Privacy Policy

Privacy Policy

At the Pendulum Hotel & Manchester Conference Centre we are committed to protecting and respecting your privacy.

Please read this Privacy Notice, together with any other privacy notice that we may provide to you, as it contains important information about how we collect, manage, use and protect your personal data. This Privacy Notice may also be used in conjunction with other privacy notices that we may provide you with in certain situations.

We may change this Privacy Notice from time to time. Please check this policy frequently to ensure you are aware of the most recent version and the date that it was last updated.

This policy was last updated in May 2018.

If you have any questions regarding this policy or about our privacy practices, please contact us on the below details:

  • Email: dpo@iqstudent.com
  • Post: Compliance Director, IQSA Services Limited, 7th Floor East, Cottons Centre, Hays Lane, London SE1 2QG

Who are we?

When we say ‘Pendulum Hotel or Manchester Conference Centre’, ‘we’ or ‘us’ in this policy, we are referring to IQSA (Hermes) Ltd which is a company registered in England Company Number 10037473 with its registered office at 7th Floor, Cottons Centre, Cottons Lane, London, SE1 2QG.

The IQSA Group is made up different legal entities, details of which can be found here. This list may be updated from time to time.

When we say ‘IQSA’, ‘we’ or ‘us’ in this Privacy Notice, we are referring to the relevant company in the IQSA Group responsible for processing your personal data. This will be your landlord or the company you are visiting, contracting with or applying to and includes Pendulum Hotel and Manchester Conference Centre.

IQSA is a “data controller” for the IQSA Group of the personal data that you provide to us. This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice.

IQSA Services Limited is the company that manages the properties owned by the IQSA Group. In this role, IQSA Services Limited will process your personal data on behalf of the relevant company within the IQSA Group and also as a data controller for the purposes of managing the IQSA Group’s properties. IQSA Services Limited processes your personal data in accordance with this Privacy Notice. Therefore, when we say ‘we’ or ‘us’ in this Privacy Notice, we are also referring to IQSA Services Limited.

IQSA Services Limited is a company registered in England (Company Number: 09857188) with its registered office at 7th Floor East, Cottons Centre, Hays Lane, London, SE1 2QG.

What information do we collect?

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

We collect information on guests, customers, enquirers, employment candidates, visitors to our website or premises and suppliers

We have grouped together the types of information that we may collect from you as follows:

  • Identity Data including name, gender, date of birth (and any other special dates that you have provided to us), marital status, family members, emergency contact information, driving license, passport information, employer details and job title (for example, if you are a corporate customer), CCTV footage and other information obtained through electronic means such as swipecard records or our telephone call recording systems or other information about your use of our premises, including restaurant and event bookings;
  • Contact Data including home address, billing address, business address, email address, phone numbers, geo-location;
  • Financial Data including bank account and payment card details;
  • Transaction Data including details about payments to and from you, reservation and booking details and your purchase history;
  • Technical Data including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and device;
  • Usage Data including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time), page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call us;
  • Communications Data including your preferences in receiving communications from us;
  • Marketing and Communications Data including your preferences in receiving communications from us and third parties.

Special Categories of Personal Data

We may also collect, store and use information about your health, including any medical conditions or disabilities and your religion, for example, if this is relevant to your dietary requirements.

How do we collect your information?

  • Information you give us. You may give us such information directly by booking with us, completing forms, corresponding or speaking with us by phone, email, letter or otherwise, submitting a query, providing us with feedback, visiting our website, requesting that we provide you with services / communications, or when we appoint you as a service provider.
  • Information we collect about you.
    When you visit our website, and receive emails from us we may automatically collect technical information about your equipment, browsing actions and patterns. We collect this by using cookies.
    Information obtained through CCTV footage and other information obtained through electronic means such as swipecard records when you access our premises, our telephone recording system, or other information about your use of our premises.
  • Information provided by cookies.
    Cookies are used to improve your experience while visiting our website. Where applicable this website uses a cookie control system allowing you on your first visit to the website to allow or disallow the use of cookies on your computer/device. This complies with legislation requirements for websites to obtain explicit consent from you before leaving behind or reading files such as cookies on your computer/device.
  • Cookies are small files saved to the user’s hard drive that track, save and store information about the user’s interactions and usage of the website. This allows our website, through its server, to provide users with a tailored experience.
  • If you wish to prevent the use and saving of cookies from this website on to your computer’s hard drive you should take necessary steps within web browser’s security settings to block all cookies from our website.
  • Our website uses tracking software to monitor its visitors to better understand how you use it. The software will save a cookie to the user’s hard drive in order to track and monitor engagement and usage of the Website, but will not store, save or collect personal information.
  • Other cookies may be stored on your hard drive by external vendors when our website uses referral programs, sponsored links or adverts. Such cookies are used for conversion and referral tracking and typically expire after 30 days, though some may take longer.
  • If you would like further information about cookies and how they are used, you can visit http://www.allaboutcookies.org/.
  • When we e-mail you, such e-mails may contain tracking facilities. Activity is tracked and stored in a database for future analysis and evaluation. Such tracked activity may include but is not restricted to: the opening of emails, geo-location, forwarding of emails, the clicking of links within the email content, times, dates and frequency of activity.
  • Information we receive about you from other sources.
    We may obtain information about you where someone books on your behalf as we will usually ask for the title, name and e-mail address of a person from each room that you book for identification purposes. We may also obtain information about you if you are attending an event that is being held on our premises.
  • We may obtain information about you where you have booked our hotel through a travel agency or through any other third party.
  • We may receive information if you have provided permission to referees or other organisations to share it with us. Before providing permission to such third party organisations to share your personal data, you should check their privacy notices carefully.
  • We also work with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, and, if you are a supplier, credit reference agencies) and may receive information about you from them.
  • We may receive information about you if you use any of the other websites we operate or the other services that we provide. In this case we will have informed you when we collected that data that it may be shared internally and combined with data collected on this site.
  • We may occasionally purchase the contact details of people who might be interested in hearing from us. Before purchasing such information, we will check with the vendor that your information was originally collected in a compliant manner, to make sure that we only contact people who have actively expressed an interest in receiving information from third parties.
  • We may receive information about you if you apply for a vacancy with us.

How we might use your information?

We use information held about you in the following ways:

  • To process your booking with us for any room, restaurant reservations or other events
  • To manage and administer our relationship with you including any bookings you make with us or by issuing communications and information to you
  • To carry out our obligations arising from any contracts entered into between you and us
  • To respond to your requests
  • To provide you with information about our activities
  • To improve our level of service
  • To notify you about changes to our service and notify you of new products and services
  • To seek your views on our products and services
  • To recover any unpaid sums due to us
  • If you are a guarantor, to administer your guarantee
  • To consider your application for employment
  • For administrative and quality assurance purposes
  • For the purposes of the establishment, exercise or defence of legal claims
  • To prevent and detect criminal activity, fraud and misuse of or damage to our property
  • To administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes
  • To provide and improve our site to ensure that content is presented in the most effective manner for you and for your computer
  • To allow you to participate in interactive features of our service, when you choose to do so as part of our efforts to keep our site safe and secure
  • Information we receive from other sources. We may combine this information with information you give to us and information we collect about you. We may use this information and the combined information for the purposes set out above (depending on the types of information we receive). For example, we may use your email address assigned to a Facebook account to profile you and target our Facebook advertising to similar audiences (look-alike audiences).

Communications with you

We may occasionally, with your consent, call you to provide you with information about our activities or provide you with information about products and services supplied by us. You may unsubscribe to calls by instructing the person calling you or by contacting us at any time on the details set out in the ‘Contact Us’ section of this notice.

We may also communicate with your through postal marketing when it is in our legitimate interests to do this and when these interests do not override your rights. Those legitimate interests include providing you with information on our services, products, newsletter requests, feedback, competitions and other activities. You have the right to contact us at any time and opt-out of receiving postal communications.

What is our legal basis for using your information?

There are a number of lawful reasons for us to process your personal data.

Where we are providing you with conferences, meetings, social events and accommodation or any other services we will primarily process your personal data in order to fulfil our contract with you.

Other legal bases that we will rely on include the following:

  • Where we are required to comply with our legal obligations, or to establish and defend our legal rights, or to prevent and detect crimes such as fraud or misuse of or damage to our property.
  • If we are providing you with email based promotional communications, we may rely on your consent to do so. If you have given us your consent, you can withdraw your consent at any time by clicking the ‘unsubscribe’ button at the bottom of the email. Please note that in order to fulfil your request we will have to retain your e-mail address to ensure that you do not receive any further promotional communications.
  • Where it is in our legitimate interests to do so. This means that we can process your personal data if (i) we have a genuine and legitimate reason; and (ii) are not harming any of your rights and interests. Whenever we process your personal data for our legitimate interests, we will consider and balance any potential impact on you and your rights under data protection law.
  • We will use your personal data in order to help us to provide you with the services that you have requested (for example by providing you with information about your booking), for our internal administration and to provide you with the best experience when dealing with us.

Where we use special categories of personal data, for example, information about your health or religion, we may ask for your consent to such use. However, sometimes, there may be reasons of public interest or law that enable us to use this information without consent, for example, if it is in your vital interests or is necessary in the establishment, exercise or defence of any legal claims.

Sometimes your personal data may be used for statistical research but only in a form that no longer identifies you.

How long will we hold your information for?

We will hold your personal data on our systems for as long as is necessary to fulfil the purposes that we collected it for, including for the purposes of satisfying any legal, accounting or other reporting requirements.

By law, we are required to retain certain information for a prescribed period of time. In circumstances where there are no such legal requirements, to determine the appropriate retention period, we will consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we are processing your personal data and whether we can achieve those purposes through other means.

Therefore, some information may be kept for more or less time depending on how long we reasonably feel it is required for.

We review our retention periods for personal data on a regular basis.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

If you ask us to delete your information in accordance with your rights set out below, we will retain basic information on a suppression list to record your request and to avoid sending you unwanted materials in the future.

Who we might share your information with

We will NOT sell your personal data to any third parties.

We may share your personal information with any member of our group.

We may share your information with selected third parties including:

  • Business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you e.g. our IT providers or our auditors or other professional advisors.
  • Analytics and search engine providers that assist us in the improvement and optimisation of our site – Google
  • Social media platforms for generating look-alike audiences for marketing – Facebook.
  • Automated marketing providers
  • Live chat service provider – Click Desk
  • Our employee training & development service providers.
  • If we run an event in partnership with other named organisations your details may need to be shared. We will be very clear what will happen to your data when you register.
  • If we merge with another organisation or form a new entity, your personal data may be transferred to that new entity.

We may disclose your personal information to third parties to:

  • Comply with any court order or other legal obligation or when data is requested by our regulators or by government agencies or law enforcement agencies;
  • Enforce or apply our terms of use and any other agreements;
  • Protect the rights, property, or safety of us, our employees, our customers, or others. This may include exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

International transfers of personal data

From time to time, we may transfer your personal information outside of the EU to service providers, subcontractors and regulatory authorities for the purposes described in this Privacy Notice. If we do this, your personal information will continue to be subject to one or more appropriate safeguards set out in the law, for example we may use the model contracts in a form approved by regulators, or ensure that your personal data is protected through supplier binding corporate rules. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with a room). In this case, we may have to cancel your booking but we will notify you if this is the case at the time.

Your rights

You have a number of rights. If you would like to exercise any of these rights, please contact us using the details set out below in the ‘Contact Us’ section. If you exercise any of these rights we may ask for proof of identity and sufficient information about your interactions with us so that we can locate your personal information. If we agree that we are obliged to provide personal information to you (or someone else on your behalf), we will provide it to you or them free of charge except in exceptional circumstances.

If you wish to raise a complaint in relation to our processing of your personal data, you can contact us at stay@pendulumhotel.co.uk or in writing at Pendulum Hotel, Sackville Street, Manchester, M1 3BB marking your query for the attention of The Deputy General Manger you also have the right to lodge a complaint with the data protection regulator, the Information Commissioner’s Office, if you have concerns about how we use your personal information. You can contact the Information Commissioner’s Office at: https://ico.org.uk/global/contact-us/.

Your rights include:

  • transparency over how we use you data and to make a subject access request (right of access);
  • a right to have your personal data updated and corrected (right of correction/rectification) ;
  • a right to ask us to delete your information (right to be forgotten);
  • a right to ask us to stop processing your information (right to restriction);
  • a right to object to (i) processing based on our legitimate interests; (ii) processing of your information for direct marketing purposes; and (iii) automated decision making and profiling (right to object);
  • a right to receive a copy of your information, or have this sent to a third party (right to data portability); and
  • a right to claim compensation for material or non-material damage caused if we breach the data protection rules (right to compensation).

If you would like to find out more about your rights, you can visit the Information Commissioner’s Office website (https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr).

How you can access and update your information

We strive to maintain accurate, complete, and relevant personal information for the purposes identified in this privacy statement. If any of the personal information we hold about you is inaccurate or out of date, you may ask us to correct it. It is important that the personal information we hold about you is accurate and current.

Security precautions in place to protect against the loss, misuse or alteration of your information

We have implemented reasonable measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration and disclosure. Details of these measures can be obtained on request.

Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.

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.

Our security measures are regularly reviewed.

Contact Us

If you have any questions regarding this policy or about our privacy practices, wish to exercise any of your rights or wish to make a complaint, please contact our Data Protection Officer at:

  • Email: dpo@iqstudent.com
  • Post: Compliance Director, IQSA Services Limited, 7th Floor East, Cottons Centre, Hays Lane, London SE1 2QG 

Group Company List for Privacy Notice

Release Date May 2018
Author Compliance Director
Owner Compliance Director
New or updated policy New Document
Document Version 1.00
Next Scheduled Review April 2019

 

Group Company List for Privacy Notice

Introduction

The following is a list of companies that fall under the IQSA Privacy Notice as Data Processors. IQSA Services Limited is also the Data Controller

IQSA Holdings S.a.r.l.

IQSA Group Limited

IQSA Services Limited

IQSA (Hermes) Limited

IQSA (Athena) Limited

IQSA (Huddersfield) Limited

IQSA (Oxford) Limited

IQSA (Brighton) Limited

IQSA (Westbourne) Limited

IQSA (Wembley Court) GP1 Limited

IQSA (GP1) Limited

IQSA (GP2) Limited

IQSA (Wembley Court) LP

IQSA (Bloomsbury) LP

IQ Shoreditch Letting Property Limited Partnership

IQ Two Letting Property Limited Partnership

IQ Letting Property Partnership

MP Newlands Ltd

MP Newtown Ltd

IQSA (Collingwood) Limited

IQSA (Glasgow) Limited

Pure Student Living Limited

Twerton Bath Limited

Elliot Edinburgh Limited

Redress York Limited

Lewes Brighton Limited

Arcade Holloway Limited

Pure Highbury Limited

Pure Hammersmith Limited

Pure City OpCo Limited

Pure Bankside Limited

UKSA 60 CR Limited

LTS Paris Gardens Limited Partnership

IQSA General Operating Company Limited

Opal Villas Limited