What we do with your information
To support NHS Test and Trace (which is part of the Department for Health and Social Care) in England, we have been mandated by law to collect and keep a limited record of staff, customers and visitors who come onto our premises for the purpose of contact tracing. For specific information on how your data is used to comply with this requirement, please read our Test and Trace Statement.
1. PURPOSE OF THIS NOTICE
This notice describes how we collect and use personal data about you, in accordance with the
General Data Protection Regulation (GDPR), the Data Protection Act [1998 OR 2018] and any other
national implementing laws, regulations and secondary legislation, as amended or updated from
time to time, in the UK (‘Data Protection Legislation’).
Please read the following carefully to understand our practices regarding your personal data and
how we will treat it.
2. ABOUT US
Pentire Hotel Ltd is a hotel company. We are registered in England and Wales as a limited liability
company under number: 5477775 and our registered office is at 6 Dainton Manor Estate, Ipplepen,
Newton Abbot TQ12 5TZ.
For the purpose of the Data Protection Legislation and this notice, we are the ‘data controller’. This
means that we are responsible for deciding how we hold and use personal data about you. We are
required under the Data Protection Legislation to notify you of the information contained in this
3. HOW WE MAY COLLECT YOUR PERSONAL DATA
We obtain personal data about you, for example, when:
• you make an enquiry with us;
• you make a booking;
• you contact us by email, telephone, post or social media? or
• from third parties such as booking agencies
4. THE KIND OF INFORMATION WE HOLD ABOUT YOU
The information we hold about you may include the following:
• your personal details such as your name and address;?
• details of contact we have had with you in relation to the provision, or the proposed provision, of
• details of any services you have received from us;
• our correspondence and communications with you;
• information about any complaints and enquiries you make to us;
• information from research, surveys, and marketing activities;
5. HOW WE USE PERSONAL DATA WE HOLD ABOUT YOU
We may process your personal data for purposes necessary for the performance of our contract
with you and to comply with our legal obligations.
We may process your personal data for the purposes necessary for the performance of our contract
with our clients. This may include processing your personal data where you are an employee,
subcontractor, supplier or customer of our client.
We may process your personal data for the purposes of our own legitimate interests provided that
those interests do not override any of your own interests, rights and freedoms which require the
protection of personal data. This includes processing for marketing, statistical and management
We may process your personal data for certain additional purposes with your consent, and in these
limited circumstances where your consent is required for the processing of your personal data then
you have the right to withdraw your consent to processing for such specific purposes.
Please note that we may process your personal data for more than one lawful basis depending on
the specific purpose for which we are using your data.
Situations in which we will use your personal data
We may use your personal data in order to:
• carry out our obligations arising from any agreements entered into between you and us which
will most usually be for the provision of our services;?
• provide you with information related to our services and our events and activities that you
request from us or which we feel may interest you, provided you have consented to be
contacted for such purposes;?
• seek your thoughts and opinions on the services we provide;? and
• notify you about any changes to our services.
In some circumstances we may anonymise or pseudonymise the personal data so that it can no
longer be associated with you, in which case we may use it without further notice to you.
If you refuse to provide us with certain information when requested, we may not be able to perform
the contract we have entered into with you. Alternatively, we may be unable to comply with our legal
or regulatory obligations.
We may also process your personal data without your knowledge or consent, in accordance with
this notice, where we are legally required or permitted to do so.
We will only retain your personal data for as long as is necessary to fulfil the purposes for which it is
When assessing what retention period is appropriate for your personal data, we take into
• the requirements of our business and the services provided;?
• any statutory or legal obligations;?
• the purposes for which we originally collected the personal data;?
• the lawful grounds on which we based our processing;?
• the types of personal data we have collected;?
• the amount and categories of your personal data;? and
• whether the purpose of the processing could reasonably be fulfilled by other means.
Change of purpose
we need to use your personal data for another reason, other than for the purpose for which we
collected it, we will only use your personal data where that reason is compatible with the original
Should it be necessary to use your personal data for a new purpose, we will notify you and
communicate the legal basis which allows us to do so before starting any new processing.
6. DATA SHARING
Why might you share my personal data with third parties?
We will share your personal data with third parties where we are required by law, where it is
necessary to administer the relationship between us or where we have another legitimate interest in
Which third-party service providers process my personal data?
“Third parties” includes third-party service providers. The following activities are carried out by third-
party service providers: IT services, marketing services and banking services
All of our third-party service providers are required to take commercially reasonable and appropriate
security measures to protect your personal data. We only permit our third-party service providers to
process your personal data for specified purposes and in accordance with our instructions.
What about other third parties?
We may need to share your personal data with a regulator or to otherwise comply with the law.
7. TRANSFERRING PERSONAL DATA OUTSIDE THE EUROPEAN
ECONOMIC AREA (EEA)
We will not transfer the personal data we collect about you outside the EEA.
8. DATA SECURITY
We have put in place commercially reasonable and 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 data security breach and will notify you
and any applicable regulator of a suspected breach where we are legally required to do so.
9. RIGHTS OF ACCESS, CORRECTION, ERASURE, AND RESTRICTION
Your duty to inform us of changes
It is important that the personal data we hold about you is accurate and current. Should your
personal information change, please notify us of any changes of which we need to be made aware
by contacting us, using the contact details below.
Your rights in connection with personal data
Under certain circumstances, by law you have the right to:
• Request access to your personal data. This enables you to receive details of the personal data
we hold about you and to check that we are processing it lawfully.
• Request correction of the personal data that we hold about you.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal
data where there is no good reason for us continuing to process it. You also have the right to
ask us to delete or remove your personal data where you have exercised your right to object to
processing (see below).
• Object to processing of your personal data where we are relying on a legitimate interest (or
those of a third party) and there is something about your particular situation which makes you
want to object to processing on this basis. You also have the right to object where we are
processing your personal information for direct marketing purposes.
• Request the restriction of processing of your personal data. This enables you to ask us to
suspend the processing of personal data about you, for example if you want us to establish its
accuracy or the reason for processing it.
• Request the transfer of your personal data to you or another data controller if the processing is
based on consent, carried out by automated means and this is technically feasible.
If you want to exercise any of the above rights, [please email our data protection point of contact:
You will not have to pay a fee to access your personal data (or to exercise any of the other rights).
However, we may charge a reasonable fee if your request for access is clearly unfounded or
excessive. Alternatively, we may refuse to comply with the request in such circumstances.
We may need to request specific information from you to help us confirm your identity and ensure
your right to access the information (or to exercise any of your other rights). This is another
appropriate security measure to ensure that personal information is not disclosed to any person who
has no right to receive it.
10. RIGHT TO WITHDRAW CONSENT
In the limited circumstances where you may have provided your consent to the collection,
processing and transfer of your personal data for a specific purpose (for example, in relation to
direct marketing that you have indicated you would like to receive from us), you have the right to
withdraw your consent for that specific processing at any time. To withdraw your consent, please
email our data protection point of contact: firstname.lastname@example.org
Once we have received notification that you have withdrawn your consent, we will no longer
process your personal information (personal data) for the purpose or purposes you originally agreed
to, unless we have another legitimate basis for doing so in law.
11. CHANGES TO THIS NOTICE
Any changes we may make to our privacy notice in the future will be updated on our website:
This privacy notice was last updated on 8 May 2018
12. CONTACT US
If you have any questions regarding this notice or if you would like to speak to us about the manner
in which we process your personal data, please email email@example.com
You also have the right to make a complaint to the Information Commissioner's Office (ICO), the UK
supervisory authority for data protection issues, at any time. The ICO’s contact details are as
Information Commissioner's Office
Telephone - 0303 123 1113 (local rate) or 01625 545 745
Website - https://ico.org.uk/concerns