The Vanguard, York, YO31 7NH

Privacy Policy

The Vanguard values you as our guest and recognises that privacy is important to you. We want you to be familiar with how we collect, use, and disclose your Personal and Other Data (collectively, “Data”).

DATA COVERED BY THIS PRIVACY STATEMENT

THE DATA WE COLLECT

COOKIES AND OTHER DATA

HOW AND WHERE WE COLLECT YOUR DATA

This Privacy Statement describes the privacy practices of The Vanguard for data that we collect:

  • through websites operated by us from which you are accessing this Privacy Statement, including the-vanguard.co.uk and other websites owned or controlled by the The Vanguard (collectively, the Websites);
  • through the software applications made available by us for use on or through computers and mobile devices (the Apps); through our social media pages that we control from which you are accessing this Privacy Statement (collectively, our Social Media Pages);
  • through email messages that we send you that link to this Privacy Statement and through your communications with us online or in person;
  • from third parties such as Authorised Licensees, Owners and Franchisees, and Other Sources, such as public databases, marketing partners and other third parties; and
  • when you visit or stay as a guest at one of our properties, or at homes and villas offered on the Homes and Villas by The Vanguard platform (Homes and Villas), or through other offline interactions (collectively, Property Visits and Offline Interactions).
  • ollectively, we refer to the Websites, the Apps, and our Social Media Pages, as the “Online Services” and, together with the Property Visits and Offline Interactions, the “Services.”
  • At touchpoints throughout your guest journey, we collect Personal Data in accordance with the law, and to serve you better. Personal Data is information that may identify you as an individual or relate to you as an identifiable individual. We collect and process the following types of Personal Data about you:
    • Name
    • Gender
    • Postal address
    • Telephone number
    • Email address
    • Financial information (such as credit and debit card number or other payment data)
    • Language preference
    • Date and place of birth
    • Nationality, passport, visa, or other government-issued identification data
    • Important dates: birthdays, anniversaries, and special occasions
    • Membership or loyalty program data (including co-branded payment cards, travel partner program affiliations)
    • Employer details (for business-related bookings)
    • Travel itinerary, tour group, or activity data
    • Prior guest stays or interactions, goods and services purchased, special service and amenity requests
    • Social media account ID, profile photo and other data publicly available, or data made available by linking your social media and loyalty accounts
  • In more limited circumstances, we may also collect:
    • Data about family members and companions, names, and ages of children
    • Biometric data
    • Images, video and audio data via: (a) security cameras located in public areas, such as hallways and lobbies, in our properties; and (b) body-worn cameras carried by our loss prevention officers and other security personnel
  • We may also collect information about your Preferences that we use to make your current and future stays and experience with us more enjoyable, including information about your interests and other relevant information that we learn about you during your stay. This may also include any likes and dislikes about our services that you tell us about so that we can improve our services, and specific dietary, health restrictions or personal needs to ensure your wellbeing. We may also collect your “Personal Preferences,” that may include details of your special anniversaries (such as your birthday or wedding anniversary), what type of activities you prefer to take part in when staying with us, and your hobbies. Personal Preferences may also include details about who you usually travel with, their relationship to you, and your marital status.
    If you submit any Personal Data about other people to us or our Service Providers (e.g., if you make a reservation for another individual), you represent that you have the authority to do so and you permit us to use the data in accordance with this Privacy Statement.

We may also collect “Other Data” that generally do not reveal your specific identity or do not directly relate to an identified individual. To the extent Other Data reveal your specific identity or relate to an individual, we will treat Other Data as Personal Data. Other Data include:

  • Your browser or device. We collect certain data through your browser or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Apple), screen resolution, operating system name and version, device manufacturer and model, language, internet browser type and version and the name and version of the Online Services (such as the Apps) you are using. We use this data to ensure that the Online Services function properly.
  • Cookies. We collect certain data from cookies, which are pieces of data stored directly on the computer or mobile device that you are using. Cookies allow us to collect browser type, time spent on the Online Services, pages visited, referring URL, language preferences, and other aggregated traffic data. We use functional cookies to obtain the data for security purposes, to facilitate navigation, to display content more effectively, to collect statistical data, to personalise your experience while using the Online Services, and to recognise your computer to assist your use of the Online Services. We also gather statistical cookie data about use of the Online Services to continually improve design and functionality, understand how they are used and assist us with resolving questions. Advertising cookies further allow us to select which advertisements or offers are most likely to appeal to you and display them while you are using the Online Services. We also use them to send marketing emails and to track responses to online advertisements and marketing emails. You can learn more about cookies at: http://www.allaboutcookies.org/manage-cookies/index.html
  • Pixel Tags and other similar technologies. We collect data from pixel tags (also known as web beacons and clear GIFs), which are used with some Online Services to, among other things, track the actions of users of the Online Services (including email recipients), measure the success of our marketing campaigns, and compile statistics about usage of the Online Services.
  • Analytics. We collect data through Google Analytics and Adobe Analytics, which use cookies and technologies to collect and analyse data about use of the Services. These services collect data regarding the use of other websites, apps, and online resources. You can learn about Google’s practices by going to www.google.com/policies/privacy/‌partners/ and opt out by downloading the Google Analytics opt out browser add-on, available at https://tools.google.com/dlpage/gaoptout. You can learn more about Adobe and opt out by visiting http://www.adobe.com/privacy/opt-out.html.
  • Your IP Address. We collect your IP address, a number that is automatically assigned to the device that you are using by your Internet Service Provider (ISP). An IP address is identified and logged automatically in our server log files when a user accesses the Online Services, along with the time of the visit and the pages that were visited. We use IP addresses to calculate usage levels, diagnose server problems and administer the Online Services. We also may derive your approximate location from your IP address.
  • Aggregated and Segmented Data. We may aggregate data that we collect, and this aggregated data will not personally identify you or any other user. We may also use both Personal Data and Other Data to divide customers into segments, or groups, in order to provide more relevant advertising.

This Privacy Statement describes the privacy practices of The Vanguard for Personal and Other Data that we collect through the following:

  • The Vanguard. We collect Personal Data and Other Data from other companies within The Vanguard for the purposes described in this Privacy Statement, such as providing and personalising the Services, communicating with you, facilitating the loyalty programs and to accomplish our business purposes.
  • Owners, Franchisees & Joint Ventures. We collect Personal Data and Other Data from Owners of The Vanguard branded properties that we manage, from Franchisees of The Vanguard branded properties that are independently owned and operated under a franchise agreement with us, and from Joint Venture Partners. Owners and Franchisees are independent from The Vanguard. Franchisees include their third party operators and management companies.
  • Homes and Villas Property Management Companies. We collect Personal Data and Other Data from companies and their service providers who manage Homes and Villas properties, your booking of Homes and Villas, and provide additional support to you during your stay at Homes and Villas (“Homes and Villas Property Management Companies”). Homes and Villas Property Management Companies are independent from The Vanguard.
  • Other Sources & Service Providers. We collect Personal Data and Other Data from various third parties, such as public databases, joint marketing partners and online travel agencies (OTAs).
  • Online Services. We collect Personal or Other Data when you interact with our Online Services, by performing such actions as, but not limited to, browsing, making a reservation, purchasing goods and services from our Websites or Apps, communicating with us or otherwise connecting with us or posting to social media pages, or signing up for a newsletter or participating in a survey, contest or promotional offer.
  • Internet-Connected Devices. We collect Personal and Other Data from internet-connected devices available in our properties. For example, when you connect a device to the hotel’s internet, or when a smart home assistant may be available for your use to tailor your accommodations and experience.

WHY WE COLLECT YOUR DATA (LEGAL BASIS)

PURPOSE DESCRIPTION OF ACTIVITIES ASSOCIATED WITH PURPOSE LEGAL BASES
Booking & Guest Registration There are a number of activities associated with this purpose, such as: facilitating reservations and bookings of hotel accommodations and related services; engaging in pre‑arrival communications (logistics, changes, preferences, etc.); and processing payments and security deposits. Performance of contract for the individual with the guest booking the room

Legitimate interests for the individual booking the room, for example, honoring his/her preferences, as well as for any individuals accompanying the primary guest (e.g., spouse, children, friends)

Legal obligations relating to financial transactions, such as the obligation to maintain books and records

Virtual Reception & Stay Services There are a number of activities associated with this purpose, such as: remotely facilitating check-in and check-out; processing payments; providing consistent and personalised service and advice about the on-site services (based on past usage or expressed preferences); providing remote-concierge, luggage storage and parking services; making arrangements with third‑party providers on behalf of guests (such as coordinating tours and other sightseeing excursions; arranging taxi, shuttle and chauffeur services; and facilitating reservations and bookings at restaurants and events); administering and facilitating access to Wi-Fi, TV and other connectivity services and entertainment systems (such as Netflix); housekeeping services (including preferences for special pillows, duvets and other amenities expressed by the guest) and dry-cleaning services; handling customer requests, inquiries and complaints. Performance of contract, such as processing payments

Legitimate interests, such as honoring the guest’s preferences (e.g., for a room on the ground floor)

Consent, such as collecting information regarding parking preferences that the guest chooses to provide

Legal obligations, such as collecting national ID numbers where legally required & for security due to our 24 contact-free self check-in process

The Vanguard Operations & General Business There are a number of activities associated with this purpose, such as: administering customer-care services to facilitate and address inquiries, comments and complaints about any of our services (such as over the phone, via whatsapp/SMS, email, or on social media); handling security and fraud prevention; administering online services (including troubleshooting, data analysis, testing, system maintenance, support, reporting and the hosting of data); monitoring and analysing usage of services and using data analytics to improve services, marketing, programs, overall customer experience, gathering feedback, carrying out pilot programs for potential new services and both developing new and improving existing services; and facilitating mergers, acquisitions and other reorganisations and restructurings of our business (including prospective transactions). Performance of contract, such as ensuring that online services are functioning so that individuals can make reservations or manage loyalty accounts

Legitimate interests, such as responding to customer complaints and concerns which may include, where applicable law permits, recording customer service calls

Consent, such as for marketing programs

Legal obligations relating to financial transactions, such as the obligation to maintain books and records

Emergency & Incident Response There are a number of activities associated with this purpose, such as: ensuring the security of on-site services; responding to, handling and documenting on-site accidents and medical and other emergencies (including facilitating in‑house doctor services); actively monitoring properties to ensure adequate incident prevention, response and documentation (including CCTV); requesting assistance from emergency services; and sending notifications and alerts in the event of incidents or emergencies (such as via SMS, email, call, audio-visual device prompts, etc.). Performance of contract, such as ensuring the safety of guests and personnel through interactions with on-site security personnel

Legitimate interests, such as monitoring properties through CCTV to ensure the safety of guests and personnel

Legal obligations, such as documenting on‑site accidents

Individuals’ vital interests, such as contacting medical or emergency services for an ill guest

Legal & Compliance There are a number of activities associated with this purpose, such as: complying with applicable laws; complying with legal processes; responding to requests from public and government authorities; meeting national security or law enforcement requirements; enforcing our terms and conditions; protecting our operations; protecting the rights, privacy, safety, or property of The Vanguard, guests, visitors and other relevant individuals; and allowing us to pursue available legal remedies and limiting the damages The Vanguard may sustain. Legal obligations, such as complying with legal processes

Legitimate interests, such as enforcing terms and conditions to protect trademarks

Individuals’ vital interests, such as contacting emergency services in case of disturbances and incidents involving guests

Food & Beverage Services There are a number of activities associated with this purpose, such as: facilitating reservations; honoring dietary preferences; providing consistent and personalised service based on past usage and preferences expressed by the individual; processing payments; arranging reservations; and handling customer requests, inquiries, and complaints. Performance of contract, such as processing payments

Consent, such as collecting information about dietary, health  restrictions, or personal needs of a guest when ordering food

Legitimate interests, such as providing personalised services (e.g., offering red wine to a guest based on previous requests)

Legal obligations relating to financial transactions, such as the obligation to maintain books and records

Individuals’ vital interests (e.g., when an individual becomes ill in one of the restaurants)

Child-Related Services (for Parents & Legal Guardians) There are a number of activities associated with this purpose, such as: facilitating babysitting/hotel nanny, and kids club; facilitating reservations and bookings; preparing for and coordinating hotel accommodations and services in accordance with guest preferences, instructions and expectations; payment and billing services; dining services (for example, special menus for children or special discounts for breakfast for children under a certain age). Performance of contract, such as having a child of a certain age stay in the room with his/her parents may amount to extra charges or discounts

Consent of parent or legal guardian, such as accommodating needs of children

Legitimate interests, such as providing a crib or child-sized bathrobes and other amenities for children

Legal obligations relating to financial transactions, such as the obligation to maintain books and records

Loyalty Programs, Accounts, & Relationship Management There are a number of activities associated with this purpose, such as: registering users in loyalty and other client account programs and payment card programs; determining eligibility for various programs and related services; administering loyalty programs; providing consistent and personalised service based on past usage and the preferences expressed by members; ensuring access to Online Services; processing payments; notifying members about changes to programs, terms and conditions; and handling members’ requests, inquiries and complaints. Performance of contract, such as assessing points and distributing benefits

Consent, such as honoring the mode of communication preferences (e.g., email, SMS)

Legitimate interests, such as managing members’ choices regarding how they wish to earn, track, and use points

Legal obligations relating to financial transactions such as the obligation to maintain books and records

Marketing, Promotions, Contests & Third Party Products There are a number of activities associated with this purpose, such as: communicating about products and services that may be of interest to guests; providing personalised advertisements for products and services on selected websites; facilitating participation in sweepstakes, contests and other promotions (such as best vacation photo contests on social media); and handling customer requests, inquiries and complaints. Performance of a contract, such as fulfilling obligations associated with a contest

Consent, such as honoring the mode of communication preferences (e.g., email, SMS)

Legitimate interests, such as providing advertisements for similar products and services

Legal obligations, such as handling information consistent with rules relating to sweepstakes

HOW AND WHEN WE SHARE YOUR DATA

Our goal is to provide you with the highest level of hospitality and Services, and to do so, we may share Personal Data and Other Data with the following:

  • The Vanguard. We disclose Personal Data and Other Data to other companies within the The VanguardOpen in a new browser tab for the purposes described in this Privacy Statement, such as providing and personalising the Services, communicating with you, facilitating the loyalty programs and to accomplish our business purposes. We share your Personal Data and Other Data used for making reservations with the applicable property and The Vanguard entity to fulfil and complete your reservation.
  • Franchisees. We disclose Personal Data and Other Data to Franchisees of The Vanguard branded properties for the purposes described in this Global Privacy Statement. Franchisees have a limited right to use certain Personal Data for their own purposes and therefore qualify as independent data controllers for the following processing: Franchisees manage and coordinate your stay at hotels that they operate so they may use your Personal Data for that purpose. Franchisees may also use your Personal Data for compliance with their own legal obligations, including maintaining books & records and other compliance obligations.
  • Owners: We disclose Personal Data and Other Data to Owners of The Vanguard branded properties for the purposes described in this Global Privacy Statement. Owners have a limited right to use certain Personal Data for their own purposes and therefore qualify as independent data controllers for the following processing: Owners may use your Personal Data for complying with their own legal obligations, including maintaining books & records and other compliance obligations.
  • Homes and Villas Property Management Companies. We disclose Personal Data and Other Data to Homes and Villas Property Management Companies and their service providers for the purpose described in this Privacy Statement, such as providing, facilitating, and personalising the Services, facilitating the loyalty programs and their own marketing.
  • Linked Accounts. We partner with certain third parties that allow you to enroll in their services. For example, certain companies allow you to use your loyalty program number or Online Services login to receive or register for their services. These companies include businesses such as airlines and rental car providers, and restaurant reservation and car services partners. Additionally, your social media account provider allows you to connect your social media account to your Online Services account or log into your Online Services account from your social media account. When you enroll in those services, we disclose your Personal Data and Other Data to those third parties. If you do not want us to share your Personal Data or Other Data in this way, do not provide your loyalty program number to third parties, do not use your Online Services login to register for third-party promotions and do not connect your Online Services account with accounts on third-party services. Data shared in this way will be governed by the third party’s privacy policy and not this Privacy Statement.
  • Service Providers. We disclose Personal Data and Other Data to third party service providers including, for example, companies that provide website hosting, data analysis, payment processing, order fulfilment, information technology and related infrastructure provision, customer service, email delivery, marketing, auditing, and other services.

Other Uses and Disclosures:

We will use and disclose Personal Data as we believe to be necessary or appropriate: (a) to comply with applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including authorities outside your country of residence and to meet national security or law enforcement requirements; (d) to enforce our terms and conditions; (e) to protect our operations, such as in the event of any reorganisation, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of The Vanguard business, assets or stock (including any bankruptcy or similar proceedings); (f) to protect the rights, privacy, safety or property of The Vanguard, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

We may use and disclose Other Data for any purpose, except where we are not allowed to under applicable law.

YOUR DATA, YOUR CHOICES: YOUR PRIVACY PREFERENCES & RIGHTS

At The Vanguard, we believe that you should have choices with respect to your data. We provide you with the options, information, and choices below to express your preferences: what and how much you share with us and when and how you hear from us.

Communications and Preferences

  • You can use the unsubscribe link at the bottom of any of our communications.
  • If you no longer wish to receive marketing-related emails, you may opt out by following the unsubscribe instructions in any such email you receive from us.
  • In addition, you can opt out from marketing-related emails by sending a letter to: Customer Service team, The Vanguard, 83 Eldon Street, York, YO31 7NH or by email.
  • NOTE: Even if you choose to opt out of marketing-related emails, we will continue to send you transactional messages, such as information about your reservations or stays, including confirmation and pre-arrival emails, or account security updates.

OTHER IMPORTANT PROVISIONS

Security

We seek to use reasonable organisational, technical, and administrative measures to protect Personal Data. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account has been compromised), please immediately notify us in accordance with the “Contact Us” page or section below.

Retention

We will retain your Personal Data for the period necessary to fulfill the purposes outlined in this Privacy Statement unless a longer retention period is required or permitted by law.

The criteria used to determine our retention periods include:

  • The length of time we have an ongoing relationship with you and provide the Services to you (for example, for as long as you have an account with us or keep using the Services)
  • Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them)
  • Whether retention is advisable considering our legal position (such as, for statutes of limitations, litigation, or regulatory investigations)

Sensitive Data

Unless specifically requested, we ask that you not send us, and you not disclose, on or through the Services or otherwise to us, any Sensitive Personal Data (e.g., social security number, taxpayer identification number, passport number, driver’s license number, or other government-issued identification number; credit or debit card details or financial account number, with or without any code or password that would permit access to the account, credit history; or information on race, religion, ethnicity, sex life or practices or sexual orientation, medical or health information, genetic or biometric information, biometric templates, political or philosophical beliefs, political party or trade union membership, background check information, judicial data such as criminal records, or information on other judicial or administrative proceedings).

Use of Services by Minors

The Services are not directed to individuals under the age of eighteen (18), and we request that they not provide Personal Data through the Services.

International Data Transfers

The Vanguard is a digital hotel and relies on global technology platforms for our core infrastructure. Transferring data internationally is essential to the Services so that you receive the same high-quality service wherever you are in the world. As a result, we will, subject to law, transfer Personal Data and Other Data collected in connection with the Services, to entities in countries where data protection standards may differ from those in the country where you reside, including outside the EEA, UK, or Switzerland. By making a reservation, visiting, or staying at a Vanguard branded property or using any The Vanguard branded service, you understand that we may transfer your Personal Data globally (e.g. due to the reliance of global data centres that host our technical platforms and services).

In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Data.

Some of the countries are recognised by the European Commission as providing an adequate level of data protection according to EEA standards (the full list of these countries is available hereOpen in a new browser tab).

CONTACT US

If you have any questions about this Privacy Statement, please contact us.

The data conroller for The Vanguard can be found at:

Data Controller
Vanguard Hotels Limited
83 Eldon Street
York
YO31 7NH
United Kingdom