1. Important information
Direct interactions. You may give us your Identity, Contact and Financial Data by registering as a User on our app, submitting a booking application for our motel or booking a table at our restaurant;
Automated technologies or interactions. As you interact with our app and website, we will automatically collect Technical, Profile and Usage Data about your equipment, browsing actions and patterns; and
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.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.
3. The data we collect about you
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). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
Identity Data includes first name, last name, username or similar identifier, title, date of birth, photos/images and gender.
Contact Data includes billing address, delivery address, physical address(es), postcode, email address and telephone numbers.
Financial Data includes bank account details and your debit/ credit card information.
Transaction Data includes details of the properties where you have stayed, date of arrival and departure and goods and services purchased.
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our app or this website.
Profile Data includes your username, purchases or orders made by you, your interests, preferences, feedback, details of any special occasions such as anniversaries, and/or survey responses. Usage Data includes details of your use of our app or website.
4. How is your personal data collected?
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity, Contact and Financial Data by registering as a user on our app, or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
create an account on our app;
making a reservation for our restaurant;
make a reservation for our motel;
purchase items in our restaurant and general store or via third party online ordering providers
reach out to us through other means, such as social media;
request marketing to be sent to you; or
give us feedback or contact us.
Third Parties. We will receive personal data about you from various third parties as set out below:
Type of data
Table Reservation System
Profile information submitted as part of a table reservation including name, email, phone number, date of birth
Property Management System
Profile information submitted as part of a room booking including name, email, phone number, date of birth
This covers bookings made via any channel including, but not limited to, Direct, Booking Engine, Online Travel Agents such as Booking.com or Expedia
Guest Database / CRM
Profile information submitted as part of a room booking or table reservation including name, email, phone number, date of birth
Booking and purchase history from hotel stays and restaurant visits
Profile information submitted as part of a digital payment in a restaurant or food and beverage outlet including name and email
Profile information submitted as part of a payment including name, email and billing details
Profile information and any further information provided directly by the user in regards to any query or request submitted to Mollie’s via the chat feature or other methods of communication
Information related to tracking and targeting features
Information related to tracking and targeting features
5. How we use your personal data
We will only use your personal data when the law allows us to do so. Most commonly, we will use your personal data in the following circumstances:
Where you have consented before the processing.
Where we need to perform the contract we are about to enter into or have entered into with you.
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.
Where we need to comply with a legal or regulatory obligation. We will only send you direct marketing communications by email if we have your consent or where we have previously given you an opportunity to object to the provision of direct marketing by email in the course of a sale or negotiations for sale of a product or service with you and you have not objected. Where the latter occurs, we will only send you marketing communications about the same or similar products and services which we feel may be of interest to you. You have the right to withdraw consent and/or indicate you no longer wish to receive marketing communications from us at any time by contacting us. We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below. Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest.
Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To acknowledge, confirm and deal with your restaurant booking or motel booking. (a) Identity
(a) Performance of a contract with you.
(b) Necessary for our legitimate interest.
Creating a user account on our app and website to allow you to make reservations for our restaurants and motels, take advantage of special offers, and manage your personal settings.
(a) Performance of a contract with you.
(b) Necessary for our legitimate interest.
To manage our relationship with you including notifying you of changes to your restaurant and motel booking, sending you a questionnaire or where we are asked to deal with any enquiries or complaints you make.
(d) Marketing and Communications
(a) Your consent.
(b) Performance of a contract with you.
(c) Necessary for our legitimate interest.
(d) Necessary to comply with legal obligations.
Storing and using data to improve our data models and algorithms.
Necessary for our legitimate interests (to train and improve the accuracy of our data models and analytics and to improve our service).
To administer and protect our business and our software including troubleshooting, data analysis and system testing.
Necessary for our legitimate interests (for running our business, provision of administration, IT services and network security).
6. 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. UK-651139447.8 7 5. DISCLOSURES OF YOUR PERSONAL DATA We may share your personal data with the parties set out below for the Purposes set out in the table above. |
External Third Parties as set out in the Glossary.
7. International transfers
We may transfer your personal data to the following which are located outside the United Kingdom (UK) and European Economic Area (EEA) as follows: United States of America
8. 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.
9. Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory 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, regulatory or other requirements. UK-651139447.8 8 In some circumstances we will 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.
10. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to: Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. 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 successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. 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) and there is something about your particular situation which makes you want to object to processing on this ground as 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. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms. Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
If you want us to establish the data’s accuracy.
Where our use of the data is unlawful but you do not want us to erase it.
Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable UK-651139447.8 9 format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent. If you wish to exercise any of the rights set out above, please contact us.
No fee usually required
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 is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
app means Mollie’s (version 2.1.0) mobile application software, the data supplied with the software and any updates or supplements to it which allows a customer to make a reservation in our restaurants or motels.
Consent means that you have given us permission (your consent) to process your personal data for one or more specific purposes. Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us. UK-651139447.8 10 Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract. Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
External third parties
Payment gateway – Data Controller (EEA)
Table reservation system – Data Processor (US)
Property management system – Data Processor (EEA)
Room booking engine – Data Processor (EEA)
Online ordering platform (which includes take away transactions, general store purchases, and 3rd party online ordering such as Deliveroo) – Data
Processor (US and UK)
Customer relationship management system – • Data Processor (EEA)
Guest messaging platform – Data Processor (UK) • IT networking and WiFi provider – Data Processor (UK)
Housekeeping system – Data Processor (EEA)
Gift card and voucher system – Data Processor (UK)