About this privacy notice

At Considerate Hoteliers Ltd, we respect your privacy and are committed to protecting your personal data.  This ‘privacy notice’ explains, amongst other things, how and why we collect, store, use and share personal data and your rights to control our use of it.

It applies not just to use of our website, but also personal data that we process through other interactions with individuals in the course of running our business and delivering our services.  This includes potential and existing clients, industry contacts, people interested in working for or with us and our suppliers.

Our website and services are not intended for children and we do not knowingly collect data relating to children.

Information about the data controller

In this policy, “we”, “us” and “our” refer to Considerate Hoteliers Ltd. In operation of the fluttr app and our website we collect, use and are responsible for certain personal data about you. Where we collect, use and are responsible for personal data about individuals (including you), we are regulated under applicable data protection laws, such as the EU General Data Protection Regulation (“GDPR”) and corresponding UK laws.  We are responsible as “data controller” of that personal information for the purposes of the law.

We are registered in England and Wales under registration number 07996155, and our registered office is at C/O Oliver Phillips Ltd, Suite 20, 46 Aldgate High Street, London, EC3N 1AL. Our principal place of business and contact address is: 2 Eastbourne Terrace, London, W2 6LG.

You can contact us:

(a) by post, at the contact address given above;

(b) using our website contact form;

(c) by telephone, on +44 (0)20 3865 2052;

(d) by email, using info@considerategroup.com

How we use your personal data

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). 

Applicable data protection laws, in particular GDPR, require us to explain what data we collect, for what purpose and on what legal (or ‘lawful’) basis. These categories are detailed below:

Website Users

We use Google Analytics to analyse the use of our website and track visitor numbers. Google Analytics gathers information about website use by means of cookies. The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. This information enables us to assess how each user is using our site, so we can continue to monitor and improve our service. Google’s privacy policy is available at: https://policies.google.com/privacy

If you complete the ‘Contact Us’ form on our website

If you complete the form on our website to contact us, we will store the data you enter (usually name, contact details, comment) for the purposes of answering your enquiry and/or marketing and business development. We do this on the basis that it is necessary for our legitimate interests in promoting our business to interested parties. We store your data for as long as we need to interact with you for these purposes. If you would like us to update or delete any of your information, please send us an email (as provided in our contact details above) or use the unsubscribe links on marketing emails.

Newsletter subscribers

If you sign up for our newsletter on our website, we will hold your email address for the purpose of sending you information on company updates and industry news. We process this data on the basis that we have your consent. You can withdraw your consent at any time by using the “unsubscribe” links at the bottom of each email. We use Constant Contact to deliver our newsletters and occasional mailouts. We gather statistics around email opening and clicks using industry standard technologies to help us monitor and improve our content. This service uses cookies for sending data to the marketing platform about the visitor’s device and behaviour. You can view the privacy policy of this service provider at https://www.endurance.com/privacy.

Account Data

We may hold your name, company, job title and contact details, if you work for a client or if you are working in an area related to our business. We will have been provided with this data either by you, a mutual contact or your employer, or in some cases we may have sourced it from publicly available sources. We need this data in order to interact with you (or your employer) for the purposes of the proper administration of our website and business, and to communicate with interested parties regarding news and updates.

We do this on the basis that it is necessary for our legitimate interests in operating and developing our business. We will hold your details for as long as we need to interact with you for these purposes. In all cases if you would like us to update or delete your information, please send us an email (see contact details above).

Cookies and similar technologies

If you visit the Fluttr website or use the Fluttr app, we may store information relating to you using cookies or similar technologies, which we can access when you visit our site in future. Cookies are small files, which are sent by us to your computer or other access device, that track, save and store information about your interactions and usage of our website.  Cookies enable our website to work, improve site security and help us provide you with a better service.

Generally, the cookies used do include information from which you can be identified as an individual.  For more information on our use of cookies and how to control them see our Cookie Policy.

Retention of personal information

We will only retain your personal data 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, taking into account applicable data protection laws, retention periods under applicable laws, limitation periods and our business needs.

Sharing your personal data

We may share your personal data with the following third parties in certain circumstances:

• IT and system administration service providers acting as data processors (see below) who provide services or cloud-based software to enable us to operate our organisation.
• Professional advisers such as lawyers, bankers, accountants or auditors in order to provide legal, finance, accounting or auditing services.
• Law enforcement or other authorities (such as tax authorities) if required by applicable law.

We reserve the right to disclose your information to a third party as part of a merger or transfer, acquisition or sale, or in the event of a bankruptcy. In such case, we will require the relevant third parties to provide comparable levels of protection as we provide with respect to the information we share.

Data processors:  We use a number of different service providers (acting as ‘data processors’) who provide IT and system administration services to enable us to operate our organisation and the services we provide. Your personal data is transferred to (and stored by) these data processors, who generally fall under the following categories:

• Website analytics
• Website and data hosting
• IT and system administration
• Document storage
• Email, contacts and calendar
• CRM, accounting and billing
• Engineering and metering

These ‘data processors’ only process data on our behalf.  They won’t use your personal data for their own purposes and we only permit them to use it in accordance with our instructions, our contract with them and the law.

For security reasons we do not name all our service providers in this privacy notice. Please contact us (see above) if you want further information on specific data processors or the types of personal data they process for us.

International transfers of personal data, and the measures in place to safeguard it

We do not directly transfer any of your personal data outside the European Economic Area (EEA). However, some of our data processors may do so and this section explains the impact of these international transfers and how your information is protected.

Many of our data processors operate “cloud-based systems”, which means the information is held in information data centres in different locations. In some cases, they hold copies of your personal information outside the EEA.

In each case we and our processors employ one or more of the following mechanisms that are designed to help safeguard your privacy rights:

• Restricting transfers to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.

• Use of specific contractual clauses approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries. 

• For providers storing data in the US, self-certification to the EU-US Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

Please contact us (see above) if you want further information on the specific mechanisms used by our data processors when transferring your personal data out of the EEA.

Your personal data rights

The personal data we hold about you is your data, and you have certain rights over the data under applicable data protection laws. This section summarises the rights you have where your personal data is protected under GDPR.  

• You have the right to request a copy of all personal data we hold relating to you. You also have the right to require us to correct any mistakes in the personal data we hold relating to you.

• Where we are processing your data based on your consent you can withdraw that consent and we must immediately stop processing your data.

• Where we process your data based on a “legitimate interest” (underlined in the section on “purpose and lawful basis”, above) you still have the right to object to our processing of that data if you feel it impacts on your fundamental rights and freedoms.

• You also have the right to object where we are processing your personal data for direct marketing purposes.  The easiest way to do this is to use the unsubscribe links at the bottom of all marketing emails.

• In certain situations, you have the right to require us to erase personal data where there is no good reason for us continuing to process it, or to request restriction of processing of your personal data.

• Finally, you have the right to request the transfer of your personal data to you or a third party in a structured, commonly used, machine-readable format in certain circumstances.

For further information on each of these rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals rights under the General Data Protection Regulation.

If you would like to exercise any of these rights, the easiest way is by dropping us an email (see above).

Keeping your personal information secure
We have appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorised way. In addition, we limit access to your personal data to those employees 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 also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

Your rights to lodge a complaint with the Regulator
We hope to be able to resolve any reported issues promptly and fairly. However, at any time, you have the right to report a concern or lodge a complaint with the Information Commissioner’s Office. They can be contacted via their website: https://ico.org.uk/concerns/, or by phone on 0303 123 1113.

Changes to this privacy policy
This privacy policy was last updated on 30^th October 2020.
We may change this privacy policy from time to time by amending this page.