Privacy Policy

Updated: 13th January 2021 Old Thorns believe in being upfront and transparent with how we use your data. We comply with any data protection law which would be applicable to you and closely monitor regulations and policies, including the The General Data Protection Regulation (GDPR) (EU) 2016/679.

When you interact with Old Thorns, for example by submitting an enquiry or booking a stay, we may request that you provide us with personal data. This privacy policy tells you how Old Thorns collects personal information, why we collect it and how you can edit, change and delete your data. By using our site, you confirm that you understand and accept the Privacy Policy. If you do not agree to the terms of our Privacy Policy, please do not use our website. The types of data we collect and why Old Thorns processes personal data as the data controller, as defined in the General Data Protection Regulation (GDPR).

Visitors to Old Thorns

Legal Basis for Processing: Legal obligation Retention Period: 21 days

To help stop the spread of COVID-19 and support Public Health England we are required to collect contact information for all customers and visitors to Old Thorns. This is not just for hotel residents but for any visitor to any of our dining outlets, golf course etc. On arrival the time, date, name, email & contact number of the lead booker will collected. If requested, NHS Test and Trace may require this information to contact you either because someone who visited the premises tested positive for COVID-19 or because the property has been identified as the source of a local outbreak. Your details will not be passed on to any other 3rd party and will not be used for any other purpose unless you have explicitly provided consent.

Visitors to our website

Legal Basis for Processing: Consent Retention Period: No more than 36 months

When someone visits www.oldthorns.com we use a third-party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. We do this to monitor and track trends such as visitors to the site, so we can make improvements. This information is anonymous.

We also use cookies on our website. Cookies are small data files which the website places on your computer or mobile device when you first visit the website. They can help us analyse how well our website is performing so we can make improvements. They can also improve your browsing experience by suggesting recommendations based on your browsing history. You can control, manage, disable and delete cookies in your browser’s settings.

When you make an enquiry

Legal Basis for Processing: Legitimate Interest Retention Period: As long as strictly necessary for the purpose in which it was collected.

If you make an enquiry on our website, we will collect and process your data to respond to your enquiry. This is likely to include your name and contact information. Your data may be shared between departments at Old Thorns to ensure your enquiry is responded to accurately. You will have the option to opt-in to additional marketing communications. If you do so, your data will be retained for this purpose (please see email newsletters and offers below).

E-mail newsletters and offers

Legal Basis for Processing: Consent Retention Period: While you are a registered subscriber – you can unsubscribe and remove your data at any time.

Subscription to our email newsletters and offers is completely optional. We never place you on an email list automatically – instead you will need to opt in to receive these communications, either by filling in our newsletter form or checking an opt-in box on an enquiry, booking or competition form.

We use a third-party provider, Revinate, to deliver our email newsletters and offer details. We gather statistics about email opening and clicks using industry standard technologies to help us monitor and improve our emails. For more information, please see Revinate’s privacy policy.

Bookings

Legal Basis for Processing: Contract Retention Period: As long as strictly necessary for the purpose in which it was collected.

When you make a booking either directly with us or through an Online Travel Agent or 3rd Party, we will collect personal data about you and other travellers in your group, including names, addresses, phone, email and payment details. We need this data to enter into a contract with you. If you provide us with details of other individuals included in a booking you must have the authority of those individuals to provide their personal data. We will use the information you provide us to contact you with reference to your booking. Your information will only be used for additional marketing communications if you opt-in to receive this.

Table Reservations

Legal Basis for Processing: Contract Retention Period: As long as strictly necessary for the purpose in which it was collected.

When you make a table reservation with us either online, via the telephone or in person your data is used for your booking. We use a provider called Resdiary to manage table bookings. Data is kept for 18 months and then if there is no further future bookings, the individual’s data is anonymised.

Online Chat

Legal Basis for Processing: Legitimate Interest Retention Period: As long as strictly necessary for the purpose in which it was collected.

When you open an online chat on our website, we collect information about you to help our agents answer your query. We use a 3rd party called tawk.to to record your chat history including your name, email, IP address and pages visited. The history is kept for us to assist with future queries but you may request deletion of your data at any time.

Online Voucher Purchases

Legal Basis for Processing: Contract Retention Period: As long as strictly necessary for the purpose in which it was collected.

We use a third-party provider, Voucher Cart, to process and manage online voucher sales. We use your personal information such as email, phone and address to process your voucher. Payments are handled by VoucherCart and Old Thorns do not have access to any payment information within the VoucherCart system. Your personal data such as name, email and address are held within the VoucherCart system to process and redeem your voucher. Please refer to VoucherCart’s privacy policy for further information.

Online Shop Purchases

Legal Basis for Processing: Contract Retention Period: As long as strictly necessary for the purpose in which it was collected.

We use a third-party provider, Shopify, to process and manage online product sales. We use your personal information such as email, phone and address to process your voucher. Payments are handled by Shopify and PayPal and Old Thorns do not have access to any payment information within the Shopify system. Your personal data such as name, email and address are held within the Shopify system to process your sale. Please refer to Shopify's privacy policy for further information.

Membership Details

Legal Basis for Processing: Contract Retention Period: As long as strictly necessary for the purpose in which it was collected.

If you become a member at Old Thorns either to our Health Club or our Golf Club, we will collect information from you to process your membership. For essential membership communications we will use the data you provide to inform you – e.g. for contract renewals, payment issues, changes to terms etc. We will also give you the option to opt in to additional communications such as additional member benefits and marketing offers. You can unsubscribe from these additional communications at any time.

Membership Communications

Legal Basis for Processing: Legitimate Interest Retention Period: As long as strictly necessary for the purpose in which it was collected. i.e. for as long as you are a member

If you are currently a member of Old Thorns, you’ll receive communications from either the golf or health club team (depending on which you are a member of), with information that we feel would be of interest to you and that enhances your membership. For example golf course updates, new health club classes and sessions, timetables and competitions. We recommend you receive these so you get the most from your membership. However, if you wish to be removed from these mailings you can do so by contacting the membership team or unsubscribing fro the bottom of the emails.

Complaints

Legal Basis for Processing: Legitimate Interest Retention Period: As long as strictly necessary for the purpose in which it was collected.

If you make a complaint to Old Thorns we will process your data to respond to your complaint. Your data may be shared between departments at Old Thorns to ensure your complaint is responded to accurately.

Information from 3rd parties

Legal Basis for Processing: Contract Retention Period: As long as strictly necessary for the purpose in which it was collected.

If you book your stay with us through a 3rd party such as an online travel agent, golf company, spa company they will pass on your details to us so that we can perform the contract. Your details will only be used to carry out the request/booking unless you have opted in to receive additional marketing communications.

Applying for a job

Legal Basis for Processing: Legitimate Interest/ Consent Retention Period: As long as strictly necessary for the purpose in which it was collected.

If you apply for a job at Old Thorns, the information you provide will be used by the HR team and the hiring department in the selection process. After the selection process is complete, any data will be deleted unless you have specified that you wish your data to be retained for future job opportunities in which case it will be held by our HR department for future positions.

Other uses of your data

Legal Basis for processing: Legitimate Interest Retention Period: As long as strictly necessary for the purpose in which it was collected.

We may process personal information for certain legitimate business purposes, which include some or all of the following:

Where the processing enables us to enhance, modify, personalise or otherwise improve our services/communications for the benefit of our customers to identify and prevent fraud to understand how people interact with our websites to determine the effectiveness of promotional campaigns advertising 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 at all times. Processing your information Old Thorns adopt security measures to protect your personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access. Whilst Old Thorns will take all reasonable steps to protect your personal data from any data breach, we cannot guarantee the security of the personal data you disclose online or that no data breach will occur. We encourage you to help us by ensuring that any passwords you use are kept confidentially, and you log off when using a shared computer. Storage of information Old Thorns may store your personal data in the cloud. This means that your personal data may be processed on behalf of Old Thorns by a cloud service provider and could be stored in different locations around the world. Examples of this include Revinate for email newsletters and VoucherCart for our online voucher purchases. Access to information You have the right to request access to the information we have on you. You can do this by contacting us on marketing@oldthorns.com. We will make sure to provide you with a copy of the data we process about you. In order to comply with your request, we may ask you to verify your identity.

We will fulfill your request by sending your copy electronically unless the request expressly specifies a different method for which there may be an administrative fee.

Information correction If you believe the information we have about you is incorrect or you wish to change your subscription preferences, you are welcome to contact us, so we can update it and keep your data accurate. Information deletion If at any point you wish Old Thorns to delete information about you, you can simply contact us. Please be aware that some data is necessary for us to provide you with our service (for e.g. an upcoming hotel stay, a golf tee time etc). Therefore, if you have booked a service with us, please be aware that some personal details will need to be retained for processing your booking. This can be deleted post to your stay with us – please just request this. Changes to this privacy policy We keep our privacy policy under regular review. If we make any major changes to our privacy policy we will add appropriate site notices to advise of the changes. We encourage you to periodically review this page for the latest information on our privacy practices. This policy was last updated on 18th May 2020. Contacting the data controller You can contact us at any time to:

Request access to information that Old Thorns has about you
Correct any information that Old Thorns has about you
Delete information that Old Thorns has about you
Raise a complaint on how we have handled your personal data
Ask any additional questions about Old Thorns’ collection and storage of data or about this Privacy Policy

Old Thorns Longmoor Road Griggs Green Liphook Hampshire GU30 7PE

+44 (0)1428 724 555

marketing@oldthorns.com

Cookie Policy

This cookie policy explains what cookies are and how we use them on our website. By using our website you are agreeing that we can use cookies in accordance with this policy.

What are cookies? A cookie is a small text file. Cookies are stored on the browser or hard drive of your computer or device when you visit a site.

How do we use cookies? Cookies enable us to provide a browsing experience that is unique to you and improve your experience on our website. For example, cookies enable the website to remember what you have done whilst browsing. They also provide information to us for customization or statistical purposes.

What types of cookies do we use? We use session cookies and persistent cookies on our website. Session cookies are deleted from your computer or device when you close your web browser. Persistent cookies will remain stored on your computer or device until deleted or until they reach their expiry date.

Analytical/performance cookies – these help us analyze and improve our website. Cookies enable us to see how many visits our website has received and identify areas of improvement. Functionality cookies – these help us to personalize content. These cookies recognise when you return to our website. Targeting cookies – these cookies help us to display advertising that is more relevant to your interests. They record your visit to our website and the pages you have visited. We may share this information with 3rd parties for this purpose.

Blocking cookies You can block and delete cookies via your Internet browser settings. Please note that if you disable or delete our cookies we cannot guarantee that all the web pages on the site will be displayed or work correctly or that certain services will be supplied.

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