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Date Last Modified: April 18, 2018

PRIVACY POLICY

Seacare Inverness Ltd. (Columba Hotel Inverness, under Compass Hospitality Management Group) and/or Compass Hospitality respects your preferences concerning the collection and use of your Personal Information. The following privacy policies are tailored for the different ways your Personal Information is collected through Compass Hotel Group websites.

This Policy ("Policy") lets you know how we collect and use your Personal Information, how you can control its use, and describes our practices regarding information collected from the different sources that link or refer to this Policy (not limited to but also other modes such as our websites, computer or mobile software applications, and HTML-formatted e-mail messages). Your personal information allows us to provide the products and services you have asked for, as well as enabling us to improve those products and services by understanding your interests and preferences. By understanding what you like (and what you don’t) we are able to personalize your experience, show relevant adverts and improve your stay.

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 agree to the collection and use of Personal Information as described in this Statement.

WHO WE ARE?

Seacare Inverness Ltd. (Columba Hotel Inverness, under Compass Hospitality Management Group) and/or Compass Hospitality (“we”, “our”, “us”) is the data controller when you provide information to any of our brands, including 4 distinctive brands: Compass, Citrus, Citin, and Ananda Spa (alongside our Compass Collection which includes individually ‘White label’ branded hotels and resorts), Compass Hospitality offers a large variety of lifestyle preferences and accommodation needs, delivering gracious services for a truly memorable experience.

Compass Hospitality is part of a multi-national brand and will take appropriate steps to ensure that your personal information is handled as described in this Privacy Policy and in accordance with the law with regards to international data transfers i.e. informing the client.

LEGAL BASIS FOR USING YOUR INFORMATION WITH YOUR CONSENT.

There are some activities where we process personal information with your consent, which you are able to withdraw at any time, although if you do, we may not be able to provide the product or service you have requested. For example, where we want to send you marketing messages by email, we would ask your permission first and you could opt-out at any time. We will indicate in the Policy where we rely on consent.

WHAT INFORMATION THAT WE COLLECT?

We may collect Personal Information which may include, but not limited to:

HOW WE USE AND SHARE INFORMATION

We collect information you provide to us directly and indirectly when interacting with our products and services, including when you stay with us. This may include when you:

In addition, we collect other personal information in certain cases, such as:

CHILDREN & SENSITIVE INFORMATION

The term "sensitive information" refers to information related to your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, sex life, or sexual orientation, genetic information, criminal background, and any biometric data used for the purpose of unique identification. We do not generally collect sensitive information unless it is volunteered by you. We may use health data provided by you to serve you better and meet your particular needs (for example, the provision of disability access).

We do not knowingly collect personal information from individuals under 18 years of age. As a parent or legal guardian, please do not to allow your children to submit personal information without your permission.

THIRD PARTY WEBSITES & SERVICES

Our website may contain links to third parties' websites. Please note that we are not responsible for the collection, use, maintenance, sharing, or disclosure of data and information by such third parties. If you provide information on and use third-party sites, the privacy policy and terms of service on those sites are applicable. We encourage you to read the privacy policies of websites that you visit before submitting personal information.

We may also partner with a limited number of Internet providers to offer Internet access to our guests. Your use of on-property Internet service is subject to the third-party Internet provider’s terms of use and privacy policy. You can access those terms and policies using the links on the service sign-in page, or by visiting the Internet provider’s website.

SHARING OF PERSONAL DATA

In order to offer you the expected level of hospitality and to provide you with the best level of service, we may share your personal information among members of the Compass Hospitality Portfolio of Brands, our service providers, and other third parties as set forth in detail below:

MARKETING. Knight Properties (Halifax) Ltd. (White Swan Hotel Halifax, under Compass Hospitality Management Group) may use your Personal Information and Other Information to notify you about new product releases and service developments, and to advertise Knight Properties (Halifax) Ltd. (White Swan Hotel Halifax, under Compass Hospitality Management Group) products and services in accordance with this Policy. Your website visit, marketing experience, and communications may be tailored to your interests based on your Personal Information. Knight Properties (Halifax) Ltd. (White Swan Hotel Halifax, under Compass Hospitality Management Group) may share your Personal Information to specific third party partners to facilitate interest-based advertising. Other Information uses specified above are not mandatory and may be controlled by you. Please refer to the "Registration and Privacy Choices" section below for opt-out options.

IMPROVE PRODUCTS, SERVICES AND EXPERIENCES. Knight Properties (Halifax) Ltd. (White Swan Hotel Halifax, under Compass Hospitality Management Group) may use your Personal Information to evaluate and improve our products, services, marketing, and customer relationships.

OBTAIN THIRD PARTY SERVICES. We also share Personal Information with third parties who provide services to Knight Properties (Halifax) Ltd. (White Swan Hotel Halifax, under Compass Hospitality Management Group), such as credit card processing services, analytics, website management, information technology and related infrastructure provision, customer service, e-mail delivery, and other similar services. When Knight Properties (Halifax) Ltd. (White Swan Hotel Halifax, under Compass Hospitality Management Group) shares Personal Information with third party service providers, we require that they use your Personal Information only for the purpose of providing services to us and subject to terms consistent with this Policy.

HOW WE COLLECT INFORMATION

COOKIES.Our server will query your browser to see if there are "cookies" previously set by our electronic Channels. A cookie is a small piece of information sent by a Web server to store on a Web browser so it can later be read back from that browser. Cookies may collect information, including a unique identifier, user preferences, profile information, membership information, and general usage and volume statistical information. Cookies may also be used to collect individualized website use data, provide electronic Channel personalization, or conduct and measure the effectiveness of advertising in accordance with this Policy. Some cookies may remain on users' computers after they leave the website. While the majority are set to expire within 1-24 months of your last visit to the website that set the cookie, others may not expire because of their nature, like cookies that remember opt-out preferences. Your browser may provide you with information and control over cookies. You can set your browser to alert you when a cookie is being used, and accept or reject the cookie. You can also set your browser to refuse all cookies or accept only cookies returned to the originating servers. Users can generally disable the cookie feature on their browser without affecting their ability to use the site, except in some cases where cookies are used as an essential security feature necessary for transaction completion. Cookies, however, are important to the proper functioning of a site, and disabling them may degrade your experience and interfere with website features and customizations.

REGISTRATION AND PRIVACY CHOICES

REGISTRATION.We allows you to establish an online registration profile for marketing communications. You may use the profile to customize and control your preferences for receiving electronic information, including opting into (or out of) communities, newsletters and general interest areas. You can return to the registration profile at any time to change your elections or modify your profile.

EMAIL MARKETING. We enables you to opt out of cookies that are not required to enable core site functionality. We uses its cookies preferences tool to process Internet advertising and tracking preferences, but does not respond any other Do Not Track signals.

Please remember that if you delete your cookies, or use a different browser or computer, you will need to set your cookies preferences again. You may access or change your cookie preferences at any time. If you have any problems using this cookie preference mechanism, please fill out an inquiry form.

ACCESS, CORRECTIONS AND PROFILE UPDATES

You may request to review, correct, update, suppress, or otherwise modify any of your Personal Information that you have previously provided to us through the Channels, or object to the use or processing of such Personal Information by us. You have the ability to update your profile and related Personal Information at any time. To change this information, please drop an email to dataprotection.uk@compasshospitality.com and we will provide you link to update your profile. Please also visit Frequently Asked Questions (FAQs) and request help with your account. If you have privacy concerns regarding access to or the correction of your Personal Information, please contact us write to us at dataprotection.uk@compasshospitality.com.

PROTECTING PERSONAL DATA

We will take reasonable measures to: (i) protect personal information from unauthorised access, disclosure, alteration or destruction, and (ii) keep personal information accurate and up-to-date as appropriate. We also seek to require our affiliates and service providers with whom we share personal information to exercise reasonable efforts to maintain the confidentiality of personal information about you. For online transactions, we use reasonable technological measures to protect the personal information that you transmit to us via our site. Unfortunately, however, no security system or system of transmitting data over the Internet can be guaranteed to be entirely secure. For your own privacy protection, please do not send payment card numbers or any other confidential personal information to us via email. We will not contact you by mobile/text messaging or email to ask for your confidential personal information or payment card details. We will only ask for payment card details by telephone when you are booking a reservation or promotional package. We are part of a multi-national brand and will take appropriate steps to ensure that your personal information is handled as described in this Statement and in accordance with the law with regards to international data transfers i.e. informing the client. In line with GDPR legislation, should a data breach occur i.e. data is lost/hacked/is inaccessible then we accepts its responsibility to ensure that material and non-material harm to the client is avoided and will report the breach to ICO within 72 hours.

ACCESSING PERSONAL DATA

To the extent required by applicable law, you may be able to request that we inform you about the personal information we maintain about you and, where appropriate, request that we update, correct and/or delete personal information about you that we maintain in our active database. We will make all required updates and changes within 1 month of receiving the request. If you are a Loyalty Card member, the information you provided to us at the time of registration may be accessed, reviewed and updated at any time by signing in via our customer portal.

Such requests must be submitted in writing to dataprotection.uk@compasshospitality.com or Compass Hospitality Customer Privacy Department, The Victoria Hotel, Hollinwood Avenue, Chadderton, Oldham, OL9 8DE United Kingdom. To protect your confidentiality, we can only respond to such requests to the email address that you have registered or otherwise provided to us. Please remember that if you make such a request, we may not be able to provide you with the same quality and variety of services to which you are accustomed.

In addition, in some circumstances based on applicable law, you may request that we cease sharing personal information about you with our business partners or that we cease using personal information about you by contacting us using the email or mailing address above. We will seek to honor those requests consistently with applicable law.

RETENTION AND DELETION

We will retain your Personal Information for as long as your account is active; as needed to provide you products or services; as needed for the purposes outlined in this Policy or at the time of collection; as necessary to comply with our legal obligations (e.g., to honor opt-outs), resolve disputes, and enforce our agreements; or to the extent permitted by law.

At the end of the retention period, we will delete your Personal Information in a manner designed to ensure that it cannot be reconstructed or read.

SECURITY

The security of your Personal Information is very important to Compass. We use physical, electronic, and administrative safeguards that are designed to protect your Personal Information from loss, misuse and unauthorized access, disclosure, alteration and destruction.

In addition, we uses standard security protocols and mechanisms to exchange the transmission of sensitive data such as credit card details. When you enter sensitive Personal Information such as your credit card number on our site, we encrypt it using secure socket layer (SSL) technology.

In the event that your Personal Information is acquired, or is reasonably believed to have been acquired, by an unauthorized person and applicable law requires notification, we will notify you by email. We will give you notice promptly, consistent with the reasonable needs of law enforcement to determine the scope of the breach and to investigate and restore the integrity of the data system.

SITE COPYRIGHT POLICY

The content of each page of this website is the property of Seacare Compass Manchester Ltd. (Victoria Hotel Manchester, under Compass Hospitality Management Group) and/or Compass Hospitality. No part of our website may be reproduced, displayed or republished in any form without prior consent, except that permission is granted to a user to print or photocopy individual articles or entire pages from our website, provided that this is for personal use only.

COOKIES POLICY

USE OF COOKIES

You are advised that Knight Properties (Halifax) Ltd. (White Swan Hotel Halifax, under Compass Hospitality Management Group) uses cookies or other tracers on both corporate website ( (http://www.columbahotelinverness.co.uk)) (https://www.compasshospitality.com) and its respective individual online hotel booking websites, which are under the Compass Hotel Management Group.

1. WHY HAVE A COOKIES POLICY?

To provide information and ensure transparency, Knight Properties (Halifax) Ltd. (White Swan Hotel Halifax, under Compass Hospitality Management Group) established this policy so that you can know how we process your information when browsing our websites as well as to let you know your rights in regard to cookies and tracers used by Knight Properties (Halifax) Ltd. (White Swan Hotel Halifax, under Compass Hospitality Management Group).

2. WHAT IS A COOKIE?

A Cookie and other similar tracers are packets of data used by servers to send status information to a user's browser and return status information to the original server through this same browser. It helps the website to remember information about your visit, like your preferred language and other settings. Cookies are used to store status information when a browser accesses various pages of a website or when the browser returns to this website at a later point.

3. WHY USE COOKIES?

Knight Properties (Halifax) Ltd. (White Swan Hotel Halifax, under Compass Hospitality Management Group) uses cookies and other tracers (such as “pixel tags,” “web beacons,” “clear GIFs”, links in emails, JavaScript, device IDs assigned by Google or Apple, or similar technologies) to collect this information primarily for the following purposes:

Cookies for visitor tracking are aimed at improving the comfort of users by helping Knight Properties (Halifax) Ltd. (White Swan Hotel Halifax, under Compass Hospitality Management Group) understand your interactions with Knight Properties (Halifax) Ltd. (White Swan Hotel Halifax, under Compass Hospitality Management Group) Websites (most visited pages, applications used, etc.); these cookies may collect statistics in order to improve the relevance and usability of our services.

Advertising cookies are intended to offer you, in advertising spaces, relevant, targeted content that may be of interest to you (best offers, other destinations, etc.) based on your interests, browsing behavior, preferences, and other factors.

Affiliate cookies identify the third-party website(s) that redirected a visitor to Knight Properties (Halifax) Ltd. (White Swan Hotel Halifax, under Compass Hospitality Management Group).

4. CONSENT

The installation of certain cookies is subject to your consent. Also, when you first visit the Knight Properties (Halifax) Ltd. (White Swan Hotel Halifax, under Compass Hospitality Management Group), you are asked whether you agree to the installation of this type of cookie, which is only activated after your acceptance.

You can change your mind at any time using the various methods described in section "Deleting and/or blocking cookies".

5. DELETING AND/OR BLOCKING COOKIES

You have several options for deleting cookies and other tracers as described below.

Browser settings

Although most browsers are set by default to accept cookies, you can, if you desire, choose to accept all cookies, always block cookies, or choose which cookies to accept based on their senders.

You can also set your browser to accept or block cookies on a case-by-case basis before they are installed. Your browser also allows you to regularly delete cookies from your device. Remember to configure all the browsers in your different devices (tablets, smartphones, computers, etc.).

Regarding management of cookies and your preferences, configuration varies for each browser. This is described in the Help menu of your browser, as well as how to edit your preferences with regard to cookies. For example:

For Internet Explorer™: http://windows.microsoft.com/en-US/windows-vista/Block-or-allow-cookies
For Safari™: http://www.apple.com/legal/privacy/en-ww/cookies
For Chrome™: http://support.google.com/chrome/bin/answer.py?hl=en&hlrm=en&answer=95647
For Firefox™: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences
For Opera™: http://help.opera.com/Windows/10.20/en/cookies.html

Saving a cookie to your device depends on your wishes, which you can exercise and change at any time and free of charge using the settings offered by your browser software.

Google Analytics Opt-out Browser Add-on

To provide website visitors the ability to prevent their data from being used by Google Analytics, Google developed the Google Analytics opt-out browser add-on for the Google Analytics JavaScript (ga.js, analytics.js, dc.js). https://tools.google.com/dlpage/gaoptout?hl=en

If your browser is set to accept cookies on your device, the cookies embedded in the pages and content that you view may be temporarily stored in a dedicated space on your device. They can only be read by their issuer.

However, you can set your browser to block cookies. Keep in mind that if you set your browser to block cookies, some features, pages and spaces on Seacare Inverness Ltd. (Columba Hotel Inverness, under Compass Hospitality Management Group) will not be accessible, and we cannot be held responsible in this case.

CHANGES TO OUR PRIVACY AND COOKIE POLICY

From time to time we may make changes to this Policy. This might be in relation to changes in the law, best practice, changes to the services we provide or collection and use of your personal information. We will always display clearly when the Policy was last updated and where appropriate, notify you of any relevant changes.

CONTACT

In accordance with GDPR legislation, If you have given us your explicit consent to use your contact information (mail address, fax number, email address or phone number), we may want to inform you in accordance with any preferences you have expressed, about our products and services or invite you to events via email, online advertising, social media, telephone, text message (including SMS and MMS), push notifications, in-app alerts, postal mail, our customer service call center, and other means (including on-property messaging, such as your in-room television).

If you are a Loyalty Card Member, you may change the communications you receive from us by logging on to your online account and managing your subscriptions via the online portal. Or by writing to us (and including your email address) at Compass Hospitality Customer Privacy Department, The Victoria Hotel, Hollinwood Avenue, Chadderton, Oldham, OL9 8DE United Kingdom, or by emailing us at dataprotection.uk@compasshospitality.com.

If you prefer not to receive email marketing materials from us, you may opt-out at any time by using the unsubscribe function in the email you receive from us. Opt-out requests can take up to ten business days to be effective.

To opt out of text messages, tell the hotel front desk that you do not want to receive text messages from the hotel or reply “STOP” to the message you received.

If you would like to get in touch with us, please send us an email at the following email addresses:

THAILAND dataprotection.th@compasshospitality.com
UNITED KINGDOM dataprotection.uk@compasshospitality.com
MALAYSIA dataprotection.my@compasshospitality.com