CUSTOMER PRIVACY POLICY
Welcome to the Privacy Policy of Westmorland Limited. We are committed to preserving the privacy, integrity and security of the personal information we hold about our customers and those who make contact with us when you visit our website.
We have developed this Privacy Policy to explain how we manage and use this personal information and to ensure we comply with our legal obligations under applicable data protection laws. It is important that you read this Privacy Policy together with any other privacy notice or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you carefully so that you are fully aware of how we collect and process personal information and your privacy rights and how the law protects you. This Privacy Policy supplements other notices and privacy policies and is not intended to override them.
WESTMORLAND LIMITED. WHO WE ARE
This Privacy Policy covers the personal information collected and held by Westmorland Limited. Westmorland Limited is the collective term we use for a number of different legal entities all of which are involved in the business carried on by Westmorland Limited, including The Rheged Centre, Westmorland Hotel, Gloucester Services, Cairn Lodge Services, and Tebay Services (see our website at https://westmorlandfamily.com/our-businesses/). This privacy policy is issued on behalf of the companies referred to above, so when we mention “Westmorland”, “we”, “us” or “our” in this Privacy Policy, we are referring to the relevant company responsible for processing your data.
THE CONTROLLER OF YOUR PERSONAL INFORMATION
Under applicable data protection laws, we are required to advise you who the controller of your personal information is. The controller of the personal information covered by this Privacy Policy is Westmorland Limited, Westmorland Family Office, Rheged, Redhills, Penrith, Cumbria CA11 0DQ. Further contact details can be found in the CONTACT US section of this Privacy Policy. We will let you know which entity will be the controller for your data when you purchase a product or service with us.
WHAT PERSONAL INFORMATION DO WE COLLECT
This Privacy Policy applies to all personal information collected by Westmorland Limited, by whatever means, both about its customers (being someone who makes a booking, or stays, or uses any of the services, at one of our motorway services areas, hotel or event venue, or is a member of one of our loyalty programmes) and about anybody who makes an enquiry, or contacts us, on our website or in person or by letter, phone, email or text, enters a competition run by us or uses wi-fi services offered at one of our properties or facilities but is not a customer of ours.
The personal information we collect may include:-
- name, email address, home and/or business address, phone number;
- date of birth;
- booking history;
- transactional data including details about payments to and from you and other details of products and services you have purchased from us;
- information relating to your use of our services, such as room preferences, special requests, feedback and survey responses;
- marketing preferences;
- CCTV footage and other images;
- your IP address through the use of cookies; and
- the browser and device which you use to connect with our services.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated 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 privacy policy.
We do not 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, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
HOW IS YOUR PERSONAL DATA COLLECTED?
Direct interactions. We will collect this data from you when you provide it to us by phone, email, post, loyalty cards, feedback cards, through our website, though our onsite Wi-Fi provider, or in person.
Automated technologies or interactions. As you interact with our website, we will automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy https://westmorlandfamily.com/cookies/ for further details.
LEGAL BASIS FOR PROCESSING OUR CUSTOMERS’ INFORMATION
We will only use your personal information as the law permits. The legal bases we principally rely upon are:
- it is necessary for the performance of a contract between us for the provision of services or in order to take steps at your request prior to entering into such a contract; and/or
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; and/or
- where we need to comply with a legal obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us using the contact details set out below.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We intend to use your personal information for the following purposes:-
- to fulfil your bookings and/or to provide services or facilities you request from us;
- to collect payment from you;
- to administer and manage our relationship with you, which may include asking you to complete surveys or feedback forms;
- where you have made a reservation with us, to send you information before your visit to confirm the reservation and to provide you with other information relating to your reservation which we think you may find of interest;
- to send you information relating to the loyalty club (if you are a member) (such as loyalty club redemptions and vouchers) and relating to your membership of our clubs (if you are a member);
- to send you marketing and promotional material where we think this may be of interest to you if you have provided us permission to do so
- to display relevant and targeted online advertising based on your browsing history on our website and social media activity based on your cookie data
- to improve our websites and online content based on our customers online activity on our website
- where required by law
MARKETING
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
Opting out
You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences, by following the opt-out links on any marketing message sent to you or by contacting us at any time.
Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see https://westmorlandfamily.com/cookies/.
CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
HOW LONG DO YOU KEEP MY DATA FOR?
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances you can ask us to delete your data: see YOUR RIGHT TO ACCESS YOUR PERSONAL INFORMATION AND YOUR OTHER RIGHT below.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you. We will take all reasonable steps to destroy, or erase from our systems, all the personal information we hold about you when it is no longer required.
IF YOU FAIL TO PROVIDE PERSONAL INFORMATION REQUESTED
Where we need to collect personal data by law or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to cancel a service you have booked with us but we will notify you if this is the case at the time.
SHARING YOUR PERSONAL INFORMATION WITH OTHERS
We will not disclose personal information we hold about you to any third party except where required by law or as follows:
- to companies within the Westmorland Family group;
- to third parties who provide services to us, and act as data processors for us;
- to professional advisers including lawyers, bankers, auditors and insurers;
- to HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances;
- in the event that we sell any business or assets, we may disclose personal information we hold about you to the prospective and actual buyer of such business or assets.
If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Policy. Please note that we do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
TRANSFERRING YOUR PERSONAL INFORMATION OUTSIDE THE EEA
- We may transfer your personal data to countries outside the UK where necessary for the purposes set out in this privacy policy, such as where our IT service providers process data outside of the UK. We will only do this, or allow our suppliers to do so, where we are satisfied that your data is protected by equivalent laws and/or appropriate safeguards. To obtain further information, please contact us using the details below.
DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
YOUR RIGHT TO ACCESS YOUR PERSONAL INFORMATION AND YOUR OTHER RIGHTS
Under data protection laws you have rights in relation to your personal data as follows:
- Request access to your personal data (commonly known as a “data subject access request”).
- Request correction of the personal data that we hold about you.
- Request erasure of your personal data. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party).
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in certain scenarios.
- Withdraw consent at any time where we are relying on consent to process your personal data.
If you wish to exercise any of the rights set out above, please contact us by using the contact details set out below.
MANAGING YOUR PERSONAL INFORMATION
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
If at any time you believe that any personal data we are holding about you is inaccurate, out-of-date or incomplete, please contact us using the details below.
CHANGES TO THIS POLICY
We may need to make changes to this Privacy Policy from time to time to take account of changes in law or the needs of our business. Please refer back to this page regularly to see any changes or updates to this Policy. This Policy was last updated in September 2023.
THIRD-PARTY LINKS
This website may include links to third-party websites, plug-ins and applications. 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 notice of every website you visit.
CONTACT US
If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact us using the details set out below:-
By Post
Data Protection Department
Westmorland Limited
Westmorland Family Office
Rheged
Redhills
Penrith
CA11 0DQ
Tel: 015396 24511
By Email data.protection@westmorlandfamily.com
COMPLAINTS
If you are not satisfied with our response to any queries or complaints you raise with us or believe we are not processing your personal data in accordance with the Data Protection laws you have the right to lodge a complaint at the Information Commissioner’s Office (ICO) (https://ico.org.uk/). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
UPDATED JUNE 2024
SOCIAL MEDIA COMPETITIONS
1. The promoter is: Westmorland Ltd (Company no 53 578 57) whose registered office is at Westmorland Place, Orton, Penrith, CA10 3SB.
2. Employees of Westmorland Ltd. or their family members or anyone else connected in any way with the competition or helping to set up the competition shall not be permitted to enter the competition.
3. There is no entry fee and no purchase necessary to enter our competitions.
5. Closing date for entry are stated on the competition post. After this date the no further entries to the competition will be permitted.
6. No responsibility can be accepted for entries not received for whatever reason.
8. The promoter reserves the right to cancel or amend the competition and these terms and conditions without notice in the event of a catastrophe, war, civil or military disturbance, act of God or any actual or anticipated breach of any applicable law or regulation or any other event outside of the promoter’s control. Any changes to the competition will be notified to entrants as soon as possible by the promoter.
9. The promoter is not responsible for inaccurate prize details supplied to any entrant by any third party connected with this competition.
10. No cash alternative to the prizes will be offered. The prizes are not transferable. Prizes are subject to availability and we reserve the right to substitute any prize with another of equivalent value without giving notice.
11. Winners will be chosen at random unless otherwise stated.
12. The winner will be notified by email or social meida messaging within 28 days of the closing date. If the winner cannot be contacted or do not claim the prize within 14 days of notification, we reserve the right to withdraw the prize from the winner and pick a replacement winner.
13. The promoter will notify the winner when and where the prize can be collected.
14. The promoter’s decision in respect of all matters to do with the competition will be final and no correspondence will be entered into.
15. By entering this competition, an entrant is indicating his/her agreement to be bound by these terms and conditions.
16. The competition and these terms and conditions will be governed by English law and any disputes will be subject to the exclusive jurisdiction of the courts of England.
17. The winner agrees to the use of his/her name and image in any publicity material. Any personal data relating to the winner or any other entrants will be used solely in accordance with current UK data protection legislation and will not be disclosed to a third party without the entrant’s prior consent.
18. The winner’s name will be available 28 days after closing date by sending a stamped addressed envelope to the following address: Westmorland Limited, Westmorland Place, Orton, Penrith, CA10 3SB
19. Entry into the competition will be deemed as acceptance of these terms and conditions.
20. This promotion is in no way sponsored, endorsed or administered by, or associated with, Facebook, Twitter or any other Social Network. You are providing your information to Westmorland Ltd. and not to any other party.
21. This competition is in no way sponsored, endorsed, administered by, or associated with the Prize Provider, as stated on the social media post.
22. Any images shared on social media channels are owned by the platform provider. By entering the competition you give us the right to use the image for marketing purposes.