may share your Personal Data for the purpose of enabling these third parties to provide such services or as otherwise necessary for the ongoing operation of MNWG's business, including operation of programs. Some of these third party service providers may be located overseas and in particular outside the UK/EEA. When we do outsource the processing of your Personal Data to third parties or provide your Personal Data to third party service providers, we require those third parties to protect your Personal Data with reasonable security measures and to limit their use only to the purposes for which we have disclosed it to them.

• Accor Partners: MNWG may also share your Personal Data with companies that we have partnered with or that are participants in our loyalty program to allow you to earn and redeem rewards, points, or credits in connection with your loyalty membership and in accordance with your chosen earning and spending preferences (e.g., selection of a particular airline partner through which you can earn points).
• Promotions: Personal Data submitted in connection with Promotions may be shared with third-party sponsors of such Promotions (irrespective of whether such Promotions are hosted by us), or otherwise in accordance with the rules applicable to such Promotion.
• Assignment: In the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of MNWG’s or the Estee Group Companies’ business, assets, or stock (including in connection with any bankruptcy or similar proceedings), we may transfer any and all information that we collect pursuant to this Policy.  Any successor, assignee or transferee may use your Personal Data as described in this Policy.
• Social Networking Forums: MNWG may make available interactive services (e.g., message boards, forums, and blogs) through which you may post information and materials on the Site. Please note that any information you disclose through such services becomes public information and may be available to visitors to the Site and to the general public. We urge you to exercise discretion and caution when deciding to disclose your Personal Information, or any other information, through these services. WE ARE NOT RESPONSIBLE FOR THE USE OF ANY PERSONAL DATA THAT YOU VOLUNTARILY DISCLOSE THROUGH SUCH SERVICES.
• Law Enforcement; Emergencies; Compliance. We may disclose your Personal Data: (i) when we have reason to believe that it is necessary to identify, contact, or bring legal action against persons or entities that may be causing injury to you, MNWG, MNWG Group Companies, Licensed Hotels, Affiliates, or others; (ii) when we believe that applicable law or regulation (including laws and regulations outside your country of residence) requires it; (iii) as mandated by subpoena, court order, or legal process; (iv) to establish or exercise our legal rights, defend against legal claims, or protect our operations or those of any Estee Group Companies, Licensed Hotels, or Affiliates; (v) to protect the rights, privacy, safety, or property of MNWG, MNWG Group Companies, Licensed Hotels, Affiliates, you, or others; and (vi) to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our Terms of Use or other agreements or policies, or as otherwise required or permitted by law.
• Credit Authorization:  When you apply for a credit, your Personal Data will be used and disclosed to appropriate third parties in accordance with applicable laws for the purpose of determining whether you are eligible for the creditd and whether the card issuer will grant and/or maintain a line of credit to you.

MNWG - CONTROLLER OF YOUR PERSONAL DATA

MNWG is registered with the Information Commissioners office (No.[TBC]). For the purposes of the Data Protection Act 1998, we are a data controller.NON-PERSONAL INFORMATION

MNWG may also collect “Non-Personal Information,” meaning aggregated and/or anonymized information, demographic information, and any other information that does not reveal your specific identity.  Because Non-Personal Information does not personally identify you, we may use and share such information with MNWG Group Companies, Licensed Hotels, Affiliates, and other third parties for any purpose, including without limitation to facilitate and improve your ongoing access to and use of our Site, to best tailor our services to suit personal interests, to analyze visiting patterns, enhance and improve customer service, and for our other business purposes.  As you navigate the Site, we and our service providers may collect certain Non-Personal Information such as your computer type (Windows or Macintosh), screen resolution, OS version, Internet browser, and Internet browser version using automatic data collection technologies, such as "cookies" and so-called "pixel tags," "web beacons," "clear GIFs," and other similar technologies.  .

IP ADDRESSES

Your IP address is a number that your Internet Service Provider automatically assigns to the computer that you are using to access the Site. This number is identified and logged automatically in our server log files whenever users visit the Site, along with the time of each visit and the page(s) that were visited. Collecting IP addresses is standard practice on the Internet and is done automatically by many websites. We use IP addresses for purposes such as calculating Site usage levels, helping diagnose server problems, validation of a legitimate user session via Google® captcha and administering the Site. Please note that we treat IP addresses, server log files, and related information as Non-Personal Information, except when we are required to do otherwise under applicable law.

THIRD-PARTY SITES

The Site may contain links to third-party websites. These linked sites (which may include the websites of Licensed Hotels, Affiliates, and various partners or other third parties) are not under MNWG's control, and we are not responsible for the privacy practices or the contents of any such linked site (or any link contained in any linked site). We provide such links only as a convenience, and the inclusion of a link on the Site does not imply endorsement of the linked site by MNWG or the Estee Group. If you decide to access any of the third-party websites linked to this Site, you do so entirely at your own risk and subject to the terms and conditions of use and privacy policies for such websites. If you provide any Personal Data through any such third-party website, your transaction will occur on such third party website (not this Site) and your Personal Data will be treated in accordance with the privacy policy of that third party. PLEASE NOTE THAT THIS POLICY DOES NOT ADDRESS THE PRIVACY OR INFORMATION PRACTICES OF ANY THIRD PARTIES, INCLUDING LICENSED HOTELS AND AFFILIATES.

SECURITY

Because the security of your Personal Data is important to us, we have implemented security measures that provide reasonable precautions against the unauthorized access, disclosure, alteration, or destruction of Personal Data.  The Personal Data we collect from you online is stored by us and/or our service providers and protected through a combination of physical and electronic access controls, firewall technology, and other reasonable security measures. Nevertheless, such security measures cannot prevent all loss, access, misuse, or alteration of Personal Data, and, to the fullest extent permitted by law, we are not responsible for any damages or liabilities relating to any such incidents. Where required by law, we will notify you of any such loss, access, misuse, or alteration of Personal Data that may affect you, so that you can take the appropriate actions to protect your rights.

Please do not send us your payment information or Sensitive Personal Data through e-mail or any undesignated area (e.g., submission of your credit card number in a "comment" field). If you have reason to believe that your interaction with us is no longer secure (e.g., if you feel that the security of any account you might have with us has been compromised), you must immediately notify us of the alleged problem by contacting our Customer Care Department as set forth below in this Policy. Please note that, if you choose to notify us via physical mail, this will delay the time it takes for us to respond to the alleged problem.

YOUR CHOICES

You may always choose what Personal Data (if any) you wish to provide to us. However, if you choose not to provide certain details, some of your experiences with us may be affected (for example, we cannot take a reservation without a name, and if we cannot disclose your Personal Data to Licensed Hotels or Affiliates, we may be unable to provide you with all or certain reservation services, other services, or membership-program-related benefits. Similarly, if we cannot disclose your Personal Data to other third parties, such as Estee Group partners (e.g., airlines, card issuers and other third parties), we may not be able to provide all of the available membership program services to you (e.g., earning of frequent customer points with such companies), or the provision of such services may be delayed).

If you do not wish for us to use your contact information to promote our own or third parties' products or services you can Opt-out here, or you can contact our Customer Care Department as set forth in the “Contacting Us” section of this Policy below. If you have received a promotional e-mail from us and no longer wish to receive such e-mails going forward, you may opt-out by using the unsubscribe function in the e-mail you have received from us.  Please note that when you unsubscribe from receiving promotional e-mails from us, your contact details will be “suppressed” rather than deleted. This will ensure that your request is recorded and retained unless you provide a later consent that overrides it. 

If you have a Accor account, we ask you to indicate your communication preferences at the time you become a member of the ALL program. Once you have indicated your preferences, you can change them by logging into your account.

Please note that if you opt-out as described above, we will not be able to remove your Personal Data from the databases of Licensed Hotels, Affiliates, or other third parties with which we have already shared your Personal Data.

We are entitled to assume you do not object to our doing any of the things mentioned in this statement unless you tell us otherwise in writing or in any other approved manner. However please allow up to one month for us to process all data regarding your privacy choices. Opting out does not apply to service messages such as booking confirmation emails and statements. 

If you do not opt-out, in all future contact with you in marketing mailings, phone and SMS marketing or via e-mail marketing we will give you the opportunity to decline to receive further mailings. Except where expressly permitted by the Data Protection Act, we will only deal with the personal details you give us as set out above unless you agree otherwise. We have appropriate security measures in place to protect this information. 

SUBJECT ACCESS RIGHTS

MNWG may allow you to review certain Personal Data through the Site or through other online means. Information about the availability of online means for reviewing your Personal Data is generally available at the Site or on the printed materials where such type of Personal Data was first submitted.

You are generally entitled to ask us (by letter or e-mail) what details of yours are being held or processed, for what purpose and to whom they may be or have been disclosed. We may charge a fee to respond to such a request. We promise to respond to your request within 40 days of receiving your written request and fee. In certain limited circumstances we are entitled to refuse your request. If you believe that any of your personal details which we are processing are inaccurate or incorrect please contact us immediately. 

When making a subject access request, please be sure to include your full name, address and telephone number and a copy of a document evidencing your identity (such as an ID card or passport) so we can ascertain your identity and whether we have any Personal Data regarding you, or in case we need to contact you to obtain any additional information, we may require to make that determination.  We are not responsible for updating, removing or suppressing information from the databases of Licensed Hotels, Affiliates, and other third parties with whom we have already shared your Personal Data, or for limiting their use of your Personal Data.

RETENTION PERIOD

MNWG only collects Personal Data that it believes is necessary to perform the services that you seek from MNWG and to exercise its rights and comply with its obligations as otherwise outlined in this Policy. We will keep your Personal Data only as long as we need it for the purposes for which we collect it or as otherwise permitted by law.

NOTE REGARDING THE USE OF THE SITE BY MINORS

The Site is not directed to minors (as defined by applicable law), and we request that such individuals do not provide Personal Data through the Site.

JURISDICTIONAL /DATA TRANSFER ISSUES

The Site is operated from the United Kingdom in accordance with laws of England & Wales, and visitors to our Site should be aware that the laws of England & Wales may differ from those of your country of residence.  MNWG does not represent or warrant that the Site or any part thereof is appropriate or available for use in any particular jurisdiction. Those who choose to access the Site do so on their own initiative and at their own risk and are responsible for complying with all local laws, rules, and regulations. We may limit the Site's availability, in whole or in part, to any person, geographic area or jurisdiction we choose, at any time and in our sole discretion.

By submitting any Personal Data to us, you consent to the transfer of such Personal Data to and the processing of such Personal Data in countries other than your country of residence, including countries outside the UK/EEA that may provide a different level of data security than in your country of residence. In addition, if we need to transfer any Personal Data to Licensed Hotels, Affiliates, or other third parties pursuant to this Policy, please be advised that such entities may or may not be located in countries that are considered "adequate" pursuant to the Data Protection Act 1998 or other laws.

CONTACTING US

Please note that e-mail communications will not necessarily be secure; accordingly, you should not include payment information or Sensitive Personal Data in your e-mail correspondence to us.

CHANGES TO THE POLICY

MNWG reserves the right to change, modify, or amend this Policy at any time. The date this Policy was last revised is at the top of this page. If we make a material change to this Policy, we will indicate on the Site that our privacy practices have changed and will provide a link to the new policy.  If we make material changes to how we use your Personal Information, we will notify you by e-mail to the e-mail address specified in your account (if applicable) and/or through a notice on the Site’s home page, and we will provide you with an opportunity to opt-out of such new or different use. Any changes to the Policy will become effective upon our posting of the revised Policy on the Site. Use of the Site following such changes constitutes your acceptance of the revised Policy then in effect.