Clayton Hotels Privacy Statement

Throughout this privacy statement, “we”, “us”, “our” and “ours” refer to Clayton Hotels and Dalata Hotel Group plc.

“Dalata Hotel Group plc.” hotel operator of Clayton Hotels. Dalata Hotel Group operates properties including: Clayton Hotels, Maldron Hotels, Belvedere Hotel, The Samuel Hotel, Hotel 7 and the Gibson Hotel.

Clayton Hotels and Dalata Hotel Group plc. having its registered office: 3 Arkle Rd, Sandyford Business Park, Dublin 18, D18 C9C5, Ireland with registered number: 534888.

We fully respect your right to privacy, any personal information, which you volunteer to Clayton Hotels and Dalata Hotel Group plc. will be treated with the highest standards of security and confidentiality.

We are not responsible for the content or privacy practices of other websites. Any external links to other websites are clearly identifiable as such. Some technical terms used in this statement are explained at the end of this page.

This statement outlines how we protect and manage your personal data. Please also read our Cookie Statement, which tells you how we use cookies. For a better understanding of our product and service please read our Terms and Conditions.

By using any of our products or services and/or by agreeing to this Statement, e.g. in the context of registering for any of our products or services, you understand and acknowledge that we will collect and use personal information as described in this Privacy Statement.

If you have any questions about how your information is gathered, stored, shared or used, please contact dataprotection@dalatahotelgroup.com. You have a number of rights in relation to your information, including the right to object to the processing of your personal information for direct marketing or where the legal basis for our use of your data is our legitimate business interests.

To ensure that the personal information we hold on you is accurate and up-to-date, please inform us of any relevant change to your contact details.

As we might amend this page from time to time, we encourage you to visit our Privacy Statement page regularly.

1. Personal Information

As defined in GDPR, personal information is “any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier”. It is information that identifies you as an individual or relates to an identifiable individual.

We may collect various personal information which you provided us with:

• Contact information, including: title, name, postal and email address and phone/mobile number.
• Information about your preferences for your stay.
• Meeting and event specifications (if you plan an event with us).
• Transaction information, including payment and reservation information and booking details.
• Business information from our corporate customers, including job title, employer details (company name and business postal address) as well as booking type preferences.
• Purchase history; like hotels that you have stayed in, the dates of your stay and other indicated preferences.
• Guest feedback.
• CCTV images.

2. Sensitive Personal Information

The term “sensitive information” called in GDPR “special categories of personal data”, refers to information related to your physical or mental health, racial or ethnic origin, political opinions, religious or other beliefs, your sexual life, genetic data, biometric data (if used to identify an individual) or trade union membership.

In general, we do not collect sensitive information unless it is volunteered by you. We may use health information provided by you to meet your particular needs during your stay or if required in the public interest or under public health grounds. For example such as any mobility restrictions or specific meal preferences.

3. Information from online activities

We collect information about your internet activity using the technology known as cookies, which can often be controlled through internet browsers. For detailed information on the cookies we use and the purposes for which we use them, see our Cookie Statement.

With your permission, we may collect certain information, like your IP address, or browser, and information about your computer’s operating system, application version, language settings and clickstream data which shows the traffic of your visit around this website (for example pages accessed and documents downloaded). We also collect the previous website address from which you reached us and the domain name used (for example .i.e., .com, .org, .net) If you’re using a mobile device, we might also collect data that identifies your mobile device, device-specific settings and characteristics and latitude/longitude details.

If you see our marketing ads on different websites. This is because we may show adverts we think will be of interest to you based on your activity on our site such as visiting certain pages or special offers through our advertising partners. Read more about our Cookie Statement. Our advertising partners include Google and, using the Google Display Network and in compliance with their strict advertiser policies, adverts can appear on third-party sites.

4. Personal information from children

We do not administer bookings from children under 18 years old and we do not knowingly collect their personal information. As a parent or legal guardian, you should not allow your children to submit their personal information without your permission.

5. Personal data you give us about others

In situations when you:
5.1. Stay with other guests whose details you may provide as part of the reservation;
5.2. Make a reservation on behalf of someone else;
5.3. Purchase our gift card with the delivery service to another recipient than related to you;

You should only provide us with information about other people if you have their permission to do so. It’s your responsibility to ensure that the other person is aware that you have done so and that this individual has accepted that we use their personal information as outlined in our Privacy Statement.

We use your personal information for various purposes:

1. To provide our products and services to you and perform our contract with you, we use your information in certain cases, such as:

1.1. Bookings

We use your personal information to administer your booking. If the required personal data is not provided, we will not be able to administer your booking. When you make a reservation with us, we will send a booking confirmation by email. On occasion, we may get in touch with you by email or by phone with information related to your stay, meeting or event. This is to respond and handle requests you have made or to assist you and provide you with other relevant information.

1.2. Run the reward programme

If you are a member of Make it Maldron, we use your information to administer your membership, enabling you to gain the exclusive discount that the Make it Maldron gives you.
We also use your contact information to communicate transactional and marketing materials through email or phone.

1.3. Online Services

In order to assist you and provide you with relevant content, we may process your personal information.  This may include providing you with offers that you can book or personalising the content on the website. We may also process your personal information when you make enquiries and engage with us through our website or via online chat. In addition, your participation with our social media involves us processing your information on the basis of your consent and in furtherance of our related business interest which includes marketing, service improvements, analytics and service personalisation.

1.4. Direct Marketing

1.4.1. Communication. We also use your contact information to send marketing communication about our products and services, as permitted by law (Privacy and Electronic Communications Regulations which regulates our marketing activities).
We send our customers regular newsletters by email. There may be other times when we get in touch by post, by phone or by texting you, depending on the contact information you share with us.
We also send you an email related to your upcoming stay, such as how to contact the hotel, and information that we feel might be useful to you in planning or getting the best out of your stay with us. You may opt-out from marketing communication at any time by clicking the relevant link in the e-mail message or contacting the marketing department at dataprotection@dalatahotelgroup.com.

1.4.2. Guest Review. We may use your contact information to invite you to write a review after your stay, which may ask for information about the property, the surrounding areas, and the destination. If you don’t want your name to show with your review, you can be displayed anonymously.
By completing a guest review, you’re agreeing that it can be displayed on, for example, our websites, in our social media accounts; to inform other travellers about the quality and services of the hotel.

2. To provide our products and services to you and perform our contract with you, we collect data about you from other source:

We may also collect your personal information from other sources, third parties. We may then combine this information with information that was given to us and information we collect about you. This may include information from your travel agent, online companies who’s websites allow you to book various travel services (e.g. Booking.com, Expedia) and other partners. We may use this information for the purposes described in this Privacy Statement.

3. To manage our business for our legitimate interests

“Legitimate Interests” means the interests of our company in conducting and managing our business to enable us to give you the best service and products. For example, we have an interest in making sure our marketing is relevant to you, so we may process your information to send you email marketing that is tailored to your previous stay(s).
Whenever we process data for these purposes we will ensure that we always keep your personal data rights in high regard and take account of these rights. You have the right to object to this processing if you wish, and if you wish to do so please email dataprotection@dalatahotelgroup.com. Please bear in mind that if you object this may affect our ability to carry out below tasks for your benefit.

3.1. Conduct marketing activities

3.1.1. We share personal information with media agencies, social media platforms, search engines, and other online platforms to help us target our online marketing and promote relevant offers. To create target audiences, these platforms may also use personal information they hold and combine or match it against the personal information received from us. Target audiences are the audiences that we think would be interested in our online advertising. We further segment our communications to ensure our advertising efforts are customised to your preferences.

3.1.2. When you participate in our promotional activities (e.g. competitions during trade shows or on our social media channels), your contact information will be collected to administer these promotions. If you agree (opt-in), we will use your contact information to send you regular news and offers related to our products and services. You will only be added to our marketing database with your prior marketing opt-in permission located on the form your contact details were collected. You can unsubscribe/opt-out from marketing communication at any time by clicking the relevant link in the e-mail message or contacting the marketing department at dataprotection@dalatahotelgroup.com.

3.1.3. If you choose to participate in our social media activities (e.g. competitions, shared offers or other promotions), we may use the publicly available information you voluntarily share with us during the activity (e.g. your photos). This information might only be used in connection with that specific activity.

3.1.4. Provided that you have not objected us using your details in this way, we may contact your business contact information to provide you with information related to our services and products, which we think will be of interest and value to you (meeting, event planning, corporate room rate or any other).

3.1.5. We may use automated decision making to provide our current customers with relevant offers which are delivered by email.

3.1.6. To offer the best service, we have the ability to retain your contact details should you input them on our website using VeCapture by VeInteractive. This enables us if you do not complete your transaction by clicking submit to send you the email reminder to continue with your reservation. Such contact details may be used to contact you to assist with your transaction only. The information you enter into our booking forms may be collected and stored briefly so that we can contact you in relation to the nature of your attempted transaction, even if you don’t confirm the transaction. This may be used to send an email and will not use this data for any other purpose, we won’t store it for longer than necessary and we certainly won’t share it with any other company. Our aim is to provide you with the highest level of service that we can.

3.2. Analytical
To better understand how you interact with our websites. Enhance the user experience, and improve the functionality and quality of our services.

4. Market research

We may ask our customers to take part in market research. Any additional personal details that you give us as part of the market research will only be used with your consent.

5. To adhere to reasons of public interest including in the area of public health

We may need to request personal data from you to assist government bodies or other competent authorities to adhere to public health advice.

Our commitment is to protecting your privacy. We protect your information from unauthorised use or loss and will only pass your data to our business partners, to fulfil your requirements, improve our services, in the public interest or under public health grounds or where we are required to do so by law.

We use a range of third parties to provide services – either directly or indirectly. Where relevant, these companies are required to comply with our data privacy and information security standards when handling personal data and we aim that they do not compromise your personal data and information. We may share your personal data and information if we believe in good faith that such disclosure is authorised by law or is necessary to protect your personal safety. Such disclosure may include a cross-border transfer of personal data and information. If legally compelled to disclose your information to a third party, we will use commercially reasonable efforts to notify you in advance of a disclosure unless legally prohibited.

In the event of an unpaid account or disputed account, we will instruct our appointed debt recovery agents/solicitors to proceed with the necessary course of action to retrieve any monies due to our Company without prior consent from the customer.  Only information held that is relevant to the matter in hand will be passed to our appointed third party agents.

We take security responsibilities seriously, employing the most appropriate physical and technical measures, including staff training and awareness and we review these measures regularly.

We will keep your personal data for as long as it is necessary to enable you to use our services, to provide our services to you, unless a longer retention period is required. This is to comply with applicable laws, resolve disputes with any parties and otherwise as necessary to allow us to conduct our business, including to detect and prevent fraud or other illegal activities. All personal data we retain will be subject to this Privacy Statement. If you have a question about a specific retention period for certain types of personal data we process about you, please contact us via the contact details provided below.

1. The right of access to your personal data

If you have given your personal data and information to us, you have the right to ask us to advise you of the scope of information we process about you, the purpose and nature of the processing, and information on who we share it with.

1. 1. You can do the above by emailing the completed form to dataprotection@dalatahotelgroup.com. Please write “Request personal information” in the subject line of your email.

1. 2. You can also print out the completed form and send your requests in writing to Dalata Central Office, 4th Floor, Burton Court, Burton Hall Drive, Sandyford, Ireland.

Download the access request form (PDF).

2. The right to rectification

You can also request to update, correct your personal information. We strive to retain only data that is accurate, complete and up to date.

Please contact us to ensure that the personal information we retain is up to date. You can do that by emailing dataprotection@dalatahotelgroup.com. Please write “Request personal information update” in the subject line of your email.

3. The right to deletion

You can also request to delete your personal data at any time. However, we may need to retain certain information for legal or administrative purposes, such as record keeping or to detect fraudulent activities. You can opt out of marketing contact upon request. If you are concerned about potential violation of your privacy rights, please advise us of your concerns and we will strive to resolve them as soon as practically possible.

You can do the above by emailing dataprotection@dalatahotelgroup.com. Please write “Request personal information deletion” in the subject line of your email.

4. The right to object processing

You have the right to object to processing your data under our business for our legitimate interests.
Where we are using your personal data on the basis of your consent, you are can withdraw that consent at any time subject to applicable law.
You can do the above by emailing dataprotection@dalatahotelgroup.com.

5. The right to data portability

You have the right to data portability which allows you to obtain and reuse your personal data for your own purposes across different services. This right applies where your personal information is being processed based on consent or for a performance of a contract and the processing is carried out by automated means (excluding paper files).
The right also permits the transfer of data directly to another provider where technically feasible. Therefore, depending on the technology involved, we may not be able to receive personal data transferred to us and we will not be responsible for the accuracy of same.
You can do the above by emailing dataprotection@dalatahotelgroup.com.

6. You have the right to complain to the Data Protection Commission or another supervisory authority here.

If you have any questions about your personal data or if you wish to exercise any of your data rights, please contact us:

Email: dataprotection@dalatahotelgroup.com
Phone: +353 (01) 206 9400
Postal Address: 3 Arkle Rd, Sandyford Business Park, Dublin 18, D18 C9C5

All customer complaints are promptly escalated to the relevant manager. We deal with all complaints fairly and promptly and all issues are resolved as quickly as possible. Where any customer is dissatisfied with the outcome of our efforts to resolve their complaint, the matter will be raised with senior management. Where any customer remains dissatisfied, they are notified of their rights to refer their complaint to the relevant Ombudsman.

• Web browser; the piece of software you use to read web pages. Examples are Microsoft Internet Explorer, Netscape Navigator and Opera.
• IP address; the identifying details for your computer (or your internet company’s computer), expressed in “internet protocol” code (for example 192.168.72.34). Every computer connected to the web has a unique IP address, although the address may not be the same every time a connection is made.