Privacy Policy

Last updated: [Insert Date]

1. Introduction Velvet Sky Hotel ("we", "us", or "our") is committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, share, and protect your personal data when you stay with us, use our services, visit our website, or otherwise interact with Velvet Sky Hotel in England.

By using our services, booking a room, or providing your personal data to us, you agree to the practices described in this Privacy Policy.

2. Data Controller The data controller responsible for your personal data is:

Velvet Sky Hotel [Insert Postal Address] [Insert City], England [Insert Contact Email] [Insert Contact Telephone]

3. Personal Data We Collect We may collect and process the following categories of personal data:

3.1 Identification and contact details

• Full name
• Title
• Postal address
• Email address
• Telephone number
• Nationality
• Identification details required by local law (e.g., passport number or ID details for check-in)

3.2 Booking and stay information

• Reservation details (dates of stay, room type, rate, special requests)
• Payment information (e.g., card type, last four digits of card number, payment status; full card details are processed securely by approved payment providers)
• Preferences (e.g., room preferences, dietary requirements, special occasions)
• Loyalty or membership numbers related to booking platforms, if provided

3.3 Online usage and technical information

• IP address
• Device and browser information
• Log data (date and time of access, pages visited, referring website)
• Cookies and similar tracking technologies (see Section 11)

3.4 Communications and feedback

• Records of your communications with us (email, phone, online forms, messaging apps, or in person)
• Feedback, reviews, survey responses, and complaints

3.5 CCTV and on‑site security

• CCTV images and recordings in public areas of the hotel, used for security and crime prevention purposes.

4. Legal Bases for Processing We process your personal data under the following legal bases, as provided under applicable data protection laws in England (including the UK GDPR and Data Protection Act 2018):

• Contract: to enter into and perform our contract with you (e.g., to manage your booking and provide hotel services).
• Legal obligation: to comply with applicable laws and regulations (e.g., record‑keeping, tax, immigration, and public safety requirements).
• Legitimate interests: to operate, improve, and secure our business (e.g., security, service improvement, direct marketing to existing customers, fraud prevention), provided that your interests and fundamental rights do not override these interests.
• Consent: where required by law, for example for certain marketing communications or optional cookies. You may withdraw your consent at any time (see Section 9).

5. How We Use Your Personal Data We use your personal data for the following purposes:

5.1 To manage bookings and provide our services

• Process reservations, modifications, and cancellations
• Check you in and out of the hotel
• Provide services during your stay (e.g., housekeeping, room service, concierge, additional amenities)
• Handle payments, invoices, and accounting

5.2 To communicate with you

• Send booking confirmations and pre‑arrival information
• Notify you of changes to your reservation or our services
• Respond to questions, requests, or complaints
• Communicate regarding lost property or follow‑up after your stay

5.3 For marketing and offers

• Send you information about offers, promotions, and services that may be of interest to you, subject to your marketing preferences and applicable law
• Customise our marketing communications based on your preferences and previous stays

5.4 For security, safety, and legal compliance

• Protect our guests, staff, and property
• Prevent and detect fraud and other unlawful activities
• Comply with legal obligations, including requests from authorities when legally required
• Enforce our terms and conditions

5.5 For improvement and analytics

• Understand how our services are used and improve our operations
• Perform data analysis, statistics, and reporting in an aggregated or anonymised form where possible

6. Sharing Your Personal Data We may share your personal data with:

6.1 Service providers (processors) Trusted third parties that help us operate our business and deliver services, such as:

• IT and website hosting providers
• Payment processors and banks
• Reservation and channel management systems
• Marketing and customer relationship management service providers
• Security and CCTV service providers

These service providers act on our instructions, are contractually bound to protect your personal data, and may not use it for their own purposes.

6.2 Business partners and platforms

• Online travel agencies and booking platforms you use to reserve your stay
• Travel agents and tour operators if you book through them

6.3 Public authorities and legal recipients

• Law enforcement agencies, regulators, or courts where we are legally required to do so or where it is necessary to protect our rights, guests, staff, or property.

6.4 Corporate transactions In the event of a sale, merger, reorganisation, or similar corporate transaction involving Velvet Sky Hotel, personal data may be transferred as part of that transaction, in compliance with applicable laws.

We do not sell your personal data.

7. International Data Transfers Your personal data is primarily processed in the United Kingdom. If we transfer personal data to countries outside the UK or European Economic Area, we will ensure that appropriate safeguards are in place, such as:
   • An adequacy regulation or decision from the UK Government or European Commission; or
   • Standard contractual clauses or other legally recognised transfer mechanisms.

You may contact us for more information about international transfers and the safeguards used.

8. Data Retention We keep your personal data only for as long as necessary for the purposes for which it was collected, and to meet legal, accounting, or reporting requirements. Retention periods may vary, for example:

• Reservation and billing records: kept for the period required by tax and accounting laws.
• Guest registration information: retained in line with local legal obligations relating to accommodation providers.
• Marketing data: retained until you opt out or withdraw consent, or after a defined period of inactivity, subject to applicable law.
• CCTV recordings: kept for a limited period unless longer retention is required for the investigation of an incident.

When personal data is no longer needed, it will be securely deleted, anonymised, or archived in accordance with our data retention policies.

9. Your Rights Subject to applicable law, you may have the following rights regarding your personal data:

• Right of access: to obtain confirmation as to whether we process your personal data and to request a copy of the data.
• Right to rectification: to have inaccurate or incomplete personal data corrected.
• Right to erasure: to request deletion of your personal data where there is no longer a valid reason for us to keep it, subject to legal and legitimate business requirements.
• Right to restriction of processing: to request that we limit the processing of your personal data in certain circumstances.
• Right to data portability: to receive personal data you provided to us in a structured, commonly used, and machine‑readable format, and to transmit it to another controller where technically feasible.
• Right to object: to object to processing based on our legitimate interests, including direct marketing. We will stop such processing unless we have compelling legitimate grounds or where processing is for legal claims.
• Right to withdraw consent: where we process your data based on consent (for example, certain marketing or cookies), you may withdraw this consent at any time. This will not affect the lawfulness of processing before withdrawal.

To exercise any of these rights, please contact us using the details provided in Section 13. We may need to verify your identity before responding to your request.

10. Security of Your Personal Data We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, accidental loss, destruction, or damage. These measures may include:

• Access controls and authentication
• Encryption and secure transmission where appropriate
• Regular security assessments
• Staff training and confidentiality obligations

However, no system can be completely secure. While we strive to protect your personal data, we cannot guarantee the absolute security of information transmitted to or from us over the internet.

11. Cookies and Similar Technologies Our website may use cookies and similar technologies to:

• Enable the proper functioning of the site and booking engine
• Remember your preferences and improve your user experience
• Analyse website traffic and performance
• Support marketing and advertising activities, where permitted by law and where you have provided consent if required

You can manage or disable cookies through your browser settings. Some cookies are essential for the website to function properly; disabling them may affect your ability to use certain features. For more information, please refer to our separate Cookie Policy, if available, or contact us using the details below.

12. Children’s Privacy Our services are not directed to children, and we do not knowingly collect personal data from children under the age of 16 without appropriate parental or guardian consent. If you believe that we have collected personal data from a child without such consent, please contact us so that we can take appropriate action.

13. Contact Us If you have any questions, concerns, or requests regarding this Privacy Policy or our handling of your personal data, please contact:

Velvet Sky Hotel [Insert Postal Address] [Insert City], England Email: [Insert Contact Email] Telephone: [Insert Contact Number]

14. Complaints You also have the right to lodge a complaint with the UK data protection authority, the Information Commissioner’s Office (ICO), if you believe that your data protection rights have been violated. For details on how to contact the ICO, please visit www.ico.org.uk.

15. Changes to This Privacy Policy We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or for other operational reasons. Any updates will be posted on our website with a revised "Last updated" date. We encourage you to review this Privacy Policy periodically to stay informed about how we process your personal data.