Privacy Policy

Privacy & Cookie Policy

Privacy Policy

Last updated December 2023.

This privacy notice (“Privacy Notice”) applies to the Millennium & Copthorne Hotels Limited group (the “MHR Group”, “we”, “us” or “our”). For more information about the MHR Group see https://www.millenniumhotels.com/en/about-us/our-heritage/

The MHR Group respects the privacy of every person who visits or registers with https://www.millenniumhotels.com (the “Site”) and who uses the services and products that we make available through our Site and our hotels (our “Services”). This Privacy Notice also applies to other MHR websites such as msocial.com and the websites of other MHR brands and properties. We are committed to protecting your privacy and to ensuring a safe online experience.

1 Purpose of this Notice

This privacy notice (“Privacy Notice”) explains how we process any of your personal data that we might collect from you or which we have obtained from a third party, and the purposes for which we process your personal data. This Privacy Notice also sets out your rights in respect of our processing of your personal data.

This Privacy Notice will inform you of the nature of your personal data that is processed by us and how you can request that we delete, update, transfer and/or provide you with access to it.

This Privacy Notice is intended to assist you in making informed decisions when using the Site and our Services. Please take a moment to read and understand it. Please note that it should be read in conjunction with our Terms of Website Use.

Please also note that this Privacy Notice only applies to the use of your personal data provided, or obtained by us directly. It does not apply to personal data collected during your communications with third parties.

2 Who are we and what do we do?

The MHR Group includes Millennium & Copthorne Hotels Limited (“M&C Limited”), M & C Reservations Services Limited (“MCRSL”), Millennium & Copthorne International Limited (“MCIL”) and various hotels and brands, together with their operating and/or management companies (the “Hotels”).

Millennium & Copthorne Hotels Limited

M&C Limited is the ultimate parent company of MCRSL, MCIL and the Hotels. M&C Limited is a company registered in England with company registration number 03004377 with its registered address at Corporate Headquarters, Scarsdale Place, Kensington, London, United Kingdom, W8 5SY.

M & C Reservations Services Limited

MCRSL is a company registered in England with company registration number 06754684 and with its registered address at Corporate Headquarters, Scarsdale Place, Kensington, London, United Kingdom, W8 5SY.

Millennium & Copthorne International Limited

MCIL is a Singapore-registered company with registered number/UEN 199600354R and with its registered address at 9 Raffles Place, Republic Plaza, Singapore, 0486619.

Hotels

The Hotels and their operating and/or management companies are ultimately owned by M&C Limited. A list of the Hotels is available at https://www.millenniumhotels.com/en/hotels

Each of these entities may act as a controller and will be responsible for handling your personal data.

The controller of your personal data will be the MHR entity or entities with which you have an on-going relationship.

MCRSL is the primary operating entity and data controller responsible for handling your personal data in connection with the operation of the Site and the provision of reservation and marketing Services.

MCIL is a data controller responsible for handling your personal data in connection with the management of the My Millennium loyalty programme.

Each Hotel also may act as a data controller responsible for the provision of Services at the respective MHR Group hotel(s) owned and/or operated by it.

3 How to contact us?

General privacy matters

If you have any questions about this Privacy Notice or want to exercise your rights set out in this Privacy Notice, please contact us by sending an email to our Global Data Privacy Inbox at: [email protected] or by post at the following address:

M & C Reservations Services Limited (MCRSL),

Millennium Hotels and Resorts
Scarsdale Place
Kensington
London W8 5SY
United Kingdom

Contacting our Singapore entities

Alternatively, if you are located in Singapore or if you have any feedback or enquiries regarding the collection, use and/or disclosure of your personal data by Millennium & Copthorne International Limited or its related entities in Singapore including Grand Copthorne Waterfront Hotel, Copthorne King's Hotel, Orchard Hotel, M Hotel, Studio M Hotel and M Social Singapore, you can contact us by sending an email to: [email protected] or by post at the following address and addressing your correspondence to the attention of the Data Protection Officer:

Millennium & Copthorne International Limited

9 Raffles Place
Republic Plaza
Singapore 0486619

In all correspondence, please provide:

the name, contact number, email address (if any) and address of the person submitting the complaint, feedback or enquiry; and
the relevant details pertaining to such feedback or enquiry such as the relevant time period, our employees or personnel involved, or copies of such relevant documents, if applicable.

4 What personal data do we collect and how do we use it?

We (and our service providers) use your personal data for legitimate business interests including the following:

to provide our Services to you, including enabling you to make, and us to accept, reservations online for our Hotels worldwide and enjoy our Services;
to create and operate an account or membership of a loyalty programme or promotion;
to verify your identity;
to help us improve our Services, and develop and market new products and services;
to carry out any requests made by you on the Site;
to investigate or settle inquiries or disputes;
to comply with any applicable laws, court order, other judicial process, or the requirements of a regulator;
to enforce our agreements with you;
to protect any of our rights, property or safety or those of any third parties, including our other customers and users of the Site and visitors to our hotels;
to provide support for the provision of our Services; and
to use the information as otherwise required or permitted by law.

In particular, we use your personal data for the following purposes:

4.1 Fulfilment of Services

We collect and maintain personal data that you voluntarily submit to us during your use of the Site and/or through your purchase of our Services. We also may receive your personal data from third parties you have used to purchase our Services.

We use the contact and payment details you have provided to us or third parties so that we can fulfil the supply of Services you have purchased, including but not limited to:

Providing you with any information, products or services you request from us;
Processing reservations, where we will ask for your name, mailing address, billing address, email address, telephone number, credit card information, arrival and departure dates, and airline frequent flyer (or any other applicable customer loyalty) programme information. We may also ask you to provide identification, e.g. your passport and details of your vehicle registration; and/or
Processing your room preferences and any other special requests or needs.

4.1.1 With whom do we share your personal data for this purpose?

Your personal data will be shared within the MHR Group for the above purposes and with the following categories of third parties:

To verify card payments and process refunds – we may share your information with credit card companies and other payment providers.
To help us manage our customer relationships and fulfil our Services – we use a variety of third party vendors who provide us with systems and platforms to help us provide Services to you.
To manage aspects of our Site – we use a variety of third party suppliers to help us operate features on our Site or facilitate the delivery of any products and/or services purchased through our Site.

Please note this list is non-exhaustive and there may be circumstances where we need to share personal data with other third parties in order to provide the Services to you.

4.1.2 What is our lawful basis?

It may be necessary for us to use your personal data to perform our obligations in accordance with any contract that we or a third party may have with you.

4.2 Registration and management of your My Millennium loyalty programme account, your Millennium for Business programme account, and other accounts associated with our Site and/or Services.

We collect your name, title, gender, email address, date of birth, telephone number, and mailing address when you sign-up to our My Millennium loyalty programme. You can update your personal data by logging onto the My Millennium website (via https://www.millenniumhotels.com/en/my-millennium/sign-in/ using your email address and password) and clicking on "Update my Profile".

We use this information in order to create and manage your account and to understand our customer base. Please see the “Customer Insight and Analysis” section below for more details about the personal data collected and how it is used.

In addition, we offer the Millennium for Business programme (the details of which are available at: https://business.millenniumhotels.com/).

When you sign-up to the Millennium for Business programme, in addition to the above information, we may ask you to provide your company name We also may ask you for other information about your company.

Where you create an account on, and/or log into, our Site using a social media account (such as Facebook or Google), we may collect any information you make publicly available through the social media service. We may use this information in order to communicate with you about your account with us and to personalise your experience of the Site.

4.2.1 With whom do we share your personal data for this purpose?

Your personal data will be shared within the MHR Group for the above purpose and certain third parties, including vendors that provide our Customer Relationship Management system and other systems and platforms that help us manage your account.

4.2.2 What is our lawful basis?

It is in our legitimate business interests to use the information you or third parties provide to us for the programmes and/or purposes described above.

4.3 Events

As a part of our Services, we host events on behalf of third party entities and organisations. We collect and maintain personal data that you voluntarily submit to us or which we collect from the third party entity or organisation whose event we are hosting.

We collect this personal data so that you can participate in or attend such events. The personal data that we may collect includes your name, contact details, details of allergies or any special dietary or other requests which have been submitted by you or the third party entity or organisation on your behalf.

Where events are hosted on behalf of political or religious organisations or trade unions, we may, by collecting your name and recording your participation at the event, indirectly process personal data revealing political opinions, religious or philosophical beliefs, or trade union membership. You may also be subject to the privacy policy of the applicable third party when signing up to or attending an event.

4.3.1 With whom do we share your personal data for this purpose?

Your personal data will be shared within the MHR Group for the above purpose and we sometimes share your personal data with third party event planners who help us to manage events.

4.3.2 What is our lawful basis?

It is in our legitimate business interests to use the information you or third parties provide to us for events for the purposes described above.

Where we process ‘special categories of personal data’, including details of allergies or your association with political or religious organisations or trade unions, we rely on your explicit consent to process such special categories of personal data’, which we obtain from you directly or via the relevant third party entity or organisation.

4.4 Customer services

Our Site and our Hotels use various user interfaces to allow you to request information or provide general feedback about our Services: these include a telephone enquiry service, and printed and electronic enquiry forms, including the form available here: https://www.millenniumhotels.com/en/contact-us/enquiry-form/

Contact information may be requested in each case, together with details of other personal data that is relevant to your customer service enquiry. This information is used in order to enable us to respond to your requests and feedback.

4.4.1 With whom do we share your personal data for this purpose?

Your personal data will be shared within the MHR Group for the above purpose. We do not share your personal data with third parties for this purpose.

4.4.2 What is our lawful basis?

It is in our legitimate interest to use your personal data in such a way to ensure that we provide the very best customer service we can to you.

4.5 Your feedback about our Services

From time to time, we will use your name and contact details (in our legitimate interest) to invite you to provide feedback about our Services in the form of online or in-hotel surveys. Alternatively, you may voluntarily provide us with personal data when giving feedback regarding your stay at our hotels or experience with the Services we provide. We use this information to help us monitor and improve the quality of service provided by our staff and in our Hotels, and to assist us with the selection or development of future types of services. If you do not wish to partake in a survey, you may opt-out by emailing [email protected] or you can click on the “Unsubscribe” button in the survey email.

4.5.1 With whom do we share your personal data for these purposes?

Your personal data will be shared within the MHR Group for the above purpose and we use a third party service provider to assist us with customer surveys and feedback requests.

4.5.2 What is our lawful basis?

It is in our legitimate business interests to use the information you provide to us in your feedback for the purposes described above.

4.6 Customer insight and analysis

We analyse your contact details with other personal data that we observe about you from your interactions with our Site, our email communications to you and/or by providing Services to you, such as the products and services you have purchased or viewed.

Where you have given your consent (where lawfully required), we use cookies, log files and other technologies to collect personal data from the computer hardware and software you use to access the Site, or from your mobile device. This includes the following:

An IP address to monitor Site traffic and volume;
A session ID to track usage statistics on our Site;
Information regarding your personal or professional interests, demographics, buying habits, experiences with our products and contact preferences.

Our web pages and emails may contain “cookies”, "web beacons" or other, similar technologies. Tags allow us to track receipt of an email to you, to count users that have visited a web page or opened an email and collect other types of aggregate information. Once you click on an email that contains a Tag, your contact information may subsequently be cross-referenced to the source email and the relevant Tag.

In some of our email messages, we use a “click-through URL” linked to certain websites administered by us or on our behalf. We may track click-through data to assist in determining interest in particular topics and measure the effectiveness of these communications.

Please see our Cookie Notice for further information.

This information is used to create profiles and insights about your purchase habits and the purchase habits of our other customers. Where we have your consent to do so, we will also use your location data for customer insight purposes.

By using this information, we are able to measure the effectiveness of our content and how visitors use our Site and our Services. This allows us to learn what pages of our Site are most attractive to our guests, which parts of our Site are the most interesting and what kind of offers our registered users like to see. Your data may also be used to improve the efficiency of this site and may be anonymised for this purpose.

We also use this information:

To help us with the selection of future product and service lines, hotel and websites design and to remember your preferences; and/or
For marketing purposes (see the marketing section below for further details).

4.6.1 With whom do we share your personal data for these purposes?

We may share your personal data with a variety of third party service providers to assist us with customer insight analytics. These providers are described in our Cookie Notice.

4.7 What is our lawful basis?

Where your personal data is completely anonymised, we do not require a lawful basis to use it as the information will no longer constitute personal data that is regulated under data protection laws. However, our collection and use of such anonymised personal data may be subject to other laws where your consent is required. Please see our Cookie Notice for further details.

Where your personal data is not in an anonymous form, it is in our legitimate interest to use your personal data in such a way to ensure that we provide the very best products and services to you and our other customers, for example, by using surveys to help us to improve our services.

4.8 Marketing communications

We carry out the following marketing activities using your personal data:

4.8.1 Email marketing

We use information that we observe about you from your interactions with the Site, our email communications to you and/or by providing Services to you (see the Customer Insight and Analysis section above for further details of the information collected and how it is used) and/or your email address, to send you marketing communications by email, where you have consented to receive such marketing communications, or where we have another lawful basis to do so.

4.8.1.1 With whom do we share your personal data for these purposes?

Your personal data will be shared within the MHR Group for the above purpose and we share your personal data with a variety of third party email marketing providers who assist us in delivering our email marketing campaigns to you.

4.8.1.2 What is our lawful basis?

Where your personal data is completely anonymised, we do not require a lawful basis to use it as the personal data will no longer constitute personal data that is regulated under data protection laws. However, our collection and use of such anonymised personal data may be subject to other laws where your consent is required. Please see our Cookie Notice for further details.

Where your personal data is not in an anonymous form, it is in our legitimate interest to use your personal data for marketing purposes.

We will only send you marketing communications via electronic means where you have consented to receive such marketing communications, or where we have a lawful basis to do so.

4.8.2 Online personalised advertising

We use information that we observe about you from your interactions with our Site, our communications to you and/or by providing Services to you (see the Customer Insight and Analysis section above for more details of the information collected and how it is used) to provide you with personalised online advertising.

4.8.2.1 With whom do we share your personal data for these purposes?

Your personal data will be shared within the MHR Group for the above purpose and we will share your personal data with a variety of third party service providers who assist us with our online personalised advertising campaigns. These providers are described in our Cookie Notice.

4.8.2.2 What is our lawful basis?

Where your personal data is not in an anonymous form, it is in our legitimate interest to use your personal data for marketing purposes.

4.8.3 Social media remarketing

We use information that we observe about you from your interactions with our Site, our email communications to you and/or by providing Services to you (see the Customer Insight and Analysis section above for more details of the information collected and how it is used) to provide you with personalised advertising through various internet channels

We do this using custom audiences, customer match and/or similar services. Please note that such activity is also subject to the privacy choices you have elected on such services.

4.8.3.1 With whom do we share your personal data for these purposes?

Your personal data will be shared within the MHR Group for the above purpose and with the following categories of third parties:

We share your email address with third party service providers who assist us with social media remarketing campaigns.

An unreadable version of your email address is also shared by us or our third party service providers with Facebook and/or Google under the terms of their respective custom audiences, customer match and/or similar services. To ensure that your email address is fully protected, we use Secure Hash Algorithm 256-bit (SHA-256) for cryptographic security. Cryptographic hashing using SHA 256 produce is an irreversible process.

4.8.3.2 What is our lawful basis?

Where your personal data is not in an anonymous form, it is in our legitimate interest to use your personal data for marketing purposes.

4.8.4 Social media insight

Where you are a registered user of Facebook, have an account with Google or are a user of similar social media platforms service, we will use your email address in an encrypted format to enable them to find other registered users of their services that share similar interests to you based on:

Information that we observe about you from your interactions with our Site, our email communications to you and/or with our products and services in our hotels (see the Customer Insight and Analysis section above for more details of the information collected and how it is used); and
The information Facebook and/or Google hold about you.

We do this using lookalike audiences, similar audiences and/or related services. Please note that such activity is subject to the privacy choices you have elected to make on such services.

4.8.4.1 With whom do we share your personal data for these purposes?

Your personal data will be shared within the MHR Group for the above purpose and with the following categories of third parties:

To administer marketing campaigns – we share your email address with third party service providers who assist us with social media remarketing
To utilise social media platforms – your encrypted email address is also shared by us or our third party marketing consultancies with Facebook and/or Google under the terms of their respective services, such as lookalike audiences and/or similar audience services.

4.8.4.2 What is our lawful basis?

Where your personal data is not in an anonymous form, it is in our legitimate interest to use your personal data for marketing purposes.

4.8.5 Prize draws, prize competitions and other promotions.

From time to time, we may run prize draws, prize competitions and other promotions on our Site, through our social media accounts and/or in our Hotels. For the purposes of administering such promotions, we may process your name, contact details (including email address, postal address and/or telephone number), social media handle (if relevant) and any other personal data volunteered by you in your promotion entry.

4.8.5.1 With whom do we share your personal data for this purpose?

Your personal data will be shared within the MHR Group for the above purpose and we may share your personal data collected in connection with any prize draws, prize competitions and other promotions that we run with third party providers that assist us with the administration of such promotions from time to time.

4.8.5.2 What is our lawful basis?

It is necessary for us to use your personal data to perform our obligations in accordance with any contract that we may have with you (e.g., the terms and conditions applicable to the promotion) or it is in our legitimate interest to use your personal data to enable you to participate in any surveys, prize draws, prize competitions and other promotions.

4.8.6 Careers

We may collect personal data in order to consider and process any enquiries or applications regarding our employment opportunities.

We collect and maintain personal data that you voluntarily submit to us or which we collect from third party recruitment agencies for this purpose. The information that we collect may include your name, contact details, education details, and any other information that you include on your CV, résumé and any cover letter.

You can apply for vacancies here: https://www.millenniumhotels.com/en/careers/. Where you apply for a vacancy using LinkedIn, we may collect any information you make publicly available through LinkedIn. We also may use this information in order to communicate with you about your application.

4.8.6.1 With whom do we share your personal data for this purpose?

We may share your personal data with third party service providers who assist us to match applicants with job vacancies.

4.8.6.2 What is our lawful basis?

It is in our legitimate business interests to use the information you provide to us when you apply for a job vacancy for the purposes described above.

4.8.7 Business administration and legal compliance.

We use your personal data for the following business administration and legal compliance purposes:

To comply with our legal obligations;
To enforce our legal rights;
To protect rights of third parties; and
In connection with a business transition, such as a merger, acquisition by another company, or sale of all or a portion of our assets.

4.8.8 With whom do we share your personal data for these purposes?

Your personal data will be shared within the MHR Group for the above purpose and we will share your personal data with third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Notice.

We will share your personal data with professional advisers such as lawyers and accountants, our insurers and/or governmental or regulatory authorities.

4.8.8.1 What is our lawful basis?

Where we use your personal data in connection with a business transition, enforcing our legal rights, or to protect the rights of third parties, it is in our legitimate interest to do so. For all other purposes described in this section, it is our legal obligation to use your personal data to comply with any legal obligations imposed upon us, such as a court order.

4.9. Collection of Personal Data by other Data Controllers

Some hotels in the MRH Group are managed by third parties who may collect personal data from you prior to or during your visit. In these cases, the third party is the Data Controller of any such personal data and a separate privacy notice will be available from them which relates to this data collection.

5 Where we share your sensitive (special categories of) personal data, we shall obtain your consent to do so.

Any other purposes for which we wish to use your personal data that are not listed above, or any other changes we propose to make to the existing purposes will be notified to you using your contact details.

6 How do we obtain your consent?

Where our use of your personal data requires your consent, you can provide such consent:

At the time we collect your personal data following the instructions provided; or
By informing us by email or post using the contact details set out in this Privacy

7 Our use of cookies and similar technologies

Our Site uses certain cookies, pixels, beacons, log files and other technologies of which you should be aware. Please see our Cookie Notice to find out more about the cookies we use and how to manage and delete cookies.

8 Third party links and services

Our Site contains links to third party websites and services. Please remember that when you use a link to go from the Site to another website or you request a service from a third party, this Privacy Notice no longer applies.

Your browsing and interaction on any other websites, or your dealings with any other third party service provider, are subject to that website’s or third party service provider’s own rules and policies.

We do not monitor, control, or endorse the privacy practices of any third parties.

We encourage you to become familiar with the privacy practices of every website you visit or third party service provider with which you interact and to contact them if you have any questions about their respective privacy policies and practices.

This Privacy Notice applies solely to personal data collected by us through our Services and does not apply to these third party websites and third party service providers.

9 PayPal transactions

All PayPal transactions made through our Site are subject to the PayPal Privacy Notice located at www.paypal.com.

10 Disclosures of personal data

Disclosure to Internal Third Parties

We may share your personal data within the MHR Group and some entities within the MHR Group may provide services as processors to the controllers who are responsible for handling your personal data.

Disclosure to External Third Parties

We set out in Section 4 the purposes for which we may have to share your personal data with third parties, and the types of third parties with whom we share your personal data. In addition, we generally share personal data with third parties as follows:

Service providers acting as processors who provide IT and system administration services.
Professional advisers acting as processors or joint controllers, including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
Regulators and other authorities, including tax authorities, acting as processors or joint controllers who require reporting of processing activities in certain circumstances.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We only permit our third-party service providers to process your personal data for specified purposes and in accordance with our instructions, or otherwise as required for their own regulatory compliance.

11 Overseas transfers of personal data

Due to the global nature of our business and that of our third party suppliers who process your personal data on our behalf, personal data we collect from you may be transferred, processed and stored overseas including (where applicable) outside the jurisdiction where the personal data is collected.

Although the data protection laws of these other countries may not be as comprehensive as those in your own, we will take all necessary steps to ensure that your personal data is treated securely, and in accordance with this Privacy Notice and any applicable laws.

In particular, where your personal data is transferred from one jurisdiction such as the UK, the EEA or Singapore to a jurisdiction outside of it, we will comply with our legal and regulatory obligations (and will ensure that our third party suppliers comply with their obligations) in relation to the personal data, including having a lawful basis for transferring personal data and putting appropriate and lawful measures in place to ensure an adequate level of protection for the personal data.

In respect of our third party suppliers and of transfers within the MHR Group, the use of personal data transferred outside the UK or the EEA shall (where applicable) be governed by contracts incorporating EU approved model clauses, an International Data Transfer Agreement as defined by the ICO or the transfer shall be subject to another lawful transfer mechanism.

12 How long do we keep your personal data for?

We hold your personal data in accordance with our data retention policies. Generally, we do not keep personal data for longer than is necessary for the purposes for which it was collected.

If any personal data is only useful for a short period (e.g. for a specific marketing campaign), we may delete it at the end of that period.

If you have opted out of receiving marketing communications from us, we will need to retain certain personal data so we do not send you marketing communications again.

13 Confidentiality and security of your personal data

We are committed to keeping the personal data you provide to us secure and we will take reasonable precautions to protect your personal data from loss, misuse or alteration.

We have implemented information security policies, rules and technical measures to protect the personal data that we have under our control from:

Unauthorised access;
Improper use or disclosure;
Unauthorised modification; and
Unlawful destruction or accidental loss.

All of our employees and data processors (i.e., those who process your personal data on our behalf, for the purposes listed above), who have access to, and are associated with the processing of personal data, are obliged to respect the confidentiality of the personal data of all users of our Services.

14 How to access your information and your other rights?

The UK GDPR and EU GDPR afford you the following rights in relation to the personal data we hold about you:

14.1 Your right of access.

If you ask us, we will confirm whether we are processing your personal data and, if so, provide you with a copy of that personal data (along with certain other details). If you require additional copies, we may charge a reasonable fee.

14.2 Your right to rectification.

If the personal data we hold about you is inaccurate or incomplete, you are entitled to have it rectified. If we have shared your personal data with others, we will let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we will also tell you with whom we have shared your personal data so that you can contact them directly.

14.3 Your right to request erasure.

You can ask us to delete or remove your personal data in some circumstances, such as where we no longer need it, if you withdraw your consent (where applicable), or where you close your My Millennium loyalty programme account. However, note that we may retain some of your personal data for a reasonable period of time, even after you withdraw a consent or close your My Millennium loyalty programme account, for legal or compliance purposes. If we have shared your personal data with others, we will let them know about the erasure where possible. If you ask us, where it is possible and lawful for us to do so, we will also tell you with whom we have shared your personal data so that you can contact them directly.

14.4 Your right to restrict processing.

You can ask us to ‘block’ or suppress the processing of your personal data in certain circumstances, such as where you contest the accuracy of that personal data or you object to us processing it. It would not stop us from storing your personal data, though. We will tell you before we lift any restriction. If we have shared your personal data with others, we will let them know about the restriction where it is possible for us to do so. If you ask us, where it is possible and lawful for us to do so, we will also tell you with whom we have shared your personal data so that you can contact them directly.

14.5 Your right to data portability.

You have the right, in certain circumstances, to obtain personal data you have provided to us (in a structured, commonly used and machine readable format) and to reuse it elsewhere or to ask us to transfer this to a third party of your choice.

14.6 Your right to object.

You can ask us to stop processing your personal data, and we will do so, if we are:

Relying on our own or someone else’s legitimate interests to process your Personal data, except if we can demonstrate compelling legal grounds for the processing; or
Processing your personal data for direct marketing.

14.7 Your rights in relation to automated decision-making and profiling.

You have the right not to be subject to a decision when it is based on automatic processing, including profiling, if it produces a legal effect or similarly significantly affects you. However, we may conduct automated decision-making and/or profiling where it is necessary for entering into, or the performance of, a contract between you and us.

Examples of automated decision-making and/or profiling include if we use software to automatically scan employment applications and match candidates to job vacancies, or if we were to utilise an aptitude test with algorithms or automated criteria for decision-making in our recruitment process.

14.8 Your right to withdraw consent.

If we rely on your consent (or explicit consent) as our lawful basis for processing your personal data, you have the right to withdraw that consent at any time.

14.9 Your right to lodge a complaint with the supervisory authority.

If you have a concern about any aspect of our privacy practices, including the way we have handled your personal data, you can report it to the UK Information Commissioner’s Office (ICO) or other Supervisory Authority. You can find details about how to do this on the ICO website at https://ico.org.uk/concerns/ or by calling their helpline on 0303 123 1113.

15 Changes to this Privacy Notice

We may make changes to this Privacy Notice from time to time.

To ensure that you are always aware of how we use your personal data, we will update this Privacy Notice from time to time to reflect any changes to our use of your personal data or our business practices. We may also make changes as required to comply with changes in applicable law or regulatory requirements. We will notify you by email of any significant changes. However, we encourage you to review this Privacy Notice periodically to be informed of how we use your personal data.

Should you have any questions regarding this Privacy Notice, data protection issues relating to this website or to the services we provide, please send your questions to [email protected].

This Privacy Notice became effective as of December 2023.