Introduction

 
Liberty Elite Private Members Club is committed to data security and the fair and transparent processing of personal data. This privacy policy sets out how we treat your personal data.
 
Please read this policy carefully as it contains important information on who we are, how and why we collect, store and use your personal data, your rights in relation to your personal data, how to contact us, and how to contact supervisory authorities in the event that you would like to report a concern about the way in which we process your personal data.
 

Who are we?

 
For the purposes of the General Data Protection Regulation (Regulation (EU) 2016/679) (GDPR), Libertys Elite Hotel Ltd operating as Liberty Elite Private Members Club is the ‘controller’ of your personal data. Our address is Liberty’s Hotel, Watling Street (A5), Lutterworth, Leicestershire LE17 4HU.
 
If you have any queries about this Policy, the way in which we process personal data, or about exercising any of your rights, you may contact our Privacy Representative by writing to the Privacy Officer, Liberty’s Hotel, Watling Street (A5), Lutterworth, Leicestershire LE17 4HU.
 

What personal data do we collect?

 
We collect information from you when you complete our club registration form, that information includes your name, gender, date of birth, address, telephone number(s) and email address. We may also ask you to provide other personal data if required to administer our quality assurance processes, investigations and complaints procedures. We assign a unique membership/guest number at the point of application which we also use in relation to your membership administration.
 

IP Addresses and Cookies

 
Cookies are text files stored on the hard drive of your computer. When accessing our web site these files allow us to collect information about your computer, including where available your IP address, operating system, and browser type; all of which we use for system administration and to report and use aggregate information. This statistical data about our users browsing actions and patterns does not identify any individual, but does allow us to collect, analyse and improve the performance of our services. You may refuse to accept cookies by activating the appropriate setting on your browser, however in doing so you may be unable to access certain parts of our web site and may reduce the overall quality and experience.
 

How do we use your personal data?

 
We may use your personal data where this is necessary to pursue our legitimate interests as a private members club, including to:
 
> provide you with information relating to the operation of Liberty Elite;
> undertake administration in relation to your membership;
> contact you directly in relation to our quality assurance processes, investigations and complaints;
> contact you directly in relation to new and existing services and events offered by Liberty Elite;
> assess and provide reasonable adjustments in relation to your membership where requested.
 
We may also process your personal data if required by law, including to respond to requests by government or law enforcement authorities, or for the prevention of crime or fraud.
 

Transfer of personal data outside the UK

 
You should be aware that communicating with us from outside the UK may result in an element of transferring of your personal data across intentional boarders, which may not have the same safeguards as current EU legislation.
 

Who do we share your personal data with?

 
We do not share your data with any outside third party for them to use for their own marketing purposes, but may need to share your data with other companies within our corporate family. We may need to share your data with third parties when, processing payments, providing support services including analytics and search engine providers that assist us in the improvement and optimisation of our web site. Generally this data is not linked to personal data but is aggregated or statistical data but to the extent that it is considered personal data we treat it accordingly. We will only disclose personal data with law enforcement or other authorities if required to applicable law.
 

How long will we keep your personal data?

 
We will retain personal data only for as long as necessary to provide the services you have requested and thereafter for a variety of legitimate legal or business purposes, These might include retention periods mandated by law, contract or similar obligations applicable to our business operations, for preserving, resolving, defending or enforcing our legal/contractual rights or needed to maintain adequate and accurate business records.
 

Where do we store your personal data and how is it protected?

 
We take reasonable steps to protect your personal data from loss or destruction. We hold personal data on a secure encrypted server in the UK. 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

 
Under the GDPR, you have various rights with respect to our use of your personal data:
 
Right to access
 
You have the right to request a copy of the personal data that we hold about you and because of the nature of the activities of the club, we reasonable feel that to protect our members any contact should be in writing via the postal address given under the WHO WE ARE section, and with a verifiable signature; that is a signature that we reasonably consider to be the same as or very similar to that on the original membership/guest form and a current telephone number or email address that we may contact you. Please include with your request information that will enable us to verify your identity. We will respond within 1 month of your request. Please note that there are exceptions to this right. We may be unable to make all information available to you if, for example, making the information available to you would reveal personal data about another person, if we are legally prevented from disclosing such information, or if there is no basis for your request, or if it is excessive, or if we consider it to be of a legally vexatious nature.
 
Right to rectification
 
We aim to keep your personal data accurate and complete. We encourage you to contact us using the contact details provided below to let us know if any of your personal data is not accurate or changes, so that we can keep your personal data up-to-date.
 
Right to erasure
 
You have the right to request the deletion of your personal data where, for example, the personal data is no longer necessary for the purposes for which it was collected, where you withdraw your consent to processing, where there is no overriding legitimate interest for us to continue to process your personal data, or your personal data has been unlawfully processed. If you would like to request that your personal data is erased, please contact us using the contact details provided below, using the procedures as set out in the RIGHT OF ACCESS section above.
 
Right to object
 
In certain circumstances, you have the right to object to the processing of your personal data where, for example, your personal data is being processed on the basis of legitimate interests and there is no overriding legitimate interest for us to continue to process your personal data, or if your data is being processed for direct marketing purposes. If you would like to object to the processing of your personal data, please contact us using the contact details provided below, using the procedures set out in the RIGHT OF ACCESS section above.
 
Right to restrict processing
 
In certain circumstances, you have the right to request that we restrict the further processing of your personal data. This right arises where, for example, you have queried the accuracy of the personal data we hold about you and we are verifying the information, you have objected to processing based on legitimate interests and we are considering whether there are any overriding legitimate interests, or the processing is unlawful and you elect that processing is restricted rather than deleted. Please contact us using the contact details provided below, using the contact procedures set out in the RIGHT OF ACCESS section above.
 

Contact

 
If you have any queries about this Policy, the way in which Liberty Elite processes personal data, or about exercising any of your rights, you can contact our Privacy Officer, Liberty’s Hotel,, Watling Street (A5), Lutterworth, Leicestershire LE17 4HU.
 

Complaints

 
If you believe that your data protection rights may have been breached, and we have been unable to resolve your concern, you may lodge a complaint with the applicable supervisory authority or to seek a remedy through the courts. Please visit https://ico.org.uk/concerns/ for more information on how to report a concern to the UK Information Commissioner’s Office.
 

Changes to our Policy

 
Any changes we may make to our Policy in the future will be posted on this page. Please check back frequently to see any updates or changes to our Policy.