Privacy Policy
Pillo Hotel & Leisure Club / Ink-tech Vision
PRIVACY STATEMENT
Pillo Hotel & Leisure Club is committed to protecting and respecting your privacy.
The privacy and confidentiality of personal information is important, and we are committed to
maintaining the privacy and security of your personal information. This policy sets out the basis on
which any personal data we collect from you or you provide to us, will be processed by us. Please read
the following carefully to understand our views and practices regarding your personal data and how
we will treat it. As Data Controllers under the Data Protection Act 1988 we fully endorse and adhere
to the principles of the Irish Data Protection legislation and will ensure that we:
• Obtain and process information fairly.
• Keep information only for one or more specified, explicit and lawful purpose.
• Use and disclose information only in ways compatible with these purposes.
• Keep information safe and secure.
• Keep information accurate, complete and up to date.
• Ensure that information is adequate, relevant and not excessive.
• Retain information for no longer than is necessary for the specified purpose or purposes.
• Give a copy of personal data to the individual from whom it was taken on written request.
Our Privacy Statement is a legal requirement underpinned by two distinct pieces of legislation:
▪ The Data Protection Acts 1988 & 2003 ("The Acts")
▪ Statutory Instrument Number 336 of 2011 European Communities (Electronic
Communications Networks and Services) (Privacy and Electronic
Communications) Regulations 2011 ("SI 336/2011")
▪ EU General Data Protection Regulation 2016 (“GDPR”)
We reserve the right to amend this Privacy Statement at any time and from time to time without
notice by publishing a new version on our website. Please refer to the top of this document to see
date of the latest version in force.
1. CONSENT
By using our website and voluntarily providing any personal data to us through booking or
browsing, you confirm that you agree to and consent to the terms of this Privacy Statement on
your behalf and on behalf of others you are representing including but not limited to
organisations and whose information you submit and including the collection and use of
information, to the extent that your consent is required by any applicable law. Continued access
and use of the Site without acceptance of the terms of this Privacy Statement relieves us from
responsibility to the user.
2. IDENTITY
This is the privacy policy of Pillo Hotel & Leisure Club. Our registered office is The Rath, Ashbourne, Co. Meath. If you have any questions about our privacy policy, about how we process your personal data or have any
complaints, please contact us at info@pillohotelashbourne.com.
3. PURPOSE
Information we collect on the website may be used for the following purposes:
• To operate and provide the search, booking, accounts, review, forums and other services,
facilities and functions of our websites. This includes managing any accounts or
registrations you may have with our websites and making changes to your settings and
profile at your request.
• To provide information to you about our website, systems and services, including to
respond to booking enquiries and searches, and to keep you updated generally.
• To enable you to make bookings, and to fulfil, provide, perform, administer, manage, and
enforce all bookings, orders, and other contracts which relate to you (including if you are
a guest in a booking made by someone else), and to process any transactions authorised
or made with us which relate to you.
• To collect and make payments due and administer our accounts.
• To communicate with you concerning any enquiries, bookings, services provided,
problems and complaints, and to respond to any submissions, enquiries or requests from
you.
• To keep internal records and maintain reasonable archives, including concerning as to
enquiries, bookings, contracts, services, and complaints.
• To analyse, audit, provide, operate, administer, maintain and improve our business,
website, systems, and services; to carry out surveys and analyse the results; to run
promotions and competitions; undertake product or customer research/development; to
assist us in and help us to improve our sales, editorial, advertising and marketing
processes; to carry out other business development and improvement activities; and to
provide training to our staff, sub-contractors and suppliers. For example, we may use your
personal data to help us profile how our customers generally are using our websites and
booking services with (or through) us. We may also use this information to ascertain
interests so that we can better tailor our business offerings.
• To carry out direct marketing to you that you have consented to. We do not use or disclose
your personal data for direct marketing purposes unless we have obtained your consent
to this through an opt-in tick box on any form or website of ours.
• To report aggregate information concerning usage of our websites. We normally create
anonymous statistical data about browsing actions and patterns, and do not identify any
individual.
• For any purpose which we have obtained your consent to.
4. DISCLOSURE
We may share your personal data with third parties in the following circumstances:
• We may disclose your personal data to third parties (including intermediaries) as
necessary to carry out any checks concerning you or enforce any booking or contract
with you (including credit, security, fraud and identity checks). This may include credit
reference agencies and other companies for use in credit decisions, for fraud prevention
and to pursue debtors.
• We disclose your personal data to third parties (including intermediaries) as necessary
to deal with any booking enquiry being made by or for you, to make any booking
requested by or for you, to perform and administer any booking for you or other
contract with or in respect of you. Such third parties may include any suppliers or subcontractors
and their agents
• We may disclose your personal data to any third party (e.g. supplier, contractor subcontractor)
we make any enquiries with concerning or engage or sub-contract to
perform any booking or other contract, including to provide any other products or services we have agreed to provide to you. We may disclose your personal data to any
supplier with whom we make any enquiry concerning or book any travel or other
products and services for you as agent (whether as agent for you, someone
representing you, or the supplier). Details of any third-party operators or other third
parties who will be responsible for or supply you with the services booked or enquired
about, may be obtained from us on request, and may be stated in any other brochure
provided by us.
• Where we use third parties to host, provide, operate or supply any part of our websites,
databases, systems, business, or services, or carry out on our behalf any of our business
functions or actions (including sending mail, processing payments, providing marketing
assistance, providing customer and advertising analysis, and providing customer
services), then then we may provide your personal data to them as required for use for
or processing as part of those purposes.
• Where any facility on our website is clearly designed to make certain of your personal
data public (e.g. posts you make to any public forum or reviews facility), then any
personal data you provide in relation to that forum or other facility, which is provided
in circumstance where it is clear that it is intended to be published, will be disclosed to
the public accordingly, subject to moderation by us.
• We may supply personal data to a government authority or regulator where required
to comply with a legal requirement, for the administration of justice, for the purposes
of customs, visas and immigration, or where reasonably required to protect your vital
interests or enforce any booking or other contract. We may disclose your personal data
where otherwise required by or permitted by law.
• If our customer is a business or organisation, and we are holding your personal data in
your capacity as an associate of that business or organisation (including as agent,
representative, contact, employee, officer, owner, partner, or director), then we may
disclose to them that personal data. If our customer is making a booking or booking
enquiry on your behalf, with your authority, then we may disclose to our customer your
personal data as reasonably required in connection with such booking or enquiry, or
the subsequent performance of or payment for any booking made.
• If our business is ever transferred to a third party, then your personal data will be
transferred to the acquirer to enable them to continue the business.
Where we provide your personal data to a third party one of the following two circumstances
will apply:
• In some cases, your personal data may be held and otherwise processed by them on
our behalf, in which case we will remain responsible for what they do with your
personal data, and your personal data will only be held and processed by them in
accordance with our instructions and this privacy policy.
• In other cases, your personal data may need to be provided to them to be held and
processed by them in their own right and on their own account. In such case, they will
have their own responsibility for that personal data, subject to their own privacy policy,
and we will not be responsible for what they do with it following disclosure.
We may provide links to a number of other web sites that we believe might offer you useful
information and services. However, those sites may not follow the same privacy policies as us.
Therefore, we are not responsible for the privacy policies or the actions of any third parties,
including without limitation, any web site owners whose sites may be reached through this
Site, nor can we control the activities of those web sites. We urge you to contact the relevant
parties controlling these sites or accessing their on-line policies for the relevant information about their data collection practices before submitting any personal information or other
sensitive data.
This Privacy Statement does not address, and we are not responsible for, the privacy,
information or other practices of any third parties. We have no control over, and are not
responsible for, this third party’s collection, use and disclosure of your Personal Information.
In addition, we are not responsible for the information collection, use, disclosure or security
policies or practices of other organisations, such as Facebook, Apple, Google, Microsoft or any
other app developer, app provider, social media platform provider, operating system provider,
wireless service provider or device manufacturer, including with respect to any Personal
Information you disclose to other organisations through or in connection with the Apps or our
Social Media pages.
5. RIGHT OF ACCESS
Our privacy policy is not a contract, nor does it form part of any contract. You have certain noncontractual
rights in accordance with legislation. Should you contact us regarding these rights,
we are entitled to request proof of your identity before we act, and may refuse to act if you do
not provide this.
You may request information on whether we are processing personal data about you, to tell
you what personal data we are processing and for what purposes, and to provide you with a
copy of your personal data that we hold. We must provide the data request for free unless the
request is manifestly unfounded, excessive or repetitive. In these cases, we charge a reasonable
fee not exceeding € 6.35 for handling your request. In certain cases, we may refuse your request
and will advise you at the time if this is the case.
All requests must be in writing and may be submitted by e-mail or by post to the contact details
listed below and you will receive a response within 30 days of receipt of your written request.
Where requests are complex or numerous, we will extend the deadline for providing the
information to 3 months. In such cases, we will advise you in writing within the 30-day time
period explaining why the extension is necessary.
If you would like to review, correct, update, suppress or delete Personal Information that you
have previously provided to us, you may contact us at marketing@pillohotelashbourne.com.
In your request, please make clear what Personal Information you would like to have changed,
whether you would like to have your Personal Information suppressed from our database, or
other limitations you would like to put on our use of your Personal Information.
6. RIGHT OF RECTIFICATION OR ERASURE
Our privacy policy is not a contract, nor does it form part of any contract. You have certain noncontractual
rights in accordance with legislation. Should you contact us regarding these rights,
we are entitled to request proof of your identity before we act, and may refuse to act if you do
not provide this.
All requests of rectification or erasure must be in writing and may be submitted by e-mail or by
post to the contact details listed below and you will receive a response within 30 days of receipt
of your written request.
You have the right to request us to cease using your personal data for any purpose, subject to
exceptions. You have the right to ask us to stop using your personal data to carry out direct
marketing to you.
You have the right to request us to rectify, block, erase or destroy any inaccurate personal data
we hold about you.
If you would like to review, correct, update, suppress or delete Personal Information that you
have previously provided to us, you may contact us at marketing@pillohotelashbourne.com
In your request, please make clear what Personal Information you would like to have changed,
whether you would like to have your Personal Information suppressed from our database, or
other limitations you would like to put on our use of your Personal Information.
7. EXTENT OF DATA BEING PROCESSED
We process the following types of personal data:
• Personal Data – concerning you as an individual which includes your name, age,
photograph, gender, address, telephone, mobile, fax, e-mail, social networking contact
details, proofs of identity and address, copies of passports, driving licences, and utility
bills, card and other payment details, and financial information, health information
relevant to your planned stay or services required, and travel insurances held, results
of searches carried out against you if required (such as to verify your identity, address,
and credit status), your preferences, and any other information provided to us by or in
relation to you which concern you as an individual.
• Business related data – if you are an individual associated with a business or other
organisation that is our customer, then your personal data may include the following
information that we link to you: business or organisation details (such as name, address,
telephone numbers, payment arrangements, financial information, etc.), your
relationship with that business or organisation (such as owner, partner, director,
shareholder, employee, or agent), and your contact details within that business (such
as work address, work telephone and mobile numbers, work fax number, and work email
address).
• Enquiry and Booking information – information concerning enquiries and bookings
made with or through us for your stay or services, including where you are making the
enquiry or booking or are the recipient of the travel services to which the enquiry or
booking relates. This information may include: records of enquiries and searches for
holiday and travel products made by or on your behalf, details of your personal
interests, needs and other data relevant to your enquiry; details of results, quotes,
proposals, estimates and other information given in response to enquiries; details of
the holiday, accommodation, travel, car hire, and other travel services booked or
enquired about; details of the passengers / holidaymakers travelling; details of the
provider of the travel services (e.g. tour operator); dates and times of travel; price;
payment details (including card details); passport information and visa information; foreign exchange requirements and arrangements; and sensitive information such as
health, medical, dietary, mobility, disability, religious or other special conditions or
requirements.
• Performance information – information generated concerning the performance of any
booking or other contract made with or through us, including information relating to
anything arising during any holiday or other services, and information relating to
payments to be made.
• Survey Information – information collected or generated out of any surveys we conduct.
• Competition Information – Information collected or generated out of any competitions
or promotions we run.
• Account, Registration and Loyalty Information – Information concerning any accounts,
registrations, or memberships with us, or participation in any loyalty program.
• Correspondence – Correspondence, communications and messages, including between
you and us, and between us and third parties, including relating to any booking or
booking enquiry, or performance of any contract.
• Website Usage Information – We may collect information about your visits to, browsing
of, and use of our website, unless your web browser blocks this. The range of data we
collect will depend on how you interact with our website. This information may include:
your IP address (a unique identifier allocated to your computer for your connection to
the internet); your computer device details (PC, tablet, smartphone, watch etc.); the
make and version of web browser (e.g. Internet Explorer, Firefox, Safari, Opera,
Chrome) you are using; your operating system (e.g. Windows, Windows Phone, OSX,
iOS, Android, Linux etc); your time-zone; your browser plug-ins; any web-page you
came from, identified as the referrer web page address by your web browser; cookies;
page response times; download error; pages and parts of pages you visit; usage you
make of our website, including enquiries and searches undertaken, and registrations
for accounts, forums etc.; services and products you viewed; length of visit to website
and pages; page interaction information (such as scrolling, keys pressed, mouse clicks,
touches, and mouse-overs). This will normally be collected and used anonymously, and
aggregated for analysis, with your name and any characteristics identifying you
remaining anonymous, but our privacy policy will apply, and it will be treated as your
personal data, if this information is in any way linked to you personally This information
may also include: data inputted into forms and field; registrations for any accounts,
forum, feedback mechanism, social functionality, newsletters or other features of our
site; usernames and passwords, log-in / out history, and settings; actions taken within
any account or other registration, including view and update and changes to settings;
and posts to any forum, feedback, review or other social functionality on our website.
We collect or generate personal data in the following way:
• Visiting our website – By visiting and using our website you or your computer may
provide personal data. This includes: information which is automatically provided by
your browser to our servers; information record on our web servers about your
interaction with our website and pages viewed; information we capture or place on
your computer or generate using cookies or other technologies on our website; and
information you input into forms and fields on our website.
• Data you provide – Your personal data will include data you provide (or later amend),
whether: from correspondence with you; verbally to us over the phone or in person; by
filing in any field or form on a website; by filling in any printed form we provide you
with; by e-mail; from documents you provide use with; and from updates to any
information to provide from time to time. This includes when you: register or subscribe for any service, account, members, or loyalty program, or make an enquiry or booking
for a holiday or other travel services whether in person, by phone, through our website
or otherwise; send us your comments or suggestions; subscribe to any newsletter or
other publication; and request sales and advertising information, including brochures.
• Data obtained from third parties – We may obtain personal data concerning you from
third parties, including from: providers of any holidays, accommodation, other travel
services which are enquired about or booked, and their intermediaries; credit, fraud,
identity and other searches we may undertake, including searches with public records
and regulatory and private organisations; from any business or organisation you are
associated with; from telephone numbers identified by the telephone system when you
telephone us.
• Data generated by us – We and any suppliers or sub-contractors working for us may
generate personal data relating to you, including in connection with responding to and
dealing with any enquiry, booking or complaint; or in performing any booking or other
contract with you; or through the analysis of your personal data or data gained from
your use of our website. We may record telephone calls with you.
8. COOKIES
Cookies are small text files stored on your device by a web browser (e.g. Internet Explorer) that
hold information about your previous visits to our site. On returning to our site this stored
information is fed back to us allowing us to offer you a more personal browsing experience. By
using our website you consent to cookies being used in accordance with our Cookie Policy.
Our comprehensive Cookie Policy is available here.
9. SECURITY
We (and any affiliate, subcontractor or other person processing your personal data on our
behalf) may transfer, store and otherwise process your personal data anywhere in the world.
Where we disclose your personal data to third parties, that disclosure may also involve a
transfer of your personal data anywhere in the world, and those third parties may themselves
transfer, store or otherwise process that information anywhere in the world. In each case, we
will comply with any legal requirements concerning the transfer of your personal data by us to
any third party outside the country where we are established, and where your personal data is
still controlled by us or is being stored or otherwise processed on our behalf, our security
measures will also apply.
We are committed to doing what we reasonably can to keep your personal data secure, and we
are obliged by law to put in place appropriate technical and organisational measures against
unauthorised or unlawful processing of your personal data and against accidental loss or
destruction of, or damage to, your personal data. We have accordingly implemented security
policies, rules and technical measures with a view to achieving this:
• We use Secured Socket Layer (“SSL”) software in order to encrypt the personal
information that you provide to us whilst it is in transit over the internet. This will work
if your browser is SSL enabled (which most are). You can verify that this is working by
looking for the symbol of a closed lock or solid key on the bottom bar of your browser
window, and checking that the prefix for the web address in the browser address bar
has changed from “http” to “https”.
• The personal information we collect from you online is stored by us and/or our service
providers on databases protected through a combination of physical and electronic
access controls, firewall technology and other reasonable security measures.
• For your own privacy protection, we encourage you to maintain anti-virus and other
malware protection software on your computers and other devices, and to maintain
your own measures to protect your personal data. Please do not include sensitive
personal data in any e-mails you may send to us, including payment card information.
We also encourage you to be careful about who you give personal data to. We never
contact you to ask you for sensitive personal data, such as payment card information,
or sensitive personal data such as passport numbers or log-in details, and we will only
ask you for such information in person or through our website, or by telephone in
connection with a booking you are making or have made. Please let us know if you
someone purports to contact you in our name.
10. USE OF SERVICES BY MINORS
Our website and all the services provided are not intended for individuals under the age of
eighteen (18) and we request that they not do not use our website and do not provide personal
information through our website. Our Privacy Statement prohibits us from accepting users who
are under the age of 18 and all persons under the age of 18 are directed not to use, post
information to or submit queries on this website. Should we inadvertently acquire personal
information or other data from users under the age of 18, we will not knowingly provide this
data to any third party for any purpose whatsoever, and any subsequent disclosure would be
due to the fact the user under age 18 used the website and submitted personal information
without solicitation by or permission from us.
11. ACCURATE, COMPLETE AND UP TO DATE
We are not responsible for ensuring that any personal information submitted by you on or
through our website and our online services are accurate and up-to-date. Should you wish to
verify whether or not the personal information you provided us with, that is held or may still be
held by us is up-to-date, you may contact us at info@pillohotelashbourne.com.
We will endeavour to respond to your request as soon as reasonably practicable.
12. ADEQUATE, RELEVANT AND NOT EXCESSIVE
Unless specifically requested, we ask that you not send us, and you not disclose, any sensitive
Personal Information on or through our website and our online services or otherwise to us.
Please note that we may need to retain certain information for recordkeeping purposes and/or
to complete any transactions that you began prior to requesting a change or deletion. There
may also be residual information that will remain within our databases and other records, which
will not be removed. In addition, there may be certain information to which we are unable to
enable you to review, for legal, security, or other reasons.
13. RETENTION
We keep your personal data for so long as is reasonably necessary for the purposes for which
we use it, and if longer, for any duration required by law, and for statutory claims limitation
periods where your personal data may be relevant to any possible liability we may have.
14. COMPLAINT RESOLUTION MECHANISM
The laws we comply with are regulated by Data Protection Commissioner. If you have a complaint or concern, please feel free to contact us to discuss the matter and we will strive to assist you and resolve your issue. Should you wish to seek assistance from a government regulator, the Data Protection Commissioner contact details are here below. Data Protection Commissioner Canal House Station Road Portarlington Co. Laois Ireland R32 AP23