Privacy & Cookies Policy
HCL understands that your privacy is important to you and that you care about how your personal data is used and shared online. We respect and value the privacy of everyone who visits this website, www.hospitalityconsultantslondon.com (“Our Site”) and will only collect and use personal data in ways that are described here, and in a manner that is consistent with our obligations and your rights under the law.
1. Definitions and Interpretation
In this Policy, the following terms shall have the following meanings:
“Account” means an account required to access and/or use certain areas and features of Our Site;
“Cookie” means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in section 13, below;
“Cookie Law” means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;
“personal data” means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us via Our Site. This definition shall, where applicable, incorporate the definitions provided in the EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”)
“We/Us/Our” means IWK Ventures Limited (trading as Hospitality Consultants London), a limited company registered in England under company number 12117895, whose registered address is First Floor, 184 Cheetham Hill Road, Manchester, M8 8LQ
2. Information About Us
Our Site is owned and operated by IWK Ventures Limited, a limited company registered in England under company number 12117895, whose registered address is First Floor, 184 Cheetham Hill Road, Manchester, M8 8LQ.
We are regulated by the ICO as a data controller.
3. What Does This Policy Cover?
4. Your Rights
As a data subject, you have the following rights under the GDPR, which this Policy and Our use of personal data have been designed to uphold:
- The right to be informed about Our collection and use of personal data;
- The right of access to the personal data We hold about you (see section 12);
- The right to rectification if any personal data We hold about you is inaccurate or incomplete (please contact Us using the details in section 14);
- The right to be forgotten – i.e. the right to ask Us to delete any personal data We hold about you (We only hold your personal data for a limited time, as explained in section 6 but if you would like Us to delete it sooner, please contact Us using the details in section 14);
- The right to restrict (i.e. prevent) the processing of your personal data;
- The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);
- The right to object to Us using your personal data for particular purposes; and
- Rights with respect to automated decision making and profiling.
If you have any cause for complaint about Our use of your personal data, please contact Us using the details provided in section 14 and We will do Our best to solve the problem for you. If We are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.
For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.
5. What Data Do We Collect?
- business/company name;
- job title;
- contact information such as email addresses and telephone numbers;
- demographic information such as post code, preferences, and interests;
- IP address;
- web browser type and version;
- operating system;
- behaviour and activity on Our Site;
- a list of URLs starting with a referring site, behaviour and activity on Our Site, and the site you exit to.
6. How Do We Use Your Data?
All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under the GDPR at all times. For more details on security see section 7, below.
Our use of your personal data will always have a lawful basis, either because it is necessary for Our performance of a contract with you, because you have consented to Our use of your personal data (e.g. by subscribing to emails), or because it is in Our legitimate interests. Specifically, We may use your data for the following purposes:
- Providing and managing your access to Our Site;
- Personalising and tailoring your experience on Our Site;
- Supplying Our services to you (please note that We require your personal data in order to enter into a contract with you);
- Personalising and tailoring Our services for you;
- Replying to emails from you;
- Supplying you with emails that you have opted into (you may unsubscribe or opt-out at any time by clicking the unsubscribe link on marketing emails we have sent you or sending an email to email@example.com with the subject line ‘Opt-out’;
- Market research; and
- Analysing your use of Our Site and gathering feedback to enable Us to continually improve Our Site and your user experience.
With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email, telephone, text message, post with information, news and offers on Our services.
Third parties (including social media platforms such as Instagram) whose content appears on Our Site may use third party Cookies, as detailed below in section 13. Please refer to section 13 for more information on controlling Cookies. Please note that We do not control the activities of such third parties, nor the data they collect and use and advise you to check the privacy policies of any such third parties.
Third parties whose content appears on Our Site may use tracking pixels to assist us in our marketing efforts. The data that these pixels collect is not available to Us except in aggregate form for use in creating targeted advertising audiences.
- You can prevent these pixels being set on this page and additionally at: https://www.facebook.com/ads/preferences/?entry_product=ad_settings_screen for Facebook and https://www.linkedin.com/psettings/advertising for LinkedIn.
Third parties whose content appears on Our Site may use tracking pixels to assist us in our analytics effort. We use the information gathered to improve the functioning of the site.
You have the right to withdraw your consent to Us using your personal data at any time, and to request that We delete it.
We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Data will therefore be retained for the following periods (or its retention will be determined on the following bases):
- Name – until permission is revoked or 6 years, whichever is the sooner;
- Gender – until permission is revoked or 6 years, whichever is the sooner;
- Business/company name – until permission is revoked or 6 years, whichever is the sooner;
- Job title – until permission is revoked or 6 years, whichever is the sooner;
- Profession – until permission is revoked or 6 years, whichever is the sooner;
- Contact information such as email addresses and telephone number – until permission is revoked or 6 years, whichever is the sooner;
- Demographic information such as post code, preferences, and interests – until permission is revoked or 6 years, whichever is the sooner;
- IP address – 50 months;
- Web browser type and version – 50 months;
- Operating system – 50 months;
- Mouse movements, behaviour and activity on Our Site – 50 months;
- A list of URLs starting with a referring site, behaviour and activity on Our Site, and the site you exit to.
7. How and Where Do We Store Your Data?
We only keep your personal data for as long as We need to in order to use it as described above in section 6, and/or for as long as We have your permission to keep it.
Some or all of your data may be stored outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). You are deemed to accept and agree to this by using Our Site and submitting information to Us. If We do store data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the GDPR including:
- Secure data transport over an encrypted connection between your browser, our servers and any third party servers so that it cannot be read in transit.
- Ensuring that data is only stored in countries with Privacy Shield or equivalent levels of data protection to data stored within the EEA.
Data security is very important to Us, and to protect your data We have taken suitable measures to safeguard and secure data collected through Our Site.
Steps We take to secure and protect your data include:
- Strict access control to data, reviewed regularly and monitored by the Data Protection Officer; and
- Secure data transport over an encrypted connection between your browser, our servers and any third party servers so that it cannot be read in transit.
8. Do We Share Your Data?
We may sometimes contract with third parties to supply services to you on Our behalf. These may include search engine facilities, advertising, and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law.
We may compile statistics about the use of Our Site including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymised and will not include any personally identifying data, or any anonymised data that can be combined with other data and used to identify you. We may from time to time share such data with third parties such as prospective investors, affiliates, partners, and advertisers. Data will only be shared and used within the bounds of the law.
We may sometimes use third party data processors that are located outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). Where We transfer any personal data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the GDPR including:
- Mailchimp – operating within the Privacy Shield Framework https://www.privacyshield.gov/
- Google Analytics – operating within the Privacy Shield Framework https://www.privacyshield.gov/
In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal requirements, a court order, or a governmental authority.
9. What Happens If Our Business Changes Hands?
In the event that any of your data is to be transferred in such a manner, you will not be contacted in advance and informed of the changes.
10. How Can You Control Your Data?
In addition to your rights under the GDPR, set out in section 4, when you submit personal data via Our Site, you may be given options to restrict Our use of your data. In particular, We aim to give you strong controls on Our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails and at the point of providing your details and by sending an email to firstname.lastname@example.org with the subject line ‘Opt-out’.
You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
11. Your Right to Withhold Information
You may access Our Site without providing any data at all.
12. How Can You Access Your Data?
You have the right to ask for a copy of any of your personal data held by Us (where such data is held). Under the GDPR, no fee is payable and We will provide any and all information in response to your request free of charge. Please contact Us for more details at email@example.com or using the contact details given above.
By using Our Site you may also receive certain third party Cookies on your computer or device. Third party Cookies are those placed by websites, services, and/or parties other than Us. Third party Cookies are used on Our Site for advertising services and analytical purposes. These Cookies are not integral to the functioning of Our Site and your use and experience of Our Site will not be impaired by refusing consent to them.
All Cookies used by and on Our Site are used in accordance with current Cookie Law.
Before Cookies are placed on your computer or device, you will be shown a visual bar towards the bottom of the page requesting your consent to set those Cookies. Continuing to use the site will be taken as consent for the placement of cookies, allowing Us to deliver the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Site may not function fully or as intended. You will be given the opportunity to allow only strictly necessary, analytical or marketing cookies by function. You can revoke consent at any time by visiting the cookies page of the website and using the controls provided to do so.
Certain features of Our Site depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings, but please be aware that Our Site may not work properly if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.
The following first party Cookies may be placed on your computer or device:
Name of Cookie Purpose
_status Monitors your consent and prevents any further cookies being set if consent is refused
Our Site uses analytics services provided by Google Analytics. Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling Us to better understand how Our Site is used. This, in turn, enables Us to improve Our Site and the services offered through it. You do not have to allow Us to use these Cookies, however whilst Our use of them does not pose any risk to your privacy or your safe use of Our Site, it does enable Us to continually improve Our Site, making it a better and more useful experience for you.
The analytics service(s) used by Our Site use(s) Cookies to gather the required information.
The analytics service(s) used by Our Site use(s) the following Cookies:
Name of Cookie Provider
_ga Google Analytics
_gat Google Analytics
_gid Google Analytics
Purpose: These cookies are used to collect information about how visitors use our site. We use the information to compile reports and to help us improve the site. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited.
In addition to the controls that We provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third party Cookies. By default, most internet browsers accept Cookies but this can be changed.
You can choose to delete Cookies on your computer or device at any time, however, you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.
You can remove or manage cookies set by this website, here:
- Chrome – open in Chrome;
- Firefox – open in Firefox;
- Microsoft Edge – Click on the three-dot Settings icon in the top right-hand corner that will generate a drop-down panel. Once you click “Settings” on the panel, it will shift to a different tile providing a section called “Clear browsing data.” To manage cookies, skip that for now and keep scrolling down. When you scroll to the bottom of the current panel, you should see “Advanced Settings.” Click on the associated “View advanced settings” button to access a refreshed list of settings. At the bottom, you’ll find the “Cookies” section with a drop-down menu. Your options are to block all cookies, block only third-party cookies, or don’t block them at all (default).
It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.
14. Contacting Us