This is the Privacy Statement of Tranquil Water (TW). In this statement we use the terms “we,” “our” and “us” to refer to TW.
The purpose of this Privacy Statement is to outline our position concerning the collection, use, retention, disclosure, and transfer of Personal Data which is gathered and processed by us. This Privacy Statement also sets out our information management practices.
TW respects your right to privacy and is committed to protecting your personal data. This Privacy Statement will inform you as to how we look after your personal data and tell you about your rights and how the law protects you.
It is important that you read this Privacy Statement together with any other privacy statements or fair processing notice’s we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we use your data. This Privacy Statement supplements other notices and is not intended to override them.
1. What is Personal Data?
Personal Data is any information relating to a living individual that allows for the identification of that individual. Personal Data can include a name, address, contact details, an identification number, IP address, CCTV footage, accesses cards/ fobs, audio-visual or audio recordings of a person, details about an individual's location or any other detail(s) specific to that individual such in certain cases special category data such as (Biometric).
2. Who we are and how to contact us?
This privacy statement is issued on behalf of TW so where we mention “TW”, “us”, “we” or “our” in this privacy statement, we are referring to the relevant person responsible for processing your data.
We have appointed a centralised point of contact for the Collection called a Designated Privacy Representative [“DPR”] who is responsible for overseeing questions in relation to this privacy statement and for all data protection related matters. If you have any questions about this privacy statement, including any request to exercise your legal right please contact us at TW.
3. Changes to this Privacy Statement and your duty to inform us of changes
We keep our privacy statement under regular review. It is important that the personal data that we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with is.
4. Third Party Links
This website may include links to third party websites, plugins, and applications, such as Facebook, Instagram, Twitter,LinkedIn,You Tube etc. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy statement of every website you visit.
5. Categories of personal data and how we use it.
This section of the Privacy Statement sets out the type of Personal Data collected by TW, the purposes for which such Personal Data is collected and processed and the lawful justifications for such processing in the context of the TW Websites.
We collect, use, and share aggregate data such as statistical or demographic data. Aggregate data is information gathered and expressed in a summary form for purposes such as statistical or demographic analysis. Aggregate data may be derived from your personal data but is not data that directly or indirectly reveals your identity. For example, we may aggregate your usage data of our websites to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregate data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this data protection statement.
It is not our intention to collect any special categories of personal data about you, this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, genetic and biometric data. Nor do we collect any information about criminal convictions and offences. Additionally, we may need to process special category data if you have any specific dietary requirements or require adaptation to a service due to a disability. If it is necessary to collect such special categories of personal information we will only do so with your explicit consent or where we have another lawful basis to do so and we will explain the purpose for which the information will be used at the point when we collect, it
6. The data we collect about you.
Personal data, means any information about an individual from which that person can be identified. It does not include data where the identify has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we will group together as follows;
• Identity data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender, social media profile;
• Contact data includes billing address, delivery address, email address, telephone number;
• Financial data includes bank account and payment card details;
• Transactional data includes details about payments to and from you and other details of products and services you have purchased from us;
• Technical data includes IP addresses, your login data, time zone and location, browser and plugin type or versions, device type, operating systems and platforms and other technology devices which you use to access our websites;
• Profile data includes purchases or orders made by you, your interest, social media preferences, feedback, and survey responses;
• Usage data includes information about how you use our website, products and services and our social media sites;
• Marketing communications data includes your preferences in receiving marketing from us and other third parties and your communication preferences.
• Special Category Data may include health data such as details about specific dietary requirements, allergies, or information about a disability. We will process this data with your explicit consent and in certain instances with your vital interests in mind. This is so we can ensure that we provide you with a comfortable and safe environment that meets your specific needs.
7. How do we obtain your information?
We use different methods to collect data from and about you including through:
Direct interactions
You may give us your Identity and Contact Data by filling in forms or by corresponding with us by email or otherwise. This includes personal data you provide when you:
- request our services; (booking a reservation or attending one of our Hotels or Wellness Centers/Gyms)
- subscribe to our newsletters;
- request marketing to be sent to you;
- provide feedback; or complete a survey
- apply for a job within the Collection;
- entering competitions;
- attendance at conferences or events;
- cctv imagery;
- manage your personal data preference
Automated technologies or interactions
As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions, and patterns. We collect this personal data by using cookies, server logs, and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. All cookies apart from strictly necessary cookies will require your consent.
Third parties or publicly available sources
We may receive personal data about you from various third parties such as;
- you may use various travel booking platforms such as Booking.com, HotelRez, HRS, TripAdvisor, Hotelbeds, Travel Republic, Expedia etc. to book your stay. The aforementioned is a selection of some of these booking platforms, however if you have any queries regarding the source from where we obtained your personal data, please contact us.
- advertising networks which we utilise and to which you might engage with
- interactions with Social Media site
8. What Personal Data does TW collect and use online?
We collect various types of Personal Data when a person uses our website or social media platforms. The following are examples of Personal Data collected by TW:
i. Our website uses cookies, web beacons, device identifiers, social plugins, tracking pixels, etc. “Cookies” are small pieces of information stored by your internet browser that collect data such as your browser type, your operating system, web pages visited, time of visits, content viewed, advertisements viewed, and other click stream data. We use cookies to help us tailor our websites to your needs, to deliver a better, more personalized service and to remember certain choices you have made so you do not have to re-enter them. Cookies also enable us to identify traffic to our website including pages visited, visitor numbers and traffic paths taken. We may record which users opened and clicked any embedded links in communications sent by TW to measure a campaigns effectiveness. We do not deploy un-necessary cookies, such as analytics, marketing, targeting, or profiling cookies without your consent. Please see our Cookie Policy for further details (insert cookie policy link)
ii. We may collect your personal data from Contact Forms, such as booking a room at Tranquil Water or using one of the services provided, this enables us to deal with your request in a timely manner.
iii. Competitions: When a person enters a competition, we may collect and use the entrant’s name and contact details (including postal address, email address, telephone number) in connection with the competition (including mobile competitions). Where we operate competitions in conjunction with a third-party commercial partner, subject to the competition rules and notices, that partner may collect and use the data.
iv. Social Media Pages: Content such as messages and photographs, which are posted on social media pages on which TW has a presence may be made publicly available and may be used in connection with the operation and promotion of our social media pages, services, and this website. Data such as the name of your internet service provider, the website you visited us from, the parts of our site that you have visited, the date and duration of your visit, and information from the device (e.g., device type, operating system, screen resolution, language, country location, and web browser type) used during your visit. We may process this usage data to facilitate access to our website (e.g., to adjust our website to the devices that are used)
v. Online Advertising: We may use advertising networks to help present advertisements or other content on our website and on other websites or social media platforms that display TW advertisements. By using TW online services, we may use information gathered from you, and information gathered from third parties, to provide our users with certain tailored advertising offerings through our website, social media sites and other services. TW gathers web viewing personal data from users across its various services, with their consent and which may then be used by TW and its service providers to deliver advertising to groups of users based on the preferences or interests inferred from the data collected and processed by TW (or a third-party service provider’s) technology. For example, TW will only use cookies, web beacons, social plugins, tracking pixels and similar technologies to collect information from a mobile or other device with the consent of the user.
9. The purpose and legal basis for processing your information.
We will only use your personal data where the law allows us to. Most commonly we will use data in the following situations;
a) To enter into and perform a contract with you.
We may process your information in order to enter into a contract with you or to provide you with a service which you have requested from us. For example, we need to process your personal information in order to enable you to book a room in our hotel or to provide you with a brochure or information about a product or service where you have requested it.
b) To comply with our legal obligations
We are required to process your personal information to comply with certain legal and regulatory obligations to which we are subject. For example, we are required to obtain certain business records in accordance with company and revenue law which may include your personal information.
c) For our legitimate business interests
We may use your personal information for the purposes of carrying out activities that are in our legitimate interests (or those of a third party). Where we process your information for our legitimate interests, we ensure that there is a fair balance between our legitimate interest and your fundamental rights and freedoms.
If you are a customer of TW, we may use your information to send you communications on special offers and hospitality events that may interest you and that you would reasonably expect to receive, you can at any stage easily opt out of these communications by contacting us on the details provided below or by using the un-subscribe option in the marketing communication.
For further information on the various scenarios of how we use data under Legitimate Interest please see the below table.
d) With your consent
We will request your consent for the use of all cookies on our websites outside of strictly necessary. You can withdraw this consent at any time by clicking “cookie settings” on our websites, please see this websites cookie policy for further information or click on the link of any of our hotel websites that you may visit
Generally, we do not rely on consent as a legal basis for processing of personal data although we will request consent before sending you third party direct marketing communications, passing on your personal information to a third party for marketing purposes or before sending digital marketing to you if you are not an existing customer. You can revoke your consent at any time by contacting us on the details provided below by using the un-subscribe option in the marketing communication.
e) To protect your vital interests
We will in certain circumstances use your personal information to protect your vital interests.
We have set out below, in table format a description of all the ways we plan to use your personal
data, and which legal basis we rely on to do so. We have also identified our legitimate interest where appropriate.